Caerus maintains detailed AIFMD internal control and compliance procedures to ensure the operation of each of our funds complies with applicable laws, industry standards and the respective fund’s constitution.
Our operative provisions and approach to compliance sees that our group has a robust internal reporting structure, which requires the identification and assessment of all possible business risks deemed relevant to our funds.
The following summarises the reporting structure and explains how our personnel administer such plan. Reporting is by exception, and the arrows indicate the flow of information.
As a responsible manager, we recognise that for our funds to operate within a safe and controlled environment, other systems, controls and planning mechanisms are required. Accordingly, our group has in place a number of policies and procedures that form an integral part of our compliance program. Such policies are reviewed annually by senior management in co-ordination with our group’s Audit, Risk & Compliance Committee (ARCC).
As part of our daily operations, Caerus has adopted a “four eyes principle” for the implementation of its internal control measures. As a result, we segregate various functions, i.e. dual control of fund assets, double signatures, cross-checking by at least two individuals etc.
This principle is designed to ensure that at least two minds are applied to the implementation of each of our corporate governance risks and compliance measures. Both persons’ judgments must be engaged in order that major errors or malfeasance leading to difficulties for the business as a whole, are less likely to occur. In order for such principle to apply effectively, each responsible person must have sufficient experience and knowledge of the business and the necessary authority to detect and deal with any imprudence, dishonesty or other irregularities.
All officers and employees of our group are required to report any actual or potential breaches and matters of concern in relation to their areas of responsibility as soon as practical to the group’s ARCC via a prescribed mechanism.