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CALIFORNIA PUBLIC EMPLOYEES’ RETIREMENT SYSTEMSTATEMENT OF POLICYFOR
 
DISCLOSURE OF PLACEMENT AGENT FEESMay 8, 2009
This policy is effective immediately upon adoption. This policy is intended to supplement any applicable provisions of state or federal law.
I. PURPOSE
 The CalPERS Total Fund Statement of Investment Policy, adopted by theCalPERS Investment Committee (“Committee”), sets forth CalPERS overarchinginvestment purposes and objectives with respect to all its investment programs.This Policy sets forth the circumstances under which the California PublicEmployees' Retirement System ("CalPERS") shall require the disclosure ofpayments to Placement Agents in connection with CalPERS’ investments in orthrough External Managers. This Policy is intended to apply broadly to all of thetypes of investment partners with whom CalPERS does business, including thegeneral partners, managers, investment managers and sponsors of hedge funds,private equity funds, real estate funds and infrastructure funds, as wellinvestment managers retained pursuant to a contract. CalPERS adopts thisPolicy to require broad, timely, and updated disclosure of all Placement Agentrelationships, compensation and fees. The goal of this Policy is to help ensurethat CalPERS investment decisions are made solely on the merits of theinvestment opportunity by individuals who owe a fiduciary duty to CalPERS.
II. STRATEGIC OBJECTIVES
 A. Ensure that CalPERS investment decisions are consistent with TheCalPERS Total Fund Statement of Investment Policy.B. Supplement the pool of information available to CalPERS Board Members,staff and Consultants when evaluating an investment opportunity.C. Prevent impropriety and the appearance of impropriety and providetransparency and confidence in CalPERS investment decision-making.
III. APPLICATION
This Policy applies to all agreements with External Managers that are enteredinto after the date this Policy is adopted. This Policy also applies to existingagreements with External Managers if, after the date this Policy is adopted, the
Copyright © 2009 by CalPERS. Reproduction of any part of this manual is permissible if reproduction contains notice of CalPERS copyright as follows: “Copyright © 2009 by CalPERS”.
 
DISCLOSURE OF PLACEMENT AGENT FEES Page 2 of 6 
term of the agreement is extended, there is any increased commitment of fundsby CalPERS pursuant to the existing agreement or there is an amendment to thesubstantive terms of an existing agreement, including the fees or compensationpayable to the External Manager. Finally, this Policy is intended to apply toagreements with CalPERS Vehicle Managers as set forth in paragraph IV.D.
IV. RESPONSIBILITIES
A. Each External Manager and CalPERS Vehicle Manager is responsible for:1. Providing the following information (collectively, the “PlacementAgent Information Disclosure”) to Staff and, if applicable, to thegeneral partner, managing member, or investment manager of theCalPERS Vehicle (the “CalPERS Vehicle Manager”) at the timeinvestment discussions are initiated by the External Manager or theCalPERS Vehicle Manager:a. A statement whether the External Manager or the CalPERSVehicle Manager, or any of their principals, employees,agents or affiliates has compensated or agreed tocompensate, directly or indirectly, any person (whether ornot employed by the External Manager or the CalPERSVehicle Manager) or entity to act as a Placement Agent inconnection with any investment by CalPERS or a CalPERSVehicle.b. A resume for each officer, partner or principal of thePlacement Agent (and any employee providing similarservices) detailing the person’s education, professionaldesignations, regulatory licenses and investment and workexperience. If any such person is a current or formerCalPERS Board member, employee or Consultant or amember of the immediate family of any such person, this factshall be specifically noted.c. A description of any and all compensation of any kindprovided or agreed to be provided to a Placement Agent,including the nature, timing and value thereof.Compensation to Placement Agents shall includecompensation to third parties as well as employees of theExternal Manager or the CalPERS Vehicle Manager who areretained in order to solicit an investment from CalPERS or aCalPERS Vehicle or who are paid based upon investmentcommitments secured by such employees, except for thosebona fide employees earning less than $100,000 per year insalary that do not receive any incentive compensation based
Copyright © 2009 by CalPERS. Reproduction of any part of this manual is permissible if reproduction contains notice of CalPERS copyright as follows: “Copyright © 2009 by CalPERS”.
 
DISCLOSURE OF PLACEMENT AGENT FEES Page 3 of 6 
entirely on CalPERS or the CalPERS Vehicle’s decision toinvest with the External Manager or, in the case of CalPERS,to invest in the CalPERS Vehicle.d. A description of the services to be performed by thePlacement Agent and a statement as to whether thePlacement Agent is utilized by the External Manager or theCalPERS Vehicle Manager with all prospective clients oronly with a subset of the External Manager’s or the CalPERSVehicle Manager’s prospective clients.e. A copy of any and all agreements between the ExternalManager or the CalPERS Vehicle Manager and thePlacement Agent.f. The names of any current or former CalPERS Boardmembers, employees, or Consultants who suggested theretention of the Placement Agent.g. A statement whether the Placement Agent or any of itsaffiliates are registered with the Securities and ExchangeCommission or the Financial Industry Regulatory Associationor any similar regulatory agent in a country other than theUnited States and the details of such registration orexplanation of why no registration is required.h. A statement whether the Placement Agent, or any of itsaffiliates, is registered as a lobbyist with any state or nationalgovernment.2. Providing an update of any changes to any of the informationincluded in the Placement Agent Information Disclosure within fivebusiness days of the occurrence of the change in information.3. Representing and warranting the accuracy of the informationincluded in the Placement Agent Information Disclosure in any finalwritten agreement with a continuing obligation to update any suchinformation within five business days of any change in theinformation.B. CalPERS Investment Staff (“Staff”) and CalPERS Vehicle Managers areresponsible for all of the following:1. Providing External Managers with a copy of this Policy at the timethat due diligence in connection with a prospective investment orengagement begins.
Copyright © 2009 by CalPERS. Reproduction of any part of this manual is permissible if reproduction contains notice of CalPERS copyright as follows: “Copyright © 2009 by CalPERS”.
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