Navigating ESG issues during the private fundraising process

Building a compliance program and disclosures Role of the compliance department vs. the overall organization (investment teams, investor relations, marketing etc.) ESG policies vs. guidelines ☐ What are the pros and cons of adopting a formal Advisers Act Rule 206(4)-7 ESG policy? ■ Ways to differentiate compliance policies v. statements Recordkeeping Approach to disclosures ROPES & GRAY ■ Aligning public and private disclosures ■ Interaction with gatekeepers 23

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