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Operational Risk
Management in Private
Equity Firms
July2019
PRIVATE & CONFIDENTIAL
Joseph Mundia
MScFinancial Risk Management
Portfolio Advisors LLC
Mentor: Tom DaRos
Operational Risk Management
in Private Equity Firms
Table of Contents
 Introduction to Operation Risk
 Cyber risk
 Compliance & Misconduct risks
 Outsourcing risk
 Crisis management
Page 2
Operational Risk Management
in Private Equity Firms
Introduction to Operation Risk
 Operational risk is the risk of loss resulting from inadequate or failed internal
procedures, people systems, policies or from external events
 This includes errors by employees, system failure, misconduct among other
criminal activities
 Operational risk deals mainly with tail events; meaning that exposure to
operational risk is less predictable and even hard to model
 Most firms would rather assume, It will never happen to us…..
 Hope is NOT a risk management strategy
 It should not be a matter of if, but a matter of when.
 If not well handled, poor operational risk management can hurt an organization’s
reputation, and cause severe financial damage
Page 3
Operational Risk Management
in Private Equity Firms
Cyber Risk
 Private equity firms face cyber risks from
both internal and external sources,
including employees, third parties you
work with, and other players who are
completely outside of your organization
but intent on stealing information or
otherwise doing you harm.
̶ The cyber attacks are so common in the private
sectors
̶ Notably, most criminals are looking for data which
is valuable to them
̶ Thus the cyber criminals will target employees and
customers who are most valuable.
̶ PA uses Wombat as a way to combat this risk
Page 4
Operational Risk Management
in Private Equity Firms
CyberThreat at a Glance
 92% of malware (software intentionally designed to cause damage to a
computer) is delivered by email.
 56% of IT decision makers say targeted phishing attacks are their top security
threat.
 75% of Medium sized financial Institution have no cyber risk insurance.
 191- Days on average are required to identify data breaches in organizations.
 $25 million average ransomware revenue for hackers generate each year
Page 5
Operational Risk Management
in Private Equity Firms
FrameworkTo Mitigate CyberAttack
 Evaluating the likelihood of the firm to undergo cyber attacks
 Creating security protocols and training employees (….Wombat)
 Passwords
 The firm should be fully conversant with their outsourcing business partners
 Always be willing to respond changes in the organization
 Review the company’s insurance program to assess coverage for cyber risks
 Always be ready for potential litigation
Page 6
Operational Risk Management
in Private Equity Firms
Compliance & Misconduct Risk
 Compliance risk is exposure to legal penalties, financial forfeiture and material
loss an organization faces when it fails to act in accordance with industry laws and
regulations(SEC), internal policies or prescribed best practices.
 Fraud Risk –is the risk of loss caused intentionally or unintentionally by an
employee misdeed.
 This includes:
̶ Asset misappropriation: inaccurate valuation models
̶ Corruption: in form of fees and expenses violations (SEC 2014)
̶ Fraudulent financial statements
̶ Marketing materials: inconsistencies, misrepresentations, misstatements & non-disclosure
Page 7
Operational Risk Management
in Private Equity Firms
Framework to Mitigate Compliance Risk
 Training for, key business stakeholders and other personnel, as needed
 Compliance program should be documentation
 Proper communication in regards to new requirements
 Identify, assess and prioritize fraud risks and scheme
 Legal counsel to help craft presentation, warranty, and indemnification clauses
 Perform an annual compliance review of high-risk areas
 Perform periodic fraud risk assessments
 Design and implement compliance policies and procedures
Page 8
Operational Risk Management
in Private Equity Firms
Outsourcing Risk
 Private Equity look at outsourcing as a way to optimize their competitive edge
while reducing costs and growing revenue. The shift is being fueled by more
complex tasks being supported by next-generation outsourcing companies.
 Risk Areas
1. Disruption of Customer Service due to third parties.
2. Breach of Law by third party action.
3. Reputation damage arising from third party behavior
4. Financial fraud/exposure due to third parties
Page 9
Operational Risk Management
in Private Equity Firms
Managing Outsourcing Risk
 Creating an open dialogue “Outsourcing Transparency”
 Establishing a strong governance structure
 The company should develop an integrated risk and control framework
 Balancing value protection and value creation
Page 10
Operational Risk Management
in Private Equity Firms
Crisis Management – Case Studies
 When a corporate crisis occurs, its ability to recover quickly, restore consumer
and investor confidence, is paramount for continued success.
1. UBS Bank
̶ UBS’s chief economist commented that consumer prices in China had risen mainly due to sickness among
pigs. This statement was considered a Cultural ignorance. Cultural sensitivity is important for any
multinational.
̶ Aftermath?
• UBS lost out on $1 billion China Bond Deal.
• Hong Kong unit of Chinese brokerage Haitong Securities Co, suspended relations with UBS.
• Boycott Call by Chinese investors against by the bank and social Media backlash as a result of the incidence.
2. Chipotle
̶ Chipotle was generally viewed as the fast-food model of the future. It's a brand promise: food with
integrity. Since 2015, Chipotle has suffered multiple scandals of food-borne illness .
̶ Aftermath?
• Tainted brand reputation.
• Chipotle several closed restaurants
• It's stock price, fell by 65% between (2015-2018)
• The company received a continuous onslaught of bad press.
Page 11
Operational Risk Management
in Private Equity Firms
Crisis Management – Case Studies
Page 12
Chipotle Crisis  Food borne illness outbreak
Chipotle’s
Response
 Not enough had been done to apologize to the clients.
 Subsequent incidences occurred.
 CEO landed a bigger compensation package despite a crisis.
UBS’ Crisis
 UBS’s global chief economist commented that consumer prices in China had risen mainly due to
sickness among pigs. This was considered a cultural ignorance. Cultural sensitivity is important for
any multinational company
UBS’
Response
 UBS issued public apology
 UBS asked its staff to prioritize any concerns on the matter raised by customers in China.
 UBS global chief economist, who made the remarks was put on a leave of absence.
Operational Risk Management
in Private Equity Firms
Crisis Planning Process
 Have a good plan to prepare for a crisis.
1. Risk assessment
2. Have a playbook.
3. Incident response plan.
4. Plan testing
5. Plan Maintenance
 A well-managed crisis confirms that your company has the processes and
procedures in place to address almost any issue that may develop
 In the event of a crisis:
̶ Have a plan.
̶ Ensure all communication is in one voice
̶ Be honest and open.
̶ Keep employees & clients Informed/updated as you control the situation.
̶ Ensure all other operations are closely monitored to avoid further distress.
Page 13
Operational Risk Management
in Private Equity Firms
FinalThoughts
 Conclusively, in the turbulent global economy, where bad news becomes viral in a
matter of seconds, designing and implementing strategies for managing risks is
essential.
 Having appropriate plans in place can prevent potential problems from occurring
 Create a robust risk management plan
 Failure to implement an appropriate program can end up costing your firm a far
greater loss of resources, value, and reputation
Page 14
Operational Risk Management
in Private Equity Firms
Disclosure Statement
General Disclaimer
Past performance does not guarantee future results. The past performance presented in this document reflects the particular objectives and constraints of Portfolio
Advisors’ advisory clients and/or managed funds of funds at different points in time and is based on the actual historical performance of the private equity funds, co-
investments or any other investments, as applicable (collectively or individually, as the context requires, “investments”), committed to on their behalf. No representation is
made that the investments would have been selected for any Portfolio Advisors-sponsored fund during the period shown or that the performance of any Portfolio Advisors-
sponsored fund would have been the same or similar to the performance reflected. Portfolio Advisors-sponsored funds make investments in different economic conditions
than those prevailing in the past and in different investments than those reflected in the performance record(s) shown herein. Additionally, the performance described
herein reflects the performance of certain investments over a limited period of time and does not necessarily reflect any such investments’ performance in different market
cycles. The performance record(s) shown herein were compiled, and reflect certain subjective assumptions and judgments, by Portfolio Advisors. It has not been audited or
reviewed by any independent party for accuracy or reasonableness. Prospective investors should understand that the use of different underlying assumptions and
judgments, and comparisons to different information, could result in material differences from the performance record(s) herein. Additional information can be provided
by Portfolio Advisors upon request.
General Disclosure
The summary description of any Portfolio Advisors-sponsored fund (each, the “Fund”) included herein, and any other materials provided to you, are intended only for
discussion purposes and are not intended as an offer to buy or a solicitation of an offer to buy or sell with respect to the purchase or sale of any security and should not be
relied upon by you in evaluating the merits of investing in any securities. These materials are not intended for distribution to, or use by, any person or entity in any
jurisdiction or country where such distribution or use is contrary to local law or regulation.
This summary is not intended to be complete and the description of the terms of any fund herein is qualified in its entirety by the terms contained in such fund’s
confidential private placement memorandum, partnership agreement and subscription agreement (the “Fund documents") similarly, any summaries of Portfolio Advisors’
policies are qualified in their entirety by the terms of the actual policies. Material aspects of the descriptions contained herein may change at any time and if you express an
interest in investing in the Fund you will be provided with a copy of the Fund documents. You must review the Fund documents and risk factors disclosed in the Fund
documents prior to making a decision to invest. You should rely only on the information contained in the Fund documents in making your decision to invest.
The information herein is not intended to provide, and should not be relied upon for, accounting, legal or tax advice or investment recommendations. You should consult
your tax, legal, accounting or other advisors about the matters discussed herein.
The Fund will not register as investment companies under the U.S. Investment Company Act of 1940, as amended (the “Company Act") in reliance upon the exemption
under section 3(c)(7) thereunder, and, accordingly, the provisions of the company act will not be applicable to the Fund.
An investment in the Fund will be suitable only for certain sophisticated investors who have no need for immediate liquidity in their investment. Such an investment will
provide limited liquidity because interests in the Fund will not be freely transferable and may generally not be withdrawn. There will be no public or secondary market for
interests in the Fund, and it is not expected that apublic or secondary market will develop.
Investing in financial markets involves a substantial degree of risk. There can be no assurance that the Fund’s investment objectives or any of the Fund’s (or its sectors’ and
sub-sectors’, if any) investment objectives will be achieved or that there will be a return of capital. Investment losses may occur with respect to any investment in the Fund
and investors could lose some or all of their investment. Nothing herein is intended to imply that an investment in the Fund or the Fund's investment strategies may be
considered "conservative," "safe," "risk free" or "risk averse." No regulatory authority has passed upon or endorsed this summary or the merits of an investment in the
Fund.
Page 15
Operational Risk Management
in Private Equity Firms
Distribution of this information to any person other than the person to whom this information was originally delivered and to such person's advisors is unauthorized and any
reproduction of these materials, in whole or in part, or the disclosure of any of the contents, without the prior consent of Portfolio Advisors, LLC. In each such instance is
prohibited. Notwithstanding anything to the contrary herein, each recipient of this summary (and each employee, representative or agent of such recipient) may disclose to
any and all persons, without limitation of any kind, the tax treatment and tax structure of (i) the Fund and (ii) any of its transactions, and all materials of any kind (including
opinions or other tax analyses) relating to such tax treatment and tax structure.
Certain information contained herein constitutes forward-looking statements. Due to various uncertainties and actual events, including those discussed herein and in the
Fund documents, actual results or performance of the Fund may differ materially from those reflected or contemplated in such forward-looking statements. As a result,
investors should not rely on such forward-looking statements in making their investment decisions. Any target objectives are goals only, are not projections or predictions
and are presented solely for your information. No assurance is given that the Fund will achieve its investment objectives.
Examples of investments described herein do not necessarily represent all or any of the investments that will be made by the Fund. It may not be assumed that any
investments described herein would be profitable if implemented. Investment allocations may be changed or modified at any time without notice to you at the sole
discretion of Portfolio Advisors, LLC. The information herein may not be relied on in making any investment decision. Investment decisions may only be made in reliance
upon the information set forth in the Fund documents.
If the recipient of this document is or becomes subject to: (i) section 552(a) of Title 5 of the United States Code (commonly known as the “Freedom of Information Act”) or
any public disclosure law, rule or regulation of any governmental or non-governmental entity that could require similar or broader public disclosure of confidential
information provided to such recipient; (ii) any public disclosure law, rule or regulation of any public company that could require similar or broader public disclosure of
confidential information provided to such recipient; or (iii) any public disclosure law, rule or regulation of any pension fund (or similar entity) that could require similar or
broader public disclosure of confidential information provided to such recipient (collectively, all such laws, rules or regulations, “FOIA”), then, to the extent that any such
recipient receives a request for public disclosure of this document, such recipient agrees that: (i) it shall use its best efforts to (x) promptly notify Portfolio Advisors of such
disclosure request and promptly provide Portfolio Advisors with a copy of such disclosure request or a detailed summary of the information being requested, (y) inform
Portfolio Advisors of the timing for responding to such disclosure request, (z) consult with Portfolio Advisors regarding the response to such public disclosure request,
including Portfolio Advisors’ consideration of whether such disclosure is in the best interest of the fund and, to the fullest extent permitted by law, whether all or any part of
this document may be withheld from such public disclosure request.
Nothing set forth in this document is intended to constitute a recommendation that any person take or refrain from taking any course of action within the meaning of U.S.
Department of Labor Regulation §2510.3-21(b)(1), including without limitation buying, selling or continuing to hold any security. No information contained herein should be
regarded as a suggestion to engage in or refrain from any investment-related course of action as none of Portfolio Advisors, LLC nor any of its affiliates is undertaking to
provide investment advice, act as an adviser to any plan or entity subject to the Employee Retirement Income Security Act of 1974, as amended, individual retirement
account or individual retirement annuity, or give advice in a fiduciary capacity with respect to the materials presented herein. You are advised to contact your own financial
advisor or other fiduciary unrelated to Portfolio Advisors, LLC about whether any given course of action may be appropriate for your circumstances.
None of the information contained herein was prepared, reviewed or approved by the underlying portfolio funds identified herein, if any, the general partners thereof or
any of their respective affiliates.
By accepting these materials, you hereby acknowledge and agree to all of the terms and conditions in this disclosure statement, specifically that the information contained
herein is highly confidential and that you shall not disclose or cause to be disclosed any such information without the prior written consent of Portfolio Advisors, LLC.
Disclosure Statement (continued)
Page 16

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Operation risk management in Private Equity firms

  • 1. Operational Risk Management in Private Equity Firms July2019 PRIVATE & CONFIDENTIAL Joseph Mundia MScFinancial Risk Management Portfolio Advisors LLC Mentor: Tom DaRos
  • 2. Operational Risk Management in Private Equity Firms Table of Contents  Introduction to Operation Risk  Cyber risk  Compliance & Misconduct risks  Outsourcing risk  Crisis management Page 2
  • 3. Operational Risk Management in Private Equity Firms Introduction to Operation Risk  Operational risk is the risk of loss resulting from inadequate or failed internal procedures, people systems, policies or from external events  This includes errors by employees, system failure, misconduct among other criminal activities  Operational risk deals mainly with tail events; meaning that exposure to operational risk is less predictable and even hard to model  Most firms would rather assume, It will never happen to us…..  Hope is NOT a risk management strategy  It should not be a matter of if, but a matter of when.  If not well handled, poor operational risk management can hurt an organization’s reputation, and cause severe financial damage Page 3
  • 4. Operational Risk Management in Private Equity Firms Cyber Risk  Private equity firms face cyber risks from both internal and external sources, including employees, third parties you work with, and other players who are completely outside of your organization but intent on stealing information or otherwise doing you harm. ̶ The cyber attacks are so common in the private sectors ̶ Notably, most criminals are looking for data which is valuable to them ̶ Thus the cyber criminals will target employees and customers who are most valuable. ̶ PA uses Wombat as a way to combat this risk Page 4
  • 5. Operational Risk Management in Private Equity Firms CyberThreat at a Glance  92% of malware (software intentionally designed to cause damage to a computer) is delivered by email.  56% of IT decision makers say targeted phishing attacks are their top security threat.  75% of Medium sized financial Institution have no cyber risk insurance.  191- Days on average are required to identify data breaches in organizations.  $25 million average ransomware revenue for hackers generate each year Page 5
  • 6. Operational Risk Management in Private Equity Firms FrameworkTo Mitigate CyberAttack  Evaluating the likelihood of the firm to undergo cyber attacks  Creating security protocols and training employees (….Wombat)  Passwords  The firm should be fully conversant with their outsourcing business partners  Always be willing to respond changes in the organization  Review the company’s insurance program to assess coverage for cyber risks  Always be ready for potential litigation Page 6
  • 7. Operational Risk Management in Private Equity Firms Compliance & Misconduct Risk  Compliance risk is exposure to legal penalties, financial forfeiture and material loss an organization faces when it fails to act in accordance with industry laws and regulations(SEC), internal policies or prescribed best practices.  Fraud Risk –is the risk of loss caused intentionally or unintentionally by an employee misdeed.  This includes: ̶ Asset misappropriation: inaccurate valuation models ̶ Corruption: in form of fees and expenses violations (SEC 2014) ̶ Fraudulent financial statements ̶ Marketing materials: inconsistencies, misrepresentations, misstatements & non-disclosure Page 7
  • 8. Operational Risk Management in Private Equity Firms Framework to Mitigate Compliance Risk  Training for, key business stakeholders and other personnel, as needed  Compliance program should be documentation  Proper communication in regards to new requirements  Identify, assess and prioritize fraud risks and scheme  Legal counsel to help craft presentation, warranty, and indemnification clauses  Perform an annual compliance review of high-risk areas  Perform periodic fraud risk assessments  Design and implement compliance policies and procedures Page 8
  • 9. Operational Risk Management in Private Equity Firms Outsourcing Risk  Private Equity look at outsourcing as a way to optimize their competitive edge while reducing costs and growing revenue. The shift is being fueled by more complex tasks being supported by next-generation outsourcing companies.  Risk Areas 1. Disruption of Customer Service due to third parties. 2. Breach of Law by third party action. 3. Reputation damage arising from third party behavior 4. Financial fraud/exposure due to third parties Page 9
  • 10. Operational Risk Management in Private Equity Firms Managing Outsourcing Risk  Creating an open dialogue “Outsourcing Transparency”  Establishing a strong governance structure  The company should develop an integrated risk and control framework  Balancing value protection and value creation Page 10
  • 11. Operational Risk Management in Private Equity Firms Crisis Management – Case Studies  When a corporate crisis occurs, its ability to recover quickly, restore consumer and investor confidence, is paramount for continued success. 1. UBS Bank ̶ UBS’s chief economist commented that consumer prices in China had risen mainly due to sickness among pigs. This statement was considered a Cultural ignorance. Cultural sensitivity is important for any multinational. ̶ Aftermath? • UBS lost out on $1 billion China Bond Deal. • Hong Kong unit of Chinese brokerage Haitong Securities Co, suspended relations with UBS. • Boycott Call by Chinese investors against by the bank and social Media backlash as a result of the incidence. 2. Chipotle ̶ Chipotle was generally viewed as the fast-food model of the future. It's a brand promise: food with integrity. Since 2015, Chipotle has suffered multiple scandals of food-borne illness . ̶ Aftermath? • Tainted brand reputation. • Chipotle several closed restaurants • It's stock price, fell by 65% between (2015-2018) • The company received a continuous onslaught of bad press. Page 11
  • 12. Operational Risk Management in Private Equity Firms Crisis Management – Case Studies Page 12 Chipotle Crisis  Food borne illness outbreak Chipotle’s Response  Not enough had been done to apologize to the clients.  Subsequent incidences occurred.  CEO landed a bigger compensation package despite a crisis. UBS’ Crisis  UBS’s global chief economist commented that consumer prices in China had risen mainly due to sickness among pigs. This was considered a cultural ignorance. Cultural sensitivity is important for any multinational company UBS’ Response  UBS issued public apology  UBS asked its staff to prioritize any concerns on the matter raised by customers in China.  UBS global chief economist, who made the remarks was put on a leave of absence.
  • 13. Operational Risk Management in Private Equity Firms Crisis Planning Process  Have a good plan to prepare for a crisis. 1. Risk assessment 2. Have a playbook. 3. Incident response plan. 4. Plan testing 5. Plan Maintenance  A well-managed crisis confirms that your company has the processes and procedures in place to address almost any issue that may develop  In the event of a crisis: ̶ Have a plan. ̶ Ensure all communication is in one voice ̶ Be honest and open. ̶ Keep employees & clients Informed/updated as you control the situation. ̶ Ensure all other operations are closely monitored to avoid further distress. Page 13
  • 14. Operational Risk Management in Private Equity Firms FinalThoughts  Conclusively, in the turbulent global economy, where bad news becomes viral in a matter of seconds, designing and implementing strategies for managing risks is essential.  Having appropriate plans in place can prevent potential problems from occurring  Create a robust risk management plan  Failure to implement an appropriate program can end up costing your firm a far greater loss of resources, value, and reputation Page 14
  • 15. Operational Risk Management in Private Equity Firms Disclosure Statement General Disclaimer Past performance does not guarantee future results. The past performance presented in this document reflects the particular objectives and constraints of Portfolio Advisors’ advisory clients and/or managed funds of funds at different points in time and is based on the actual historical performance of the private equity funds, co- investments or any other investments, as applicable (collectively or individually, as the context requires, “investments”), committed to on their behalf. No representation is made that the investments would have been selected for any Portfolio Advisors-sponsored fund during the period shown or that the performance of any Portfolio Advisors- sponsored fund would have been the same or similar to the performance reflected. Portfolio Advisors-sponsored funds make investments in different economic conditions than those prevailing in the past and in different investments than those reflected in the performance record(s) shown herein. Additionally, the performance described herein reflects the performance of certain investments over a limited period of time and does not necessarily reflect any such investments’ performance in different market cycles. The performance record(s) shown herein were compiled, and reflect certain subjective assumptions and judgments, by Portfolio Advisors. It has not been audited or reviewed by any independent party for accuracy or reasonableness. Prospective investors should understand that the use of different underlying assumptions and judgments, and comparisons to different information, could result in material differences from the performance record(s) herein. Additional information can be provided by Portfolio Advisors upon request. General Disclosure The summary description of any Portfolio Advisors-sponsored fund (each, the “Fund”) included herein, and any other materials provided to you, are intended only for discussion purposes and are not intended as an offer to buy or a solicitation of an offer to buy or sell with respect to the purchase or sale of any security and should not be relied upon by you in evaluating the merits of investing in any securities. These materials are not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use is contrary to local law or regulation. This summary is not intended to be complete and the description of the terms of any fund herein is qualified in its entirety by the terms contained in such fund’s confidential private placement memorandum, partnership agreement and subscription agreement (the “Fund documents") similarly, any summaries of Portfolio Advisors’ policies are qualified in their entirety by the terms of the actual policies. Material aspects of the descriptions contained herein may change at any time and if you express an interest in investing in the Fund you will be provided with a copy of the Fund documents. You must review the Fund documents and risk factors disclosed in the Fund documents prior to making a decision to invest. You should rely only on the information contained in the Fund documents in making your decision to invest. The information herein is not intended to provide, and should not be relied upon for, accounting, legal or tax advice or investment recommendations. You should consult your tax, legal, accounting or other advisors about the matters discussed herein. The Fund will not register as investment companies under the U.S. Investment Company Act of 1940, as amended (the “Company Act") in reliance upon the exemption under section 3(c)(7) thereunder, and, accordingly, the provisions of the company act will not be applicable to the Fund. An investment in the Fund will be suitable only for certain sophisticated investors who have no need for immediate liquidity in their investment. Such an investment will provide limited liquidity because interests in the Fund will not be freely transferable and may generally not be withdrawn. There will be no public or secondary market for interests in the Fund, and it is not expected that apublic or secondary market will develop. Investing in financial markets involves a substantial degree of risk. There can be no assurance that the Fund’s investment objectives or any of the Fund’s (or its sectors’ and sub-sectors’, if any) investment objectives will be achieved or that there will be a return of capital. Investment losses may occur with respect to any investment in the Fund and investors could lose some or all of their investment. Nothing herein is intended to imply that an investment in the Fund or the Fund's investment strategies may be considered "conservative," "safe," "risk free" or "risk averse." No regulatory authority has passed upon or endorsed this summary or the merits of an investment in the Fund. Page 15
  • 16. Operational Risk Management in Private Equity Firms Distribution of this information to any person other than the person to whom this information was originally delivered and to such person's advisors is unauthorized and any reproduction of these materials, in whole or in part, or the disclosure of any of the contents, without the prior consent of Portfolio Advisors, LLC. In each such instance is prohibited. Notwithstanding anything to the contrary herein, each recipient of this summary (and each employee, representative or agent of such recipient) may disclose to any and all persons, without limitation of any kind, the tax treatment and tax structure of (i) the Fund and (ii) any of its transactions, and all materials of any kind (including opinions or other tax analyses) relating to such tax treatment and tax structure. Certain information contained herein constitutes forward-looking statements. Due to various uncertainties and actual events, including those discussed herein and in the Fund documents, actual results or performance of the Fund may differ materially from those reflected or contemplated in such forward-looking statements. As a result, investors should not rely on such forward-looking statements in making their investment decisions. Any target objectives are goals only, are not projections or predictions and are presented solely for your information. No assurance is given that the Fund will achieve its investment objectives. Examples of investments described herein do not necessarily represent all or any of the investments that will be made by the Fund. It may not be assumed that any investments described herein would be profitable if implemented. Investment allocations may be changed or modified at any time without notice to you at the sole discretion of Portfolio Advisors, LLC. The information herein may not be relied on in making any investment decision. Investment decisions may only be made in reliance upon the information set forth in the Fund documents. If the recipient of this document is or becomes subject to: (i) section 552(a) of Title 5 of the United States Code (commonly known as the “Freedom of Information Act”) or any public disclosure law, rule or regulation of any governmental or non-governmental entity that could require similar or broader public disclosure of confidential information provided to such recipient; (ii) any public disclosure law, rule or regulation of any public company that could require similar or broader public disclosure of confidential information provided to such recipient; or (iii) any public disclosure law, rule or regulation of any pension fund (or similar entity) that could require similar or broader public disclosure of confidential information provided to such recipient (collectively, all such laws, rules or regulations, “FOIA”), then, to the extent that any such recipient receives a request for public disclosure of this document, such recipient agrees that: (i) it shall use its best efforts to (x) promptly notify Portfolio Advisors of such disclosure request and promptly provide Portfolio Advisors with a copy of such disclosure request or a detailed summary of the information being requested, (y) inform Portfolio Advisors of the timing for responding to such disclosure request, (z) consult with Portfolio Advisors regarding the response to such public disclosure request, including Portfolio Advisors’ consideration of whether such disclosure is in the best interest of the fund and, to the fullest extent permitted by law, whether all or any part of this document may be withheld from such public disclosure request. Nothing set forth in this document is intended to constitute a recommendation that any person take or refrain from taking any course of action within the meaning of U.S. Department of Labor Regulation §2510.3-21(b)(1), including without limitation buying, selling or continuing to hold any security. No information contained herein should be regarded as a suggestion to engage in or refrain from any investment-related course of action as none of Portfolio Advisors, LLC nor any of its affiliates is undertaking to provide investment advice, act as an adviser to any plan or entity subject to the Employee Retirement Income Security Act of 1974, as amended, individual retirement account or individual retirement annuity, or give advice in a fiduciary capacity with respect to the materials presented herein. You are advised to contact your own financial advisor or other fiduciary unrelated to Portfolio Advisors, LLC about whether any given course of action may be appropriate for your circumstances. None of the information contained herein was prepared, reviewed or approved by the underlying portfolio funds identified herein, if any, the general partners thereof or any of their respective affiliates. By accepting these materials, you hereby acknowledge and agree to all of the terms and conditions in this disclosure statement, specifically that the information contained herein is highly confidential and that you shall not disclose or cause to be disclosed any such information without the prior written consent of Portfolio Advisors, LLC. Disclosure Statement (continued) Page 16