ACF aims to capitalise on its best-in-class position in equity research / investment research globally by growing revenues and profitability in the sale of investment research products and related services around the world. ACF’s strategy is to seek to grow the available market for its products as well as its market share, by providing leading differentiated solutions to its clients.

ACF’s clients are private and public nano, micro, small and mid-cap companies as generally classified by market participants in the North American and European markets. Our aim is to improve capital markets effectiveness for all. Smaller and mid-size companies are the largest global generators of employment. They are the heart of the global economy. By transforming the effective use of global capital markets for small and mid-size companies everyone benefits. Jobs are created, which lifts people out of poverty and in turn provides education opportunities. We believe education and employment leads to equality, which improves and saves lives.

The key features of the business model:

• Revenues are principally generated through the sale of best-in-class equity research / investment research services and products and monthly related services.
• ACF clients are provided with both education, support and advice on how to use our products and services to generate long-term sustained value where this is required or requested. This assists us in our strategy to develop recurring annualised and monthly revenues.
• ACF use independent analytical techniques and client references to build its reputation for its capital markets effectiveness.
• ACF does not issue single research notes except under conditional pre-IPO circumstances. All clients are provided with at least an initiation note and second follow up note over a 12-month period to maintain the integrity of ACF’s brand and therefore the investment made by all its clients.
• Product and service innovation.
• Exceptional commitment to ACF’s brand values.
• Diverse, open minded, flexible, and so progressive approach to hiring, team building and culture.
• Innovative approach to use of technology and working policies leading to operational flexibility.

ACF’s investment research products are produced under a regulated umbrella but they are not required to be produced in this way. ACF’s investment research is produced to institutional quality and content expectations and is accessible to all readers including retail investors. There is no regulatory barrier to retail investors enjoying the same level of ACF Equity Research reports.

ACF’s research reports and related products are distributed globally by the more credible major institutional platforms and additionally on a selected number of retail platforms that we believe are aligned with ACF’s internal and brand values. ACF’s leading investment research products and services are designed for use by our clients and market participants. ACF’s leading investment research products and services are designed for use inside and outside the capital markets environment to maximise the longevity and usefulness of ACF clients’ investment in ACF’s investment research services and products.

The Board/Executive Management Team has collected evidence that demonstrates that ACF’s proposition is effective, value generating for clients, high-end and substantively differentiated from ACF’s competitors.

ACF is one of the leading equity research companies globally and deploys technology and technology driven processes that uplift the value generation to its clients. ACF’s investment research products and services are constantly innovated in order that they remain differentiated and respond to constantly changing capital markets dynamics. In investment research businesses ACF believes that constant innovation is an effective substitute for patented products and services.

The leading challenges to ACF’s strategy are:

• Corporate budgets – ACF’s growth and performance is affected by the corporate budgets, money raising ability and confidence in cash flow generation of its target corporate clients and their need for high quality leading investment research. 

ACF risk mitigation:

• ACF mitigates these risks by creating an international internal culture that lends itself to an investment research sector agnostic approach and a global client base.

• ACF has no overall reliance on either single or small groups of equity research sectors or economic geographies. By offering both progressive research education and advice to the global market and individual corporate teams ACF is growing its pipeline of potential clients and relationships.

• ACF uses a progressive education approach to equity research to enhance and show the value proposition, effectiveness, varied use and longevity of its valuation research and related capital markets products and services.

• As one of many investment research companies, ACF’s progressive research approach emphasises both public and private company investment research services in the nano, micro, small and mid-cap segments.

• ACF offers fixed price progressive investment research packages ranging from the financially accessible a full-service holistic set of solutions and deliverables to its clients.

• Competitive position – There are very many companies offering investment research services globally. However, ACF’s executive management team concluded that there are either zero or very few explicitly direct competitors to ACF’s holistic, creative and progressive cultural approach.

• ACF’s executive management team estimates that there are six investment research companies across its global regions with which ACF regularly comes into competitive contact. Only one of these equity research companies is present in all of ACF’s target markets and sectors.

ACF risk mitigation

• These competitive risks are mitigated by ensuring a constantly innovative approach to private and capital markets product and service development.

• ACF achieves innovation through the creative use of technology and its core cultural values that include a diverse and progressive hiring policy for investment research analysts, sales and strategy, distribution and operations.

• Capital markets sentiment – ACF’s prospects and growth are subject to the activity and sentiment of the local and global capital markets.

ACF risk mitigation

• Capital markets sentiment and activity risk is mitigated by ACF using a three-pronged strategy – operational flexibility, financial flexibility, and global prospecting across private and public markets.

• ACF’s emphasis on nano, micro, small and mid-cap companies provides it with more opportunities that it can address even in highly risk averse market conditions, prolonged economic downturns or deep and dramatic local or global market corrections.

• ACF constantly seeks to understand and meet stakeholder requirements and expectations.

The Managing Director and the Head of Operations are responsible for maintaining a dialogue with stakeholders, they are supported by the Non-Executive Chairman and communications advisors. The MD and the Head of Operations hold both one-to-one and group meetings with stakeholders as and when this is required or desired. 

Christopher Nicholson
Founder and Managing Director
cnicholson@acfequityresearch.com
+44 20 7419 7928

Amalia Barnoschi
Co-Head and Head of Operation
abarnoschi@acfequityresearch.com
+44 20 7419 7928

At the centre of ACF’s business model is the production and progressive distribution of credible and insightful high-quality equity / investment research that investors want to read. ACF continues to develop and innovate its investment research products, related services and distribution strategies.

Our goal is to improve our clients’ capital markets effectiveness. The inceptual goal of ACF’s products and services was to improve the quality of investment research available to investors of all types on nano, micro, smaller and mid-cap companies. The research and its production are designed to be as independent as possible. For corporates we aim to deliver insightful information and counsel along with our progressive investment research products and services that deliver tangible long-term benefits to our clients.

ACF has been successful in achieving this central objective and its products and services are used globally by financial markets and public and private corporates.

By improving capital markets effectiveness for its clients, ACF reduces client  project IRRs for clients ACF improves a client’s ability to raise capital and so to create jobs. By helping clients create jobs, ACF helps pull people out of poverty, ACF improves the probability of people getting education, and through education ACF improves the chanced of emancipation.

ACF collaborates with clients and service providers ethically. ACF is a small, growing, progressive investment research services business. ACF’s commitment to ESG (Environmental, Social and Governance) policies is under constant review and as ACF grows, it does more. 

ACF recognises that it is dependent on the commitment and delivery of its team and the ecosystem of partners and suppliers that it works with. Specific actions ACF undertakes to foster its culture include:

Communication – The Senior Leadership Team [SLT] meets regularly throughout the month and has a permanently open channel to discuss business achievements and challenges and interdisciplinary team matters.  Line managers regularly and quickly update employees on Company decisions, expectations, and goals.

• Team members are supported by an internal coaching-partner system, with particular emphasis on constant skill development and upgrading.
• Outside training is provided where necessary to enhance job performance and bring new skills to the team.
• ACF regularly reviews the benefits offered to the team, ranging from cultural change to lifestyle incentives.

ACF has a culture that encourages and rewards continuous feedback from the team. The Senior Leadership Team discusses recommendations and ideas, and feeds back to rest of the team.

ACF is not a company that has a substantial impact on the environment. However, ACF recognises that even as a service business it generates environmental impact from car driving to home heating. ACF recognises that some of its current and future clients do have a substantial environmental impact. ACF acknowledges its responsibility to minimise its own environmental impact and to encourage its clients to acknowledge and act upon the same. Activities ACF undertakes to minimise environmental impact: 

• Where possible, products are recycled within ACF. Recycling as a policy is encouraged in team members at home.
  
• Paper, cardboard, batteries, and printer cartridge recycling collection facilities are in place and are regularly used in ACF’s offices and by the team when working from home.
• Redundant computer equipment is offered to employees or disposed of in accordance with good practice.
• ACF does not operate a company vehicle fleet. Instead the MD and Head of Operations provide their personal vehicles for personal use to appropriately qualified team members. This vehicle policy encourages safer more efficient driving through personal responsibility, the reduction of consumption of materials through servicing and repairs and a reduction of pollution of the environment.
  
• ACF encourages team members to participate in car sharing and exercise and is a member of the cycle to work (Bike2Work) scheme.
• ACF has since inception encouraged and made every effort and investment within its capacity to allow employees to work from home as much as practicable. In addition, when car based transport is unavoidable the MD and Head of Operations specifically encourage team members to travel with them and make their personal vehicles available to appropriate team members to minimise the purchase of new vehicles and maximise mileage efficiency and congestion.
• ACF encourages individual team members to participate in physical and mental health low-carbon emission activities via a supported Fitbit scheme.
• ACF encourages individual team members to monitor their home electricity consumption and share the data with the Company in order that the team can generate ideas to share and to innovate home energy consumption practices.
• ACF continually reviews the consumable products it buys with a view to removing unethically produced or environmentally damaging processes of production with substitute consumables as far as it is currently able. 

• ACF produces investment research / equity research products and related services that generate great value by guiding and stimulating the growth and effectiveness of small and medium sized companies, to improve capital markets efficiency and so to generate employment, education and emancipation opportunities around the world.
  
• ACF has an embedded culture that promotes personal success. ACF believes that personal success is underpinned by coaching, self-belief, and a will to succeed. The pure talent of its team members by itself accounts for only a small percentage of personal success. ACF also aims to provide a safe and secure working environment that promotes ethically achieved success, is socially diverse, highly flexible, creative and interactive. ACF has a variety of processes for recognising achievement, encouraging and nurturing success.
• ACF recognises client needs for a high touch service level that generates high levels of measurable value. ACF achieves this value generation by a constant cycle of innovation in its investment research products and services in order to provide maximum longevity, effectiveness and to broaden the usefulness to clients and investors.
• Client feedback is sought formally and informally as is independent third-party feedback and discussed during the Weekly Management Meetings and the Senior Leadership Team Channel. 

• As a producer of financial markets products and services, ACF operates in a highly regulated environment and is subject to financial and criminal penalties if in breach.
• ACF provides appropriate health and safety equipment to team members irrespective of whether it is obliged to do so or not under current legislation. ACF is of the view that its care of its team members extends beyond simple working hours.
• All drivers of the MD and Head of Operations personal vehicles must undergo refresher driving lessons and review, revision, and formal re-testing of the highway code every three years. Particular attention is paid to knowledge and safe driving protocols with respect to pedestrians, cyclists, motorcyclists, and equestrians on an annual basis.
• Health and safety matters are reviewed weekly at the Weekly ACF Management Meetings. ACF embeds effective risk management, considering both opportunities and threats, throughout the organisation

The Directors recognise their responsibility for ACF’s system of internal control and have established systems to ensure that an appropriate and reasonable level of oversight and control is provided. ACF’s systems of internal control are designed to help ACF meet its business objectives by appropriately managing, rather than eliminating, the risks to those objectives. The controls can only provide reasonable, not absolute, assurance against material misstatement or loss.

The Senior Management Team and or the Senior Leadership Team meet weekly to review both the risks facing the business and the controls established to minimise those risks and their effectiveness in operation on an ongoing basis. The aim of these reviews is to provide reasonable assurance that material risks and problems are identified, and appropriate action taken at an early stage. 

ACF maintains a comprehensive risk register which includes commercial, operational and financial internal and external risks that are assessed according to nature and magnitude and given a priority rank based on the seriousness of the risk and the likelihood of the risk occurring. Those ranked in the highest category which are considered both serious and more likely to occur are managed by the Senior Management Team and monitored to mitigate the risks. The Senior Leadership Team manages the remainder of the risks and reviews them as part of the management meeting cycle.  New potentially material risks which arise in the meantime, such as the impact of the 2020 viral pandemic, are discussed and acted upon as they arise.

The annual budget is reviewed and approved by the Senior Management Team. Operational performance is examined monthly and compared to forecasts quarterly with comparisons to budget. Latest forecasts are reported weekly to the Head of Operations and the MD along with challenges, observations and issues and approaches to address such challenges. Significant variances in financial and operational targets are addressed annually via ACF Strategic plan.

Approval levels for authorisation of expenditure are at set levels throughout the team structure. Most team members are encouraged to develop financial and budgetary acumen in a limited and controlled manner using pre-paid cards. The Senior Management Team approves expenditure exceeding pre-paid card amounts. 

Measures continue to be taken to review and embed internal controls and risk management procedures into the business processes of the organisation and to deal with areas of improvement which come to the Senior Management Team’s and or Senior Leadership Team’s attention. Metrics and quality objectives continue to be innovated and monitored as part of a continual improvement programme.

ACF’s accountant is encouraged to raise comments on internal control in its weekly management reports. The points raised and actions arising are monitored through to completion by the Head of Operations.

The Senior Management Team currently consists of two executives, one male and one female.

The Senior Leadership Team currently consists of three leaders, two female and one male. 

The non-executive Chairman is responsible mentoring and guiding the Senior Management Team to improve effective leadership, operation, and governance of ACF. The non-executive Chairman assists the Senior Management Team with counsel and action in the development and implementation of ACF’s strategy whilst ensuring that the nature and extent of its strategy is determined and challenged. The MD and Head of Operations are responsible for the management of ACF’s business and for implementing ACF’s strategy.

The Non-Executive Chairman is considered independent of management and free of any relationship that could materially interfere with the exercise of independent judgement. The Non-Executive Chairman was considered independent upon appointment.

ACF has a Remuneration committee – details and links to their terms of reference are set out under Commitment 8 below.

Details of the Non-Executive Chairman, the Senior Management Team and the Senior Leadership Team and their suitability for their roles is set out under Commitment 5 below.

Michael Wort, Non-Executive Chairman

Background and suitability for the role: Michael Wort is a life science communications expert and former life sciences CEO (large to start-up). He graduated in microbiology and lectured to science undergraduates in both the UK and Nigeria. He joined the pharmaceutical industry, working in a number of senior sales, marketing and clinical roles for Glaxo, SmithKline, and Wellcome in the UK and overseas.

Michael Wort was appointed IR Manager for Wellcome, where he helped organise its global roadshow for a £2.4bn secondary offering. Michael Wort has managed over 20 IPOs and secondary raisings bringing in well in excess of £600m, He has consulted on and conducted M&A and DD in the life science sector and developed disaster recovery programmes for SME companies.

Michael Wort worked with Deutsche Bank to privatise the Bulgarian pharmaceutical industry. As the CEO of Balkanpharma, Michael Wort led the consolidation of the three key assets into one cohesive unit. Balkanpharma has, through a series of M&A activities, become a significant part of NYSE listed Allergan.

Formerly MD at De Facto Communications, Bell Pottinger’s healthcare offering, Michael Wort retired from Walbrook, the UK’s most successful SME PR/IR agency and subsequently joined ACF Equity Research as a consultant and became ACF’s non-executive Chairman in 2019. In addition, Michael has co-founded a number of life science start-up companies in Europe and the USA.

Current external appointments: Michael Wort sits on the board of Diaceutics PLC and is Executive Chairman of Texadon Oil and Gas PLC

Christopher Nicholson – Managing Director

Background and suitability for the role: Christopher Nicholson is a financial analyst, entrepreneur, professionally qualified equestrian and amateur eventer. He trained as a financial analyst at Global US based fund manager Legg Mason Investors and at the European Bank for Reconstruction and Development (EBRD). He was head of Technology and Media Equity Research at Bryan Garnier, a pan-European investment bank and brokerage and worked for Eurotunnel in a Head Office role in Business Administration when it was a project company. He worked as a law and finance researcher for an MP who was special advisor to the then Chancellor of the Exchequer.

Christopher Nicholson founded ORACA Independent Equity Research a ground-breaking highly independent thinking large-cap secondary commission investment research business and ACF Equity Research, a very high-quality independent issuer-pays nano, micro, small and mid-cap investment research business. Christopher Nicholson opened his first corporate finance business (Destrier Partners) several years ago. 

For 11 years Christopher Nicholson broadcasted as an expert investment research analyst guest and wrote regularly in the leading pan-European and international media including Bloomberg Television, BBC Radio 4 and the Financial Times.

Christopher Nicholson studied Biochemistry and Microbiology at Kings College London, followed by mathematical Economics at LSE. He can conduct business in English and French, speaks German and has a basic knowledge of Spanish and Italian. 

Current external appointments: Christopher Nicholson is a Board Director of ORACA Ltd, a Partner of Destrier LLP, a Board Director of Destrier Partners Ltd and a Board Director of Hawk & Lion Ltd..

Amalia Barnoschi – Head of Operations

Background and suitability for the role: Amalia Barnoschi co-leads and is Head of Operations at ACF Equity Research having joined at its founding. Amalia Barnoschi started her career in financial services in 2007 on the sell-side with ORACA Limited, a large-cap independent equity research business that changed the industry. Before financial services Amalia Barnoschi was a successful and rapidly promoted young manager in manufacturing. Amalia Barnoschi has worked closely at board level for over 15 years with SMEs in the City and in other financial markets. Amalia Barnoschi is highly IT literate and runs ACF’s IT operations.

Amalia Barnoschi is bilingual English/Romanian, reads Italian and is working towards her accountancy ACCA qualification with AAT.

Current external appointments: None

Anne Castagnede – Sales & Strategy

Background and suitability for the role: Anne Castagnede leads ACF’s Sales & Strategy team and is a member of the ACF Senior Leadership Team. Anne Castagnede is a sales professional with a top-tier luxury goods background. In the past 5 years she worked with the great Haute Couture houses including Chanel and Jimmy Choo where she established a reputation as a top sales performer. Anne Castagnede managed flagship boutiques. Anne Castagnede started her career with Air France and has acquired management skills from back office through to front office. Anne Castagnede is bilingual French and English and speaks Spanish. 

Current external appointments: None

The Senior Management Team believes that, in addition to dealing with any matters as they arise, it is appropriate to carry out a formal evaluation of the performance of the Senior Management Team each year. This is intended to ensure that the Senior Management Team is effective, well-informed and able to make high quality and timely decisions for the benefit of all stakeholders in ACF.

In general, no major concerns were identified with the evaluation carried out in January 2021, nevertheless a number of material matters were considered for review. 

The Senior Management Team evaluation process.  The Senior Management Team evaluates each member in open discussion providing feedback and problem solving on a weekly basis. For further support with problem solving and performance matters, both Senior Managers have access to: the Non-Executive Chairman; a third-party mentor from outside ACF; and third-party training.

Succession planning. Unlike most small companies ACF has undergone succession planning. ACF does have internal candidates to succeed both the MD and the Head of Operations. In addition, a programme of identification and production of detailed Standard Operating Procedures relating to the complex MD and Head of Operations functions has been instigated.  Succession planning is kept under review, and consideration is made when recruiting for vacancies as they arise. The Senior Management Team does not believe it is appropriate or effective to recruit further senior team members solely for the purpose of succession.

Strategy plan. In 2021, strategic discussions have taken up a larger part of the Senior Management Meeting time due to the growth of ACF and the opportunities presented by the Sars-CoV-2 pandemic. ACF is planning its Financial Year End 2022 strategy discussion to take place the financial final quarter of 2021. 

ACF’s services and products are designed to improve capital markets effectiveness for its clients and to encourage and support global job creation, education, and emancipation. To achieve these two goals ACF must recruit talented individuals who can grow with the Company. ACF’s good reputation and professional practice standing of behaving above and beyond the requirements of its regulator are key to continuing to grow its global business.

ACF’s highly creative culture of constant technical and non-technical innovation require a particularly diverse team, and a culturally and flexible environment. ACF’s long-term success is underpinned by a supportive internal culture combined with the ethical values of honesty and responsibility in dealing with customers and suppliers globally. 

ACF conducted a formal offsite process in which the Company team members worked through a scored and ranked assessment system that allowed them to define and articulate the company culture map as they experience it. This was followed up with sessions in which the team assessed which cultural elements they valued most and which they valued least. We can best summarise ACF’s culture as follows:

Using Erin Meyer’s Culture Map analysis, approach, and vocabulary – The elements that ACF’s team felt were strongly and unambiguously experienced in ACF culture were that ACF is a low context (hierarchy does not preclude or alter communication), direct negative feedback (as opposed to indirect negative feedback), principles first (as opposed to applications first), task-based linear-time (as opposed to flexible time) organisation. 

Using the Culture Map insights, ACF’s team defined ACF’s cultural keystones as: 

• Talent combined with nurturing, leading to self-belief;
• Trust is built on delivery;
• Effectiveness is measured by merit alone;
• Flexibility, progressive action and continuous education, creates, attracts and keeps a diverse dynamic team. 

ACF operates a very flat structure with all staff having the ability to discuss matters with the Senior Management Team and the Senior Leadership Team individuals. The Senior Management Team talks daily to encourage clear communication, teamwork, and agility. Specifically, the Senior Management Team’s communications mantra is ‘close the loop’; daily goals are reviewed in short meetings at the beginning and end of each day for and with all team members; the agility philosophy is the ‘tank crew’ – everyone has a top tier specialisation, and everyone has to be able to operate the vehicle.  

The culture is monitored by the team.

The Senior Management Team (SMT) and the Senior Leadership Team review the team’s feedback and invite and respond to external counsel. 

A rolling flexible agenda is left permanently open to review and change structures and processes as they are needed to support the evolution of ACF. The Senior Management Team reviews any pertinent items at its weekly meeting. Ad hoc meetings are called as required to discuss specific topics with the Senior Leadership Team and or the entire team.

The Committee reviews and sets the remuneration of the Senior Management Team, the Sales & Strategy Team and other members of the team and considers any bonuses to be awarded to them. The Committee makes decisions on all aspects of share schemes including the approval of share options. The Committee is made up of the Senior Management Team, which seeks advice from external third parties on an independent basis to ensure equitable and financially appropriate bonuses and bonus systems, incentives, and share options are offered. There is a structured bonus system for the Sales & Strategy team members and the Senior Management Team and a structured but discretionary bonus system for all other team members. 

Anti-Bribery Statement

ACF is committed to the highest standards of ethical conduct and integrity in its business activities in the UK and overseas. Corruption of any kind is detrimental not only to ACF but also to the wider community. ACF will not tolerate any form of bribery by, or of, its employees, agents or consultants or any person or body acting on its behalf. The Senior Management Team and the Senior Leadership Team are committed to implementing effective measures to prevent, monitor and eliminate bribery, corruption and injustice. This is not just a cultural commitment on the part of ACF; it is a moral issue, a legal requirement and central to ACF’s progressive investment research culture.

ACF prides itself on its reputation for acting fairly, honestly, ethically and above the standards required by its regulatory body, the FCA, wherever it does business. ACF’s reputation is built on its integrity as a Company, through the values of its culture and its team members as a collective commitment.

ACF has implemented policies and legal clauses in its client and supplier contracts, which are designed to prevent bribery.  Any breach of the policies or legal clauses is likely to constitute a serious disciplinary, contractual and criminal matter for the individual concerned and may cause serious damage to the reputation and standing of ACF.

If any person acting on behalf of ACF has any doubts about the Company’s Anti-Bribery commitment or Policy, they should refer the matter to their Line Manager, the Head of Operations, the MD or the Non-Executive Chairman in accordance with ACF’s whistle blowing policy.

Page last updated: 17 March 2021

2.1 Employee Diversity

Gender representation of global employees (%)

Racial/Ethnic group representation of global employees (%)

Basic wages excl. commissions (% of total wage bill)

ACF hires with respect only to suitability and talent.

ACF has internal and external mentorship for senior professional staff and executives and a senior coach is appointed for professional members of staff no matter their seniority. Where ACF deems it appropriate for the development of the business and the team members in question, ACF does invest in outsourced training.

3.1 Monetary losses associated with legal proceedings

Total monetary losses associated with legal proceedings

Since inception of the firm, ACF has not been subject to any judgements, orders, trials, settlements, pleas, or prosecutions in any context. As a result, there have been no monetary losses. 

Since inception, ACF has not been subject to any of the items in 1.1 and as such no corrective actions have been necessary.

ACF (FRN 607274) outsources to a third party its internal compliance program and in addition as a regulated entity its regulator the Financial Conduct Authority (FCA) provides an open anonymous and discreet procedure for whistle blowers. ACF’s third party compliance provider of which ACF is an Appointed Representative is City & Merchant Limited (FRN 154182), which is authorised and regulated by the Financial Conduct Authority.

ACF has not been subject to any whistle blower cases or inquiries.

3.2 Number and percent of employees with a record of investment-related investigations

Number and percent of employees with a record of investment-related investigations

ACF (FRN 607274) outsources to a third party its internal compliance program and in addition as a regulated entity its regulator the Financial Conduct Authority (FCA) provides an open anonymous and discreet procedure for whistle blowers. ACF’s third party compliance provider of which ACF is an Appointed Representative is City & Merchant Limited (FRN 154182), which is authorised and regulated by the Financial Conduct Authority. In addition, ACF has its own internal independently minded compliance officer.

3.3 Number of mediation and arbitration cases associated with professional integrity, including duty of care

Number of mediation and arbitration cases associated with professional integrity, including duty of care

3.3. Monetary losses due to legal proceedings associated with professional integrity, including duty of care

Total monetary losses due to legal proceedings associated with professional integrity, including duty of care

Corrective actions implemented

N/A

3.4 Approach to ensuring professional integrity, including duty of care

Policies to ensure professional integrity, including duty of care

ACF has an ongoing program of Standard Operating Procedure (SOP) development, exterior mentoring, non-executive senior appointments and fosters an internal culture of open debate. In addition, the brand values of ACF include a default position of operating to a standard that is markedly higher than the legal and regulatory requirements to which it is subject.