Principles of reporting

General considerations

These Guidelines are principally designed for use by General Partners (“GPs”) reporting to their Limited Partners (“LPs”) on closed-ended funds investing using Private Capital alternative investment strategies.

The information described in these Guidelines should generally be reported on a whole fund basis. In cases where a fund comprises parallel partnerships, particularly where they have different contractual terms, the GP may also provide details on a legal entity basis in addition to providing whole fund information. Further, as appropriate, disclosure of portfolio company information should be aggregated and presented on a whole fund basis in order that LPs can see the total investment under management by the GP.

Some funds invest in multiple securities or tranches of the same portfolio company. The disclosures described in these Guidelines are expected to be shown on the same basis that the manager would transact. If the manager expects to transact all positions in the same underlying portfolio company simultaneously, then disclosures would be for the aggregate investment in the portfolio company. If the manager expects to transact separately, for example selling a debt position independently from an equity position, then disclosure for each individual instrument will be more appropriate.

It is recognized that in some instances, disclosure of detailed information regarding a particular portfolio company or investment may give rise to issues of commercial sensitivity for that company/investment, for example when it is in or close to a sale process. The GP may in such circumstances need to exercise discretion in the level of detail provided in the report, bearing in mind the extent to which reports are available to a wide selection of parties including investors, administrators, custodians, advisers, etc.