GRAMERCY'S CORPORATE GOVERNANCE

Regulatory Registrations
Gramercy has been a Registered Investment Advisor with the U.S. Securities and Exchange Commission (“SEC”) since 2000, the earliest date possible for our registration under SEC criteria at the time.

Gramercy Ltd, our UK affiliate, is registered with the Financial Conduct Authority (“FCA”) and has maintained registration with advisor/arranger permissions since December 2010. The FCA was formerly known as the Financial Services Authority (“FSA”).

Gramercy Investment Funds plc, our affiliate in Ireland, is registered with the Central Bank of Ireland pursuant to the Companies Acts 1963 to 2012 and the European Communities (Undertakings for Collective Investment in Transferable Securities) Regulations (2013).

Industry Organizations

Gramercy is a Signatory to the Hedge Fund Standards Board. The HFSB is a standard setting body for the hedge fund industry and custodian of the Hedge Fund Standards which create a framework of transparency, integrity and good governance for the industry, facilitate investor due diligence and complement public policy. More information can be found here: www.hfsb.org.

Gramercy Initiatives
Gramercy is SSAE 16 SOC1 Type II compliant. Gramercy has proactively sought to increase investor comfort through additional independent examinations of our operations and investor assets, including SSAE 16 SOC1 Type II (formerly SAS 70) audits of Gramercy’s internal control environment and quarterly asset verifications of commingled fund assets. Obtaining this certification for Gramercy was completely voluntary in order to undergo the rigorous scrutiny required to obtain this certification. Gramercy engages PricewaterhouseCoopers to perform Quarterly Asset Verifications of our commingled funds to confirm the existence of fund holdings at their custodian/prime broker.

In addition, Gramercy maintains a detailed compliance program to guide and monitor employee conduct.