Disclosure Policy

Graphite Capital is a responsible investor and strongly supports environmental and social initiatives across its portfolio companies.

We welcome the Guidelines for Disclosure and Transparency in Private Equity issued by the Walker Working Group (the Walker Guidelines). The Guidelines make recommendations in three areas:

disclosures by portfolio companies above certain size thresholds;
disclosures by the private equity firms which manage the investments in such companies; and
recommendations for the BVCA, including greater collection and dissemination of industry-wide data.

Graphite Capital does not manage any investments in portfolio companies to which the first part of the Guidelines apply. As a result the disclosure requirements on us as a firm in the second part also do not apply. However, we have voluntarily sought to comply with the Walker Guidelines wherever possible. In particular this website includes:

a description of Graphite Capital Management LLP, its history, investment approach and investment holding periods, illustrated with case studies;
the names and brief CVs of all the partners of Graphite Capital;
a description of our significant portfolio companies; and
a description of our funds and our investors.

Additionally we confirm that:

appropriate arrangements are in place to deal with conflicts of interest. Graphite Capital is a fund manager only and has no corporate advisory capability;
reporting to limited partners is of the utmost importance to us and we have regard to the EVCA reporting guidelines;
valuations are prepared having regard to the IPEV valuation guidelines; and
we are complying fully with the BVCA’s enhanced data collection programme.