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.

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.

Shareholder Rights Directive Disclosure (“SRD II”)

The Shareholder Rights Directive II (SRD II) is a European Union (EU) directive, which sets out to strengthen the position of shareholders. SRD II also establishes specific requirements to encourage shareholder engagement. Click here for the SRD II 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 and Article 63-4 of the Financial Instruments and Exchange Act of Japan.

Please contact [email protected] to request such documents.

日本において届出を行っているアレスのファンドに関して、金融商品取引法第63条及び第63条の4に基づき公衆縦覧に供すべき書類を提供致します。当該書類が必要な方は

[email protected] までお問い合わせ下さい。

Sustainable Financial Disclosure Regulation ("SFDR")

The Sustainable Financial Disclosure Regulation (“SFDR”) is a European Union (EU) Regulation, which lays down harmonised rules for financial market participants and financial advisers on transparency with regard to the integration of sustainability risks and the consideration of adverse sustainability impacts in their processes and the provision of sustainability‐related information with respect to financial products.

Click here for Ares Management Luxembourg’s SFDR Statement.

UK Investment Firms Prudential Regime

Each of Ares Management Limited, Ares Management UK Limited and Ares European Loan Management LLP are required to comply with the UK Investment Firms Prudential Regime. As part of that regime, certain public disclosures are required to be made available publicly.

Please click here for Ares Management Limited’s Disclosure Statement.

Please click here for Ares Management UK Limited’s Disclosure Statement.

Please click here for Ares European Loan Management LLP’s Disclosure Statement.

UK TCFD (Task Force on Climate-related Financial Disclosures) Reporting

In line with the requirements set out by the UK FCA (Financial Conduct Authority) within the ESG Sourcebook in the FCA’s Handbook of Rules and Guidance, Ares Management Limited (“AML”) and Ares Management UK Limited (“AMUKL”) (together referred to as the “UK Entities”) have published a combined UK TCFD statement. The UK TCFD Statement only includes disclosures specific to the UK Entities' TCFD In-Scope Business.

Please click here for the UK TCFD Statement

Luxembourg Complaints Handling Policy

Ares Management Luxembourg is subject to the prudential supervision of the Luxembourg financial services regulator, the Commission de Surveillance du Secteur Financier (the “CSSF”), and as such has put in place a robust complaints handling policy in order to ensure full compliance with all provisions of CSSF Regulation N° 16-07 and any subsequent legislation or regulation.
Please click here for Ares Management Luxembourg’s Complaints Handling Policy.

Luxembourg Whistleblowing Policy and Whistleblowing Reporting System

Ares Management Luxembourg has put in place the necessary internal procedures and communication channels to allow direct and confidential reporting about breaches that have been identified in a professional context. Please click here for an overview of Ares Management Luxembourg’s Whistleblowing Policy and Whistleblowing reporting system.

Transparency in Coverage

This link leads to the machine-readable files that are made available in response to the federal Transparency in Coverage Rule and includes negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers. The machine-readable files are formatted to allow researchers, regulators, and application developers to more easily access and analyze data.