1. Purpose

The Valuation Policy establishes the framework, methodologies, governance, and controls under which the firm determines the fair value of investments held by its managed funds. The Policy reflects the firm's commitment to consistent, transparent, and independent valuation of every position on the platform.

2. Scope

This Policy applies to all investments held by all funds managed by the firm, including real assets, credit, infrastructure, natural capital, venture and growth equity positions, and any other asset class in which the firm's funds invest.

3. Governance

The Valuations function owns the recommended fair value of every position. The Director of Valuations recommends; the Chief Financial Officer ratifies; the Chief Investment Officer is consulted but does not approve. The Valuation Committee, comprising the Director of Valuations (chair), Chief Financial Officer, Head of Internal Audit, Chief Risk Officer, and an independent committee member, reviews and approves the quarterly valuation cycle. Material valuation disputes escalate to the Chief Executive Officer and the Audit Committee.

4. Independence

The Valuations function is structurally independent of deal teams. Deal teams may provide inputs and observations but do not approve valuations. The Director of Valuations reports to the Chief Executive Officer with a reporting line to the Audit Committee, and is not subordinate to the Chief Financial Officer for purposes of valuation determinations.

5. Standard of Value

Investments are valued at fair value in accordance with U.S. GAAP, including ASC 820, and the AICPA Accounting and Valuation Guide for Investment Companies. Fair value is the price that would be received to sell an asset in an orderly transaction between market participants at the measurement date.

6. Inputs Hierarchy

The firm applies the ASC 820 fair value hierarchy: Level 1 inputs are quoted prices in active markets for identical assets; Level 2 inputs are observable inputs other than Level 1 prices, including quoted prices for similar assets, quoted prices in markets that are not active, and other market-corroborated inputs; Level 3 inputs are unobservable inputs reflecting the firm's assumptions about the assumptions market participants would use. The substantial majority of the firm's investments are classified as Level 3 and are valued using techniques described in Section 7.

7. Methodologies by Asset Class

Real assets (housing, commercial real estate, hospitality, infrastructure, energy). Direct capitalization, discounted cash flow, recent comparable transactions, and replacement cost are applied as appropriate to the asset and stage. Inputs include market rent, vacancy, capitalization rate, discount rate, terminal capitalization rate, and operating expense ratios. Annual third-party appraisal coverage is maintained for stabilized assets above defined thresholds.

Credit. Performing credit positions are valued using a yield-based approach reflecting current market spreads for comparable credit risk. Non-performing positions are valued using a recovery analysis or collateral-based approach. Inputs include credit spread, base rate, loss severity, and recovery timing.

Natural capital and timberland. Discounted cash flow incorporating biological growth, harvest schedules, log prices, and stumpage values, combined with land value supported by recent comparable transactions and conservation easement valuations.

Venture and growth equity portfolio companies. Recent transaction price, market multiple analysis using comparable public companies and comparable transactions, and option pricing models for complex capital structures. Calibration to recent transaction price is the primary method when a transaction has occurred within the prior twelve months.

8. Quarterly Cycle

The quarterly valuation cycle runs from T+30 to T+45 following each quarter-end. The cycle comprises (a) data collection and input refresh; (b) draft mark preparation by Valuations; (c) deal team review for factual inputs only; (d) Valuation Committee review and approval; (e) CFO ratification; (f) Audit Committee briefing; (g) LP reporting. Marks are final upon CFO ratification.

9. Material Change Thresholds

Quarter-over-quarter movements exceeding defined thresholds (currently fifteen percent or ten million dollars, whichever is greater, at the position level) trigger a material change review. The review includes documentation of the drivers of change, a sensitivity analysis, and a fresh challenge by an independent committee member. Material change reviews are reported to the Audit Committee.

10. Annual Third-Party Specialist Review

The firm engages a qualified independent valuation specialist to review a sample of marks each year. The specialist's review includes selection of positions across asset classes and risk profiles, review of inputs and methodologies, independent calculation, and a final written report to the Audit Committee. The specialist is independent of the firm and rotates lead reviewer every five years.

11. Dispute Resolution

Disputes between Valuations and deal teams are documented and resolved by the Valuation Committee. Disputes between Valuations and the CFO are escalated to the Chief Executive Officer. Material unresolved disputes are reported to the Audit Committee. Limited partners may raise valuation concerns through the LP Advisory Committee or the channels described in the Whistleblower Policy.

12. Reporting

Quarterly valuations are reported to limited partners within forty-five days of quarter-end as part of the quarterly fund report. Material valuation changes between quarterly reports are disclosed in interim communications. The Valuation Policy itself is provided to limited partners on request and is reviewed annually by the Audit Committee.