First Reserve Management, L.P.

Allegations: THE SEC ALLEGED THAT FIRST RESERVE (I) DID NOT PROVIDE APPROPRIATE DISCLOSURE OR RECEIVE EFFECTIVE CONSENT REGARDING CERTAIN BUYOUT FUNDS BEARING CERTAIN EXPENSES OF TWO ENTITIES FORMED AS INVESTMENT ADVISERS TO (AND OWNED BY) A PORTFOLIO COMPANY OF THOSE BUYOUT FUNDS THAT WAS A POOLED INVESTMENT VEHICLE, (II) CAUSED THE FIRST RESERVE FUNDS TO PAY INSURANCE PREMIUMS FOR A LIABILITY POLICY COVERING FIRST RESERVE FOR RISKS THAT DID NOT ENTIRELY ARISE FROM ITS MANAGEMENT OF THE FIRST RESERVE FUNDS AND (III) DID NOT PROVIDE DISCLOSURE THAT FIRST RESERVE RECEIVED A LEGAL FEE DISCOUNT FROM A LAW FIRM FOR ITSELF FOR CERTAIN SERVICES WHILE THE FIRST RESERVE FUNDS DID NOT RECEIVE A DISCOUNT ON THE SAME SERVICES (ALTHOUGH THE FUNDS RECEIVED CERTAIN DISCOUNTS ON OTHER TYPES OF SERVICES). IN ADDITION, FIRST RESERVE DID NOT ADOPT AND IMPLEMENT WRITTEN POLICIES AND PROCEDURES REASONABLY DESIGNED TO PREVENT THE ABOVE VIOLATIONS OF THE ADVISERS ACT. Status: Final Sanction Detail: THE ORDER IMPOSES A CIVIL PENALTY OF $3.5 MILLION. PURSUANT TO THE ORDER, THE PENALTY WILL BE PAID WITHIN 10 BUSINESS DAYS OF THE ENTRY OF THE ORDER. Summary: THE SEC ADMINISTRATIVE ORDER IS FINAL. THE CIVIL PENALTY WILL BE PAID WITHIN 10 BUSINESS DAYS OF THE ENTRY OF THE ORDER.