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Transparency

Transparency and Disclosures

TRANSPARENCY AND DISCLOSURES

AlpInvest Partners B.V., a Dutch limited liability company (“AlpInvest”), holds a license as an alternative investment fund manager under the Alternative Investment Fund Managers Directive (2011/61/EC), as implemented in the Netherlands. AlpInvest is also a registered investment adviser in the United States and regulated by the U.S. Securities and Exchange Commission (the “SEC”). You can find more information about AlpInvest that is filed with the SEC at https://www.adviserinfo.sec.gov/Firm/159215. An investment adviser’s registration with the SEC does not imply a certain level of skill or training.

AlpInvest is wholly-owned by The Carlyle Group Inc. (“Carlyle”), a U.S. publicly traded corporation (Nasdaq: CG). For more information about Carlyle, including its directors, officers, significant stockholders, business, and other material matters, please refer to Carlyle’s public filings with the SEC (see ir.carlyle.com).

The information contained on this website is not intended to be (and may not be relied on in any manner as) legal, tax, investment, accounting or other advice or as an offer to sell or a solicitation of an offer to buy any securities of any investment product or any investment advisory service, including any limited partnership or comparable limited liability equity interests in any fund, managed account or other similar investment vehicle or product sponsored by AlpInvest (each, a “Fund”). Any such offer or solicitation may only be made pursuant to such Fund’s final confidential private placement memorandum and/or the related subscription documents, which will be furnished to qualified investors on a confidential basis at their request for their consideration in connection with such offering.

Shareholder Rights Directive

In accordance with article 5:87c sub 4 of the Dutch Act of Financial Supervision (as amended, the “AFS”), AlpInvest does not deem it necessary to formulate an engagement policy as required pursuant to article 5:87c sub 1-3 of the AFS since the core investment strategy of AlpInvest does not include investing in financial instruments listed on a regulated market, and an investment in financial instruments listed on a regulated market only occurs on an incidental basis.

Sustainability

In accordance with article 5:87c sub 4 of the Dutch Act of Financial Supervision (as amended, the “AFS”), AlpInvest does not deem it necessary to formulate an engagement policy as required pursuant to article 5:87c sub 1-3 of the AFS since the core investment strategy of AlpInvest does not include investing in financial instruments listed on a regulated market, and an investment in financial instruments listed on a regulated market only occurs on an incidental basis.

In accordance with the EU Sustainable Finance Disclosure Regulation (2019/2088) ("SFDR"), AlpInvest wishes to make certain disclosures with regard to the integration of sustainability risks and the consideration of adverse sustainability impacts in its processes. These disclosures can be found here.

If you would like to obtain more information, please make a request via email to compliance@alpinvest.com and indicate your name, company name, position and email address.

Transparency

In May 2009, Carlyle became a signatory to the Public Pension Fund Code of Conduct (the "Code"). Pursuant to the Code, AlpInvest is providing information regarding the professional backgrounds of certain key personnel (“Disclosure Persons”) and such information can be found here and under their individual biographies in the “Team” section of this website. In addition, AlpInvest is providing details of certain political contributions to candidates for U.S. state and local offices as well as certain U.S. federal contributions. Please click here for campaign contribution information.

Also pursuant to the Code, AlpInvest is disclosing certain Fund Fees and Expenses that have been paid on an aggregate basis with respect to investment funds to which U.S. public pension funds have committed since the effective date of the Code and the form of disclosure provided to public pension funds in respect of their investment.

Notice to Japanese Residents

Pursuant to Article 63, Paragraph 6 and Article 63-4, Paragraph 3 of the Financial Instruments and Exchange Law of Japan, operators of Specially Permitted Businesses for Qualified Institutional Investors, etc. are required to make available to the public certain information. Information on the following entities can be obtained upon request:

  • Alpinvest Atom GP, L.P.
  • AlpInvest Co-Investment VIII GP, LLC
  • AlpInvest Global Private Equity Program III, LLC

If you would like to obtain information, please make a request via email to LegalUS@alpInvest.com and indicate your name, company name, position and email address.