Corporate Governance

The governance system within SAI Atlas Asset Management SA (hereinafter referred to as "SAI Atlas AM") is based on the implementation of an operational flow that ensures the fulfillment of the legislative provisions in the matter of corporate governance. The purpose of corporate governance within SAI Atlas AM is to ensure transparency and trust in the services offered by SAI Atlas AM.

Organizational Structure of SAI Atlas AM

The organizational chart of SAI Atlas AM reflects the way of organization, subordination and links between the company's departments and is based on the following structures:

• General Meeting of Shareholders
• The Board of Administration
• Audit Committee
• Effective leadership
• Compliance Department
• Risk management department
• Departments, according to the organization chart (Organization chart- here)

The management and administration of SAI Atlas AM are carried out by:

• General Meeting of Shareholders
• The Board of Administration
• Effective leadership

SAI Atlas AM control is carried out by:

• Compliance department
• The financial auditor
• Internal audit
• Audit Committee
• Risk department

The application of corporate governance principles are carried out by:

• Board of administration
• Directors of SAI Atlas AM

Coordination and supervision of departments by Directors

1.        The General Director coordinates and supervises:

• • • Analysis & Placements Department
    • Accounting department

1.       The Deputy General Director coordinates and supervises

• • • Back Office Department
    • IT department

The main characteristics of the governance system

The governance system within SAI Atlas Asset Management SA is based on compliance with the following principles:

1. ensuring a transparent and adequate organizational structure within SAI Atlas AM;
2. appropriate allocation and separation of responsibilities;
3. appropriate risk management/risk management through the permanent monitoring of SAI Atlas AM risks by the person responsible for risk management;
4. the adequacy of policies and strategies, as well as internal control mechanisms;
5. ensuring an efficient communication and information transmission system;
6. the application of solid operational procedures to prevent the disclosure of confidential information;
7. monitoring potential conflicts of interest;
8. fulfilling the principles of the employee remuneration policy;
9. compliance with all internal rules and procedures of SAI Atlas AM.

The conclusions of the evaluation of the financial position 

The financial auditor of SAI Atlas AM and of the managed funds is Deloitte Audit SA. 

According to the financial auditor's report, the financial statements faithfully present, under all significant aspects, the financial position and performance for the financial year and the cash flows for the ended financial year. The financial statements were drawn up in accordance with ASF Norm no. 39/2015 for the approval of the Accounting Regulations in accordance with the International Financial Reporting Standards applicable to entities authorized, regulated and supervised by the ASF in the Instruments Sector     and financial investments. 

(Financial statements – here).

The main characteristics of the formal framework regarding the application of financial reporting principles and practices, including those of prudential reporting

The financial statements of SAI Atlas AM as well as of the managed funds are drawn up in accordance with the International Financial Reporting Standards (IFRS) and the ASF regulations in force.

The accounting policies were developed in such a way as to ensure the provision of information that 

(1) to faithfully represent the results and financial position of SAI Atlas AM and the managed funds,

(2) to be easy to understand by users

(3 relevant in making decisions as well

(4) comparable, to compare financial statements over time.

The organizational structures within SAI Atlas AM involved in the application of financial reporting principles and practices, including those of prudential reporting, are:

Audit Committee 

(1) informs the members of the board of directors about the results of the statutory audit,

(2) monitors the financial reporting process and submits recommendations or proposals to ensure its integrity

(3) monitors the effectiveness of the internal quality control systems and the entity's risk management systems and, as the case may be, of the internal audit regarding the financial reporting of the audited entity, without violating its independence

(4) monitors the audit of the annual financial statements, especially its performance, taking into account the findings and conclusions of the competent authority, in accordance with the relevant regulations in force

(5) is responsible for the selection procedure of the financial auditor or the audit firm and recommends the appointment in accordance with the relevant regulations in force,

(6) evaluates and monitors the independence of financial auditors or audit firms in accordance with the relevant regulations in force.

The Board of Administration is responsible for ensuring the existence of an adequate framework for verifying the way in which the specific legislation regarding reporting to the ASF is applied, as well as the information transmitted to the ASF, at its request, regarding certain actions undertaken by SAI Atlas AM.

Internal Auditor has the obligation to supervise the management of SAI Atlas AM, to verify the correct preparation of the financial statements, the regular keeping of the registers, the legal evaluation of the patrimonial elements.

Compliance Department supervises compliance by SAI Atlas AM and its staff with the legislation in force concerning the capital market, as well as with internal regulations.

Risk department identifies, quantifies and manages the relevant risks for SAI Atlas AM and the managed funds.

The main characteristics of the system regarding the administration/management of risks

The company has implemented a complete set of procedures and rules, regarding the specific risks of the activity carried out both for SAI Atlas AM and for the managed funds, and a rigorous cost control to maintain an adequate financial position, respecting both the legal limits of adequacy of capitals as well as those approved internally, which are much more conservative.

The market risk of the financial instruments of SAI Atlas AM and of the managed funds is managed daily within the risk department through the permanent monitoring of the financial positions of SAI Atlas AM and the managed funds for their permanent inclusion in the risk categories approved internally and according to the regulations in force.

The evaluation and management of market risks, credit risks, liquidity risks as well as treasury flow risk are quantified internally through daily monitoring and reporting to the ASF of legal reports. The indicators regarding the adequacy of own funds as well as the control of exposures are reported to the Financial Supervisory Authority, Financial Instruments and Investments sector according to the legislation in force and internal rules. 

The risks related to professional liability are covered, according to EU Regulation 231/2015, from additional own funds that amount to at least 0.01% of the value of the managed FIA portfolios. The value of the managed portfolios is the sum of the absolute values of all assets, including the assets acquired through the use of leverage, the derivative financial instruments being valued at their market value. 

The conclusions of the evaluation of the effectiveness of the administration/risk management system.

Every six months, the members of the board of directors evaluate the effectiveness of the risk management system. Following this evaluation, it was found that the risk management system is operational and adequate to the complexity of SAI Atlas AM's activity. No risks were identified that could disrupt the activity of SAI Atlas AM and the managed funds.

Risk is inherent in the activities of SAI ATLAS AM, but it is managed internally through a continuous process of identification, measurement and monitoring.

Warning Policy (Whistleblowing)

Warning Policy (Whistleblowing) aims to provide assistance to employees, clients or other parties who interact with the activity carried out by SAI Atlas AM and who suspect cases of market abuse, violation of professional conduct or incorrect use of regulations, ethical violations, fraud and any other aspects of non-compliance that would cause image, commercial damage or would attract legal sanctions, so that it can communicate, in a confidential manner, real and significant suspicions regarding to the way of managing the activity.

SAI Atlas AM has established different communication channels that can be used by the company's employees, clients or other parties that have relations with the company's activity to address a suspicion as follows:

a) by sending a document by post to the company's address
explanatory;

b) via e-mail, to the compliance officer: conformitate@atlas-am.ro.

You can get more details on the warning policy at the headquarters of SAI Atlas AM in Sos. Bucharest-Ploiesti no. 7A, floor 6, office 1 or at no. by phone +40 371 306 540.