Compliance Framework

Compliance Policies.

Written policies that govern the firm's conduct, its investment activity, its treatment of LPs, and the standards to which its personnel are held.

Standards of conduct for the firm, its personnel, and its supervised persons.

Identification, disclosure, and management of actual and potential conflicts.

Anti-money-laundering, know-your-customer, and sanctions screening.

Methodology, cadence, and independent verification of asset values.

Concentration, leverage, and liquidity limits governing every investment decision.

Which expenses are borne by the firm and which are borne by the funds.

Confidential and non-retaliatory reporting of concerns.

Access control, incident response, and vendor security.

Continuity of operations across disruption scenarios.

Full Documentation

Complete policy documentation is provided in the DDQ.

Full policy text, procedures, and attestations are provided to qualified LPs under NDA.