ACSRF has a formal Conflicts Policy in accordance with government regulations. The conlicts policy covers circumstances where one or all of the interests of members are inconsistent with, or diverge from, some or all of the interests of the Trustee or its representatives. In relation to investments in particular, any member of the Investment Committee who has an actual or potential conflict of interest in relation to any item on the agenda must declare that conflict at the start of the meeting. The Committee member must disclose all relevant information about the conflict in such manner and form as determined by the other Committee members.
Where a conflict of interest is declared, the Committee must assess the conflict to determine its materiality and significance to any relevant agenda item and decide what action should be taken i.e. abstention from the relevant part of the meeting, abstention from voting or no action. The details of any declared conflicts and the Committee’s decision must be recorded in the minutes and in the conflicts register. The fund maintains a register of duties, financial interests and conflicts. Directors are required to delcare any conflict of interests at every Trustee meeting.
The Trustee and Investment Committee (IC) have an Investment Governance Framework which provides guidelines to manage investments to protect the interests, and meet the reasonable expectations, of beneficiaries. It sets out the selection and monitoring process for investment managers. Monitoring is done on a quantitative and qualitative basis. The IC meets regularly with managers to discuss any issues.