A private equity firm should publish either in the form of an annual review or through regular updating of its website:
- A description of the way the FCA-authorised entity fits into the firm as a whole with an indication of its investment approach including investment holding periods along with an indication of the leadership of the firm and confirmation that it has appropriate arrangements to deal with conflicts of interest; and
- A commitment to conform to the Guidelines, a description of the companies in the private equity firm’s portfolio and a categorisation of the limited partners in the fund or funds including a geographic categorisation and a breakdown by type of investor.
Additionally, private equity firms should, in their reporting to limited partners, follow established guidelines, such as those published by Invest Europe, follow established guidelines in the valuation of their assets, and should provide data to the BVCA in support of its enhanced role in data collection, processing and analysis.
Private equity firms should ensure that their portfolio companies comply with (or explain departures from) the required disclosure and provide data on their portfolio companies for annual reporting on performance.
Private equity firms should also commit to ensure timely and effective communication with employees, either directly or through their portfolio company, as soon as confidentiality constraints are no longer applicable.
A private equity firm is also required to sign the statement of conformity annually.