1.  A Manager should develop a comprehensive and integrated framework to manage trading and business operations, taking into account the size and complexity of its activities, the nature of its investment, and the requirements of its investment strategy.

1.  The framework should include:

1. policies and procedures which provide for appropriate checks and balances for the significant operational and accounting controls, including:
   • appropriate selection and management of counterparty relationships;
   • adequate management of cash, margin and collateral requirements;
   • careful selection of key service providers;
   • adequate infrastructure and operational practices;
   • adequate operational and accounting processes, including appropriate segregation of business operations and portfolio management personnel; and
   • a disaster recovery process;
2. systems, infrastructure and automation commensurate with the scale of the business and trading operations of the Manager, including regular review of such infrastructure to assess operational risks in light of both internal and external changes; and
3. a member of senior management, such as a Chief Operating Officer or person with similar responsibilities, with responsibility for the Manager’s business operations, supported by internal personnel or, where applicable, external resources, with skills appropriate to the complexity of the Manager’s business operations. This role and the operational areas of the firm should coordinate and work in partnership with the investment professionals and senior management.

2.  The Manager should develop infrastructure and operational practices tailored to its business. Requirements for the infrastructure needed will vary depending on the types of investments, frequency of trading, and the need for manual processing, as opposed to the availability of automated systems.

2.  No applicable guidance.