Compliance & Ethics
There can be little doubt that bribery and corruption impede the efficient use of government revenue, discourages private investment and negatively impacts inclusive growth and development. The social and political consequences of corruption rob nations of their potential and drive inequality and resentment.
ARCH is firmly committed to the concept that the citizens deserve full transparency in the procurement and implementation of critical basic services and maintains zero tolerance with respect to all aspects of bribery and corruption. We are determined to act with the highest levels of integrity and have implemented a number of policies and procedures to ensure that our employees, and those we do business with - behave legally and ethically at all times.
Employee, Investee and Supplier Conduct
ARCH representatives are expected to observe the highest standards of business integrity in their dealings with each other and third parties, acting with professional and personal integrity at all times. The FCA code of conduct rules are embedded in ARCH culture and internal procedures and policies. Clear guidelines and training on conduct are provided to employees, and as applicable to investee companies and suppliers on what constitutes and/or is required for good conduct.
Anti-Bribery & Corruption and Anti-Money Laundering Policies
ARCH is dedicated to combating bribery and corruption and has implemented an Anti-Bribery and Corruption Policy that fully complies with the UK Bribery Act of 2010. We are equally committed to participating in international efforts to combat money laundering and terrorist financing, and in line with international and local regulations and legislation, have developed a financial crime risk framework to ensure compliance with our obligations. All our staff are required to undergo regular anti-corruption and anti-money laundering training.
Fully Transparent Procurement Policies
ARCH has developed and adopted procurement policies designed to address the specific challenges surrounding the markets in which we do business. These policies ensure that a formal and transparent selection process is observed where services are procured, including for the appointment of consultants, contractors and other third party advisers.
Risk-based know your customer procedures
ARCH has developed Know Your Customer (“KYC”) procedures to ensure that no employee, consultant, counterparty or investor is employed or retained unless their identities have been diligently identified and verified. Our procedures employ a risk-based approach that categorises each relevant person or entity as either low, medium, or high risk, and applies corresponding KYC measures and monitoring methods.
Personal Account Dealing Policy
At times, employees may have access to non public information about certain companies which could give rise to an unfair advantage if acted upon. Accordingly, ARCH operates internal procedures to mitigate market abuse risks. ARCH has established a Personal Account Dealing (PDA) Policy which obligates employees to obtain prior approval before executing personal trades, and requires disclosure of investment holdings to the Head of Compliance and Human Resources at the commencement of employment. Employees are required to complete a quarterly mandatory self-declaration attestation regarding their personal trades, and anti- market abuse training is provided to all employees on an annual basis.
In conformance with the Financial Conduct Authority’s (FCA) requirements, ARCH has established a Whilsteblowing Policy. Employees are aware of how to raise any concerns of wrongful, dishonest or unlawful activities by the firm or work colleagues. ARCH actively encourages its employees to raise concerns, and no individual will be subject to detrimental treatment because they have disclosed their concerns, either under this policy or ARCH’s Grievance Procedure.
Equal Opportunities Employer
As a company, we pride ourselves on treating all members of staff and job candidates equally, irrespective of their or their associated persons gender, sex, pregnancy or maternity status, marital status, race, colour, religion, belief, disability, age, sexual orientation, gender reassignment. All employees are required to comply with their obligations to promote a working environment free from discrimination as part of their conduct commitments.
ARCH recognises that a company’s management of environmental, social and governance (ESG) issues can materially affect its financial performance. We actively seek opportunities to create long-term sustainable value through integrating best practice ESG considerations across our advisory themes. By working closely with local partners and portfolio companies to identify and manage ESG risks, value creation becomes a shared exercise resulting in positive development outcomes in the markets we serve.
Our advisory themes will:
Comply with or exceed all applicable legislation and regulations in their investment jurisdictions;
At minimum, exclude investment activities listed on the International Finance Corporation’s (IFC) Exclusion List (2007);
Apply the International Finance Corporation’s (IFC) Environmental and Social Performance Standards to assess and manage the risks of their investments;
Measure and report on ESG performance at regular intervals to stakeholders;
Follow good international industry practice (GIIP) for the sectors and technologies in which they invest.
We communicate our commitment to this through ARCH's Sustainability Policy.
Disclosures in accordance with Regulation (EU) 2019/2088 Sustainable Finance Disclosures Regulation (the “SFDR”)
ARCH is an investment adviser to certain regulated managers. The managers of ARCH advised funds are domiciled outside of the European Union and therefore firm level disclosures (for such Managers) under SFDR are not applicable.
Where required, fund/vehicle specific disclosures in accordance with the SFDR will be made available in the data room and the investor portal.
The managers advised by ARCH do not consider the adverse impacts of investment decisions on sustainability factors within the meaning of the SFDR. Whilst ESG considerations are integrated into all investment processes as outlined in the Sustainability Policy, the detailed rules underlying the SFDR will require ARCH to ascertain the availability of the data expected to be reported under the new requirements of the SFDR. As such, the position will continue to be monitored and reviewed by ARCH as the underlying rules are finalised.