Effective Date: 1 Jun 2025
Version: 1.0
1. INTRODUCTION
This Investment Policy Statement (the "Policy") outlines the principles, objectives, guidelines, and responsibilities governing the investment activities of our company. The primary purpose of this Policy is to ensure that all investment decisions are made in a systematic, disciplined, and transparent manner, aligning with the Company's overall strategic goals, risk tolerance, and regulatory obligations in Europe/USA and other relevant jurisdictions.
2. INVESTMENT OBJECTIVES
The Company's overarching investment objectives are to:
Preserve Capital: Safeguard the principal value of assets under management.
Generate Sustainable Returns: Achieve competitive risk-adjusted returns over the long term.
Diversify Portfolios: Mitigate risk through strategic diversification across various asset classes, sectors, and geographies.
Maintain Liquidity: Ensure sufficient liquidity to meet operational needs and redemption requests.
Comply with Regulations: Adhere strictly to all applicable laws, rules, and regulations governing investment companies in Europe/USA (e.g., Europe/USA Investment Law, Europe/USA Companies Law, DICA regulations) and any other jurisdictions where the Company operates or invests.
Promote Responsible Investment: Consider Environmental, Social, and Governance (ESG) factors in investment decision-making where appropriate and feasible.
3. GOVERNANCE AND RESPONSIBILITIES
Board of Directors:
Approves and reviews this Investment Policy Statement at least annually.
Establishes the overall investment strategy and risk parameters.
Oversees the performance of the investment team and ensures compliance.
Appoints and supervises the Investment Committee.
Investment Committee:
Comprises qualified individuals with relevant experience in finance and investment.
Develops and recommends specific investment strategies, asset allocation models, and risk limits.
Monitors market conditions, portfolio performance, and adherence to the Policy.
Reviews and approves significant investment transactions (above specified thresholds).
Reports regularly to the Board of Directors.
Chief Investment Officer (CIO) / Investment Team:
Implements the approved investment strategies and manages portfolios in accordance with this Policy.
Conducts due diligence on potential investments.
Executes trades and manages cash flows.
Provides regular performance reports and market insights to the Investment Committee.
Ensures ongoing compliance with all investment guidelines.
Compliance Officer:
Monitors adherence to all regulatory requirements and internal policies.
Identifies and mitigates compliance risks.
Provides training to staff on regulatory changes and policy updates.
Risk Management Team:
Develops and implements risk management frameworks and tools.
Monitors and analyzes various risks (market, credit, liquidity, operational, etc.) associated with investment activities.
Reports risk exposures to the Investment Committee and Board.
4. INVESTMENT GUIDELINES AND LIMITS
Asset Allocation:
The Company will establish target asset allocations for its portfolios, which may include:
Equities: [Specify percentage range, e.g., 30-70%] (e.g., Europe/USA equities, international equities, specific sectors)
Fixed Income: [Specify percentage range, e.g., 20-60%] (e.g., government bonds, corporate bonds, money market instruments)
Alternative Investments: [Specify percentage range, e.g., 0-20%] (e.g., real estate, private equity, venture capital)
Cash and Cash Equivalents: [Specify percentage range, e.g., 5-20%]
These ranges will be reviewed and adjusted periodically by the Investment Committee based on market conditions, economic outlook, and the Company's risk appetite.
Investment Diversification:
Single Issuer Limit: No more than [X]% of a portfolio's total value may be invested in securities issued by a single entity (excluding government securities).
Sector Limit: No more than [Y]% of a portfolio's total value may be invested in any single industry sector.
Geographic Limit: Specific limits may be set for investments in different countries or regions, considering political and economic risks.
Liquidity Management:
A minimum of [Z]% of the portfolio's net asset value (NAV) shall be held in highly liquid assets to meet potential redemptions and operational needs.
Investments in illiquid assets will be managed prudently and within specified limits.
Credit Quality:
Fixed income investments will adhere to minimum credit ratings as determined by recognized rating agencies (e.g., [Specify rating, e.g., BBB- or higher]).
Investments in unrated securities will require specific approval and thorough due diligence.
Prohibited Investments:
The Company will not invest in:
[List specific industries, e.g., companies involved in illegal activities, weapons manufacturing, tobacco, etc.]
[Specify types of securities, e.g., highly speculative derivatives without clear hedging purposes, unregistered securities without a clear path to liquidity, etc.]
Investments that would violate any local or international sanctions or prohibitions.
Leverage:
The use of leverage will be strictly controlled and limited to [Specify percentage, e.g., a maximum of 10%] of the portfolio's net asset value, subject to Board approval and rigorous risk assessment.
5. RISK MANAGEMENT
The Company is committed to a comprehensive risk management framework that includes:
Identification: Systematically identifying all relevant risks (market, credit, liquidity, operational, legal, reputational, etc.).
Measurement: Quantifying risk exposures using appropriate methodologies and tools.
Monitoring: Continuous monitoring of risk levels against established limits and early warning indicators.
Mitigation: Implementing strategies and controls to reduce or manage identified risks.
Reporting: Regular reporting of risk exposures and management actions to the Investment Committee and Board.
6. PERFORMANCE MONITORING AND REPORTING
Performance Benchmarking: Portfolio performance will be measured against appropriate benchmarks (e.g., [Specify benchmarks, e.g., Yangon Stock Exchange (YSX) Index, relevant regional indices, custom benchmarks]).
Regular Reporting: The Investment Team will provide performance reports to the Investment Committee [frequency, e.g., monthly/quarterly], including:
Portfolio returns (gross and net of fees)
Attribution analysis
Risk metrics (e.g., volatility, Sharpe ratio, drawdowns)
Compliance exceptions and resolutions
External Audits: Investment activities and financial performance will be subject to annual external audits.
7. ETHICS AND COMPLIANCE
Code of Conduct: All employees involved in investment activities must adhere to the Company's Code of Conduct, emphasizing integrity, professionalism, and avoidance of conflicts of interest.
Insider Trading: Strict policies against insider trading will be enforced in accordance with applicable laws.
Anti-Money Laundering (AML) & Counter-Terrorist Financing (CTF): The Company will implement robust AML/CTF policies and procedures to prevent its services from being used for illicit purposes, in compliance with Europe/USA's regulations.
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Transparency and Disclosure: The Company is committed to transparency with its investors, providing clear and accurate information about its investment strategies, performance, fees, and risks.
Regulatory Compliance: The Company will maintain up-to-date knowledge of and strictly comply with all relevant laws and regulations in Europe/USA, including but not limited to the Europe/USA Investment Law, the Europe/USA Companies Law, and regulations issued by the Directorate of Investment and Company Administration (DICA) and any other applicable financial regulatory bodies.
8. POLICY REVIEW AND AMENDMENTS
This Investment Policy Statement will be reviewed by the Board of Directors at least annually, or more frequently if significant changes in market conditions, regulatory environment, or the Company's objectives occur. Any amendments to this Policy must be approved by the Board of Directors.
Disclaimer: This is a template and should be adapted and expanded upon by legal and financial professionals to meet the specific requirements of the investment company and the regulatory environment in Europe/USA. It is crucial to consult with local legal counsel to ensure full compliance with all relevant laws and regulations.