Santiago Principles Self-Assessment

Investment Corporation of Dubai

Fund Details Fund Website Search Assessments PDF version
  • Pillar 1: Legal
  • Pillar 2: Institutional
  • Pillar 3: Investment
Principle 1

1. The legal framework for the SWF should be sound and support its effective operation and the achievement of its stated objective(s).

1.1. The legal framework for the SWF should ensure legal soundness of the SWF and its transactions.

1.2. The key features of the SWF’s legal basis and structure, as well as the legal relationship between the SWF and other state bodies, should be publicly disclosed.

The Investment Corporation of Dubai ("ICD") is an entity wholly owned by the Government of Dubai (the "Government"). It was established in Dubai on 3 May 2006 under Law No. (11) of 2006 "Establishing the Investment Corporation of Dubai" issued by H.H. Sheikh Mohammed Bin Rashid Al Maktoum, Vice President and Prime Minister of the United Arab Emirates (“UAE”) and The Ruler of Dubai.

Law No. (11) of 2006 provides ICD with financial and administrative autonomy and the full capacity required to achieve its objectives in accordance with the laws, decrees, and regulations issued by the Government.

Law No. (11) of 2006 sets out the functions and responsibilities of the entity, the governing entity and the management. 

Law No. (11) of 2006 is publicly available on the Dubai Legislation Portal.

Principle 6

6. The governance framework for the SWF should be sound and establish a clear and effective division of roles and responsibilities in order to facilitate accountability and operational independence in the management of the SWF to pursue its objectives.

ICD's Board has oversight of the organisation’s corporate governance affairs and related policies and procedures. It is responsible for the stewardship of ICD, seeking to ensure that ICD’s investment management and operational arrangements are functioning effectively. 

The Board is composed of a Chairman, a Deputy Chairman, the Managing Director, and other Board members who are appointed by a Decree of the Ruler of the Emirate of Dubai. The composition of the Board of  Directors is disclosed in ICD’s Annual Report. 

Law No. (11) of 2006 provides for ICD to establish and implement a strategy to invest the assets of the Government.  

Law No. (11) of 2006 further provides for the Managing Director to be responsible to the Board of Directors for the implementation of the general policy of ICD, the efficiency of its bodies, and to manage ICD and supervise its affairs.  

The Board has put in place appropriate delegations for the management of the operations of ICD. Delegated authority allows for the efficient day-to-day management of ICD and promotes responsibility and accountability. 

The management of ICD’s investment and operational activities is conducted by investment and related professionals who act independently from day-to-day government activities. 

The Government of Dubai is not involved in the investment or operating decisions taken by ICD or its portfolio companies or subsidiaries, save in the capacity as a regulator or in relation to legal or regulatory matters.

A number of Committees support the overall Board and  Management Governance Framework as outlined below: 

The Investment Committee comprises three Board members. The Investment Committee is primarily responsible for the review and recommendation to the Board of ICD’s investment strategy, oversight of the performance of investments made by ICD, and approval of investment transactions. 

The Audit Committee comprises four Board members. The Audit Committee is primarily responsible for the oversight of ICD’s financial reporting and the audit process, its system of internal control, and its process for monitoring compliance with applicable standards, laws and regulations. 

The Remuneration Committee comprises three Board members. The Remuneration Committee is primarily responsible for the review and approval of the remuneration of executive directors, oversight of ICD’s compensation and benefits plans, and the review and approval of the corporate performance-related objectives of ICD. 

The Management Committee comprises the senior management team of ICD and has the responsibility for overseeing its day-to-day operations. 

The Risk Management Committee is comprised of all department heads and is primarily responsible for recommending and overseeing the implementation of a  sound risk management framework. This committee provides guidance to ICD departments in their efforts to enhance internal control systems and processes necessary to ensure risks are effectively managed. 

The ESG Management Committee is comprised of three members of ICD’s management team and performs an oversight and monitoring role in relation to ICD’s management of its own ESG responsibilities and the implementation of ICD’s ESG framework and strategy.


Principle 18

18. The SWF’s investment policy should be clear and consistent with its defined objectives, risk tolerance, and investment strategy, as set by the owner or the governing body(ies), and be based on sound portfolio management principles.

18.1. The investment policy should guide the SWF’s financial risk exposures and the possible use of leverage.

18.2. The investment policy should address the extent to which internal and/or external investment managers are used, the range of their activities and authority, and the process by which they are selected and their performance monitored.

18.3. A description of the investment policy of the SWF should be publicly disclosed.

ICD’s investment policy is outlined within the mission statement: to invest in attractive opportunities to achieve appropriate risk-adjusted returns over the long term by partnering with high-quality managers and investors and engaging responsibly and sustainably across a range of asset classes, sectors and geographies. 

ICD’s investment strategy is derived from the mandate given in its governing law to: 

  1. Consolidate and manage the existing portfolio of companies and investments of the Government of Dubai; 
  2. Provide financial and strategic oversight of the portfolio in order to preserve wealth and grow value sustainably; and 
  3. Efficiently deploy and recycle capital by making new investments, either locally, if commercially sound and strategically aligned, or internationally, to enhance returns and diversification. 

Significant progress was made with regard to the first part of this mandate in ICD's early years. The composition of the core portfolio has remained relatively stable whilst achieving growth and performing well over cycles. 

For some time now, ICD’s focus has been directed towards portfolio management and capital deployment, both critical to the successful second limb of the mandate. 

In recent years, as a natural evolution of the strategy, ICD has increasingly emphasised capital deployment in international markets and in diversifying asset classes to enhance the long-term risk-adjusted return potential of ICD’s investment portfolio. 

ICD’s approach to asset allocation and investment selection is underpinned by the following features: 

  • The maintenance of a high level of visibility on ICD’s short and long-term cash flows and funding requirements to support robust capital budgeting, giving consideration to existing commitments, the effective build-out of long-term investment themes, and well-timed capital recycling; 
  • A clear framework for capital allocation across asset classes and sectors internationally; 
  • A willingness to partner with external managers to secure the best access to high-quality investments globally; 
  • The continuous review and calibration of market dynamics and industry trends to develop views  on asset classes and sector attractiveness, encourage the development of new investable hypotheses and shape the approach to possible allocation; and 
  • Professional and efficient transaction execution balancing thoughtful and quality execution with nimbleness and an ability to respond to opportunities with appropriate speed. 

Taking these features into consideration, asset allocation is determined by balancing commitments to strategic initiatives, support of portfolio companies, capital recycling events and new investments in target verticals. 

Whilst investments in Dubai have historically favoured a significant degree of influence and active engagement, our approach to international investments leverages the expertise of highly credentialed external managers offering access to the target asset classes, sectors, and geographic markets. 

ICD aims to strike a balance between strong conviction in investment decisions based on sector knowledge and deep due diligence and diversification of exposure and reliance on external managers. 

ICD’s approach is to carefully select and partner with external managers with established track records in the relevant sector through fund commitments and co-investments. ICD looks for partners with well-tested strategies and a history of superior risk-adjusted performance. ICD ultimately seeks exposure to companies with strong market positions, capable management teams, leading products and services, and clear roadmaps for value creation.  

ICD, from time to time, may solicit third-party funding to support its activities. ICD monitors and manages this leverage conservatively through objectives set within  ICD’s investment, risk and governance frameworks.