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ADM Capital

PRI reporting framework 2017

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage

New selection options have been added to this indicator. Please review your prefilled responses carefully.

01.1. Indicate if you have an investment policy that covers your responsible investment approach.

01.2. Indicate the components/types and coverage of your policy.

Select all that apply

Policy components/types

Coverage by AUM

01.4. Indicate what norms you have used to develop your investment policy that covers your responsible investment approach.

other (1) description

          EBRD’s “Integrity Due Diligence and Monitoring Guidelines for Private Equity Operations”
        

other (2) description

          International Finance Corporation’s policies on Corrupt Practices, Fraudulent Practices, Coercive Practices, Collusive Practices and Obstructive Practices
        

other (3) description

          HK Prevention of Bribery Ordinance (Cap. 201) (the “POBO”); HK Anti-Money Laundering and Counter-Terrorist Financing (Financial Institution) Ordinance (2012) O”); HK AML Guidelines
        

01.6. Provide a brief description of the key elements, any variations or exceptions to your investment policy that covers your responsible investment approach. [Optional]

See above


SG 02. Publicly available RI policy or guidance documents

New selection options have been added to this indicator. Please review your prefilled responses carefully.

02.1. Indicate which of your investment policy documents (if any) are publicly available. Provide a URL and an attachment of the document.

URL/Attachment

02.4. Additional information [Optional].

Attached is a sample document setting out of ESG policy approach for a recently launched PE style fund in our strategy.


SG 03. Conflicts of interest

03.1. Indicate if your organisation has a policy on managing potential conflicts of interest in the investment process.

03.2. Describe your policy on managing potential conflicts of interest in the investment process.

Identifying Conflicts: reasonable steps to identify conflicts of interest between: (a) the firm (including its  employees or any other person directly or indirectly linked to it), and clients of the firm; or (b) one client and another client; that arise in the course of the firm providing any services in the course of carrying on our business.

Conflict may arise where there may be a material risk of damage to the interests of a client, and in such situtation the Firm must take into account, whether the Firm or a relevant person, or a person directly or indirectly linked by control to the Firm: (a) makes a financial gain, or avoids loss, at the expense of  client; (b) has interest in the outcome of a service; (c) has anincentive to favour the interest of a client   over the interests another client; (d) carries on the same business as the client; or (e) receivesan inducement in relation to a service provided to the client.Segregation of functions:   Senior management of the Firm segregate duties so as to avoid conflicts of interest.

Disclosure of conflicts to clients/investors: The Firm refers conflictsto the relevant governing body (eg. Advisory Board) of the fund.

03.3. Additional information. [Optional]


SG 04. Identifying incidents occurring within portfolios (Private)


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