Code of Conduct

Introduction
DIF Management B.V. and its subsidiaries (CVC DIF) expects all directors, officers and employees and Supervisory Board members (together referred to as CVC DIF Staff) and CVC DIF’s contractors to always act with integrity and honesty, to abide by the law, not to cut corners and to uphold CVC DIF’s good reputation. CVC DIF expects all CVC DIF Staff to always do business in accordance with its Code of Conduct. Below is a summary of CVC DIF’s Code of Conduct.

Integrity
CVC DIF and CVC DIF Staff will act with integrity. This means that CVC DIF Staff must attest to CVC DIF’s Code of Conduct and any other of CVC DIF’s policies.

Conflict of interest
First and foremost, it is CVC DIF’s responsibility to protect the interest of the investors in the funds that CVC DIF manages. CVC DIF will seek to manage conflicts of interests fairly, both between itself and CVC DIF Staff and investors in a Fund and between the different Funds and different investors and groups of investors. 

Market Abuse and Personal Transactions
CVC DIF and CVC DIF Staff must comply with the rules on Market Abuse and on Personal Transactions as set out in the EU Market Abuse Regulation, the EU AIFM Regulation and the Dutch Financial Supervision Act. 

Trading in CVC Group Securities
As part of the CVC Group, all CVC DIF Staff and CVC DIF’s contractors must comply with the applicable rules on insider dealing and do not abuse and do not place themselves under suspicion of misusing Inside Information in relation to trading in CVC Group Securities.

Gifts and entertainment 
Gifts or entertainment are permissible; however, they should never affect the independence or freedom of the recipient which would be the case if they could create, or even suggest, a sense of obligation. Any travel and/or accommodation associated with any of the foregoing must be paid by the CVC DIF Staff Member or CVC DIF. Note that cheques, money, expenses and suchlike may never be offered or accepted.

Discrimination and harassment 
CVC DIF does not tolerate discriminating and harassing behaviour directed by or towards its employees, investors, advisors, clients, suppliers, vendors or anyone else with whom CVC DIF Staff comes into contact in the course of the performance of their job duties. 

Anti-bribery and corruption 
CVC DIF has a strong stance against Bribery and Corruption. This zero-tolerance approach means we are committed to the mitigation, deterrence and detection of bribery and corruption. CVC DIF does not and will not pay bribes or kickbacks or offer improper inducements to anyone for any purpose, nor do we or will we accept bribes, kickbacks or improper inducements or anything that could be perceived as such and expect the same from our clients, investors, project managers and suppliers.  

Anti-Money Laundering and Counter-Terrorism Financing
CVC DIF and CVC DIF Staff is committed to fully prevent Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF). CVC DIF must comply with all applicable laws and regulations wherever CVC DIF conducts business. CVC DIF has an AML and CTF program consisting of policies and procedures (including training) designed to prevent and detect money laundering and any other related activities. 

Confidentiality and Privacy 
CVC DIF and CVC DIF Staff is committed to keep data safe. This includes both Personal Data of our investors, counterparties and employees as well as data in relation to its professional activities. 

IT and Information Security
CVC DIF has appropriate processes and controls in place to ensure all risks are identified, analysed, measured, monitored, managed and reported. 

Communication 
Only authorized employees or officers may make any public statements on behalf of CVC DIF, whether to the media (including social media), investors or in other external forums, including the internet. 

Sustainability
CVC DIF has formalized its commitment towards environmental, social and governance matters (ESG) as part of its Sustainability strategy. CVC DIF Staff is expected to behave in line with CVC DIF’s Responsible Investment Policy and Strategy.

Training and Awareness
CVC DIF provides Code of Conduct training to CVC DIF Staff through various training programs and awareness sessions such as annual e-learnings and introduction programs.