By Stonebridge Advisors LLP / / 2 min read
The principle
A registered fund is judged as much on how it is run as on what it owns. The simplest governance principle is also one of the most useful: no one person should both take a decision and check it.
At Stonebridge Advisors LLP, the investment decision, the compliance function and the fund accounts sit with different named individuals.
The investment function
Investment direction is provided by Mr. Ajay Seladia, Designated Partner and Chief Investment Officer, with fund management by CA Bhavesh Pokiya, the Fund Manager. The research behind each decision is supported by the wider investment team.
The compliance function
Compliance is a named responsibility held by a qualified Company Secretary, not a duty shared out among the investment team. CS Parth Godhani, the Compliance Officer, is responsible for the Fund's adherence to the SEBI AIF Regulations, 2012, for its regulatory filings and for the governance records the Fund must keep.
Keeping this role outside the investment team means the person checking whether a decision complies with the rules is not the person who wanted to make it.
The accounts
The Fund's books and its periodic financial statements are reviewed by a Chartered Accountant who advises the Investment Manager on accounting policy and financial reporting, separately from the people who make the investment decisions.
Qualified people in control roles
Fund management, accounting and compliance are held by professionals carrying ICAI, ICSI and the relevant NISM certifications for their function. Qualifications do not replace judgement, but they set a floor: each control function is held by someone trained in the discipline it requires.
What an investor can ask
Separation of duties is something an investor can test. Ask who makes the investment decision, who checks it against the rules, and who keeps and reviews the books. If the same name comes back for more than one of those questions, it is worth asking why.
The Fund operates under the SEBI (Alternative Investment Funds) Regulations, 2012. Its full terms, including investor rights, are set out in the Private Placement Memorandum.
An educational note
This article is published for education and general information. It is not investment, legal or tax advice, and it is not an offer or a solicitation. Units in Anchor Rock Investment Fund - I are offered only by private placement to eligible investors, and the terms of the Fund are set out solely in the Private Placement Memorandum. Read the disclosures.