Policies and 
procedures

Acura Capital meets its regulatory and fiduciary responsibilities with transparency and efficiency in conducting its business through a solid structure of policies and procedures. This structure is continuously maintained by monitoring the evolution of the regulatory and business environment.

We are constantly adapting to the complexity of our operations
and the highest standards of ethics and conduct.

Compliance Manual

It includes the company's rules, procedures and internal controls related to security information, employee certification, "know your counterpart", continuity plan and general policy of fair allocation, which must be interpreted alongside with the policy of apportionment and the managed division of orders.

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Ethics code

It gathers rules and establishes the standards of ethics and behaviour for the employees.

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Personal Investiments

Provides posture standards regarding the real state negotiation by the employees.

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Orders Apportionment

Determines the principles and procedures adopted for apportioning orders among the funds managed by Acura Capital.

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Voting Exercise

It contemplates the principles and procedures made for voting in meetings representing the investment funds under the company's management.

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Risk Management 

Describes the company's risk management practices.

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Money Laundering Prevention

It points out the guidelines to be followed by the company in order to detect, prevent and mitigate all the risks related to Money Laundering and Terrorism Financing.

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Liquidity Risk Management 

Indicates the rules and establishes standards for risk and liquidity management for the 555 Funds.

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Reference Form - CVM 558 - Annex 15 II 

Informs the legal structure of the company, as well as its operational organization for activities managing.

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Policy for Hiring Service Providers

Guidelines for the selection, approval and monitoring of service providers managed by Acura.

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PLD Policy

It relates to the prevention of money laundering, terrorist financing and the proliferation of weapons of mass destruction.

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