While the lead portfolio manager has ultimate responsibility for the overall portfolio, all investment personnel are responsible for ensuring that the portfolios are being managed in a way that is consistent with the investment objectives and constraints of the products. Review and control procedures include a continuous evaluation of all holdings in the portfolios on both fundamental and valuation bases. In addition, portfolios are monitored on an ongoing basis in order to ensure sufficient diversification by industry and to control aggregation risk.
From a more formal control perspective the Chief Compliance Officer conducts regular fund oversight meetings to review all portfolios managed by Galibier. The meetings include all investment personnel and include a review of recurring and ad-hoc compliance topics such as portfolio holdings, portfolio constraints, transaction activity, commissions and broker allocations, personal trading, restricted lists, trade settlements and account reconciliations.