Oversight & Governance Sample Clauses

Oversight & Governance. From an oversight and governance perspective, ▇▇▇▇▇▇ ▇▇▇▇▇’▇ investment activities are overseen by the Investment Management Committee (IMC), a sub-committee of the Board of Directors of ▇▇▇▇▇▇ ▇▇▇▇▇. Membership of the IMC comprises the firm’s Managing Director, investment directors, senior investment personnel as well as other senior members of the firm. The committee meets formally on a quarterly basis. The IMC oversees the activities of the firm’s investment platform which has four components: Investment Research, Portfolio Implementation, Dealing and Cash Management. The firm’s Dealing team is solely responsible for the execution of investment activity, which includes the foreign exchange (FX) transactions necessary for settlement of non-base currency equity trades. The firm’s Trading Oversight Group (TOG), under delegation from the IMC, ensures adequate governance, oversight and challenge of the firm’s dealing activities and compliance with the firm’s related policies. The TOG comprises inter alia senior investment personnel as well as other senior members of the firm. The TOG is responsible for, but is not limited to: • Challenging the output from Transaction Cost Analysis – execution rates and counterparty use; • Ensuring the firm meets the Markets in Financial Instruments Directive (MiFID) II and Markets in the Financial Instruments Regulation (MiFIR) Best Execution Reporting requirements; • Oversight relating to controls around Commissions and Inducements; • Challenging the output from the Trade Surveillance system; • Approval, monitoring and review of the counterparties on the approved list; • Oversight with respect to counterparty risk; and • Reviewing related policies and procedures as and when required. The TOG typically meets on a quarterly basis and reports to the IMC on a quarterly basis.