In accordance with the Sarbanes-Oxley Act of 2002, the Audit Committee of the Fund has established the Sarbanes Accounting Complaint Hotline (“Whistleblower Hotline”) to receive, retain, investigate and act on anonymous complaints and concerns regarding accounting, internal accounting controls, and auditing matters which pertain to the Fund. The Fund’s senior management encourages Reporting Persons and the Adviser’s Personnel to report any Suspected Violations to the Whistleblower Hotline, which by law is managed on a confidential and anonymous basis. The Whistleblower Hotline is managed on a confidential and anonymous basis by Convercent, Inc., an independent company unaffiliated with the Fund or the Adviser.
Complaints or concerns regarding the Fund may be reported, either through a web-based portal or by calling a toll-free number and leaving a message. Voices in messages left at the tollfree number are slightly distorted to protect the caller’s identity. Please visit the following link for more information: https://www.whistleblowerservices.com/newmountain.
All messages will be reviewed on a confidential basis by the Fund’s Audit Committee Chairman, an individual who is independent from the Fund and the Adviser. Upon leaving a message, Reporting Persons will be provided with a code that will allow such person(s) to anonymously follow up on the reported violation and check whether the Audit Committee Chairman has asked for clarification or has follow-up questions.
The Whistleblower Hotline can be accessed through the following methods:
Web Portal: https://www.
Toll Free Voicemail: 1-877-909-6999
The Fund encourages open communications with respect to ethical matters and businesspractices and specifically prohibits retaliatory action against parties who, in good faith, initiate communications about such matters.
The Whistleblower Hotline is an enhancement to the Adviser’s existing Code of Ethics which requires Reporting Persons to report any violation(s) of the Code or the Compliance Manual or any other inappropriate conduct to Compliance. The Whistleblower Hotline does not replace other sources available to employees to voice their complaints or concerns, such as supervisors, managers, and human resources staff, rather it is an alternate channel available on an anonymous basis to employees 24 hours a day, 365 days a year.