TowerBrook has an Allocation Committee (the "AC") to address potential conflicts of interest between the private equity investment strategy and the structured opportunities investment strategy. The AC determines the parameters of investment allocations between the two strategies, reviews the allocations and resolves any conflicts of interests that may arise and cannot be solved by the TSO Investment Committee and/or the PE Investment Committee. The AC also assesses the effectiveness of TCP's investment allocation policies and procedures. The AC is co-chaired by TowerBrook’s Co-CEOs, Ramez Sousou and Neal Moszkowski, and its other members include TowerBrook Managing Directors Filippo Cardini, Glenn Miller, Matthew Gerber and Abrielle Rosenthal. The AC meets at least once annually, and conducts a look-back analysis on the allocation of all transactions that have closed during the preceding year.
The Limited Partner Advisory Committee of each fund also reviews any matters involving a potential conflict of interest presented by the General Partner.
TowerBrook's also has put into place a written Conflicts Policy, which can be found in the Compliance Manual and Code of Ethics, which is certified by all team members on a quarterly basis. Conflicts of interest that may arise among the various individual and organizations comprising TowerBrook, the TowerBrook Funds and other affiliated entities are monitored on a continuous basis by the CCO and TowerBrook's legal department. A written conflicts register is maintained, which is reviewed annually on a formal basis by TowerBrook's legal department and assessed periodically by TowerBrook's Risk and Compliance Committee. Each team member is required to disclose upon joining, and as applicable thereafter, all outside commitments that involve a substantial time commitment, or which could otherwise present an actual or perceived conflict of interest. The CCO also holds a one-to-one discussion with each team member at least annually to discuss any conflicts of interests relating to such person's outside activities. A summary of such discussions, as well as a risk assessment of the outside activities of each partner and employee, is presented to TowerBrook's Risk and Compliance Committee periodically for review and approval.