Santiago Principles Self-Assessment®
PIF 2025
Pillar 1: Legal
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.
Palestine Investment Fund (“PIF”) was established by Presidential Decree in 2000 and formally registered in 2003 as a public shareholding company under Palestinian corporate law. Its shares are owned collectively by the Palestinian people.
PIF’s Articles of Association and Bylaws define its objectives and governance framework, outlining the roles and responsibilities of both the Board of Directors and the General Assembly.
PIF is governed by an independent Board of Directors composed of nine distinguished members—leading business figures, economists, and policymakers—appointed by the President for a three-year term. The Board is responsible for setting PIF’s strategic direction, goals, and objectives.
The General Assembly, representing the ultimate shareholder—the people of Palestine—consists of 30 independent members appointed by the President. Its members are drawn from the business community, academia, regulatory institutions, and civil society. The Assembly provides strategic oversight to the Board, approves annual reports and financial statements, appoints the external auditor, and endorses the distribution of dividends to the Palestinian Treasury.
Information regarding PIF’s structure, governance, and performance is publicly available through its annual reports and on its official website:
Principle 2
2. The policy purpose of the SWF should be clearly defined and publicly disclosed.
PIF’s primary mandate is to promote sustainable economic growth and advance private sector development in Palestine. As a development-oriented sovereign investment fund, PIF seeks to generate long-term impact by investing in strategic projects within underdeveloped sectors, while simultaneously achieving sustainable financial returns.
PIF allocates the majority of its assets to domestic investments across critical sectors of the Palestinian economy, including energy, renewable and traditional, healthcare, agriculture, infrastructure, real estate, technology, entrepreneurship, and capital markets.
PIF’s investment strategy, approved by its Board of Directors, is publicly disclosed through PIF’s annual reports and official website.
Principle 3
3. Where the SWF’s activities have significant direct domestic macroeconomic implications, those activities should be closely coordinated with the domestic fiscal and monetary authorities, so as to ensure consistency with the overall macroeconomic policies.
PIF plays a pivotal developmental role in the Palestinian economy, with a focus on strengthening the private sector and attracting both regional and international investment.
Through its investments, PIF has played a key role in job creation, developing local industries and services, strengthening the resilience of the Palestinian capital market, and supporting Palestinian GDP growth. However, given the scale and structure of these investments, their influence at the broader macroeconomic level remains limited.
Principle 4
4. There should be clear and publicly disclosed policies, rules, procedures, or arrangements in relation to the SWF’s general approach to funding, withdrawal, and spending operations.
4.1. The source of SWF funding should be publicly disclosed.
4.2. The general approach to withdrawals from the SWF and spending on behalf of the government should be publicly disclosed.
PIF was established through a one-time capital injection, consisting of commercial assets and investments previously held by the Palestinian Authority. Since its inception, PIF has relied on the returns generated from these investments to expand and grow its asset base.
At the request of the Palestinian government, the PIF Board of Directors may recommend a dividend distribution to the General Assembly. Once approved by the General Assembly, dividends are transferred to the Palestinian Treasury.
These distributions are transparently reported in the audited financial statements and disclosed in PIF’s annual reports, which are widely distributed and available on the official website.
Principle 5
5. The relevant statistical data pertaining to the SWF should be reported on a timely basis to the owner, or as otherwise required, for inclusion where appropriate in macroeconomic data sets.
Monthly and quarterly operational and financial reports are prepared for PIF’s executive management and Board of Directors to ensure effective oversight and decision-making.
PIF’s annual audited financial statements are published as part of the Annual Report. Copies are formally submitted to the Palestinian President and the Government, while also made publicly available through wide distribution and publication on PIF’s official website.
In addition, further details on financial performance and the broader economic impact of PIF’s investments are regularly disclosed and accessible on the PIF website.
Pillar 2: Institutional
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.
PIF’s Governance Manual defines the overall governance framework, outlining the roles and responsibilities at every level of the organization. It also establishes a strict authority matrix to guide the decision-making process and ensure accountability.
PIF’s governance structure is built on three main pillars:
- General Assembly: the General Assembly consists of 30 independent members representing PIF’s ultimate shareholder—the people of Palestine. Members are appointed by the President and drawn from the business community, academia, regulatory institutions, and civil society. The Assembly provides strategic guidance to the Board of Directors, approves annual reports and financial statements, appoints the external auditor, and authorizes the distribution of dividends to the Palestinian Treasury.
- Board of Directors: the Board is composed of 9 independent members, appointed by the President, including prominent business leaders, economists, and policymakers. It is responsible for setting PIF’s goals, strategic direction, asset allocation, and for overseeing overall operations.
To strengthen its oversight, the Board operates through specialized committees, including the governance committee, audit and risk committee, investment committee, and human resources committee. - Executive Management: the Executive Management team is responsible for executing PIF’s strategy and managing daily operations. The team reports directly to the Board of Directors, ensuring alignment between strategic objectives and operational performance.
Principle 7
7. The owner should set the objectives of the SWF, appoint the members of its governing body(ies) in accordance with clearly defined procedures, and exercise oversight over the SWF’s operations.
PIF’s Articles of Association, Bylaws, and Governance Manual set out the criteria and procedures for appointing the Board of Directors, the General Assembly, and the Executive Management (in line with GAPPs 1 and 2).
PIF’s annual reports, including audited financial statements, are formally submitted to the President and relevant governmental bodies, and are also published on PIF’s official website to ensure transparency and public accessibility.
In addition, PIF’s operations are subject to oversight by the State Audit and Administrative Control Bureau, which reports directly to the President, the Government, and the Legislative Council.
Principle 8
8. The governing body(ies) should act in the best interests of the SWF, and have a clear mandate and adequate authority and competency to carry out its functions.
PIF’s Articles of Association, Bylaws, and Governance Manual clearly define the authorities, roles, and responsibilities of the Board of Directors, the General Assembly, and the Executive Management.
The Board of Directors is entrusted with a clear mandate, equipped with adequate authority, and the necessary competencies to effectively discharge its functions. Its responsibilities include, among others:
- Establishing PIF’s strategic goals, objectives, and corporate policies;
- Reviewing and approving the long-term strategy and annual business plans;
- Evaluating PIF’s +initiatives, programs, and subsidiaries regularly;
- Approving company-wide policies, authority matrices, the code of conduct, and governance, transparency, and disclosure frameworks;
- Monitoring the performance of executive management;
- Approving investment and procurement decisions in line with the Authority Matrix;
- Ensuring compliance with laws, regulations, and ethical standards;
- Addressing and resolving any conflicts of interest at both Board and executive management levels.
The Board discharges its duties with the support of several specialized committees, which enhance oversight and ensure effective governance.
The General Assembly supports the Board and has several responsibilities, including, among others:
- Providing strategic guidance to the Board of Directors,
- Approving annual reports and financial statements, Appointing the external auditor,
- Authorizing the distribution of dividends to the Palestinian Treasury.
Principle 9
9. The operational management of the SWF should implement the SWF’s strategies in an independent manner and in accordance with clearly defined responsibilities.
PIF is governed by an independent Board of Directors, which serves as the highest authority within the Fund. The Board is responsible for approving strategy, asset allocation, and major investment decisions, as well as overseeing PIF’s overall operations.
An independent Executive Management team is entrusted with the implementation of the approved investment strategy and asset allocation, the management of daily operations, and the execution of operational decisions. The Executive Management operates in full compliance with corporate law, PIF’s Articles of Association and Bylaws, the Governance Manual, and a comprehensive set of internal policies and procedures. Its activities are further guided by a strict Authority Matrix that ensures transparency, accountability, and proper delegation of responsibilities.
Principle 10
10. The accountability framework for the SWF’s operations should be clearly defined in the relevant legislation, charter, other constitutive documents, or management agreement.
PIF’s accountability framework is clearly defined in its Articles of Association, Bylaws, and Corporate Governance Manual.
In addition, PIF is governed by Palestinian corporate law, which establishes the duties and responsibilities of the Board of Directors, the General Assembly, and Executive Management, as well as the requirement to prepare and publish audited financial statements.
Furthermore, PIF’s operations and accounts are subject to independent oversight by the State Audit and Administrative Control Bureau, which reports directly to the Palestinian President, the Government, and the Legislative Council.
Principle 11
11. An annual report and accompanying financial statements on the SWF’s operations and performance should be prepared in a timely fashion and in accordance with recognized international or national accounting standards in a consistent manner.
PIF issues a complete set of audited financial statements, including detailed notes and full disclosure of accounting policies, within 90 days of year-end. The financial statements are prepared in accordance with International Financial Reporting Standards (IFRS) and audited by a leading international audit firm.
These financial statements form an integral part of PIF’s Annual Report, which is widely distributed to stakeholders and made publicly available on PIF’s official website.
Principle 12
12. The SWF’s operations and financial statements should be audited annually in accordance with recognized international or national auditing standards in a consistent manner.
PIF’s annual financial statements are audited by an international accounting firm in accordance with International Standards on Auditing (ISA). The audited financial statements and accompanying audit report are published in PIF’s Annual Report and made publicly available on its official website.
In addition, PIF’s accounts and operations are subject to ongoing review by the Internal Audit Department, which reports directly to the Audit and Risk Committee of the Board of Directors. The Internal Audit function operates in close cooperation with an international accounting firm to ensure the highest standards of control and compliance.
Furthermore, PIF is subject to independent oversight by the State Audit and Administrative Control Bureau, which reports to the President, the Government, and the Legislative Council.
Principle 13
13. Professional and ethical standards should be clearly defined and made known to the members of the SWF’s governing body(ies), management, and staff.
PIF’s Governance Manual and Code of Conduct establish the principles and guidelines for ethical behavior across the organization, including the management of conflicts of interest.
In addition, PIF’s Human Resources policies, employment contracts, and operational procedures set forth the standards of professional conduct expected from all staff, ensuring consistency and accountability in daily operations.
Furthermore, all employees engaged in capital markets investments are required to comply with the CFA Institute Code of Ethics and Standards of Professional Conduct, reinforcing PIF’s commitment to the highest levels of integrity and professionalism.
Finally, executive management, the investment team, and all individuals with access to investment information are required to formally disclose any personal investments or business interests. They must also obtain approval from the Board of Directors’ Governance Committee before engaging in any new investment or business initiative
Principle 14
14. Dealing with third parties for the purpose of the SWF’s operational management should be based on economic and financial grounds, and follow clear rules and procedures.
The majority of PIF’s investments are managed by its internal portfolio management team, ensuring direct oversight and alignment with PIF’s strategic objectives. The use of external fund managers is limited to international capital market investments, where their specialized expertise and market access enable the Fund to capture global opportunities. External managers are selected through a rigorous process based on professional qualifications, proven track record, and commercial criteria.
PIF’s procurement activities are governed by formally approved policies that mandate fair, transparent, and competitive tendering procedures, ensuring accountability and value for stakeholders.
Principle 15
15. SWF operations and activities in host countries should be conducted in compliance with all applicable regulatory and disclosure requirements of the countries in which they operate.
The majority of PIF’s investments are deployed in the domestic market, supporting the growth and development of the Palestinian economy. International exposure is limited to capital market investments, which are managed through reputable external fund managers. These managers are required to ensure full compliance with all applicable regulatory, governance, and disclosure requirements in their respective jurisdictions.
Principle 16
16. The governance framework and objectives, as well as the manner in which the SWF’s management is operationally independent from the owner, should be publicly disclosed.
PIF’s governance framework and its operational independence are fully disclosed in PIF’s Annual Reports and on its official website.
The disclosures include, among other matters, PIF’s organizational structure, the composition of Executive Management, the roles of the Board of Directors and General Assembly, as well as the responsibilities of internal and external auditors.
Principle 17
17. Relevant financial information regarding the SWF should be publicly disclosed to demonstrate its economic and financial orientation, so as to contribute to stability in international financial markets and enhance trust in recipient countries.
Relevant financial information—including audited financial statements, asset allocation, key investments, investment returns and impact, and dividend distributions—is disclosed in PIF’s Annual Reports, which are widely distributed and published on the PIF’s official website.
The scale of PIF’s international market investments is limited and therefore poses no risk to the financial stability of those markets.
Pillar 3: Investment
Investment and Risk Management Framework.
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.
PIF’s investment strategy is anchored in its core mandate of promoting sustainable economic growth and supporting private sector development in Palestine.
The three-year investment strategy is reviewed and approved by the Board of Directors and presented to the General Assembly. The strategy is translated into annual business plans, which set asset allocation priorities as follows:
- Origination and investment in strategic projects within underdeveloped and vital sectors of the Palestinian economy, in partnership with the domestic private sector and international investors.
- Maintaining a limited foreign asset portfolio composed of highly liquid capital market investments, designed to maximize returns while minimizing risk, until suitable opportunities emerge for redeployment within Palestine.
Financial risk management is integral to PIF’s strategy. Leverage is conservatively applied, primarily in private equity and real estate investments, and always in line with approved policies and procedures. The use of derivatives—such as swaps and forwards—is strictly limited to hedging currency exposures.
The majority of PIF’s investments are managed in-house, with external fund managers engaged only for international capital market investments. The selection, authority, and oversight of external managers are governed by PIF’s Capital Markets Policies and Procedures Manual.
PIF’s investment policy is summarized in its Annual Reports and published on PIF’s website.
Principle 19
19. The SWF’s investment decisions should aim to maximize risk-adjusted financial returns in a manner consistent with its investment policy, and based on economic and financial grounds.
19.1. If investment decisions are subject to other than economic and financial considerations, these should be clearly set out in the investment policy and be publicly disclosed.
19.2. The management of an SWF’s assets should be consistent with what is generally accepted as sound asset management principles.
In line with the approved Investment Policy, all investment decisions at PIF are based on sound economic and financial considerations, with the dual aim of minimizing risk and maximizing return.
Consistent with its mandate and strategy, PIF prioritizes investments that deliver developmental impact—emphasizing job creation and import substitution—while ensuring sustainable financial returns.
All investment activities are carried out within a well-defined governance framework that regulates the decision-making process. Under this framework, investment proposals are first reviewed by PIF’s Executive Committee and subsequently approved by the Board Investment Committee and/or the Board of Directors, in accordance with a clear and structured Authority Matrix.
Principle 20
20. The SWF should not seek or take advantage of privileged information or inappropriate influence by the broader government in competing with private entities.
PIF is registered as a public shareholding company and governed by an independent Board of Directors. It operates in full compliance with the requirements of Palestinian corporate law, as well as all other applicable legislation, including tax laws.
In the domestic market, the majority of PIF’s projects and investments are undertaken in partnership and close cooperation with the private sector, reinforcing its role as a catalyst for private sector development and sustainable economic growth.
Principle 21
21. SWFs view shareholder ownership rights as a fundamental element of their equity investments’ value. If an SWF chooses to exercise its ownership rights, it should do so in a manner that is consistent with its investment policy and protects the financial value of its investments. The SWF should publicly disclose its general approach to voting securities of listed entities, including the key factors guiding its exercise of ownership rights.
PIF exercises its ownership rights primarily in domestic investments where it holds a significant stake, with the overarching objective of safeguarding the financial interests of both PIF and its ultimate shareholder, the Palestinian people.
By contrast, PIF’s international investments are limited in scale and are managed under a passive investment approach, reflecting their non-strategic and supplementary nature.
Principle 22
22. The SWF should have a framework that identifies, assesses, and manages the risks of its operations.
22.1. The risk management framework should include reliable information and timely reporting systems, which should enable the adequate monitoring and management of relevant risks within acceptable parameters and levels, control and incentive mechanisms, codes of conduct, business continuity planning, and an independent audit function.
22.2. The general approach to the SWF’s risk management framework should be publicly disclosed.
Risk Management is an integral component of PIF’s operations and is embedded across all functional activities through established policies, processes, and system controls. These include segregation of duties, structured reporting, continuous monitoring, internal audit oversight, and a robust governance framework that together ensure effective checks and balances.
Risk management is applied at multiple levels:
- Financial risks are managed at the subsidiary and portfolio level, as part of portfolio management processes.
- Operational risks are managed at the unit level, integrated into daily workflows and controls.
- Legal and reputational risks are overseen at the executive level, reflecting their strategic importance.
PIF’s risk management framework, approach, and guiding principles are set out in detail in the Governance Manual, ensuring alignment with international best practices and institutional accountability.
Principle 23
23. The assets and investment performance (absolute and relative to benchmarks, if any) of the SWF should be measured and reported to the owner according to clearly defined principles or standards.
Quarterly investment performance reports are prepared for the Board of Directors to ensure effective oversight and informed decision-making.
PIF’s Annual Reports, including audited financial statements, are formally submitted to the President and the Government and are also made publicly available on the Fund’s official website.
The website further provides detailed information on the economic impact of PIF’s investments.
Principle 24
24. A process of regular review of the implementation of the GAPP should be engaged in by or on behalf of the SWF.
The implementation of GAAP is subject to an annual review, conducted as part of the Internal Audit Department’s approved annual audit plan.