1. 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.

2. Scope

This Policy applies to any person who reports a suspected concern in good faith, including all Personnel, all officers and directors, all contractors and secondees, all limited partners and their representatives, all portfolio company personnel, all vendors and their personnel, and any other person with information relevant to a Protected Disclosure.

3. Protected Disclosures

Protected Disclosures include suspected: (a) violations of federal or state securities laws; (b) violations of other applicable laws and regulations, including anti-bribery, employment, tax, and environmental laws; (c) fraud or theft; (d) financial misstatement or accounting irregularity; (e) violations of the firm's Code of Ethics, Conflicts of Interest Policy, Valuation Policy, Risk Appetite Statement, Cybersecurity Policy, or any other written firm policy; (f) harassment, discrimination, retaliation, or other workplace misconduct; (g) any other material concern that, if substantiated, would be of significance to limited partners, regulators, or the firm's governance bodies.

4. Reporting Channels

Reporters may use any of the following channels:

• Chief Compliance Officer. Direct contact at [email protected] or by phone. Suitable for most concerns, including policy violations, ethics concerns, and operational issues.
• Audit Committee Chair. Direct contact for matters involving senior executives, financial reporting integrity, the integrity of internal controls, or matters in which the reporter believes the Chief Compliance Officer or General Counsel may have a conflict.
• Anonymous Hotline. A third-party-operated hotline accessible by telephone or web that accepts anonymous reports and forwards them to the Audit Committee Chair and Chief Compliance Officer. Reporters using the hotline are not required to identify themselves and may communicate further with the firm through a hotline-issued report identifier.
• General Counsel. Direct contact for matters involving legal interpretation, regulatory exposure, or external counsel engagement.
• External regulators. Nothing in this Policy limits the right of any person to report suspected violations of law directly to the Securities and Exchange Commission, the U.S. Department of Justice, state regulators, or any other governmental authority. Personnel are encouraged but not required to use internal channels first.

5. Anti-Retaliation

The firm strictly prohibits retaliation against any person who makes a Protected Disclosure in good faith or who participates in an investigation, proceeding, or hearing relating to a Protected Disclosure. Retaliation includes termination, demotion, threats, harassment, denial of benefits, refusal to hire, and any other adverse action taken because of a Protected Disclosure. Persons who engage in retaliation are subject to disciplinary action up to and including termination of employment or engagement, and may be subject to civil liability under federal and state whistleblower protection statutes.

6. Investigation Procedures

Reports are reviewed promptly upon receipt. The Audit Committee Chair and Chief Compliance Officer determine the appropriate investigative path, including assignment to Internal Audit, engagement of external counsel, or escalation to the Board of Directors as warranted. Investigators have unrestricted access to firm records, systems, and personnel necessary to investigate the matter. The firm cooperates fully with regulatory and law enforcement investigations.

7. Confidentiality

The identity of a reporter is maintained in confidence to the extent permitted by law and consistent with the firm's ability to conduct a thorough investigation. The firm shares the identity of a reporter only with persons who have a legitimate need to know in connection with the investigation, with regulators or law enforcement as required by law, and with the Audit Committee. Anonymous reports submitted through the hotline are investigated to the extent possible without identifying the reporter.

8. Reporting in Good Faith

Protected Disclosures shall be made in good faith. Good faith does not require that the report be substantiated; it requires that the reporter have a reasonable belief that the conduct described constitutes a violation. Reports made with knowing falsity or in reckless disregard of the truth are not protected and may themselves be subject to disciplinary action.

9. Documentation and Recordkeeping

Reports, investigations, and findings are documented and retained in accordance with the firm's record retention schedule and applicable law. Records are accessible to the Audit Committee, the Chief Compliance Officer, the Head of Internal Audit, and external regulators and counsel as authorized.

10. Reporting to the Audit Committee

The Chief Compliance Officer and Audit Committee Chair receive each Protected Disclosure. The Audit Committee receives a summary of reports, investigations, findings, and remediations at each regular Audit Committee meeting. The Audit Committee may direct additional investigation, engage external counsel, or escalate to the Board of Directors as warranted.

11. External Whistleblower Rights

This Policy does not limit any person's right to report suspected violations to external regulators, including the Securities and Exchange Commission under Section 21F of the Securities Exchange Act of 1934, the Department of Labor, the Equal Employment Opportunity Commission, the Department of Justice, state attorneys general, and other governmental authorities. Personnel may be entitled to monetary awards under federal whistleblower programs and to remedies under federal and state anti-retaliation statutes.

12. Annual Review

The Whistleblower Policy is reviewed annually by the Audit Committee. Reporting channel effectiveness, anti-retaliation compliance, and the volume and nature of reports received are reviewed as part of the annual review.