Public Pension Fund Reform Code of Conduct


Ares Management LLC ("Ares,"we," "us" or "our") became a signatory to the NYAG Public Pension Fund Reform Code of Conduct (the "Code") in February 2010. Pursuant to the Code, Ares is providing information regarding professional backgrounds of its Senior Management and other personnel whose standard professional duties include communicating with public pension fund investors and their officials, advisors, fiduciaries and employees (“Disclosure Persons”). The list of the Disclosure Persons can be found here.


In addition, Ares is providing details of certain political contributions. This campaign contribution information and other certifications related to the Code can be found by clicking here.


MiFID II Annual Best Execution Disclosure


In compliance with Article 27 of the recast Markets in Financial Instruments Directive (“MiFID II”) and the corresponding Regulatory Technical Standard 28 of the delegation regulation, Ares Management Limited has published its annual best execution disclosure, setting out quantitative and qualitative information with respect to its approach to execution. Click here for the 2017 Annual Best Execution Disclosure and here for the 2018 disclosure.


UK Stewardship Code


The Financial Reporting Council has produced The UK Stewardship Code for institutional investors. It aims to enhance the quality of engagement between institutional investors and companies to help improve long-term returns to shareholders by setting out good practice on engagement with investee companies. Click here for the UK Stewardship Code Disclosure Statement.


UK Modern Slavery Act 2015


In compliance with the UK Modern Slavery Act 2015, Ares Management Limited has published its annual Modern Slavery Act Statement, setting out the steps it has taken to endeavor to ensure that slavery and human trafficking are not taking place in its business and supply chains. Click here for the Modern Slavery Act Statement.


Financial Instruments and Exchange Act of Japan


With respect to Ares funds that are registered in Japan, Ares will provide to any member of the Japanese public a copy of such documents as are required to be made publicly available pursuant to Article 63 of the Financial Instruments and Exchange Act of Japan. Please contact [email protected] to request such documents.


金融商品取引法第63条に基づき、アレスマネジメントでは日本で届出を行っている当社が運用するファンドの目論見書やその他関連書類の公衆縦欄を必要に応じて提供致します。各ファンドの関連書類の公衆縦欄に関しては [email protected] までお問い合わせ下さい。