Governance
Who is responsible for what
Investment activity at Block Asset Management runs through defined functions, a documented Investment Committee and a decision process in which those who research an opportunity are not those who approve it.
01
Functional responsibilities
Responsibilities are allocated across four functions, with oversight of investment, operational and regulatory obligations.
Senior Management
Accountable for firm strategy, resourcing and the overall control environment.
Investment & Research
Responsible for manager research, quantitative research, due diligence and portfolio construction.
Risk & Operations
Responsible for exposure monitoring, operational processes, service-provider oversight and reporting.
Compliance
Responsible for regulatory obligations, investor eligibility, marketing review and record keeping.
02
Investment committees
Investment governance is exercised at the level of each structure rather than once for the firm. Each structure has an investment committee that operates under a written mandate, with membership defined in writing and decisions recorded.
Where an external alternative investment fund manager is appointed to a structure, a director of that manager sits on its committee alongside directors of BAM. For the remaining structures, the committee comprises directors of BAM.
Committees meet periodically and additionally whenever a decision is required, so an opportunity or an event does not wait for a calendar slot.
Written mandate
Terms of reference define what each committee exists to decide.
Defined membership
Membership is set out in writing for each committee, rather than by whoever attends.
Recorded decisions
Decisions are minuted, so what was decided and when is a matter of record.
Committee members are drawn from the firm's senior management and, where applicable, from the appointed alternative investment fund manager of the relevant structure. That manager's director sits by virtue of its regulatory role, not as an independent member. BAM does not describe either committee as independent, and neither includes independent external members.
03
How this works, structure by structure
Governance is not uniform across the range, because the structures are not the same. Each is set out below, with the parties appointed to it.
Every party named here is stated in the relevant offering documentation, where the terms on which they act are also set out.
Luxembourg structure
Block Asset Management is the alternative investment fund manager, registered with the CSSF.
- Investment committee
- Directors of Block Asset Management
- Alternative investment fund manager
- Block Asset Management S.à r.l.
- Administrator
- Banque de Patrimoines Privés, Luxembourg
- Auditor
- Mazars, Luxembourg
- Legal adviser
- Eversheds Sutherland, Luxembourg
- Independent non-executive director
- None appointed
Malta structure
An authorised alternative investment fund manager is appointed, with an independent non-executive director on the board and a licensed depositary.
- Investment committee
- Appointed by the AIFM, minimum three members. Currently Block Asset Management’s CEO and its CFO/COO, together with a managing director of AQA Capital Ltd
- What the AIFM does
- AQA Capital Ltd has been licensed by the MFSA since 7 March 2017 and provides portfolio management and risk management, subject to the supervision of the scheme’s directors
- Alternative investment fund manager and investment manager
- AQA Capital Ltd
- Depositary
- Swissquote Financial Services (Malta) Ltd
- Administrator
- Fexserv Fund Services Limited
- Auditor
- PwC Malta
- Independent non-executive director
- Appointed to the board
Certificate structure
A certificate, not a fund. It has no board and no depositary, and the safeguards that attach to a fund structure do not apply to it.
- Investment committee
- Directors of Block Asset Management
The differences matter. An eligible investor should read each structure on its own terms rather than assume that a safeguard present in one is present in another — which is precisely why they are set out separately here.
04
How an investment decision is made
The same sequence governs an allocation to an external manager and the deployment of a systematic strategy to live capital.
- 01
Research
Investment & ResearchManagers, strategies, models and markets are researched against the standards of evidence set out in our investment approach.
- 02
Recommendation
Investment & ResearchA recommendation is formed and put forward. Forming a recommendation is not the same as being able to act on it.
- 03
Review
Risk & Operations · ComplianceRisk and Operations contributes its analysis, and Compliance reviews investor eligibility and the regulatory position — both before approval, not after implementation.
- 04
Approval
Investment committeeThe committee for the relevant structure approves or declines. Neither Risk and Operations nor Compliance sits on a committee; they inform its decision.
- 05
Monitoring
Risk & Operations · Investment & ResearchApproval begins the monitoring obligation rather than discharging it. What happens next is set out below.
Those who research an opportunity are not those who approve it. That separation is a matter of function, and it is the reason a recommendation has to survive review before it becomes an allocation.
05
Escalation
Where monitoring shows style drift, risk outside agreed limits, or a material operational event, defined triggers set out in writing require the matter to be escalated for decision.
The triggers themselves are internal. What is stated publicly is that they exist, are written down, and are not left to individual judgement in the moment — which is the part that matters to an allocator assessing whether oversight is real.
06
Ongoing review
Supervision is continuous, and is supplemented by a periodic formal re-underwriting review of each approved manager.
The frequency of that formal review varies by manager rather than following a single firm-wide cadence, so that scrutiny reflects the profile of what is being reviewed.
Where the evidence warrants it, allocations are reduced, paused or redeemed. Monitoring that never changes an allocation is reporting, not oversight.
07
Governance of systematic strategies
BAM's systematic capabilities are implemented using signals and systems produced by a specialist third-party provider. BAM does not develop those models. Its role is selection, due diligence and continuous supervision of the provider — the same discipline applied to any external manager, directed at a systematic one.
Provider selection and due diligence
A systematic provider is assessed as a manager: the rationale for the approach, the discipline of the research process, the evidence that an effect is genuine rather than fitted, and the operational infrastructure around it.
Assessment before deployment
A system is assessed before deployment against defined criteria, with explicit attention to the risk that historical fit does not reflect a genuine, repeatable effect, and to whether out-of-sample behaviour supports the claim being made.
Approval into production
A systematic strategy reaches live capital by decision of the investment committee for the relevant structure, through the same sequence as an allocation to an external manager.
Live monitoring
Live behaviour is compared against research expectations on a continuing basis. Divergence between researched and realised behaviour is treated as a signal to investigate rather than as noise to be tolerated.
Exposure and execution discipline
Exposure is determined by predefined rules rather than by discretionary conviction, within limits set in advance for leverage, concentration and aggregate exposure. Implementation concentrates on the most liquid segments, because a signal that cannot be executed at reasonable cost is not an investable signal.
Change control
Where the provider makes a material change to its system, that is treated as a new decision and returns to the investment committee — not absorbed as an operational detail.
Human oversight
Systematic does not mean unattended. Defined oversight governs exposure and the circumstances in which a strategy is reduced or withdrawn, on the same basis that an allocation to any external manager can be reduced, paused or redeemed.
BAM is not the developer of these models and does not present itself as one. What BAM is accountable for is the decision to use a provider, the diligence supporting that decision, and the oversight that follows it.
Governance is what an allocator diligences first
This page describes how investment activity is governed at firm level. Product-specific materials — including offering documentation, reporting and performance history — are available to eligible investors through controlled access.