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Compliance

At Cordis Asset Management we are committed to maintaining the highest standards of compliance and regulatory integrity in our investment activities focused on publicly traded medical technology companies. As a registered asset manager, we adhere to stringent regulatory requirements and ethical principles to safeguard the interests of our clients and uphold the trust they place in us. This Compliance Page outlines our commitment to compliance, regulatory adherence, and investor protection.

Regulatory oversight

Cordis Asset Management Pty Ltd is a Corporate Authorised Representative, No. 1282680, of Avenir Capital Pty Ltd (ACN 150 790 355, AFSL 405469) and comply with all applicable regulations governing asset management, securities trading, and investor protection.

Investment approach

Our investment strategy focuses on identifying and investing in publicly traded medical technology companies with promising growth prospects, innovative technologies, and sound fundamentals. We conduct rigorous due diligence and analysis to assess the financial health, regulatory compliance, and corporate governance practices of potential investment opportunities.

Compliance framework

1. Code of Ethics: Cordis Asset Management Pty Ltd maintains a comprehensive Code of Ethics that outlines the standards of conduct expected from our employees, investment professionals, and affiliated entities. Our Code of Ethics promotes integrity, honesty, and transparency in all business dealings and ensures compliance with applicable laws and regulations.

2. Regulatory Compliance: We have established robust compliance policies and procedures to ensure adherence to relevant laws, regulations, and industry best practices. Our compliance framework encompasses monitoring, reporting, and mitigating compliance risks across all aspects of our business operations.

3. Insider Trading Policies: Cordis Asset Management Pty Ltd strictly prohibits insider trading and maintains policies and procedures to prevent the misuse of material, non-public information in our investment activities. We educate our employees about their obligations under insider trading laws and provide guidelines for proper handling of confidential information.

4. Conflicts of Interest Management: We proactively identify and manage potential conflicts of interest that may arise in the course of our investment activities. Our Conflict of Interest Policy outlines procedures for disclosing, evaluating, and mitigating conflicts to ensure fair treatment of our clients and adherence to fiduciary duties.

5. Risk Management: Cordis Asset Management Pty Ltd implements robust risk management practices to identify, assess, and mitigate risks associated with our investment strategies and portfolio holdings. We employ quantitative models, stress testing, and scenario analysis to monitor and manage investment risks effectively.

Investor protection

Cordis Asset Management Pty Ltd is dedicated to safeguarding the interests of our clients and investors. We provide transparent and timely communication, regular reporting, and access to information to enable informed investment decisions. Our investor relations team is available to address inquiries, concerns, and feedback from investors and ensure a positive investor experience.
At Cordis Asset Management Pty Ltd, compliance is not just a regulatory requirement but a fundamental pillar of our business philosophy. We are committed to upholding the highest standards of integrity, transparency, and regulatory compliance in all aspects of our operations. By adhering to rigorous compliance standards and prioritizing investor protection, we strive to build trust, foster long-term relationships, and deliver superior investment outcomes for our clients.
For any inquiries or concerns around our Compliance policies, pls contact us by filling out the below form

    Innovative medical therapies

    These opportunities may involve early-stage ventures, unexplored markets, or underappreciated trends that have the potential to redefine industries and create new sources of returns.

    Emerging opportunities need to be defined by a combination of hard criteria.

    Strong management

    For emerging opportunity companies, we look for management teams with a proven track record in scaling an idea into a business. Many of these companies are still run by founders, and while this is not a requirement, a strategic long-term plan to deliver strongly defendable market positioning while growing towards positive earnings and increasing shareholder wealth is. 

    Disruptive innovation

    Emerging opportunities often stem from disruptive innovation, breakthrough technologies, or paradigm shifts that challenge existing business models and create new market dynamics. They may involve frontier technologies such as artificial intelligence, blockchain, genomics, or renewable energy.

    Untapped markets

    We like to look at underserved or overlooked markets with latent demand and untapped potential. These arise from changing consumer behaviours, evolving regulatory landscapes, or demographic shifts that create new market niches or unmet needs.

    Risk-reward profile

    Investments in emerging opportunities typically carry higher risk due to uncertainty, market volatility, and execution challenges. However, they also offer the potential for outsized returns for early movers who can identify and capitalize on nascent trends before they become mainstream. 

    Dynamic growth, strong discipline

    This Strategy is very dynamic and exciting. We are looking here for disruptive business models, revolutionary products, or transformative technologies. While high-growth investments offer the potential for substantial returns, they also entail higher risk.

    High growth needs a very strong and disciplined approach.

    Strong management

    For high growth companies, we love management teams with a proven track record of product commercialization and driving scalable growth. It is important at this stage of a company’s lifecycle that management is able to coherently and concisely communicate with investors and outline the path to profitability that we require. Cordis uses a unique scorecard to measure and assess Management trust and attitude towards long term value versus short term profit. An awareness of generating shareholder value can be an important factor is assessing management strategy at this juncture.

    Expanding addressable market

    These companies target large and expanding addressable markets with significant growth potential. They may capitalize on emerging trends, demographic shifts, or global megatrends driving demand for their offerings.

    Scalable business model

    High-growth companies possess scalable business models capable of rapidly growing operations, entering new markets, and capturing market share without proportionately increasing costs. They may benefit from network effects, platform economies, or leverage digital distribution channels for rapid expansion.

    Agile and adaptive

    High-growth companies are agile and adaptive, capable of quickly responding to market dynamics, customer feedback, and competitive pressures.

    Long-term compounding returns

    These companies typically have strong fundamentals, stable cash flows, and competitive advantages that enable them to generate consistent profits. Their policy tends to be to reinvest profits back into the business for further growth, allowing compounding effect to accelerate earnings and free cash flow.

    Strong management

    Earnings compounders are often led by capable and shareholder-friendly management teams that prioritize long-term value creation over short-term gains. They make strategic decisions focused on sustainable growth, prudent capital allocation, and shareholder returns. Cordis uses a unique scorecard to measure and assess Management trust and attitude towards long term value versus short term profit.

    Stable business model

    Companies with a predictable and resilient business model that generates recurring revenue streams are often considered earnings compounders. They tend to operate in industries with steady demand for their essential products, driving consistent profitability.

    Competitive advantage

    This is specifically hard to assess. The strong team at Cordis allows us to identify companies that typically possess durable competitive advantages such as strong brands, intellectual property, proprietary technology, or economies of scale that protect their market position and profitability against competitors.

    Rock solid balance sheet

    This is a non-negotiable. We want to be able to sleep easy at night, and can do so knowing the strength of the cumulative balance sheet of our portfolio. A solid balance sheet allows protection during the inevitable periods when external factors go wrong, and flexibility to be opportunistic when those rare chances arise. 

    Tim Fortin

    BA (Western University, London, Ontario), GAICD

    Investment Committee Former MD of Medtronic in ANZ

    Tim is an international business leader with 30 years of diversified experience as a member of executive leadership teams at two global MedTech conglomerates, Medtronic and Boston Scientific. He has a proven track record of delivering results, substantially increasing revenues and operating profit across Australia & New Zealand, the Asia Pacific region and globally.

    Donal O’Dwyer

    BE (University College Dublin), MBA (Manchester)

    Executive Director and Chairman of Investment Committee

    Donal has over 35 years of experience in the medical device/healthcare sector – initially as a senior executive in the global cardiovascular and medical devices industries and more recently as a Non-Executive Director. He was global President for Cordis Cardiology, a division of Johnson & Johnson’s Cordis Corporation. He was previously the European President of the Cardiovascular Group of Baxter Healthcare, now Edwards Lifesciences and formerly a director of Cochlear. Donal is currently on the Board of Directors of several Healthcare and Medical Device companies, including Fisher & Paykel Healthcare, Mesoblast and NIB Health Funds.

    Professor John Fraser

    MBChB, PhD, FRCP, FFARCSI, FRCA, FCICM

    Intensive Care, Device VC Brisbane

    John is a medical disruptor, who started Australia’s largest multi-disciplinary research group - Critical Care Research Group - based in the country’s largest cardiothoracic centre in the region, The Prince Charles Hospital. He has built a team of more than 80 leading clinicians, engineers, scientists and economists with global links – connected to all of the major cardiothoracic hospitals across Queensland, Australia, and the world. He has been a serial entrepreneur working with leaders in medicine, engineering, science and industry in a truly global network of mature collaborations. He simultaneously runs Australia’s first ever international Centre for Research Excellence in Bionic Hearts and Lungs. Professor Fraser has published over 400 peer-reviewed publications (including NEJM, Circulation, Lancet, AJRCCM, JACC) and has earned in excess of $41 Million AUD in competitive grants.

    Professor Michael Mack

    MD, MACC 

    Cardiovascular Surgery, Texas

    Mike is a cardiovascular surgeon and the Director of the Cardiovascular Service Line at Baylor Scott & White Health System, Chairman of the Board of Baylor Scott & White Research Institute in Dallas, Texas and co-chair of the Heart Valve Collaboratory. He has been in practice since 1982 and performed thousands of cardiac surgeries, of which well over 4,000 have involved heart valve procedures. He is one of the key global figures at the forefront of Transcatheter Aortic Valve Replacement (TAVR), having been a pioneer since the early days of this life-changing procedure. Michael has also authored or co-authored over 750 publications in peer-reviewed journals. He sat on the Board of the American College of Cardiology Foundation from 2015-2019 and has previously served as President of the Society for Thoracic Surgeons, Thoracic Surgery Foundation for Research and Education, Southern Thoracic Surgical Association and the International Society for Minimally Invasive Cardiothoracic Surgery.

    Professor David Celermajer

    AO, MBBS, MSC, PhD, DSC, FAHA, FRACP, FAA

    Cardiologist, Sydney

    David is an experienced Advisor and Investor in the Medical Devices area. He is the Founder of Corvia Inc (a Boston based cardiac devices company) and the Founder and Chief Medical Officer of the Brain Protection Company. He is a former University Medallist in Medicine from the University of Sydney, Rhodes Scholar and since 2014, has been an Officer of the Order of Australia. He has been involved in supporting and advising many successful MedTech companies, in Australia and the USA, over the last 20 years. David is Professor of Cardiology and Head of the Discipline of Cardiology at The University of Sydney and an Academic Cardiologist at Royal Prince Alfred Hospital. In addition to these roles, David is also the Clinical Director of the Heart Research Institute and serves on the Board of Directors of Heart Kids Australia. He has been a Fellow of the Australian Academy of Science since 2006 and a Fellow of the Australian Academy of Health and Medical Science since 2018. David sits on the Editorial Boards of many of the world’s leading Cardiology Journals, including the European Heart Journal, the Journal of the American College of Cardiology and Heart. He has published over 400 papers, with career citations of over 60,000 and an H-index of over 100. In recognition of this, he was awarded the inaugural Charles Blackburn Medal from the University of Sydney in 2019, for outstanding Clinical Research.

    Professor Michael Vallely

    MBBS PhD (Syd), FRACS 

    Founder and Chairman of the Medical Advisory Panel

    Michael is one of the founding partners of Cordis Asset Management. He is currently a Professor of Surgery & Surgical Director of Structural Heart at the Ohio State University Wexner Medical Center. Michael has a special interest in elderly and high-risk patients, anaortic off-pump coronary bypass surgery, transcatheter and open-heart valve surgery, minimally invasive heart & lung surgery, and electrophysiological device implants (e.g. pacemakers, defibrillators, and CRT). He has authored or co-authored more than 130 scientific publications in peer-reviewed journals, multiple book chapters and has been active in international clinical trials and first-in-man procedures and device trials. Professor Vallely is an Industry Advisor with the McKinsey and a consultant to Medtronic and other medical technology firms.

    James Cook

    B Eco and Politics (Monash University)

    Chief Investment Officer

    James formerly the Chief Investment Officer at U Ethical Investors, having worked for over 20 years in global equities investing. He has been involved at all levels of equities analysis, with a proven track record of consistently strong investment performance over rolling three year periods. James brings a wealth of experience in asset management to our team given his significant skill set.

    Michael Cartmill

    BSc (JCU) MIT (QUT) MBA (QUT) 

    Medical Device Specialist

    Michael is an active clinical engineer for medical device start-ups and a Founder and shareholder of Cordis. Michael has 10 years of global industry experience in Healthcare Informatics and Cardiovascular Device Technology. His industry experiences span senior management and technical roles with major medical technology companies, giving him invaluable insight into the companies we concern ourselves with.

    Jacob Celermajer

    BComm/BEng (Hons) (Syd), CFA

    Senior Equity Analyst

    Jacob joined Cordis at its inception as an equity analyst, quickly becoming an instrumental part of the portfolio construction process. He has 10 years of experience analysing companies and as a stockbroker, after beginning his career in the Equity Team at Deutsche Bank in Sydney, where he covered both domestic and international Healthcare companies as a part of the local sales team. Jacob has a Bachelor of Commerce and Engineering with Honours from the University of Sydney and is also a Chartered Financial Analyst (CFA).

    Simon Ford

    BE (Syd) MBA (Chicago) MSc (LSE) DFS (AFMA) GAICD

    Investment Committee

    Simon has over 40 years’ experience in portfolio, wealth and investment management in Sydney, London and Chicago with ANZ, Credit Suisse, J.P. Morgan and Mercantile House. He is a former Portfolio Manager for ANZ Optimix and Head of Alternative Investments for ANZ Wealth. Simon is currently a Trustee at the Centenary Foundation for Medical Research at Royal Prince Alfred Hospital in Sydney. He is a former Managing Director of Credit Suisse, Head of Alternative Investments for Asset Management, Co-Head of the European Pension Advisory and Structuring Group, Co-Head of Fund-Linked (Hedge Fund) Products, Global Head of Commodity Marketing and former Director of Advice for Life Pty Ltd, Capricorn Financial Advisors Pty Ltd, Financial Lifestyle Solutions, the London Gold Fixing and on the Markets Committee of the UK National Association of Pension Funds Investment Council. 

    Professor Toshimasa Okabe

    MD, MS

    Cardiac Electrophysiologist, Ohio, USA

    Dr Toshimasa Okabe is originally from Japan where he obtained his medical degree from University of Tokyo in 2006. He then completed his internal medicine residency and cardiology fellowship at Thomas Jefferson University in Philadelphia. During his time at Thomas Jefferson University, he was the recipient of several awards, including the best teaching resident and the best teaching fellow award. Dr Okabe also received a master of science degree in clinical investigation from Thomas Jefferson University in 2014. He went on to complete his cardiac electrophysiology fellowship at the Ohio State University, Columbus, Ohio. Dr Okabe joined the faculty at the Ohio State University in 2016, and is currently Assistant Professor of Internal Medicine. He is American Board of Internal Medicine certified in Cardiovascular Disease and Clinical Cardiac Electrophysiology. Dr Okabe has authored or co-authored more than 50 peer-reviewed publications, and 4 book chapters, and has presented at numerous national and international meetings.

    Dr Okabe’s areas of special interest are complex catheter ablation of various arrhythmias, ablation of epicardial ventricular tachycardia, fluoroscopy reduction techniques, and novel leadless pacing technologies.

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    Melissa Vincent

    BComm (Curtin) Micro Masters (Digital Marketing) (Curtin) Graduate Certificate in Finance (UWA) Post Graduate Diploma of Acting from Drama Studio London.

    Marketing Coordinator

    Melissa’s experience in marketing and communication over the past 5 years expands over the Finance, Wellness and Arts industries, working in Australia and the United Kingdom.

    Rudi Engelbrecht

    MSC Comp Sci (Pretoria), BSC Comp Sci (Pretoria)

    Director of Operations

    Rudi is the Founder and Managing Director for Paradigm Global Solutions, which designs innovative technology and administrative solutions for financial services. He is also a co-founder and joint-CEO for Latus Solutions. Prior to this, he acted as a director and Chief Technology Officer for Equinox and Tradestream in South Africa.

    Megan Inwood

    BSc, LLB and LLM (Syd)

    General Counsel and Company Secretary 

    Megan has over 30 years of legal experience and is currently a legal contractor for AMP Australia. Prior to AMP, she acted as legal counsel for Zurich Financial Services Australia and Macquarie Group for twenty years, across various financial services businesses. Formerly, she has practised as a tax lawyer for KPMG and Touche Ross.

    Andrew Inwood

    BEcon (Syd)

    Andrew Inwood is the founder of the CoreData Group and brings with him deep knowledge of the financial services industry. CoreData is a financial services research and consulting business which owns CoreData and CoreData Research and has operations in Australia, the UK, the USA and the Philippines. He focuses on the area of Behavioural Economics, with a particular interest in the process of trust transfer between individuals and corporations.

    Tom Bignill

    Non Executive Director and Director of Marketing and Distribution 

    Thomas has over 25 years’ experience in Wealth Management and Asset Management, at Bankers Trust, Merrill Lynch, Bell Potter and Next Financial before Co-founding Mason Stevens in 2011. As Managing Director of Mason Stevens, Thomas worked across the Asset Management and Wealth Management business and was responsible for driving its distribution into the advisory channels. In 2019, he became Co-Chief Investment Officer. Over the last 2 decades he has advised Family Office, HNW clients and worked closely with Advisory groups on managing investments across all asset classes. He currently is the Chair of Investment Committee for Norwest Asset Management, and is a director of private investment advisory firm Tenix Capital.

    Stephen Roberts

    BComm (UTS), GMQ (UNSW), MBA (Insead), GAICD

    Non Executive Director, Investment Committee

    Stephen has 30 years’ experience in leadership roles across globally recognised blue-chip investment, superannuation and financial services companies at CEO or Senior Executive level. He is currently Chairman of Growth Farms Ltd, a Non-Executive Director of AMP Superannuation Limited and Longreach Wealth Pty Ltd, a Member of the Supervisory Board of Pyrolyx AG, Germany and a Member of the Leadership Council of Social Ventures Australia. He was formerly CEO of Mercer Investments Asia Pacific and Russell Investment Consulting in Australia. Stephen brings a wealth of experience in investment consulting and asset management to our Board given his significant senior executive and non-executive board experience across Asia Pacific. Stephen has proven track record of successfully leading people and organisations through period of exceptional growth and change.