Allocation of Investments Policy Template (Australia)

For fund managers & AFS licensees allocating investments

$299.00 +GST

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Use this policy to:
  • Set clear rules for allocating investment opportunities fairly between products;
  • Manage conflicts when investment strategies or mandates overlap;
  • Document a rotation list for competing direct property acquisitions;
  • Assign key roles, obligations and annual review responsibilities.

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Policy document table showing version history, approval status, and review dates for an investments policy.

About this Document

Use this policy if you:
  • Manage two or more funds, mandates or portfolios whose investment strategies overlap and need a documented, fair allocation framework
  • Need to manage conflicts when a limited or capacity-constrained investment opportunity could disadvantage one Product if allocated to another
  • Manage direct property or real estate funds and want an objective rotation list for competing acquisitions
  • Operate managed discretionary accounts (MDAs) or advise clients outside your Products and need to address allocation between them
  • Are building conflicts management arrangements under s 912A(1)(aa) of the Corporations Act 2001 (Cth), aligned with ASIC Regulatory Guide 181
It is suited to:
  • Australian responsible entities and fund managers
  • AFS licensees managing two or more funds, mandates or portfolios with overlapping strategies
  • Wholesale and retail fund managers, including managers of managed discretionary accounts (MDAs)
  • Managers of one or more direct property or real estate funds
What this policy covers:
  • How to avoid conflicts when setting investment strategies and product mandates
  • The process for allocating limited opportunities between Products that do not hold direct property assets, including summary investment papers and Investment Committee decisions
  • A rotation list mechanism for allocating direct property and real estate acquisitions where investment mandates overlap
  • How to manage other conflicts, including personal trading by Our People
  • Document control, version history and a key obligations table setting out responsibilities and timing
  • A key legislation and regulatory guides reference table with live links, including the Corporations Act 2001 (Cth), ASIC Regulatory Guide 181 and ASIC Reports 820 and 823
  • An allocation decision-flow diagram and a Schedule 1 for recording each property Fund’s investment mandate and priority
  • A placeholder checklist to confirm every field has been completed before Board approval
You receive an editable Word document with placeholders for your company name, ACN, AFSL number, roles and fund details, so you can tailor it to your funds and mandates. It is a practical, lawyer-drafted starting point for documenting conflicts management, not a substitute for tailored legal advice in complex or high-risk scenarios.

How To Use This Template

This template is a starting point, not a final document. It’s been drafted by Australian lawyers to be practical and flexible, but it still needs to be reviewed and tailored for your specific business, transaction and risk profile.

Before you use it, you should:

  • Complete all placeholders, bracketed items and optional fields;
  • Remove any drafting notes or clauses that aren’t relevant to your situation; and
  • Check that party names, entity details, dates, addresses, contact details and defined terms are accurate.

Make sure the template is consistent with your other documents and obligations – including any existing contracts, policies, procedures, website terms, privacy disclosures, regulatory requirements or internal governance documents. If anything conflicts, it should be resolved before you sign, issue, adopt or implement the document.

If you are using the template as an agreement, it should be reviewed and signed by all relevant parties in accordance with applicable law and your internal signing requirements. If you are using it as a policy, procedure, notice or compliance record, it should be approved and stored under your organisation’s normal document control processes.

This template is provided as general information only and is not legal advice. Complex, high‑value, highly regulated or cross‑border matters will usually require bespoke drafting. For anything outside a straightforward use case, we strongly recommend obtaining legal advice before relying on, signing or implementing this document.

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