Conflict of Interest
The CrossBoundary Group is a frontier markets investment firm. Our mission is to unlock the power of private capital to make a strong return and a lasting difference in underserved markets.
In Pursuit Of Our Mission, The CrossBoundary Group Has The Following Primary Platforms:
- CrossBoundary Advisory (CB Advisory) facilitates private investment in Africa through our transaction advisory teams. We have advised on over $550M of closed transactions over the last several years in a wide variety of sectors including agriculture, manufacturing and infrastructure. In energy, we have three teams supporting Power Africa through the following programs: Southern Africa (SAEP), Kenya INVEST and Nigeria Power Sector Program (NPSP). These teams work on utility-scale and distributed energy transactions.
- CrossBoundary Mini-Grid Innovation Lab (CB Lab), launched in 2018 with support from the Rockefeller Foundation, prototypes and tests innovations that help mini-grids in Africa provide more power, to more people, at lower cost. It operates under the CB Advisory business. The Lab shares evidence with developers, governments, and funders so they can scale successful innovations.
- CrossBoundary Energy (CBE) is a separate legal entity. It finances solar power for large commercial and industrial businesses (typically 400 kWp+ systems). CBE has ~30MW of distributed solar assets under operation, construction or awarded across East and West Africa
- CrossBoundary Access (CB Access) is a separate legal entity. It is a blended finance facility for post-construction project finance for mini-grids. It uses impact capital to provide long-term concessional finance for first-time grid quality power to rural Africans. CBEA seeks to finance an initial 30,000 connections, serving 170,000 people, from $16M of blended capital, beginning in East Africa.
CrossBoundary Group Has Implemented Rigorous Internal Controls Across Its Teams To Protect Client Confidential Information And Mitigate Potential Or Perceived Conflicts Of Interest
CrossBoundary’s mission is to unlock the power of capital to make a strong return and a lasting difference in frontier markets. We generally believe that the advisory services performed by CB Advisory, and the arrangement and management of investments in renewable energy projects and mini-grids performed by CBE and CBEA further the CrossBoundary Group’s mission. These activities generally complement each other. Nonetheless, given that CBE and CBEA invest in geographies and sectors where CB Advisory undertakes advisory work, the CrossBoundary Group has adopted special safeguards to avoid even the appearance of Organizational Conflicts of Interest (OCI).
We recognize that playing these multiple roles in the energy sector raises potential or perceived OCI related to:
- How we share confidential data between teams, and;
- How we allocate resources (whether funding or advice).
The following section below sets out how we manage potential OCI issue with respect to both information sharing and resource allocation decisions through clear policies and procedures.
Protection Of Confidential Information:
To maintain fair competition in the business, we take affirmative steps to avoid gaining unequal access to information:
- Internal Information Controls: If CB Advisory is undertaking advisory work for a client in the same geography and sector as CBE or CBEA do or may invest in, we will institute an “Information Fire Wall” for documents and communications between the employee teams in order to reasonably restrict cross contamination. In practice, this means that each of the CrossBoundary Group’s platforms above have separate team members, separate NDAs, and restricted file and list serve access to tools such as DropBox, Slack, Group Email, and Evernotes.
- Restrictions on Use of Information: In all cases, CrossBoundary Group partners, lawyers, or employees may not use any client or vendor’s proprietary information obtained in connection with an advisory engagement to provide an unfair business advantage to CBE or CBEA in connection with any of their investment activities, or use such proprietary information for any purpose other than that for which it was furnished.
Mitigation Of Potential Or Perceived Conflicts Of Interest:
The CrossBoundary Group strictly follows the US Government regulations regarding Organizational Conflicts of Interest (OCI). In geographies and sectors where CB Advisory undertakes advisory work and either CBE or CBEA are active, CrossBoundary Group has adopted additional, special safeguards to avoid even the appearance of OCI:
- Full disclosure: We provide full disclosure to all relevant parties of any activities that any member of the CrossBoundary Group may undertake that could lead to an appearance of OCI. The CrossBoundary Group makes it a policy to (i) disclose what other work CBE and CBEA may undertake in the sector, (ii) document our information sharing restrictions policies, and (iii) seek clients’ prior informed consent to any perceived OCI when embarking on a new engagement.
- We generally keep business activities separate: CBE and CBEA are distinct and separate legal entities from CB Advisory, and from each other. As a general policy, employees other than partners or those that support all CrossBoundary Group activities such as the legal and finance departments, are assigned to either support CB Advisory or the investment platforms CBE and CBEA.
- No Concurrent Investment and Transaction/Strategic Advisory Services: Except with prior written authorization of the relevant government agency or prime contractor, both CBE and CBEA are restricted from investing in a third party while CB Advisory is providing advisory services. Following the end of an advisory engagement by CB Advisory, CBE and CBEA must observe a “cooling-off period” (typically 6 months) until they may invest in or provide direct or indirect financing to the client.
We believe we have rigorous internal controls in place to protect client confidential information and to prevent leakage of confidential information from Advisory to other CrossBoundary Group teams, as well as a stringent policy regarding potential or perceived conflicts of interest with the direct investment platforms.
We want to be a trusted partner to our stakeholders above all. Please contact [email protected] with any questions or comments.