Our Firm PGIM Global Partners (“PGP”) is the name under which Prudential International Investments
Advisers, LLC (“PIIA”), an SEC registered investment adviser organized as a Delaware
limited liability company, does business. PGIM Global Partners has been in business since
2005. When we use the terms “we,” “us,” and “our” in this brochure, we are referring to
PGIM Global Partners. In addition, any reference to “our employees” or “our officers” means
PGIM Global Partners employees or officers.
PGIM Global Partners is a direct, wholly-owned subsidiary of Prudential International
Investments, LLC (“PII”) and an indirect, wholly-owned subsidiary of Prudential Financial,
Inc. (“Prudential Financial”)1, a publicly held company (NYSE Ticker "PRU").
Our Advisory Business in General PGIM Global Partners offers discretionary investment management services; and, non-
discretionary model portfolios and advisory services, including investment management
services for equity and fixed income portfolios and asset allocation strategies all of which are
delegated to affiliated and non-affiliated sub-advisers.
PGIM Global Partners provides advice on the selection of sub-advisers to affiliated entities, as
requested or necessary. PGIM Global Partners’ initial identification and review of advisers
include coordination with each client’s investment and product teams. The review and
recommendation process is principally focused on a quantitative and qualitative analysis of
each sub-adviser’s strategy, investment process, team, and performance.
PGIM Global Partners has three client relationships with two affiliated offshore investment
managers for certain offshore domiciled investment products and one unaffiliated Italian bank
for investment of proprietary capital.
• PGIM Global Partners’ primary client is our affiliate, Pramerica SGR S.p.A.
(“Pramerica SGR”). Pramerica SGR is a joint venture between Unione di Banche
Italiane S.p.A. (“UBI Banca”) and Prudential International Investments Company,
LLC (“PIIC”), an indirect, wholly-owned subsidiary of Prudential Financial. PGIM
Global Partners acts as a non-discretionary investment adviser to individual client
accounts of Pramerica SGR. PGIM Global Partners delegates the provision of these
services to an affiliated sub-adviser, QMA LLC (“QMA”), through a separate sub-
advisory agreement. PGIM Global Partners also serves as a discretionary investment
1 Prudential Financial, Inc. of the United States is not affiliated in any manner with Prudential plc,
incorporated in the United Kingdom or with Prudential Assurance Company, a subsidiary of M&G plc,
incorporated in the United Kingdom.
manager to series of funds for Pramerica SGR and Pramerica Management Company
S.A., a wholly-owned subsidiary of Pramerica SGR. PGIM Global Partners delegates
the provision of these services to affiliated sub-advisers through separate sub-advisory
agreements.
• PGIM Global Partners’ second client is our affiliate, Prudential Financial Securities
Investment Trust Enterprise (“PGIM SITE”), which is an indirect, majority-owned
subsidiary of Prudential Financial. PGIM Global Partners acts as a non-discretionary
investment adviser to PGIM SITE. PGIM Global Partners delegates the provision of
these services to QMA, an affiliated sub-adviser, through separate sub-advisory
agreements.
• PGIM Global Partners’ third client is UBI Banca, the joint venture partner described
above. PGIM Global Partners acts as a non-discretionary investment adviser to UBI
Banca for the investment of UBI Banca proprietary capital in emerging market fixed
income securities. PGIM Global Partners delegates the provision of these services to
QMA, an affiliated sub-adviser, through a separate sub-advisory agreement.
Additional information about these client relationships can be found in Item 10.
Our Assets Under Management As of December 31, 2019, our assets under management were as follows:
• Discretionary:
$6,749,278,799
• Nondiscretionary: $0
The amount disclosed under “Assets Under Management” does not include any assets for
which PGIM Global Partners provides non-discretionary investment advisory services,
because PGIM Global Partners does not provide continuous and regular supervisory or
management services in relation to such assets.
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Advisory Fees We negotiate fees with our clients individually. Fees paid by clients vary based on factors,
such as the type of advice provided, the size of the client account, the investment strategy,
the relationship with the client, and the required level of service. Fees may also differ based
on account type. Since fees are negotiable, clients with similar characteristics, investment
objectives or strategies may pay different fees.
Payment of Fees Depending on the client’s preference, advisory fees are billed to the client and are typically
payable monthly in arrears.
We neither require nor solicit clients to pay advisory fees in advance. If a client were to pay
advisory fees in advance and the client’s advisory contract were terminated before the end of
a billing period, we would refund any unearned, prepaid fees on a pro rata basis.
Other Amounts Payable by Clients Our advisory fees are the only amounts payable by clients to PGIM Global Partners. PGIM
Global Partners pays fund sub-advisers out of PGIM Global Partners’ advisory fees according
to multi-year contracts. Advisory fees may only be changed by written amendment and
agreement with impacted clients.
Clients are generally responsible for other fees and expenses related to their accounts,
including custodian fees, brokerage fees, and other transaction costs.
Other Compensation Neither PGIM Global Partners nor its supervised persons receive any compensation directly
related to the sale of securities or other investment products.
Compensation of Our Investment Professionals PGIM Global Partners’ investment professionals are compensated through a combination of
base salary, a performance-based annual cash incentive bonus, and an annual long-term
incentive grant.
An investment professional's incentive compensation, including both the annual cash bonus
and long-term incentive grant, is determined by considering (i) such person's contribution to
the selection, review, and monitoring of potential and/or existing sub-advisors and (ii)
qualitative contributions to the organization, and (iii) the financial results of the business. The
incentive compensation of each investment professional is not based on the performance of, or
the value of assets in, any single account or group of client accounts. The long-term incentive
grants are subject to vesting requirements.
Prudential Human Resources regularly benchmarks its total compensation program against
leading asset management firms to monitor our competitiveness.
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PGIM Global Partners does not currently receive any performance-based fees (fees based on a
share of capital gains on or capital appreciation of the assets of a client). PGIM Global Partners
does not engage in side-by-side management (PGIM Global Partners does not manage
accounts with asset-based fees alongside accounts with performance-based fees).
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Our clients (as discussed in Item 4 and Item 10) are affiliated offshore investment managers
for certain offshore domiciled investment products and an unaffiliated Italian bank for non-
discretionary advice on investment of proprietary capital. Products include investment trusts,
UCITS funds (used here to refer to collective investment schemes permitted under the
European Union Directives known as Undertakings for Collective Investment in Transferable
Securities Directives), and SICAVs (société d'investissement à capital variable, a type of
collective investment scheme). These products are not subject to provisions of the Investment
Company Act of 1940 of the U.S. Generally, we do not require a minimum account size.
However, we may review account size when considering the investment vehicle and
characteristics of a mandate.
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PGIM Global Partners provides advice on the selection of sub-advisers to affiliated entities,
as requested or necessary, and in consultation with each client’s investment and product
teams. The following describes PGIM Global Partners selection and monitoring
methodology. While there are risks associated with PGIM Global Partner’s selection and
monitoring of affiliated or unaffiliated sub-advisers, for specific risks associated with our
sub-adviser’s methodologies and strategies, clients should refer to the specific sub-adviser’s
Form ADV Part 2A or other regulatory disclosure documents.
PGIM Global Partners’ review and recommendation process is principally focused on a
quantitative and qualitative analysis of each potential sub-adviser’s strategy, investment
process, team, and performance. With respect to the selection of sub-advisers, PGIM Global
Partners obtains performance returns for the investment universe under consideration for a
new mandate and each fund or strategy is ranked based on performance, risk adjusted returns,
and volatility of returns to score the potential sub-advisors.
Based on this initial criteria, certain managers are asked to complete a request for proposal
questionnaire which covers a broad range of investment related topics as well as sections on
Compliance, Legal, Operations, and Operational Risk and we hold a conference call with
each sub-adviser candidate to review the respective questionnaires and discuss any questions
identified through the RFP process.
A written report for each potential sub-advisor is prepared and reviewed by the PGIM Global
Partners CEO and a final report is sent to the client. The final report to the client includes the
recommended sub-adviser.
With respect to ongoing monitoring, sub-adviser performance is reviewed on a monthly basis
relative to the respective benchmark and peer group of the strategy and may result in
discussions with the portfolio management team if necessary. On a quarterly basis, a
performance analysis report is prepared, documenting performance drivers and any
highlighted issues are discussed with the sub-adviser.
On an annual basis, PGIM Global Partners conducts a due diligence review of the sub-
advisers with PGIM Global Partners Compliance, Operations, Operational and Investment
Risk collaborating on a review of the delegated managers.
The review of the sub-advisers conducted by each functional area is done through a series of
questions/data requests with a written report with findings/conclusions presented to the
PGIM Global Partners Board of Directors at the annual Board meeting.
Certain Risks Related to Cybersecurity and Technology.
Investment advisors, including PGIM Global Partners, must rely in part on digital and network
technologies to conduct their businesses and to maintain substantial computerized data relating
to client account activities. These technologies include those owned or managed by ourselves
as well as those owned or managed by others, such as custodians, financial intermediaries,
transfer agents, and other parties to which we or they outsource the provision of services or
business operations.
Like all businesses that use computerized data, we and our affiliates and the systems we use
might in some circumstances be subject to a variety of possible cybersecurity incidents or
similar events that could potentially result in the inadvertent disclosure of data to unintended
parties, or the intentional misappropriation or destruction of data by malicious hackers
mounting an attack on computer systems. We and our affiliates have implemented and
maintain an information technology security policy and program that includes certain technical
and physical safeguards intended to protect the integrity, availability and confidentiality of the
data we have and the systems that store it and take other reasonable precautions to limit the
potential for cybersecurity incidents, and to protect data from inadvertent disclosure or
wrongful misappropriation or destruction.
Nevertheless, despite reasonable precautions, cybersecurity incidents could occur, and might
in some circumstances result in unauthorized access to sensitive information about us or our
clients. In addition, such incidents might cause damage to client accounts, data, systems or
affect client services.
Furthermore, these systems may fail to operate properly or become disabled as a result of
events or circumstances wholly or partly beyond our or others’ control. Technology failures,
whether deliberate or not, including those arising from use of third-party service providers or
client usage of systems to access accounts, could have a material adverse effect on our business
or our clients and could result in, among other things, financial loss, reputational damage,
regulatory penalties or the inability to transact business.
General Investment Risk A more detailed discussion of the specific risks associated with investing in a particular product
offered by us may be found in the offering documents for such product, which is available
upon request. However, it is impossible to identify all of the risks associated with investing
and the particular risks applicable to an investment will depend on the nature of the client, its
investment strategy and the types of investments held. While we seek to manage accounts so
that the risks are appropriate to the strategy, it is impossible or not desirable to fully mitigate
risks.
Risks Related to Regulation Laws and regulations affecting our business change from time to time, and we are currently
operating in an environment of significant regulatory reform. We cannot predict the effects, if
any, of future legal and regulatory changes on our business or the services we provide.
Risks Related to Our Conflicts of Interest We are subject to various conflicts of interest in the ordinary course of our business. We strive
to identify potential risks, including conflicts of interest, which are inherent in our business,
and conduct formalized conflict of interest reviews. When actual or potential conflicts of
interest are identified, we seek to address such conflicts through one or more of the following
methods:
• elimination of the conflict;
• disclosure of the conflict; or
• management of the conflict through the adoption of appropriate policies and
procedures.
Various conflicts of interest are discussed throughout this document, including in Item 11.
Please review this information carefully and contact us if you have any questions.
We reserve the right to maintain confidentiality with respect to any and all aspects of our
processes, in our discretion, to protect our proprietary rights in our investment strategies and
processes.
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There have been no legal or disciplinary events that would be material to an evaluation of our
advisory business or the integrity of our management.
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As an indirect wholly-owned subsidiary of Prudential Financial, we are part of a diversified,
global financial services organization. We are affiliated with many types of financial service
providers, including broker-dealers, insurance companies and other investment advisers.
PGIM Global Partners has relationships and arrangements with the following affiliated
investment advisers: QMA, Jennison Associates LLC (“Jennison”), and PGIM, Inc.’s public
fixed income unit (“PGIM Fixed Income”). None of the funds described below have been
registered under the Investment Company Act of 1940 and no fund shares are offered for sale
in the U.S. or to any U.S. person (as defined under the Securities Act of 1933).
Relationships with Affiliates Pramerica SGR S.p.A. (“Pramerica SGR”)
We act as an investment adviser of our affiliate Pramerica SGR with respect to investment
funds offered and managed by Pramerica SGR in Italy. Pramerica SGR is registered with Italy's
Commissione Nazionale per le Società e la Borsa. As Pramerica SGR’s investment adviser,
we provide nondiscretionary and discretionary advisory services to several individual client
accounts of Pramerica SGR.
Nondiscretionary Advisory Services PGIM Global Partners provides its affiliate Pramerica SGR with nondiscretionary advisory
services with respect to assets managed by Pramerica SGR. PGIM Global Partners delegates
the provision of these services to QMA, an affiliated sub-adviser, though a separate sub-
advisory agreement. Pramerica SGR retains the sole and absolute discretion to make purchase
and sale decisions and retains the authority to designate brokers and dealers executing
transactions for those assets. Pramerica SGR is also responsible for all administrative,
operational, legal, compliance, accounting and audit, transfer agency, custody, reporting, and
other services relating to those assets.
Discretionary Advisory Services PGIM Global Partners serves as the discretionary investment manager to a designated series
of the Pramerica SICAV Fund (the “SICAV Fund”) in Luxembourg as well as designated
series of the Pramerica Fund (the “Pramerica Mutual Funds”) based in Italy.
The SICAV Fund is a multi-series offshore investment company with variable capital (Societe
d’ Investissement a Capital Variable) formed under the laws of the Grand Duchy of
Luxembourg. Pramerica Management Company S.A., (the “Management Company”)
organized under the laws of the Grand Duchy of Luxembourg and a wholly owned subsidiary
of Pramerica SGR, is the appointed management company of the SICAV Fund. The
Management Company has delegated its investment management function for designated
series of the SICAV Fund to PGIM Global Partners or to Pramerica SGR, which then delegates
to PGIM Global Partners. PGIM Global Partners has further delegated such function to
affiliated U.S. domiciled and registered investment advisers. As discussed above, these
affiliated sub-advisers are: QMA, Jennison, and PGIM Fixed Income.
• QMA is a sub-adviser to PGIM Global Partners with respect to Pramerica SICAV Asia
Pacific Equity Fund, Pramerica SICAV Emerging Markets Equity Fund, Pramerica
SICAV Global Equity Fund and Pramerica SICAVUS Core Equity Fund.
• Jennison is a sub-adviser to PGIM Global Partners with respect to Pramerica SICAV
USA Equity Fund and Pramerica SICAV Global Infrastructure Fund.
• PGIM Fixed Income is a sub-adviser to PGIM Global Partners with respect to
Pramerica SICAV High Yield Bond Fund, Pramerica SICAV Emerging Markets Bond
Fund, Pramerica SICAV Global Corporate Bond Fund, Pramerica SICAV Cedola
Emerging Markets Bond Fund, Pramerica SICAV Global High Yield Euro Hedged
Fund, Pramerica SICAV – Globo (Global Bond) Fund, Pramerica SICAV Global
Absolute Bond Euro Hedged, and Dynamic Bond Euro Hedged.
The Pramerica Mutual Funds are open-ended funds established and managed by Pramerica
SGR in Italy. Pramerica SGR has delegated its investment management function for designated
series of the Pramerica Mutual Funds to PGIM Global Partners. PGIM Global Partners has
further delegated such function to an affiliated U.S. domiciled and registered investment
adviser, PGIM Fixed Income.
• PGIM Fixed Income is a sub-adviser to PGIM Global Partners with respect to
Pramerica High Yield Fund, Pramerica Dollar Bond Fund, Pramerica Global Corporate
Fund and Pramerica Global High Yield (Euro Hedged) Fund.
Prudential Securities Investment Trust Enterprise (“PGIM SITE”)
PGIM Global Partners serves as nondiscretionary investment adviser to our affiliate PGIM
SITE, which is registered with Taiwan's Securities and Futures Bureau (“SFB”). PGIM SITE
is an indirect majority owned subsidiary of Prudential Financial. PGIM Global Partners
delegates the provision of these services to two affiliated sub-advisers through separate sub-
advisory agreements.
Nondiscretionary Advisory Services QMA is a sub-adviser to PGIM Global Partners with respect to: Prudential Financial SITE
Global Consumer Trends Fund, Prudential Financial SITE Global Resources Fund, Prudential
Financial SITE Latin America Fund, Prudential Financial SITE European Selection Fund,
Prudential Financial SITE Emerging Market Selection Fund, and Prudential Financial SITE
Asia Pacific Fund.
Jennison Associates is a sub-adviser to PGIM Global Partners with respect to the Prudential
Financial SITE Global Bio-Health Fund.
• PGIM Global Partners also advises PGIM SITE with respect to the selection of
unaffiliated sub-advisers for several other PGIM SITE Funds.
Other Clients PGIM Global Partners also provides non-discretionary advisory services to our unaffiliated
client, UBI Banca, with respect to proprietary assets of UBI Banca. PGIM Global Partners
delegates the provision of these services to QMA, an affiliated sub-adviser through a separate
sub-advisory agreement. Such advice includes model portfolios, research, and selection of
individual issues within the investment universe for emerging market sovereign debt. UBI
Banca retains the sole and absolute discretion to make purchase and sale decisions and retains
the authority to designate brokers and dealers executing transactions for those assets. UBI
Banca is also responsible for all administrative, operational, legal, compliance, accounting and
audit, transfer agency, custody, reporting, and other services relating to those assets.
Conflicts Related to Our Affiliations Board Membership/Dual Officer Status
Prudential Financial, the ultimate parent company of PGIM Global Partners, holds a 35%
ownership interest in Pramerica SGR through its subsidiary, PIIC. As set forth further above,
Pramerica SGR is also a PGIM Global Partners client. One of PGIM Global Partners’
representatives serves as a member of Pramerica's board of directors. Pursuant to written
controls and agreements among all of the parties, no employees or officers of PGIM Global
Partners are permitted to participate in any Pramerica SGR board discussions or voting which
may involve PGIM Global Partners.
Other Conflicts
As discussed in Item 4 and Item 8, PGIM Global Partners provides advice concerning the
selection of sub-advisers to our clients. PGIM Global Partners’ search process may include
the evaluation and recommendation of affiliated and unaffiliated sub-advisers. PGIM Global
Partners has and may continue to recommend that an affiliate act as a sub-adviser.
Furthermore, PGIM Global Partners applies a similar process in its evaluation of an affiliate
or non-affiliate sub-adviser. PGIM Global Partners’ initial identification and review of
advisers will include coordination with each client’s investment and product teams. The
review and recommendation process is principally focused on a quantitative and qualitative
analysis of each sub-adviser’s strategy, investment process, team, and performance.
A final written recommendation report is shared with each client’s investment and product
teams for their consideration and due diligence. Clients always retain discretion over the sub-
advisers selected. In some instances, our clients will specifically direct us to select among our
affiliated sub-advisers. Although our process may be adjusted to accommodate the client's
wishes, our review and recommendation process remains principally the same in its focus on
analysis of strategy, process, capabilities, and performance.
Regarding replacing sub-advisers, PGIM Global Partners oversees an annual quantitative and
qualitative review of sub-advisers which is presented to the PGIM Global Partners Board of
Directors and used to make recommendations to clients accordingly. Clients can also initiate
an evaluation of sub-advisers. Clients always retain discretion over replacing a sub-adviser.
Conflicts Related to Our Financial Interests and the Financial Interests of Our Affiliates We, Prudential Financial, and other affiliates of ours, at times have financial interests in, or
relationships with, companies whose securities we hold, purchase or sell in our client
accounts. Certain of these interests and relationships are material to us or to the Prudential
enterprise. At any time, these interests and relationships could be inconsistent or in potential
or actual conflict with positions held or actions taken by us on behalf of our client accounts.
For example:
• We or our sub-advisers invest in the securities of one or more clients for the accounts
of other clients.
• Our affiliates sell various products and/or services to certain companies whose
securities our sub-advisers purchase and sell for our clients.
• We or our sub-advisers invest in the debt securities of companies whose equity is held
by affiliates.
• Our affiliates hold public and private debt and equity securities of a large number of
issuers. We or our sub-advisers invest in some of the same issuers for our client
accounts but at different levels in the capital structure. For example:
o Affiliated accounts can hold the senior debt of an issuer whose subordinated
debt is held by our clients or hold secured debt of an issuer whose public
unsecured debt is held in client accounts. In the event of restructuring or
insolvency, the affiliated accounts as holders of senior debt may exercise
remedies and take other actions that are not in the interest of, or are averse to,
other clients that are the holders of junior debt.
o To the extent permitted by applicable law, we or our affiliated sub-advisers
can also invest client assets in offerings of securities the proceeds of which are
used to repay debt obligations held in affiliated accounts or other client
accounts. Our interest in having the debt repaid creates a conflict of interest.
Prudential has a refinancing policy to address this conflict.
In general, conflicts related to the financial interests described above are addressed by the
fact that we or our affiliated sub-advisers make investment decisions for each client
independently considering the best economic interests of such client.
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Trading
Code of Ethics We maintain a code of ethics as required by applicable SEC rules. Our code of ethics requires
employees to conduct business in an honest and forthright manner in accordance with the
highest ethical standards. In addition, the code of ethics requires employees to put client
interests ahead of our own and disclose actual and potential significant conflicts of interest.
The code of ethics incorporates our information barrier and personal securities trading policies
that are described in greater detail below. PGIM Global Partners employees’ outside business
activities are required to be approved in advance by the employee’s supervisor and law and
compliance units. Generally, PGIM Global Partners employees are not permitted to invest in
outside businesses which directly compete with PGIM Global Partners. Our employees are
required to promptly report any violation of the code of ethics to our Chief Compliance Officer.
We will provide a copy of our code of ethics to clients or prospective clients upon request.
Information Barrier Policy PGIM Global Partners’ information barrier policy and support procedures are designed to
prevent the communication of material, non-public information across the firm and to mitigate
the potentials for breaches to the information barrier. Under the policy, an employee may not
communicate material, non-public information to another employee without approval from the
law and compliance units. In addition, employees sign a document evidencing receipt of the
policy and attest that they understand it. All PGIM Global Partners employees must undergo
initial and annual training and subsequently attest to their understanding of the policy and the
Chief Compliance Officer approval must be obtained for any exceptions to the policy.
Our policy requires that we maintain a restricted list of any issuers about which we have
material, non-public information.
Personal Securities Trading Standards Personal trading by our employees may create a conflict when they are trading the same
securities or types of securities as our sub-adviser’s trade on behalf of our clients. Our code of
ethics incorporates Prudential Financial’s personal securities trading standards which are
intended to address some of these conflicts. The standards include a trade pre-clearance
requirement that enables our compliance unit to determine whether the proposed trade by an
employee conflicts with a pending trade on behalf of a client account. If it does, the employee
will not be allowed to transact in that security.
PGIM Global Partners’ personal securities trading policy governs the trading activities of our
employees as well as their household members and dependents. Subject to certain limited
exceptions, employees are required by the policy to:
• report personal securities transactions to our corporate compliance unit;
• pre-clear personal securities transactions (for employees considered to be “access
persons” under SEC rules);
• maintain brokerage accounts only with certain approved brokers that report transaction
information to our corporate compliance unit; and
• annually report securities holdings to our corporate compliance unit.
Our access persons and investment personnel are subject to additional restrictions under the
policy, including the following:
• investment personnel are generally prohibited from purchasing securities in initial
public offerings;
• investment personnel are prohibited from trading any security within seven days before
or after we trade such security (or an equivalent security) for client accounts (other than
in client accounts that replicate a broad-based index);
• investment personnel must disgorge any profits from the purchase and sale (in
whatever order) of the same security within 60 days;
• access persons may not trade any security on the same day that we trade such security
(or an equivalent security) for client accounts (other than in client accounts that
replicate a broad-based index); and
• access persons may not write naked call options or buy naked put options on a security
held in a client account.
All employees must annually confirm that they have read and understand our code of ethics,
including the personal securities trading and information barrier policies.
Gifts and Entertainment Policy Our employees may occasionally give or receive gifts, meals or entertainment of moderate
value, subject to compliance with applicable laws and regulations. PGIM Global Partners has
adopted gift and entertainment standards to address the conflicts of interest related to gifts and
entertainment, such as the appearance of having given or received something of value that
influenced our business decisions or the business decisions of our clients. The policy requires
the reporting and preclearance of gifts, meals and entertainment given or received which
exceed certain thresholds, with additional procedures in place to ensure compliance with (i)
ERISA regulations, (ii) the Foreign Corrupt Practices Act (“FCPA”), and (iii) rules related to
employees of local, state or federal governments. In addition, our employees are prohibited
from soliciting the receipt of gifts, meals or entertainment. Senior management periodically
reviews summaries of gifts and entertainment activity to detect trends of abuse, conflicts of
interest, or possible violations of the standard.
Political Contributions Policy Due to the potential for conflicts of interest, Prudential Financial and PGIM Global Partners
have established standards, policies and procedures relating to political contributions that are
designed to comply with applicable federal, state and local law. Under PGIM Global Partners’
political contributions policy, all employees (including spouses and dependent children) must
obtain preapproval before making any political contributions.
Conflicts Relating to Our Investments PGIM Global Partners may hold different opinions on the investment merits of a given
sector, country, or industry than that developed and published by an affiliate. Conversely, our
affiliates research may recommend to our clients, an investment out of the same sector,
country, or industry for which a different affiliate may be recommending or executing an
investment into (including an investment in a particular security).
Conflicts Related to Outside Business Activity From time to time, certain of our employees or officers may engage in outside business activity,
including outside directorships. Any outside business activity is subject to prior approval
pursuant to our personal conflicts of interest and outside business activities policy. Actual and
potential conflicts of interest are analyzed during such approval process. We could be restricted
in trading the securities of certain issuers in client portfolios in the unlikely event that an
employee or officer, as a result of outside business activity, obtains material, nonpublic
information regarding an issuer.
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Brokerage Selection/Recommendations Subject to our advisory agreements, we have also delegated to those sub-advisers the authority
to select broker-dealers. For example, under the terms of the discretionary management and
sub-advisory agreements relating to the select sub-funds of the SICAV Fund, PGIM Global
Partners and our affiliated sub-advisers are authorized to manage the investments of each sub-
fund. Under each agreement, PGIM Global Partners and/or our affiliated sub-advisers are
subject to certain parameters as to the brokers or dealers that may be utilized.
Soft Dollars and Research Services Currently, PGIM Global Partners does not execute trades with any brokers and does not enter
into any third party or proprietary soft dollar arrangements where a broker-dealer provides
research services in exchange for an expectation of receiving a certain dollar amount of
commissions.
Affiliated sub-advisers that manage portfolios of the SICAV Fund and the Pramerica Mutual
Funds have their own policies and practices with respect to brokerage, as described in the
relevant advisers’ Form ADV brochure.
Brokerage for Client Referrals We do not select or recommend broker-dealers.
Directed Brokerage Currently, PGIM Global Partners does not select, recommend, or execute trades with any
brokers.
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PGIM Global Partners periodically reviews client accounts. Our investment professionals led
by the Chief Executive Officer reviews each portfolio’s performance against relevant peer
groups and benchmarks on a quarterly, annual, and a longer-term basis. The investment
professionals share a quantitative and qualitative analysis of the sub-advisers’ investment
activity and fund’s performance with the client as needed and upon request. In addition, the
investment professionals review monthly and quarterly reports prepared by the sub-advisers.
Pursuant to our advisory agreements, the sub-advisers produce and deliver written reports to
the client. These reports include monitoring of portfolio holdings in accordance with
investment policies, guidelines and objectives of the fund, and any material violations.
PGIM Global Partners investment professionals identify, evaluate, select, and monitor sub-
advisers. This may include periodic visits with investment sub-advisers. Our compliance
department works with the management review team both during initial due-diligence as well
as part of ongoing compliance monitoring. The sub-adviser selection and evaluation process
utilizes both qualitative and quantitative analysis utilizing questionnaires, detailed interviews,
on-site visits, and ongoing monitoring of portfolio performance and holdings.
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We do not receive economic benefits from anyone who is not a client in connection with the
advisory services we provide to our clients. We also do not compensate any person (who is not
our supervised person) for client referrals.
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We do not take physical custody of the assets of our clients. Client assets are held in custodial
accounts with banks, broker-dealers or other qualified custodians retained by our clients under
arrangements negotiated by them.
Our clients will receive account statements from their custodians on at least a quarterly basis
and are advised to carefully review those statements.
A client’s custody agreement with its custodian may contain authorizations with respect to
the transfer of client funds or securities broader than those in the client’s written investment
management agreement with PGIM Global Partners. In these circumstances, PGIM Global
Partner’s authority is limited to the authority set forth in the client’s written investment
management agreement with PGIM Global Partners regardless of any broader authorization
in the client’s custody agreement with its custodian. The custodian’s monitoring, if any, of
the client’s account is governed by the client’s relationship with its custodian.
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PGIM Global Partners receives discretionary investment authority pursuant to a written
investment management or similar agreement between the client and PGIM Global Partners.
As discussed further in Item 10, we have delegated that authority to competent investment
advisers subject to client approvals.
Our discretionary authority to manage client accounts is guided by the mandate selected by the
client and any client-imposed guidelines or restrictions.
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PGIM Global Partners does not take any action with respect to the voting of proxies solicited
by, or with respect to, the issuers of any securities held in those client portfolios. PGIM Global
Partners or another delegated investment adviser may provide advice to clients regarding the
clients’ voting of proxies. For certain client portfolios, delegated investment advisers have the
responsibility to vote proxies. These advisers apply voting procedures and conflicts of interest
policies that are disclosed to the relevant clients or are otherwise made available as part of the
relevant adviser's Form ADV brochure. For certain other client portfolios, clients retain the
responsibility for receiving and voting proxies for securities maintained in such portfolios.
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Open Brochure from SEC website