Initial Business Response / [redacted] (1000, 8, 2016/05/06) */ Contact Name and Title: [redacted] Contact Phone: [redacted] Contact Email: [redacted] Dear [redacted] , Thank you for your recent inquiry with the Revdex.com ( [redacted] ) regarding your investment in the GrowthWorks Atlantic Venture Fund Ltd("Atlantic Fund") and for allowing me [redacted] to provide an explanation I understand that you would like to redeem the shares you hold in the Atlantic Fund and have tried to do so on several occasions in the past yearI certainly appreciate your frustration in not being permitted to redeem your Atlantic Fund shares However, at this time the Atlantic Fund is closed for both redemption and saleEnclosed with this letter is a copy of a press release issued by Atlantic Fund on November 20, announcing the suspension of redemptions and a copy of a press release issued by Atlantic Fund on November 20, announcing that Atlantic Fund's Board of Directors approved a Pro Rata Redemption Plan for future redemptions, which was subsequently ratified by Atlantic Fund shareholders at the Atlantic Fund's Annual General Meeting in February Both releases were posted at [redacted] As outlined in the Pro Rata Redemption Plan press release (and further detailed in the Frequently Asked Questions document enclosed with this letter), Atlantic Fund established a [redacted] ("***") comprised of independent directors and its own independent counselThe ***'s review was commenced in light of a range of factors, including Atlantic Fund's cash position, actual and projected levels and timing of divestment activity, the prospects for generating exit values in excess of carrying values and the prospects for Atlantic Fund resuming weekly redemption processing and future capital raising The [redacted] recommended the Pro Rata Redemption Plan to the Board of Atlantic Fund with an overarching focus on maximizing potential returns to shareholders and ensuring fairness among all shareholdersIn accepting the recommendation of the ***, the Board of Atlantic Fund determined that the manner in which Atlantic Fund distributes available cash to shareholders should be changed from distributions by way of redemptions on a "first redemption request in, first paid out" basis to distributions by way of redemptions to all shareholders on a pro rata (or proportional) basisIn the Board's view, a distribution method of providing cash by way of redemptions on a "first redemption request in, first paid out" basis has significant risk of having some shareholders receive liquidity to the exclusion of others The Board will review regularly the potential for making payments to shareholders when Atlantic Fund has available funds for distribution under the Pro Rata Redemption PlanThe amount and timing of available funds for redemptions under the Pro Rata Redemption Plan will depend on the timing and amount of exit proceeds generated in Atlantic Fund's portfolioAtlantic Fund's Board believes the overall potential of Atlantic Fund's venture portfolio to provide value and meaningful cash through exit transactions remains strong and believes many of the portfolio companies are continuing to grow and mature, improving the prospects for cash-generating exitsUnfortunately, the timing of exit transactions is largely beyond the control of Atlantic Fund because it depends heavily on the merger and acquisition, initial public offerings, and secondary investment markets and Atlantic Fund has minority positions in its investee companies As such, I cannot give you assurance as to the timing or amount of funds that will available for distribution to shareholders under the Pro Rata Redemption Plan or that Atlantic Fund will be able to complete an orderly sale of its portfolio companiesFurther, while circumstances may change, given the stage of development of Atlantic Fund's portfolio companies and potential exit opportunities, Atlantic Fund does not anticipate that funds will be available for distribution under the Pro Rata Redemption Plan for the next several quarters I appreciate that you and other Atlantic Fund shareholders are not be pleased with the current situationI can assure you that GrowthWorks is focused on identifying exit opportunities for the Atlantic Fund's venture portfolio to generate the requisite liquidity (i.e., cash) for shareholders while maximizing the value of the venture portfolio which is in the best interest of all shareholdersShould you have any questions, please feel free to contact me at [redacted] or [redacted] I understand that this is a frustrating situation and you may not be satisfied with my responseGrowthWorks is a member of the [redacted] (***)You may be eligible for their dispute resolution service and enclosed is information on taking your complaint to the *** Sincerely, [redacted]
Initial Business Response / [redacted] (1000, 8, 2016/05/06) */ Contact Name and Title: [redacted] Contact Phone: [redacted] Contact Email: [redacted] Dear [redacted] , Thank you for your recent inquiry with the Revdex.com ( [redacted] ) regarding your investment in the GrowthWorks Atlantic Venture Fund Ltd("Atlantic Fund") and for allowing me [redacted] to provide an explanation I understand that you would like to redeem the shares you hold in the Atlantic Fund and have tried to do so on several occasions in the past yearI certainly appreciate your frustration in not being permitted to redeem your Atlantic Fund shares However, at this time the Atlantic Fund is closed for both redemption and saleEnclosed with this letter is a copy of a press release issued by Atlantic Fund on November 20, announcing the suspension of redemptions and a copy of a press release issued by Atlantic Fund on November 20, announcing that Atlantic Fund's Board of Directors approved a Pro Rata Redemption Plan for future redemptions, which was subsequently ratified by Atlantic Fund shareholders at the Atlantic Fund's Annual General Meeting in February Both releases were posted at [redacted] As outlined in the Pro Rata Redemption Plan press release (and further detailed in the Frequently Asked Questions document enclosed with this letter), Atlantic Fund established a [redacted] ("***") comprised of independent directors and its own independent counselThe ***'s review was commenced in light of a range of factors, including Atlantic Fund's cash position, actual and projected levels and timing of divestment activity, the prospects for generating exit values in excess of carrying values and the prospects for Atlantic Fund resuming weekly redemption processing and future capital raising The [redacted] recommended the Pro Rata Redemption Plan to the Board of Atlantic Fund with an overarching focus on maximizing potential returns to shareholders and ensuring fairness among all shareholdersIn accepting the recommendation of the ***, the Board of Atlantic Fund determined that the manner in which Atlantic Fund distributes available cash to shareholders should be changed from distributions by way of redemptions on a "first redemption request in, first paid out" basis to distributions by way of redemptions to all shareholders on a pro rata (or proportional) basisIn the Board's view, a distribution method of providing cash by way of redemptions on a "first redemption request in, first paid out" basis has significant risk of having some shareholders receive liquidity to the exclusion of others The Board will review regularly the potential for making payments to shareholders when Atlantic Fund has available funds for distribution under the Pro Rata Redemption PlanThe amount and timing of available funds for redemptions under the Pro Rata Redemption Plan will depend on the timing and amount of exit proceeds generated in Atlantic Fund's portfolioAtlantic Fund's Board believes the overall potential of Atlantic Fund's venture portfolio to provide value and meaningful cash through exit transactions remains strong and believes many of the portfolio companies are continuing to grow and mature, improving the prospects for cash-generating exitsUnfortunately, the timing of exit transactions is largely beyond the control of Atlantic Fund because it depends heavily on the merger and acquisition, initial public offerings, and secondary investment markets and Atlantic Fund has minority positions in its investee companies As such, I cannot give you assurance as to the timing or amount of funds that will available for distribution to shareholders under the Pro Rata Redemption Plan or that Atlantic Fund will be able to complete an orderly sale of its portfolio companiesFurther, while circumstances may change, given the stage of development of Atlantic Fund's portfolio companies and potential exit opportunities, Atlantic Fund does not anticipate that funds will be available for distribution under the Pro Rata Redemption Plan for the next several quarters I appreciate that you and other Atlantic Fund shareholders are not be pleased with the current situationI can assure you that GrowthWorks is focused on identifying exit opportunities for the Atlantic Fund's venture portfolio to generate the requisite liquidity (i.e., cash) for shareholders while maximizing the value of the venture portfolio which is in the best interest of all shareholdersShould you have any questions, please feel free to contact me at [redacted] or [redacted] I understand that this is a frustrating situation and you may not be satisfied with my responseGrowthWorks is a member of the [redacted] (***)You may be eligible for their dispute resolution service and enclosed is information on taking your complaint to the *** Sincerely, [redacted]