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EUROPEAN AND CAYMAN ISLANDS DISCLOSURES


PRIVACY POLICY

At HPS, we are committed to protecting and respecting your privacy. This policy
explains how we collect and use any personal information (i.e., any information
that relates to you and that identifies or can be used to identify you) about
you that you share with us or that we obtain from other sources, including how
we collect, process, protect and share your personal information.

You do not need to take any action as a result of this privacy policy, but you
may have certain rights as described below.

We keep this privacy policy under regular review. This privacy policy was last
updated on 26 October 2023.

When you provide us with your personal information, HPS Investment Partners,
LLC, HPS Advisors, LLC, HPS Securities, LLC, HPS Investment Partners (UK) LLP,
HPS Investment Partners CLO (UK) LLP, Segovia Loan Advisors (UK) LLP, HPS
Investment Partners Lux S.à r.l., HPS Investment Partners (HK), Limited, HPS
Investment Partners (SG) Pte. Ltd. and HPS Investment Partners (AUS) Pty Ltd.
and, in each case, their affiliated companies and the investment funds and
accounts advised by them and their affiliates (together, “HPS”, “we”, “us” and
“our”) act as “controllers” as such term is defined in Regulation (EU) 2016/679
(the General Data Protection Regulation), the General Data Protection Regulation
as it forms part of the laws of United Kingdom by virtue of the European Union
(Withdrawal) Act 2018 or the Data Protection Law, 2017 of the Cayman Islands, as
applicable. In simple terms, this means that we: (i) “control” the personal
information that you provide, including making sure that it is kept secure; and
(ii) make certain decisions on how to use and protect such personal information,
but only to the extent that we have informed you about the use or are otherwise
permitted by law.

Please note that this privacy policy pertains to information that may be
collected in connection with your use of this Website and in certain other
limited circumstance as described herein.  Personal information HPS may collect
from investors in funds and accounts sponsored or managed by HPS will be
addressed in separate notices to the extent required by law. 

If you have any questions regarding our use of your personal information, or
this privacy policy, please contact the Compliance Department
at GDPR-compliance@hpspartners.com.

This privacy policy is provided in a layered format so you can click through to
the specific areas set out below:

1. What information do we collect about you?
2. Why we use your personal information
3. Who we share your personal information with
4. Our retention of your personal information
5. Transfers of your personal information
6. Your rights
7. Contact us
8. Complaints



1. What information do we collect about you and how do we collect it?

The types of personal information we collect about you depends on the nature of
your interaction with us. The types of personal information we collect may
include:

 * Information that you provide to us: This includes information that you give
   us by communicating with us, whether face-to-face, by phone, e-mail or
   otherwise and may include:
   * personal, device and business contact information (such as name, postal and
     email address, IP addresses, and telephone number);
   * your date of birth, passport details or other national identifier, driving
     licence, your national insurance or social security number and income,
     employment information and details about your investment or retirement
     portfolio(s);
   * other personal information you submit to us, such as information you
     provide to register for email alerts or correspond with us in relation to
     inquiries; and
   * work authorization status, education history, employment history,
     professional designations, other information about your qualifications and
     any other personal information you may submit to us in connection with any
     potential employment opportunities;
 * Information that we collect or generate about you: This includes:
   * information relating to your use of our website;
   * information about our interactions with you that we generate and store on
     our customer relationship management systems;
   * call recordings; and
   * background checks and checks required by law such as anti-money laundering
     and sanctions checks;
 * Information that we obtain from other sources: information we may collect
   about you in connection with evaluating and making investments to the extent
   that you are connected to the relevant transaction from transaction parties,
   service providers or your employer or in connection with evaluating whether
   to hire you from your employer and previous employers.

The personal information collected about you will help us provide you with
better service or facilitate our business relationship.

 

2. Why we use your personal information

We will use the personal information you provide us or we otherwise collect for
the following purposes, and pursuant to the corresponding legal bases:

Purpose

Legal Basis

To enter into, and perform, contracts with you that you have requested.

Contractual necessity

To improve our website and notify you about changes to our services.

Legitimate interest

To respond to requests for information submitted by you through our website.

Legitimate interest

To keep a record of your relationship with us.

Legitimate interest

To assess your qualification for available employment opportunities.

Legitimate interest

To conduct know-your-customer, anti-money laundering and similar reviews.

Legitimate interest or Necessity for compliance with a legal obligation

Where we rely on the legal basis that the use of your personal information is
necessary for our legitimate interest, these legitimate interests are:

 * operating and administering our business;
 * managing legal and regulatory compliance and other risks;
 * generating new business and revenue; and
 * operating our recruitment processes.

Additionally, we will use your personal information, subject to applicable law,
to keep you informed of our products and services (e.g. future funds that we are
raising) based on our legitimate interest.

 

3. Who we share your personal information with

We will share your personal information with third parties as required by law or
regulation.

We will also share your personal information with affiliates and certain service
providers and professional advisors, including our lawyers, auditors and other
professional advisors and service providers as necessary to fulfil the purposes
set out in this privacy policy.

We will also share your personal information with applicable third parties in
the event of a reorganization, merger, sale, acquisition, assignment or other
disposition of all or a portion of our business, assets or shares.

 

4. Our retention of your personal information

We will keep your personal information only for as long as is necessary for the
purposes it was collected, set out in section 2 of this privacy policy, unless a
longer retention period is required under applicable law. To determine the
appropriate retention period for personal information, we consider the amount,
nature, and sensitivity of the personal data, the potential risk of harm from
unauthorised use or disclosure of your personal information, the purposes for
which we process your personal information and whether we can achieve those
purposes through other means, and the applicable legal requirements.

 

5. Transfer of your personal information

To the extent that you reside in the European Union or United Kingdom, or EU, UK
or Cayman Islands data privacy legislation applies to our processing of your
personal information, and we transfer your personal information to countries
located outside of the European Economic Area (“EEA”) or UK, such transfers are
made in accordance with applicable data privacy laws. This can be done in a
number of ways, for instance:

 * the country that we send the information to might be approved by the European
   Commission or the UK Government;
 * the recipient might have signed up to a contract based on standard
   contractual clauses approved by the European Commission or the UK Government,
   obliging them to protect your personal information; or
 * where the recipient is located in the US, it might be a certified member of
   the EU-US Data Privacy Framework and the US-UK Data Bridge extension to that
   scheme.
   

In other circumstances the law may permit us to otherwise transfer your personal
information outside the EEA or UK. In all cases, however, we will ensure that
any transfer of your personal information is compliant with data protection law.

You can obtain more details of the protection given to your personal data when
it is transferred outside the EEA or UK (including a copy of the standard data
protection clauses which we have entered into with recipients of your personal
data) by contacting us using the details set out above.

 

6. Your rights

To the extent that you reside in the European Union or United Kingdom, or EU, UK
or Cayman Islands data privacy legislation applies to our processing of your
personal information, you have the right to access the personal information we
hold about you, and there are, subject to certain limitations, a number of ways
you can control the way in which and what information we store and process about
you. We have explained these individual rights and controls below. To exercise
these rights and controls, please contact us at GDPR-Compliance@hpspartners.com.

Access: You have the right to access the personal information that we hold about
you free of charge (subject to certain situations where we may charge a
‘reasonable fee’).

Correction: You have the right to correct any inaccuracies in the information we
hold about you.

Deletion: You have the right to request that we delete your personal information
in certain situations (subject to any legal rights or obligations for us to
retain it).

Restrictions on use: You may request that we stop processing your personal
information (other than storing it): (i) while its accuracy is verified; (ii) if
the processing is illegal; (iii) if the processing is no longer necessary for
the purposes for which it was collected; or (iv) if you object to the processing
and we are verifying whether our legitimate grounds to process your personal
information override your own rights.

Object: You have the right to object to processing, including: (i) for direct
marketing (from which you may opt-out at any time); (ii) for research or
statistical purposes; and/or (iii) where processing is based on legitimate
interests.

This website may contain links to other websites. HPS is not responsible for the
privacy practices or the content of such third party websites. Please see our
“Website Terms of Use” for more information about our online terms and policies.

 

7. How to contact us

For any questions regarding our processing of your personal information
(including the rights and controls explained in section 7 of this privacy
policy) please contact GDPR-Compliance@hpspartners.com. 

 

8. Complaints

If you reside in the European Union, or EU data privacy legislation applies to
our processing of your personal information, and you should you wish to lodge a
complaint with regards to how your personal information has been processed by
HPS, please contact your local supervisory authority. If you reside in the
United Kingdom, or  UK data protection applies to our processing of your
personal information, and should you wish to lodge a complaint with regards to
how your personal information has been processed by HPS, please contact the
Information Commissioner (https://ico.org.uk/). If you are an investor in a
Cayman Islands fund you may lodge a complaint with the Cayman Islands Ombudsman
(www.ombudsman.ky). 

 


MIFIDPRU DISCLOSURES

HPS Investment Partners (UK) LLP 2023

HPS Investment Partners CLO (UK) LLP 2023

Segovia Loan Advisors (UK) LLP 2023

 


MODERN SLAVERY ACT STATEMENT

Background

The United Kingdom (the “UK”) enacted the Modern Slavery Act (“MSA”) in October
2015. The MSA is designed to address all forms of human trafficking and slavery,
including compulsory or coerced labor, deprivation of personal freedom or
facilitating the movement of people for exploitation.

The MSA requires certain commercial organizations that carry on business in the
UK to prepare a slavery and human trafficking statement. HPS Investment Partners
(UK) LLP, HPS Investment Partners CLO (UK) LLP, HPS Investment Partners (UK) I,
Ltd., HPS Investment Partners (UK) II, Ltd. and Segovia Loan Advisors (UK)
LLP(together “HPS UK Entities”) have prepared this statement in accordance with
Section 54 of the MSA.


HPS Structure and Business

The HPS UK entities are members of the HPS Group which is a global alternative
investment management firm that focuses on both private and public credit
strategies with the ability to invest across the credit landscape on behalf of
its clients. The HPS Group is headquartered in New York with 14 additional
offices globally and carries on business in the UK through HPS Investment
Partners (UK) LLP, HPS Investment Partners CLO (UK) LLP and Segovia Loan
Advisors (UK) LLP which are each authorized by the Financial Conduct Authority.
HPS Investment Partners (UK) I Ltd. and HPS Investment Partners (UK) II, Ltd.
are each corporate members of HPS Investment Partners (UK) LLP, HPS Investment
Partners CLO (UK) LLP and Segovia Loan Advisors (UK) LLP.


Supply Chain

As alternative asset management firms, the HPS UK Entities consider the risk of
slavery or human trafficking existing within their business or supply chain to
be low. The goods and services the HPS UK Entities purchase in the conduct of
business are primarily limited to professional services, real estate, facility
management, office equipment, software, and related services which present a low
risk of modern slavery and human trafficking.
The HPS UK Entities also utilize certain additional services which may present a
somewhat higher risk of modern slavery including catering, cleaning and
maintenance work. However, given the geographic exposure of the services the
risk is still deemed to be low.


Policies

The HPS UK Entities are committed to ensuring that slavery and other human
rights abuses do not take place in connection with their business and take the
following steps to ensure that the risk of slavery and human trafficking is
adequately addressed in their business and supply chain:

 * Risk assessment of our supply chains to identify any high risk areas;
 * Requiring enhanced contractual terms from any high risk suppliers identified
   through the risk assessment process; and
 * Staff training to promote awareness of the MSA and issues relating to modern
   slavery and human trafficking and to encourage the reporting of concerns.


Monitoring and Reporting

If the HPS UK Entities were to identify a reasonable cause for concern that a
supplier represents a modern slavery risk, appropriate steps will be taken
including but not limited to discontinuing the engagement and/or reporting the
concerns to relevant authorities. To date the HPS UK Entities have not
identified any cause for concern relating to compliance with the MSA.


This statement was approved by the governing bodies of the HPS UK entities on 27
June 2023.

 

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SHAREHOLDER RIGHTS DIRECTIVE

Under Rule 2.2B.5R of the Conduct of Business Sourcebook in the FCA Rules, HPS
Investment Partners (UK) LLP and HPS Investment Partners CLO (UK) LLP (together
the "Firms") are required either to develop and publicly disclose an engagement
policy, as described in the revised Shareholder Rights Directive (the “SRD II”),
or publicly disclose a clear and reasoned explanation of why they have chosen
not to develop and adopt a shareholder engagement policy.

The Firms provide investment management and advisory services focusing on
private and public credit strategies.  They invest in a range of asset classes,
including corporate and sovereign bonds, secured and unsecured term loans,
collateralised loan obligations and performing and non-performing assets, on
behalf of their clients.  The Firms do not employ equity-focused investment
strategies.  Investments in shares traded on a regulated market are infrequent
and do not represent a significant part of the Firms’ investment activity.

The Firms have determined that, given their investment strategies and their low
exposure to shares traded on a regulated market, there are limited occasions on
which they are in a position to have active engagement with company management
as equity holders or exercise voting rights in relation to shares.  Accordingly,
developing an engagement policy would be disproportionate and of limited
relevance to the Firms’ business.  Therefore, while the Firms are generally
supportive of the objectives that underlie the SRD II, they do not consider it
appropriate to adopt a shareholder engagement policy as described by SRD II at
this time. The Firms will keep their position under review and update this
statement if there is a change in their approach.

 

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UK TAX STRATEGY

Download here.

 

 

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HPS INVESTMENT PARTNERS LUX SÀRL

HPS Investment Partners Lux Sàrl (“HPS Lux”), is an Alternative Investment Fund
Manager (“AIFM”) authorized and regulated by the Commission de Surveillance du
Secteur Financier (“CSSF”), the Luxembourg Regulator, with registration number
A00002799.


Information

As an AIFM, HPS Lux will make available free of charge and on request to
investors in the funds it manages (the “Funds”) information on, but not limited
to: (i) the risk management processes it employs; (ii) the risk profile,
including risk limits, of the Funds; (iii) the liquidity management of the
Funds; (iv) certain information on HPS Lux, the Funds and their depositaries and
, service providers; (v) fee arrangements; (vi) voting rights and shareholder
engagement strategy; and (vii) any contractual discharge of depositary
liability.

Additionally, HPS Lux also provides free of charge and on request to the
investors of the Funds a copy of its best execution/selection policy, complaints
policy and conflicts of interest policy.

Investors may request any of the information stated above by email, to:
AIFM@hpspartners.com


Complaints

HPS Lux is committed to investigating all complaints competently, diligently and
impartially. An investor in a Fund can submit a complaint free of charge:

 * By email, to: AIFM@hpspartners.com

 * By letter, to:

HPS Investment Partners Lux Sàrl
Conducting Officer in charge of Complaints Handling
291, route d’Arlon
L-1150 Luxembourg
Grand Duchy of Luxembourg

The investor should include all relevant information to ensure an efficient
investigation of the complaint. This should include: the investor’s identity and
contact details, reason(s) for the complaint, the resulting alleged damage or
loss in relation thereof, and where relevant copies of any relevant
documentation.

The investor will receive an acknowledgement of receipt in writing within ten
(10) Luxembourg business days of receipt unless the answer itself is provided
within this period.

If, after receiving the final response, the investor is not satisfied with the
response provided, or if HPS Lux has failed to provide the investor with an
adequate response within a reasonable time from receipt of the complaint, the
investor may be eligible to refer their complaint directly to the CSSF.  Further
information on this process and on applicable regulation, can be found on the
CSSF website: https://www.cssf.lu/en/customer-complaints/

© 2024 HPS Investment Partners, LLC

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