Whistleblower Policy
Confidential, anonymous, and protected channels through which Personnel, limited partners, portfolio-company personnel, vendors, and other persons may report suspected violations of law, regulation, or firm policy, with strict anti-retaliation protections.
- Policy Owner
- Audit Committee Chair
- Approving Body
- Audit Committee
- Effective Date
- January 1, 2026
- Last Reviewed
- June 1, 2026
- Next Review
- January 1, 2027
- Version
- 1.0
Purpose
The Whistleblower Policy establishes the firm's commitment to providing confidential, anonymous, and protected channels through which Personnel, limited partners, portfolio company personnel, vendors, and other persons may report suspected violations of law, regulation, or firm policy. The Policy reflects the firm's recognition that a credible whistleblower process is a fundamental control over governance, financial reporting, ethics, and limited partner trust.
Scope
This Policy applies to any person who reports a Concern in good faith, including Personnel, former Personnel, limited partners, portfolio company personnel, vendors, and any other person with a good-faith basis to raise a Concern.
Covered Concerns
Reportable Concerns include, without limitation: violations of law or regulation; violations of the Code of Ethics or any other firm policy; questionable accounting, financial reporting, internal controls, or auditing matters; fraud, bribery, or corruption; retaliation against a person who has raised a Concern; and any other matter that a person reasonably believes may present material harm to the firm, the funds, or the limited partners.
Reporting Channels
Concerns may be reported to (a) the reporting person's direct manager, (b) any officer of the firm, (c) Compliance or Legal, (d) Internal Audit, (e) the Audit Committee Chair, or (f) the firm's independent Whistleblower Hotline, operated by a qualified third-party provider available 24 hours a day, seven days a week, in multiple languages, with anonymous submission supported.
Confidentiality
The firm maintains confidentiality of the reporting person's identity to the maximum extent consistent with a fair and complete investigation and applicable law.
Anti-Retaliation
The firm strictly prohibits retaliation, whether direct or indirect, against any person who in good faith reports a Concern or participates in an investigation. Retaliation is itself a violation of this Policy and grounds for disciplinary action up to and including termination.
Intake and Triage
Every Concern is logged in the firm's Whistleblower Register, acknowledged to the reporting person where identifiable within one business day, and triaged for severity, jurisdictional reach, and investigation ownership.
Investigation
Investigations are conducted by qualified investigators independent of the subject matter. Where a Concern involves a member of firm management, the Audit Committee Chair oversees the investigation. External counsel is engaged where the matter involves potential regulatory, criminal, or material civil exposure.
Reporting to the Audit Committee
All Concerns and their disposition are reported to the Audit Committee on at least a quarterly basis. Concerns involving financial reporting, senior management, or material regulatory exposure are reported to the Audit Committee immediately.
External Reporting Rights Preserved
Nothing in this Policy limits the right of any person to report a Concern directly to any regulatory or law-enforcement authority, or to any court, or to participate in any government investigation or proceeding, including under the Dodd-Frank Act and the Sarbanes-Oxley Act.
Recordkeeping
The firm retains Concern intake, investigation, and disposition records for a minimum of seven years.