Privacy Policy

 Public Policies for Family Offices & Private Equity Firms (Private Markets Only)

These policies promote transparency, risk control, legal compliance, and fiduciary responsibility, even in lightly regulated or exempt structures.

1. Code of Ethics & Professional Conduct

Purpose: Ensure integrity and responsible decision-making.

Policy Highlights:

Act in the best interests of clients, beneficiaries, or family principals.

Avoid self-dealing or undisclosed related-party transactions.

Prohibit insider trading, fraud, or misrepresentation (even for private deals).

2. Regulatory & Legal Compliance Policy

Purpose: Maintain adherence to applicable laws, even if exempt from registration.

Policy Highlights:

Comply with Anti-Fraud provisions of securities law (e.g., U.S. SEC Rule 10b-5).

Monitor thresholds that may trigger registration (e.g., AUM, co-investment structures).

For U.S. firms: qualify under SEC’s Family Office Rule or as an Exempt Reporting Adviser (ERA) if applicable.

3. Anti-Money Laundering (AML) & Know Your Customer (KYC) Policy

Purpose: Prevent illicit capital from entering investment structures.

Policy Highlights:

Verify identities of partners, investors, and counterparties.

Monitor source of funds and suspicious activity.

Maintain compliance files for audits or due diligence requests.

4. Investment and Due Diligence Policy

Purpose: Ensure disciplined investment selection in illiquid, private assets.

Policy Highlights:

Conduct financial, legal, operational, and ESG due diligence.

Evaluate sponsor background, capital structure, and exit potential.

Use external advisors where necessary to validate assumptions.

5. Risk Management Policy

Purpose: Identify and mitigate key risks in private investments.

Policy Highlights:

Diversify by sector, geography, and deal type (where feasible).

Stress-test investment assumptions (e.g., cap rates, valuation).

Define limits on leverage, illiquidity exposure, and concentration.

6. Privacy and Data Protection Policy

Purpose: Safeguard sensitive personal and financial data.

Policy Highlights:

Follow data protection laws (e.g., GDPR, CCPA).

Limit access to sensitive data to authorized personnel.

Establish a breach response protocol and secure digital storage.

7. Environmental, Social & Governance (ESG) Policy

Purpose: Align investments with responsible business practices.

Policy Highlights:

Include ESG factors in deal evaluation (e.g., governance practices, labor standards).

Encourage ESG improvements in portfolio companies.

Report on ESG metrics if applicable.

8. Conflict of Interest Policy

Purpose: Identify and mitigate conflicts, especially in co-investment or multi-entity structures.

Policy Highlights:

Disclose any related-party transactions.

Establish fair allocation of investment opportunities.

Use independent valuation or review for sensitive deals.

9. Whistleblower and Ethics Reporting Policy

Purpose: Allow internal stakeholders to report unethical behavior without fear.

Policy Highlights:

Provide confidential and anonymous reporting mechanisms.

Prohibit retaliation.

Investigate reports fairly and promptly.

10. Governance and Reporting Policy

Purpose: Ensure transparency and accountability to key stakeholders.

Policy Highlights:

Maintain regular performance and valuation reporting.

Set clear authority levels for investment approvals.

Document key decisions and committee discussion