Reverse solicitation request

Certain members of the CapGen group act as investment manager or adviser (as applicable) to the investment portfolios of certain families and trusts (our Clients”). Note that certain of our Clients are located within the European Union. CapGen is not an AIFM as defined in the Alternative Investment Fund Managers Directive 2011/61/EU (“AIFMD”). Neither does it act as placement agent for any AIF (as defined in AIFMD).

Request for investment information

Where applicable, CapGen may make a request at its own initiative for any given fund, fund manager and/​or any of its associates to market potential investment opportunities to CapGen, any of its associates and/​or its Clients, regardless of the form which such investment opportunities may take (including in particular if they take the form of an alternative investment fund that such fund or fund manager would otherwise be unable to market to under AIFMD). Where CapGen has made such request, the information provided may include the latest legal documents, marketing materials and all due diligence materials and other relevant information in relation to the proposed or actual offering or placement of interests in the relevant investment fund (the Fund”) together with any future supplements and amendments to those documents and materials, as sent by the fund, fund manager and/​or their respective associates or agents. CapGen may also request:

1. an opportunity to discuss with the fund, fund manager and/​or their respective associates or agents the offering or placement of the Fund; and/​or

2. that the fund, fund manager and/​or their respective associates or agents inform CapGen, any of its associates and/​or its Clients of any other potential investment funds or investment opportunities that may arise in relation to future investment funds (together with the Fund, the Investments”).

All legal, due diligence and other relevant information sent to CapGen or its associates in relation to the Investments may be disclosed to its Clients. 

No receipt of inside information 

Please note that CapGen does not under any circumstances wish to receive non-public price-sensitive information or any other information that could constitute inside information” (as defined in the jurisdiction of disclosure or receipt), in the form of oral, written or any other communication. CapGen will assume that, unless otherwise notified in writing, all information received from you or your associates does not constitute inside information.