Investment Policy & Strategy Management Lawyers for Funds & Family Offices
One written investment policy, one operating document & investor disclosure kept consistent with both, drafted & maintained by our specialist funds lawyers.
- One written investment policy covering strategic, tactical & dynamic asset allocation, asset selection, liquidity, valuation & reporting
- One operating document recording who does what & what happens when someone leaves
- Information memorandum, website & factsheets reviewed for consistency & s1041H exposure each time the fund changes
- Investment committee charter, constraints & service provider reviews maintained as the portfolio moves
Our Investment Policy & Strategy Management Services
Trustees & managers of wholesale funds remain subject to s1041H of the Corporations Act 2001 (Cth), which prohibits misleading or deceptive conduct in relation to a financial product or financial service, and an accurate information memorandum does not necessarily address an inaccurate or misleading statement made elsewhere. GRM LAW documents the investment policy a fund or family office runs on, the operating document behind it & the coordination layer that keeps investor materials consistent with both, including:
01. The Written Investment Policy
We draft one written investment policy that records how capital is allocated & how each investment decision is tested before it is made, covering:
- Strategic, tactical & dynamic asset allocation (SAA thematics, TAA adjustment tilts, DAA anomalies) & how each shapes portfolio risk, expected return & Sortino ratio.
- Asset selection, acquisition & divestment protocols, divestment scenario testing, constraints & diversification and concentration limits.
- Debt deployment, risk management strategy, cyber security, asset valuation management, liquidity management & stress testing, portfolio reporting & service provider management and review.
02. Operating Document, Committee Charter & Continuity
We prepare the operating document & investment committee charter that say who decides what, on which models, & what happens when someone leaves, including:
- Drafting the investment committee charter, delegations & constraints, & recording the investment management model, development feasibility model & go/no-go model the committee works from.
- Recording roles, responsibilities & approval authorities across the manager, trustee, committee & service providers.
- Business continuity plans covering the departure of a key person so the fund keeps operating when the person who knows how it all works steps away.
03. Disclosure Consistency & s1041H Review
We keep the information memorandum, constitution, website, factsheets & investor communications consistent with each other & with the fund as it operates, including:
- Reviewing website & marketing content against the current information memorandum & constitution each time the fund changes.
- Tracking changes to investment strategy or portfolio composition, target returns, liquidity or withdrawal arrangements, fees & distributions, valuation methodology & material risks across every investor-facing document.
- Operating a standing process for updating affected materials when disclosure changes, with each amendment reviewed & approved by GRM LAW before the client is notified.
04. Coordination Layer, Reporting & Investor Portal
We establish one coordination layer that owns the connections between the policy, the committee, service providers & investors, so the principal no longer carries the integration work personally, covering:
- Equity raising: deal marketing, data rooms, investor KYC/AML checks & an equity raising tracker.
- Active investment management: waterfall distribution calculations, capital calls & notifications, & distribution notices.
- Reporting: customisable reports for investors, the board, the compliance committee, risk committee & investment committee, & investor performance dashboards on a portal.
Who We Act For
GRM LAW’s funds & financial services lawyers document & maintain investment policy for wholesale fund operators & private capital holders across Australia, including:
Family Offices
Private wealth groups running family capital across property, credit & fund exposures who need the investment process written down & maintained.
Small Superannuation Funds
Trustees of smaller superannuation funds that need an investment policy, committee charter & reporting cycle sized to the fund.
Councils with Investment Portfolios
Local governments holding investment portfolios that need a documented policy, constraints & a service provider review process.
Small & Emerging Fund Managers
New or growing managers establishing their first investment policy, operating document & investor reporting before or after launch.
Private Credit Lenders
Lenders & credit funds documenting debt deployment, liquidity management & stress testing alongside their credit policies.
Self-Managed Superannuation Funds
SMSF trustees with substantial or concentrated holdings who want the investment strategy, constraints & valuation approach recorded.
High Net Worth Investors
Individuals & private investment companies co-investing in wholesale funds & direct assets under a defined policy.
Wholesale Fund Trustees & Managers
Trustees & managers of wholesale funds who need the information memorandum, website & factsheets kept consistent to manage s1041H exposure.
Discuss Your Investment Policy & Operating Document
Our funds lawyers will contact you to discuss your fund or portfolio & outline next steps.
What Our Clients Say
How The Process Works
01.
Scoping & Current State
We review what is written down today: the constitution, information memorandum, any existing policy, committee papers & the website & factsheets investors see.
02.
Policy & Operating Document Design
We draft the written investment policy & the operating document, working through allocation, selection protocols, constraints, liquidity, valuation, reporting & who does what.
03.
Committee Adoption & Disclosure Alignment
The investment committee adopts the policy under its charter & we bring the information memorandum, website & factsheets into line with it.
04.
Ongoing Management
Each change to strategy, target returns, liquidity or withdrawal arrangements, fees & distributions, valuation methodology or material risks is captured in the policy & carried across every investor document, with each amendment reviewed & approved by GRM LAW.
Discuss Your Investment Policy & Operating Document
Our funds lawyers will contact you to discuss your fund or portfolio & outline next steps.
Why Choose GRM LAW
01. Wholesale Funds & AFSL Governance Focus
We act for wholesale funds, private credit & property funds, responsible entities & AFSL licensees, so the investment policy sits inside the governance framework ASIC expects behind a licence.
02. Policy Tied to Disclosure
We draft the policy & align the information memorandum, website & factsheets with it in the same engagement, so the documents investors receive describe the strategy the fund runs.
03. Integrated Policy, Operating Document & Charter
The policy, operating document, committee charter & constraints are drafted as one set so they reference each other & are maintained together.
04. Continuity Built In
The operating document records who does what & what happens when someone leaves, so the fund does not depend on one person’s memory.
05. Partner-Led With National Reach
Gavin McInnes personally supervises all funds & financial services work for clients across Australia.
Meet Gavin McInnes
Gavin McInnes is the founder of GRM LAW & an Accredited Specialist in Business Law. For nearly 20 years, he has advised key players in banking, private credit, property and funds management across Australia. His practice covers AFSL governance, RG 166 financial resources & the documentation behind private credit & property funds.
Gavin personally supervises all funds & financial services work, including the drafting of investment policies, operating documents & committee charters & their alignment with each fund’s information memorandum & investor materials.
Recognition & Awards
Investment Policy & Strategy Essentials
s1041H & Investor Materials
Section 1041H of the Corporations Act 2001 (Cth) prohibits misleading or deceptive conduct, or conduct likely to mislead or deceive, in relation to a financial product or financial service, and it applies to trustees & managers of wholesale funds. ASIC has scrutinised managed fund advertising & website disclosure, including representations about investment performance & risk, and in 2022 stated that its surveillance extended to marketing directed at retail investors & potentially unsophisticated wholesale investors. An accurate information memorandum does not necessarily address an inaccurate or misleading statement made elsewhere.
Changes That Break Consistency
Inconsistency arises where a change is reflected in the fund’s formal documents but not on its website or in other investor materials. The changes that go unreflected may include investment strategy or portfolio composition, target returns, liquidity or withdrawal arrangements, fees & distributions, valuation methodology & material risks affecting the fund. An information memorandum updated for a change to the fund’s investment strategy or liquidity arrangements while the website or factsheet stays unchanged is one example.
What the Written Policy Contains
The policy records strategic, tactical & dynamic asset allocation & how each shapes portfolio risk, expected return & Sortino ratio. It sets asset selection, acquisition & divestment protocols, the investment committee charter, constraints & diversification limits, debt deployment, risk management, cyber security, valuation management, liquidity management & stress testing, portfolio reporting & service provider review. The operating document beside it records who does what & what happens when someone leaves.
Why Family Offices & Small Managers Need One
The UBS Global Family Office Report 2026 surveyed 307 family offices & found that half have a documented investment process including an investment policy statement, 37% hold a strategy or operating manual & 41% have cybersecurity controls. GRM LAW’s view is that the same gap exists in small fund management houses. The service pairs the written policy with an operating document & a coordination layer for that reason.
Discuss Your Investment Policy & Operating Document
Our funds lawyers will contact you to discuss your fund or portfolio & outline next steps.
Legal & Compliance Insights
Books By Gavin McInnes
Practical guides on structuring, asset protection and private credit in Australia.
Protect Your Assets
A plain‑English guide to protecting your home, business interests and investments under Australian law. Written for business owners, professionals and families who want to keep what they’ve built safe from avoidable risk.Â
Private Credit In Australia (Coming Soon)
A forthcoming guide to structuring, documenting and managing private credit transactions in the Australian market, written for lenders, sponsors and their advisers.Â
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