Private company
KKR Credit Advisors (US) LLC
Last updated Oct 21, 2026.
Overview
Corporate structure
KKR Credit Advisors (US) LLC is part of a group headed by KKR Group Partnership L.P.. 5 entities, 1 country on record. Switch between the flow chart and the network, and select any entity to see its details.
Major holders of KKR Credit Advisors (US) LLC
- Kkr & Co. Gp LLC Owns control (general partner, trustee or manager) of Kohlberg, since 01/2020 (Form ADV)
- Kkr Holdco LLC Owns 75% or more of Kkr & Co. Gp, since 01/2020 (Form ADV)
- Kkr Group Co. Inc. Owns 75% or more of Kkr Group, since 12/2017 (Form ADV)
- Kkr Group Holdings L.P. Owns 25% to 50% of Kkr Group, since 01/2020 (Form ADV)
- KKR & Co. Inc. Owns 75% or more of Kkr Group Co., since 05/2022 (Form ADV)
- KKR Group Partnership L.P. New York, New York, United States
- Kohlberg Kravis Roberts & Co. L.P.
- KKR Credit Advisors (US) LLC
- Dave & Buster's Stake · Coppell, Texas, United States
- FS KKR Capital Corp Stake · Philadelphia, Pennsylvania, United States
- KKR Credit Advisors (US) LLC
- Kohlberg Kravis Roberts & Co. L.P.
Built from parent and subsidiary links from GLEIF, the Global Legal Entity Identifier Foundation (CC0); stakes of 5% or more it reported on Schedules 13D and 13G (2 companies); owners and owned firms from Form ADV, the registration investment advisers file with the SEC. Each entity in the chart links to its source.
Investment adviser
KKR Credit Advisors (US) LLC is registered with the SEC as an investment adviser. This is what it reports on Form ADV, the registration every adviser files and keeps current.
- Assets it manages$270.9B2 204 accounts, all with discretion
- Employees609 181 in investment advice or research
- ClientsInsurance companies: 21 ($171.4B); Pooled investment vehicles (other than investment companies and: 167 ($93.2B); Pension and profit sharing plans (but not the plan participants or: 6 ($3.5B); Investment companies: 5 ($1.9B); State or municipal government entities (including government pension: 5 ($984.7M)
- How it is paidA percentage of assets under its management; Performance-based fees; Other: MANAGEMENT FEES
- What it doesPortfolio management for investment companies; Portfolio management for pooled investment vehicles (other than investment companies); Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investment vehicles); Publication of periodicals or newsletters
- Holds client assetsYes: cash and securities
- RegistrationSEC 801-69633, CRD 146629 IAPD record
Who owns it
Owners of 5% or more as the firm lists them (Schedule A), and the owners of those owners up the chain (Schedule B).
- KOHLBERG KRAVIS ROBERTS & CO. (public company)owns 75% or more, since 06/2004
- KKR & CO. GP LLCowns general partner, trustee or manager of KOHLBERG, since 01/2020
- KKR GROUP HOLDINGS CORP.owns general partner, trustee or manager of KKR GROUP, since 05/2022
- KKR & CO. INC. (public company)owns 75% or more of KKR GROUP CO., since 05/2022
- KKR GROUP CO. INC.owns 75% or more of KKR GROUP, since 12/2017
- KKR GROUP PARTNERSHIP L.P.owns 75% or more of KKR GROUP CO., since 01/2020
- KKR GROUP PARTNERSHIP L.P.owns 75% or more of KKR HOLDCO, since 01/2020
- KKR HOLDCO LLCowns 75% or more of KKR & CO. GP, since 01/2020
- KKR GROUP HOLDINGS L.P.owns 25% to 50% of KKR GROUP, since 01/2020
Disciplinary record
The firm answered yes to 7 of the disciplinary questions on Form ADV (Item 11). A yes can concern the firm itself or an affiliate.
- The SEC or the CFTC has found the firm or an advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes.
- The SEC or the CFTC has entered an order against the firm or an advisory affiliate in connection with investment-related activity.
- The SEC or the CFTC has imposed a civil money penalty on the firm or an advisory affiliate, or ordered the firm or an advisory affiliate to cease and desist from any activity.
- Any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority has found the firm or an advisory affiliate to have been involved in a violation of investment-related regulations or statutes.
- In the past ten years, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority has entered an order against the firm or an advisory affiliate in connection with an investment-related activity.
- Any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority has denied, suspended, or revoked the firm's or an advisory affiliate's registration or license, or otherwise prevented the firm or an advisory affiliate, by order, from associating with an investment-related business or restricted the firm's or an advisory affiliate's activity.
- Any self-regulatory organization or commodities exchange has found the firm or an advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approved by the SEC).
The 1 record concern KOHLBERG KRAVIS ROBERTS & (1), which reports the details on its own Form ADV.
In its own words: the client brochure
Form ADV Part 2A, the plain-English document an adviser must give its clients, quoted as filed 9/25/2026.3 It covers the firm’s services, fees, investment strategies and their risks, and its conflicts of interest.
Item 4: Advisory business Services
Overview of the Advisers’ Businesses This brochure details the advisory businesses of KKR Credit (as defined below), and in particular, KKR Credit Advisors US LLC (“KKR Credit U.S.”), and KKR Credit Advisors (Singapore) Pte. Ltd. (“KKR Credit Singapore,” and together with KKR Credit U.S., the “Advisers”). KKR Credit U.S. KKR Credit U.S. is a Delaware limited liability company founded in August 2004 and registered as an investment adviser with the U.S. Securities and Exchange Commission (the “SEC”). KKR Credit U.S. has approximately $270.8 1 billion in assets under management as of December 31, 2025, managed on a discretionary basis. 2 KKR Credit U.S. advises pooled investment vehicles, dedicated separately managed account vehicles, collateralized loan obligation vehicles (“CLOs”), closed-end investment companies registered under the U.S. Investment Company Act of 1940, as amended (the “Investment Company Act”) (the “RICs”), discretionary accounts established for third-party institutional investors, including pension plans, a closed-end management investment company that operates as an interval fund and side-by-side vehicles investing alongside other KKR Credit Funds and Other Clients (as defined below). KKR Credit also provides sub-advisory services to certain investment funds and investment vehicles established and managed by Kohlberg Kravis Roberts & Co. L.P. and its affiliates (“KKR”), including non-U.S. listed and unlisted investment trusts that have investment exposure to funds and investments managed by KKR and its affiliates. Additionally, KKR Credit U.S. provides sub-advisory services to certain non-diversified closed-end management investment companies registered under the Investment Company Act of 1940 that operate as interval funds and are managed by an unaffiliated third-party investment adviser. KKR Credit U.S.’s alternative credit platform consists of private credit strategies, including asset-based finance, which focuses on multi-sector investments secured by portfolios of financial assets, and corporate credit, historically referred to as direct lending, the scope of which has expanded alongside market evolution into corporate private credit. KKR Credit U.S.’s alternative credit platform also includes a Strategic Investments Group, which provides partnership capital solutions to high quality mid-to-large cap companies, typically in situations requiring customized financing or strategic capital support. KKR Credit Singapore KKR Credit Singapore is a Singapore private limited company incorporated in February 2020 and is licensed by the Monetary Authority of Singapore (the “MAS”). KKR Credit Singapore is also registered as a non-investing Category I Foreign Portfolio Investor with the Securities and Exchange Board of India. KKR Credit Singapore has approximately $4.9 3 billion in assets under management as of December 31, 2025, managed on a discretionary basis. 4 KKR Credit Singapore advises pooled investment vehicles, dedicated separately managed account vehicles, discretionary accounts established for third-party Represents KKR Credit U.S.’s most recently published AUM as disclosed in Part 1. AUM calculations could differ from those used in other regulatory filings by KKR Credit U.S. in accordance with applicable requirements and guidelines. KKR Credit U.S. does not manage client assets on a non-discretionary basis as of December 31, 2025, although certain clients have consent or opt-out rights with respect to certain investments. Represents KKR Credit Singapore’s most recently published AUM as disclosed in Part 1. AUM calculations could differ from those used in other regulatory filings by KKR Credit Singapore in accordance with applicable requirements and guidelines. KKR Credit Singapore does not manage client assets on a non-discretionary basis as of December 31, 2025, although certain clients have consent or opt-out rights with respect to certain investments.
institutional investors including pension plans, and side-by-side vehicles investing alongside other KKR Credit Singapore Funds and Other Clients. KKR Credit Singapore’s investment management and advisory activities focus on private credit opportunities, including but not limited to senior and unitranche corporate lending, subordinated corporate lending (mezzanine and other subordinated debt investments), asset-based finance investments, and liquid credit investment opportunities through investment in a diversified portfolio of financial instruments throughout the Asia-Pacific credit markets. Overview of KKR Credit’s Business The use of the term “KKR Credit” throughout this brochure refers broadly to KKR’s credit advisory business made up of management entities that are controlled by KKR and its affiliates (the “KKR Credit Managers”) 5 pursuing a credit strategy, their participating affiliate and relying advisers, and the affiliated entities listed in Item 10. KKR Credit’s investment management and advisory activities focus on U.S. and European leveraged credit strategies, such as leveraged loans, high yield bonds, opportunistic credit and revolving credit strategies, structured credit and U.S., European and Asian alternative credit strategies, including special situations, strategic investments and private credit strategies, such as direct lending and private opportunistic credit (or mezzanine) investment strategies (including investments in mezzanine and mezzanine-like instruments, structured and illiquid credit, and direct senior loan origination), specific types of syndicated credit investments (i.e., investments in revolver credit facilities, special situations investments and credit investments relating to other assets held by funds and other investment vehicles and accounts advised by KKR, including private equity and real assets, such as infrastructure, energy and real estate. KKR Credit is affiliated with KKR Alternative Investment Management Unlimited Company (“KKR AIM”), which is authorized as an alternative investment fund manager under the European Union (Alternative Investment Fund Managers) Regulations 2013 (S.I. No. 257 of 2013), and regulated by the CBI, . KKR AIM separately files reports as an exempt reporting adviser with the SEC. KKR AIM enters into delegation and/or sub-advisory agreements with KKR Credit under which KKR Credit will provide certain portfolio management services to KKR AIM in connection with investment funds with respect to which KKR AIM serves as alternative investment fund manager for the purposes of Directive 2011/61/EU of the European Parliament and of the Council of 8 June 2011 on Alternative Investment Fund Managers (“AIFMD”). The Advisers are also affiliated with KKR Registered Advisor LLC (“KRA”), an investment adviser that is separately registered with the SEC. KRA advises KKR Real Estate Select Trust Inc. (“KREST”), a closed-end management investment company registered under the Investment Company Act, which will invest primarily in stabilized, income-oriented commercial real estate, prime single tenant equity investments and real estate debt investments. KKR Credit Advisors (US) owns a 50% interest, alongside an affiliate of Franklin Square Holdings, L.P. (“FS Investments”) who owns the other 50% interest, in FS/KKR Advisor, LLC, an investment adviser registered with the SEC. FS/KKR Advisor, LLC provides investment advisory services to FS KKR Capital Corp., a business development company (“BDC”) registered under the Investment Company Act and listed on the New York Stock Exchange (“NYSE”), KKR FS Income Trust, a privately-placed BDC, and KKR FS Income Trust Select, also a privately-placed BDC. Kohlberg Kravis Roberts & Co. L.P.
The term “KKR Credit Managers” includes the Advisers and wholly owned and controlled management entities established with respect to one or more Clients for operational and other purposes.
The Advisers are affiliated with KKR & Co. Inc. (formerly KKR & Co. L.P.) (“KKR & Co.” or “KKR” the “KKR Public Company”) which, through its subsidiaries, acquires stakes in, or seeds, or otherwise holds interests in third-party hedge funds and fund of fund managers (the “Stakes and Seed Managers”). KKR Credit is affiliated with KKR and its subsidiaries, which operate under the name “KKR”. KKR advises and sub-advises private equity funds and other investment vehicles, including proprietary entities that invest capital for long-term appreciation, by acquiring controlling or minority positions in portfolio companies, and other assets. Such funds also make investments in publicly traded equity and debt securities and other marketable securities and instruments (collectively with any investments in derivative instruments, “Marketable Securities”). In addition, to its traditional private equity strategy, KKR advises funds and other investment vehicles focused on infrastructure, energy and real estate, which invest capital primarily through acquiring interests in companies or acquiring underlying assets. KKR also advises investment funds and other investment vehicles that make growth capital and core investments. KKR also advises vehicles that make real estate debt investments, including real estate investment trusts (“REITs”). KKR also offers and sponsors funds and other investment vehicles that make co-investments alongside KKR proprietary investments or in specific or multiple portfolio companies and other assets invested in by investment funds advised by KKR and its affiliates, a customized platform that invests in funds advised by KKR and its affiliates and funds sponsored and managed by unaffiliated investment managers (collectively, “third party funds”) and related co-investments, and strategic partnership vehicles or other multi-strategy or multi-asset arrangements that invest across multiple funds and investment strategies advised by KKR and its affiliates several publicly listed vehicles that are publicly traded on a stock exchange or are otherwise made available for investment by public investors, including a publicly listed energy company. KKR’s Global Institute (“KGI”) periodically publishes papers, highlighting views from KKR’s portfolio companies and portfolio managers and political, economic and social trends. KKR’s Global Macro and Asset Allocation Group also periodically publishes commentary on macro-economic trends and related topics through KGI and oversees a proprietary portfolio of investments in a variety of instruments and securities. KKR & Co. owns The Global Atlantic Financial Group LLC (together with its subsidiaries, “Global Atlantic”). KKR Credit U.S. and KKR Credit Singapore provide investment management services to Global Atlantic Accounts through a sub-advisory agreement with KKR. Global Atlantic is a retirement and life insurance company with an over 20-year track record of providing a broad suite of protection, legacy, and products to customers and across individual and institutional markets. In 2024, KKR & Co. completed the acquisition of the remaining interests in Global Atlantic that KKR did not own. KKR (including through KKR Credit) serves as Global Atlantic’s investment manager for certain assets. Based on preliminary financial results of Global Atlantic, the estimated value of Global Atlantic assets managed by KKR as of December 31, 2025, was approximately $49.1 billion. For additional information regarding KKR’s clients, including the definitions of “KKR Credit Advisors Funds” and “Other Clients,” please see Item 7 – “Types of Clients”. Additional information regarding the Advisers’ “relying advisers” which are investment advisory affiliates that rely on the Advisers, as their filing adviser, to file (and amend) a single umbrella SEC registration on their behalf, and other advisory affiliates that are separately registered with the SEC, is provided in Item 10 – “Other Financial Industry Activities and Affiliations.” KKR Credit also has an affiliated capital markets business operated through affiliated broker-dealers. Please see Item 10 – Other Financial Industry Activities and Affiliations for additional information regarding KKR’s affiliated broker dealers.
Item 5: Fees and compensation Fees
General Each Adviser (including, where applicable, KKR Credit GPs) generally receives management fees, carried interest allocations and/or performance fees in connection with the investment management and administrative services that it provides to Clients. Certain co-investment vehicles and Manager Coinvestment Vehicles (as defined in Item 6 – Performance-Based Fees and Side By Side Management), as discussed in Item 6, are not subject to such fees and/or carried interest allocations. The allocation of a portion of the profits of a KKR Credit Fund, whether allocated to the capital account of a KKR Credit GP or distributed to a KKR Credit GP is referred to herein as “carried interest.” Management fees, carried interest, performance fees and other compensation payable to KKR Credit (including KKR Credit GPs) by KKR Credit Funds or Other Clients together with other terms governing the management of KKR Credit Funds or Other Clients by KKR Credit, are established by KKR Credit at the time of the establishment of the relevant KKR Credit Funds (and negotiated with participating investors prior to their investment) or at the beginning of the advisory relationship with the relevant Other Clients,
as applicable. Specific details of such compensation and its method of calculation are set out in the offering materials, disclosure documents, advisory agreements, investment management agreements and/or governing documents of the relevant KKR Credit Funds or Other Clients and vary among KKR Credit Funds or Other Clients. Fee terms of KKR Credit Funds or Other Clients will not generally be changed during the term of the relevant relationship. The share of compensation earned by KKR Credit or its affiliates in respect of a KKR Credit Fund or Other Client varies among investors in such KKR Credit Fund pursuant to the terms of the governing documents, side letter agreements or other arrangements with specific investors in such KKR Credit Fund whereby such investors receive direct or indirect reductions of management fees or other compensation otherwise payable with respect to their investments managed by KKR Credit. For example, each of KKR Credit, and KKR has entered into, and intends in the future to enter into, strategic partnerships or other multi-strategy or multi-asset class arrangements with investors that commit capital to a range of KKR Credit’s, and KKR’s platform of products, investment ideas and asset classes. Such arrangements generally (subject to applicable terms) include KKR Credit or KKR granting certain preferential terms to such investors, including blended fee and carried interest rates that are lower than those applicable to other investors in a particular KKR Credit Fund and/or investment fund managed by KKR, as applicable, when applied to the entire strategic partnership. Where a strategic investor participates in a KKR Credit Fund, investment fund managed by KKR through a dedicated investment vehicle or account as part of such arrangement, such investment vehicle or account will generally (subject to applicable terms) be granted terms, including management fees or carried interest, that are more favorable than those applicable to other investors. In cases where a strategic investor’s management fees and carried interest are due at the level of such vehicle and account, such terms will generally (subject to applicable terms) include a waiver of management fees and carried interest on such strategic investor’s investment in KKR Credit Funds, investment funds managed by KKR. In addition, where a strategic partner enters into such an arrangement with KKR Credit or KKR, other investors in KKR Credit Funds will not be notified of or receive documentation of such an arrangement. Please see Item 11 – Other Conflicts of Interest for further information regarding strategic partnerships. In addition, KKR Credit enters and is expected in the future to enter into arrangements with one or more third-party sponsors to establish conduit investment vehicles and other dedicated feeder vehicles to facilitate the indirect participation in a KKR Credit Fund by certain “high net worth” investors and other qualified Clients of such sponsor (each a “Dedicated Feeder”). Such third parties are expected to also solicit a direct investment in a KKR Credit Fund by certain of its Clients in consideration of the payment of a placement fee from KKR Credit or such KKR Credit Fund (each, a “Placed Investor”). In connection with the admission of any Dedicated Feeder to a KKR Credit Fund, the applicable KKR Credit GP will determine, in its discretion, whether to aggregate the indirect capital commitments of the investors in such Dedicated Feeder, including, without limitation, for purposes of calculating any reductions in management fees to which such Dedicated Feeder is entitled. In connection with the foregoing, there have been circumstances in which reductions, if any, are provided on an aggregated basis with respect to some, but not all, Dedicated Feeders, which would have the effect of establishing more favorable economic terms with respect to such Dedicated Feeders as compared to those applicable to other comparably sized Dedicated Feeders. Further, reductions in management fees generally do not apply to Placed Investors, but will be granted to Placed Investors at KKR Credit’s sole discretion. KKR Credit does not control the economic terms of such Dedicated Feeders, which are established independently by the relevant third parties and their underlying investors. In certain circumstances, such terms require third parties to use such payments in whole or in part to offset incremental fees and expenses applicable at the level of the relevant Dedicated Feeders or to otherwise pass on such fees and expenses to the benefit of the Dedicated Feeders and their investors. Management Fees
Management fees compensate KKR Credit generally for the various services KKR Credit’s business professionals provide in managing KKR Credit Funds or Other Clients. Typically, KKR Credit U.S. charges management fees at an annual rate of between 0.15% and 1.75% for most KKR Credit Funds or Other Clients. However, KKR Credit Singapore generally charges management fees at an annual rate of between 0.40% and 1.50%, depending on the strategy of the relevant KKR Credit Singapore Fund or Other Client, the amount of assets under management, and the point in time in the life cycle of the account. Management fees may be based on capital committed, net asset value, net invested capital, gross managed assets, aggregate collateral balance, or collateral pledged by the relevant client. For example, for certain KKR Credit Funds, investors in the same fund pay different management fees based on whether they invested in an early or later round of fundraising and the amount of their investment or the amount invested by investors with the same discretionary manager or consultant, with earlier or larger investors (or groups of investors) potentially paying lower management fees than other investors. Management fees may be paid monthly or quarterly in advance or arrears, depending on the KKR Credit Fund or Other Client. KKR Credit will, from time to time, accrue management fees for a given payment period but defer collecting such fees until a later payment period primarily for administrative purposes. KKR Credit generally does not charge interest on such deferred management fees. The KKR Credit GPs generally make capital calls on investors in KKR Credit Funds for the amount of management fees payable by the KKR Credit Funds to KKR Credit and then cause the KKR Credit Funds to pay the amounts received from the investors to KKR Credit, consistent with the governing documents of the KKR Credit Funds. KKR Credit generally invoices Other Clients for management fees. In some cases, management fees due to KKR Credit are deducted from proceeds otherwise distributable to investors in a KKR Credit Fund or Other Client or paid out of the assets of such KKR Credit Fund or Other Client, consistent with the governing documents of such KKR Credit Fund or Other Client. If a KKR Credit Fund obtains a subscription facility, management fees due from a KKR Credit Fund may also be paid by drawdowns by KKR Credit (or relevant KKR Credit GP) under such KKR Credit Fund’s subscription credit facility (which drawdowns are subsequently repaid through capital calls or investment proceeds) if consistent with the governing documents of such KKR Credit Fund or Other Client. For some KKR Credit Funds or Other Clients where management fees are paid in advance with respect to a KKR Credit Fund or Other Client, the terms applicable to the relevant KKR Credit Fund typically do not contemplate repayments of fees to the extent that KKR Credit’s services terminate (or an investor withdraws or redeems its interests in such KKR Credit Fund or Other Client) prior to the end of the relevant payment period. Where management fees are based on committed capital or the remaining invested capital of a KKR Credit Fund, the management fee payable by such KKR Credit Fund will be due to KKR Credit even if the fair value of the relevant remaining investments is below cost or even zero. When calculating the amount of remaining invested capital of a KKR Credit Fund or Other Client, KKR Credit includes any capital contributions used to pay fees or expenses of or relating to a portfolio company, including transaction, acquisition, or other fees paid to KKR Credit or an affiliated or related person thereof. In addition, unless otherwise provided in the applicable governing documents or management agreements of the KKR Credit Funds or Other Clients, or otherwise elected by KKR Credit, partial dispositions, write-downs, write-offs (except to the extent the KKR Credit Fund or Other Client has claimed a worthless securities deduction under section 165(g) of the U.S. Internal Revenue Code of 1986, as amended from time to time), reorganizations, dividend payments or recapitalizations, including dividend recapitalizations, refinancings or other similar transactions of portfolio investments in some situations do not reduce the remaining invested capital for purposes of calculating the management fees under the governing documents of the KKR Credit Funds or Other Clients. These practices involve a conflict of interest and, in certain instances, can result in the management fee base – and thus the management fee – not being decreased when a client or investor could otherwise expect it to be decreased.
Item 8: Methods of analysis, investment strategies and risk of loss Investment strategies and risks
Investment Strategies and Methods of Analysis The investment strategies employed by KKR Credit (US) in respect of the KKR Credit (US) Funds or Other Clients focus, primarily, on global leveraged credit strategies, such as leveraged loan and high yield bond strategies, alternative credit strategies (including mezzanine and mezzanine-like instruments, junior debt, special situation instruments, structured and illiquid credit, asset based lending and direct senior loan origination and related instruments), preferred equity, equity, and real assets. Certain KKR Credit (US) Funds might also accommodate co-investments alongside investment funds managed by KKR and its affiliates, including private equity funds and funds that invest in real assets. In pursuit of these strategies, KKR Credit (US), on behalf of KKR Credit Funds or Other Clients, from both a long or short investment perspective, will sometimes invest in a broad range of securities and/or loans and other financial instruments including: U.S. and non-U.S. debt securities and/or loans including public and privately placed corporate and government bonds and other debt securities, equity securities, hybrid securities, stock market indices, exchange traded funds, convertibles, asset backed and other structured debt securities, emerging market debt, warrants, bank loans and participations in bank loans, direct lending loans, accounts receivable loans, repurchase agreements, foreign currency and interest rate forward contracts, swap agreements (including credit default swaps), options, commodities, futures contracts on intangibles and interests in partnerships investing in oil and gas and real estate interests and other derivative or synthetic investment instruments, and joint venture equity investments. The investment strategies employed by KKR Credit Singapore in respect of the KKR Credit Singapore Funds or Other Clients focus, on (a) private credit opportunities, including direct lending, which focuses primarily on originated secured first lien financings, including stretch senior and unitranche investments, capital solutions, which focuses on originated second lien, mezzanine and other junior capital investments with debt-like characteristics, and collateral-backed opportunities, which focuses on debt instruments originated against financial assets, hard assets or structured credit, typically targeting more developed credit markets; and (b) liquid credit investment opportunities through investment in a diversified portfolio of financial instruments throughout the Asia-Pacific credit markets. KKR Credit Singapore Funds might also accommodate co-investments alongside investment funds managed by KKR Credit, KKR and its affiliates including private equity funds and funds that invest in real assets. In pursuit of these strategies, KKR Credit Singapore, on behalf of KKR Credit Singapore Funds or Other Clients, from both a long or short investment perspective, will sometimes invest in a broad range of securities and/or loans and other financial instruments including: U.S. and non-U.S. debt securities and/or loans including public and privately placed corporate and government bonds and other debt securities, equity securities, hybrid securities, stock market indices, exchange traded funds, convertibles, asset backed and other structured debt securities, emerging market debt, warrants, bank loans and participations in bank loans, repurchase agreements, foreign currency and interest rate forward contracts, swap agreements (including credit).
KKR Credit employs both “top-down” and “bottom-up” analyses when making investments. KKR Credit’s top-down analysis involves a macro analysis of relative asset valuations, long-term industry trends, business cycles, interest rate expectations, credit fundamentals and technical factors to target specific industry sectors and asset classes in which to invest. KKR Credit’s bottom-up analysis includes, in the case of credit/debt strategies, a rigorous analysis of the credit fundamentals and capital structure of each credit considered for investment and a thorough review of the impact of credit and industry trends and dynamics and dislocation events on such potential investment. In implementing its strategic investments, special situations, private credit and mezzanine investment strategies, KKR Credit also uses internally developed proprietary industry and company-specific models as a basis for forecasting market and company specific trends. KKR Credit utilizes multiple sources of information in analyzing investments, including financial newspapers and magazines, inspections of corporate activities, research material prepared by others, corporate rating services, annual reports, prospectuses, filings with the SEC, and company press releases. KKR Credit also uses industry magazines, third party consultants, expert networks, lawyers, accountants, asset operators, regulatory filings filed with U.S. and non-U.S. regulators, its global network of contacts at major companies and corporate executives, commercial and investment banks, financial intermediaries, other investment and advisory institutions and its direct and indirect contacts through its affiliation with KKR. KKR Credit employees also participate in on-site visits, industry group and portfolio company management meetings, creditors’ committees, steering committees or on the boards of directors of portfolio companies, which will also be a source of information in respect of such companies subject to policies and procedures related to nonpublic and proprietary information. In addition, KKR Capstone, other Consultants, Senior Advisors, Executive Advisors, Industry Advisors and KKR Advisors often provide supplemental insights to KKR and KKR Credit from a management consulting perspective and from the perspective of a C-level executive (i.e., “chief” executive officers or other senior officers) or board of directors. KKR has a roster of active Senior Advisors, Executive Advisors, and Industry Advisors globally, many of whom have extensive corporate management expertise, having served as Chief Executive Officer, Chief Financial Officer, Chairman of the Board, or other comparable positions at large, industry-leading companies or governmental regulatory agencies. In conducting due diligence on investments in third party funds, KKR Credit will use many of the above due diligence methods, as appropriate, in addition to a detailed review of fund governing documents in conjunction with external counsel and consultants. Material Risks of Significant Investment Strategies The risk factors briefly summarized below are not applicable to all KKR Credit Funds or Other Clients. Such summary does not purport to be a complete list or explanation of the risks involved in an investment in a KKR Credit Fund or Other Client. The offering materials, disclosure documents and/or governing documents of each KKR Credit Fund or Other Client will typically include a more detailed summary of material risks applicable to the KKR Credit Fund or Other Client and its investment strategy and structure and should be read in conjunction with the risks below. Investments and General Risks relating to KKR Credit Funds and Other Clients Investments made by KKR Credit Funds involve a number of material risks including (but not limited to) the risks discussed below. Illiquid and Long-Term Investments Investments in KKR Credit Funds or Other Clients are speculative in nature and require a long-term commitment, with no certainty of return of capital or gains. The investments are expected to be
predominantly private, subordinated, illiquid loans and corporate bonds, in addition to certain equity investments, and there can be no assurance that a KKR Credit Fund or Other Client will be able to generate returns for investors. The realizable value of a highly illiquid investment is often less than its intrinsic value. Furthermore, there are no readily ascertainable market prices for a substantial majority of illiquid investments held by KKR Credit Funds or Other Clients. KKR generally determines the fair value of the investments of KKR Credit Funds in accordance with accounting principles generally accepted in the United States of America (“U.S. GAAP”). U.S. GAAP requires the application of accounting guidance and policies that often involve a significant degree of judgment. These accounting estimates require the use of assumptions, some of which are highly uncertain at the time of estimation and can be incomplete or inaccurate despite our engagement of third parties to assist with certain aspects of our valuations. The amount of judgment and discretion inherent in valuing assets renders valuations uncertain and susceptible to material fluctuations over possibly short periods of time. KKR’s determination of an investment’s fair value may differ materially from the value that would have been determined if a ready market for the securities had existed and the valuations the general partners of other funds or other third parties ascribe to the same investment. There can be no assurance that our policies will address all necessary valuation factors or completely eliminate potential conflicts of interest in such determinations. Although certain investments by KKR Credit Funds and Other Clients generate current income, the return of some or all of their capital and the realization of gains, if any, from an investment generally will occur only upon the partial or complete disposition of such investment, and the timing of and returns that may be generated by such credit dispositions is uncertain. While investments of KKR Credit Funds and Other Clients can generally be sold at any time, realization events such as sales typically only occur a number of years after the investment is made. KKR Credit Funds and Other Clients will generally not be able to sell securities and/or loans comprising an investment publicly unless their sale is registered under applicable securities laws, or unless an exemption from such registration requirements is available. In addition, in some cases, a KKR Credit Fund or Other Client will be prohibited by contract from selling certain securities and/or loans for a period of time, which will restrict their ability to exit the relevant investment and sometimes means that the KKR Credit Fund or Other Client is unable to take advantage of favorable market prices when doing so. In view of such limitations on liquidity, which are illustrative and not exhaustive, KKR Credit Funds or Other Clients will generally not be able to realize on an investment until the sale of such investment. Furthermore, such illiquidity sometimes continues even if the underlying portfolio companies or other relevant issuers obtain listings on securities exchanges. There can be no assurance that a KKR Credit Fund or Other Client will be able to dispose of its investments at any particular price and at the time it wishes to do so, and investors should expect that they will likely not receive a return of some or all of their capital for a long period of time even if the valuations of the investments of the KKR Credit Fund or Other Client in which they are invested appreciate. Valuation Risk KKR Credit Funds and Other Clients will rely on the relevant KKR Credit GP or KKR Credit and its affiliates, as applicable, for valuation of their assets and liabilities. KKR Credit Funds and Other Clients will primarily hold securities and/or loans and other assets that will not have readily ascertainable market values. In such instances, the relevant KKR Credit GP or KKR Credit will determine the fair value of such securities and/or loans and assets in its reasonable judgment based on various factors and in reliance on internal pricing models, in accordance with KKR Credit’s valuation policies and procedures. KKR Credit makes use of, and relies on, valuation information and data developed and provided by certain third parties. Such valuations sometimes vary from similar valuations performed by other independent third parties for similar types of securities or assets. In addition, KKR Credit Funds and Other Clients rely on the valuations or valuation information provided by, or determined in consultation with, the relevant KKR general partner or KKR and its affiliates, as applicable (for example, when KKR Credit Funds or Other Clients are investing in KKR investment strategies). The valuation of illiquid securities and other assets is inherently subjective
Item 7: Types of clients
KKR Credit provides investment management, advisory and administrative services, as described above in response to Item 4 – Advisory Business, to the KKR Credit Funds and Other Clients. With limited exceptions (including, currently, with respect to KKR Credit Funds established as RICs and Manager Co-investment Vehicle), investment in KKR Credit Funds is generally only available to institutional investors and certain high net worth investors that are “accredited investors” and “qualified purchasers” or in the case of Employees, “knowledgeable employees”, within the meaning of the Securities Act and the Investment Company Act, as applicable. KKR Credit Funds or Other Clients, from time to time, have a specified minimum investment amount as set forth in their offering materials, disclosure documents and/or governing documents. These minimum amounts generally are subject to discretion, on the part of KKR Credit or the relevant KKR Credit GP, to permit investments of a smaller amount generally or with respect to any investor. Investment minimums and the circumstances under which they are waived are set forth in their respective offering materials, disclosure documents and/or governing documents. A broad range of U.S. and non-U.S. institutional investors, including, among others, governmental and corporate pension and profit-sharing plans, endowments and foundations, insurance companies, financial institutions, sovereign wealth funds, funds of funds, private wealth and other third party distribution platforms and certain high net worth individuals and family offices, invest in KKR Credit Funds and Other Clients. Additionally, Employees and other persons associated with KKR Credit and/or its affiliates and portfolio companies, including, for example, current or former portfolio company executives, and certain KKR proprietary entities, make capital contributions to KKR Credit Funds, generally though special
purpose vehicles set up as feeder funds that invest in those KKR Credit Fund, or alongside KKR Credit Funds, including, in particular, Manager Co-investment Vehicles. Some of these investment vehicles accept qualified individual (non-institutional) investors primarily sourced through third party brokerage firms, banks, third-party feeder providers, and independent investment advisors (“K-Series Vehicles”). Certain of the K-Series Vehicles advised by KKR Credit affiliates have been structured as RICs, BDCs, or as holding company conglomerates that are structured and operated in reliance on exclusions from the definition of “investment company” under the Investment Company Act. Given the large number of investors, U.S. K-Series Vehicles are typically registered under the Securities Exchange Act of 1934, as amended.
Item 6: Performance-based fees and side-by-side management Conflicts of interest
As noted in Item 5 – Fees and Compensation above, KKR Credit (including the KKR Credit GPs) generally receives carried interest allocations and fees from KKR Credit Funds or Other Clients. From time to time, KKR Credit has an incentive to favor, or take increased investment risk with respect to KKR Credit Funds or Other Clients from which it receives higher carried interest allocation (or which are subject to lower
preferred return hurdles) or higher fees over KKR Credit Funds or Other Clients from which lower or no carried interest allocation or fees is received (and notwithstanding that such accounts do not give rise to carried interest allocations, KKR Credit in any event will in certain cases have an incentive to favor a certain KKR proprietary entity over any other KKR Credit Fund or Other Client). KKR Credit has in place policies and procedures to address these conflicts, including policies and procedures designed to ensure allocation of investment opportunities among all client and KKR proprietary entities on a fair and equitable basis, taking into account the client’s investment objectives. These policies and procedures are described in more detail below in Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. KKR Credit advises certain KKR Credit Funds that are either feeder funds investing in other KKR Credit Funds or side-by-side vehicles investing alongside other KKR Credit Funds established primarily for the benefit of Employees, Senior Advisors, Industry Advisors and KKR Advisors and certain other persons associated with KKR and KKR Credit (including, without limitation, executives of KKR and KKR Credit portfolio companies, external consultants, service providers and their affiliated entities) (“Manager Coinvestment Vehicles”). Manager Co-investment Vehicles are not subject to management fees or carried interest allocations but are generally allocated monitoring fees, transaction fees, break-up fees and other similar fees based on their respective ownership (including indirect ownership through KKR Credit Funds) of the portfolio company or investment as discussed above in Item 5 – Fees and Compensation (except in the case of investments made alongside certain older KKR Credit Funds). KKR Credit or its affiliates retains such compensation to the extent it is allocable to Manager Co-investment Vehicles (except in the case of investments made alongside certain older investment funds managed by KKR and its affiliates). KKR Credit or its affiliates bears the allocable share of KKR Credit Fund organizational costs and other expenses on behalf of the Manager Co-investment Vehicles. As the investment activities of these vehicles are implemented indirectly through the other KKR Credit Funds in which they invest or alongside other KKR Credit Funds, as applicable, KKR Credit does not view these arrangements as giving rise to the types of conflicts of interest described above.
Item 10: Other financial industry activities and affiliations Conflicts of interest
RICs managed by affiliates of KKR Credit, and is compensated by an Affiliated Broker for such services.
The Affiliated Brokers do not otherwise execute transactions on behalf of KKR Credit Funds or Other Clients. While fees, commissions, upfront placement fees, interest payments and other compensation paid to the Affiliated Brokers, are generally believed by KKR Credit to be reasonable and charged at rates that are market rates for the relevant activities, such compensation is generally determined through negotiation with related parties. KKR Credit Funds or Other Clients generally do not have the right to share in the compensation received by an Affiliated Broker for its role in any transaction. Affiliated Brokers do not share in any transaction fees, which are generally allocated among KKR Credit Funds, Other Clients and Manager Co-investment Vehicles as discussed in Item 5 – Fees and Compensation. Under certain circumstances, the relationship KKR Credit has with its Affiliated Brokers gives rise to a potential conflict of interest between KKR Credit and KKR Credit Funds or Other Clients that have an interest in any portfolio companies or investment vehicles with respect to which the Affiliated Brokers provide services (please see the discussion below for further information as to how such conflicts are addressed). In particular, such relationships could create a perception that KKR has sought to influence. KKR Credit might be seen as incentivized to seek to influence the decision by a portfolio company’s management to retain an Affiliated Broker, or to borrow from or otherwise transact with an Affiliated Broker, instead of other unaffiliated broker-dealers or other service providers or counterparties that are more appropriate or offer better terms. Where an Affiliated Broker (or another KKR entity) acts as a lender to a portfolio company in which a KKR Credit Fund or Other Client holds investments in the same or different levels of the capital structure, under certain cases, the arrangement will lead to a conflict between the Affiliated Broker and the KKR Credit Fund or Other Client in the event of a default by, or the liquidation of, the portfolio company or a restructuring or renegotiation of the terms of the loan (similar conflicts can also arise where KKR is a lender to a portfolio company out of its proprietary assets). In certain circumstances, including without limitation, where a portfolio company becomes distressed and the participants in the relevant offering undertaken by such portfolio company have a valid claim against the underwriter, the participating KKR Credit Fund or Other Client will have a conflict in determining whether to seek recourse or sue an Affiliated Broker. KKR Credit could also be seen as incentivized to structure portfolio company transactions, including related co-investment opportunities, so that they require the use of a broker-dealer (and consequently provide an opportunity for an Affiliated Broker to be retained by a portfolio company or acquisition company established for the relevant transaction and generate fees, including underwriting, placement, syndication fees, transaction fees, commissions, underwriting discounts, interest payments or other compensation for such an Affiliated Broker). Affiliated Brokers also provide financing and capital markets services to third parties that are not portfolio companies including third parties that are competitors of portfolio companies of particular KKR Credit Funds or Other Clients, or that are service providers, suppliers, customers, or other counterparties with respect to such companies (“Competitor Companies”) and act as placement agent in respect of investment funds that are sponsored and managed by other third party investment managers, including funds that could compete with KKR Credit Funds or Other Clients. Affiliated Brokers also act as placement agent in respect of investment funds that are sponsored and managed by third parties (for example, certain investee companies of KKR Credit as described in Item 4) and receive consideration for such services. In providing such services to, or with respect to, such funds or companies, Affiliated Brokers will not take into consideration the interests of the relevant portfolio companies or KKR Credit Funds or Other Clients. In addition, Affiliated Brokers can also be engaged to provide financing or other capital markets services to third parties in connection with transactions that are also appropriate for a KKR Credit Fund or for Other Clients. In some cases, these services offered to third parties in connection with a transaction might be provided concurrently with services being provided in a similar manner to a KKR Credit Fund or Other Client even if the KKR Credit Fund or Other Client has a competing interest with the third party. Affiliated Brokers providing services to third parties, including to Competitor Companies, have and will come into possession of information that they are prohibited from acting on (including on behalf of a KKR Credit Fund or Other Client) or disclosing to KKR Credit as a result of applicable confidentiality requirements or
applicable law, even though such action or disclosure would be in the best interests of a KKR Credit Fund or of Other Client. An Affiliated Broker’s ability to receive commissions or other transactional compensation in certain capital markets transactions on the basis of a KKR Credit Fund’s or Other Client’s participation is limited in certain circumstances. As a result, in the event that such services are provided to an issuer that is or becomes a potential investment opportunity for a KKR Credit Fund or Other Client, KKR Credit, through the Affiliated Brokers, will, in certain cases, have a conflict of interest between a KKR Credit Fund or Other Client investment opportunity or a related capital markets transaction. Where an Affiliated Broker serves as underwriter with respect to a security in which a KKR Credit Fund or Other Client invests, such KKR Credit Fund or Other Client will be subject to a “lock-up” period following the offering under applicable regulations during which time its ability to sell the security that it continues to hold is restricted. In certain cases, this will prejudice a KKR Credit Funds’ or Other Clients’ ability to dispose of such security at an opportune time. Affiliated Brokers have access to confidential and/or material non-public information regarding KKR Credit Funds, Other Clients or their portfolio companies and, subject to applicable law and confidentiality agreements, are permitted to use such information in connection with financing and other services provided by the Affiliated Brokers. Transactions involving a KKR Credit Fund or Other Client and an Affiliated Broker are reported periodically to KKR’s Global Conflicts Committee. In addition, KKR Credit reviews such transactions to ensure that the requirements of Section 206(3) of Advisers Act in respect of principal transactions between any KKR Credit Fund or Other Client and KKR or its affiliates (including any Affiliated Broker) are complied with in the context of such transactions. Transactions involving a KKR Credit Fund or Other Client and an Affiliated Broker are reported periodically to KKR Credit Conflicts Committee. Other Investment Advisers Special Purpose Vehicles KKR Credit U.S. has the following wholly-owned special purpose subsidiaries in the U.S., and the Cayman Islands, through which it provides investment management and administration services to certain KKR Credit Funds and Other Clients: •
KAM Advisors LLC
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KAM Fund Advisors LLC
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KAM Credit Advisors LLC
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KKR Credit Fund Advisors LLC
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KKR CS Advisors I LLC
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KKR FI Advisors Cayman Ltd.
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KKR FI Advisors LLC
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KKR Financial Advisors II LLC
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KKR Mezzanine I Advisors LLC
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KKR Strategic Capital Management, L.L.C
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KKR Financial Advisors LLC
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KKR Credit Advisors (Hong Kong) Limited
Each of the above entities is a special purpose vehicle (each, a “KCA SPV”) established by KKR Credit U.S. for certain administrative and operational convenience purposes. KKR Credit Advisors (US) is the sole member or shareholder, as applicable, of each KCA SPV. Accordingly, the activities of each KCA SPV are wholly controlled by KKR Credit U.S. Each of the directors of KKR FI Advisors Cayman Ltd is an employee of KKR Credit U.S. Relying Advisers KKR Credit U.S. and KKR Credit Singapore are affiliated with KKR Credit Advisors (Ireland), which is regulated by the Central Bank of Ireland. KKR Credit Advisors (Ireland) provides management, subadvisory and administration services to or otherwise in respect of specific KKR Credit Funds or Other Clients and provides certain operational and other efficiencies with respect to such services. KKR Credit Advisors (Ireland) is subject to KKR Credit’s regulatory oversight and its Code of Ethics (see response to Item 11 below) together with its other compliance policies and procedures as adopted by KKR Credit U.S. pursuant to the requirements of the Advisers Act. More particularly, certain KKR Credit U.S. officers and employees serve as dual personnel of both KKR Credit U.S. and KKR Credit Advisors (Ireland). KKR Credit U.S. treats all officers and other personnel of KKR Credit Advisors (Ireland) as its “associated persons” and access persons for purposes of the Advisers Act. Participating Affiliate KKR Credit U.S. and KKR Credit Singapore, either directly or indirectly, controls or is under common control with KKR Credit Advisors (EMEA) LLP, which is located in the United Kingdom. KKR Credit Advisors (EMEA) LLP is a “Participating Affiliate” and is involved in identifying, negotiating and monitoring investments recommended by KKR Credit U.S. and KKR Credit Singapore to KKR Credit Funds and Other Clients in the relevant jurisdictions and regions. KKR Credit Advisors (EMEA) LLP is authorized and regulated by the U.K. Financial Conduct Authority (“FCA”) as an investment manager. KKR Credit Advisors (EMEA) LLP is subject to KKR Credit’s supervision and Code of Ethics together with its compliance policies and procedures as adopted pursuant to the requirements of the Advisers Act, as applicable (in addition to applicable local laws and regulation). Any employees of the Participating Affiliate who provide services to KKR Credit’s Clients will be considered “associated person” of KKR Credit and access persons for purposes of the Advisers Act. Kohlberg Kravis Roberts & Co. L.P. KKR Credit is also affiliated with KKR, which is its parent company, and KKR’s other subsidiaries and affiliated entities that manage KKR’s private equity funds and other funds, investment vehicles and accounts (“KKR Funds”). KKR is separately registered under the Advisers Act as an investment adviser. Certain executives of KKR serve on investment committees established by KKR Credit. KKR Credit also, from time to time, acts as sub-adviser in respect of capital allocated within KKR Funds to strategies implemented by KKR Credit and also delegates sub-advisory authority to KKR in respect of capital allocated within certain KKR Credit Funds or Other Clients to strategies implemented by KKR (in each case, at no incremental cost to the relevant KKR Fund, KKR Credit Fund or Other Client). Please see Item 11 for a discussion of the relationship of KKR Credit, KKR Credit Funds and Other Clients and the KKR Funds. KKR is affiliated with KKR Credit Advisors (Ireland). Certain employees of KKR Credit Advisors (Ireland) are employees of KKR. Certain KKR Credit Advisors (Ireland) personnel also participate in Manager Co-investment Vehicles. Private funds, managed accounts and CLOs managed and advised by KKR Credit Advisors (Ireland) generally pursue primarily European credit strategies including investments in European leveraged loans and high yield bonds, alternative credit opportunities such as investments in mezzanine-like instruments, originated senior loans and specific types of syndicated credit investments (e.g., investments in revolver credit facilities) and other structured and illiquid credit investments.
Item 11: Code of ethics, participation or interest in client transactions and personal trading Conflicts of interest
Code of Ethics KKR Credit is subject to a Code of Ethics (the “Code”) in accordance with Rule 204A-1 under the Advisers Act. The Code has been established by its affiliate, KKR, for all of its investment advisory subsidiaries, including KKR Credit. The Code sets out standards of business and personal conduct for each Employee (which for these purposes includes other persons as set out in the Code, including certain consultants, advisors, temporary employees and other persons and addresses conflicts that arise from personal trading by such persons and provides for disciplinary sanctions for Code violations. The Code is available upon written request of current or prospective investors in KKR Credit Funds and Other Clients. The policies and procedures set forth in the Code recognize that as an investment adviser, KKR Credit is in a position of trust and confidence with respect to the KKR Credit Funds and Other Clients and has a duty to place the interests of the KKR Credit Funds and Other Clients before the interests of KKR Credit and its Employees (which for these purposes includes other persons as set out in the Code, including certain consultants, advisors, temporary employees and other persons). This duty includes an obligation to address or mitigate both conflicts of interest and the appearance of any conflicts of interest. The Code also recognizes that as an investment adviser registered under the Advisers Act, KKR Credit has a further obligation to comply with the provisions of the Advisers Act as well as the other U.S. federal securities laws. The Code includes a code of conduct adopted by KKR Credit which requires Employees to (i) act with integrity, honesty, competence, and in an ethical manner when dealing with the public, regulators, clients, investors, prospective investors and their fellow Employees; (ii) adhere to the highest standards with respect to any potential material conflicts of interest with KKR Credit Funds and Other Clients; and (iii) preserve the confidentiality of information that they obtain in the course of KKR Credit’s business and use such information properly, consistent with applicable legal standards, and not in any way adverse to the interests of any KKR Credit Funds or Other Clients.
Under the Code and Firm policy, Employees are prohibited from trading in securities and/or loans of any company while in possession of material, non-public information regarding the company. This prohibition applies to KKR-related securities and the securities of KKR affiliates, as well as other issuers. The Code also includes a personal securities investment and reporting policy. This policy, among other things, significantly restricts an Employee’s ability to engage in personal securities transactions with respect to publicly-trade equity or debt of corporate issuers to avoid conflicts of interest and preclude the potential misuse of proprietary and material non-public information with respect to such issuers. The policy also requires preclearance of investments in private companies and non-KKR or KKR Credit Funds, and requires Employees to disclose all brokerage or securities accounts held in the Employee’s name or over which the Employee has any direct or indirect beneficial ownership, including accounts over which investment discretion is exercised either directly or indirectly. Certain investment personnel of KKR Credit also maintain personal private investment holdings which from time to time include investments in private companies and assets that are owned or become targeted for acquisition by KKR or KKR Credit, or KKR or KKR Credit Funds, or Other Clients (or investments in private assets that compete with assets or business owned or targeted by KKR Credit Funds or Other Clients) and/or private funds that invest in or own private companies or other issuers or assets that compete with assets or businesses owned or targeted by KKR or KKR Credit Funds or Other Clients (i.e. through the acquisition of or investment in an asset of an affiliated or unaffiliated private fund sponsor). Certain of these personal investments are maintained with third-party investment managers, including third-party investment managers or sponsors that KKR Credit or its affiliates, KKR Credit Funds or Other Clients have an economic interest in, who sponsor investment vehicles that compete with KKR or KKR Credit, or that KKR, KKR Credit or their respective affiliates recommend to their respective clients (for example, through KKR’s customized portfolio solutions business). Furthermore, certain of these personal investments have terms that are more favorable than those routinely offered by the unaffiliated investment manager (for example, reduced fees) and those favorable terms will not be shared with and might not be available to KKR Credit Fund or Other Clients. Such personal investments give rise to potential or actual conflicts of interest between KKR Credit Funds and Other Clients on the one hand, and KKR, KKR Credit and their respective affiliates, on the other hand, including, in particular, to the extent such investment personnel participate in the management of a KKR Credit Fund’s or Other Client’s investments in such assets and the personal investment interests of such investment personnel are not aligned with those of a KKR Credit Fund or Other Client. In addition, certain KKR personnel hold investments in entities that are or become service providers to KKR or KKR Credit or portfolio companies of KKR or KKR Credit Funds or Other Clients. Although the relevant KKR Credit personnel do not have control or other influence over the decisions of the relevant service provider (including whether to enter into a business arrangement with KKR Credit or portfolio companies of KKR Credit Funds or Other Clients), a conflict of interest or the perception thereof could nevertheless arise in engaging the relevant entity as a service provider in light of the personal benefits that accrue through the investment they hold in the service provider. KKR Credit’s personal securities investment and reporting policies, which require the pre-approval from KKR’s Compliance Group on any personal private fund or private investments, seek to address any potential or actual conflicts of interest relating to personal private investments. The Code restricts Employees’ ability to conduct activities outside the Firm that conflict with the interests of the KKR or KKR Credit Funds or Other Clients, requires pre-approval for Employees to engage in certain outside business activities or receive and/or provide gifts and entertainment in excess of certain values and restricts Employees’ ability to make political donations. However, Employees, Senior Advisors, Executive Advisors, Industry Advisors, KKR Advisors, and other Consultants from, time to time also serve as directors or interim executives, or otherwise could be associated with companies that are competitors of portfolio companies of certain KKR or KKR Credit Funds or Other Clients (as discussed below).
KKR’s Compliance Group receives and reviews trading and other reports and Employee certifications, questionnaires and pre-approval requests submitted pursuant to the Code to determine that personal trading (as well as other activities subject to compliance oversight) conducted by Employees and other covered persons is consistent with the requirements and restrictions set forth in the Code. Employees also engage in certain cases outside business activities, including serving on boards of directors of third party entities, which give rise to certain conflicts of interests. KKR’s Compliance Group reviews Employee certifications, questionnaires and pre-approval requests to identify such conflicts of interest. Additionally, KKR and KKR Credit have adopted inside information barriers and other policies and procedures to provide for the proper handling of confidential information (i.e., nonpublic information received or created by KKR Credit in connection with its activities) to prevent violations of laws and regulations prohibiting the misuse of such information and to avoid situations that might create an appearance of such misuse. KKR’s Compliance Group is responsible for monitoring the information barriers established by the Firm, administering the information sharing policies and procedures, overseeing potential conflicts of interest, and escalating to an established oversight committee, as appropriate. There could be circumstances in which one or more individuals associated with KKR Credit, including investment executives and committee members otherwise involved in investment activities, will be precluded from providing services to KKR Credit or from being involved in specific investment related activities or decisions because of certain confidential information available to those individuals or to other parts of KKR, or because of other applicable legal or regulatory restrictions resulting from their involvement. In such circumstances, applicable legal or regulatory restrictions (or applicable information barrier policies and procedures or other related compliance policies) could require such investment executives to recuse themselves from the relevant investment committees or otherwise from participating in investment activities or decisions relating to a KKR Credit Fund’s or Other Client’s investments or alternatively, KKR Credit could determine that such investment executives should so recuse themselves to ensure that they can participate in the investment activities and decisions of certain KKR Credit Funds or Other Clients. KKR Credit Funds and Other Clients could be adversely impacted in such circumstances. The Code is available upon written request of KKR Credit Funds or Other Clients and their current or prospective investors. Participation or Interest in Client Transactions Principal Transactions In accordance with the anti-fraud provisions of the Advisers Act and with KKR Credit’s internal compliance policies and procedures, KKR Credit and its affiliates will not, as principal, sell a security to, or buy a security from, any KKR Credit Fund or Other Client, or Global Atlantic Accounts and other proprietary entities, without providing appropriate disclosure and obtaining the informed consent of such KKR Credit Fund or Other Client prior to the settlement of each such transaction, as well as the prior authorization of KKR Credit’s Chief Compliance Officer. The BDCs, RICs and other regulated entities will generally not engage in principal transactions, except as permitted under the Investment Company Act and SEC guidance thereunder. Principal transactions occur, for example, where KKR Credit warehouses an investment, in whole or in part, in one of its proprietary entities for the benefit of one or more KKR Credit Funds or Other Clients, seeds the initial portfolio of a KKR Credit Fund by making the initial commitment and capital contributions to the KKR Credit Fund pending the admission of third party investors to such KKR Credit Fund and the acquisition by the KKR Credit Fund or an Other Client of the investment from the proprietary entity or the participation by such third party investors in such seeded initial portfolio of investments, as applicable. Principal transactions may also occur where a KKR Credit Fund or Other Client buys or sells all or a portion
Item 12: Brokerage practices Conflicts of interest
Selecting or Recommending Broker-Dealers It is KKR Credit’s policy to seek to obtain best execution of trades (if any) in public equity and debt securities and other marketable securities traded on behalf of the KKR Credit Funds and Other Clients by a selected broker-dealer. In seeking best execution, the determinative factor is not always the lowest possible per security price or commission but whether, in KKR Credit’s view, the transaction represents the best overall qualitative and quantitative execution for the KKR Credit Fund or Other Client. KKR Credit’s process of determining best execution involves not only an assessment of brokerage commissions or bid/offer spreads, but also an evaluation of broker-dealer ancillary services. KKR Credit generally considers a range of a broker-dealer’s services in assessing best execution, including: •
competitiveness of commission rates and spreads;
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promptness of execution;
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past history in executing orders;
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clearance and settlement capabilities;
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access to markets, investments (including access to new issues) and distribution network;
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whether the broker-dealer is making a market in a particular issuer;
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trade error rate and ability or willingness to correct errors;
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anonymity/confidentiality;
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market impact;
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liquidity;
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speed of execution;
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expertise with complex transactions;
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trading style and strategy; and
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geographic location.
Although KKR Credit will seek competitive commissions and spreads, it will not necessarily obtain the lowest possible rates for portfolio transactions. The commissions, spreads or other transaction or financial advisory fees charged by an executing broker-dealer will be higher or lower than those charged by other broker-dealers. On a quarterly basis, KKR Credit’s Trade Review Committee conducts an evaluation of the qualitative and quantitative factors surrounding the execution quality of its counterparties. As noted above in Item 10, the Affiliated Brokers do not execute transactions on behalf of KKR Credit Funds and Other Clients. In addition, such Affiliated Brokers do not maintain client accounts. Research and Other Soft Dollar Benefits Pursuant to KKR Credit’s policy, it does not enter into soft dollar or comparable commission sharing arrangements with broker-dealers relating to transactions executed for the benefit of KKR Credit Funds or Other Clients, despite the incentive to receive research or other products or services without paying. It should be noted, however, that various broker-dealers provide KKR Credit or its affiliates with proprietary research and other products and services, which KKR Credit, in certain cases, uses to service all KKR Credit Funds or Other Clients. KKR Credit is of the view that it would receive such research, products and services regardless of the volume of transactions executed through such broker-dealers or the level of commissions or spreads generated by such transactions and that, accordingly, it is not causing any KKR Credit Fund and Other Client to “pay up” for such research, services or products and such research, products and services are not a factor considered by KKR Credit in directing client transactions to such brokerdealers. KKR Credit does not cause KKR Credit Funds or Other Clients to pay commissions higher than those charged by other broker-dealers in return for soft-dollar benefits or direct client transactions to a particular broker-dealer in return for soft dollar benefits. Acquisitions of portfolio companies will typically be executed by KKR Credit on behalf of KKR Credit Funds or Other Clients on terms specifically negotiated by KKR Credit with such companies or the seller of such companies. In certain jurisdictions, such as the United Kingdom and Ireland, KKR Credit’s locally-regulated affiliates will be required to pay for research services they consume in order to comply with MiFID II standards as implemented by the relevant local financial services regulator. The purpose of the MiFID II standards regarding research consumption is to ensure there is a clear delineation between commissions paid for trading services and the provision of research. KKR Credit is of the view that this aligns with KKR Credit’s approach to soft dollar arrangements discussed above as it ensures that the provision of research is not a consideration when deciding where to direct client transactions. Brokerage for Client Referrals KKR Credit engages broker-dealers or affiliates of broker-dealers with whom it engages in securities transactions on behalf of KKR Credit Funds and Other Clients to place securities issued by KKR Credit Funds. Similarly, such entities will be underwriters of, or otherwise involved in the placement of securities issued by KKR Credit or KKR Credit portfolio companies. The foregoing relationships with broker-dealers and their affiliates give rise to a conflict of interest to the extent that such relationships could be viewed as influencing KKR Credit’s selection of broker dealers and other trading counterparties. As noted above, however, KKR Credit takes into account a number of factors in attempting to satisfy its fiduciary obligation to seek best execution for its clients’ securities transactions. Directed Brokerage KKR Credit does not recommend, request or require that a client direct KKR Credit to execute transactions through a specified broker-dealer.
Aggregation of Client Orders (Bunched Trades) In order to minimize execution costs and obtain best execution for KKR Credit Fund and Other Client transactions in marketable securities, KKR Credit bunch orders for KKR Credit Funds and Other Clients (subject to KKR Credit’s obligation to seek best execution for KKR Credit Funds and Other Clients and otherwise treat KKR Credit Funds and Other Clients in a fair and equitable manner over time). Allocations of bunched trades are made consistent with KKR Credit’s allocation policies and procedures described above in Item 11.
Item 14: Client referrals and other compensation Conflicts of interest
Economic Benefits from Non-Clients As described in more detail under Item 5 and Item 10, Employees, Affiliated Brokers, KKR Capstone other KKR proprietary entities and other Consultants receive economic benefits from portfolio companies of KKR Credit Funds and Other Clients. Please see Item 5 – Fees and Compensation with respect to monitoring fees, financial advisory fees, transaction fees, accelerated fees, break-up fees and other compensation. Please see Item 5 – Fees and Compensation with respect to directors’ fees for Employees serving on boards of portfolio companies. Please see Item 5 – Fees and Compensation and Item 10 – Other Financial Industry Activities and Affiliations with respect to compensation received by Affiliated Brokers.
Please see Item 5 – Fees and Compensation with respect to portfolio companies of KKR Credit Funds or Other Clients and fees and/or servicing payments payable to KKR, its affiliates (or other Consultants). Compensation to Non-Supervised Persons for Client Referrals KKR Credit enters into solicitation agreements pursuant to which it compensates a third-party intermediary for client referrals that result in the provision of investment advisory services by KKR Credit. KKR Credit will disclose these solicitation arrangements to affected investors, and any cash solicitation agreements will comply with Rule 206(4)-3 under the Advisers Act. Solicitors introducing clients to KKR Credit receive compensation from KKR Credit, such as a retainer and/or a percentage of introduced capital. Such compensation will be paid pursuant to a written agreement with the solicitor and generally is terminable by either party from time to time. The cost of any such fees will be borne entirely by KKR Credit or KKR and not by any affected client.
Item 9: Disciplinary information
Except as described below, neither KKR Credit, including its affiliates, nor any of its executive officers, members of its investment committees or portfolio management committees or other “management persons” as defined in Form ADV have been subject to legal or disciplinary events responsive to this Item. On January 14, 2025, a subsidiary of KKR & Co. Inc. filed a complaint (the “KKR Complaint”) in the U.S. District Court for the District of Columbia against Doha Mekki in her official capacity as Acting Assistant Attorney General of the United States for the Antitrust Division, the United States Department of Justice (“Antitrust Division”), the Federal Trade Commission (“FTC”), and the United States of America (collectively, the “Defendants”) pertaining to certain investigations conducted by the Antitrust Division with respect to the accuracy and completeness of certain filings made by KKR and its affiliates pursuant to the premerger notification requirements under the Hart-Scott-Rodino Act of 1976 (“HSR Act”) for certain transactions in 2021 and 2022. The KKR Complaint requests various forms of relief, including declaratory judgments that: (i) KKR and its affiliates did not violate the HSR Act; (ii) the Antitrust Division’s and FTC’s interpretations of the HSR Act are unconstitutionally vague; and (iii) the Antitrust Division seeks an excessive fine in violation of the U.S. Constitution. On January 14, 2025, the Antitrust Division filed a civil antitrust complaint (the “DOJ Complaint”) in the U.S. District Court for the Southern District of New York against KKR and certain affiliates, including various KKR-sponsored investment entities (the “KKR Defendants”) alleging violations of the HSR Act. The DOJ Complaint requests various relief for the alleged violations of the HSR Act by the KKR Defendants, including civil penalties in an amount to be determined and various equitable relief, including potential disgorgement and injunctive relief against future violations of the HSR Act. On January 16, 2025, KKR Defendants voluntarily dismissed the KKR Complaint from the U.S. District Court for the District of Columbia. That same day, the KKR Defendants refiled the KKR Complaint in the Southern District of New York. The KKR Defendants filed a motion to dismiss the DOJ Complaint on April 17, 2025. The DOJ filed its motion to dismiss the KKR Complaint on April 23, 2025, and the parties agreed to dismiss one count of the KKR Complaint and to stay the rest of the DOJ’s motion to dismiss pending resolution of KKR Defendants’ motion to dismiss the DOJ Complaint. On August 26, 2026, KKR Defendants entered into a Stipulation and Order (the “Stipulation”) with the
Antitrust Division to resolve the DOJ Complaint. Pursuant to the Stipulation, and contingent upon a proposed final judgment becoming effective, the Antitrust Division would release all KKR Defendants from claims made in the DOJ Complaint, and a subsidiary of KKR & Co. Inc. would pay $250.0 million to the Antitrust Division. Additionally, the Antitrust Division notified KKR & Co. Inc. that it had terminated all of its related investigations against KKR & Co. Inc. and its affiliates. The Stipulation and a proposed final judgment were filed with the U.S. District Court for the Southern District of New York. The proposed final judgment is subject to judicial approval under the Antitrust Procedures and Penalties Act, 15 U.S.C. § 16, for the limited purpose of determining whether the proposed final judgment is in the public interest. In addition, KKR is currently, and may from time to time become, subject to other investigations by the Antitrust Division of the DOJ and other U.S. or non-U.S. governmental authorities related to antitrust matters, including the European Commission’s investigation relating to the acquisition of certain infrastructure assets of Telecom Italia S.p.A. and FiberCop S.p.A. KKR is currently cooperating in connection with these other investigations. On January 13, 2025, KKR and its affiliates entered into a settlement with the SEC to resolve the SEC’s investigation related to the preservation of text messages and similar communications on electronic messaging applications under the Advisers Act. Under the terms of the settlement, among other things, KKR and its affiliates paid a civil penalty of $11.0 million, made certain admissions about recordkeeping violations under the Advisers Act, and agreed to conduct a self-assessment of KKR’s compliance with its policies and procedures to preserve electronic communications. In the ordinary course of business, KKR Credit and its affiliates are party to litigation, investigations, inquiries, employment-related matters, disputes and other potential claims. Further information can be found in KKR & Co.’s Annual Report on Form 10-K for the fiscal year ended December 31, 2025, filed with the SEC on February 27, 2026, and its other periodic filings with the SEC, which are available at www.sec.gov. Item 10.
Other Financial Industry Activities and Affiliations
Affiliated Broker-Dealers KKR Credit is an affiliate of Global Atlantic Distributors LLC, KKR Capital Markets, LLC and KKR Capital Markets II, LLC (formerly MCS Capital Markets, LLC), each of which is registered as a brokerdealer in the U.S. with the SEC and FINRA. KKR Credit is also affiliated with KKR Capital Markets Partners LLP located in London, which is authorized and regulated by the FCA to conduct broker-dealer activities in the UK; KKR Capital Markets (Ireland) Limited located in Dublin, which is authorized and regulated by the CBI to conduct broker-dealer activities in Ireland; KKR Capital Markets Japan Limited, which is a certified Type I and Type II Financial Instruments Business Operator (broker-dealer) licensed by the Japanese Financial Services Agency; KKR Capital Markets Asia Limited, a Hong Kong licensed asset manager and broker-dealer licensed by the Securities and Futures Commission in Hong Kong to carry on dealing in securities, advising on securities and asset management regulated activities, and KKR Capital Markets Asia II Limited, a Hong Kong licensed broker-dealer licensed by the Securities and Futures Commission in Hong Kong to carry on dealing in securities and advising on securities activities. In addition, KKR Credit is also affiliated with KKR Australia Pty Limited and KKR Australia Investment Management Pty Limited, KKR MENA Limited, KKR Saudi Limited, KKR Singapore Pte. Ltd. and KKR Credit Singapore, KKR Switzerland GmbH, and KKR Holdings Mauritius, Ltd., which hold financial services licenses from the Australian Securities and Investment Commission, the Dubai Financial Services Authority, the Capital Market Authority in Saudi Arabia, the Monetary Authority of Singapore, FCA, and the Financial Services Commission, Mauritius, respectively, permitting them among other things to conduct capital raising and other broker-dealer activities (collectively, the “Affiliated Brokers”).
Affiliated Brokers (including their respective related lending vehicles) manage or otherwise participate in underwriting syndicates and/or selling groups with respect to the existing or potential securities, debt instruments or other financial products portfolio companies and other non-controlled entities in or through which KKR Credit Funds or Other Clients invest, including for or in connection with the acquisition of such portfolio companies, in respect of securities or other instruments of such portfolio companies in which KKR Credit Funds or Other Clients have not invested and with respect to securities and other instruments held directly or indirectly by certain co-investment vehicles. From time to time, affiliated brokers are otherwise involved in the public or private placement of such securities and other instruments, and/or the provision of capital markets advisory services to portfolio companies and other non-controlled entities in or through which KKR Credit Funds or Other Clients invest, including in connection with mergers and acquisitions, recapitalizations, refinancings and restructurings, and will alone, or with other counterparties, which might include other KKR Credit investment vehicles, third party banks or other unaffiliated finance providers, provide acquisition financing, lines of credit, bridge financing, hedging and other corporate lending services to such entities in addition to financing provided through a KKR Credit Fund’s or Other Client’s investment. Affiliated Brokers also provide loans and lines of credit or bridge financing to portfolio companies of KKR Credit Funds and Other Clients through the Affiliated Brokers’ respective related lending vehicles. Affiliated Brokers alone or with other lenders (including other KKR entities), arrange lines of credit for (i) portfolio companies and other controlled or non-controlled entities in or through which KKR Credit Funds or Other Clients invest; (ii) KKR Credit Funds; (iii) Other Clients; and (iv) other third parties. Affiliated Brokers (through their respective lending related vehicles) also provide loans and lines of credit or bridge financing to such entities, or participate actively in the financing of a KKR Credit Fund’s or Other Client’s portfolio investments, including, for example, by arranging financing. Affiliated Brokers also provide syndication services to such entities including in respect of co-investments in transactions participated in by KKR Credit Funds or Other Clients. Affiliated Brokers will generally receive fees, including underwriting, arranger, placement, syndication fees, transaction, commissions, underwriting discounts, interest payments and other compensation, which are payable in cash or securities and/or loans, in respect of the activities described above. KKR Credit Funds and Other Clients will directly bear, or indirectly bear through portfolio companies, holding vehicles and other entities in or through which they invest (including where such costs are shared between such entities and KKR Credit Funds or Other Clients), the foregoing fees paid to Affiliated Brokers, as well as the expenses, charges and costs of any benchmarking, verification or other analysis related thereto. Affiliated Brokers from time to time waive such fees. Affiliated Brokers and other KKR Credit affiliated entities will, as a consequence of such activities, hold positions in instruments or securities and/or loans issued by portfolio companies, including, for example, where a KKR proprietary entity commits to a fund the shortfall amount, if any, resulting from the incomplete syndication by an Affiliated Broker of a portfolio co-investment opportunity. Under such circumstances, a KKR proprietary entity will commit to provide capital support for the syndication on a short-term basis (i.e. to provide certainty to KKR Credit Funds and Other Clients that there will be sufficient capital to complete the proposed transaction) or fund a different instrument or security in the portfolio company than that held by KKR Credit Funds and Other Clients to facilitate the syndication, which KKR proprietary entities may in either scenario sell down prior to KKR Credit Funds or Other Clients disposing of their respective investments in the portfolio company. An Affiliated Broker also has acted and could act in the future as placement agent or underwriter of securities and/or loans of a third party that a KKR Credit Fund or Other Client purchases (for example, a co-investment vehicle). Where an Affiliated Broker acts as the placement agent for a KKR Credit Fund in certain jurisdictions and such Affiliated Broker does not receive compensation for such service; however, if compensation is received, such compensation would be made on a fully disclosed basis. As described in
Item 13: Review of accounts
KKR Credit has an internal structure which allocates responsibility for oversight of KKR Credit Fund and Other Client portfolios and/or specific KKR Credit Fund or Other Client portfolio investments to the respective KKR Credit investment committees and/or executive investment management, and for certain Other Clients, as it relates to strategic investment oversight, to appropriate senior investment executives. Generally, investments of KKR Credit Funds and Other Clients are overseen by established investment committees, which primarily consist of representation by portfolio management, KKR Credit senior investment executives, and for certain credit strategies, trading. Additionally, certain KKR Credit Portfolio Managers oversee the investment process for Other Clients investing in certain strategies. Please see Item 16 – Investment Discretion for additional information regarding Investment Discretion with respect to Other Clients. KKR Credit Fund and Other Client portfolios and their respective investments are reviewed and monitored with respect to historic and anticipated performance, market developments and compliance with the investment mandate of the relevant KKR Credit Fund or Other Client on an ongoing basis, both informally and formally through scheduled periodic meetings of the investment committees or established portfolio monitoring governance structure, as appropriate. The nature and frequency of regular reports to KKR Credit Funds and Other Clients and to investors in KKR Credit Funds and Other Clients depends on the terms of the governing documents of such KKR Credit Funds and Other Clients, regulatory requirements, and/or the requirements of any exchange or market on which their securities are admitted to trade or the relevant management agreement. Typically, investors in KKR Credit Funds are provided with written quarterly unaudited financial reports and annual audited financial statements.
Item 15: Custody
KKR Credit has custody of the assets of certain KKR Credit Funds and Manager Co-investment Vehicles, and these KKR Credit Funds and their investors receive annual audited financial statements from the KKR Credit Funds’ auditor. Other KKR Credit Funds and Other Clients of KKR Credit receive account statements from broker-dealers, banks or other qualified custodians with respect to the assets managed by KKR Credit. KKR Credit sends certain account and performance information to KKR Credit Funds and Other Clients, and KKR Credit urges the KKR Credit Funds and Other Clients to compare the information they receive from KKR Credit with the information received from KKR Credit Fund auditors or brokerdealers, banks or other qualified custodians.
Item 16: Investment discretion
KKR Credit, including through the KKR Credit GPs, generally has discretionary authority based on its investment management agreements with each KKR Credit Fund or Other Client and the governing documents of the KKR Credit Funds and Other Clients to buy and sell securities or other investments on behalf of the KKR Credit Funds and Other Clients and to determine the amount of such investments to be bought and sold. The terms upon which KKR Credit serves as investment manager of a KKR Credit Fund are established at the time each KKR Credit Fund is established and are generally set out in the governing documents entered into by KKR Credit with respect to the relevant KKR Credit Fund, and disclosed in the offering or disclosure documents for the relevant KKR Credit Fund, as applicable. These terms, which vary as among each KKR Credit Fund, potentially restrict KKR Credit’s advice concerning investment in certain securities or types of securities, geographies, and leverage. Typically, the governing documents of the KKR Credit Funds contain limited investment restrictions and requirements as to diversification of fund investments, either by geographic region or asset type. For Other Clients and certain other investment vehicles established for a single investor, KKR Credit would negotiate the level of investment discretion with the client at the outset of the advisory relationship. In addition to the conflicts of interest described under Item 11, as a general matter, KKR Credit will, in certain cases, exercise its investment discretion to give advice or take action (including entering into short sales, derivative transactions or other “opposite way trading” activities) with respect to the investments held by, and transactions of KKR Credit Funds, Other Clients or KKR proprietary entities that is different from or otherwise inconsistent with the advice given or timing or nature of any action taken with respect to the investments held by, and transactions of, other KKR Credit Funds, Other Clients or KKR proprietary entities. Such different advice and/or inconsistent actions will be due to a variety of reasons, including, without limitation, differences between the investment objectives, programs, strategies and tax treatment
of certain KKR Credit Funds, Other Clients or KKR proprietary entities or the regulatory status of other KKR Credit Funds or Other Clients and any related restrictions or obligations imposed on KKR Credit as a fiduciary thereof (including for example KKR Credit Funds or Other Clients that are registered as investment companies under the Investment Company Act). Such advice and actions will, in certain cases, adversely impact KKR Credit Funds and Other Clients. For example, another KKR Credit Fund, Other Client, Seed Investment or other KKR proprietary entity establishes a short position in a security held by a KKR Credit Fund, Other Client, Seed Investment or other KKR proprietary entity (for example as collateral) and such short sale results in a decrease in the price of the security that the relevant KKR Credit Fund, Other Client, Seed Investment or other KKR proprietary entity hold. Similarly, KKR Credit seeks to buy or sell a security for a KKR Credit Fund or Other Client and, concurrently or in close proximity in time, seek to buy or sell the same securities or similar securities in the opposite direction; this can benefit the execution quality of the second account to execute such a trade. KKR Credit has established policies and procedures intended to address conflicts of interest inherent in effecting long and short positions in the same security (i.e., opposite way trading) with respect to KKR Credit Funds, Other Clients, Seed Investments and other propriety accounts. These policies and procedures are designed to ensure that KKR Credit will treat all accounts (including Seed Investments and other KKR proprietary entities) on equal footing and not favor long trading or short trading, or short trading over long trading; and also ensure that opposite way trading is the result of independent investment theses and is executed in an orderly and equitable fashion.
Item 17: Voting client securities
In accordance with Rule 206(4)-6 under the Advisers Act, KKR Credit has adopted policies with respect to voting Client securities, and has engaged an independent third party proxy voting specialist, Institutional Shareholder Services, Inc. (“ISS”), to assist KKR Credit in the proxy voting process. The services provided by ISS include research and voting recommendations as well as ballot notifications, execution, reporting and recordkeeping with respect to both U.S. and non-U.S. securities of publicly traded companies. KKR Credit has engaged ISS to assist with its proxy voting, however, KKR Credit, retains ultimate voting discretion with respect to KKR Credit Fund or Other Client securities. It is the general policy of KKR Credit to vote proxies in the best interest of its’ Clients. KKR Credit will, in certain cases, either depart from an ISS recommendation in order to avoid voting decisions believed to be contrary to the best interests of KKR Credit Funds and Other Clients, or even choose not to vote proxies in certain situations. Any such exceptions will be documented by KKR Credit Compliance. KKR Credit recognizes that in certain cases there will also be a potential conflict of interest in voting proxies due to business or personal relationships it maintains with persons having an interest in the outcome of certain votes. KKR Credit has adopted policies to address these and other issues that could give rise to a conflict, including referring the matter to the KKR Credit’s Compliance Group to address issues raised from potential conflicts. Appropriate documentation to support its proxy voting position on such proxy matters will be maintained. A KKR Credit Fund or Other Client or investor in a KKR Credit Fund can obtain a copy of KKR Credit’s Proxy Voting policies and procedures and information on how KKR Credit voted proxies on behalf of such party on written request to KKR Credit.
Item 18: Financial information
KKR Credit does not require the payment of management fees or other compensation six months or more in advance. There exists no financial condition of which KKR Credit is currently aware that would impair KKR Credit’s ability to meet contractual commitments to its Clients.
Filings
21 filings to the SEC since October 2021: 21 other. The latest 20:
- Aug 27, 2026N-PX EDGAR
- Aug 14, 202613F-NT EDGAR
- May 15, 202613F-NT EDGAR
- Nov 14, 202513F-NT EDGAR
- Aug 28, 2025N-PX EDGAR
- Aug 14, 202513F-NT EDGAR
- May 15, 202513F-NT EDGAR
- Feb 14, 202513F-NT EDGAR
- Nov 14, 202413F-NT EDGAR
- Aug 30, 2024N-PX EDGAR
- Aug 14, 202413F-NT EDGAR
- May 15, 202413F-NT EDGAR
- Feb 14, 202413F-NT EDGAR
- Nov 14, 202313F-NT EDGAR
- Aug 14, 202313F-NT EDGAR
- May 15, 202313F-NT EDGAR
- Feb 14, 202313F-NT EDGAR
- Nov 14, 202213F-NT EDGAR
- Aug 12, 202213F-NT EDGAR
- May 16, 202213F-NT EDGAR
The 21 filings since October 2021 can be filtered by form type and year here when JavaScript is on.
Every filing from the last five years, summarized. The full record is on SEC EDGAR.
Stakes it holds
KKR Credit Advisors (US) LLC has told the SEC it owns more than 5% of 2 companies, latest first (Schedules 13D and 13G).
- FS KKR Capital CorpSC 13D/A Feb 16, 2022 to Nov 22, 20234
- Dave & Buster'sSC 13D/A Nov 5, 2021 to Mar 28, 20225
Sources
The numbers on this page point here. Each one links to the record it came from.
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