Governance
Governance across our operations
Corporate governance
Risk management, ethics, and integrity
RI governance across our investments
RI Committee
RI Workgroups
RI team
Our RI policies
Managing conflicts of interest
Introduction | Governance | Responsible investing | People and society | Appendices
Every single day, we work hard to earn—and keep—the trust of our stakeholders. We do this by acting with integrity and prioritizing effective oversight in the markets where we operate.
We've custom designed our governance structures to promote the high level of accountability, transparency, and ethical behavior that our corporate standards and values demand.
Our Board of Directors is the highest governing authority here at StepStone. It has ultimate responsibility for overseeing the strategies and policies that are important for our business, including those that relate to RI. These responsibilities are outlined in the Principles of Corporate Governance of our Board, which we review every year.
Find out more about the members of our Board.
Our Global Head of RI, Suzanne Tavill, keeps the Board notified on the firm's RI performance (including climate change-related updates) as a recurring agenda item.
Alongside the Board, several committees and groups support our corporate objectives, obligations, and commitments to our stakeholders, including those related to RI.
Nominating and Corporate Governance Committee
Identifies individuals qualified to become members of our Board, in line with Board-approved criteria
Oversees the development of corporate governance guidelines and principles (including RI considerations).
Audit Committee
Oversees financial audits and manages the engagement of our outside auditors
Reviews the adequacy of our internal controls over financial reporting and disclosure controls and procedures
Reviews our practices around risk assessment and risk management, including:
- financial statements and financial reporting practices
- compliance
- information technology and cybersecurity.
Compensation Committee
Oversees our overall compensation philosophy, policies, and programs
Makes recommendations to the Board about the compensation of the CEO
Reviews and approves the compensation of other executive officers
Recommends the amount and form of director compensation.
Global Executive Committee
Acts as the consultative body for major StepStone operating decisions
Supports the CEO in the day-to-day management of the firm.
Global Allocation Committee
Oversees portfolio management for the multi-asset-class mandates that we manage or advise.
Portfolio and Risk Management Committees (PRMCs)
Work with our Head of Portfolio Management and Head of Risk
Oversee the portfolio management process for the mandates that we manage
Offer non-binding advice to client account managers of discretionary mandates on portfolio management questions
Each of our private markets asset classes has its own dedicated PRMC.
Enterprise Risk Management Committee
Oversees company-wide risks (including strategic, financial, credit, market, liquidity, security, property, IT, legal, regulatory, reputational)
Develops and enhances means of identifying, measuring, monitoring, and mitigating key risks.
Disclosure Committee
Helps StepStone’s management fulfill their responsibility for oversight of the accuracy and timeliness of the disclosures that we make to our stockholders, including by:
establishing and evaluating the effectiveness of its disclosure controls and procedures
reviewing disclosure reports and public statements.
RI-related policies
RI integration efforts (including stewardship)
advocacy
RI training.
Find out more about the RI Committee.
We set a high bar for ourselves when it comes to considering the evolving nature of regulatory, operational, reputational, and systemic risks—including RI risks. We believe managing risk is a responsibility shared by all our employees, so we’ve built our culture on processes designed to positively influence risk management behavior across the entire firm.
Our Head of Risk and Head of Research and Portfolio Management work together to help optimize our data, systems, and other resources for both our portfolio and risk management needs. The Head of Risk is responsible for identifying, monitoring, and managing the risks relating to client function as it relates to portfolio and investment risk.
To address the nature, scale, and complexity of our business, we have Portfolio Risk Management Committees (PRMCs) for each of our asset classes. The PRMCs oversee our investment strategies for alignment with the risk tolerance and specific requirements of each vehicle.
We look at managing enterprise risk from a firmwide perspective, addressing issues such as business continuity, disaster recovery, oversight of service providers, cybersecurity, and information security.
In the event of a disaster or disruption, our disaster recovery and business continuity plan outlines procedures to maintain critical operations and core business processes:
Our employees can work remotely from any Internet-connected location via secure remote access connections or virtual desktops
We have a work-from-home model if one or more of our offices becomes physically inaccessible due to a disaster or other incident that jeopardizes safety
Our technology infrastructure features built-in redundancy and replication across multiple availability zones to help secure data and maintain operations with minimal downtime.
To make sure our disaster recovery plan is still working as intended, we carry out periodic IT testing, with the most recent exercise taking place in February 2024.
Our Global Compliance Manual applies to our employees worldwide. It sets out our approach to ethics, governance, and compliance, and covers topics including:
fiduciary responsibilities
our Whistleblower Policy (explained on p5 of our Code of Conduct and Ethics
advertising and marketing
electronic communications
anti-money laundering
privacy
information security.
If something’s going wrong within our organization—whether it’s a potential violation of firm policy or improper conduct—we want our employees to let us know.
In our Code of Conduct and Ethics, we encourage our directors, executive officers, and employees to report possible violations of federal securities laws, firm policy, or any other illegal or improper conduct, to, among others:
the Chief Compliance Officer
the Chief Legal Officer
or the Chief Human Resources Officer.
And if they prefer to remain anonymous, directors, executive officers, and employees are also free to report their concerns in confidence to our whistleblower hotline—available anytime.
Find out more here
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Delivered annually, our mandatory firmwide compliance training includes:
a review of our compliance policies and procedures
an overview of material changes to regulations affecting private markets asset managers and advisers globally.
Our compliance training concludes with an attestation and formal knowledge check, which our employees must pass to complete their training.
In addition, they must complete training relating to their obligations as employees of a publicly held company. We also run ad hoc training for various audiences within the firm on a range of compliance matters.
As technology and cybersecurity threats increase in number and sophistication, we're firmly focused on protecting the security and integrity of our information systems.
Our Head of IT is responsible for regularly assessing our cybersecurity protocols and addressing potential risks, supported by our Legal, Compliance, and Risk functions. Our IT team works with leading third-party cybersecurity providers to:
stay up to speed with global standards for data privacy and security
monitor our systems in real time
carry out external and internal penetration testing and employee social engineering assessments
address risks presented by new hardware or software changes.
Our Information Security Policy and Data Privacy Policy set out the processes and procedures we to protect our data, as well as that of our clients.
We also maintain an Incident Response Plan that establishes protocols to be followed in the event of an information security or cybersecurity incident.
We’re dedicated to investing in employee training and education to help promote awareness of and compliance with our policies, as well as identifying potential threats and responding appropriately.
As part of our onboarding process, we train our employees on cybersecurity best practices and our security policies and procedures. In addition, we hold regular training sessions on information security to help maintain a culture of cyber awareness and vigilance.
Discover how we approach Managing cybersecurity risk within our investments.
As technology evolves, so do the security risks we must be prepared to face. AI offers incredible promise, but also brings new challenges for organizations and security professionals. That's why we're dedicated to staying ahead of the curve and taking a robust approach to tackling a broad threat landscape and protecting the integrity of our systems."
We’ve designed our governance structure to foster the high standards of leadership and acountability needed to drive effective RI integration and stewardship activities across our organization and our investment process:
When it comes to managing our RI activities and corporate sustainability, our RI Committee leads the charge.
Bringing together senior members across our global offices, the Committee is supported by representatives from our asset class investment teams and from RI and Legal to Technology and Compliance in its effort to improve RI and corporate sustainability and ensure effective implementation of RI across the firm.
The RI Committee is chaired by Suzanne Tavill, Partner and Global Head of RI, and is responsible for:
approving StepStone’s RI-related policies
overseeing the effective functioning of the RI governance structure throughout StepStone to support the implementation of relevant processes and training, including introducing new initiatives to incorporate RI and stewardship into our investment process
approving RI due diligence on investments following review by dedicated RI Workgroups.
Suzanne Tavill
Partner, Global Head of RI, RI Committee Chair Sydney
Simon Beer
Partner, Infrastructure & Real AssetsLondon/Toronto
Jason Ment
President & Co-Chief Operating Officer, Operations New York
Jennifer Ishiguro
Partner, Chief Legal Officer & Secretary, Legal & ComplianceLa Jolla
Christian Frei
Head of Risk, Partner, Private DebtZurich
Emma Love
Chief Compliance Officer, SGEAIL, OperationsDublin
Brendan MacDonald
Partner, Chief Operating Officer, Real EstateSan Francisco
Dawn Powell
Principal, Venture Capital & Growth EquityNew York
Bhavika Vyas
Managing Director, Private Equity New York
Tyler Johnson
Partner, Chief Technology Officer, OperationsLa Jolla
Peter Dunbar
Principal, RILondon
Our RI efforts are supported by five dedicated RI Workgroups—one for each asset class and one for corporate-level initiatives. Led by asset-class specialists in partnership with the RI team, and overseen by the Global Head of RI, these Workgroups play a crucial role in integrating relevant RI practices across our investment and corporate activities.
Members of the asset-class workgroups actively review and challenge RI due diligence and monitor and drive best practices throughout our investment activities.
They work closely with our investment teams, giving them with the tools they need to conduct robust RI due diligence, drive engagement with GPs and assets, and ensure that RI standards are implemented consistently across our organization.
The Corporate RI Workgroup spearheads firmwide corporate initiatives to drive sustainability, including carbon footprinting and vendor due diligence.
Corporate
Private Equity
Infrastructure and Real Assets
20
24
12
Private Debt
Real Estate
18
8
Reflecting our commitment to RI, we’ve established a dedicated RI team comprising six full-time members, as of December 31, 2024, and led by Suzanne Tavill.
The team’s collective experience within private markets gives us a deep understanding of StepStone’s business, enabling us to embed material RI and stewardship considerations to help protect and enhance the value of investments.
Operating globally, the team also contributes to several firm-level sustainability initiatives, including:
advocating for carbon footprint measuring within our supply chain
monitoring vendor practices, including modern slavery considerations
overseeing our efforts to maintain carbon neutrality in our operations.
Learn more about the background and experience of our RI team members in the Appendices.
To enhance the RI expertise of our investment professionals, members of our RI team and RI Workgroups deliver regular training that can be tailored by asset class, jurisdiction, and strategy on topics including:
RI governance
RI due diligence integration for primaries, secondaries, and co-investments
specialized impact due diligence
stewardship and engagement
RI reporting
regulatory considerations and product design
specific RI topics including nature, climate change, and responsible AI.
Launched in February 2024, our monthly RI newsletter is designed to keep our internal stakeholders up to speed with the rapidly evolving world of RI. It incorporates features such as:
review of media coverage of RI-related themes
rundown of the latest developments in RI regulation, policy, and legislation
roundup of recent industry events and academic studies
internal updates, including team news, achievements, and milestones
breakdown of our team’s contribution to thought leadership and participation in speaking events on key RI issues.
We’re delighted to report that Suzanne Tavill, Partner and Global Head of RI, was named in the PEI Group’s Women of Influence in Private Markets list for 2024. The list recognizes the contribution of 42 women who are helping to shape the fast-changing alternatives landscape.
Separately, Suzanne was also featured in Venture Capital Journal’s 10 Women Making an Impact in VC list.
stewardshipUK/ˈstjuː.əd.ʃɪp/ US/ˈstuː.ɚd.ʃɪp/
Stewardship is a key part of our job—and one that we take very seriously. At StepStone, we strongly believe that effective stewardship activities have an important role to play in private markets.
As responsible stewards of our clients’ capital, we have a fiduciary duty to not only create economic value for our clients today, but also to allocate, manage, and oversee the capital we deploy in a way that fosters sustainable value for our clients in the long term.
We apply our RI Policy, Stewardship Policy, and Climate Policy globally across asset classes and investment strategies. These policies play a crucial role in upholding our values and driving responsible practices across StepStone.
To keep pace with changing market conditions and the continued expansion of our business, we need our policies to stay dynamic too.
To achieve this, our RI Committee ensures that we adhere to these policies across the firm and reviews them annually to check they are still effective. We also address emerging regulatory and industry developments as they happen, enabling us to effectively navigate the evolving environment.
To align with our clients’ stewardship and investment policies, we maintain close collaboration and communication with them to deliver services that meet their needs and solutions that align with their commitments.
For commingled funds, our approach to stewardship is consistent with our own RI Policy, Stewardship Policy, and Climate Policy, which we designed to accommodate a broad spectrum of client needs.
These policies act as a framework that incorporates relevant RI considerations and practices across our investment process and are aligned with industry-recognized standards.
1. As of December 31, 2024.
Adopted: March 2014 Last updated: April 2025
Outlines our dedication to integrating material RI considerations into every step of our investment process and our corporate sustainability efforts within our internal operations.
Adopted: October 2022Last updated: April 2025
Explains our approach to practicing effective stewardship and engagement both within our investments and the broader private markets industry.
Sets out our approach to integrating material climate change-related considerations across our investment process and internal operations.
Since StepStone was founded, we’ve invested significant time and resource in building a global private markets platform. At the heart of this sits SPI by StepStone, our proprietary suite of integrated data and technology solutions. These include SPI Research, our private markets intelligence database, and SPI Reporting, our performance monitoring software. Our RI efforts are embedded in both systems.
In addition, StepStone Infrastructure and Real Assets is implementing AXA Altitude—a Software-as-a-Service (SaaS) solution that provides data-driven, location-based assessments of climate change and nature risk—for all its co-investments. The insights provided by this tool will complement the due diligence conducted both by the SIRA team and GPs. For more on AXA Altitude, click here.
dedicated data and software engineering experts1
Management and continued development of SPI Research, SPI Reporting, and our additional proprietary tools built on the SPI by StepStone platform.
1 As of December 31, 2024.
portfolio analytics and reporting experts1
Customized portfolio analytics and reporting on the performance of our clients' investments, including RI- and stewardship-related reporting for relevant clients.
SPI Research is our proprietary private markets research library and a powerful decision-making tool for our investment professionals and clients. It opens up access to detailed research on the funds StepStone covers, including:
fund summaries
investment memos
track-record analysis
benchmarks
RI due diligence and scorecard
RI metrics
impact metrics.
Custom-designed for the private markets, our SPI Reporting platform gives clients enhanced transparency and insights into their portfolios. detailed analytics, including:
It provides real-time access, empowers clients to analyze and benchmark performance, and generates:
J-curve and cash flow analysis
time-period analysis (e.g., internal rate of return, time-weighted returns)
private markets equivalent (PME) analysis
RI and stewardship-related metrics post-investment.
Highlights1
18K+ GPs
48K+ funds
241K+ investments
5,300+ meeting notes LTM.
24K+ investor commitments
$1T+ investor commitments.
Example use case: Endowment
Clients can leverage SPI Research to scale their teams more effectively and cover the market more efficiently.
Example use case: Pension plan
Clients can use SPI Reporting to track exposures and performance at the GP, fund, and asset level, including RI-related data to inform stewardship practices.
1 Data as of December, 31 2024.
We have a fiduciary responsibility to act in the best interests of our clients, and this includes making full and fair disclosure of conflicts of interest whenever they happen.
Managing conflicts of interest is a crucial part of our Compliance program and is underpinned by the following processes:
Our Chief Compliance Officer, Chief Legal Officer, and their teams help identify and manage potential conflicts
StepStone employees must undergo compliance training when they join the firm and on an annual basis thereafter
Employees must follow processes set out in our Code of Conduct and Ethics, Global Compliance Manual, and Insider Trading Policy
We’ve established procedures to report and manage potential misconduct
We disallow political contributions
We have an investment allocation policy designed to mitigate conflicts of interest in serving our clients.
Our Board has adopted a Code of Conduct and Ethics to promote compliance with applicable laws and ethical conduct. This helps us provide appropriate disclosure levels as a public company and mechanisms to report unethical conduct to foster a culture of honesty and accountability.
The Code specifically deals with issues relating to conflicts of interest, including:
use of corporate funds and assets
loans or guarantees by the firm of obligations of employees or their family members
confidential information
investment allocation
personal financial gain.
Reinforcing this, our Global Compliance Manual and Code of Ethics deal with conflicts of interest, covering:
identification of conflicts
management of conflicts
allocation of investment opportunities
prohibition on recommending outpooled investment products to our advisory clients
appropriate supervision
additional safeguards to reduce potential conflicts of interest.
When it comes to conflicts of interest, we take our responsibilities extremely seriously. Our framework helps us to identify and manage potential conflicts as effectively as possible, with our Legal and Compliance team reviewing proposed client mandates before we enter into them.
Once we identify a potential conflict, we start by weighing up our own ability to manage the conflict appropriately—liaising with the client relationship lead and relevant partners within the firm.
If we determine that we can move forward with the mandate while appropriately managing the potential conflict, we’ll put in place protocols to ensure that each client receives independent and objective advice. If, on the other hand, we determine that we cannot effectively manage the conflict without the consent of the affected clients, we’ll seek their consent before pursuing the opportunity any further.
We identify and manage potential conflicts of interest ourselves, including any conflicts that relate to stewardship. If we find a material conflict of interest, our CCO is tasked with deciding on the appropriate course of action. We also keep a record of how the conflict of interest is resolved.
monitoring corporate actions
receiving and voting client proxies
disclosing potential conflicts of interest.
In line with our policy and fiduciary duty to our discretionary clients, we vote proxies for portfolio securities (where we are responsible for doing so) in a way that we believe aligns with their best economic interests. In general, we have no legal authority to vote proxies on behalf of advisory clients.
Proxy voting
As private market investors, proxy voting does not form a key part of our stewardship activities, which mostly take place when companies are still private.
Instead, we focus on exercising our rights to vote on any actual or potential conflicts of interest through:
our positions on Limited Partner Advisory Committees (LPACs)
board seats
engagement with GPs and assets.
In certain circumstances, we may use ethical dividers to manage the confidentiality of client information in connection with a potential conflict of interest, as follows:
We will establish ethical dividers for each client team affected by the potential conflict of interest and inform them of the need to maintain confidentiality with regard to their specific mandate
Each of the parties is serviced by a different mandate lead
Supporting professional staff deal only with one of the parties concerned
Partners and staff are briefed independently and are instructed not to discuss confidential matters with anyone outside their specific project team
All hard- and soft-copy information relating to each engagement is maintained securely to make sure no members of the potentially conflicted mandate teams can access the other’s information.
We manage a variety of account types with different strategies and scopes of services. When the amount of an investment opportunity is limited, our decision on allocating the opportunity carries inherent conflicts. To help mitigate these conflicts, we’ve adopted an Allocation Policy.
We don’t recommend any StepStone pooled investment products to our advisory clients. Clients that are interested in investing in this type of product are responsible for making the decision to invest—either on their own or in conjunction with advisers or consultants that are not affiliated to StepStone.
So how do we handle conflicts of interest when they happen? The table below sets out examples of action we may take in certain scenarios:
Scenario 1
We, or any of our supervised persons, have a financial, business or personal relationship with an issuer.
If we identify a material conflict of interest, the Chief Compliance Officer will determine appropriate disclosures to the affected parties, and determine next steps. These may include:
supervised person recusing themselves
the client voting proxies themselves, or
addressing the voting issue through other objective means, such as voting in a way that aligns with a predetermined voting policy.
Scenario 2
We’re involved in a transaction where a client is selling interests on the secondary market, and the buyer is another StepStone entity.
In a situation like this, we would:
notify the Advisory Board of the vehicle involved in that transaction
confirm with the seller that it approves of StepStone as the buyer
seek written confirmation from the seller that StepStone is not advising
not be involved in a seller’s formal decision-making process for this type of transaction
take steps to avoid any conflicts, including using a third party to determine the price or other key terms of the sale.
Scenario 3
Multiple StepStone investment teams hold the same issuer across multiple asset classes and/or the capital stack.
Our Allocation Policy is designed to address the acquisition and sale of the same investment held across multiple clients. Where multiple asset classes may invest in the same issuer across the capital stack, appropriate ethical walls would be created and our capital stack guidelines followed.
Scenario 4
We invest a client’s funds into a StepStone vehicle if the client asks us to do so, or if we determine in conjunction with the client that the investment is in their best interests.
In line with our guidelines, we would seek signoff from the investing client, acknowledging its decision to invest into the StepStone vehicle. This type of investment would also be reviewed by the Legal and Compliance teams, as well as by the relevant Portfolio and Risk Management Committee, which would vote on approval.
