Corporate Governance & Compliance

Conflicts of Interest

  • We ensure that where conflicts of interest arise, the Designated Person is informed immediately with details of how the conflict arose and what action has been taken or is proposed to be taken.
  • We try to ensure that all potential conflicts of interest between clients are disclosed prior to engagement.
  • CCM has procedures in place to ensure that all applicable conflicts of interest can be identified, monitored and managed at all times.
  • Potential conflict of interest reports are compiled on a quarterly basis.

Supervision of Delegates

  • CCM’s board have clear structures in place for the on-going monitoring of work delegated to third parties.
  • Detailed monthly reporting is received from the Administrator and the Investment Manager. Reporting is also received from the Depositary on a monthly basis. The reports, as outlined in the Programme of Activity, were received by the relevant parties in accordance with the compliance calendar requirements.

Complaints Handling

  • We ensure that any complaint from an investor is treated fairly and consistently and is to be addressed promptly and effectively.
  • Here at CCM we do our best to resolve the issue raised by the complainant and identify and resolve any system and control weaknesses.

Remuneration

  • CCM has in-place remuneration policies designed to ensure that relevant conflicts of interests can be managed.
  • CCM’s remuneration policies are compliant with Schedule 2 of the Irish Regulations and the ESMA Remuneration Guidelines.

Record Keeping

  • The Head of Risk and Compliance will monitor the recordkeeping procedures of CCM to ensure a full record of transactions entered by the CCM Funds maintained.
  • All records required to demonstrate compliance with the provisions of the Irish Regulations and requirements of the Central Bank are maintained in a readily accessible.

Decision Making

  • The board retains responsibility and competence in relation to all material decisions affecting the operation and conduct of CCM.
  • CCM has established, implemented and maintains decision-making procedures and an organisational structure which specifies reporting lines and allocates functions and responsibilities clearly and in a documented manner.
  • CCM has organised its structure and reporting lines to ensure that no one person can decide on the direction of CCM without the endorsement of another.