Procedures and Organisation
This article contains the information about other procedures and organisational measures the GP should implement.
While the efficient operation of the GP will be supported by adhering to general principles of good governance and effective business management, there are certain matters that are specific to the industry that the GP should address.
The GP should implement procedures to address the following matters (which are in no particular order):
- personal dealing in investments by GP staff and connected persons and if necessary, with other parties with whom the GP is dealing;
- decision-making on investments in target companies and disposals of portfolio companies on behalf of the funds;
- storage (and as required, confidential destruction) of documents and record-keeping;
- outsourcing of material functions (particularly where they may impact on the management of funds);
- anti-corruption rules, the prevention of money laundering and other forms of financial crime;
- anti-trust law requirements, in particular bid-rigging;• business continuity in the case of a business interruption;
- insurance requirements to protect both the GP and the funds it manages, for example Directors & Officers insurance for executives appointed as directors or non-executive directors on portfolio company boards and professional indemnity insurance, if applicable;
- the protection of the fund and the GP in the event of key employee departures;
- any other required regulatory procedures as outlined in, for example, FATCA and AIFMD.