ENVIRONMENTAL SOCIAL AND GOVERNANCE PHILOSOPHY
OVERVIEW
OUR PHILOSOPHY

We view ESG considerations as a critical investment tool, contributing to the research and management of leveraged finance investments. Our deep and talented team integrates ESG factors throughout the investment, portfolio construction and risk management process with rigor and discipline. In addition to this embedded approach, we are able to provide clients with customized ESG and SRI solutions to meet their investment objectives. In the quest for capital preservation and long-term investment gains, we view the integration of our ESG Principles in our investment process as a critical risk mitigation tool, which is closely monitored by our risk team.

OUR ESG PRINCIPLES
  • ESG factors are considered when making investment decisions.

  • ESG issues can have a direct impact on profitability, cash flow and an issuer’s ability to pay back debt in a timely manner and, therefore, are a critical part of investment analysis.

  • ESG factors are not “stand-alone” but are integrated into Shenkman’s disciplined and structured investment process.

  • The ability to constructively engage with management teams and equity sponsors is a core principle of Shenkman’s investment philosophy.


    We have a long track record of integrating ESG factors across our broad leveraged finance platform and building customized solutions, including tailoring to client specific SRI objectives, since 2002.  While ESG analysis has been included in our firm’s discipline for many years, we have recently become PRI signatories and have worked to systematize the ESG process across the organization.
PRI ASSESSMENT

Shenkman became a signatory to the Principles for Responsible Investment (PRI) in August 2017 and, as a result, we are required to submit a report on our responsible investing activities on an annual basis. 2019 (for calendar year 2018) was our first required reporting year.  The PRI publishes a public version of our annual questionnaire (Transparency Report), which is available here:  https://www.unpri.org/.

  • According to the PRI, the annual reporting ensures:
    • Accountability of the PRI and its signatories
    • A standardized transparency tool for signatories’ reporting
    • That signatories receive feedback from which to learn and develop
  • SHENKMAN'S 2019 PRI ASSESSMENT
    There is no overall score, rather, Shenkman was scored on the following modules: (i) Strategy & Governance; (ii) Fixed Income – Corporate Financial; (iii) Fixed Income – Corporate Non-Financial; and (iv) Fixed Income – Securitised. Scores range from A+ to E and PRI publishes a median score of all responders of each module. Shenkman’s score, and the median score, for each module is described below:
    MODULE NAME SHENKMAN
    SCORE
    MEDIAN
    SCORE
    Strategy & Governance A A
    Fixed Income - Corporate Financial A B
    Fixed Income - Corporate Non-Financial A B
    Fixed Income - Securitised A C
    Shenkman is committed to incorporating all factors that could potentially impact the value of an investment. We remain engaged in the ESG space -- as a PRI signatory, maintaining dialogue with our clients, educating our team members and continuing to evaluate best practices for responsible investing.
    ESG NEWSLETTERS

    CALIFORNIA CONSUMER PRIVACY NOTICE

    JANUARY 2020

    Introduction

    As a valued partner of the Shenkman Group of Companies, your privacy is very important to us. This notice (this “California Consumer Privacy Notice”) is provided by the Shenkman Group of Companies, and their affiliates (collectively the “Shenkman Group”), as well as mutual funds, private funds (single investor or commingled), Collateralized Loan Obligations (“CLOs”), and UCITS funds managed by the Shenkman Group (each, a “Sponsored Fund” and, collectively “Sponsored Funds”).

    This California Consumer Privacy Notice contains disclosures required by the California Consumer Privacy Act (“CCPA”), is only relevant to residents of California, and applies only to the collection or other use of “personal information” that is subject to the CCPA.

    References to “you”, “your”, “investor”, or “client” in this California Consumer Privacy Notice mean any resident of California. References to, “we”, “us”, or “our” in this Privacy Notice mean a Sponsored Fund or the Shenkman Group, as applicable. The Shenkman Group includes Shenkman Capital Management, Inc., Shenkman Capital Management Ltd, Romark Credit Advisors LP, Romark CLO Advisors LLC, and their affiliates. Capitalized terms used but not defined herein have the meanings assigned to them in the Form ADV Part 2A of Shenkman Capital Management, Inc., or of Romark Credit Advisors LP, as applicable, each of which may be supplemented, updated or modified from time-to-time.

    Personal Information We Collect

    In the past 12 months, we may have collected, without limitation, the following categories of personal information about you:

    • Identifies, such as your real name, alias, email address, postal address, Internet Protocol (IP) address, account name, Social Security number, driver’s license number, passport number, or other similar personal identifiers;
    • Other personal information categories (as listed in the California Customer Records statute), such as your signature, physical characteristics or description, telephone number, insurance policy number, education, employment, employment history, bank account number or any other financial information, medical information, or health insurance information;
    • Protected classification characteristics under California or federal law, such as your age, race, citizenship, marital status, gender, or veteran or military status;
    • Commercial information, such as your account activity, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
    • Biometric information, such as your fingerprints, faceprints, voiceprints, and iris or retina scans;
    • Internet or other similar network activity, such as information regarding your interaction with our website, online portal, or other applications;
    • Sensory data, such as recordings of your audio (e.g., voicemails);
    • Professional or employment-related information, such as your current or past job history or performance evaluations;
    • Non-public education information, such as your education records maintained by an educational institution or party acting on its behalf; and
    • Inferences drawn from other personal information, such as a profile reflecting your preferences, characteristics, trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

    We do not knowingly collect or solicit personal information from anyone under the age of 18.

    Sources of Personal Information We Collect

    We primarily collect personal information from the following categories of sources:

    • Your communications with us;
    • Service providers, including, but not limited to, administrators, lenders, banks, trading counterparties, auditors, law firms, consultants, placement agents, employment agencies and recruiters, and background check providers;
    • Affiliates not under the Shenkman Group brand;
    • Nonprofit organizations; and
    • Government entities.

    Use of Personal Information

    We may use or disclose the personal information we collect for one or more of the following purposes:

    • Providing you with information about our products and services;
    • Providing performance and other updates;
    • One or more of the following business purposes:
      • Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
      • Auditing related to our interactions with you (e.g., counting ad impressions to unique visitors, verifying positioning/quality of ad impressions, and auditing compliance, etc.);
      • Legal compliance;
      • Internal operations;
      • Activities to maintain and improve our services; and
    • Other commercial purposes, including, but not limited to, activities that are directed to advancing commercial or economic interests, such as inducing a person to buy, rent, lease, join, subscribe to, provide or exchange products or services, or enabling or effecting a commercial transaction.

    Sharing Personal Information.

    We may provide personal information to:

    • Service providers, including but not limited to, administrators, lenders, banks, trading counterparties, auditors, law firms, consultants, placement agents, employment agencies and recruiters, and background check providers;
    • Affiliates;
    • Business partners;
    • Legal or government regulatory authorities as required by applicable law; and
    • In connection with a potential business transfer.

    In the past 12 months, we have not sold any personal information we collect to third parties, and we have shared the categories of personal information we collect only as set forth above.

    Rights of California Consumers

    The CCPA provides a California consumer the following rights, subject to certain exceptions and limitations:

    • The right to request (a) the categories and specific pieces of personal information we collect, use, disclose, and sell about you, (b) the categories of sources from which we collected your personal information, (c) our purposes for collecting or selling your personal information, (d) the categories of your personal information (if any) that we have either sold or disclosed for a business purpose, and (e) the categories of third parties with which we have shared personal information;
    • For certain categories of personal information, the right to request a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the past 12 months and the names and addresses of those third parties;
    • The right to request that we delete the personal information we have collected from you or maintain about you;
    • The right to opt out of our sale(s) (if any) of your personal information; and
    • The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

    You may submit requests to exercise your rights under the CCPA to our Chief Compliance Officer at DataProtection@shenkmancapital.com or at (212) 867-9090.

    Revisions to Our Privacy Policies

    The Shenkman Group evaluates its privacy policies and procedures to implement improvements and refinements from time-to-time. The Shenkman Group reserves the right to amend the terms contained herein in whole or in part for any reason without notice to you. We therefore suggest that you review this California Consumer Privacy Notice periodically, which is available at https://www.shenkmancapital.com/.

    California Privacy Notice Page

    PRIVACY NOTICE

    April 2020

    Introduction

    As a valued partner of the Shenkman Group, your privacy is very important to us. This notice (this “Privacy Notice”) is provided by Shenkman Group of Companies, and their affiliates (collectively the “Shenkman Group”), as well as mutual funds, private funds (single investor or commingled), Collateralized Loan Obligations (“CLOs”), and UCITS funds managed by the Shenkman Group (each, a “Sponsored Fund” and, collectively “Sponsored Funds”). This Privacy Notice sets forth our policies for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of personal data relating to current, prospective and former clients and investors in Sponsored Funds, as applicable.

    References to “you”, “your”, “investor”, or “client” in this Privacy Notice mean any investor in a Sponsored Fund or any client of the Shenkman Group, as applicable. References to, “we”, “us”, or “our” in this Privacy Notice mean a Sponsored Fund or the Shenkman Group, as applicable.

    The Shenkman Group includes Shenkman Capital Management, Inc., Shenkman Capital Management Ltd, Romark Credit Advisors LP, Romark CLO Advisors LLC, and their affiliates. Capitalized terms used but not defined herein have the meanings assigned to them in the Form ADV Part 2A of Shenkman Capital Management, Inc., or of Romark Credit Advisors LP, as applicable, each of which may be supplemented, updated or modified from time-to-time.

    Who to Contact About This Privacy Notice

    This Privacy Notice is being provided in accordance with the applicable requirements under the privacy and data protection laws that apply in the jurisdictions where we operate (collectively, the “Data Protection Laws”). Certain Shenkman Group entities and Sponsored Funds are considered to be data controllers in respect of any personal data we hold about you for the purposes of certain Data Protection Laws, please see the last section of this Privacy Notice for a comprehensive list. This means that each of the Sponsored Funds and the Shenkman Group (alone or jointly, as applicable) determines the purposes and the means of the processing of your personal data.

    Please contact our Chief Compliance Officer at DataProtection@shenkmancapital.com, at (212) 867-9090, or by writing to the following address, Shenkman Capital Management, Inc., 461 Fifth Avenue, New York, NY 10017 with any questions about this Privacy Notice or requests with regards to the personal data we hold.

    Please note that certain service providers (collectively, the “Service Providers”) of the Shenkman Group and/or Sponsored Fund including, without limitation, administrators, transfer agents, legal advisers, depositaries, distributors, prime brokers, and custodians work under a range of professional and legal obligations that require them to process personal data (e.g., anti-money laundering legislation).

    In order to meet the requirements of such obligations, such Service Providers, from time-to-time, would not be acting on our instructions but instead in accordance with their own respective professional or legal obligations and, therefore, would be acting as data controllers in their own right with respect to such processing. For more specific information or requests in relation to the processing of personal data by such service providers, you may also contact the relevant Service Provider directly, and we can provide relevant contact information upon request. With respect to Sponsored Funds, Service Provider contact information may be found in the prospectus or confidential private placement memorandum of the applicable Sponsored Fund.

    The Types of Personal Data We May Hold

    The categories of personal data we may collect include, but are not limited to: names; residential or business addresses, or other contact details; signature; nationality; tax identification, passport, or social security number or similar identification number; date of birth; place of birth; country of incorporation or domicile; jurisdiction of tax residence(s) photographs; copies of identification documents; bank account details; information about assets or net worth; credit history; information on investment activities; financial information, for example, interest, dividends, income from certain insurance contracts or products and other income generated with respect to assets held in the account or payments made with respect to the account; account balances; proceeds from the sale or redemption of property paid or credited to the account; or other personal data, such as certain special categories of personal data (including, where relevant, information on political affiliations, ethnic origin, or criminal convictions), as specified under the applicable Data Protection Laws, that may be contained in the relevant materials, documents, or obtained through background searches, together with any other information required by applicable law or regulation.

    How We Collect Personal Data

    We may collect personal data about you through:

    (i) information provided directly to us by you, or another person on your behalf;

    (ii) information that we obtain in relation to any transactions between youand us; and

    (iii) recording and monitoring of telephone conversations with you.

    We also may receive your personal data from third parties or other sources, such as, but not limited to, our affiliates, the Service Providers, publicly accessible databases or registers, tax authorities, governmental and non-governmental agencies and supervisory authorities, credit agencies, fraud prevention and detection agencies, or other publicly accessible sources, such as the internet.

    How We May Use Personal Data

    We may process your personal data in the course of our business tasks, including, without limitation, in connection with:

    (i) Entering into an advisory agreement or accepting subscription documentation;

    (ii) administering the relationship between you and us;

    (iii) processing subscriptions and redemptions;

    (iv) executing discretionary transactions;

    (v) providing communications and reporting;

    (vi) maintaining the registers of investors of Sponsored Funds;

    (vii) marketing of our products and services;

    (viii) monitoring and analyzing our activities;

    (ix) processing investments and withdrawals of and payments of dividends to investors;

    (x) maintaining global client and investor records and providing centralized administrative, marketing and client services;

    (xi) investigating and resolving complaints and recording calls and managing litigation monitoring electronic communications for fraud or crime detection or for regulatory reasons; or

    (xii) complying with applicable AML rules and other legal and regulatory obligations, such as maintaining controls in respect of CRS/FATCA obligations and reporting tax information to tax authorities.

    We will use one of the permitted grounds under the applicable Data Protection Laws to process your personal data. Such grounds include, for example, circumstances where: (i) processing is necessary to perform our obligations under applicable advisory agreements or Sponsored Fund governing documents; (ii) we are required to comply with a legal or regulatory obligation applicable to us; or (iii) we, or a third party on our behalf, have determined that it is necessary for our legitimate interests to collect and use your personal information, such as if we believe that you have a reasonable expectation for us or a third party to collect or use your personal data for such purpose.

    What Are The Consequences Of Failing To Provide Personal Data

    Where personal data is required to satisfy a statutory or regulatory obligation (including compliance with applicable anti-money laundering or sanctions requirements) or a contractual requirement, failure to provide such information may result in our advisory agreement with you, or, as applicable, your subscription in the applicable Sponsored Fund being rejected or terminated, and/or your interests in a Sponsored Fund becoming subject to compulsory redemption or withdrawal, as applicable. Where there issuspicion of unlawful activity, failure to provide personal data may result in the submission of a report to the relevant law enforcement agency or supervisory authority.

    How We May Share Personal Data

    We may disclose certain personal data about you to our affiliates, Service Providers or other third parties to onboard you as an advisory client, or in the case of Sponsored Fund investors, to accept your subscription, administer and maintain your account(s), or otherwise perform our contractual obligations.

    We may also need to share your personal data:

    (i) with courts, ombudsmen, regulatory, tax, law enforcement, or other non-governmental regulators and/or authorities to comply with applicable legal or regulatory requirements;

    (ii) to respond to court orders, or in the context of regulatory requests for information, administrative proceedings, or investigations; or

    (iii) when we believe in good faith that disclosure is legally required or we or a Sponsored Fund have a legitimate interest in making a disclosure, such as where necessary to protect our or a Sponsored Fund’s rights and property. We will also release information about you if you direct us to do so.

    It may also be necessary, under anti-money laundering and similar laws, to disclose personal data about you to facilitate the establishment of trading relationships for your accounts, or in the case of Sponsored Fund investors, accounts of the Sponsored Funds, with prime brokers, custodians, executing brokers or other trading counterparties.

    We may also disclose personal data about you, or your transactions and experiences with us, to our affiliates or Service Providers for our everyday business purposes, such as administration of our business, record-keeping, maintaining security of our information technology systems, reporting and monitoring of our activities, investor relations activities, and compliance with applicable legal and regulatory requirements.

    We may also disclose personal data about you to any third party that acquires, or is interested in acquiring, all or part of our assets or ownership interests, or that succeeds us in carrying on all or a part of our or its business, whether by merger, acquisition, reorganization or otherwise.

    Retention Periods and Security Measures

    We will take reasonable steps to protect your personal data against loss or theft, as well as from unauthorized access, disclosure, copying, use or modification, regardless of the format in which it is held.

    We will retain personal data for a minimum period of six years from the date on which you redeem all of your shares or units in the relevant Sponsored Fund(s) or you close your account with the Shenkman Group, or for as long as required for us to perform the services or comply with applicable legal or regulatory obligations.

    We will notify you of any material personal data breaches affecting you in accordance with the requirements of applicable Data Protection Laws.

    Monitoring of Communications

    We may record and monitor telephone conversations and electronic communications with you for the purposes of: (i) ascertaining the details of instructions given, the terms on which any transaction was executed or any other relevant circumstances; (iii) ensuring compliance with our regulatory obligations; and/or (iii) detecting and preventing the commission of financial crime.

    Additional Information under the U.S. Gramm-Leach-Bliley Act 1999 (Reg S-P) and Fair Credit Reporting Act (Reg S-AM)

    For purposes of U.S. federal law, this Privacy Notice applies to current and former clients and investors who are individuals or Individual Retirement Accounts. We are providing this additional information under U.S. federal law.

    Please refer to the Privacy Statement of Refinitiv, a due diligence Service Provider of the Shenkman Group, located here: https://www.refinitiv.com/en/policies/privacy-statement

    We may disclose information about our clients, investors, prospective investors or former investors to affiliates (i.e., financial and non-financial companies related by common ownership or control) or nonaffiliates (i.e., financial or non-financial companies not related by common ownership or control) for our everyday business purposes, such as to process your transactions, maintain your account(s) or respond to court orders and legal investigations. Thus, it may be necessary or appropriate, under anti-money laundering and similar laws, to disclose information about our clients or Sponsored Fund investors in order to accept subscriptions from them. We will also release information about you if you direct us to do so.

    We may share your information with our affiliates for direct marketing purposes, such as offers of products and services to you by us or our affiliates. You may prevent this type of sharing by contacting us at DataProtection@shenkmancapital.com. If you are a new client or investor in a Sponsored Fund, we can begin sharing your information with our affiliates for direct marketing purposes 30 days from the date we sent this Privacy Notice. When you are no longer our client or an investor in a Sponsored Fund, we may continue to share your information with our affiliates for such purposes.

    You may contact us at any time to limit our sharing of your personal data at DataProtection@shenkmancapital.com. If you limit sharing for an account you hold jointly with someone else, your choices will apply to everyone on your account. U.S. state laws may give you additional rights to limit sharing.

    We do not share your information with non-affiliates for them to market their own services to you. We may disclose information you provide to us to companies that perform marketing services on our behalf, such as any placement agent retained by a Sponsored Fund, or a client solicitor.

    Additional Information under the Cayman Islands Data Protection Law 2017 (“DPL”)

    With respect to investors in Sponsored Funds organized under the laws of the Cayman Islands, the applicable Sponsored Fund may share your personal data with its Services Providers, including the Shenkman Group, as well as the Sponsored Fund’s administrators, transfer agents, depositories, distributors, custodians, prime brokers, or others who are located outside the Cayman Islands. It may also be necessary to share your information with the Cayman Islands Monetary Authority or the Tax Information Authority, which may, in turn, exchange this information with foreign tax authorities, regulatory or law enforcement agencies. By submitting your personal data to us, you consent to the transfer of your personal data to Shenkman and the other recipients described in this notice that are located in countries outside of the Cayman Islands. Any transfer of your personal data by us, our affiliates or service providers outside the Cayman Islands will be carried out in accordance with the DPL.

    Investors may withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

    You may have certain rights under the DPL, including: (i) the right to be informed; (ii) the right of access; (iii) the right to rectification; (iv) the right to stop or restrict processing; (v) the right to stop direct marketing; (vi) rights in relation to automated decision making; (vii) the right to seek compensation; and (viii) the right to complain to the supervisory authority. If you wish to exercise these rights, please contact DataProtection@shenkmancapital.com. A complaint in respect of a Sponsored Fund organized under the laws of the Cayman Islands may be lodged with the Office of the Ombudsman in the Cayman Islands, although, we ask that you contact DataProtection@shenkmancapital.com in the first instance to give us the opportunity to address any concerns you may have.

    Additional Information under the EU General Data Protection Regulation

    You may have certain rights under EU General Data Protection Regulation (“GDPR”) in relation to our processing of your personal data and any processing carried out on your behalf. These rights include: (i) the right to request access to your personal data; (ii) the right to request rectification of your personal data; (iii) the right to request erasure of your personal data (the “right to be forgotten”); (iv) the right to restrict our processing or use of your personal data; (v) the right to object to our processing or use where we have considered this to be necessary for our legitimate interests (such as in the case of our marketing activities); (vi) where relevant, the right to request the portability of the data; (vii) if your consent to processing has been obtained, the right to withdraw your consent at any time; and (viii) the right to lodge a complaint with a supervisory authority. Please note that the right to be forgotten that applies in certain circumstances under GDPR is not likely to be available in respect of the personal data we hold, given the purpose for which we collect such data, as described above. Please contact DataProtection@shenkmancapital.com if you wish to exercise these rights. A complaint in respect of the Shenkman Capital Management Ltd may be lodged with the Information Commissioner’s Office in the United Kingdom, although, we ask that you contact DataProtection@shenkmancapital.com in the first instance to give us the opportunity to address any concerns you may have. Due to the international nature of our business, your personal data may be transferred to jurisdictions that do not offer equivalent protection to personal data as under the GDPR (“Third Countries”). By submitting your personal data to us, you consent to the transfer of your personal data to Shenkman and the other recipients described in this notice that are located in countries outside of the EEA. Investors may withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. In such cases, we will process personal data (or procure that it be processed) in the Third Countries in accordance with the requirements of GDPR.

    The Shenkman Group has entered into EU standard contractual clauses (“Model Contracts”) for intragroup transfers of personal data. Investors have a right to request copies of the Model Contracts by contacting DataProtection@shenkmancapital.com. We may also be required to transfer your personal data to our regulators or government agencies in Third Countries in cases where such transfers are necessary in the context of administrative proceedings, such as requests for information, examinations or investigations, or to other relevant parties in Third Countries where it is necessary for the purposes of establishing, bringing, or defending legal claims, or for another legitimate business purpose, such as compliance with our legal or regulatory obligations under foreign law.

    Revisions to Our Privacy Policies

    The Shenkman Group evaluates its privacy policies and procedures to implement improvements and refinements from time-to-time. The Shenkman Group reserves the right to amend the terms contained herein in whole or in part for any reason without notice to you. We therefore suggest that you review this

    Privacy Notice periodically, which is available at https://www.shenkmancapital.com/privacy_notice.

    Data Controllers

    As referenced above, the Shenkman Group entities and Sponsored Funds identified in the table below may be considered to be data controllers in respect of certain personal data we hold about you for the purposes of the applicable Data Protection Laws:

    Shenkman Capital Management, Inc.

    Shenkman Capital Management Ltd

    Shenkman Investments, LLC

    Shenkman Capital Management, L.L.C.

    Adams Mill CLO Ltd.

    Adams Mill CLO LLC

    Adams Mill Issuer Subsidiary I LLC

    Adams Mill Issuer Subsidiary II LLC

    Adams Mill Issuer Subsidiary III LLC

    Credos Floating Rate Fund Ltd.

    Credos Floating Rate Fund Subsidiary I Ltd.

    Four Points Multi-Strategy Master Fund, Inc.

    Four Points Multi-Strategy Master Fund Subsidiary I, Ltd.

    Four Points Multi-Strategy Master Fund Subsidiary II, Ltd.

    Four Points Multi-Strategy Master Fund Subsidiary IV, Ltd.

    Four Points Multi-Strategy Fund, Inc.

    Shenkman High Yield Bond Master Fund, Inc.

    Jackson Mill CLO Ltd.

    Jackson Mill CLO LLC

    Jackson Mill Issuer Subsidiary I LLC

    Jackson Mill Issuer Subsidiary III LLC

    Jefferson Mill CLO Ltd.

    Jefferson Mill CLO LLC

    Jefferson Mill Issuer Subsidiary I LLC

    Primus High Yield Bond Fund Ltd.

    Shenkman Structured Credit Master Fund Ltd.

    Shenkman Energy Opportunity Master Fund Ltd.

    Shenkman Energy Opportunity Fund Ltd.

    Shenkman Energy Opportunity Fund Subsidiary I Ltd.

    Shenkman Energy Opportunity Fund Subsidiary II Ltd.

    Shenkman CLO Equity Opportunity Fund I LP

    Shenkman Winchester GP LLC

    Shenkman Tactical Credit GP LLC

    Romark Credit Advisors LP

    Romark CLO Advisors LLC

    Shenkman CLO Equity Opportunity Fund I GP, LLC

    Shenkman Opportunistic Credit Master Fund LP

    Shenkman Opportunistic Credit Fund Ltd.

    Shenkman Opportunistic Credit Intermediate Fund LP

    Shenkman Tactical Credit Fund (Cayman) LP

    Shenkman Tactical Credit Intermediate Fund (Cayman) Ltd.

    Shenkman Tactical Credit Master Fund LP

    Sudbury Mill CLO Ltd.

    Sudbury Mill CLO LLC

    Sudbury Mill Issuer Subsidiary I LLC

    Slater Mill Loan Fund, L.P.

    Slater Mill Loan Fund, LLC.

    Brookside Mill CLO Ltd.

    Brookside Mill CLO LLC

    Romark WM-R Ltd.

    Romark WM-R LLC

    Romark CLO-I Ltd.

    Romark CLO-I LLC

    Romark CLO-II Ltd.

    Romark CLO-II LLC

    Romark CLO-III Ltd.

    Romark CLO-III LLC

    Shenkman High Income Fund

    Shenkman Short Duration High Income Fund

    Shenkman Global Convertible Bond Fund

    Shenkman Global High Yield Bond Fund

    Shenkman Credit Fund plc

    CG Shenkman Hansa High Yield Fund

    CG Shenkman Credit Funds

    Privacy Notice Page

    TERMS OF SERVICE

    JANUARY 2020

    Introduction

    By accessing this website and any of the pages herein (collectively, the “Site”), you signify your agreement with and understanding of the following Terms of Service pertaining to both this Site and any material on it. This Site is offered to you conditioned on your acceptance without modification of the terms, conditions, and notices contained herein. Your use of this Site constitutes your agreement to all such terms, conditions, and notices.

    The Shenkman Group (the “Shenkman Group”, “we”, “us”, or “our”) consists of Shenkman Capital Management, Inc., and its affiliates and subsidiaries, including, without limitation, Shenkman Capital Management Ltd, Romark Credit Advisors LP, and Romark CLO Advisors LLC. The Shenkman Group reserves the right to change the terms, conditions, and notices under which this Site is offered, and such changes are effective immediately. You are bound by such changes and thus should periodically visit this page to review the then-current terms and conditions. If you do not agree to be bound by and subject to these Terms of Service, you must not access or use this Site.

    No Offer of Securities or Advice

    This Site sets forth general information about the Shenkman Group and the services it provides. The material on this Site is not intended to be, and should not be considered as, impartial investment advice, an offering of investment advisory services or an offer to sell or a solicitation to buy any securities. Any offer to sell or any solicitation to buy securities in any jurisdiction, including without limitation any interest of an investment fund or vehicle managed by the Shenkman Group. Any offer to sell or any solicitation to buy securities of an investment fund or vehicle managed by the Shenkman Group will be made only by means of the Prospectus or Offering Memorandum relating to that fund or vehicle. All interests in securities of any fund or vehicle shall not be offered or sold in any jurisdiction in which such an offer, solicitation or sale would be unlawful or would require registration of disclosure until the requirements of the laws, rules and regulations of such jurisdiction have been satisfied. Access to information about such funds is limited to investors who, among other requirements, either qualify as “accredited investors” and “qualified purchasers” within the meaning of the Securities Act of 1933, as amended, and the rules promulgated thereunder, or those investors who generally are sophisticated in financial matters, such that they are capable of evaluating the merits and risks of prospective investments.

    Nothing contained on the Site constitutes tax, accounting, regulatory, legal, or investment advice.

    Investment Risk

    The investment strategies and services discussed on this Site may not be suitable for all investors. Shenkman makes no representations that the contents contained herein are appropriate in all jurisdictions or for all investors or counterparties.

    This Site does not undertake to explain the risks associated with any investment strategy referred to herein. No person or entity should invest in any strategy referred to herein unless satisfied that it (or its investment representative) has asked for and received all information that would enable it (or them) to evaluate the merits and risks thereof. Investment in any strategies described on the Site carries substantial risk, including the possible loss of principal. Past performance is not a guarantee of future results.

    No Reliance

    While the Shenkman Group uses reasonable efforts to update the information on this Site, the Shenkman Group makes no representations or warranties as to the accuracy, reliability or completeness of any information on this Site, and is under no obligation to make such updates. The contents of this Site are subject to change without notice.

    Material to be Consulted in its Entirety

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