Placement Agent Policy

SWIB works with its own consultants to evaluate and manage alternative investment funds. SWIB believes its consultants have comprehensive coverage of the universe of opportunities available to SWIB and, together, SWIB, its legal counsel, and its consultants work to perform all necessary due diligence before SWIB makes any new investments. SWIB recognizes that many private markets fund managers use placement agents to identify sources of capital, which could be located anywhere in the world. If SWIB is contacted by a placement agent or a lobbyist regarding a potential investment or if a placement agent is otherwise involved in a fund investment, SWIB has a number of institutional controls in place to ensure full disclosure of any potential conflict of interest. This is to ensure that no SWIB board member or staff person benefits personally from any SWIB investment. All of SWIB’s investments are made within the context of SWIB’s fiduciary responsibility to the funds it manages.