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Policies

OUR STANDARDS

​​As a licensed Collective Investment Scheme (CIS) Manager regulated by the Mauritius Financial Services Commission (FSC), we are committed to maintaining the highest standards of integrity, professionalism, and compliance. This Code of Conduct outlines the principles and standards that govern our operations and client relationships, in alignment with both Mauritius law and internationally recognized best practices.

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This Code of Conduct embodies our commitment to international best practices in investment management, compliance, and corporate governance. All directors, officers, employees, and representatives are required to adhere to these principles to uphold the trust and confidence of our clients and stakeholders.

CODE OF CONDUCT

1. Compliance with Laws, Regulations & International Standards


We adhere to all applicable laws and regulations of Mauritius and other jurisdictions in which we operate. Our practices align with global standards, including:

  • The IOSCO Principles for the regulation of collective investment schemes;

  • The FATF Recommendations on Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT);

  • The OECD Principles of Corporate Governance.

 

2. Fiduciary Duty & Investor First Principle


We act with loyalty, care, and diligence in the best interests of our investors, ensuring their financial objectives and protections are always prioritized.

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3. Integrity, Fairness & Transparency


Our business is conducted with integrity, fairness, and full transparency, ensuring clear and honest communications with all stakeholders.

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4. Conflict of Interest Management


We proactively identify, disclose, and manage conflicts of interest, ensuring fair and impartial treatment of all investors in line with IOSCO standards.

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5. Confidentiality & Data Protection


We maintain the confidentiality of all client and stakeholder information, in compliance with the Mauritius Data Protection Act and relevant international data protection laws, including the EU GDPR where applicable.

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6. Fair Treatment of Investors


We uphold the principle of equitable treatment, ensuring no investor is disadvantaged through preferential practices.

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7. Risk Management & Internal Controls


We have robust internal controls and risk management systems aligned with international frameworks such as the COSO framework and IOSCO guidelines, designed to safeguard investor assets and ensure operational integrity.

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8. Professional Competence & Continuous Development


We are committed to maintaining high standards of professional competence through continuous training and development, ensuring our team remains updated with regulatory changes and evolving market practices.

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9. Sustainability & Responsible Investment

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We incorporate Environmental, Social, and Governance (ESG) considerations into our investment processes, in line with international initiatives such as the UN Principles for Responsible Investment (UN PRI), fostering long-term sustainable value.

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10. Ethical Reporting & Whistleblowing


We maintain secure and confidential whistleblowing channels for the reporting of unethical, illegal, or non-compliant behavior. Our whistleblower protection policy aligns with global best practices, ensuring safe reporting without retaliation.

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11. Anti-Money Laundering & Combating the Financing of Terrorism (AML/CFT)


We enforce stringent AML/CFT policies aligned with FATF standards and FSC Guidelines. Our AML/CFT framework includes:

  • Comprehensive client due diligence and Know Your Customer (KYC) procedures;

  • Ongoing transaction monitoring;

  • Timely reporting of suspicious activities.

We have appointed a dedicated Money Laundering Reporting Officer (MLRO), who is responsible for overseeing the implementation and effectiveness of our AML/CFT framework. The MLRO ensures that the firm’s obligations under the Financial Intelligence and Anti-Money Laundering Act and FSC guidelines are fully met, including:

  • Reviewing and reporting suspicious transactions;

  • Maintaining up-to-date AML/CFT policies and procedures;

  • Providing regular training to staff;

  • Liaising with regulators and law enforcement as required.

 

12. Sanctions Compliance


We fully comply with all applicable sanctions regimes, including:

  • United Nations Sanctions,

  • European Union Sanctions,

  • U.S. OFAC Sanctions,

  • UK OFSI Sanctions,

  • and other relevant jurisdictional lists.

We screen clients, transactions, and counterparties against sanctions lists and monitor regulatory updates, ensuring strict adherence to global sanctions laws. Our MLRO plays a key role in ensuring ongoing sanctions compliance.

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