Governance
The framework that governs how the firm invests.
Discipline does not follow automatically from good intentions. This page sets out how the firm is governed, who decides and the standards we hold ourselves to.
Statement of capital
How the firm invests.
Elite Prime Far East Limited invests on its own account. The firm does not manage assets for third parties, does not operate any collective investment scheme and is not licensed by the Securities and Futures Commission to provide investment services to the public.
Framework
Eight pillars of governance.
Each pillar is supported by a written policy, approved by the firm's principals and reviewed annually.
01
Ownership and accountability
The firm's principals are responsible for every investment decision and for the conduct of the firm as a whole. Authority is delegated in writing, exercised through the investment committee and reviewed annually.
02
Investment committee
A standing committee of the firm's principals and senior investment staff approves every material investment. Meetings are minuted, recommendations are made in writing and any member may decline a proposal. The committee reviews the whole portfolio quarterly.
03
Risk management
Concentration limits by strategy, sector, geography and counterparty are set by the committee and monitored by Finance. The firm does not borrow to invest, and it holds sufficient liquidity to meet all of its commitments without selling assets.
04
Conflicts of interest
Personal investments by staff in securities within the firm's research universe are restricted and must be pre-cleared. Related-party dealings between the firm, its people and portfolio companies are recorded in a conflicts register that the committee reviews.
05
Counterparty integrity
Every counterparty is screened against sanctions and adverse-media sources before we engage, and beneficial ownership is established to the standard expected of a Hong Kong financial institution. We decline transactions where ownership or source of funds cannot be verified.
06
Responsible ownership
We consider environmental, social and governance factors as part of ordinary commercial diligence, because they bear on the durability of the businesses we own. We exclude sectors and activities that conflict with the firm's standards, whatever the return.
07
Information security and confidentiality
Deal information is held on a need-to-know basis, with access controls and audit logging. Confidentiality obligations survive the end of any process, and we do not disclose our involvement in a transaction without the counterparty's agreement.
08
Regulatory position
The firm does not carry on any regulated activity for third parties and does not hold itself out as doing so. We comply with all applicable company, tax, anti-money-laundering and sanctions requirements in Hong Kong and in each jurisdiction in which we invest.
Investment committee
Who decides, and how.
- Composition
- The firm's principals and senior investment staff. Legal, Risk & Compliance attends without a vote.
- Frequency
- Weekly, with additional sessions convened for time-sensitive matters.
- Quorum and approval
- A majority of members, including at least one principal. Any member may decline a proposal; a single objection is enough to require further work.
- Documentation
- A written recommendation including a downside case, a conflicts declaration and a summary of diligence. All meetings are minuted.
- Thresholds
- Every investment above a de minimis threshold requires committee approval. Follow-on commitments and material changes to terms are approved afresh.
- Review
- The whole portfolio is reviewed quarterly against original theses, concentration limits and liquidity requirements.
Regulatory position
Where the firm sits.
Elite Prime Far East Limited does not carry on any regulated activity under the Securities and Futures Ordinance of Hong Kong for third parties, and does not hold itself out as providing any service that would require a licence from the Securities and Futures Commission.
The firm complies with all applicable requirements under Hong Kong company law, tax law, the Anti-Money Laundering and Counter-Terrorist Financing Ordinance and the United Nations Sanctions Ordinance, together with the laws of each jurisdiction in which it invests. Counterparty screening and beneficial-ownership verification are conducted to the standards expected of a Hong Kong financial institution.
Should the firm’s activities ever change in a way that brings them within a regulatory perimeter, the firm will obtain the relevant authorisation before conducting those activities. We do not test boundaries.
Questions about the firm’s governance may be directed to info@eliteprimefareast.com.
Related
Legal notices and policies
Questions about how we operate?
We are glad to explain our structure, our process and our standards to any counterparty considering working with us.