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Alder Capital Investment Management (Delisted)

PRI reporting framework 2020

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

01.4. Describe your organisation’s investment principles and overall investment strategy, interpretation of fiduciary (or equivalent) duties,and how they consider ESG factors and real economy impact.

Alder Capital operate our ESG policy with the following categories.

1. Principals

2. Governance

3. Execution

4. Information Sharing

5. Risk Management and Compliance

6. Credit and Counterparty Risk

  • Market Risk
  • Operational Risk
  • Settlement Risk
  • Compliance Risk
  • Legal Risk
  • Confirmation & Settlement

7. Office Environment

As an organisation Alder Capital are committed to adhering to and improving on the categories we have created.

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]

1.Principals  We will strive for the highest ethical standards and create a strong culture of ethical and professional conduct with regards to Market activities through the following: 

 Ethics training by relevant staff, employee code of conduct, senior management to be highly visible to all personnel in articulating and modelling the desired practices, values, and conduct.

2. Governance. We will have remuneration and promotion structures that promote market practices and behaviours that are consistent with our ethical and professional conduct expectations. We will have appropriate policies and procedures to handle and respond to potentially improper practices and behaviours effectively.

3. Execution. 

We  handle orders fairly and with transparency in line with the capacities in which we act.

We will not request transactions, create orders, or provide prices with the intent of disrupting market functioning or hindering the price discovery process.

We will identify and resolve trade discrepancies as soon as practicable to contribute to a well-functioning Market.

As a firm relying on trading algorithms, we will provide adequate disclosure regarding how they operate.

4. Information Sharing

We will clearly and effectively identify and appropriately limit access to Confidential Information.

We will communicate in a manner that is clear, accurate, professional, and not misleading.

We will provide personnel with clear guidance on approved modes and channels of communication.

5. Risk Management and Compliance  

We will have frameworks for risk management and compliance.

We will abide by all applicable law and regulation and have an appropriate compliance framework in place.

We will maintain an appropriate risk management framework with systems and internal controls to identify and manage the risks we face.

We will have practices in place to limit, monitor, and control the risks related to Market trading activity.

We will have processes in place to independently review the effectiveness of and adherence to the risk management and compliance functions.

6. Credit and Counterparty Risk We will have adequate processes to manage counterparty credit risk exposure, including where appropriate, the use of appropriate netting and collateral arrangements, such as legally enforceable master netting agreements and credit support arrangements.

Market Risk 

We will have processes to measure, monitor, report, and manage market risk in an accurate and timely way.

We will have independent processes in place to mark-to-market trading positions to measure the size of our profit and loss and the market risk arising from trading positions.

Operational Risk

We will have business continuity plans (BCPs) in place that are appropriate to the nature, scale, and complexity of our business and that can be implemented quickly and effectively in the event of large-scale disasters, loss of access to significant trading platforms, settlement, or other critical services, or other market disruptions.

Settlement Risk

We will take prudent measures to manage and reduce Settlement Risks, including prompt resolution measures to minimise disruption to trading activities.

Compliance Risk

We will keep a timely, consistent, and accurate record of our market activity to facilitate appropriate levels of transparency and auditability and have processes in place designed to prevent unauthorised transactions.

We will perform “know-your-customer” (KYC) checks on our counterparties to ascertain that our transactions are not used to facilitate money laundering, terrorist financing, or other criminal activities.

Legal Risk

We will have processes in place to identify and manage legal risks arising in relation to our market activities.

Confirmation & Settlement

We will establish consistency between our operating practices, documentation, and policies for managing credit and legal risk.

We will institute a robust framework for monitoring and managing capacity in both normal and peak conditions.


7. Office Environment

Energy saving policy

Staff wellness

Encouraging the following:

 envirnoment awareness, use of public transport, recycling in the workplace, flexibility with remote working and an aspiriation that staff are aware of their carbon footprint. 


01.6. Additional information [Optional].


SG 01 CC. Climate risk

01.6 CC. Indicate whether your organisation has identified transition and physical climate-related risks and opportunities and factored this into the investment strategies and products, within the organisation’s investment time horizon.

Describe why your organisation has not yet gone through a process to identify transition and physical climate-related risks and opportunities.

We have reviewed the range of  limate related ESG products that are available and spoken to the ICE Exchange in London to see if there is a liquid futures contract that we can trade . Currently the market is not there but we watch for ESG futures contracts that have enough liquidity for our programs.

01.8 CC. Indicate whether the organisation publicly supports the TCFD?

Explain the rationale

It is something we do support but have yet to implemented this as a policy.  We welcome the ideas behind TCFD and intend publically supporting. 

01.9 CC. Indicate whether there is an organisation-wide strategy in place to identify and manage material climate-related risks and opportunities.

Describe how and over what time frame the organisation will implement an organisation-wide strategy that manages climate-related risks and opportunities.

Following on from last year's submission to UNPRI, Alder Capital engaged on a Cloud Migration project to reduce our energy consumption and decided to minimise the reliance on our inhouse servers to be able to work more efficiently in a cloud based environment. This has resulted in less energy consumption and more efficient ways of working.

However, due to  the nature of Alder Capital's business being primarily a Currency Manager, we have no way of implementing climate-related risk and opportunities directly that affect our investment strategies. We  continue to engage on our office energy savings policies, promote recycling and actively discourage wastage in our day to day work. We have looked at potentially trading in indices where climate related indices feature, however this a new market and not something we can do something with at the moment.   

1.10 CC. Indicate the documents and/or communications the organisation uses to publish TCFD disclosures.

SG 02. Publicly available RI policy or guidance documents


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.

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.

Under our Principals 

We will identify and address conflicts of interest.

Conflicts of interest policy reviewed annually.

Conflicts of interest are a standing agenda item at Board Meetings.


03.3. Additional information. [Optional]

How we trade to ensure conflict of interest doesn't occur, is set out below:

Orders are generated by model / client.

Quarterly review of bunched orders is performed to ensure trades are allocated fairly.

Compliance & Procedures Manual – Market Abuse prevention.

Alder only enters the market to trade – either trading the best price on the trade aggregator or executing by telephone. The times of trading are determined by the trading algorithm. Alder does not provide prices and does not generate orders with the intent of disrupting the market or hindering price discovery.


SG 04. Identifying incidents occurring within portfolios (Private)