Investment Committee
Where every acquisition decision is made.
Composition
The Investment Committee is chaired by the Founder and CEO and includes the Chief Investment Officer, the head of the sector fund making the recommendation, the General Counsel, and at least one independent advisor with sector or governance expertise. Quorum requires three members including the chair.
Authority
The Investment Committee approves all new-platform acquisitions, all follow-on and tuck-in investments above defined thresholds, valuation write-downs, portfolio company CEO changes, and any transactions involving related parties. Below-threshold decisions are delegated to fund GPs subject to reporting-back.
Process
Every deal follows a standardized four-stage IC process — Screening, First Diligence, Deep Diligence, Final IC — documented in a written memo, financial model, and structured risk register. Materials are circulated in advance; decisions are recorded with dissenting views preserved.
Cadence
The Investment Committee meets at minimum bi-weekly and on-demand for time-sensitive matters. Portfolio review sessions occur quarterly, with a full-year strategic and valuation review each January.
Portfolio Company Governance
Every portfolio company on the same standard.
| Element | Standard | Timeframe |
|---|---|---|
| Board composition | Minimum 3 directors — including at least 1 independent director for companies over defined revenue thresholds | Within 90 days of close |
| Committee structure | Audit committee required at scale; compensation committee required for all | Within 180 days |
| Financial reporting | Monthly management accounts, quarterly GAAP financials, annual audit or review | Within 60 days |
| Code of conduct | Standardized company-wide policy including anti-bribery, anti-corruption, whistleblower protections | Within 90 days |
| Cybersecurity | Baseline controls (MFA, endpoint protection, encrypted backups, incident response plan); SOC 2 path for customer-data-holding companies | Within 180 days |
| Legal & regulatory register | Documented inventory of licenses, permits, contracts with change-of-control triggers, and regulatory obligations | At close |
| Board reporting to platform | Standardized quarterly board pack including operating KPIs, financial results, forecast, and risk log | First quarter post-close |
Valuation Policy
How we mark, review, and disclose portfolio value.
Framework
Portfolio holdings are valued in accordance with U.S. GAAP fair value principles (ASC 820) using a combination of market comparables, transaction comparables, discounted cash flow analysis, and — where relevant — recent-round pricing.
Review
Valuations are prepared quarterly, reviewed by the CFO and General Counsel, presented to the Investment Committee, and — for at least a representative sample each year — subject to independent third-party review.
Audit
Annual financial statements at both the fund and platform level are audited by a nationally recognized accounting firm (currently PwC) applying institutional PE audit standards, including a valuation walk and mark-to-market testing.
Conflicts & Independence
Managing conflicts before they become problems.
Conflict Identification
Every deal team member and Investment Committee member completes a conflict declaration prior to each transaction. Declared conflicts trigger recusal from the deliberation and vote on the affected matter.
Cross-Fund Allocations
Opportunities that could plausibly fit more than one Develobrite fund are allocated according to a documented allocation policy prioritizing fund mandate, current deployment pace, and LP fairness. Allocations are reviewed by the General Counsel and disclosed in quarterly LP reporting.
Related-Party Transactions
Any transaction involving a related party — the GP, an affiliate, or a family member of a decision-maker — requires disclosure, independent review, arm's-length terms verification, and Investment Committee approval with the conflicted parties recused.
Personal Trading Policy
All investment professionals and officers are subject to a personal trading policy covering pre-clearance of individual public equity trades, restricted lists, and holding-period requirements — with quarterly reporting and annual attestation.
LP Advisory Committee
Independent LP oversight where it matters.
Each Develobrite fund of sufficient scale forms a Limited Partner Advisory Committee (LPAC) comprising representative LPs. The LPAC reviews conflict-of-interest matters, key-person events, valuation methodology, and other governance topics defined in the LPA.
- Meetings occur at least annually and on-demand for material governance matters.
- Attendance is compensated only for reasonable expenses; no LPAC service fees.
- LPAC minutes are documented and distributed to all LPs after each meeting.
- LPAC members are indemnified consistent with market practice for institutional PE funds.
Regulatory & Compliance
Registered where required; disciplined where not.
Registration Status
Develobrite Capital Management operates in accordance with applicable federal and state investment adviser laws. RIA registration status, Form ADV disclosures, and any exemption reliance are documented on the Legal & Disclosures page and updated as regulatory obligations evolve.
Compliance Program
Written policies covering AML, KYC, insider information, marketing rules, custody, and books-and-records are maintained by the General Counsel and a designated Chief Compliance Officer. Annual compliance review is conducted with findings reported to the Investment Committee.
Independent Auditor
PwC serves as external auditor for platform and fund financial statements. Auditor independence is reviewed annually and disclosed to LPs.
Outside Counsel
Develobrite retains outside counsel for fund formation, transaction documentation, regulatory advisory, and litigation matters. Counsel selection is periodically reviewed for independence, conflict clearance, and service quality.