Governance and controls.
Independent oversight of risk, audit, compliance, and valuations underpins every investment decision at MajorWave.
Four pillars of oversight.
Risk oversight
Maintains the Risk Appetite Statement, monitors exposure across funds and portfolio companies, and stress-tests deployment against rate, liquidity, concentration, counterparty, and covenant scenarios. Risk review is structurally independent of deal teams, reports to the CEO with a dotted line to the Audit Committee, and is a required input to every Investment Committee decision. The function holds veto rights on covenant, concentration, and counterparty matters.
Compliance oversight
Administers the Code of Ethics, Conflicts of Interest Policy, regulatory disclosures, personal trading pre-clearance, marketing review, and limited partner communications. Maintains the firm's regulatory registrations, manages relationships with external counsel, and serves as the principal point of contact for the SEC and state regulators. Compliance is independent of investment, finance, and operations.
Internal Audit
Independently assesses the design and operating effectiveness of the firm's controls across investment, valuation, finance, operations, compliance, and technology. Prepares the annual Internal Audit Plan, the quarterly Control Attestation, the per-finding remediation tracker, and the LP DD readiness package. Structurally independent of CFO and Legal; reports primarily to the Audit Committee.
Valuations
Owns the recommended mark for every position across the platform on the quarterly cycle (T+30 to T+45). The Director of Valuations recommends; the CFO ratifies; the CIO is consulted but does not approve. Marks are audited annually by PricewaterhouseCoopers LLP.
Governing bodies.
- Board of Directors. Oversight of firm strategy, capital structure, executive compensation, and Board-approved policies. Meets not less than quarterly.
- Audit Committee. Independent oversight of external audit, internal audit, cybersecurity, valuation, and compliance. Committee Chair is the primary reporting line for Internal Audit and the Whistleblower channel.
- Investment Committee. Every commitment. Chaired by the CEO. Unanimous approval required. Chief Risk Officer holds veto rights on threshold breaches.
- LP Advisory Committee (each fund). Established at first close. Anchor LP representation. Reviews conflicts, valuation methodology, and material policy questions.
Governance policy library.
The MajorWave policy library is maintained by the Chief Compliance Officer and reviewed annually. Full policy text is available for institutional LPs through Investor Relations.
Code of Ethics →
Standards of conduct, personal trading, gifts, confidentiality, and reporting obligations.
AML, KYC & Sanctions →
Customer identification, beneficial ownership verification, sanctions screening, and suspicious-activity reporting.
Conflicts of Interest →
Identification, disclosure, mitigation, and where appropriate consent for conflicts of interest.
Valuation →
Framework, methodologies, governance, and controls under which fair value is determined.
Whistleblower →
Confidential, anonymous, and protected reporting channels with strict anti-retaliation.
Business Continuity →
Sustaining critical operations during disruption; recovering systems and data.
Risk Appetite →
Level and types of risk the firm accepts, with CRO veto rights on threshold breaches.
