The Fund: Governance & Oversight

May 15, 2024
Transparency, Fairness & Integrity

Governance, The Cornerstone Of Commercial Sustainability
At CHROME TEMPLE Investments, we believe that effective governance is the cornerstone of sustained success. As we strive to redefine the alternative investment landscape, our commitment to robust governance practices remains unwavering. Join us as we explore the principles and practices that underpin our governance framework, and discover how they shape every decision we make.

A Culture Of Transparency, Accountability, And Responsibility
Governance isn't just about following rules – it's about creating a culture of transparency, accountability, and responsibility. That's why our governance framework encompasses a set of principles and practices designed to guide decision-making, ensure compliance, and define relationships among stakeholders. By prioritising transparency, fairness, and integrity, we lay the foundation for sustainable growth and value creation.

Key Elements Of Fund Governance
From decision-making processes to risk management protocols, our governance framework encompasses a range of essential elements. By implementing a structured decision-making process, we ensure that every investment decision aligns with our objectives and strategies. Meanwhile, our focus on accountability promotes transparent reporting and fosters a culture of integrity and trust. With a clear separation of duties and robust compliance mechanisms in place, we mitigate potential risks and uphold the highest ethical standards.

The Fund’s 9 key elements of governance:

  1. Decision Making Processes: We've implemented an innovative decision-making process to bolster compliance with Fund policies and objectives. This mandatory procedure, leveraging technology and a tailored framework, ensures that every trade adheres to established criteria, promoting transparency and accountability. By enhancing efficiency and consistency, we underscore our commitment to the Fund's overarching objectives and uphold the highest standards of integrity and compliance.
  2. Accountability: Every trade undergoes a comprehensive process that records and reports on (i) all the factors and research that went into an investment decision and (ii) the accountable party for each step of the process. Each piece of information is verified and only non-flagged information can proceed to subsequent steps.  Reports are generated for every flag and for every trade. These reports are reviewed by the Investment Committee and, as needed, the Board of Directors.
  3. Separation Of Duties: Within our Fund, tasks are meticulously divided to ensure fairness and transparency. Each aspect of the investment process, including decision-making, research, data analysis, and reporting, is assigned to specific individuals or teams. This systematic approach helps to avoid conflicts and biases while ensuring the accuracy of each task. Similar to a system of checks and balances, this division of responsibilities maintains order and integrity in our operations.
  4. Compliance: The Fund must comply with legal and regulatory requirements and align with its strategy and objectives. Oversight comes from two groups: the Trustee, who holds an AFSL licence, ensures legal and regulatory adherence, while the Investment Committee monitors alignment with the Fund's objectives, processes, policies and investment strategies. The Investment Manager documents activities accordingly. Regular audits by both groups ensure transparent processes and decision-making.
  5. Ethical Conduct: Our operations prioritise integrity, honesty, and transparency in all actions. Every decision, from investment strategies to daily operations, is guided by a commitment to investors' best interests. Our code of ethics outlines expected behaviour, ensuring fairness and responsibility. Regular training reinforces ethical conduct, fostering a culture of accountability and trust.
  6. Risk Management: We employ a comprehensive risk management approach to identify, assess, and mitigate potential risks affecting the Fund's performance. Regular risk assessments, conducted by specialised Board members, evaluate factors like market volatility, economic conditions, and investment risks. Findings are presented to the Investment Committee and Board for strategic decision-making.
  7. Transparency: We prioritise open communication and transparency, fostering a culture of openness to ensure investors have a clear understanding of our operations. Comprehensive reporting mechanisms offer detailed insights into the Fund's activities, performance, and decision-making processes. This commitment extends to interactions with regulatory bodies and all parties in the Fund structure, ensuring compliance with reporting requirements and industry standards.
  8. Performance Monitoring: We employ a systematic approach to continuously assess and evaluate the Fund's effectiveness and efficiency. This includes regular reviews of investment strategies, portfolio performance, and operational processes. The Investment Committee conducts thorough analyses to ensure alignment with strategic objectives. Internal audits and risk assessments provide valuable insights for ongoing improvements.
  9. Third Party Oversight: SILC, the Fund’s Trustee, offers vigilant third-party oversight, providing an additional layer of assurance through its external and independent perspective. They diligently monitor legal and regulatory compliance, ensuring adherence to prescribed standards. Although not obligatory, we periodically engage external experts to conduct audits, enhancing the objectivity of reporting. This dual oversight mechanism, involving both the Trustee and external experts, bolsters the Fund's integrity, transparency, and accountability.

In Summary
We recognise that effective governance is paramount for maintaining stability, fostering accountability, and achieving desired outcomes for the Fund and ultimately its investors. To this end, we have meticulously crafted a governance framework inspired by the best practices observed among the industry's leading investment funds and asset managers. This proactive approach ensures that our Fund operates with the highest standards of excellence and integrity, setting the stage for sustainable growth and investor confidence.


Continue Reading:
The Fund Intro 00: Genesis
The Fund Intro 01: Objective
The Fund Intro 02: Investment Thesis
The Fund Intro 03: Acquisition Strategy
The Fund Intro 04: Fund Structure
The Fund Intro 06: Information Memorandum

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