Whistleblower Policy
Protected channels for reporting suspected misconduct, and the firm’s prohibition on retaliation.
1. Purpose
This policy encourages the good-faith reporting of suspected legal, regulatory, ethical, or policy violations and protects those who report from retaliation.
2. Scope
The policy applies to all personnel, and welcomes reports from limited partners, service providers, and other stakeholders.
3. Reportable Matters
Reportable matters include suspected fraud, financial misstatement, securities-law violations, misuse of assets, conflicts of interest, harassment, and breaches of firm policy.
4. How to Report
Reports may be made to the Chief Compliance Officer, to any member of senior management, or anonymously through the firm’s designated reporting channel. Reports to regulators are also permitted and protected by law.
5. Confidentiality
The firm maintains the confidentiality of reports to the fullest extent consistent with a thorough investigation and applicable law.
6. Non-Retaliation
The firm strictly prohibits retaliation against anyone who reports a concern in good faith or participates in an investigation. Retaliation is itself a violation subject to discipline.
7. Investigation
Reports are investigated promptly and impartially. Findings are documented and, where warranted, remedial and disciplinary action is taken.
8. Regulatory Rights
Nothing in this policy limits any person’s right to report possible violations to the SEC or other authorities or to receive any resulting whistleblower award.
Notice
This document is a summary of the firm’s internal policy as adopted by the approving body identified above. The complete policy as adopted governs in any case of conflict between this summary and the underlying policy document. Limited partners and other authorized parties may request the full policy from the policy owner. This document does not create contractual rights, employment rights, or third-party beneficiary rights, and may be amended at any time by action of the approving body.
Questions about this policy should be directed to [email protected]. Confidential or anonymous reports may also be made through the channels described in the Whistleblower Policy.
Questions about firm governance
Limited partners, regulators, and counterparties with questions about firm governance, policies, or compliance should contact [email protected].