Lighthouse has a set of policies that reflect its commitment to responsible investing and ethical conduct. These policies include:
Staff Trading & Personal Dealing Policy
Lighthouse ensures that personal investment activities are always conducted with the Fund’s reputation in mind, and are in compliance with all applicable laws and regulations. It (the Fund) generally discourages personal securities transactions where preclearance is required. However, it permits limited personal trading where preclearance is required. The policies to be adhered to while trading in Employee Related Accounts are delineated in this policy.
This policy regulates the personal trading activities of its staff, and ensures that they do not engage in any transactions that may conflict with the interests of the Fund or its investors.
Anti-bribery and Anti-corruption Policy and Procedures
Lighthouse is committed to upholding its highest ethical standards and operates on a zero-tolerance policy with respect to bribery and corruption. Its policy includes Lighthouse partners, employees, members, owners, principals, directors, and officers and, where applicable, consultants and also includes portfolio companies of funds managed/advised by Lighthouse and “Portfolio Company Covered Persons.
Anti-Money Laundering Policy
Lighthouse ensures that proper policy frameworks are put in place as per the guidelines on Anti Money Laundering standards notified by SEBI. This policy also extends to all investment advisory/management entities of Lighthouse. Portfolio Companies (as defined below) shall also adhere to the provisions of this policy, unless an anti-money laundering policy of suitable standards has been adopted by them internally.
Procurement Policy
Lighthouse understands that a robust procurement policy can help to ensure a consistent, efficient, and best practice approach to procurement, as well as to support purchasing processes and sourcing strategies.
With that objective, Lighthouse’s procurement policy creates a framework:
- of governance for procurement and a structure that enables the use of appropriate process steps and tools to enable the right selection of vendors and solutions; and
- to provide a competitive advantage to the business by reducing costs and developing excellence in purchasing and sourcing processes.