Policies & Directives
Compliance and Business Ethics
At Partners Group, we recognize that in the industry in which we operate, reputation and trust are of utmost importance. Since our inception, we have strived to cultivate a strong culture of ethics and compliance with local and international laws and regulations to ensure our clients’ interests are always at the forefront of our activities.
Our compliance management program consists of various measures by which we address the legal and regulatory risks we face and achieve our compliance objectives in various jurisdictions. This includes the monitoring of regulatory developments in relevant jurisdictions, the fulfillment of our ongoing regulatory obligations and procedures, and the propagation of our firm’s directives and policies.
Our Code of Conduct summarizes the key directives, policies, practices and values which enable us to maintain the high standards of business conduct which have always been at the heart of our success. We review and update (where necessary) our directives and policies at least on an annual basis to reflect regulatory developments or relevant operational changes. Our global directives may also be supplemented by local directives where required by local laws. These policies and directives are drafted to the highest global standards to inform employees of their regulatory obligations and expected standards.
To ensure all employees are fully aware of the contents of these policies and directives, we conduct targeted training and education sessions, coordinated by our Compliance team. Among existing compliance trainings are:
- Introduction sessions for new joiners, in which new joiners are introduced to the most relevant compliance policies and directives. All new employees must complete the new employee compliance curriculum, passing the embedded knowledge checks, in their first ten days of employment. Further, they attend introduction day events, where various teams provide presentations, or watch those presentations via prerecorded videos on our intranet. Group Compliance forms part of those introductory sessions and introduces the department, the compliance program, including those directives and policies which are most relevant for all employees, and the obligations of employees;
- On an annual basis, every employee, including all members of our Executive Committee and Board of Directors, has to take and pass an online compliance training and test, where they have to answer questions regarding the content of various compliance policies and directives, as well as ad hoc trainings which are more specialized and specifically held with certain groups of people within Partners Group, such as international marketing training for the Client Solutions teams or AML/KYC training for all employees involved in the onboarding of new clients
- The firm also operates a Corporate Deliverables Policy, which outlines employees' responsibilities for adhering to internal and external corporate-related obligations, to encourage personal accountability by Partners Group employees. Breaches of Partners Group compliance instructions or failure to adhere and complete trainings are subject to sanctions under the policy. These sanctions include fines to an employee's compensation to address the non-compliance.
Partners Group expects its employees to speak up if they know of or suspect misconduct, i.e. conduct or occurrences that violate law, regulations, internal instructions, group processes or the Partners Group Charter. Examples of misconduct include, but are not limited to, the following:
- Human rights violations
- Fraud, bribery and corruption, theft or other crime
- Financial irregularities
- Regulatory breaches
- Insider dealing, market manipulation or unlawful disclosure of inside information
- Breaches or omissions that could lead to a breach of Partners Group instructions or the Partners Group Charter
- Sexual harassment and discrimination, coercion and bullying
- Violations of health and safety regulations
- Falsification of company business and/or financial records
- Expense reimbursement fraud
- Questionable business practices such as miss-selling or non-adherence to marketing rules
- Suppression and elimination of documents
- Failing to disclose an existing or potential conflict of interest
- Failing to disclose information (e.g. “kickback” / “back-hand” schemes / gifts and invitations) where an employee receives or offers an incentive in exchange for offering a third-party Partners Group business or receiving an investment/service from a third-party
- Failure to disclose material information required for an informed investment decision
- Abusing a position of responsibility (e.g. embezzlement)
Partners Group employees are encouraged to share their concerns of misconduct with someone who can address them properly. This person will usually be an employee's cell leader. If the employee feels uncomfortable reporting to their cell leader, they may report to anyone in the Global Executive Board, Executive Team (ExTeam), the Head of Human Resources, a Global co-Head Compliance, or the General Counsel.
Another way to report misconduct is via our Speak-up Platform, which is administrated by a third party in order to ensure anonymity for whistle-blowers. Employees that have suspicions of or knowledge about any misconduct may report such incidents through this channel. The Speak-up Platform enables them to send reports and communicate securely and anonymously with Partners Group’s case manager by way of an individual case number and password. Partners Group is obliged to launch an internal investigation into any incident reported via the Speak-up Platform.
In accordance with our Code of Conduct and Charter, we aim to act as a good corporate citizen, paying the correct amount of tax at the correct time. We aim to do this by ensuring that we manage and report our tax affairs in a manner that safeguards compliance with international tax guidelines and all applicable tax laws and obligations in each country in which we operate.
We do not undertake aggressive tax planning or artificial tax arrangements. Where we seek for efficient management of tax matters to protect shareholder value, we only implement supportable and sustainable tax positions based on sound commercial activities and in line with the spirit of the law.
Data Protection and Privacy
Managing the data we receive from our customers, employees, and business partners around the world is an important part of building the strong relationships that are key to our success. Our global data protection framework is based on internationally recognized data protection and privacy principles and guides our collection, use, transfer, release, disclosure, and security of personal data and outlines our expectations of third parties who process data on our behalf. The framework includes policies on, among others, information security measures, training and awareness, and business relevant procedures guided by our Data Protection Officer and specialized legal counsel. Additionally, we take care to understand the changing landscape of relevant laws and regulations that may apply to continuously update our global data protection framework.
Anti-Bribery and Corruption
Partners Group operates a zero tolerance approach to the offering or receiving of bribes in any form. All employees and service providers are expected to conduct themselves with integrity, impartiality and honesty at all times.
Gifts, hospitality, promotional and other business events, as defined in our Anti-bribery and Gifts Directive, have to be disclosed and submitted for approval in our intranet-based approval tool. The appropriate "Approving Person" as defined by our policy conducts a first check to assess whether such gifts may be accepted/events attended based on a set of rules, and a second check is conducted by our Compliance team.
Gifts given to or offered by employees or Partners Group’s service providers as a reward, inducement or encouragement for preferential treatment or improper or dishonest conduct are strictly prohibited. Furthermore, our employees must not solicit gifts of any type or value.
Partners Group is also committed to transparently disclosing any political contributions as well as charitable contributions and sponsorships made by the firm. In 2020, Partners Group did not support any local political campaigns and candidates in Switzerland (2019: CHF 30,000). Furthermore, in 2020, Partners Group provided CHF 186,000 (2019: CHF 218,000) in sponsorships to various industry associations directly or indirectly related to private markets and CHF 200,000 (2019: CHF 100,000) in charitable donations to its employee foundation PG Impact (Verein). Partners Group did not make any contributions to lobbying or interest representation nor any spending related to ballot measures or referendums between 2017 and 2020.
Partners Group has a set of sound Anti-Money Laundering (AML) procedures that allow employees to make an informed decision as to whether a transaction with a customer may involve money laundering or may finance improper or illegal activities.
Based on the type of clients we engage with and the illiquidity and duration of most of our investment programs, it is our assessment that the risk of money laundering across our business is relatively low. Nonetheless, we are conscious of the need to be vigilant and are aware of the obligations and challenges posed by money laundering. We have implemented a robust global framework to ensure that we are not used as a conduit for money laundering.
When undertaking customer and beneficial owner due diligence, we have in place AML controls (e.g. careful due diligence; verification; checks against lists of suspected terrorists; assessment of whether the amount invested is commensurate with source of wealth and funds) to identify and verify the identity of customers. As part of the due diligence process, a risk assessment is undertaken to determine whether a potential customer is to be classified as low-risk, standard-risk or high-risk. Where an underlying principal or beneficial owner has been identified as a politically exposed person (PEP), the customer may generally be classified as high-risk. We continue to monitor these aspects and conduct controls throughout the lifetime of our investment programs.
Monitoring also includes the monitoring of customer transactions. Additional investigations are carried out into business transactions that are deemed to involve higher risk. For instance, such transactions may include transactions inconsistent with the pattern of activity expected of a particular customer, or requests by customers to carry out money transfers to bank accounts other than those held in the name of the customer.
In order to ensure oversight of AML matters, we have appointed AML officers depending on the office where the client due diligence is conducted. AML procedures may be handled in-house or, where appropriate, outsourced to regulated service providers in the relevant jurisdiction.
Prevention of Market Abuse
As a company listed on the SIX Swiss Exchange and asset manager of collective investment schemes according to the Swiss Collective Investment Schemes Act, Partners Group and its employees are subject to strict market conduct rules and are under the supervision of regulators including FINMA, FCA, SEC, CSSF and GFSC as well as European regulations including MAR. Partners Group regularly receives, handles and generates confidential information. In order to comply with the rules of financial regulators around the treatment of confidential information, comply with contractual limitations on access to confidential information, effectively handle potential conflicts of interest, comply with best business practice to prevent market abuse and to effectively mitigate reputational risk, robust controls around the flow of information are required. Market abuse can occur in a number of ways, through insider trading, the unlawful disclosure of insider information, market manipulation and front/parallel running.
Partners Group acknowledges that in the business in which it operates, reputation and trust are of utmost importance. Partners Group therefore strives to apply the highest standards to avoid insider trading, market manipulation and front/parallel-running and the appearance thereof by the firm and its employees and applies a zero tolerance approach. It has therefore established strict procedures to ensure these matters are addressed appropriately. It is the responsibility of every Partners Group employee and member of the Board of Directors or Executive Committee ("PG Persons") to understand their responsibilities under the firm's Prevention of Market Abuse Directive in controlling the flows of confidential information. PG Persons in general and members of the investment and transaction teams in particular, must be sensitive with respect to confidential information they learn about in the course of their private markets activities.
Where employees have any concerns or questions in relation to insider trading, market manipulation or front/parallel-running, in particular whether a specific activity is permitted or not, it is recommended that they seek advice from the firm Compliance team. Where a PG Person has reasonable grounds for suspecting that another PG Person has executed transactions on behalf of Partners Group involving insider trading, market manipulation or front/parallel-running, he/she shall immediately inform the firm's Compliance team in accordance with Partners Group’s Speak-Up Directive. In case such transactions are capable of having a substantial impact on the risks of Partners Group or the financial sector as a whole, the firm's Corporate Legal team will report them to the FINMA. Furthermore, the firm's Corporate Legal team will initiate further required steps under applicable laws and regulations.
Any PG Person found to be misusing insider information, conducting market manipulation or front/parallel-running will be subject to disciplinary proceedings, which may include the termination of employment. PG Persons are aware that such activity may also result in criminal prosecution.
We place considerable importance on providing our clients with the highest level of service. However, we understand that there may be occasions when clients' expectations may not be met. We understand the importance of complaints and view them as an opportunity to learn and to improve our controls, as well as a chance to put things right for our clients.
Our Client Complaints Policy outlines the channels through which our clients can make complaints and the ways these will be handled and resolved.
UK Modern Slavery Statement
In our regulated investment management business, the risk of slavery and human trafficking is, by definition, very low. We can only hire employees with appropriate training, experience and without a criminal record. Therefore, we are competing with other service providers to attract the best professionals and provide them with a demanding and rewarding working environment.
In our supply chain, the risk of slavery and human trafficking is also very limited because our service providers are known, reputable, professional and/or regulated service providers.
We endeavor to prevent slavery and human trafficking in our business and supply chains by:
- periodically reviewing and adapting our company policies to raise awareness of and reflect our endeavors in the prevention of slavery and human trafficking;
- subjecting new prospective employees to strict checks on their identity, references, qualifications and criminal records without exception;
- training the relevant staff involved in procurement;
- obtaining services only from known, reputable, professional and/or regulated services providers and suppliers, who are subject to our supplier and service procurement assessments and processes;
- including appropriate contractual language in our service and supplier contracts;
- periodically subjecting our supplier and service procurement processes to internal audit spot checks
We are committed to investing our clients’ capital in a responsible way by integrating environmental, social and governance (ESG) factors, alongside commercial and financial factors, into our investment due diligence and ownership. We believe this is a core part of our fiduciary duty to act in the best interests of our clients and their beneficiaries. As a private markets investment manager, we integrate ESG factors throughout the investment process in all investment types (direct, primary and secondary) and asset classes (private equity, private debt, private infrastructure and private real estate). To ensure the systematic integration of ESG factors in this process, we have developed an ESG & Sustainability Directive, which is reviewed and updated on a yearly basis.
Climate change has emerged as a global challenge following growing scientific consensus that the earth is warming, and that this process is likely driven by increasing greenhouse gas (GHG) concentrations. Extreme weather events, natural disasters, and unmanaged climate change are among the top five global risks, both in terms of likelihood and impact, according to the World Economic Forum. While addressing climate change requires action from governments, civil society and businesses, we believe that investors are uniquely positioned to catalyze the transition to a low-carbon economy through the systematic assessment and management of climate risks and opportunities. At Partners Group, we are committed to managing those risks for our global portfolio of investments and our firm.
Our group-wide Climate Change Strategy outlines our approach to managing climate risks and impacts across our firm and the key stages of our investment process, from sourcing and due diligence through to ownership and exit. The strategy aligns with the Task Force on Climate-related Financial Disclosures' (TCFD) recommended disclosures.
Diversity and Prevention of Harassment and Discrimination
Partners Group is strongly committed to promoting a diversity of perspectives, skills and backgrounds as we believe this makes us better at what we do. Diversity inherently enhances our capabilities and operational excellence, and it remains a priority for us to ensure the policies and practices that govern our firm accurately reflect this belief. We are proud of our professional and congenial work environment and will take all necessary steps to ensure that this environment is free from harassment and discrimination based on legally protected characteristics.
Our policy on the Prevention of Harassment, Discrimination and Retaliation outlines our expectations regarding employee respect, civility and professionalism. All employees, officers, and other workers over whom Partners Group has control are required to read and agree to comply with the policy.
Partners Group realizes potential in private markets and creates sustainable returns with lasting, positive impact for all of its stakeholders. The Board of Partners Group Holding AG is entrusted with the overall strategy and direction of the company and with the supervision of its management. The composition of the Board is fundamental to achieving the firm's strategic needs for the future.
Partners Group recognizes and embraces the benefits of having a Board that is adequately staffed with diverse and accretive skills to drive strategy and support value creation initiatives. A truly diverse Board will include and make good use of differences in the technical know-how, regional and industry experience, social and ethnic background, race, gender, as well as other distinctions between directors such as cognitive and personal strengths (the "PG Board Diversity").
Diversity is therefore one critical element of board composition that Partners Group has focused on over the years in its refreshment and succession planning processes. All Board appointments and succession plans are based on merit and objective criteria, in the context of the skills, experience, independence and knowledge which the Board requires to be effective.
The Nomination and Compensation Committee will discuss and agree annually on measurable objectives for achieving the PG Board Diversity mentioned above and recommend them to the Board for adoption. At any given time, the Board may seek to improve one or more aspects of the objectives of the PG Board Diversity.
Based on the PG Board Diversity objectives, the Board has established a target of ensuring that the proportion of newly elected independent directors is comprised of at least 50 percent of the following groups on a three-year rolling-basis:
- persons identifying other than (cis-)male,
- persons from the LGBT+ community,
- persons from under-represented ethnic minority groups
While this target is maintained going forward, the Board recognizes that periods of change in the Board composition may result in temporary periods when this balance is not achieved.
Health & Safety
This Health and Safety Policy sets out Partners Group's commitments to ensure a work environment which promotes physical and mental health.
The Policy applies to all employees and contingent workers of Partners Group while they are on Company premises. Where local legislation is more stringent, the local health and safety requirements will apply in addition to the Policy. The Company strives to ensure the health and safety of employees and visitors to its premises.
The Company considers a safe and healthy working environment to be a clean, hygienic office premises, as defined by the relevant applicable laws, aiming at employees being free from both physical and/or psychological harm and where safe, ergonomic work practices are observed to the extent reasonably practicable. Employees and visitors to the Company's workplace are expected to adhere to the Company's Health and Safety Policy. Partners Group fosters a culture of compliance and ethically sound business conduct and invites its employees, visitors, and external stakeholders to raise health and safety concerns if they know of or suspect conduct or occurrences that violate laws or regulations.
This Human Rights Policy sets out Partners Group's commitment to respecting internationally recognized human rights across the firm globally.
The Policy applies to Partners Group worldwide. Where local legislation is more stringent, the local requirements will apply in addition to the Policy.
As a responsible corporate citizen, Partners Group respects internationally recognised human rights and aims to not infringe on human rights, be complicit or contribute to human rights abuses. As a global private markets firm, Partners Group is responsible towards its employees, its investments1, clients, and society at large.
Partners Group's Code of Conduct confirms its commitment to preserving high legal, ethical and moral standards, and aims to foster compliance with local and international laws and regulations. Partners Group aims to assess, identify, and monitor material human rights risks across its corporate and investment2 activities (with various degrees of control and influence across its lead direct investments, secondaries and primaries), to address identified potential and actual human rights violations, as appropriate. Partners Group fosters a culture of compliance and ethically sound business conduct and invites its employees, clients, and external stakeholders to raise concerns about human rights violations, or if they know of or suspect conduct or occurrences that violate (other) laws or regulations. The Speak-Up Directive has been established internally to prevent and eliminate misconduct within its organization, including inter alia to provide remedy to actual negative human rights impacts.