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Who is responsible for risk oversight?

The roles and responsibilities of the teams responsible for the various aspects of risk monitoring and
management within GAM’s enterprise risk management framework are summarised in the table overleaf.


Department Activities Monitoring frequency
Investment Teams Monitoring and management of market, sector
and instrument-specific risk, using GAM’s
portfolio construction and modelling systems,
statistical analysis systems and internal reports.
Departments/ Dealers
Responsible for daily trading error monitoring. Daily
Investment risk
Monitoring and management of market, sector
and instrument-specific risk, using GAM’s
portfolio construction and modelling systems,
Risk Metrics, statistical analysis systems and
internal reports.
Weekly/Monthly and ad hoc
Controlling teams
These teams monitor our investment teams’
adherence to applicable legal and regulatory,
prospectus, contractual and internal investment
restrictions. They escalate established
investment restriction breaches, enforce and
control the timely remedy of such breaches and
report relevant breaches to applicable external
auditors and regulators, if required
Legal and
These teams monitor best execution, fair
allocation, interact with investment controlling
teams in case of investment restriction breaches
and oversee and monitor other legal and
regulatory risks.
Operational risk
Responsible for monitoring of processes
susceptible to risk using key risk indicators,
aiming to identify deterioration in the quality of
critical business processes at an early stage, so
that corrective measures can be taken within a
short timeframe
Local risk teams Monitor financial and non-financial agency and
proprietary risks, identifying key risks within
business units and designing solutions to
mitigate sensitivities.
Group M Ultimate responsibility for ensuring that all forms
of risk are appropriately monitored and managed.
Board of Directors of
parent company
(GAM Holding AG)
Oversight and governance of risk issues as part
of Board meetings.
Group Internal Audit
Reviews controls to assess their adequacy and
compliance with Group control requirements.
Formal audit every 1-4 years
or ad hoc based on audit
outcomes or specific
requests by management

Atlanticomnium operates its own independent oversight of its business environment with additional
controls as it relates to interfacing with the GAM teams:

Department Activities Monitoring Frequency
Investment Team The investment team is responsible for monitoring
and managing all investment risk at the first level
(Liquidity, credit, market). The Risk Management
Process (RMP) tool covers pre-trade, post trade
and hedging of UCITS and prospectus restrictions.
All investment restrictions are monitored twice a
Operations Team Responsible for daily trade monitoring
reconciliation of the custodian platform Vs
Atlanticomnium PMS, and ultimately interface
with GAM middle office.
Risk and Compliance
Team (internal &
The second level control is Responsible for
monitoring the good execution of the first level risk
control and the adherence to regulatory standards
and investment restrictions. The team is also
responsible for reporting its findings to relevant
senior management and the Board. The analysis
on the investment restrictions is done weekly
whereas the reporting to GAM of the regulatory
standards through the KPI is done on a monthly
Daily monitoring,
weekly reporting,
Risk Manager Within the Risk & Compliance team, the Risk
manager is responsible for the oversight of all key
processes including the development,
implementation and embedding of processes
whereby management identifies assesses,
monitors, controls and mitigates the risks in their
Provides weekly key management reporting to the
Management Committee and liaises with Legal
and Compliance as to relates to external audit
Management Committee Ultimate responsibility for ensuring that all forms of
risk are appropriately monitored and managed.
Board of Directors of
Atlanticomnium SA
Oversight and governance of risk issues as part of
Board meetings.
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