BAM has always been committed to the highest legal and ethical standards. It is of the utmost importance to us that our investors have confidence that we take compliance seriously. There are three main compliance pillars, which we follow as a firm:
1. Experienced Team - Dedicated to Compliance Globally
We have an experienced eight person team of legal and compliance professionals, six of whom have a Juris Doctorate or the UK equivalent of a J.D. Compliance is involved across all areas of the firm globally. Every investment office has an onsite compliance professional.
2. Disciplined Processes and Procedures
We maintain strict internal compliance processes and personal trading policies. All processes and procedures are well documented with regular recertification to ensure employees are well informed and the latest rules and regulations are followed:
- Employee Training:
- The Compliance Team conducts an Initial Compliance Outreach at the time an employee joins the firm.
- We hold annual Insider Trading, General Compliance, Personal Trading and Hot-Button training for all employees.
- Trade Testing:
- Our Compliance Department reviews weekly portfolio summaries circulated by our Portfolio Managers. This allows Compliance to maintain an ongoing understanding of the information the Portfolio Managers use to make investment decisions.
- We utilize Financial Tracking to automate trade blotter testing by comparing BAM's trading against public announcements.
- We test most profitable trades and review reports containing daily, weekly, monthly and YTD pnl (by dollar amount and % of notional) for each PM.
- Expert Network policies:
- We have a formal Expert Network guideline and approval process managed by our compliance department.
- We also have a Consultant approval process that requires our compliance department to review and approve each Consultant sourced through an Expert Network before a conversation is permitted take place.
- Expert Networks are primarily used by our Healthcare and Deep Research teams as well as a limited number of other teams.
- Restricted Trading list:
- We have a Restricted Trading List which is actively maintained by the Compliance Department.
- Updates are circulated firm-wide via email. All employees can access BAM's restricted trading list online.
- The Watchtower compliance function (part of Eze Castle, our trade order management system) automatically enforces trade restrictions and prevents trade orders from being executed.
- Background Checks:
- We conduct background checks on all employees prior to the commencement of their employment. We also conduct annual background checks on all employees and annual credit checks on all investment personnel, senior management, and accounting personnel.
- We also conduct background checks on any part-time, temporary or consulting staff that work onsite at our firm.
- BAM maintains a comprehensive Compliance Manual that provides a full description of our policies and procedures.
3. Committed Fiduciary for our Investors
- BAM is registered with the relevant regulators in the jurisdictions of all of our offices globally.
- BAM has been registered as an Investment Advisor with the SEC since January 23, 2006.
- Balyasny Europe Asset Management Europe, LLP was authorized by the FCA June 7, 2005.
- Balyasny Asset Management (Hong Kong) Limited was licensed with the Securities and Futures Commission on March 3, 2008.
- BAM Registered with the CFTC/NFA on January 1, 2013
*Registration with the SEC or any other regulator does not imply a certain level of skill or training.
- BAM maintains active memberships with:
- Alternative Investment Management Association (AIMA)
- Managed Funds Association (MFA)
We may from time to time amend or change these programs. These changes may be due to, but are not limited to, changes in the law or other regulatory requirements, current market practices, changes in regulations, or other guidance provided by counsel and other third party service providers.