Disclosure and Transparency

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 investments in any portfolio companies to which the Guidelines apply and so the disclosure requirements on us as a firm 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 (which is the FSA regulated entity), 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 pure fund manager 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 IPEVC valuation guidelines; and
• we are complying fully with the BVCA’s enhanced data collection programme.