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Jasper Ridge Partners, L.P.
201 Main Street, Suite 1000
Fort Worth, TX 76102
(817) 333-0027
www.jasperridge.com
March 31, 2025
This Brochure provides information about the qualifications and business practices of
Jasper Ridge Partners, L.P. (“Jasper Ridge Partners”). If you have any questions about
the contents of this Brochure, please contact us at 817-333-0027. The information in this
Brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any state securities authority.
Additional information about Jasper Ridge Partners also is available on the SEC’s website
at www.adviserinfo.sec.gov.
Copies of this Brochure may be requested by contacting Adán Araujo, Chief Compliance
Officer, at 817-333-0027 or aaraujo@jasperridge.com.
Additional information about Jasper Ridge Partners is also available via the SEC’s
website www.adviserinfo.sec.gov. The SEC’s website also provides information about
any persons affiliated with Jasper Ridge Partners who are registered, or are required to
be registered, as investment adviser representatives of Jasper Ridge Partners.
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Material Changes
Since our last annual update dated March 30, 2024, we have made the following material
change to this Brochure:
•
In the Client Referrals and Other Compensation section, we have added information
regarding our agreement with Clifford Street LLP (“Clifford Street”) pursuant to which
Clifford Street will introduce prospective investment advisory clients and/or prospective
private fund investors to Jasper Ridge Partners.
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Table of Contents
Cover Page .................................................................................................................................. i
Material Changes ........................................................................................................................ ii
Table of Contents ....................................................................................................................... iii
Advisory Business ....................................................................................................................... 1
Fees and Compensation ............................................................................................................. 2
Performance-Based Fees and Side-By-Side Management .......................................................... 8
Types of Clients .......................................................................................................................... 9
Methods of Analysis, Investment Strategies and Risk of Loss .................................................... 10
Disciplinary Information ............................................................................................................. 12
Other Financial Industry Activities and Affiliations ...................................................................... 12
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................ 14
Brokerage Practices .................................................................................................................. 17
Client Referrals and Other Compensation.................................................................................. 19
Review of Accounts ................................................................................................................... 20
Custody ..................................................................................................................................... 20
Investment Discretion ................................................................................................................ 21
Voting Client Securities ............................................................................................................. 21
Financial Information ................................................................................................................. 22
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Advisory Business
Jasper Ridge Partners is a wealth advisor and asset management firm providing tailored advisory
services. As of December 31, 2024, we managed approximately $40,116,659,292, of which
$39,566,649,649 was on a discretionary basis and $550,009,643 was on a non-discretionary
basis.
We provide advisory services to individuals and institutions in one of three ways:
First, we manage assets on a discretionary basis through investment vehicles, typically limited
partnerships, organized for each investor (the “Private Investment Vehicles”). These Private
Investment Vehicles may be created for individuals or institutions and are essentially separate
accounts.
Second, we manage nine privately offered pooled investment vehicles (collectively the “Pooled
Funds”): Jasper Ridge Diversified, L.P. (“JRD”), Jasper Ridge Diversified (Tax Exempt), L.P.
(“JRD TE”), Jasper Ridge Private Opportunities, L.P. (“JRPO”), Jasper Ridge Private
Opportunities TS, L.P. (“JRPO TS”), Jasper Ridge Private Opportunities II, L.P. (“JRPO II”),
Jasper Ridge Private Opportunities II TE, L.P. (“JRPO II TE”), Jasper Ridge Private Opportunities
II Offshore, L.P. (“JRPO II Offshore”), Jasper Ridge Private Investments, L.P. (“JRPI”), and Jasper
Ridge Private Investments (TE), L.P. (“JRPI TE”). JRD, JRD TE, JRPI, and JRPI TE are open-
end funds. JRD, JRD TE, JRPI, and JRPI TE are open to new and existing investors. JRPO,
JRPO TS, JRPO II, JRPO II TE, and JRPO II Offshore are closed-end funds which are past their
offering and investment period. Our investment professionals have ownership interests in the
general partnerships that manage the Pooled Funds. Jasper Ridge Partners is the investment
adviser to the Pooled Funds.
Third, we help individuals manage their overall wealth by managing their liquid portfolios and
administering their illiquid portfolios. We provide this service in conjunction with investments in
our Pooled Funds, with the overall goal of maximizing expected returns on a risk and liquidity
adjusted basis. In connection with those services, we also assist in developing and implementing
estate and philanthropic plans.
The Private Investment Vehicles, Pooled Funds, and individuals for whom we manage their
overall wealth, are collectively referred to as “Clients.”
Neither the Private Investment Vehicles nor the Pooled Funds are registered under the U.S.
Securities Act of 1933 or the U.S. Investment Company Act of 1940. Owners of the Private
Investment Vehicles and investors in the Pooled Funds must satisfy the applicable eligibility and
suitability requirements of a “Qualified Purchaser” (as defined in Section 2(a)(51)(A) of the
Investment Company Act of 1940).
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Depending on a Client’s objectives, we may invest in a broad mix of U.S. and foreign securities
and financial instruments, in both traditional and alternative asset classes. We invest in the
following: pooled vehicles (hedge funds, private equity funds, venture capital funds, mutual funds,
and exchange-traded funds) purchased either in primary or secondary transactions, public
equities, fixed income securities, cash equivalent instruments, currencies, real assets, natural
resources, private equity and co-investments in private equity, private debt, sponsors or general
partners of private investment funds, options, futures, warrants, derivatives, swaps/forwards, and
commodities, among other public and private instruments. We also engage in hedging
transactions, including foreign currency hedging, and use leverage.
Jasper Ridge Partners is independently owned and managed. Its partners control Jasper Ridge
Partners’ operations through several intermediary entities.
Jasper Ridge Partners is controlled by Jasper Ridge Genpar, LLC, which in turn is owned by JRP
Manager Holdings, L.P. JRP Manager Holdings, L.P. is controlled by JRP Manager Professionals,
L.P., which is ultimately controlled by Jasper Ridge Partners’ partners. Jasper Ridge Partners’
capital flows to JRP GP Holdings, L.P. and JRP Manager Holdings, L.P., whose ownership is
divided among Jasper Ridge Partners’ partners and professionals, as well as certain other third
parties.
Fees and Compensation
Overview
Fee and expense arrangements are described in detail in limited partnership agreements,
investment advisory agreements, private placement memoranda, subscription documents, and
other agreements we negotiate with Clients (collectively, “Governing Documents”). Terms reflect
the particular needs and characteristics of the services we provide to each Client, and as a result,
are negotiable. We have previously and may in the future waive or modify provisions of a specific
investor’s or limited partner’s Governing Documents, including the fees charged to the respective
investor or limited partner without obtaining the consent of any other investor or limited partner.
Additionally, the Private Investment Vehicles, Pooled Funds (collectively, “Client Vehicles”), and
accounts we manage may all have differing fees, fee structures, and expense arrangements.
Advisory Fees
In connection with providing advisory services to Clients, Jasper Ridge Partners charges Clients
a management fee, generally equal to a percentage of the assets held in a Client account.
Additionally, as described in more detail in the following section (entitled Performance-Based
Fees and Side-By-Side Management), Jasper Ridge Partners may also charge Clients a
performance fee based on a percentage of capital appreciation in a Client account. In all
instances, fees and expenses will be deducted from Client accounts, either in advance or arrears
depending on the Client agreement, on a quarterly basis. In the event an advisory relationship
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is terminated, any unearned fees beyond agreed-upon minimum fees, will be refunded on a pro
rata basis to the applicable Client.
Fee and expense arrangements between Jasper Ridge Partners and a Client Vehicle are
determined by the applicable Governing Documents. Fees for management or advisory services
provided to individuals depend on the services being provided and are negotiated separately with
each Client.
In calculating fees, Jasper Ridge Partners values the investments in accordance with generally
accepted accounting principles in the United States (“GAAP”). Valuations under GAAP generally
rely on third parties to value Client assets. Such third parties may include market data vendors,
external pricing services, the Client’s custodian, broker/dealer(s), or other discretionary
investment managers (e.g., separate account managers or the managers/general partners of
private investment partnerships). In addition, some assets may be fair-valued by our internal
valuation committee or marked-to-market, in accordance with GAAP when third party valuations
are not readily available or where we cannot rely on third party audited financial statements.
In addition to our fees, Clients typically incur fees charged by the general partner or manager of
underlying investments into which we invest on behalf of Clients, as well as the expenses noted
below.
Allocation of Expenses
General Policy
Jasper Ridge Partners bears its own direct administrative and overhead expenses, including all
expenses for rent, salaries, wages, bonuses and other employee benefits, office costs and
expenses, business development costs, non-client related outside legal expenses, and non- client
related travel and entertainment. Expenses incurred by Jasper Ridge Partners that are for the
direct benefit of Clients, including expenses incurred in connection with the sourcing, evaluation,
acquisition, monitoring or disposition of Client investments are allocated to Client accounts.
Jasper Ridge Services, LLC, is a separate entity and affiliate of Jasper Ridge Partners. It provides
accounting, record-keeping, reporting, tax services, legal, technology and other support services
for the benefit of Clients. It also provides similar support services, as well as regulatory compliance
services, to Jasper Ridge Partners. It employs the Chief Financial Officer, the General Counsel,
the Chief Compliance Officer, the Chief Technology Officer, the Controller, the Director of Human
Resources, attorneys, accountants, tax professionals, compliance professionals, technology
professionals, client and investor support personnel, paralegals, records clerks, administrative
professionals, and other operations personnel. Since it primarily provides support services for the
benefit of Clients, most of the expenses incurred by Jasper Ridge Services are borne by Clients,
with the remainder (including the cost of regulatory compliance services) borne by Jasper Ridge
Partners.
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Specifically, Clients bear Jasper Ridge Services’ expenses incurred to service Client accounts.
Jasper Ridge Services' expenses allocated to Clients include, but are not limited to, employee
salaries, bonuses, benefits, insurance, health and wellness incentives; rent, office costs and
expenses (including the costs of team-building initiatives and incentives); computer software,
party services; and other
other subscriptions and equipment; professional fees; related third
overhead costs and expenses.
‐
Jasper Ridge Partners bears Jasper Ridge Services’ expenses incurred to service the investment
adviser and its affiliates. Jasper Ridge Services’ costs and expenses (including personnel and
overhead costs) for accounting, legal and administrative support provided to Jasper Ridge
Partners, as well as regulatory compliance and marketing costs, are allocated to Jasper Ridge
Partners only and are not borne by Clients.
Some expenses are borne by a single Client; however, in certain cases, expenses are allocated
among multiple Clients. Such allocations may create a conflict of interest for us, since managing
multiple accounts with varying fee structures may create the incentive to favor accounts with
higher fees over accounts with lower fees—potentially resulting in a higher allocation of expenses
to low-fee paying Clients. Jasper Ridge Partners and Jasper Ridge Services have established an
expense allocation policy intended to mitigate risks related to this conflict of interest and ensure
that expenses are allocated in a fair, equitable, and consistent manner.
Although we strive to allocate expenses between Clients and Jasper Ridge Partners, and among
Clients, on a basis that we consider to be equitable, in some instances it will be necessary to
make adjustments, estimates, and approximations. Furthermore, the timing of such allocations
may be delayed due to lags in data production and periodic reporting by vendors.
Broken Deal Expenses
All costs and expenses incurred in connection with the due diligence of an investment that fails to
be consummated, including, but not limited to, outside legal and tax advice costs, internal legal
costs, travel, professional fees and research reports are allocated to the Client Vehicles that have
been identified as potential investors in the investment, in accordance with Jasper Ridge Partners’
expense allocation policy. In some instances, Client Vehicles that have demand for a specific
investment may be withdrawn from participation in the investment should Jasper Ridge Partners
determine that such Clients are no longer viable investors in the investment. (Client demand for
potential investments is determined by a proprietary portfolio construction framework.) Should
such withdrawal occur during the due diligence process, any expenses that are charged to the
Client Vehicle will be limited to the expenses incurred before the point at which we determined
that the Client Vehicle is not a viable investor.
Whenever a Jasper Ridge professional or employee invests alongside Clients directly or through
an entity such as a special purpose vehicle, such professional or employee will bear his/her
portion of all applicable expenses as if he/she were a Client.
Outside Legal Costs and Expenses
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Outside legal costs incurred for the benefit of Clients are generally paid directly by Jasper Ridge
Services and then allocated to the Client Vehicles/entities responsible for such costs, according
to Jasper Ridge Partners’ expense allocation policy. Allocations of outside legal costs may
include:
• Outside legal costs incurred by Jasper Ridge Partners on behalf of a Client Vehicle,
including costs related to its formation, the preparation or amendment of its constituent
documents and any other similar costs, will be allocated to such Client Vehicle only.
•
Outside legal costs that are incurred in connection with the general investment activities
of Jasper Ridge Partners for the benefit of multiple Client Vehicles will only be allocated
to the designated Client Vehicles that are expected to receive the benefit of such general
investment activities, pro rata in proportion to their assets under management.
•
Outside legal costs incurred in connection with an investment, but prior to its closing,
(whether or not such investment is ultimately consummated) will be allocated to the
Client Vehicles identified by Jasper Ridge Partners’ investment professionals as having
demand for such opportunity, pro rata in proportion to their demand for the investment.
•
Outside legal costs billed in connection with an investment that is ultimately closed will
be allocated to the Client Vehicles invested therein, pro rata in proportion to their capital
commitments to such investment.
Travel Expenses
Travel expenses, including, but not limited to, first-class airline travel, are allocated according to
Jasper Ridge Partners’ expense allocation policy. Allocations of travel expenses may include:
•
Travel expenses incurred by an investment professional in connection with due diligence
or monitoring of investments (whether or not consummated) are allocated to, and
reimbursed by, those Client Vehicles designated by the investment professional as
having an interest in, a current investment in or demand for a particular manager or
investment opportunity.
•
Travel expenses related to due diligence for future investments are allocated to
designated Client Vehicles based on the Client Vehicles’ potential demand for an asset.
•
Travel expenses related to monitoring current investments are allocated pro rata among
Client Vehicles currently invested in the investment being monitored pursuant to the
pertinent Client Vehicles’ ownership in the specific investment relative to other Clients.
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•
Travel expenses related to in-person Client meetings may be allocated to Clients where
permitted by the Client’s Governing Documents.
•
Travel expenses incurred by a Jasper Ridge Services employee in connection with the
general provision of support services to Clients are allocated to currently-investing Client
Vehicles, pro rata in proportion to the assets under management of such Client Vehicles.
•
Travel expenses incurred by a Jasper Ridge Services employee in connection with the
business matters of a particular Client Vehicle are allocated to such Client Vehicle only.
Data Service Expenses
•
All costs of investment-related data charged by service providers in connection with the
provision of services to Client Vehicles are allocated among Client Vehicles with
mandates that benefit from the use of such service providers according to the pertinent
Client Vehicles’ demand for the asset class for which the data is being provided.
•
The costs of software and data services that are used by both Jasper Ridge Partners
and Jasper Ridge Services (such as e-mail and IT products and support services) are
allocated among the two entities based on their respective head count.
Miscellaneous Expenses
Each Client Vehicle will pay to, or reimburse, Jasper Ridge Partners for all external and internal
operating and administrative expenses attributable to the Client Vehicle, including the following:
• expenses incurred in connection with the sourcing, evaluation, acquisition, monitoring
or disposition of the Client Vehicle’s investments (whether or not consummated),
including: loan fees; brokerage commissions; research fees; interest and commitment
fees; transfer taxes and premiums; underwriting commissions and discounts; legal,
accounting, investment banking, consulting, information services and professional fees;
costs of procuring computer software and hardware for use in research activities; travel
(including first-class airfare, hotels, meals and incidentals); communications; and other
expenses related to the discovery, assessment, due diligence, development, initiation
and disposition of investments (whether or not consummated);
•
expenses incurred in connection with the carrying or management of Client Vehicle
investments, including interest and related expenses and custodial, trustee, record
keeping and other administrative fees and expenses;
• amounts payable under indemnification provisions in applicable Governing Documents;
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•
expenses incurred in connection with any leverage or other indebtedness of the Client
Vehicle, including, without limitation, borrowings, dollar rolls, reverse purchase
agreements, credit facilities, margin financing, total return swaps and the issuance of
debt securities;
•
attorneys’ and accountants’ costs, fees, and disbursements, including in-house legal,
accounting, tax, and personnel-related expenses and disbursements (including
employee salaries, bonuses, benefits, insurance, health and wellness incentives; rent,
office costs and expenses (including the costs of team-building initiatives and
incentives); computer software, other subscriptions and equipment; professional fees;
party services; other overhead costs and expenses; and expenses incurred
related third
in connection with any amendments, modifications, or revisions of the Governing
‐
Documents);
•
third-party administrators and consultants’ fees;
•
taxes and other governmental charges levied against the Client Vehicle;
•
insurance, regulatory and litigation expenses;
•
expenses (including legal fees) incurred in complying with any law or regulation related
to the activities of a Client Vehicle, including on-going offerings of interests in the Pooled
Funds, such as costs related to new investors, additional investments by existing
investors and any “blue sky” filing fees;
• costs and expenses incurred in connection with the dissolution, winding up or
termination of a Client Vehicle;
•
costs and expenses incurred in connection with the valuation of investments or other
property held by (or on behalf of) a Client Vehicle;
•
costs and expenses incurred in connection with distributions to limited partners (or other
beneficial owners) of a Client Vehicle;
• costs and expenses incurred in connection with the accounting, tax compliance, and
reporting requirements of a Client Vehicle, including but not limited to, preparation,
review and audit of the Client Vehicle reports, tax returns and related disclosure
schedules; costs incurred by the tax matters partner or partnership representative acting
in such capacity; preparation and delivery of financial statements, reports, tax returns
and Schedule K-1s (or similar schedules) of the Client Vehicles; and
•
conference-related expenses if they relate to monitoring, due diligence or sourcing of a
specific investment.
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Allocation of Fees and Expenses to Individual Clients
For individual Clients, we may provide certain administrative services for illiquid securities held by
Clients directly or at other institutions. Examples of such services include managing capital calls
and monitoring distributions. In addition, we may provide discretionary investment advice with
respect to a portion of the Client's marketable securities held in accounts at other financial
institutions. We provide these services in conjunction with their investment in a Client Vehicle.
Due to the nature of these services to individual Clients, many expenses listed above for Client
Vehicles may not be applicable. In such an event, we negotiate an arrangement with each
individual Client whereby the costs and expenses for providing administrative services are
charged back to the Client. Typically, Clients set an explicit limit on the amount that they can be
charged or are required to reimburse us for the incurred cost of services provided, generally on a
time-spent basis.
Performance-Based Fees and Side-By-Side Management
We have entered into performance fee arrangements with some of our Clients. The terms of the
performance fee arrangements vary among Clients. There are different return hurdles and
different fee arrangements reflecting the customized objectives and preferences of each Client.
We have and will structure any performance or incentive fee arrangement subject to Section
205(a)(1) of the Investment Advisers Act of 1940 in accordance with the available exemptions,
including the exemption set forth in Rule 205-3. In measuring Clients' assets for the calculation of
performance-based fees, we include realized and unrealized capital gains and losses.
Performance-based fee arrangements generally align incentives with Client goals, although, they
can also create conflicts of interests. Such fee arrangements may create an incentive for us to
recommend investments that are riskier than those which would be recommended under a
different fee arrangement. We have implemented procedures designed to mitigate such
incentives, such as rigorous committee approval processes for investments and various forms of
monitoring and testing investment decisions. They may also create an incentive to purchase
securities that are certain to receive a mark-up in value soon after acquisition. For example,
secondaries are generally purchased at a discount to net asset value and initially recorded at the
purchase price for the transaction. They are subsequently marked up to net asset value (generally
in the following quarter) in accordance with applicable accounting standards, thereby positively
impacting performance. Thus, the subsequent mark-up in those assets’ values will affect the
performance fee calculation.
Performance-based fee arrangements also create an incentive to favor some accounts over
others in the allocation of investment opportunities. For example, they create an incentive to
allocate investments with higher expected returns (such as secondaries and co-investments) to
Clients that have high hurdle rates or more profitable fee arrangements. We employ procedures
designed to manage and mitigate this conflict. These procedures apply a formulaic approach to
constrained allocations but preserve the flexibility for Jasper Ridge Partners to determine on a
case-by-case basis the most fair and appropriate set of factors to consider when allocating
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constrained investment opportunities among Clients in consideration of their specific portfolio
holdings, liquidity, objectives, and customized mandates.
In cases of constrained investment opportunities (where we determine that our Clients’ demand
for an investment exceeds the amount that is available), the investments will generally be
allocated pro rata (based on each Client’s appetite for the investment) between or among Clients
with demand for the investment. However, in some instances, we implement an allocation that
results in a Client obtaining less than the Client’s pro rata share depending on a number of factors,
including: underlying portfolio constraints, minimum investment size, existing commitments to
similar opportunities (by number and/or amount), investment policies or requirements, target
allocations, overall portfolio risk and return characteristics, legal and tax considerations. Similarly,
we have previously and may in the future implement an allocation that results in a Client obtaining
more than the Client’s pro rata share depending on numerous factors, including a Client’s pre-
existing commitments to, or special relationship with, an underlying fund manager. For purposes
of this policy, Client Vehicles that are part of a series of similar vehicles—such as JRPO, JRPO
II, JRPI, and JRPI TE —are considered one Client. Although we monitor allocation decisions in
an attempt to ensure that no Client is routinely or consistently favored over any other Client in the
allocation process, there is no assurance that a Client will receive a pro rata allocation of any
particular constrained investment opportunity.
In making the determination of pro rata allocation, we consider the volume of investments
available to both taxable and tax-exempt Clients in an attempt to ensure that the pro rata allocation
is fair over time (not necessarily on a deal-by-deal basis) to both taxable and tax- exempt Clients,
in light of the opportunity set available to each type of Client. This approach is taken since not all
investments are appropriate for tax-exempt Clients, so they will not be able to participate in certain
investments, and they will generally have fewer investment opportunities. In situations where both
taxable and tax-exempts can participate, taxable Clients have previously and may in the future
obtain a smaller allocation than if we did not employ this approach and used a simpler pro rata
approach. Similarly, tax-exempt Clients have previously and may in the future receive a higher
allocation to investments in which they can participate alongside taxable Clients.
Types of Clients
Jasper Ridge Partners’ Clients are the Private Investment Vehicles created to manage assets for
individuals and institutional Clients, the Pooled Funds, and the individuals who receive our
comprehensive wealth management services. Certain Clients, such as Pooled Funds, have
minimum investment amounts as set forth in their Governing Documents; however, Jasper Ridge
Partners has the discretion to waive such minimum investment amounts.
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Methods of Analysis, Investment Strategies and Risk of Loss
Our professionals monitor the markets on both a macro and micro level. We employ fundamental,
technical, and cyclical analysis. In constructing and managing portfolios, we consider expected
investment returns and risks, covariances among different asset classes, risk tolerances of our
Clients, tax considerations, liquidity factors, and leverage constraints.
The strategies we employ depend on the Clients’ objectives. We manage some Clients’ assets
with the goal of creating a diversified, endowment-style portfolio. Other Clients have given us
more limited mandates, such as constructing portfolios comprised solely of private equity
investments or managing their existing liquid and illiquid portfolios in conjunction with investments
in our Pooled Funds. In addition to long-term model portfolios, tactical tilts may be employed,
reflecting our views on short-term market dislocations or special investment opportunities that
may materialize.
We select and monitor investments, including investments in managers of pooled funds or other
investment vehicles or accounts in which our Clients may invest, based on research, interviews,
and our analysis and assessments. Jasper Ridge Partners selects and monitors these
investments based on our diligence, which, for primary fund investments, includes, but are not
limited to, available market data, investment performance, risk management techniques,
performance volatility, investment philosophies and factors relating to their senior managers and
investment professionals such as experience, industry relationships, insight, and commitment.
Secondary investments are analyzed based on the quality of the portfolios’ assets and their
management teams, discounts to net asset value, our competitive advantages in the bidding
process, the ability to invest on favorable economic terms, the amount of unfunded commitments,
and other related factors. Direct investments or co-investments are analyzed based on a risk
adjusted approach of the particular investment opportunities, including their risk adjusted return
profile in comparison to other investment opportunities. Hedge fund investments are based on
numerous factors, including the investments’ risk-return profile, fees and expenses, market beta,
and fund terms, among other factors. Direct investments in publicly traded, liquid market securities
are based on multiple factors, including their betas to underlying asset classes, performance,
costs, and liquidity. This description of factors considered for each investment is not exhaustive.
In addition, we regularly monitor Client accounts to assess whether rebalancing or reallocations
are warranted.
While we seek to produce superior, risk-adjusted investment returns, there can be no guarantees.
Investments in securities involve risk of loss that Clients should be prepared to bear. We may
underperform the overall stock market and/or specific indices or benchmarks. We may not be able
to select the best third-party managers for our Clients’ investments. Portfolio construction or
security selection decisions may also result in negative performance. We may be unsuccessful
in attempts to hedge risks with options, futures, swaps, and currency hedges and investments in
such derivative instruments can pose greater risks than investments in securities. We may not be
able to access sufficient quantity of certain investments (such as secondaries, co-investments,
and certain oversubscribed managers) to satisfy all of our Clients’ demand for such investments.
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Investments in foreign securities may be riskier than investments in U.S. securities due to:
changes in currency rates versus the dollar, higher transaction costs, political risks in foreign
countries, the existence of smaller or less liquid markets, and the possibility of less rigorous
accounting and reporting standards for foreign companies. Investments in real assets, natural
resources, hedge funds, private equity and venture capital present liquidity risk – the risk that the
investments may be difficult to buy or sell in the markets, potentially resulting in unfavorable
prices. Similarly, investments in fixed income securities pose a number of unique risks, including
interest rate risk, credit risk, and prepayment risk. In short, we invest in a wide range of
instruments, each of which poses unique risks. All of the risks cannot be thoroughly explained
here, but we manage assets on behalf of sophisticated investors. They generally have a solid
understanding of the markets and the risks involved in our methods and strategies, which we
discuss in more detail with Clients at periodic meetings or at their request. Furthermore, for
investors in the Client Vehicles, a more comprehensive description of risks is contained in the
Governing Documents for the Client Vehicles.
Environmental, Social and Governance Factors
In addition to the considerations discussed above, we also seek to integrate review of
environmental, social and governance (“ESG”) factors into our processes for selecting
investments whenever we determine applicable and reasonably possible, consistent with our ESG
policies and processes. When making investments, our ability to influence and exercise control
over investments will vary based on the investment structure and terms. For example, when we
make blind pool commitments to third-party funds, we rely on the fund’s managers to use
appropriate judgment when evaluating ESG-related issues. In those instances, we typically have
no ability to influence the managers’ decisions, only to decide whether to invest in the manager
or not. In other instances, such as where we make direct investments in private companies, we
may have more ability to judge and affect ESG factors.
Our consideration of ESG factors is qualitative and subjective by nature; therefore, there is no
guarantee that the criteria utilized by us, or any judgment exercised by us, will reflect the beliefs
or values of any particular Client or investor. There are significant differences in interpretations of
what ESG characteristics mean by region, industry, and topic, as well as interpretations of their
scope and materiality. ESG practices are also evolving rapidly across the financial services
industry and could become subject to additional regulation in the future. Accordingly, our
interpretations, approach, and decisions with respect to the consideration of ESG factors are
expected to vary over time.
In addition, in evaluating an investment, we expect to depend upon information and data provided
by several sources, including the investments’ managers and various reporting sources which
could be incomplete, inaccurate, or unavailable, and which could cause us to incorrectly assess
a company’s ESG practices or related risks and opportunities. We do not intend to independently
verify all ESG information reported by investments or third parties.
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Further, our consideration of ESG factors may cause us to make an investment or to refrain from
pursuing certain investments. It may also cause us to make a management decision with respect
to an investment, differently than we would have made in the absence of considering ESG factors.
Importantly, while we consider ESG factors, they are not the only consideration we review when
evaluating an investment decision. Unless your investment mandate specifically instructs us
otherwise with respect to your account(s), we will not make any investment decision or
management decision based upon our consideration of ESG factors alone or sacrifice investment
returns for the subset of investments we do pursue in exchange for furthering ESG interests. We
will base our decision upon a complete review of all relevant factors and consistent with our
fiduciary duty.
Once we have made an investment, we typically have limited options to affect the investment, so
our monitoring activities with respect to ESG factors are usually passive in nature.
We reserve the right to change our ESG policies and processes at any time if we determine
appropriate to do so and in certain circumstances could determine that it is not feasible or practical
to implement or complete certain ESG practices based on cost, timing or other considerations. It
is also possible that market dynamics or other factors will make it impractical, inadvisable, or
impossible for us to adhere to all aspects of our ESG policies and processes.
Disciplinary Information
There are no legal or disciplinary events that would be material to an evaluation of Jasper Ridge
Partner’s advisory services or the integrity of its management.
Other Financial Industry Activities and Affiliations
Relationships with Other Entities
Jasper Ridge Partners was previously one of several independently owned and managed
investment platforms that shared the name “Oak Hill”, each of which grew out of the Robert M.
Bass family office and each of which is focused on a specific type of investment product. Currently,
the Oak Hill platforms are comprised of the following separately managed investment
partnerships: Oak Hill Capital Management, LLC (a private equity firm) and Oak Hill Advisors,
L.P. (a debt securities firm), (collectively, the “Oak Hill Entities”). Certain Jasper Ridge Partners’
professionals, founders and Clients have minority, passive economic interests in the general
partners of select legacy partnerships managed by the Oak Hill Entities. In addition, certain
principals of the Oak Hill Entities have passive, minority ownership interests in Jasper Ridge
Partners’ general partner vehicles and may invest in portfolios or investments managed by Jasper
Ridge Partners. Additionally, one of our equity holders and former managing partner, George
Phipps, serves on the board of directors of The Bessemer Group, Incorporated and its principal
subsidiary banks and the board of managers of Bessemer Securities LLC and its principal
subsidiary.
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Investments in Entities that have some Affiliation
Jasper Ridge Partners occasionally invests in investments, including private funds, offered and
managed by the Oak Hill Entities. Conflicts may arise as a result of the affiliations and cross-
ownership between Jasper Ridge Partners and the Oak Hill Entities. Jasper Ridge Partners will
try to manage these conflicts in an attempt to minimize the effect on Clients, but there can be no
assurance that conflicts will be eliminated.
We occasionally also invest in Bessemer affiliated private funds. Investments in Bessemer
affiliated private funds or in Oak Hill Entities are only made after objectively assessing their
appropriateness, as noted below in the section entitled “Investments by Jasper Ridge Partners or
its Related Persons.”
Co-Investments with the Oak Hill Entities
Co-investments by Jasper Ridge Partners or its Clients and the Oak Hill Entities may raise
significant conflicts of interest for the same reasons of affiliation and cross ownership. Similarly,
the Oak Hill Entities may enter into transactions with portfolio companies of Jasper Ridge
Partners, which also may raise the same significant conflicts of interest. To the extent that Jasper
Ridge Partners enters into any such co-investments or any portfolio company enters into any such
transactions, the terms of such transactions will be on an arm’s length basis to Jasper Ridge
Partners and Clients.
Jasper Ridge Partners and the Oak Hill Entities may from time to time acquire investments in the
same portfolio company, as part of a single transaction or otherwise. Any investment by Jasper
Ridge Partners in which any of the Oak Hill Entities participate may present conflicts of interests,
particularly if Jasper Ridge Partners and the Oak Hill Entities invest in different classes or types
of securities of the same portfolio company.
Investments Managed by Jasper Ridge Partners’ Clients or Fund Investors
Jasper Ridge Partners invests Client assets in third-party pooled funds or private investments
whose founders, principals, or managers are Jasper Ridge Clients or investors in our Client
Vehicles. We do so only after evaluating the attractiveness of the investments on a stand-alone
basis and believe that some of these relationships may benefit our Clients by providing us access
to investments we may not otherwise be able to obtain. The relationships can be material. Some
of these investments made on behalf of Clients are substantial and some of these individuals
have invested significant sums of money with us. These situations present conflicts, such as
creating an incentive for us to invest Client assets in the funds or entities controlled by those
individuals who are our Clients or invest in our funds. To mitigate the conflicts, we employ
procedures to ensure that each Client investment is appropriate as noted in the Code of Ethics
section below.
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Side Letters
The Pooled Funds occasionally enter into letter agreements or other similar agreements
(collectively, “Side Letters”) with some of their limited partners, which provide such limited partners
with different rights (including, with respect to access to information, fee arrangements, minimum
investment amounts and exclusion from participation in certain investment transactions) than
other limited partners. The Pooled Funds are typically not required to notify the other limited
partners of any such Side Letters or any of the rights, terms or provisions thereof; nor are the
Pooled Funds required to offer such additional or different rights or terms to the other limited
partners. Such rights may include, among others, the right to sell a limited partner’s interest in a
Pooled Fund to the general partner (or its affiliates) at an agreed upon price in the event that
certain specified events that could create a conflict of interest. Any acquisition of a Pooled Fund
interest in accordance with any such Side Letter provision shall not constitute an investment
opportunity of a Pooled Fund, and no limited partner shall have any right to participate in any such
acquisition.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
We have implemented a securities compliance policy that includes a formal code of ethics and
insider trading policies and procedures. Among other things, the policy requires that employees
act with integrity, place the interests of Clients above their own, avoid actual and potential conflicts
of interests and comply with applicable provisions of the federal securities laws. The policy also
requires employees to pre-clear certain personal securities transactions, report personal
securities transactions on at least a quarterly basis and provide Jasper Ridge Partners with a
detailed summary of certain securities holdings annually.
We have also adopted a gift policy that applies to all Jasper Ridge Partners employees. Generally,
the giving or receiving of gifts in excess of $500 from or to a person who does business with, or
is seeking to do business with Jasper Ridge Partners, or a Client, investor or prospective Client
or investor must be pre-approved by the Chief Compliance Officer.
A copy of Jasper Ridge Partners’ securities compliance policy will be provided to any Client or
prospective Client upon request.
Participation or Interest in Client Vehicles
Our affiliates serve as the general partners of the Client Vehicles and may have capital invested
in the Client Vehicles along with the limited partners. These entities receive compensation, as
noted in the relevant partnership documents, for acting as the general partners.
When providing wealth management services, which are offered in conjunction with investments
in our Pooled Funds, we may recommend further investments in our Pooled Funds. As the Pooled
Funds’ adviser and general partner there is a conflict when we recommend an investment in a
Pooled Fund. We mitigate the conflict by following practices, policies, and procedures aimed at
ensuring that we fulfill our fiduciary duty to our Clients and only recommend appropriate
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investments. In addition, our Clients are high net worth individuals, typically sophisticated on
investment matters, and receive additional information about our Pooled Funds, including
information contained in Governing Documents, historical performance data, and various other
sorts of information which are available upon request.
As noted above, Jasper Ridge Services, an affiliate of Jasper Ridge Partners, provides
accounting, legal and other support services to Jasper Ridge Partners and the Client Vehicles.
Investments by Jasper Ridge Partners or its Related Persons
Jasper Ridge Partners’ professionals invest on a no-fee or reduced-fee basis in the Pooled
Vehicles that we offer to Clients.
Jasper Ridge Partners and its professionals have previously, and may in the future, invest in the
same securities that we recommend to Clients. We co-invest, along with our Clients, in individual
companies, securities, limited partnerships, hedge funds, venture capital funds, or distressed debt
funds, among other investment vehicles. We typically co-invest on terms that are substantially
similar to those offered to our Clients. In some instances, we receive lower fees or a different
arrangement than those available to our Client Vehicles. In addition, conflicts arise where we have
an interest in an investment and an incentive to bring in additional investors.
Jasper Ridge Partners and its affiliates have previously, and may in the future, also participate,
along with our Clients, in opportunities to invest in the sponsors or general partners of private
investment funds, including those of the Oak Hill Entities. These transactions typically consist of
a minority and non-controlling passive investment in the fund sponsor’s management company,
as well as the right to invest in the general partner of the investment entity, entitling investors to a
portion of the management fee and/or carried interest income streams. They may also include a
right or an obligation for the participants to invest in one or more of the sponsor’s investment funds
on beneficial economic terms, such as reduced management fees or carried interest percentages.
Jasper Ridge Partners may participate through its general partner in the Client Vehicles (since
the general partner typically invests alongside the limited partners of a Client Vehicle) and its
professionals may invest in the transactions with Client Vehicles on a side-by- side basis.
These transactions present conflicts of interest between Jasper Ridge Partners and Clients or
among Jasper Ridge Partners’ Clients. Conflicts arise when, among other issues:
• Jasper Ridge Partners or its professionals are investing on materially different terms and
conditions than Clients;
• Jasper Ridge Partners or its professionals are not investing with the same relative ratio
as participating Clients in the fund manager and its funds;
• Jasper Ridge Partners wishes to invest a Client in a subsequent fund of the fund
manager and the Client did not participate in the fund manager transaction; or
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• Clients are invested in prior funds of the fund manager but are not participating in the
fund manager transaction.
Jasper Ridge Partners will evaluate each investment opportunity to determine whether a specific
conflict exists that may require Client notification and/or consent.
Certain principals of the Oak Hill Entities have passive, minority ownership interests in Jasper
Ridge Partners and may invest in investments managed by Jasper Ridge Partners.
Jasper Ridge Partners has previously, and may in the future, invest Clients’ assets in investments,
including private funds, offered and managed by the Oak Hill Entities. Conflicts arise as a result
of the affiliations and cross-ownership between Jasper Ridge Partners and the Oak Hill Entities.
Jasper Ridge Partners will manage these conflicts in an attempt to minimize the effect on Clients,
but there can be no assurance that conflicts will be eliminated. Investments in Oak Hill Entities
are only made after assessing their appropriateness, as noted below. In addition, as noted above,
we may also invest Client assets in third-party pooled funds or private investments whose
founders, principals, or managers are Jasper Ridge Clients or investors in Client Vehicles.
In every instance, a Client investment is made only after determining that it is appropriate for each
Client’s portfolio based on the Client’s investment objectives. The fee and carry arrangements at
the fund level must also be appropriate and consistent with market standards. Jasper Ridge
Partners’ investment decisions are made at the time of investment, in our capacity as a manager,
independent of any related persons’ ownership interest in the management structure for the
investment and without regard to any personal investments held by third party managers in a
Jasper Ridge Partners’ fund or vehicle. In each case, any such investment or transaction is made
on terms and conditions that are no less favorable to the Client than if it had been entered into
with an independent third-party. On an ongoing basis, Jasper Ridge Partners periodically monitors
and evaluates these investments on behalf of the Client.
To mitigate conflicts, if a particular Jasper Ridge Partners professional has a material conflict of
interest with respect to an investment for a Client, that professional will recuse himself or herself
from performing analysis on the investment and voting on the Investment Committee for or against
the investment, although such professional may participate in the discussion of such investment
with the members of the Investment Committee.
Non-Exclusivity of Client Vehicles
Potential conflicts of interest may exist for Clients. They are described in the Governing
Documents. Jasper Ridge Partners and its affiliates manage other investment partnerships or
separate accounts, some of which follow substantially similar investment programs. Jasper Ridge
Partners and its affiliates are generally not restricted from allocating investment opportunities
(including limited opportunities) to other Clients, forming additional Client Vehicles, entering into
other investment advisory relationships, or engaging in other business activities, even though
such activities may be in competition with existing Clients and may involve substantial time
and resources of Jasper Ridge Partners. These activities could be viewed as creating a conflict
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of interest in that the time and effort of Jasper Ridge Partners and its officers and employees will
not be devoted exclusively to the business of a specific Client, but instead, would be allocated
between the business of such Client and the management of the monies of other advisees of
Jasper Ridge Partners.
Although the partners of Jasper Ridge Partners devote substantially all of their time and attention
to the management of the affairs of Jasper Ridge Partners, they may also engage in other
business activities and investments. Any of Jasper Ridge Partners’ principals may serve as an
officer, director, advisor, or in comparable management functions for portfolio funds or companies
in which a Client invests, and may be compensated as a result, creating a conflict of interest. As
a result, Jasper Ridge Partners may, under certain circumstances, be prohibited for a period of
time from engaging in transactions with respect to the securities of such a portfolio company,
which may have an adverse effect on such Client.
Brokerage Practices
Due to the asset classes employed and the focus on investing in private assets and pooled funds,
we do not seek to actively trade in publicly listed securities. We do manage public securities
received as distributions from private funds, engage in hedging transactions, and regularly
purchase and sell futures and ETF shares. When a particular Client’s investment objective or
strategy requires the services of a broker/dealer, our main rationale for selecting a broker/dealer
to execute Client transactions is based primarily upon the broker’s ability to deliver the best
qualitative execution for our Clients. The factors that we use in making this determination include
the following:
• price per unit of the security or instrument,
• depth and breadth of the market accessible to customers of the broker/dealer,
• reliable two-way markets,
• commission rates or mark ups,
• ability to deliver prompt, accurate confirmations and on-time delivery of securities,
• ability to post collateral for certain trades (such as over the counter trades) and the
capacity to segregate, protect, and return in a timely manner collateral posted by Jasper
Ridge Partners,
• ability to maintain confidentiality of our Clients’ identity and trading intentions,
• ability to structure trades in a thoughtful and economical manner,
• ability to assist us in the trade process for large or complex trades,
•
financial and operational stability,
• accuracy of information (e.g., valuations),
• effective operational risk management,
• ability to help us navigate through tax, legal, and regulatory issues,
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• quality of personnel,
• ability to operate in different jurisdictions,
• ability to provide timely and relevant views on market structure and the trading
environment;
• other relevant factors that may impact the price or execution quality of a trade, and
• other execution capabilities.
We are not required to solicit competitive bids or seek the lowest available commission or
transaction cost. The commissions or transaction costs (including spreads) charged by any broker
may be greater than the amount another firm might charge if we determine in good faith that the
amount of such commission is reasonable in relation to the value of the brokerage services.
Generally, our choice of broker/dealer will depend on the security or instrument we are trading.
For exchange-traded funds and mutual funds (for which third-party brokers are used), we will
generally use a broker that can execute the trade at the national best bid and offer on an agency
basis, or a broker with the ability to act as an Authorized Participant for the purposes of creating
or redeeming fund units. The broker’s commissions must be reasonable in comparison to those
generally available in the market place for similar trades. For in-kind distributions from private
equity funds, we will generally use a single specialist broker or its affiliate. We do so to avoid time
delays, costs, and potential errors that may result from executing through a large number of non-
core relationships. Trades of other individual securities will be executed through a broker that can
provide the best qualitative execution based on the factors enumerated above. Derivative
transactions, including exchange-traded derivatives and over-the-counter derivatives, are more
complicated than other securities trades and the qualitative factors noted above, as well as the
value of existing relationships will be primary consideration factors.
Jasper Ridge Partners does not have a soft dollar arrangement with any broker, nor does any
broker provide Client or investor referrals. However, we may receive certain products and services
in addition to brokerage services from a broker/dealer, those being primarily research reports
provided to us as a Client by broker/dealers that we use to execute trades. In every instance, the
receipt of such services will be in accordance with the safe harbor provided by Section 28(e) of
the Securities Exchange Act of 1934. To the extent we receive research, we will generally use
the research for any Clients who may benefit from the research.
When we determine that one or more Client Vehicles should participate in an investment
opportunity, Jasper Ridge Partners will seek to execute orders for all of the participating funds or
accounts, on an equitable basis, taking into account such factors as investment objectives,
tolerance for risk, relative amounts of available capital, duties, portfolio concentration and
weighting, liquidity, diversification, investment policies, objectives or requirements applicable to
each Client, relative exposure to market risk factors, fiduciary duties, priority for pre-existing
investments, contractual restrictions, and legal, tax and other factors applicable to each Client
Vehicle as well as the structure, terms and nature of the consideration being provided in the
particular transaction.
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With respect to trade execution, if applicable, orders for the same security entered on behalf of
more than one Client Vehicle will generally be aggregated, provided that the aggregation is in
the best interests of all participating Client Vehicles. All Clients participating in each aggregated
order shall receive the average price, subject to minimum ticket charges and minor fill differentials,
and pay a pro rata portion of commissions and/or execution costs. If an order on behalf of more
than one account cannot be fully executed under prevailing market conditions, securities may be
allocated among the different accounts on a basis that Jasper Ridge Partners or its affiliates
considers equitable and in accordance with a fair allocation mechanism.
Directed Brokerage
Clients may direct us to use certain broker/dealers to execute trades on their behalf. In those
instances, we will use the broker/dealer that the Client directs us to use, and we will not be
governed by the strictures of our best execution policies. Clients that direct us to use a
broker/dealer may not obtain best execution and directing brokerage may cost Clients more
money. In directed brokerage arrangements, we may not be able to aggregate orders to reduce
transaction costs, or Clients may receive less favorable prices.
Cross Trades
From time to time, securities to be sold on behalf of one Client may be suitable for purchase by
another Client. In such circumstances, if Jasper Ridge Partners determines in good faith that the
transaction is in the best interests of and advantageous to both Clients, the securities may be
transferred between such Clients. Jasper Ridge Partners and its affiliates shall not receive a
commission directly or indirectly in connection with any such trade. The rationale for such trades
is generally to avoid commissions, mark ups, bid-offer spreads, and market risks for Clients
involved in the trade. There may be other reasons for doing a cross trade, but in all instances, we
employ procedures to ensure no Client will be disadvantaged by entering into the cross trade.
In-Kind Distributions
During the realization of successful investments, we occasionally have the opportunity to receive
securities in-kind from fund managers to whom we have allocated capital. Often these securities
are highly appreciated with low tax basis and may be attractive charitable currency. As an
alternative to selling them inside of a Pooled Investment Vehicle and realizing capital gains, we
may periodically have the opportunity to distribute these securities to investors in such Pooled
Investment Vehicles to use for charitable gift purposes. Investors who are interested in
participating in such distributions can contact our investor relations team.
Client Referrals and Other Compensation
Compensation from a Third Party
Jasper Ridge Partners does not receive any economic benefit from any third party for providing
advisory services.
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Compensation to a Third Party
Jasper Ridge Partners has entered into an agreement with Clifford Street LLP (“Clifford Street”),
a firm based out of the United Kingdom, pursuant to which Clifford Street introduces prospective
foreign and United States based investment advisory clients and private fund investors to Jasper
Ridge Partners.
In consideration for Clifford Street’s introductions, Jasper Ridge Partners pays Clifford Street a
flat quarterly fee. Additionally, Jasper Ridge may pay Clifford Street an annual discretionary bonus
of such amount and subject to such conditions as Jasper Ridge may determine appropriate from
time to time. The fees clients or investors pay to Jasper Ridge will not increase as a result of the
compensation paid by Jasper Ridge Partners to Clifford Street. Further, with respect to US
prospects, Clifford Street will not (i) engage in distribution or marketing services that constitute
sales and/or marketing of Jasper Ridge Partners products or advisory services or (ii) act as a
placement agent, broker or dealer for private funds managed by Jasper Ridge Partners, and no
part of the above-referenced compensation shall be for such activities.
Due to the above-referenced compensation, Clifford Street is incentivized to recommend Jasper
Ridge Partners to prospective investment advisory clients and/or prospective private fund
investors instead of the investment advisory services or private funds of other investment
advisers, resulting in a material conflict of interest for Clifford Street.
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Review of Accounts
Our senior investment professionals regularly review Client accounts to monitor performance,
assess investment opportunities for Clients, and determine whether rebalancing or reallocations
are warranted. Such reviews are typically performed on a quarterly basis. Similarly, the
performance of third-party investment funds is monitored on a regular basis and is subject to
ongoing supervision and review by Jasper Ridge Partners’ senior investment professionals.
Limited partners and investors of the Client Vehicles generally receive quarterly reports regarding
their investments in the Client Vehicles, which include capital account balance and investment
performance statistics. They also receive quarterly letters discussing the performance of the
vehicles. Investors also receive annual audited financial statements for the Client Vehicle in which
they are invested. Additionally, Jasper Ridge Partners may provide more frequent reports to Client
Vehicles as specified in the applicable investment advisory agreement or other constituent
documents. Individual Clients have periodic meetings, typically quarterly, with one of our
investment professionals to discuss their portfolios, and will receive reports, including balance
and performance information, in connection with these meetings.
Custody
We are deemed to have custody of some of our Clients’ assets in accordance with Rule 206(4)-
2 under the Advisers Act of 1940 because (i) Jasper Ridge Partners and its affiliates act as the
general partner to some Client Vehicles; (ii) Jasper Ridge Partners manages cash positions for
certain Clients; and (iii) investment professionals serve as trustees for trusts established for the
benefit of Clients or the beneficial owners of such Clients.
Clients’ funds and securities are maintained at all times in a separate account by a qualified
custodian (either a U.S. or foreign bank or broker/dealer) or they may also be maintained at a
mutual fund company, as custodian. Jasper Ridge Partners receives statements from the
custodians and uses those statements to create quarterly reports for our Clients.
Each Client Vehicle and each investor or owner of the Client Vehicle receives GAAP audited
financial statements for the Client Vehicle within 180 days after the conclusion of the Client
Vehicle’s fiscal year, including audited schedules of investments, balance sheets, income
statements and cash flow statements. As part of the audit process, the auditors customarily
confirm Clients’ positions with the custodians. We also may have custody over Client accounts if
we are given authority to move assets out of those accounts. In those cases, we follow the
requirements of Rule 206(4)-2(a) of the Investment Advisers Act of 1940, including obtaining
independent verification of the assets in the accounts and maintaining the assets at a qualified
custodian that sends statements directly to Clients at least quarterly. In those situations, Clients
will receive account statements directly from the broker-dealer or bank acting as custodian, and
Clients should carefully review those statements. Clients should compare the statements they
receive from the custodians to all statements, reports and information they receive from us.
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Investment Discretion
We receive discretionary authority to manage securities on behalf of our Clients, typically through
the partnership documents for the Client Vehicles. The partnership documents for each of the
Client Vehicles typically provide us, as the General Partner, or other affiliated persons with the
ability to select securities to be bought and sold and to determine the amount of the transactions.
We may also receive discretionary authority to manage securities through investment advisory
agreements we enter into with our individual Clients. We exercise the discretion in a manner
consistent with the Client’s goals and investment objectives.
Voting Client Securities
We maintain a Proxy Voting Policy that reflects our duty as a fiduciary to vote proxies in the best
interests of our Clients. Proxies are an asset and we treat them with the same care, diligence,
and loyalty as any other Client asset. To that end, we will vote in a way that we believe to be
consistent with our fiduciary duty to maximize the value of the assets we manage. Any proxy
voting instructions provided by a Client in writing will supersede our proxy voting policy.
Although we generally vote proxies, we reserve the right to abstain from voting proxies or acting
on consents in appropriate circumstances, such as where a security is no longer held by a
portfolio, or where expenses related to the vote appear to outweigh any apparent economic value
from acting on the matter.
Proxy Voting for Public Securities
For public securities, we generally vote in support of the recommendations made by the Board of
Directors or management team. We do so even when a Client or investor in a Pooled Fund is an
officer or director of the company.
Proxies for assets managed by an outside manager are voted on by the outside manager or a
designated custodian. We vote on assets we manage directly; except that in instances where
public securities are held by a custodian, we may delegate proxy voting authority to the custodian.
In cases of material conflicts of interests, we may vote with the recommendations made by the
Board of Directors or management team, abstain, or disclose the conflict to the Client and obtain
the Client’s consent.
Voting for Non-Public Securities
For non-public securities, we are frequently called upon to vote on issues relating to investments,
including amendments to limited partnership agreements and consents on behalf of our Clients.
Such matters are reviewed by our legal/compliance and investment professionals to determine
the best course, consistent with our fiduciary duty.
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In cases of material conflicts of interest, we may bring that matter to our internal Compliance
Committee for resolution or disclose the conflict to the Client and obtain the Client’s consent. We
may also abstain from a proxy vote when there is a conflict of interest.
Our complete, written proxy voting policies and procedures are available for review by
Clients upon request. In addition, our complete proxy voting record for a Client is available
to the Client. Please contact us if you have any questions or if you would like to review
these documents or records.
Financial Information
Jasper Ridge Partners has no financial commitment that impairs its ability to meet contractual and
fiduciary commitments to Clients, and it has not been the subject of a bankruptcy proceeding.
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