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Horizon Capital LLP

PRI reporting framework 2019

You are in Strategy and Governance » Investment policy

Investment policy

SG 01. RI policy and coverage (Private)

SG 01 CC. Climate risk (Not Applicable)

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.



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


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02.3. 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.

It is our policy to identify the conflicts of interest that may exist between a) ourselves or anyone linked to the Firm and our clients or b) one client and another. We must ensure that clients are not adversely affected by potential risks. Therefore we document the arrangements we have put in place to manage the conflicts identified which create a material potential risk of damage to the interests of one or more clients. We take all reasonable steps to prevent conflicts of interest from constituting or giving rise to a material risk of damage to the interests of our clients. Where the potential risk can not be effectively managed with reasonable confidence to prevent the risk, we disclose this to our client before providing services. We make disclosure in a durable medium; providing sufficient detail to enable that client to take an informed decision with respect to the service in the context of which the conflict of interest arises.

03.3. Additional information. [Optional]

The arrangements to manage potential conflicts of interest include:
• Segregation of functions;
• Independent supervision;
• Removal of direct remuneration incentives;
• Avoiding inappropriate influence being brought to bear in the way clients are treated;
• Operation of dual controls; and
• Policies in relation to members’ and employees’ personal interests in investments i.e. PA Dealing Rules.
Where our arrangement to manage conflicts of interest are not adequate we disclose the conflict of interests to our clients (via the Investor Advisory Committee) or potential clients.

SG 04. Identifying incidents occurring within portfolios (Private)