Legal

Disclaimer

EXPONENT PRIVATE EQUITY LLP - WEB SITE TERMS AND CONDITIONS

Your use of this Exponent Private Equity LLP (together with its affiliates, "Exponent") web site operated from URL "www.exponentpe.com" and the information contained therein (including any password-protected sections, the "Web Site") is subject to the following terms and conditions as may be amended by Exponent from time to time (these "Terms").

By using the Web Site you signify your consent to abide by these Terms and regulatory restrictions governing its use. On each occasion you access the Web Site you will be deemed to have accepted these Terms. If you do not accept these Terms, you may not use the Web Site.

1. Restrictions on Use of the Web Site Exponent allows you to use the Web Site for your personal, non-commercial or internal business use.

You may not use the Web Site:

without agreeing to these Terms;
for any unlawful purpose;
to interfere with, attempt to interfere with or disrupt the Web Site or any network or web site connected to the Web Site;
to access data not intended for you by logging onto a server or account that you are not authorised to access;
to allow any other person or entity to use your username and password on the Limited Partners' login;
to interfere with the enjoyment or use of the Web Site by any other person; and/or
to gain unauthorised access to any other computer systems.

2. No Offer Nothing on the Web Site shall constitute an offer by Exponent of, or the solicitation of an offer, invitation or inducement by Exponent to buy or sell from or to any person, any goods, services, investments, or securities or provide investment advice to engage in any other transaction.

3. General Conditions Use of the Web Site in accordance with these Terms is subject to, and does not modify or amend in any way, the terms of any applicable written agreements between you or any of your affiliates or connected persons, and Exponent or any of its affiliates.

Exponent may terminate, change or suspend any part of the Web Site, including any content, features, hours of availability or these Terms, at any time. Any changes which Exponent makes to these Terms will be effective immediately upon notice being posted on the Web Site. Continued use of the Web Site after Exponent has made any such changes will signify your consent to the changes. You are bound by any such changes and should, therefore, periodically visit this page to review these Terms.

Exponent Private Equity LLP is authorised and regulated by the U.K. Financial Conduct Authority (the "FCA"). The Web Site is directed only at "professional clients" and "eligible counterparties", as defined in chapter three of the FCA's Conduct of Business Sourcebook (together, the "Relevant Persons"). The contents of the Web Site must not be acted on or relied on by persons who are not Relevant Persons.

Any services or information relating to any services referred to in the Web Site will not be made available to "retail clients" as defined in chapter three of the FCA's Conduct of Business Sourcebook. As such, the protections afforded to retail clients under the FCA's Handbook of rules and guidance ("FCA Rules") will not apply and compensation under the Financial Services Compensation Scheme or any other relevant investor-compensation scheme may not be available.

Nothing in these Terms shall exclude or restrict any duty or liability which Exponent has under the UK Financial Services and Markets Act 2000 or under the FCA Rules and which duty or liability may not be excluded or modified by agreement or the giving of notice.

4. No Liability for Web Site Provision Use of the Web Site requires internet connectivity and telecommunications links. Exponent will not be liable to you for any telephone or other costs that you may incur in using the Web Site.

Exponent cannot guarantee that material from the Web Site will be free from infection, viruses, worms, Trojan horses and/or other similar code. You are responsible for virus checking and taking any other protective steps. Exponent does not accept any responsibility for any damage or loss caused by any failure to take protective measures.

5. Intellectual Property The content of the Web Site is protected by copyright, trade marks, database and other intellectual property rights and Exponent will take action against any and all third parties that Exponent believe are infringing such rights. Provided you retain all and any copyright and proprietary notices, you may:

* retrieve and display the content of the Web Site on a computer screen; * store content of the Web Site in electronic form (except that you may not store it on any server or other storage device connected to a network); and/or * print copies of the content for your own personal non-commercial or internal business use.

You may not transmit, reproduce, modify, copy, distribute or use for commercial purposes any of the materials or content on the Web Site without the prior written consent of Exponent.

Use of the Web Site does not constitute a licence for you to use any trade marks, designs, get-up and/or logos of Exponent.

6. No Advice The materials on the Web Site are provided for general information purposes only. Information on the Web Site is not offered as advice or recommendation on any particular matter and should not be treated as a substitute for specific advice or your own due diligence. In particular, no professional, financial, securities or investment advice is offered or given by Exponent to persons accessing information on the Web Site. Consequently, information or opinions contained in the Web Site must not be used for making an investment or other business decision. Advice from a suitably qualified professional should always be sought in relation to any particular matter or circumstances.

7. Financial Statements/Performance Information To the extent that the Web Site contains any forward-looking statements, they will be based on Exponent's opinions, expectations and projections as at the time of writing. Exponent undertakes no obligation to update or revise any forward-looking statements. Actual results may differ materially from those anticipated in any forward-looking statement.

Exponent makes no representation, and it should not be assumed, that past investment performance is an indication of future results.

Unless otherwise indicated, any information contained on the Web Site is as of the date indicated therein and will not be updated or otherwise revised to reflect information that subsequently becomes available, or circumstances existing or changes occurring after such date. The posting of any material on the Web Site does not imply that the information contained therein is correct as of any time subsequent to the date of such material. The provision of access to the Web Site at any time shall not, under any circumstances, create an implication that the information contained herein is correct as of any time subsequent to the dates described above. Exponent is under no obligation to update the information contained on the Web Site or to notify you of any subsequent update to the Web Site.

Certain information contained on the Web Site (including financial information and information relating to investments in companies) has been obtained from published and non-published sources prepared by other parties, which in certain cases have not been updated through the date hereof. While such information is believed to be reliable for the purpose used herein, Exponent does not assume any responsibility for the accuracy or completeness of such information, and such information has not been independently verified by Exponent.

Any projections or other estimates contained in the materials that are available on the Web Site, including estimates of returns or performance, are forward-looking statements and are based upon certain assumptions. While made in good faith, there can be no assurance that such assumptions will prove correct or will be applicable to any Exponent fund's actual investments. Actual events are difficult to project and often depend upon factors that are beyond the control of Exponent. To the extent that any document contained on the Web Site describes any historical investment returns or historical investment performance or provides any valuation of any investment, no representations are made or assurances given that such returns or performances are or will be indicative of future investment returns or future investment performance or that realised value will equal or exceed any such valuations.

8. Limitation of Liability The Web Site is provided "as is". Whilst Exponent has taken due care in the preparation of the content of the Web Site, Exponent cannot guarantee that the content is accurate or complete and no representations or warranties of any kind, either express or implied, are given in this regard. The information and opinions contained in the Web Site are provided by Exponent and are for information purposes only.

You agree that Exponent will not be liable to you or any third party for any:

loss of business; loss of revenue; loss of profits; loss of anticipated savings; wasted expenditure, loss of privacy and/or loss of data; and/or
any other loss or damage which does not result directly from the actions of Exponent its subcontractors or agents; and which arise out of or are related to your use of the Web Site.

Exponent shall not be liable to you for failure to perform any of Exponent's obligations arising out of the failure of any computer equipment or telecommunications link nor shall Exponent be liable to any person for any loss or damage which may arise from the use, misuse or inability to use any of the information contained in any materials on the Web Site.

To the maximum extent permitted by law, this limitation of liability applies to damages of any kind, including compensatory, direct, indirect or consequential damages, loss of data, income or profit, loss of or damage to property and claims of third parties.

If you have accessed the Web Site using a link from another site, Exponent does not accept any liability or responsibility for the accuracy of the information contained within sites of other providers who have links to any pages on the Web Site.

9. Indemnification By accessing the Web Site, you agree to indemnify Exponent and Exponent's respective partners, shareholders, members, managers, officers, directors, employees and agents (collectively, the "Exponent Indemnitees") against, and hold the Exponent Indemnitees harmless from, any and all claims and expenses , including lawyers' fees, arising from your use of the Web Site. You hereby release the Exponent Indemnitees from any and all claims, demands, debts, obligations, damages (actual, consequential or special), costs and expenses of any kind whatsoever that you may have against the Exponent Indemnitees arising out of or in any way related to such disputes.

10. Restricted Areas Access to specific areas of the Web Site is restricted for reasons of confidentiality and, therefore, requires the use of a username and associated password. The areas of the Web Site that are password protected are only directed at persons who are permitted to invest in unregulated collective investment schemes (such as financial institutions and other sophisticated investors with sufficient experience to understand the risks inherent in these types of investments). If you are not such an investor and have not been provided with a password by Exponent, you should not rely on the information on these parts of the Web Site and you will not be permitted to invest in any of the products offered by Exponent unless Exponent is satisfied that certain thresholds have been met in accordance with applicable law and regulations.

If you have a username and password, you are responsible for the activities which occur in connection with their use and as such should take steps to protect them from misuse. If you become aware of any unauthorised use of, loss or theft of your username and password, immediately inform a representative of Exponent.

The materials presented on the Web Site's restricted areas contain confidential, proprietary, trade secret and other commercially sensitive information, and by accessing such materials, you agree (a) to keep such information strictly confidential and not reproduce or redistribute the information in any format without the express written approval of Exponent, (b) upon request of Exponent, to promptly return to Exponent any materials that you have downloaded and (c) that in the event you become legally required to disclose any of the materials, you shall promptly notify Exponent in writing of such requirement prior to any such disclosure and use reasonable best efforts to obtain a protective order or other appropriate remedy (or, at Exponent 's request, assist Exponent in seeking a protective order or other appropriate remedy) to prevent the disclosure of such materials. In the event that a protective order or other remedy is not obtained pursuant to clause (c) above, you agree to use reasonable best efforts to obtain assurance that confidential treatment will be accorded to the materials disclosed.

11. Cookies When you use the Web Site it stores data created by its web server on your computer's hard drive otherwise known as "cookies". These "cookies" are used to track your usage patterns and preferences making the Web Site quicker and easier for you to use. You can disable or refuse these "cookies" by selecting the "cookie" option in your browser. If you do so, you may not be able to use the Web Site properly.

CookieNameExplanation

Content Management Systemexp_tracker exp_last_activity exp_last_visitThese cookies are used to improve the user experience of the website by building up anonymous data profiles that enable us to understand user journeys and behaviour across the Exponent website.

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org

12. Third Party Sites The Web Site may include links to third party web sites from time to time ("Third Party Sites"). Any such links are provided for your convenience and Exponent does not monitor or endorse the content of Third Party Sites. You acknowledge and agree that Exponent will not be responsible for the availability of such Third Party Sites and will not be responsible or liable for any content or services available (or unavailable) or security or privacy policies from such Third Party Sites. You should check the privacy statements and terms and conditions of use of Third Party Sites accessible from the Web Site.

Furthermore, you agree not to link any of your web sites or any third party web sites to the Web Site without the express prior written consent of Exponent.

13. International Use UNLESS OTHERWISE SPECIFIED, THE MATERIALS ON THE WEB SITE ARE DIRECTED SOLELY AT THOSE PERSONS WHO ACCESS THE WEB SITE FROM THE UNITED KINGDOM MAINLAND. EXPONENT MAKES NO REPRESENTATION THAT ANY PRODUCTS AND/OR SERVICES REFERRED TO IN THE MATERIALS ON THE WEB SITE ARE APPROPRIATE FOR USE, OR AVAILABLE IN LOCATIONS, OUTSIDE THE UNITED KINGDOM. THOSE WHO CHOOSE TO ACCESS THE WEB SITE FROM LOCATIONS OUTSIDE THE UNITED KINGDOM ARE RESPONSIBLE FOR COMPLIANCE WITH LOCAL LAWS IF AND TO THE EXTENT THAT LOCAL LAWS ARE APPLICABLE. EXPONENT PROHIBITS ANY ACCESS AND / OR USE OF THE WEB SITE FROM TERRITORIES OUTSIDE THE UNITED KINGDOM WHERE THE CONTENTS OF THE WEB SITE ARE ILLEGAL OR UNLAWFUL OR WHERE TO ALLOW SUCH ACCESS WOULD REQUIRE ANY REGISTRATION, FILING, APPLICATION FOR ANY LICENCE OR APPROVAL OR OTHER STEPS TO BE TAKEN BY EXPONENT IN ORDER TO COMPLY WITH LOCAL LAWS OR OTHER REGULATORY REQUIREMENTS IN SUCH TERRITORY.

14. Advertising and Sponsorship Part of the Web Site may contain advertising and sponsorship provided by third parties. You agree that Exponent will not be responsible for ensuring that such material complies with relevant laws and codes and that Exponent will not be responsible for any error or inaccuracy in such material.

15. Miscellaneous If any part of these Terms is found to be void or unenforceable, it will be severed from the rest to the extent that it does not affect the validity and enforceability of the remainder.

You may not assign, sub-license or otherwise transfer any of your rights under these Terms.

The headings used in these Terms are for convenience only and shall not affect the interpretation of those provisions.

Any failure or delay by Exponent in enforcing an obligation or exercising a right under these Terms does not amount to a waiver of that obligation, or right or any other obligation or right.

These Terms are effective until terminated by Exponent.

16. Governing Law These Terms are governed by and construed in accordance with the laws of England. You agree to submit to the exclusive jurisdiction of the English Courts.

17. Email Disclaimer

This transmission shall not constitute an offer, solicitation or recommendation in relation to any securities or funds sponsored by, or any investment services provided by, Exponent Private Equity LLP or its affiliates in any jurisdiction where it is unlawful to do so. This transmission, and any other materials, may only be distributed and interests in a fund may only be offered and placed to the extent that they may be lawfully distributed and the interests may lawfully be offered or placed (including at the initiative of the investor). The information in this transmission has been prepared on the basis that you are an investment professional, is for the sole use of your organization, and should not be shared with any other parties. Unless otherwise stated, this transmission is not an invitation or an inducement to engage in investment activity for the purposes of section 21 of the Financial and Services Markets Act 2000. Any information in this transmission shall not be construed as constituting legal, tax or investment advice. The contents of this transmission are based on information obtained from sources believed to be reliable but Exponent Private Equity LLP and its affiliates make no representation and accept no responsibility or liability as to their completeness or accuracy. Exponent Private Equity LLP is authorised and regulated by the U.K. Financial Conduct Authority.

18. Further Information If you have any queries regarding these Terms please contact us on +44 (0)20 7845 8526. The "exponentpe.com" Web Site is owned and operated by Exponent Private Equity LLP, a limited liability partnership whose registered office is at 30 Broadwick Street London W1F 8JB. Telephone: +44 (0)20 7845 8520.

Exponent Private Equity LLP is entered in the Financial Services Register with the following firm reference number: 231527.

Exponent Private Equity LLP is also duly registered with the Information Commissioner with number P28777152.

Privacy policy

EXPONENT PRIVATE EQUITY LLP - PRIVACY POLICY

Exponent Private Equity LLP, and its affiliates, ("We") are committed to protecting and respecting your privacy.

This policy (together with our Terms and Conditions) and any other documents referred to on it sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

For the purpose of the Data Protection Act 2018 (the "Act") and Regulation (EU) 2016/679 (the “GDPR”), the data controller is Exponent Private Equity LLP of 30 Broadwick Street, London W1F 8JB.

1. Information we may collect from you

Web Site

We may collect and process the following data about you:

Information that you provide by filling in forms on our Web Site http://www.exponentpe.com (our "Web Site"). This includes information provided at the time of registering to use our Web Site, posting material or requesting further services. We may also ask you for information when you report a problem with our Web Site.
If you contact us, we may keep a record of that correspondence, including your name, phone number, email address and any other information you provide to us about you.
Details of your visits to our Web Site including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access.
Various personal and financial details as well as any details of goods or services that we have provided to you.

IP addresses We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

Cookies For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on your browser or the hard drive of your computer. Cookies contain information and are transferred to your computer's hard drive and used to track your usage patterns and preferences, helping Exponent to make the Web Site quicker and easier for you to use. They help us to improve our Web Site and to deliver a better and more personalised service. Some of the cookies we use are essential for the Web Site to operate.

We use the following cookies:

- Google analytics:

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These cookies are used to improve the user experience of the Web Site by building up anonymous data profiles that enable us to understand user journeys and behaviour across the Web Site.

- Expontentcookie:

This cookie is used to improve the user experience of the Web Site by building up anonymous data profiles to prevent the cookie policy re-displaying once agreed.

You block cookies by activating the setting on your browser which allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be to access all or parts of our Web Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon you visit our Web Site.

Except for essential cookies, all cookies will expire after the session has ended.

Investors

We may collect the following information provided to us about previous, current and future investors who are natural persons and about the individuals associated with the investors who are non-natural persons:

(i) Personal contact information such as first name, last name, place and date of birth, gender, nationality, business and home telephone, fax, postal or e-mail address and such other identifiers that we may request;

(ii) Government issued identifiers such as passport, identification card, tax identification number, national insurance number;

(iii) Financial and tax information such as financial qualifications for subscription, bank details, invested amount and holdings in funds, employment details, details of your sources of wealth, tax identification details, individual self-certification form for tax reporting;

(iv) Information regarding a potential investor’s eligibility to invest in a fund.

Service providers suppliers and professional advisors

We store limited amounts of personal information relating to service providers, suppliers and professional advisors (and individuals employed by or otherwise connected with any such third party) including personal contact information such as first name, last name, gender, business and home telephone, fax, postal or e-mail address as well as job title, qualifications and employer organisation.

Transaction personnel

If you are involved in a transaction that we and/or the funds that we manage or advise enters into, or a potential transaction that we consider, we may store personal information relating to you. This might include your CV, details of your previous employment history, business profile and professional activities, information relating to your financial status and dealings, nationality information (including copies of identity documents such as passports and national identity cards), references provided by third parties, and results of other due diligence carried out.

2. Uses made of the information and the legal basis

Website

We use information held about you in the following ways:

To ensure that content from our Web Site is presented in the most effective manner for you and for your computer.
To carry out our obligations arising from any contracts entered into between you and us.
To allow you to participate in interactive features of our service, when you choose to do so.
To notify you about changes to our service.
To contact you and respond to queries.
To market our services.

The lawful basis for the processing of your personal data through the Web Site will generally be because it is necessary for our legitimate interests in operating the Web Site as part of our business, and communicating with individuals who express an interest in Exponent. In some circumstances, the performance may be necessary for the performance of a contract or to comply with a legal obligation.

Investors

We require personal information in respect of Exponent funds for a number of reasons, including:

verifying the identity of prospective investors for the purpose of complying with the statutory and regulatory requirements of the relevant fund and any functionary of the fund in relation to anti-money laundering requirements
evaluating and complying with any anti-money laundering, regulatory and tax requirements in respect of the relevant fund;
contacting investors with information about other products and services provided by us which we consider may be of interest to investors;
carrying out the function of the manager of the relevant fund and administering the investor’s investment in the fund;
meeting the legal, regulatory, reporting and/or financial obligations of the relevant fund or any functionary of the relevant fund or elsewhere, including, without limitation, with respect to compliance with the US Foreign Account Tax Compliance Act (“FATCA”) and the OECD common reporting standard (“CRS”) or any legislation, regulations or guidance enacted in any jurisdiction that seeks to implement a similar tax reporting or withholding tax regime; and
any purpose ancillary to the management and operation of the relevant fund and/or any of its investments.

In the case of investors and individuals associated with investors, our legal basis for processing personal information about you is that such processing is, in some cases, necessary for the performance of a contract, and in other cases is necessary for compliance with a legal obligation or is necessary for our legitimate interests in running and operating our business and ensuring effective communications with investors.

Service providers suppliers and professional advisors

We will hold personal information relating to service providers, suppliers and professional advisors (and individuals employed by or otherwise connected with any such third party) for the purposes of (without limitation):

administering and maintaining records of services or advice we have received and commissioning further services;
complying with our regulatory, tax and legal obligations, including assessing and managing risk;
safeguarding our legal rights and interests; and
seeking and receiving advice from our professional advisors, including accountants, lawyers and other consultants.

In the case of personal information relating to service providers, suppliers and professional advisors (and individuals employed by or otherwise connected with any such third party), our legal basis for processing personal information about you is that such processing is, in some cases, necessary for the performance of a contract, and in other cases is necessary for compliance with a legal obligation or is necessary for our legitimate interests in running and operating our business and ensuring effective communications with our providers and other business contacts.

Transaction personnel

We require personal information relating to transaction personnel for the purposes of (without limitation):

assessing potential transactions;
maintaining records of investments;
administering any transaction that we enter into;
assessing your suitability for involvement in a transaction, including by verifying your identity;
complying with our regulatory, tax and legal obligations, including assessing and managing risk;
safeguarding our legal rights and interests;
seeking and receiving advice from our professional advisors, including accountants, lawyers and other consultants; and
providing periodic business updates.

In the case of transaction personnel, our legal basis for processing personal information about you is that such processing is necessary for our legitimate interests in assessing potential transactions and, occasionally, for compliance with legal obligations.

3. Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by an affiliate of us operating outside the EEA. Such affiliate maybe engaged in, among other things, the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing.

We will ensure that appropriate or suitable safeguards are in place to protect your personal information and that transfer of your personal information is in compliance with applicable data protection laws.

Where required by applicable data protection laws, we have ensured that service providers (including affiliates) sign standard contractual clauses as approved by the European Commission or other supervisory authority with jurisdiction over the relevant Firm exporter. You can obtain a copy of any standard contractual clauses in place which relate to transfers of your personal data by contacting us using the details set out below.

You have a right to request a copy of any data transfer agreement under which your personal data is transferred, or to otherwise have access to the safeguards used. Any data transfer agreement made available to you may be redacted for reasons of commercial sensitivity.

4. Your rights as a data subject

Right to access, correct and delete your personal data

We aim to ensure that all personal data are correct. You also have a responsibility to ensure that changes in personal circumstances (for example, change of address and bank accounts) are notified to us so that we can ensure that your data is up-to-date.

You have the right to request access to any of your personal data that we may hold, and to request correction of any inaccurate data relating to you. You furthermore have the right to request deletion of any irrelevant data we hold about you. To correct/update data about yourself, please contact us using the details set out below.

Data portability

Where we are relying upon your consent or the fact that the processing is necessary for the performance of a contract to which you are party as the legal basis for processing, and that personal data is processed by automatic means, you have the right to receive all such personal data which you have provided to us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible.

Right to restriction of processing

You have the right to restrict our processing of your personal data where:

you contest the accuracy of the personal data until we have taken sufficient steps to correct or verify its accuracy;
where the processing is unlawful but you do not want us to erase the data;
where we no longer need the personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims; or
where you have objected to processing justified on legitimate interest grounds (see below) pending verification as to whether we have compelling legitimate grounds to continue processing

Where personal data is subjected to restriction in this way we will only process it with your consent or for the establishment, exercise or defence of legal claims.

Right to withdraw consent

Where we have relied on your consent to process particular information and you have provided us with your consent to process data, you have the right to withdraw such consent at any time. You can do this by contacting us using the details set out below. It will only however be rarely that we rely on your consent to process personal data.

Right to object to processing justified on legitimate interest grounds

Where we are relying upon legitimate interest to process data, then you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

Right to complain

You also have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal data infringes applicable law.

For further information regarding your rights, or to exercise any of your rights, please contact us using the details set out below.

5. Automated decision making and profiling

At present, we do not operate any automated decision-making procedures in relation to profiling of users of the Web Site or investors.

In the event that we decide to apply automated decision making and profiling in relation to the personal data that we hold, the details of any such procedures shall be made available.

6. Disclosures

Disclosures relating to investors

In relation to personal data processed in connection with a fund, each fund’s structure involves legal entities affiliated with Exponent that allow us to operate and fulfil its aims.

We also rely on third parties to help us document, effect and administer investments in each fund both at the outset and on an on-going basis. We may, therefore, transfer personal data to third parties from time to time including:

Our legal and other advisers including, without limitation, to allow them to facilitate investments in the relevant fund.
Any fund’s outsourced administrator or other service providers, such as depositaries, that provide administrative services to the fund.
Our financial service providers, such as placement agents, custodians, banks and others used to facilitate transactions.

Other disclosures

In wider circumstances, we may also transfer personal data to third parties, including:

Entities with the Exponent group,

Our legal and other advisers.
Our financial service providers, such as placement agents, custodians, banks and others used to facilitate transactions.
Our other service providers such as IT service providers and consultants, that provide support and administrative services to us.
Credit reference agencies.
Financial intermediaries.
Other persons who have an interest or involvement in, or who are considering an interest or involvement in, an Exponent transaction, including co-investors, other providers of finance and investors in our funds.

There may also be circumstances where we are obliged by law to disclose personal data, including to law enforcement or other government agencies, tax authorities, applicable regulators (or in response to requests from such parties) or in the context of litigation.

7. Retention of personal data

We endeavour to ensure that personal data are kept as current as possible and that irrelevant or excessive data are deleted or made anonymous as soon as reasonably practicable.

Our general approach is to only retain personal data for as long as is required to satisfy the purpose for which it was collected by us or provided by you. In relation to investors, this will usually be the period of your investment plus the length of any applicable limitation period following the end of your investment, although some data may need to be kept for longer, such as contact information for the purposes of marketing further investment opportunities. We may keep some specific types of data, for example, tax records, for different periods of time, as required by applicable law. Some personal data may be retained for varying time periods in order to comply with legal and regulatory obligations and for other legitimate business reasons.

8. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

9. Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected]. Please also contact us at this address if you wish to exercise any of the rights described above.

Exponent Private Equity LLP is registered with the Information Commissioners Office under registration number Z8777152.

Disclosures

EXPONENT PRIVATE EQUITY LLP – DISCLOSURES

The Financial Conduct Authority (“FCA” or “regulator”) in the Prudential sourcebook for MiFID Investment Firms in the FCA Handbook (“MIFIDPRU”) sets out the detailed prudential requirements that apply to Exponent Private Equity LLP (“Exponent” or the “Firm”). Chapter 8 of MIFIDPRU (“MIFIDPRU 8”) sets out public disclosure rules and guidance with which the Firm must comply, further to those prudential requirements.

Exponent is classified under MIFIDPRU as a small and non-interconnected MIFIDPRU investment firm (“SNI MIFIDPRU Investment Firm”). As such, the Firm is required by MIFIDPRU 8 to disclose information regarding its remuneration policy and practices.

This document has been prepared by Exponent in accordance with the requirements of MIFIDPRU 8 and is verified by the Governing Body. Unless otherwise stated, all figures are as at the Firm’s 31 March financial year-end.

Overview

As an SNI MIFIDPRU Investment Firm, Exponent is subject to the basic requirements of the MIFIDPRU Remuneration Code (as laid down in Chapter 19G of the Senior management arrangements, Systems and Controls sourcebook in the FCA Handbook (“SYSC”)). Exponent, as an alternative investment fund manager, is also classified as a collective portfolio management investment firm, and as such, is also subject to the AIFM Remuneration Code (SYSC 19B). The purpose of the remuneration requirements is to:

Promote effective risk management in the long-term interests of the Firm and its investors;
Ensure alignment between risk and individual reward;
Support positive behaviours and healthy firm cultures; and
Discourage behaviours that can lead to misconduct and poor investor outcomes.

The objective of Exponent’s remuneration policies and practices is to establish, implement and maintain a culture that is consistent with, and promotes, sound and effective risk management and does not encourage risk-taking which is inconsistent with the risk profile of the Firm and the services that it provides to investors.

In addition, Exponent recognises that remuneration is a key component in how the Firm attracts, motivates, and retains quality staff and sustains consistently high levels of performance, productivity, and results. As such, the Firm’s remuneration philosophy is also grounded in the belief that its people are the most important asset and provide its greatest competitive advantage.

Exponent is committed to excellence, teamwork, ethical behaviour, and the pursuit of exceptional outcomes for its investors. From a remuneration perspective, this means that performance is determined through the assessment of various factors that relate to these values, and by making considered and informed decisions that reward effort, attitude, and results.

Characteristics of the Firm’s Remuneration Policy and Practices

Remuneration at Exponent is made up of fixed and variable components. The fixed component is set in line with market competitiveness at a level to attract and retain skilled staff. Variable remuneration is paid on a discretionary basis and takes into consideration the Firm’s financial and non-financial performance as well as the financial and non-financial performance of the individual in contributing to the Firm’s success. All staff members are eligible to receive variable remuneration.

The fixed and variable components of remuneration are appropriately balanced: the fixed component represents a sufficiently high proportion of the total remuneration to enable the operation of a fully flexible policy on variable remuneration. This allows for the possibility of paying no variable remuneration component, which the Firm would do in certain situations, such as where the Firm’s profitability performance is constrained, or where there is a risk that the Firm may not be able to meet its capital or liquidity regulatory requirements.

Governance and Oversight

The Governing Body is responsible for setting and overseeing the implementation of Exponent’s remuneration policy and practices. In order to fulfil its responsibilities, the Governing Body:

Prepares and makes decisions regarding remuneration, including decisions that have implications for the risk and risk management of the Firm.
Ensures that the Firm’s remuneration policy and practices take into account the long-term interests of the Firm and other stakeholders, including the investors in the funds that it manages.
Ensures that the overall remuneration policy is consistent with the business strategy, objectives, values, and interests of the Firm and the investors in the funds that it manages.

Exponent’s remuneration policy and practices are reviewed annually by the Governing Body.

Quantitative Remuneration Disclosure

For the financial year 1 April 2022 to 31 March 2023, the total amount of remuneration awarded to all staff was £7.8m, of which £5.9m comprised the fixed component of remuneration, and £1.9m comprised the variable component. For these purposes, ’staff’ is defined broadly, and includes the Firm’s Partners and its employees.