Conflicts of Interest Policy
The firm's framework for identifying, disclosing, mitigating, and where appropriate consenting to conflicts of interest that arise in managing the funds and serving limited partners.
- Policy Owner
- Chief Compliance Officer
- Approving Body
- Board of Directors
- Effective Date
- January 1, 2026
- Last Reviewed
- June 1, 2026
- Next Review
- January 1, 2027
- Version
- 1.0
Purpose
The Conflicts of Interest Policy establishes the firm's framework for identifying, disclosing, mitigating, and where appropriate consenting to conflicts of interest that arise in the course of managing the firm's funds and serving its limited partners. The Policy reflects the firm's fiduciary duty of full and fair disclosure of material conflicts.
Scope
This Policy applies to all Personnel and to all activities of the firm and its managed funds. The Policy covers actual conflicts, potential conflicts, and appearance conflicts, and applies regardless of whether the conflict involves the firm, its personnel, its affiliates, its portfolio companies, or its limited partners.
Identification
Personnel are required to identify and disclose conflicts as they arise through onboarding disclosures, annual attestations, transactional pre-clearance workflows, and ongoing self-reporting. The Chief Compliance Officer maintains the firm's Conflicts Register.
Categories of Conflict
The Policy addresses conflicts across categories including: allocation of investment opportunities among funds; allocation of expenses among funds; cross-fund transactions and secondary transactions; principal transactions; co-investment allocations; use of affiliated service providers; personal trading; outside business activities and board seats; and gifts, entertainment, and political contributions.
Investment Allocation
The firm allocates investment opportunities among eligible funds and accounts pursuant to the Allocation Policy and the terms of each fund's limited partnership agreement. Deviations require documented justification and, where required by the LPAs, LP Advisory Committee consent.
Cross-Fund Transactions
Any transaction between funds managed by the firm, or between a fund and the firm, an affiliate, or a portfolio company, requires LP Advisory Committee consent from each affected fund's committee. Independent valuation is required.
Affiliated Service Providers
The firm may engage affiliated service providers only where the terms are competitive with third-party market alternatives, the arrangement is disclosed to the LP Advisory Committee, and, where required, LP Advisory Committee consent is obtained. Fees from affiliated providers are disclosed in fund financial statements.
Board Service
Personnel serving on portfolio-company boards owe fiduciary duties to those companies. Where those duties may conflict with the firm's interests or another fund's interests, the conflict is disclosed and the affected person is recused from firm-side decisions on the matter.
Mitigation Toolkit
Depending on the nature and severity of the conflict, the firm may apply any combination of the following mitigants: disclosure; recusal; information barriers; independent verification; LP Advisory Committee consent; and, in extreme cases, declining the transaction.
Disclosure to Limited Partners
Material conflicts are disclosed in the firm's Form ADV, in offering documents, in quarterly LP reports, and, where warranted, in specific written notices to affected limited partners.
Review and Reporting
The Chief Compliance Officer reports on the Conflicts Register and material conflicts to the Board of Directors and the Audit Committee not less than annually.