Item 5.)
Conflicts Related to Employee/Investment Professional Trading
Personal Trading by Our Employees. Personal trading by our employees creates a conflict when they are
trading the same securities or types of securities as we trade on behalf of our clients. This conflict is mitigated
by our personal trading standards and procedures described above.
Side-by-Side Management of Accounts. See Item 6 for a description of conflicts of interest related to our
side-by-side management of accounts.
Conflicts Related to Outside Business Activity
From time to time, certain of our employees or officers engage in outside business activity, including outside
directorships. Any outside business activity is subject to prior approval pursuant to our personal conflicts of
interest and outside business activities policy, and may be restricted or denied if conflicts cannot be managed.
Actual and potential conflicts of interest are analyzed during such approval process.
We could be restricted from trading the securities of certain issuers in client portfolios in the unlikely event
that an employee or officer, as a result of outside business activities, obtains material, nonpublic information
regarding an issuer.
Allocation of Limited-Capacity Investment Opportunities
Certain private investment strategies managed by PGIM Private Credit overlap with one another, and in some
cases with strategies managed by PGIM Fixed Income, such that the same investment opportunity may be
suitable for multiple funds or client accounts. In addition, certain private investment opportunities are limited
in size or availability. In certain instances where funds or client accounts do not have exclusivity with respect
to particular investment opportunities, PGIM Private Credit has discretion to allocate below investment grade
or distressed investments, as well as power, infrastructure and certain other investment opportunities, among
such funds or client accounts. These circumstances give rise to conflicts of interest, including where an
investment opportunity falls within the investment focus of multiple strategies (such as distressed, mezzanine
61 PGIM Credit and SCG (FORM ADV PART 2A)
FORM ADV—PART 2A
or direct lending strategies), or where PGIM Private Credit and another PGIM investment group pursue the
same investment opportunity. We address these types of allocation conflicts in a manner that we determine is
fair and equitable to each client, taking into account the nature of the investment opportunity, the sourcing of
the transaction, diversification considerations and any other considerations deemed relevant by us.
Conflicts arising from the use of Warehousing
We sometimes acquire private debt, private equity, real estate investments, asset-backed securities and public
bonds that are “warehoused” temporarily until subsequently placed in certain funds managed by PGIM or
syndicated to unaffiliated investors. When investors subscribe to the funds, these assets are generally
transferred to the funds, but an asset could decline in value from the time it is purchased by the warehousing
entity to the time it is transferred to the fund.
SCG (Investment-Group-Specific)
Information Barrier Standards
SCG maintains its own information barrier policies and related procedures to prevent the improper
communication and misuse of MNPI. SCG personnel are not permitted to communicate MNPI to other
employees without approval from the relevant legal and compliance teams, and are subject to training and
annual attestation requirements. SCG is subject to the firm-wide information barrier framework described
above and maintains restricted lists applicable to its investment activities.
Compensation of SCG Investment professionals
SCG investment professionals are compensated through a combination of base salary, annual performance
incentive bonus and long term incentive grant. Base salary is based on market data, past performance, years of
experience and scope of responsibility. Incentive compensation is largely driven by the individual's
contribution to providing investment performance to clients consistent with portfolio objectives, guidelines
and list parameters, as well as qualitative contributions to the organization.
Conflicts Related to Employee/Investment Professional Trading
Personal trading by SCG personnel creates a conflict and when they are trading the same securities or types
of securities as we trade on behalf of clients. This conflict is mitigated by a firm-wide personal investing
standards and information barrier policies described above.