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Janus Capital Management LLC (Delisted)

PRI reporting framework 2017

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage (Not Completed)

SG 02. Publicly available RI policy or guidance documents (Not Completed)

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.

Our Conflicts of Interest (COI) policy document is fourteen pages; however, the most applicable portions are included below:

Broadly defined, a “conflict of interest” exists when two or more activities or relationships are incompatible to some extent. A conflict situation can arise when employees take actions or have interests that may make it difficult to perform their Janus work objectively or effectively. In general, Janus employees are advised to avoid any direct or indirect business connection with Janus’ customers, clients, suppliers and competitors, except on behalf of Janus.

Our COI policy addresses these, among other issues:

-  Control and Mitigation

-  Identification and Monitoring

-  Education and Training of Employees

-  Employee Guiding Principles - Conflicts of Interest


Potential conflicts of interest that require disclosure include, but are not limited, to the following:

-  Outside Employment or Material Business Relationships

-  Outside Directorship

-  Self-Dealing

-  Gifts and Entertainment

-  Personal Trading

-  Political Activity

-  Purchasing and Service Provider Selection

-  Family or other personal relationships, which might dissuade an employee from acting in the best interests of Janus and the Janus shareholders.

-  Any other arrangement or circumstance.

03.3. Additional information. [Optional]

SG 04. Identifying incidents occurring within portfolios (Private)