Internal Control Procedures — Process for Approval and Monitoring of Individual Transactions Sample Clauses

Internal Control Procedures — Process for Approval and Monitoring of Individual Transactions. The Investment Manager will maintain a list of personnel authorized to initiate derivative transactions. In examining whether a Company should engage in a particular derivative transaction, an authorized member of the Investment Manager will consider (i) the guidelines set forth herein, (ii) the intended purpose of the transaction, (iii) the incremental risk to the Company caused by engaging in such derivative transaction, and (iv) alternative mechanisms for achieving the same purpose. All proposed derivative transactions will be documented on the trade date on a Derivative Transaction Control Sheet (“Control Sheet”), substantially in the form attached hereto as Exhibit A. The Control Sheet may be updated from time to time to reflect changing information requirements from regulators or as best practices evolve. A Control Sheet will not be deemed complete unless a draft of the underlying confirmation is attached thereto and the Control Sheet contains the following information: • type of derivative instrument(s) to be used; • type of strategy to be undertaken; • underlying investment position or other balance sheet or income statement item to which the derivative transaction relates; • description of the transaction, its purpose and its intended effect, including a precise identification of the risks being hedged or replicated, if applicable; • identity of the counterparty or, with respect to exchange-traded transactions, the identity of the exchange and the name of the firm that handled the trade; • notional amount of the transaction; • consideration for the transaction; • any additional collateral or other credit support taken or provided; and • Investment Manager’s recommendation for the most appropriate method for assessing effectiveness based on acceptable choices provided by a Company in the event hedge accounting is to be used (final determination to be made by a Company for accounting/tax purposes). On the date of a derivative transaction, two members of the Investment Manager must sign the Control Sheet, one of whom is authorized by the Investment Manager to initiate derivative transactions and the other of whom is in the Operations area responsible for settling all derivative transactions. Prior to the end of the day on which a derivative transaction has occurred, the Investment Manager will ascertain that: • the Control Sheet is complete; • the derivative transaction complies with this Plan, including a Company’s established quantitative and quali...
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