Silver Lake Terms of Use

Last Updated: April 6, 2022

These Silver Lake Terms of Use (“Terms of Use”) apply to the Internet sites of Silver Lake Technology Management, L.L.C. and its affiliates (“Silver Lake” or “we”), including www.silverlake.com, all sites hosted within or associated with that domain, and any other affiliated sites that we operate on which these Terms of Use are posted (collectively, the “Site”). Please read these Terms of Use carefully before using the Site. These Terms of Use set forth the legally binding terms and conditions that govern your access to and use of the Site, including all materials, information, and content thereon (collectively, the “Content”). By visiting the Site, you accept, and agree to be bound by, these Terms of Use. We may update the Site or these Terms of Use at any time without notice. Any update to these Terms of Use will be effective upon posting the modified version of these Terms of Use on the Site. We encourage you to periodically consult these Terms of Use to learn about any modifications thereof and updates thereto. Your continued use of the Site after any such modifications or updates to these Terms of Use shall constitute your acceptance of these Terms of Use as modified or updated. If you do not agree to these Terms of Use for any reason, please discontinue your access and use of the Site.

If you have any questions or comments about these Terms of Use, you can write us at Website Inquiry c/o Legal and Compliance, Silver Lake, 2775 Sand Hill Road, Suite 100, Menlo Park, CA 94025.

Uses of Our Site and Content

We have the right (but not the obligation) to monitor the Site for any unauthorized or objectionable conduct and to take all appropriate actions in response, without notice to you. We have listed below the permitted and prohibited uses of our Site and the Content.

You may copy, download, and print individual pages of our Site for your own personal use and not for any commercial use or purpose. You may not remove any copyright, trademark, or other proprietary notices or other legends from any such pages. You may not alter or modify the Content in your copies.  In no event may you (i) extract, copy, or download a large portion of the Content, such as by a bot, webcrawler, scraper, spider or other device that “harvests” portions of the Site, (ii) make more than a few copies of a given page of the Site or copy a substantial portion of the Site or any Content, or (iii) engage in any commercial exploitation of any of our Content, or post it elsewhere on the Internet.

You may not (and may not encourage others to) attempt to violate the security of this Site or use or gain access to the identities, information, or computers of others, through this Site or use the Site to violate any law or regulation or the intellectual property, privacy, or publicity, or contractual rights of others.

Trademarks and Other Intellectual Property

SILVER LAKE®, SILVER LAKE PARTNERS®, SLP®, SILVER LAKE ALPINE™, SLA™, SILVER LAKE LONG TERM CAPITAL™, LTC™, SILVER LAKE SUMERU®, SUMERU®, SLS™, SILVER LAKE KRAFTWERK®, SLK™, SILVER LAKE WATERMAN™, SLW™, and certain other marks or logos displayed on the Site are trademarks and service marks of and owned by Silver Lake or other parties, who may or may not be affiliated with Silver Lake. You may not use any of those or any other Silver Lake trademarks, trade names, or service marks in any manner that creates the impression that such names and marks belong to or are associated with you or your affiliates or are used with Silver Lake’s consent.

All trademarks or service marks on the Site that are not owned by Silver Lake are the property of their respective owners. You may not use any such trademarks or service marks without the permission of their respective owners. All Content included on the Site is owned by Silver Lake or other parties, and is protected by copyright and other intellectual property law.

No Offer or Advice

The Content included on the Site is for informational purposes only and does not constitute an offer to sell or buy any securities, financial instruments, investments, or other services of Silver Lake or any entity, and may not be used or relied upon in connection with any offer or sale of securities, financial instruments, investments, or other services. An offer or solicitation will be made only through a final private placement memorandum, subscription agreement, and other related documents with respect to a particular investment opportunity and will be subject to the terms and conditions contained in such documents, including the qualifications necessary to become an investor.

Silver Lake is not utilizing the Site to provide investment or other advice, and nothing on the Site is to be deemed a recommendation that you buy, sell, hold, or make any other security or investment decision.  The Site and its Content should not be relied upon for the purpose of making or communicating investment or other decisions nor construed as investment, legal, accounting, tax, or other professional advice. To obtain such advice, you should consult with your own professional advisor.  Any transactions listed on the Site are included as representative transactions and are not necessarily reflective of overall performance. 

Not Advertising or Marketing Material

The Content on the Site is for informational purposes only and is not, and should not be considered as, an offer to provide investment advisory services with regard to securities to any person or entity.

Forward Looking Statements

The Content on the Site may contain forward­-looking statements that are based on beliefs, assumptions, current expectations, estimates, and projections about the financial industry, the economy, Silver Lake itself or its investments. These statements are not guarantees of future performance and involve certain risks, uncertainties, and assumptions that are difficult to predict with regard to timing, extent, likelihood, and degree of occurrence. Therefore, actual results and outcomes may materially differ from what may be expressed or forecasted in such forward­-looking statements. Furthermore, Silver Lake undertakes no obligation to update, amend, or clarify forward­-looking statements, whether as a result of new information, future events, or otherwise.  

Past Performance is Not Indicative of Future Results

Any performance-related Content on the Site is exclusively an indication of past performance. Silver Lake makes no representation that any investment or transaction will result in profits or losses similar to those achieved in the past, or that significant losses will be avoided. Certain companies represent past and present investments made by multiple Silver Lake Funds which may have different strategies, including with respect to degree of governance or involvement by Silver Lake. Some information herein may reflect our strategic principles and historic performance from which we have developed general theses, but there is no guarantee that historical trends will continue into the future or that our strategy and principles will ultimately prove to be correct.

Links to Other Websites

The Site may contain links to, or may be linked from, other websites that are not maintained by us. Silver Lake does not endorse, have any responsibility for or control over, or make any representations about, any other websites, including their products and services, content, communications, and website use policies. If you access or follow links to websites not affiliated or controlled by us, you do so at your own risk. We encourage you to review the terms and conditions, privacy policies, and other user agreements of all such websites that you visit as such terms and conditions, policies, and agreements will govern your access and use of those websites. We do not guarantee and are not responsible for the privacy or security of these sites, including the accuracy, completeness, or reliability of their information. Silver Lake expressly disclaims any responsibility for your access to or use of such other websites.

Disclaimers

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE SITE AND ALL CONTENT AVAILABLE ON OR THROUGH THE SITE ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS. You expressly understand that Silver Lake does not make and hereby disclaims all express and implied warranties, representations, and endorsements , including but not limited to, implied warranties of merchantability, fitness for a particular purpose, and warranties of title and non-infringement, as to the operation of the Site or the CONTENT. SILVER LAKE DOES NOT WARRANT THAT SUCH CONTENT IS ACCURATE, RELIABLE, OR CORRECT, THAT THIS SITE WILL BE AVAILABLE AT ANY PARTICULAR TIME OR LOCATION, OR THAT THE SITE IS FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS.  YOUR ACCESS TO AND USE OF THE SITE AND ITS CONTENTS IS AT YOUR SOLE RISK.

You acknowledge and accept that: (1) the Site may not be available, may not function properly or may have or cause technological problems (including, without limitation, computer malfunction, failure of performance, delays, interruptions, defects, errors, worms, or viruses) from time to time; and (2) Silver Lake or its designee cannot, and does not, guarantee that the Site will be free of security problems (including, without limitation, unauthorized interception of data or communications).

All Content available on or through the Site is only as of the date indicated.  Although we make reasonable efforts to provide accurate information, Silver Lake undertakes no obligation to, and at times we may not promptly, update or correct the Site even if we are aware that it is inaccurate, outdated or otherwise inappropriate, whether as a result of new information, future events or otherwise.

Limitation of Liability

Silver Lake and its affiliates and all of their respective officers, directors, managers, partners, members, shareholders, employees, affiliates, representatives, licensors, and agents will not be liable hereunder for any direct or indirect damages or injury, including but not limited to special, incidental, punitive, or consequential damages (whether in an action in contract or tort or under statute), that result from the access to or use of (or the inability to access or use) the Site and its Content, or a website to which the Site links, including any damages or injury caused by any failure of performance, error, omission, interruption, defect, delay in operation, computer virus, line failure, or other computer malfunction, or from any action that you take or decision you make in reliance on any information contained in the Site. IN NO EVENT WILL SILVER LAKE’S AGGREGATE LIABILITY TO YOU, DIRECT OR OTHERWISE, EXCEED ONE HUNDRED UNITED STATES DOLLARS (USD $100). 

THE LAWS OF CERTAIN JURISDICTIONS MAY NOT ALLOW THE EXCLUSIONS AND LIMITATIONS OF DAMAGES IN THIS SECTION, IN WHICH CASE SILVER LAKE’S LIABILITY FOR DAMAGES IN CONNECTION WITH THESE TERMS OF USE IN SUCH JURISDICTIONS SHALL BE LIMITED TO THE MAXIMUM EXTENT PERMITTED BY THE LAWS OF SUCH JURISDICTION.

Notwithstanding the foregoing, nothing contained in preceding paragraphs or elsewhere in these Terms of Use shall constitute a waiver by you of any of your legal rights under applicable U.S. federal securities laws or any other laws whose applicability is not permitted to be contractually waived.

Indemnification

You agree to indemnify and hold harmless Silver Lake and its affiliates and their respective officers, directors, managers, partners, members, shareholders, employees, affiliates, and agents from any and all liabilities, damages, losses, claims, expenses, and fees resulting from your access or use of the Site or your breach of these Terms of Use.

International Use

The Site is operated and controlled by Silver Lake in the United States. Access to the Site or distribution of the Content on the Site from countries or territories where such access or distribution is illegal is prohibited. Silver Lake makes no claims that the Site is appropriate or lawful for use or access outside the United States.  You are responsible for complying with all local laws, rules, and regulations.

Governing Law / Venue

You agree that your use of the Site and any disputes relating to the Site or these Terms of Use are governed in all respects by the laws of the State of New York without giving effect to any principles or rules of conflicts of laws to the extent such principles or rules are not mandatorily applicable by statute and would require or permit the application of the laws of other jurisdictions, as to all matters, including, but not limited to, matters of validity, construction, effect, performance, and remedies.

Silver Lake may bring an action against you in connection with any dispute, controversy, or claim arising out of these Terms of Use or your access or use of the Site (“Dispute”) in any jurisdiction.  Without limiting Silver Lake’s right to do so, you agree not to object to the exercise of personal jurisdiction by and to venue in the courts of the State of California and the United States District Court for the Northern District of California located in or near Menlo Park, County of San Mateo, California.  Silver Lake may elect to resolve any Dispute through binding arbitration and, if it so elects, you and we agree that such Dispute shall be resolved pursuant to the Commercial Arbitration Rules of the American Arbitration Association.  The seat of such arbitration shall be San Mateo, California, U.S.A. Any such arbitration will be conducted as an individual arbitration and you agree that no arbitration shall be brought by you or resolved on a class, mass, or representative basis.  You agree that any claim or cause of action arising out of or related to these Terms of Use or your access or use of the Site must be filed within one (1) year after such claim or cause of action arose regardless of any statute or law to the contrary.

Termination and Suspension

Silver Lake may terminate or suspend your access to the Site at any time, for any reason or no reason, with or without prior notice.

Additional Important Information

Please refer to Silver Lake’s Form ADV for additional information on relevant investment strategies.

Privacy Notices

You may view our privacy notices at the links below:

Website Privacy Policy

California Privacy Policy

California Job Applicant Privacy Notice

UK Recruitment Process Privacy Notice

Miscellaneous

If any provision of these Terms of Use is found to be invalid by any court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of these Terms of Use, which shall remain in full force and effect. No waiver of any provision in these Terms of Use shall be a further or continuing waiver of such provision or any other provision in these Terms of Use. The section names in the Terms of Use are for convenience only and have no legal or contractual effect.  You may not assign these Terms of Use, or any of your rights or obligations hereunder, without the prior written consent of Silver Lake. We may assign, transfer or sublicense any or all of our rights or obligations under these Terms of Use at any time without your prior consent. Except as expressly provided elsewhere in the Site, these Terms of Use and any other terms and conditions expressly incorporated by reference into these Terms of Use by Silver Lake constitute the entire agreement between you and Silver Lake with respect to your use of the Site.

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Privacy Policy

Last Updated: August 8, 2024

California residents can find our California Privacy Notice, which supplements this Privacy Policy, at this link: https://www.silverlake.com/california-privacy-notice

General

This Privacy Policy applies to the Internet sites of Silver Lake Technology Management, L.L.C. (“Silver Lake”), including www.silverlake.com and affiliated sites, and our social media platforms and email account (collectively, the “Site”). We are committed to protecting the privacy of visitors to our Site. Silver Lake is the data controller in relation to personal information collected through the Site. Silver Lake’s portfolio companies may be data controllers with respect to personal information shared through Silver Lake’s talent networks.

This Privacy Policy describes the information we collect about you when you visit or upload information to the Site or correspond with us via email, and how we use such information. This Privacy Policy does not address our privacy practices concerning any personal information we collect about our investors when investing in our funds; we address those practices in separate notices sent to our investors or potential investors.

Any update to this Privacy Policy will be effective upon posting a notice of the modified Privacy Policy on our Site. We encourage you to periodically consult this Privacy Policy to learn about any modifications and updates.

If you have any questions or comments about this Privacy Policy, you can contact us as described in the “How to Contact Us” section below.

Personal Information We Collect

Personal Information is information that personally identifies you, directly or indirectly, such as your name, postal address, email address, or credit card information (or other information that is associated by us with such information). 

The Site is directed toward and designed for use by persons aged 16 or older. We do not knowingly collect personal information from individuals under the age of 16.

Information You Provide

We may collect personal information that you choose to provide to us through the Site, including, but not limited to, your first and last name, physical address, email address, or telephone number, such as when you:

• Fill out a form on the Site;
• Sign up to a feature that we offer on the Site and you provide your personal information in connection with that feature;
• Sign up to attend an event that we have organized;
• Communicate with us (for example, on a social media platform or by sending us an email);
• Provide personal information to us on Silver Lake’s social media pages; or
• Otherwise voluntarily provide personal information to us through the Site or third-party websites such as Consider.com (“Consider”), including education and employment history or other information provided in connection with an application for employment or internships at Silver Lake or its portfolio companies.

Information from Third Parties

We also may obtain personal information about you from third parties acting on our behalf, such as our website host, including the frequency with which you visit our Site and the links you use.

Device Information

We use server logs, which automatically record certain information from the devices of Site visitors, such as the number and frequency of visits, as well as IP addresses, time spent on the Site, and pages viewed.

Social Media Widgets

The Site may include social media functions, such as Twitter, LinkedIn, and Facebook widgets. These widgets may collect information about which pages you visit on the Site and the IP address of the device you use to connect to the Internet. The widgets may also set a cookie to ensure the features are functioning properly.

Social media functions and widgets are hosted either by a third party or directly on the Site. Your interactions with the social media functions and widgets located on the Site are governed by the privacy policies of the companies that provide them. If you use any of the social media functions or widgets on our Site, we strongly suggest you review the privacy policies of the companies that provide those functions and features.

How We Use the Information We Collect

We may use personal information in a number of ways, depending on the context, as follows:

• To respond to your inquiry (for example, to contact you about your request or to ask a question about your inquiry);
• To contact you for reasons related to offering and improving our services;
• To provide announcements about future events and opportunities;
• To audit the use of and develop our products and the Site, including through surveys;
• To administer the Site, including to fix any formatting errors and improve its functionality;
• To develop new products and services;
• To perform market research;
• To analyze our products, services, and websites;
• To conduct due diligence activities in connection with corporate transactions or investments;
• To meet legal requirements, including complying with court orders, valid discovery requests, and other appropriate legal mechanisms;
• To detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and assist in the prosecution of those responsible for that activity;
• To provide information to representatives and advisors, including lawyers and accountants, to help us comply with legal, accounting, or security requirements;
• To record and respond to any compliments, comments, or complaints from supporters or service users and to appropriately investigate and implement necessary changes; and
• To evaluate candidates as part of job/internship applications and maintain necessary employee records.

We use the personal information for the purposes described above because either:

• It is necessary to further our legitimate interests in providing services to our investors and other interested individuals, taking steps to protect and improve the Site and our IT systems, and other related matters that are not overridden by your interests, rights, and freedoms;
• Where required, we have obtained your consent for the given purpose(s); or
• It is necessary for compliance with our legal obligations.

Cookies & Tracking Technologies

On www.silverlake.com and affiliated sites:

Cookies are small text files that store information, such as your preferences and account settings, on the hard drive of your computer. Similar to many websites, if you have enabled cookies in your browser, Silver Lake, independently and through enabled third-party tools and programs, has the ability to collect certain technical information, such as originating IP address, browser type, browser language, browser location, how a user got to the Site (i.e., the URL of the last website the user visited), the next website the user visits, what pages are visited, the length of each Site visit, and the date and time of the user’s visit. This information helps us track trends and improve user experiences when visiting the Site.

How We Use Cookies and Other Tracking Technologies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Our website may use a variety of cookies or other tracking technologies (collectively hereinafter, “Cookies”):

• Session Cookies: These are stored temporarily on your device whilst you browse our Site and are deleted from your device when you finish browsing.
• Persistent Cookies: These are stored on your device after you have finished browsing our Site so that we can remember your preferences when you visit our website in the future.
• Other tracking technologies: We may collect information from the Site through other automated means, such as web server logs, web beacons or tracking pixels, JavaScript, and other code that may run on your computer. 

First-party Cookies are set by us. Third-party Cookies are set by a third-party’s website and subject to the terms of the third-party’s privacy policy. We encourage you to review the privacy policies of such providers to understand their policies that apply to their collection and use of information.

We may use third-party analytic tools and technologies to analyze information received from our Cookies, including how visitors use the Site, to research our visitors’ demographics, interests, and behavior, to improve the Site, to provide visitors with customized services and information, and for other similar purposes.

Cookies We May Use

The table below describes the Cookies we use, their names, and what we use the Cookies for:

Amending Your Cookies Preferences and How We Respond to Do Not Track Signals

If you wish to restrict, block, or delete the Cookies which are set by our Site and third parties, you can do this using your browser settings to refuse all or some browser Cookies, or to alert you when websites set or access Cookies. If you set your browser preferences to block all Cookies, you may not be able to access all or parts of our Site. If you delete Cookies relating to our Site, including your Cookie preferences, you will be treated as a first-time visitor the next time you visit our Site. We do not respect a “do not track” signal from your browser.

On the Consider Platform:

If you choose to join our talent network through, or otherwise interact with, Consider please review the cookie information provided by Consider in its Privacy Policy.

Disclosure of Information

We may share your personal information with our affiliates, portfolio companies, and our advisors, for the purposes described in this Privacy Policy.

We may share personal information with third-party service providers to facilitate our services and perform functions on our behalf, such as sending postal mail and email and providing us with technical, analytical, and hosting functions for the Site. As required by applicable law, we permit them to use or disclose personal information only as necessary to perform services on our behalf or comply with applicable legal requirements. 

In addition, we may disclose personal information about you (a) if we are required to do so by law or legal process (for example, due to a request from a law enforcement authority, a subpoena, court order, or discovery request); (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss; (c) when we believe in good faith that such disclosure is necessary or appropriate in connection with any activity that violates the law (including relating to intellectual property, fraud, contracts, and privacy) or may expose us to liability; (d) in connection with the investigation of suspected or actual fraudulent or other illegal activity; (e) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation); and (f) to our professional advisors, such as lawyers, accountants, insurers, and financial services, but only as is necessary for the performance of their services.

Protection of Personal Information

The security of your personal information is important to us. We employ technical, administrative, and physical security measures to protect any personal information you provide through the Site from unauthorized access or use. You should be aware, however, that “perfect security” does not exist on the Internet, and there is always the risk that unauthorized persons may access or use your personal information. You use the Site and send us such information at your own risk.

Other Websites, Links and Third-Party Technologies

Please note that this Privacy Policy applies only to the Site and not to any other third-party website that may link to or may be linked from it. We do not control the privacy policies or practices of other websites. If you follow links to websites not affiliated or controlled by Silver Lake, you should review their privacy policies, as this Privacy Policy no longer applies – i.e., the policies and practices of other websites and other parties are governed by their respective privacy policies. Silver Lake does not guarantee and is not responsible for the privacy or security of these other sites, including the accuracy, completeness, or reliability of their information. We encourage you to ask questions and read the privacy policies of other websites before you disclose any personal information to them.

Please be advised that the virtual data room portals that can be accessed through links on the Site by investors in funds managed by Silver Lake are maintained by our third-party service providers, FIS Data Systems (previously SunGard DX) and Intralinks. FIS Data Systems’ and Intralinks’s respective privacy policies apply to those portals and to the personal information you provide in activating and using your account to access those portals. FIS Data Systems and Intralinks inform us of who has access to the portals they operate and each user’s usage of the portals. You can review FIS Data Systems’ privacy policy for the portal [here] and Intralinks’s privacy policy for the portal [here].  We encourage you to review those privacy policies.

Providing Personal Information through the Site

This Site is hosted in the United States.  If you access this Site from outside the United States, you are voluntarily transferring your personal information to the United States, a jurisdiction which does not offer the same type of protection to the personal information of individuals as the UK and countries within the European Economic Area (“EEA”).

Transfers of Your Personal Information

Some of the third parties listed in the “disclosure of information” section may be located in jurisdictions outside of the UK or the EEA.

If you are located in the UK or EEA, we will comply with applicable legal requirements to provide adequate protection for the transfer of personal information to recipients in countries outside of the UK and EEA respectively. In all such cases, we will only transfer your personal information if:

• The country to which the personal information will be transferred has been granted an adequacy decision by the UK government (for transfers of UK data subjects’ personal data) or the European Commission (for transfers of EEA data subjects’ personal data);
• We have put in place appropriate safeguards in respect of the transfer, for example the Standard Contractual Clauses; or
• In the absence of an adequacy decision and where it is not possible to implement appropriate safeguards, we have another lawful basis for doing so.

If you are located in the UK or EEA you also may request a copy of the safeguards that we have put in place in respect of transfers of personal information by contacting us as described in the How to Contact Us section below.

How Long We Keep Your Personal Information

The time period for which we keep personal information depends on the purpose for which we collected it. In all cases we keep it for as long as reasonably necessary to fulfil the purposes for which we collected it. We will then delete the personal information, unless we are legally required to retain it, if we need to retain it in order to comply with our legal obligations (for example, for tax and accounting purposes), or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Subject to any applicable legal requirements, we typically retain personal information as follows:

• Personal information you provide to us through our Site: We keep this personal information for as long as necessary in order to fulfil the purpose for which you provided it to us, which will generally not exceed six years from the date you provided the data, and for a short further period in case you send us further requests.
• Personal information you provide when you sign up to receive direct marketing communications: We keep most of this personal information for the duration of our relationship with you until you opt-out or we do not have any contact with you for a long period of time.
• Personal information collected for analytics purposes: We keep this personal information for a short period of time necessary for us to carry out the analytics.
• Website logs: We keep Site audit logs, which may contain your personal information, for several months.

Your Rights

If you are located in the UK or EEA, you may, depending on the circumstances, have the following rights in relation to personal information that we hold about you:

• To request confirmation of whether we process personal information relating to you and, if so, to request a copy of that personal information;
• To request that we rectify or update your personal information that is inaccurate, incomplete, or outdated;
• To request that we erase your personal information in certain circumstances, such as where we collected personal information on the basis of your consent and you withdraw your consent;
• To request that we restrict the use of your personal information in certain circumstances, such as while we consider another request that you have submitted (for example, a request that we update your personal information);
• Where you have given us consent to process your personal information, to withdraw your consent;
• To request that we provide a copy of your personal information to you or a third party in a structured, commonly used, and machine-readable format in certain circumstances;
• To object to certain of our data processing, such as for direct marketing purposes; and
• To lodge a complaint with the relevant data protection authority in your jurisdiction (for example, the Information Commissioner’s Office in the UK). If you would like to discuss your concern with us before contacting a data protection authority, please use our contact details below.

If you are located in the UK or EEA and you wish to exercise any of your data protection rights, or if you consider that we have processed your personal information in violation of applicable law, or have any concerns regarding your privacy, please contact us as detailed in the “How to Contact Us” section below. 

How to Contact Us

If you have any questions regarding this Privacy Policy, or wish to notify us of any errors or changes as to any personal information you provide us through the Site, you can write to us at Privacy Matters, Silver Lake, 2775 Sand Hill Road, Suite 100, Menlo Park, CA 94025, or at Broadbent House, 65 Grosvenor Street, London W1K3JH, United Kingdom, or email us at [email protected].

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California Job Applicant Privacy Notice

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California Privacy Notice

In addition to the categories of third parties identified above, during the 12-month period prior to the Last Updated date of this CA Privacy Notice, we may have disclosed personal information about you to government entities (e.g., law enforcement authorities) and to third parties in connection with actual or proposed corporate transactions, such as mergers, acquisitions, or bankruptcy.

California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

Access:  You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, and disclosed about you.

Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.

Deletion: You have the right to request that we delete certain personal information we have collected from you.  Please note that as a registered investment adviser, we are required by law to maintain certain records and may be unable to accommodate your request.

If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.  For questions or concerns about our privacy policies and practices, please contact us as described in the “How to Contact Us” section of our Privacy Policy, which can be found on our website at https://www.silverlake.com/privacy-policy.

How to Submit a Request

To submit an access, correction or deletion request on your own behalf or as an authorized agent, email us at [email protected] or call our toll-free number at (866) 994-0462.

Verifying Requests

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request.  If you request access to, or correction or deletion of, your personal information, we may require you to provide certain information, such as your full name, email address, and phone number.  In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

Additional Information

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.  This CA Privacy Notice is available in alternative formats upon request.  Please contact [email protected] or our toll-free number at (866) 994-0462 between the hours of 9:00 am and 5:00 pm Pacific Time to request this CA Privacy Notice in an alternative format.

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Modern Slavery Act Statement

Silver Lake Europe LLP (“SLE”)

OVERVIEW

In October 2015, the UK’s Modern Slavery Act (“MSA”) came into force, requiring large organisations doing business in the United Kingdom to produce a public “slavery and human trafficking statement”. The concept of “modern slavery” encapsulates behaviours such as forced, compulsory or coerced labour, deprivation of personal freedom or facilitating the movement of people for exploitation.

BUSINESS STRUCTURE

SLE acts as a sub-advisor to Silver Lake’s US affiliates in relation to the investment of European based assets of Silver Lake managed funds. SLE is based in the U.K. and authorised and regulated by the U.K. Financial Conduct Authority. 

Although SLE is not technically required to publish a statement under the MSA, we have decided to publish this statement on a voluntary basis. This statement covers our financial year ending 31 December 2023. This statement is published on behalf of SLE and references to “we” or “our” are to that entity.

SUPPLY CHAIN AND RISK ASSESSMENT

SLE takes a zero-tolerance approach to slavery and human trafficking in all its forms. We endeavour to ensure that our business and supply chains are conducted and managed responsibly, in line with the principles underpinning the MSA.

Given the nature of SLE’s advisory business, we believe there is a relatively low risk of slavery or human trafficking in connection with our activities. The goods and services we typically procure are limited to areas such as office equipment, IT, professional services, facility management and catering.

Nonetheless, we understand that no business is completely risk-free and so, consistent with the principles of the MSA and as part of our initiative to identify and manage risk:

We continually look to better (a) identify, assess and monitor potential higher risk areas in the supply chains to our business, (b) mitigate the risk of slavery and human trafficking occurring in these supply chains through enhanced contract terms (to the extent appropriate and obtainable), (c) train relevant employees as to these risks and the need to manage them and (d) protect whistle blowers (please see below for further information on our Whistleblowing procedures).  

 Where possible, we build long-standing relationships with our key suppliers and ensure that expectations of business behaviour are clear and consistent.  

POLICIES

A number of our existing policies and procedures support our commitment in this area. These include:

• Compliance Manual, covering a number of different areas, which underpins our standards of behaviour and expectations of good business practice for all of our employees;
• Anti-bribery and Corruption Policy and Gifts and Entertainment Policy, which set out our zero-tolerance approach towards the receipt or request of bribes and other corrupt behaviour;
• Whistleblowing procedure, which includes both internal and external contact information for reporting malpractice and raising concerns and allows for any actual or suspected issues to be raised in a confidential manner; and
• We proactively support community organisations and develop relationships with organisations that are working to address issues that are a priority for our firm. Silver Lake supports community and equal opportunity initiatives, such as SEO London’s ‘Careers’ program, which the firm participates in.

IMPLEMENTATION

Our SLE legal and compliance team take responsibility for implementing the objectives considered in this statement, monitoring progress of our efforts in this area and issues (should they arise) and report back to SLE’s Management Committee directly as appropriate.

Since our first MSA statement was published, we have used the following key performance indicators to track our progress toward increasing the awareness of and protecting against slavery and human trafficking arising in, or the supply chains to, our business:

• We provide training on slavery, human trafficking and the MSA to relevant SLE personnel (see below);
• We have incorporated a MSA section into our Silver Lake Europe LLP Compliance Manual, which is provided to all SLE employees; and
• We review suppliers to our business and the terms which we work with them on (see above).

These metrics will continue to be used going forward.

TRAINING

Our SLE legal and compliance team provide training to relevant SLE personnel to educate them on the importance of implementing and enforcing effective systems to ensure slavery and human trafficking is not taking place in our business or supply chains.

A MSA update is included in our annual compliance refresher, which highlights the key issues employees should be aware of and provides an overview of the key legislative framework in this area.

MONITORING AND REPORTING

If issues are identified in relation to modern slavery or human trafficking, these should be immediately reported to our legal and compliance team.

More general issues in relation to the running of this policy are reported back to the Management Committee as appropriate.

This statement is reviewed annually and is published on our website – https://www.silverlake.com/modern-slavery-act-statement.

MANAGEMENT COMMITTEE APPROVAL

Silver Lake Europe LLP Management Committee approved this statement on 1 July 2024.

This statement is made on a voluntary basis pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes SLE’s slavery and human trafficking statement for the financial year ending 31 December 2023.

Date: 1 July 2024

Next review date: June 2025

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Transparency in Coverage

This link leads to the machine-readable files that are made available in response to the federal Transparency in Coverage Rule and includes negotiated service rates and out-of-network allowed amounts between health plans and healthcare providers. The machine-readable files are formatted to allow researchers, regulators, and application developers to more easily access and analyze data.

https://www.cigna.com/legal/compliance/machine-readable-files

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UK Recruitment Process Privacy Notice

Last Updated: January 31, 2024

This Privacy Notice describes how Silver Lake Europe LLP (“Silver Lake” or “we”) collects and uses the personal data of prospective personnel for Silver Lake and its portfolio companies in connection with recruitment by the firm (“Prospects” or “you”). Silver Lake is the data controller in respect of Prospect personal data.

If at any point you have questions about this notice or how we will treat your personal data, you should contact us using the details at the end of this notice.

Personal Data We Collect About You

We may collect (directly or indirectly), store, and use the following personal data about Prospects:

• Personal details and characteristics including your name, address, and previous addresses, birthplace and date, phone numbers, e-mail address, passport details, photographs, and birth and marriage certificates.

• Information contained in your C.V. and covering letter or provided as part of a background, reference, or credit check, including occupational details, current job title, current job description, previous employment details, office location, education details, qualifications, credit history, and other information from our application form.

• Economic, financial, and insurance information including historic salary, benefits and incentives, income and financial information, tax situation, historic insurance package, personal accounts, and holdings.

• Information about your use of technology resources including IP address.

• Your communications with us including information you provide to us during interviews.

• Tests or qualification exam results from any assessments that are required to work with us.

We may also collect (directly or indirectly), store, and use information that may identify or infer information about you in connection with more sensitive types of personal data including:

• your race or ethnicity, religious beliefs, sexual orientation, political opinions and contributions, and trade union membership if you provide it to us.

• information about your health, including any medical condition, health and sickness records.

• your history, if any, of criminal convictions and offences.

You may be required to provide certain personal data to Silver Lake so that we may consider your suitability. If you fail to provide any personal data that is required, we may be unable to continue evaluating your suitability.

How We Collect Personal Data

We typically collect personal data about Prospects from the following sources:

• you directly.

• other Silver Lake affiliates.

• recruitment agencies we collaborate with to fulfil vacancies, from which we may receive information including your resume/C.V., current and past employment, and other qualifications.

• professional background check providers.

• credit reference agencies.

• your named referees, former employers and other references, from whom we collect information about your previous employment and suitability for the role you are applying for.

• publicly accessible sources, including the internet and financial regulator registers, from which we collect information about your qualifications, regulatory authorisations, and news items involving you.

• our server logs, which automatically record certain information from the devices of Site visitors, such as the number and frequency of visits, as well as IP addresses, time spent on the Site, and pages viewed.

How We Use Your Personal Data

We use the personal data that we collect, subject to applicable law and regulations, in the following ways:

• Recruitment: managing and administering recruitment processes, carrying out background checks, making travel arrangements, assessing your skills, qualifications, and suitability for the vacancy you are applying for, communicating with you about the recruitment process, making offers to successful Prospects, personnel onboarding, and keeping records related to our hiring process to monitor and ensure fairness in our practices. We process personal data for these purposes on the basis that it is necessary for our legitimate interests in managing and administering our business and recruiting personnel for Silver Lake and its portfolio companies.
  
• Legal and compliance: compliance with legal and other requirements such as immigration, record-keeping, and reporting obligations, reviewing HR processes, political contributions, responding to legal process such as subpoenas and court orders, pursuing legal rights and remedies, defending litigation and managing any internal complaints or claims, conducting investigations and complying with internal policies and procedures. We process personal data for these purposes on the basis that we are required to do so by law or it is necessary for the establishment, exercise, or defence of legal claims.
  
• Communications, facilities and emergencies: facilitating communications with you, protecting the health and safety of anyone visiting our premises, and safeguarding office equipment, facilities, and other property. We process personal data for these purposes on the basis that it is necessary for our legitimate interests in managing and administering our business, and administering, maintaining, and ensuring the security of our IT systems and premises.
  
• Sensitive information: We may also collect certain types of sensitive personal data for specific purposes, including the collection of health or medical information for accessibility and ‘fit for work’ purposes and diversity-related personal data (such as gender, race, or ethnicity) for equal opportunity monitoring and reporting purposes. We do not collect your sensitive personal data unless we are required or permitted to do so by applicable law including in order to carry out our legal obligations or exercise rights in connection with your potential employment, it is needed in the public interests (such as for equal opportunities monitoring), or (in limited circumstances) you have, in accordance with applicable law, provided your explicit consent.

• Criminal convictions information: Depending on the role you apply for, we may need to collect information about your criminal convictions history during the application process, if we intend to offer you employment (conditional on checks and any other conditions, such as references, being satisfactory).  Where the law allows or requires us to, we will carry out a criminal records check in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for employment with us.  For example, we will need to carry out a Standard Disclosure and Barring Service Check for those wishing to work in our London office that will be discharging certain functions regulated by the Financial Conduct Authority.  We will inform you directly where we need to perform criminal convictions checks on you for your application.  We process personal data for these purposes on the basis that it is necessary for compliance with our legal obligations, where applicable, or on the basis of your explicit consent.

Data Sharing

We may share your personal data with Silver Lake Technology Management, L.L.C. and its portfolio companies for the purposes described in this Notice.

We may share personal data with service providers that perform services on our behalf such as payment service providers, benefits service providers, analytics providers, and hosting providers. As required by applicable law, we permit them to use or disclose personal data only as necessary to perform services on our behalf or comply with applicable legal requirements.

In addition, we may disclose personal data about you (a) if we are required to do so by law or legal process, for example due to a request from a law enforcement or other governmental authority, a subpoena, court order, or discovery request; (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss; (c) when we believe in good faith that such disclosure is necessary or appropriate in connection with any activity that violates the law (including relating to intellectual property, fraud, contracts, and privacy) or may expose Silver Lake to liability; (d) in connection with the investigation of suspected or actual fraudulent or other illegal activity; and (e) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

Data Transfers

We may transfer the personal data that we collect about you to recipients in countries other than the country in which the personal data originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the personal data. When we transfer your personal data to recipients in other countries (such as the U.S.), we will take appropriate steps to ensure it is adequately protected in compliance with the UK GDPR. We will usually do this by entering into standard contractual clauses (approved by the UK Information Commissioner’s Office) for data transfers with the recipient of your personal data.

You may request a copy of the safeguards that we have put in place in respect of cross-border transfers of personal data by contacting us as described in the ‘How to Contact Us’ section below.

Data Retention

Your personal data is retained for the duration of the relevant recruitment processes/discussions and as long as necessary thereafter to fulfil the purposes described above, which may be for up to six-years.

Retention periods may be extended if we are required to preserve your personal data in connection with litigation, investigations and proceedings, or if a longer retention period is required by applicable law.

Retention periods may also be extended if you ask us to inform you about future job opportunities.

If your application is successful personal data provided to us in the recruitment process may be further processed by Silver Lake and retained as described in any applicable employee privacy notice.

Your Rights and Choices

Prospects applying for a position with Silver Lake in the UK may have the following rights in relation to that personal data:

• To request confirmation of whether we process personal data relating to you and, if so, to request a copy of that personal data;

• To request that we rectify or update your personal data that is inaccurate, incomplete, or outdated;

• To request that we erase your personal data in certain circumstances, such as where we collected personal data on the basis of your consent and you withdraw your consent;

• To request that we restrict the use of your personal data in certain circumstances, such as while we consider another request that you have submitted, for example a request that we update your personal data;

• Where you have given Silver Lake consent to process your personal data, to withdraw your consent;

• To request that we provide a copy of your personal data to you or a third party in a structured, commonly used and machine-readable format in certain circumstances;

• To object to certain of our data processing, such as for direct marketing purposes; and

• To lodge a complaint with the relevant data protection authority in your jurisdiction (for example, the Information Commissioner’s Office in the UK).

If you wish to exercise any of your data protection rights, or if you consider that we have processed your personal data in violation of applicable law, please contact us as detailed in the “How to Contact Us” section below.

How to Contact Us

If you have any questions regarding this Privacy Policy, or wish to notify us of any errors or changes as to any personal data you provide us through the Site, you can write to us at Privacy Matters, Silver Lake, 2775 Sand Hill Road, Suite 100, Menlo Park, CA 94025, or at Broadbent House, 65 Grosvenor Street, London W1K3JH, United Kingdom, or e-mail us at [email protected].

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Walker Guidelines: Disclosures

Effective as of: December 13, 2024

In November 2007, a UK advisory group led by Sir David Walker published the Walker Guidelines for Disclosure and Transparency in Private Equity, which make recommendations to encourage greater disclosure and transparency by private equity firms investing in United Kingdom portfolio companies.

Silver Lake has voluntarily agreed to endeavour to conform on a “comply or explain” basis as part of its support of the Walker Guidelines. Silver Lake also intends to work alongside its United Kingdom portfolio companies covered by the Walker Guidelines to do the same.

Silver Lake has published this document in order to provide information on its UK private equity operations as part of its ongoing commitment to compliance with the Guidelines.

Silver Lake and Silver Lake Europe’s Private Equity Operations
Silver Lake is the global leader in technology investing, with more than $103 billion in combined assets under management and committed capital and a team of professionals located around the world. Dedicated to the thesis that the dynamism and rapid pace of innovation in global technology demand intensely focused domain expertise, Silver Lake devotes its full scope of talent and intellectual capital to the singular mission of investing in the world’s leading technology, technology-enabled and related growth businesses. Applying the strategic insights of an experienced industry participant, the operating skill of a world-class management team, and sophisticated investing and structuring capabilities, Silver Lake leverages the deep knowledge and expertise of a global team based in North America, Europe and Asia.

Silver Lake Europe LLP (SLE) acts as a sub-advisor to Silver Lake’s US affiliates in relation to the investment of European based assets of Silver Lake managed funds. SLE is based in the U.K. and authorised and regulated by the U.K. Financial Conduct Authority.

Launched in 1999 as a specialist firm focused on technology company investments, Silver Lake has maintained its strategic discipline since its founding and engages in a synergistic and collaborative approach to investing across the following investment strategies:

• Silver Lake Partners engages as a strategic market participant via large-scale investments in technology, technology-enabled and related growth businesses.
• Silver Lake Alpine targets structured equity and debt investment opportunities in large-cap technology, technology-enabled and related growth businesses.
• Silver Lake Long Term Capital is a 25-year long term strategy that furthers Silver Lake’s ability to partner with companies across all stages of growth.

The average holding period for our European private equity investments is expected to be between 4 and 6 years.

For more information on our investment approach and private equity operations, please see our website (https://www.silverlake.com).

For more information on our structure and investment approach and how we deal with conflicts of interest see our website (https://www.silverlake.com) and Silver Lake Technology Management L.L.C.’s public filings with the US Securities and Exchange Commission (https://www.sec.gov).

Portfolio Companies
As of the date of this document, we have more than $103 billion in combined assets under management and committed capital and a team of professionals located around the world. Silver Lake’s portfolio companies collectively generate nearly $248 billion of revenue annually and employ approximately 444,000 people globally. For a list of our current portfolio companies, including those headquartered in the United Kingdom, please see our website (https://www.silverlake.com/portfolio/).

Conflicts of Interest
Silver Lake places significant importance on the prevention and management of conflicts of interest. Silver Lake has established and implemented a formal conflicts policy which ensures that it has appropriate systems and controls in place to identify, prevent and manage conflicts between its own interests and those of its clients and those of one client and another.

Silver Lake and SLE Team and Leadership
Silver Lake has a team of investment, operating and group professionals located in North America, Europe and Asia that manage Silver Lake’s investment activities across the globe.

For more information on the SLE team, based in London, including its leadership, please see our website (https://www.silverlake.com/team).

Limited Partners
We have established strong relationships with a diverse base of investors by type and geography. Many of these investors have invested with us since our inception and across multiple funds that we have sponsored. The commitments we receive come from a variety of institutions, with the largest percentage of our commitments for Silver Lake Partners V, Silver Lake Partners VI and Silver Lake Partners VII coming from public pensions and sovereign wealth funds. We also receive commitments from insurance companies, financial institutions, high net worth individuals, family offices and endowments and foundations, among other types of investors. 4% of these institutions are based in the United Kingdom, with the remaining 96% being based throughout the rest of the world.

Commitment to the Walker Guidelines
Silver Lake is supportive of the Walker Guidelines. SLE endeavours to conform to the Walker Guidelines on a “comply or explain” basis and intends to work alongside our United Kingdom portfolio companies covered by the Walker Guidelines to do the same.

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UK Public Disclosure

1. Introduction

1.1 Purpose

Silver Lake Europe LLP (FRN 460882) (the “Firm“) is authorised and regulated by the Financial Conduct Authority (the “FCA”). The Firm is part of the Silver Lake group (the “Group“), which is an alternative asset management group specialising in private equity investments.

This document (the “Disclosure Statement“) sets out the information the Firm is required to disclose annually under chapter 8 of the MIFIDPRU Sourcebook in the FCA Handbook of Rules and Guidance. All information is as at the date on page 1 unless otherwise indicated.

1.2 Scope

The information in this Disclosure Statement relates to the Firm on an individual basis, i.e., it does not concern any other entities in the Group.

A number of functions used by the Firm are Group-level. As such, the Firm will involve Group-level functions in the activities described below, as required.

Unless otherwise noted, the information contained in this Disclosure Statement has not been audited by the Firm’s external auditors and does not constitute any form of financial statement and should not be relied upon in making any judgment on the Firm.

2. Governance Arrangements

2.1 Role of Management Committee

The Firm is governed by members of its management committee (“Management Committee“). The Firm is required to ensure that the Management Committee defines, oversees and is accountable for the implementation of governance arrangements that ensure effective and prudent management of the Firm, including the segregation of duties in the Firm and the prevention of conflicts of interest, and in a manner that promotes the integrity of the market and the interests of clients.

The Firm seeks to achieve this through several means, including:

• through adopting an appropriate process for appointments to the Management Committee;
• processes for the functioning of the Management Committee, including reporting of management information on risks the Firm is or might be exposed to, or the Firm poses or might pose to others;
• obligations under the FCA Senior Managers and Certification Regime, as part of which certain senior members of staff (“Senior Management Function-holders“) are required to be approved by the FCA and a number of other members of staff are required to be certified by the Firm as fit and proper to perform their roles;
• legal obligations applicable to members of the Management Committee under the Limited Liability Partnership Regulations 2001 and fiduciary and agency law;
• policies and procedures, including in particular the Firm’s compliance manual, conflicts of interest policy, remuneration policy, and its policies on personal account dealing and market abuse;
• its policy on the suitability of the management body, which seeks to ensure that:
  • individually, the members of the Management Committee are of sufficiently good repute, possess sufficient knowledge and experience to perform their duties, commit sufficient time to the role and demonstrate honesty, integrity and independence of mind; and
  • the Management Committee as a whole possesses adequate collective knowledge, skills and experience to understand the Firm’s activities, including the main risks and reflect an adequately broad range of experiences; and
• the appointment of legal and accounting advisers and compliance consultants and other advisers as required from time to time.

2.2 Composition of the Management Committee

The members of the Firm’s Management Committee are set out in the following table, together with the number of directorships held by each member (i.e. excluding their role on the Management Committee, since this is not a directorship at law), including directorships of portfolio companies but excluding (i) directorships held in organisations which do not pursue predominantly commercial objectives and (ii) directorships of Group entities.

Name	Number of directorships (executive and non-executive)
Simon Patterson	8
Jonathan Galore	4

2.3 Diversity of the Management Committee

The Firm is committed to promoting diversity and equal opportunities for staff throughout the Firm, including on its Management Committee. The Firm believes that diverse and inclusive teams make better decisions, and this informs the Firm’s recruitment and retention strategies, both across the organisation as a whole and at the level of its Management Committee. 

All appointments are made on merit against objective criteria, and with regard to individual and collective knowledge, skills, experience and diversity of the Management Committee, as a whole, in accordance with the Firm’s policy on the suitability of the management body.

2.4 Risk governance

The Firm has well-established risk management policies in relation to the operational risks facing the business as well as those associated with the Firm’s activities. The Management Committee is ultimately responsible for the Firm’s overall risk management and for maintaining an appropriate internal control framework. 

The Firm does not have an independent risk management function, nor is it required to maintain a Risk Committee. Instead, the Firm’s Management Committee is supported in its responsibility for managing the risks inherent in the Firm’s activities by the Legal, Compliance and Finance departments.

3. Risk Management Objectives and Policies

3.1 Potential for harm associated with the Firm’s business strategy

The Firm considers that the potential for harm associated with its business strategy is low. Notably, the Firm does not engage in proprietary trading, underwriting, placing, clearing or settlement activities, hold significant balance sheet exposures, have tied agents or provide custody services or services to retail clients.

The Firm’s business strategy reflects its generally low-risk appetite, including towards risks in conduct, prudential matters, reputation, legal, compliance and regulation, financial crime, data and cyber security, and sustainability.

The Firm is remunerated by an affiliated fund management entity on a cost-plus basis and receives sufficient revenues to cover the Firm’s total costs plus a mark-up.

The level of detail of information in this Disclosure Statement is consistent with this proportionality assessment.

3.2 Strategies and processes used to manage risks addressed by own funds and liquid assets requirements

Basic Own Funds Requirement and Basic Liquid Assets Requirement

The Firm is subject to a Basic Own Funds Requirement and a Basic Liquid Assets Requirement.

The Firm’s Basic Own Funds Requirement is the higher of (i) £75,000, (ii) one quarter of its preceding year’s fixed overheads (its fixed overheads requirement, or “FOR“) and (iii) a ‘K-factor’ requirement (“KFR“) (0.02% applied to its assets under ongoing advice).

The Firm’s Basic Liquid Assets Requirement is the sum of one third of its FOR and 1.6% of the total amount of any guarantees provided to clients.

Details of the Firm’s own funds (i.e. its corporate member capital contributions) are set out at Schedule 1.

Details of the Firm’s Basic Own Funds Requirement are set out at Schedule 2.

Overall Financial Adequacy Rule 

The Firm must at all times comply with the overall financial adequacy rule (the “OFAR“). This requirement, which supplements the Firm’s Basic Own Funds Requirement and Basic Liquid Assets Requirement, requires the Firm to holds sufficient own funds and liquid assets to:

• ensure it can remain viable throughout the economic cycle, with the ability to address any potential harm the Firm’s ongoing activities might cause to its clients and counterparties, the markets in which it operates and the Firm itself; and
• allow its business to wind‑down in an orderly way, minimising harm to clients and counterparties and to other market participants.

The Internal Capital Adequacy and Risk Assessment

The Firm uses an internal capital adequacy and risk assessment (“ICARA“) process to identify whether it is complying with its OFAR and, if it is not, to identify what steps it should take to remedy this.

The focus of the ICARA process is on identifying and managing risks that may result in material harms to clients and counterparties, the markets in which the Firm operates and the Firm itself, measuring the effectiveness of the Firm’s strategies to monitor and mitigate those harms, and determining whether additional own funds and/or liquid assets are required to mitigate any residual risks.

The FCA recognises that the risk of some material harms can be reduced through proportionate measures other than holding additional financial resources, for example implementing additional internal systems and controls, strengthening governance and oversight processes or changing the manner in which the Firm conducts certain business.

However, for other harms identified, it may be that the only realistic option to manage them and to comply with the OFAR is for the Firm to hold additional own funds and/or additional liquid assets above its Basic Own Funds Requirement and Basic Liquid Assets Requirement.

The Firm has therefore formed a judgment about what is appropriate and proportionate in its particular circumstances, informed by its risk appetite, which is set by the Management Committee.

The Firm’s ICARA document is updated annually (or more frequently, as required) by the Firm’s Legal, Compliance and Finance teams, with input from external advisers as required. The document and the key assumptions underlying it are then reviewed and approved by the Management Committee.

Responsibilities of Senior Management Function-holders

The Firm has a Senior Management Function-holder whose responsibilities encompass prudential compliance. The Management Committee is responsible for deciding whether to take any and all recovery actions set out in its ICARA; it will designate particular individuals to be responsible for the implementation of specific recovery actions, as required, which are expected to include members of the Firm’s Legal and Finance teams.

All Senior Management Function-holders recognise that the ICARA process is a key requirement of the regulatory system for the Firm and that it is an essential part of the Firm’s internal systems and procedures for ensuring that the Firm’s business is run prudently.

3.3 Concentration risk

Concentration risk refers to the risks arising from the strength or extent of the Firm’s relationships with, or direct exposure to, a single client or group of connected clients. The Firm has identified the following concentration risks and has put in place the following control strategies:

Earnings

This is the risk that the Firm has a significant amount of its revenue concentrated in a small number of clients, leaving it exposed if it loses one or more of those clients.

The Firm’s revenue is derived entirely from an affiliate under a cost-plus arrangement. Whilst this technically creates a concentration risk, the Firm considers that any downside of this is more than offset by the stability of revenue that the arrangement creates.

Cash deposits

The Firm maintains instant-access cash accounts with an institutional Fitch A Stable (or above) UK credit institution in order to keep cash deposit risk to an acceptable level.  The Firm, including Finance, monitors and controls its cash deposit risk on an ongoing basis.

4. Remuneration

4.1 Remuneration governance

The Management Committee has overall responsibility for the Firm’s remuneration policies and procedures, which have been adopted by the Management Committee and are reviewed annually.

The Management Committee has allocated responsibility for overseeing the implementation of the Firm’s remuneration policy to a Senior Management Function-holder. The Firm’s remuneration policies and practices are operated on a day-to-day basis by the Human Resources Department with support from the Compliance department.   

4.2 Material Risk Takers

The Firm’s material risk takers (“MRTs“) are those individuals whose professional activities have a material impact on the Firm’s risk profile. The Firm’s MRTs comprise of members of the Management Committee and the Compliance and Money Laundering and Reporting Officer.

During the course of the year, the Firm identified three MRTs in total.

4.3 Remuneration structure

The Firm’s remuneration arrangements seek to ensure effective risk alignment between the Firm’s staff, the Firm itself and the Funds advised by the Group.

The Firm awards both fixed remuneration (typically, Firm members’ fixed annual profit share / Firm employees’ salary, together with salary-linked pension contributions and certain benefits (as applicable)) and variable remuneration (typically, variable annual profit share / annual performance staff bonus, and carried interest awards (which are treated as variable remuneration for the purposes of MIFIDPRU only), where applicable).

Fixed remuneration is determined primarily by the market rate for the role performed, having regard to the skills, expertise and experience demonstrated by the particular individual.

In the case of employees, variable remuneration is determined based on the Firm’s performance assessment criteria, having regard to the individual’s performance against those criteria during the relevant performance period and over a multi-year framework and for the Firm members, on the basis of the performance of the Firm as a whole. Variable remuneration typically takes the form of an annual discretionary bonus / variable annual profit shares (as applicable) and other cash bonus arrangements. Different categories of variable remuneration are available to different types of staff and eligibility for certain types of variable remuneration is also linked to positions held within the Firm, but most schemes are available to the majority of staff.  For example, certain staff are eligible to participate in carried interest arrangements and Silver Lake’s leveraged co-invest schemes, and, in the case of the Firm members, receive variable annual profit share, where applicable.

The total available pool of variable remuneration is determined by reference to the Firm’s financial performance, taking into account the Firm’s regulatory capital and liquidity requirements, future working capital needs and any reasonably foreseeable liabilities or obligations. Where applicable, individual performance is assessed by reference to both financial and non-financial criteria, including whether an individual has adhered to the Firm’s internal compliance policies and procedures and demonstrated behaviours consistent with the Firm’s corporate values.

The Firm does not typically offer non-standard forms of variable remuneration. The Firm hires individuals into roles conferring MRT status only rarely. In exceptional circumstances, the Firm has the ability to offer guaranteed variable remuneration to MRTs joining the Firm in the form of a ‘lost opportunity bonus’, provided the Firm’s capital position is sufficiently sound at that time.

The Firm has obtained legal advice in relation to the requirements in SYSC 19G but does not use external consultants in the development of its remuneration policies and practices.

4.4 Risk adjustment

The Firm’s variable remuneration arrangements are fully discretionary, and the Firm is able to apply in-year adjustments to reduce (including to zero) the amount of variable remuneration that would otherwise have been paid to any member of staff (including MRTs).

Variable remuneration awarded to MRTs is subject to additional adjustments. In specific circumstances where an MRT has (i) participated in or been responsible for conduct which has resulted in significant losses to the Firm and/or (ii) failed to meet appropriate standards of fitness and propriety, the Firm may take one or more additional measures including malus (reducing the amount of variable remuneration awarded to an MRT) and/or clawback (requiring the MRT to make a payment to the Firm equal to all or some variable remuneration received within a specified time period).

The Firm ensures that any payments to MRTs relating to the early termination of an employment contract reflect the individual’s performance over time and do not reward failure or misconduct.

The Firm maintains policies and procedures governing its approach to risk adjustments and severance payments, including how the Firm takes into account current and future risks when adjusting remuneration.

5. Quantitative disclosures  

The Firm has aggregated its disclosures in relation to senior management and other MRTs in order to avoid disclosing information concerning one or two individuals only.

Total renumeration to all staff			Severance payments made to MRTs			Guaranteed variable remuneration awarded to MRTs
Total fixed remuneration	(GBP million)		Total payments made	(GBP million)		Total payments made	(GBP million)
Senior management and other MRTs	1.9		Senior management and other MRTs	N/a		Senior management and other MRTs	N/a
Other staff	5.8		TOTAL	N/a		TOTAL	N/a
SUB-TOTAL	7.7		Amount of highest severance payment awarded	N/a
Total variable remuneration	(GBP million)		Awards of severance payments made	No. of MRTs		Awards of guaranteed variable remuneration made	No. of MRTs
Senior management and other MRTs	5.3		Senior management and other MRTs	N/a		Senior management and other MRTs	N/a
Other staff	9.5
SUB-TOTAL	14.9
GRAND TOTAL	22.5

SCHEDULE 1 OWN FUNDS

Composition of regulatory own funds (“Template OF1”)
Item	Amount (GBP thousands)	Source based on reference numbers/letters of the balance sheet in the audited financial statements
OWN FUNDS
TIER 1 CAPITAL
COMMON EQUITY TIER 1 CAPITAL
Fully paid-up capital instruments	5,000	Members’ capital classified as equity
Share premium	N/a	N/a
Retained earnings	N/a	N/a
Accumulated other comprehensive income	N/a	N/a
Other reserves	N/a	N/a
Adjustments to CET1 due to prudential filters	N/a	N/a
Other funds	N/a	N/a
(-) TOTAL DEDUCTIONS FROM COMMON EQUITY TIER 1	N/a	N/a
CET1: Other capital elements, deductions and adjustments	N/a	N/a
ADDITIONAL TIER 1 CAPITAL
Fully paid-up, directly issued capital instruments	N/a	N/a
Share premium	N/a	N/a
(-) TOTAL DEDUCTIONS FROM ADDITIONAL TIER 1	N/a	N/a
Additional Tier 1: Other capital elements, deductions and adjustments	N/a	N/a
TIER 2 CAPITAL
Fully paid up, directly issued capital instruments	N/a	N/a
Share premium	N/a	N/a
(-) TOTAL DEDUCTIONS FROM TIER 2	N/a	N/a
Tier 2: Other capital elements, deductions and adjustments	N/a	N/a

Own funds: reconciliation of regulatory own funds to balance sheet in the audited financial statements
	a	b	c
	Balance sheet as in published/audited financial statements	Under regulatory scope of consolidation	Cross- reference to template OF1
	As at period end (GBP thousands)	As at period end (GBP thousands)
Assets – Breakdown by asset classes according to the balance sheet in the audited financial statements
Tangible assets	3,305	N/a	N/a
Debtors: amounts falling due after more than one year	3,359	N/a	N/a
Debtors: amounts falling due within one year	27,249	N/a	N/a
Cash at bank and in hand	5,731	N/a	N/a
Total Assets	39,644	N/a	N/a
Liabilities – Breakdown by liability classes according to the balance sheet in the audited financial statements
Creditors: amounts falling due within one year	5,605	N/a	N/a
Provision for other liabilities	666	N/a	N/a
Total Liabilities	6,271	N/a	N/a
Shareholders’ Equity
Members’ capital classified as equity	5,000	N/a	Fully paid-up capital instruments
Members’ capital classified as debt	2,145	N/a	N/a
Other amounts due to members	26,228	N/a	N/a
Total Shareholders’ equity	33,373	N/a	N/a

Own funds: main features of own instruments issued by the firm

Free text included below.

The Firm meets its own funds threshold requirement (“OFTR“) through its fully paid-up member capital contributions, the entirety of which have been contributed by the Firm’s corporate member which is the Firm’s immediate parent undertaking.

SCHEDULE 2 BASIC OWN FUNDS REQUIREMENTS

	Category of requirement	Amount (GBP thousands)
1	PERMANENT MINIMUM REQUIREMENT	75
2	FIXED OVERHEADS REQUIREMENT	3,082
3	K-FACTOR REQUIREMENT (K-AUM: ASSETS UNDER MANAGEMENT)	426
	BASIC OWN FUNDS REQUIREMENT (HIGHEST OF ROWS 1-3)	3,082

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Silver Lake’s 2024 Environmental, Social and Governance Policy

While Silver Lake believes that the ESG credentials of portfolio companies are relevant to current and future value and can provide meaningful enhancement either directly or through the mitigation of relevant risks, Silver Lake does not pursue an ESG-based investment strategy or limit its investments to those that meet specific ESG criteria. Activities which seek to address ESG factors in portfolio company value chains can add value and reduce risk, though no guarantee is made that there will be such outcomes. Silver Lake believes that engaging with portfolio companies on ESG matters is an important component of seeking to deliver maximized risk adjusted returns to its investors. ESG initiatives described in this ESG policy may not apply to some or all of a fund’s investments and none are mandatory features of the manager’s investment strategy. There can be no assurance that ESG initiatives will continue or be successful.

1.     Commitment to Mitigating Risk and Creating Value

Silver Lake Technology Management, L.L.C. (“Silver Lake” or the “Firm”) has been delivering value to a variety of stakeholders – including investors, portfolio companies and employees – since its founding in 1999. The Firm takes a proactive approach to evaluating and managing Environmental, Social and Governance (“ESG”) factors that can impact the performance and long-term success of the Firm and the portfolio companies that it supports, as well as the communities where the Firm operates. This ESG philosophy is consistent with Silver Lake’s investment approach.

2.     Background

Silver Lake’s approach to ESG is tailored to the particular investment strategy.  The Silver Lake Partners (“SLP”) and Silver Lake Alpine (“SLA”) strategies principally target larger investments in later stage companies, and Silver Lake frequently has varying degrees of governance rights and varying degrees of ability to influence a company’s trajectory.  In contrast, Silver Lake Long Term Capital (“LTC”) principally target companies or funds, which often include smaller, more passive investments than SLP or SLA, and therefore Silver Lake is likely to have a more limited ability to influence the company or fund.[1] 

Material ESG factors (including both opportunities and risks) are considered as part of the diligence process to evaluate new investments and inform related policies and procedures. For purposes of this policy, material ESG factors include considerations that Silver Lake believes may meaningfully affect a portfolio company’s value and performance or otherwise subject the company to substantial risk.

We have developed an ESG framework to guide our approach to diligence, monitoring and engagement with portfolio companies. Priority areas include: data privacy and cybersecurity, business ethics, corporate governance (including ESG governance), employee engagement, equity, diversity and inclusion (“ED&I”), health and safety, GHG emissions and energy management. Our ESG framework also takes into account respect for human rights, which is embedded across several of these priority areas. We monitor policies, practices and disclosures as available in each area, as well as compliance with applicable laws and regulations (e.g., labor and anti-corruption laws and information security regulations).

The strategic and systematic consideration of ESG factors is an integral part of Silver Lake’s investment management activities. Silver Lake seeks to promote responsible business practices and is committed to lawful and responsible behavior by its portfolio companies in order to maximize risk adjusted investment returns through creating, enhancing and preserving the long-term value of the investments made by our Funds. Accordingly, Silver Lake incorporates the review of ESG factors in its processes when assessing potential investment opportunities, when engaging in investment management and when preparing for exit, in each case where appropriate and feasible.

3.     Purpose

The purpose of this policy is to define Silver Lake’s approach to integrating the consideration of ESG risks and associated value creation opportunities with respect to potential and current investments. Silver Lake is a member of the American Investment Council (“AIC”), which developed the Guidelines for Responsible Investment (“Guidelines”).[2] These Guidelines incorporate the UN Global Compact’s principles and have been used to inform Silver Lake’s approach and commitment to ESG integration.

Silver Lake is committed to evaluating material ESG factors (both opportunities and risks) during the initial investment process, and throughout the investment management and exit processes to the extent reasonably practicable under the circumstances, and subject to the provisions of the Confidential Private Placement Memorandums, Limited Partnership Agreements and other legally binding documents associated with the Funds.

The Firm considers relevant portions of various globally accepted standards, frameworks, guidelines and guidance, including the Sustainability Accounting Standards Board’s sustainability framework. Silver Lake will continue monitoring various standards, legal requirements, industry research and emerging best practices, among other things, to evolve the Firm’s approach to ESG integration as appropriate. Starting in 2024, Silver Lake joined the ESG Data Convergence Initiative (“EDCI”) to facilitate streamlined and effective collection and reporting of ESG data.

4.     Scope

This policy is intended to apply to the investments considered or made across all strategies, although Silver Lake’s ability to influence the Funds’ investments and integrate the consideration of ESG priorities will vary across each of its investments.

As such, the ESG framework for the SLP and SLA strategies is more extensive than the framework for LTC’s strategy, anticipating a lighter touch and higher level approach for LTC than the other strategies within Silver Lake.  Certain of the practices described below are expected to be modified based on limitations regarding, among other things, a company’s own infrastructure and ability to gather, or practices relating to gathering, ESG-related information.  For example, LTC is not expected at this time to conduct portfolio company surveys on an annual basis.

It may not always be feasible for Silver Lake to engage directly with portfolio companies on material ESG factors or influence their behavior, especially where a Fund has a small relative ownership interest in the company.[3] Where Silver Lake does not expect to be in a position to influence material ESG factors, this is taken into account in the investment decision and the Firm will nonetheless consider whether there are other appropriate reasonable efforts for Silver Lake to take in furtherance of the goals of this policy.

5.     Investment Process Integration

Silver Lake seeks to integrate the consideration and thoughtful management of ESG factors throughout the investment cycle of each portfolio company, subject to the limitations outlined in sections two (2), three (3) and four (4) above.

Initial Investment Process: During the initial investment process, Silver Lake professionals, as well as third-party advisors that the Firm may engage, such as outside counsel and/or third-party expert consultants, perform legal, industry and company-specific due diligence[4] that aims to identify potential material risks and opportunities, including relating to ESG factors. Due diligence may include, among other items, evaluation of important and complex business, operational, financial, tax, accounting, corporate governance, environmental, social and legal issues.[5] Silver Lake may seek to collect relevant ESG-related information from a potential portfolio company via questionnaires, publicly available information, engagement with company management teams, or other means. Material findings relevant to the considerations for transactions are to be documented and shared with the Investment Committee, where appropriate.

During Investment: Silver Lake works to monitor each portfolio company’s focus on applicable ESG-related factors. Where an ESG issue is considered by the Firm to require action (including an issue identified during the initial investment process), the responsible investment professionals, in consultation with others, are tasked with determining the appropriate course of action. Consideration of ESG topics has been incorporated as part of the Portfolio Company Review process as well.

At Exit: Silver Lake will determine the manner in which it addresses any ESG-related efforts during the exit process of any portfolio company on a case-by-case basis.

6.     Portfolio Monitoring

Silver Lake undertakes certain documentation efforts as part of this ESG Policy:

Initial Investment Process: For the SLP and SLA Funds, Silver Lake will document material ESG findings as part of the due diligence process, which will be considered in connection with analyzing material risks or value creation opportunities regarding a new investment.

During Investment:[6] Silver Lake will conduct an annual survey of some or all of the portfolio companies in the SLP and SLA Funds (depending on, among other things, the size of the stake). The survey has historically incorporated metrics identified by the EDCI and select metrics from other frameworks, standards and regulations, including the Task Force on Climate-related Financial Disclosures and the EU’s Sustainable Finance Disclosure Regulation.  The survey is updated periodically.  Aggregate data will be used to help identify trends or opportunities for improvement across companies and inform engagement plans. Company-level findings will be shared with deal teams as appropriate, including issues or risks believed to be in need of action. Portfolio company assessments will take into account survey responses, observed progress and insights from third-party data sources.

Ad Hoc: In the event a material ESG issue is identified at a portfolio company, either through third-party sources or engagement with the company, Silver Lake will review and consider the appropriate course of action including, where appropriate, in partnership with the company’s management team (depending on, among other things, Silver Lake’s level of influence).

Silver Lake values transparency with its investors. Where relevant and practicable, the Firm will consider what, if any, disclosure may be appropriate or permissible, either verbally or in writing.

7.     Portfolio Engagement

The Silver Lake portfolio represents a diverse group of companies, each in a unique stage of its ESG journey. Where feasible, the Firm’s goal as a partner is to assist portfolio companies in promoting robust governance and helping them to advance ESG performance in areas that are considered material. Where Silver Lake employees serve on the Board of Directors of a portfolio company, they will to the extent practicable seek to promote progress regarding material ESG factors.

In addition, for SLP and SLA Fund portfolio companies, the Silver Lake team has historically hosted sessions on ESG topics of shared interest so that portfolio company ESG program leaders can learn from each other and from outside advisors that bring additional expertise. The Firm also maintains an ongoing dialogue with individual companies on ESG topics and has shared research and observations with companies that are earlier in their ESG development. Silver Lake recognizes the role that other stakeholders, including other investors, may play in advancing ESG-related practices at a company. As such, the Firm will seek to collaborate with other investors and stakeholders on an ad-hoc basis.

8.     Management and Accountability

ESG is a shared responsibility across the Firm. The Firm has an ESG Committee, which is chaired by the Chief Compliance Officer and Head of Litigation and is comprised of senior members of the Firm across relevant functional areas. The Managing Partners are ultimately accountable for oversight of this policy with support from the ESG Committee and other leaders across the Firm. It is the responsibility of Silver Lake’s Head of ESG & Impact, who reports directly to the Managing Partners, to ensure that the policy is properly and reasonably applied and that ESG training occurs periodically, covering this policy and a range of key ESG-related topics and issues. This has historically included a new hire training for Analysts and Associates as they join the Firm as well as an annual ESG governance session designed for Board members and other investment professionals to stay current on key ESG topics. Additional ESG updates are shared with the ESG Committee and Silver Lake professionals on an ongoing basis.

Silver Lake professionals are responsible for following this policy and identification of ESG factors during due diligence and throughout the investment cycle for each company. Through the Firm’s Portfolio Company Review process, investment and operating professionals are to report on material ESG factors identified in the SLP and SLA portfolios during or subsequent to the investment process. The Head of ESG & Impact is responsible for oversight of the monitoring process. The Fundraising and Investor Relations team helps to coordinate the reporting of ESG-related information to investors and other relevant third-parties. The Legal team manages the Funds’ legal risks.

Recognizing the importance of ESG to many of Silver Lake’s Limited Partners, the Firm seeks to share relevant ESG updates during Limited Partner Advisory Committee meetings, the Annual General Meeting, investor communications, or other forums, when practical and appropriate. Silver Lake publishes an ESG & Impact report annually to summarize programmatic changes and updates. Members of the Fundraising and Investor Relations and ESG teams are available to discuss the Firm’s ESG program upon request.

This policy will be reviewed and revised as needed to reflect changes in Silver Lake’s business and the context in which the Firm operates.

9.     Firm Alignment

Silver Lake is committed to conducting itself in accordance with this ESG policy. Silver Lake holds its employees to the highest of standards and demands that they act ethically, professionally and responsibly. Silver Lake views compliance with this policy as part of each employee’s responsibility to abide and uphold the Firm’s commitment. This policy will be furnished or made available to all Silver Lake employees.

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[1] Under the current sub-advisory agreement with Silver Lake Waterman (“SLW”), the SLW team will execute on its own ESG policy and procedures.

[2] American Investment Council, Guidelines for Responsible Investment, published 2009, https://www.investmentcouncil.org/guidelines- for-responsible-investing/

[3] For example, in cases where a Silver Lake Fund(s) holds a minority investment in the publicly traded securities of a company, Silver Lake may have limited control or influence over any ESG risks or opportunities that may affect such company.

[4] ESG due diligence will vary based on, among other things: (i) the nature of Silver Lake’s investment, (ii) the transaction process and timeline, (iii) the level of access to information, specifically as it pertains to ESG factors, and (iv) the target investment’s sector or business model.

[5] Silver Lake Waterman and LTC are expected to conduct more limited due diligence given the size of the strategies’ investments and focus on investments in earlier-stage private companies and/or funds.

[6] Assumes access to requisite information.

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