As a registered investment advisor since April 2012, CD&R complies with the Dodd-Frank Act and annually files form ADV and Form PF with the SEC. CD&R’s internal Compliance Committee, which reviews and approves key compliance matters, includes Joan Barke, Kevin Conway, Kenneth Giuriceo, Jillian Griffiths, Don Gogel, Theresa Gore, John Malfettone, Christian Rochat and J. L. Zrebiec.

CD&R utilizes a fully-automated monitoring system to efficiently and effectively monitor the firm’s key procedures and code of ethics. On a quarterly and annual basis, CD&R engages an external compliance advisor to review its compliance protocols. The Firm’s quarterly portfolio company valuations are also reviewed by a third party advisor (see Valuation Policy Overview).

Finance

Theresa Gore, a certified public accountant who has been with CD&R for 21 years, serves as Chief Financial Officer. Rigorous controls are in place to govern capital call and distribution procedures. Allocations, which are prepared internally, are reviewed by both the CFO and a third party counsel (accounting and/or legal), and all distributions require second approval by the CFO or controller. In addition, the Finance team is responsible for detailed reporting to investors including quarterly capital accounts and fund-level reports as well as maintaining the investor web site. Quarterly valuations, which are prepared by deals teams and reviewed by both the Valuation Committee and a third party advisor (see Valuation Policy Overview), are booked by the finance team onto the LP reporting site for investors.

Human Resources & Business Operations

The human resources and business operations group is led by Barbara Barry, who has more than 25 years of HR and Business Operations experience in financial services, and Joan Barke, the Office Manager in CD&R Europe office. The team is responsible for overseeing background checks, managing employee benefits, conducting ongoing training, and ensuring compliance with local and federal labor regulations. Additionally, the team oversees various day-to-day business operations including management of administrative staff, facilities and business continuity.

Information Technology

The information technology group is led by Vanessa Dong-Monaco, who has been with CD&R for 20 years as an employee or consultant. The team has established a

rigorous multi-layer security system for buildings, floors and data centers, as well as disaster recover protocols to ensure minimal business impact in times of distress. CD&R’s IT Steering Committee, comprising professionals from across the organization, regularly reviews the Firm’s technology roadmap to shape policies and standards that promote both productivity and security.

Legal

CD&R’s legal team entails both in-house and outside counsel. Our In-House Counsel, Terrianne Patnode, supports CD&R’s deal teams in reviewing and negotiating contracts as well as operational departments on a variety of in-house legal matters. Debevoise & Plimpton LLP serves as the Firm's outside legal advisor on a range of transactions, fund formation and administration, compliance, litigation, risk, corporate governance and other matters.