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Albright Capital Management

PRI reporting framework 2018

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

01.3. Indicate if the investment policy covers any of the following

Starting in 2017, we have incorporated an annual review of the UN Sustainable Development Goals for all portfolio companies in which we have an ongoing, active role (i.e., certain legacy assets have been excluded from this review because of lack of ongoing governance rights or nearly complete exit of the original investment).  This will be applied to all new investments, as well.  We have retained an outside specialist to conduct this annual assesment, and the results are shared with our investors.   

01.4. Describe your organisation’s investment principles and overall investment strategy, and how they consider ESG factors and real economy impact.

ACM believes that, in EM private investments, fulfillment of fiduciary duty and generation of attractive risk-adjusted returns can only be achieved through integration of ESG risk and opportunity variables.  ESG factors have a material impact on financial results.  In ACM’s case, among other processes, Secretary Albright aligns her reputation with Limited Partners in the Fund through her right to veto any proposed Special Situation investment on political risk, ethical or reputational grounds.  ACM’s priority is fulfillment of fiduciary duty.  ACM believes that principled and pragmatic integration of ESG considerations into an EM investment process is essential to accomplish that goal by mitigating political and other risks associated with an investment.  ACM also knows that difficulties, and criticism, are part of working in emerging markets.  The bedrock of our approach is to seek investments that have sustainable, positive economic benefits for all stakeholders.  For all investments, ACM looks to identify potential adverse impacts. With certain exceptions, ACM avoids a prescriptive approach, opting instead to apply its ESG guidelines in a principled and pragmatic fashion, based on all facts and circumstances, while recognizing that some risks and adverse impacts cannot be mitigated or justified and must be avoided. 

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


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

02.2. Indicate if any of your investment policy components are publicly available. Provide URL and an attachment of the document.

URL/Attachment

02.3. Indicate if your organisation’s investment principles, and overall investment strategy is publicly available

02.4. Additional information [Optional].


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.

As a registered investment adviser, ACM has adopted a Conflicts of Interest Policy that sets forth policies and procedures to implement ACM’s legal and ethical requirements as a fiduciary for its investment advisory clients. ACM's policy identifies various circumstances that could potentially be deemed a conflict of interest, and provides for associated procedures intended to address the conflict of interest in a manner that is fair and equitable for ACM and its clients while ensuring that clients are not disadvantaged relative to ACM, including the disclosure of the same to its clients.  Most of these are disclosed and agreed with investors in ACM's funds at the time of investment, with the balance to be disclosed and resolved with the Advisory Committee of investors in the fund if they arise.  In addition, ACM's Policy covers the following specific matters:  (1) placement agency costs, if any; (2) size of capital raise; (3) transaction fee offsets;  (4) resolution of conflicts arising from conflicting mandates; (5) investment allocations; (6) follow-on rounds; (7) co-investments; (8) fees derived by affliated parties; (8) shareholder-directorship appointments to portfolio companies (conflict in fiduciary duties); and (9) divestment timing of assets held by multiple funds of different vintages.  

 

03.3. Additional information. [Optional]

We would be happy to submit the Conflicts of Interest of Policy, which is too large to be included in these responses.


SG 04. Identifying incidents occurring within portfolios (Private)


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