Risk Management Policy

JSC «AMC PFA «UkrSib Asset Managementт» applies certain standards while managing assets. A risk management system is stipulated by the following documents:

1. Procedure for conducting securities transactions for personal interests by using insider information by the personnel.

Procedure implies limits to securities transactions carried out for personal interests or interests of the third party by using insider information and incorporates supplementary rules for the whole personnel of the company, especially for those who hold “sensitive” posts. According to standards of BNP Paribas Group and legislation of Ukraine, the procedure is implemented on purpose to:

  • protect the image and reputation of the company;
  • prevent conflict of interest between AMC and clients, the personnel, and others due to disclosed insider information;
  • provide integrity of financial markets and raise clients’, partners’, and investors’ trust in AMC.

2. Procedure for an unauthorized access to internal information and its illegal use, approved by the management of AMC.

3. Provisions of the Investment Committee.

The Investment Committee is a collegial body at JSC «AMC PFA «Ukrsib Asset Management», which is authorized to make decisions on miscellaneous issues related to investment activity at AMC, as well as mutual and corporate investment funds that are under management of the company.

Provisions stipulate authority of the Investment Committee, its membership, member liabilities, meeting schedules, approval and decision-making procedures.

4. Provisions of investment procedures.

These provisions are an internal regulatory document that regulates the mechanism for conducting securities transactions and establishes procedure for portfolio management of the funds.

The provisions are intended to:

  • determine a decision making mechanism for imposing limits to securities investments;
  • place an order for investment portfolio monitoring and revise limits to securities investments;
  • arrange a mechanism for bad assets;
  • to establish a cooperation mechanism for units of the company that are involved in securities transactions.