Compass Group Management, LLC (“Compass,” the “Firm,” “we,” “us” or “our”), a Missouri 
Limited Liability Company, was organized in 2015 and is headquartered in St. Louis, MO. Compass 
is a wholly owned subsidiary of Compass Group Holdings, LP (“Compass Group Holdings”), 
which is ultimately owned by Mr. John Huhn and Mr. Chris Gibson through entities under their 
control.  Messrs. John Huhn and Chris Gibson control and are the principals of Compass and 
Compass  Group  Holdings.  Compass  invests  in  lower  middle-market  companies,  bringing  to 
management a mix of capital, hands-on support, and value-add expertise to accelerate growth, 
exceed historical performance and add value to a business. 
Compass provides investment advisory services to privately pooled private equity funds exempt 
from registration under the Investment Company Act of 1940 (“Investment Company Act”) (each, 
a  “Fund”  and  collectively,  the  “Funds”).  Compass  also  provides  discretionary  investment 
advisory services to co-investment special purpose funds established to invest alongside a fund in 
a single portfolio company (each, a “Co-Investment Fund” and collectively with the Funds, the 
“Funds” unless the context otherwise requires).  In limited circumstances, as more fully described 
in Item 7 below, the Firm permits certain investors and third parties to co-invest alongside a Fund 
directly into a portfolio company.  Unlike the Co-Investment Funds mentioned above, such direct 
co-investments are not considered Funds or clients of Compass.   
Each Fund is affiliated with a general partner (each, a “General Partner” and collectively, the 
“General Partners”). The General Partners have ultimate responsibility for decisions relating 
to management and operations made on behalf of the Funds and have ultimate responsibility for 
the  investment  decisions  made  on  behalf  of  the  Funds.  Each  General  Partner  has  delegated 
investment management and advisory responsibilities for the Funds to Compass. For purposes of 
this  Brochure,  references  to  Compass  shall  include  the  General  Partners,  unless  the  context 
otherwise requires.   
The  Funds  invest  through  privately  negotiated  transactions  in  operating  companies,  generally 
referred  to  as  “portfolio  companies”.  Each  portfolio  company  has  its  own  independent 
management team responsible for managing its day-to-day operations, although (i) members of 
Compass or representatives appointed by the Firm are expected to serve on the boards of, or 
otherwise  act  to  influence  control  of  the  management  of,  such  portfolio  companies  and  will 
therefore have a significant impact on the long-term direction of the company, including at times 
the selection of management team members and (ii) in some cases, Compass will more directly 
influence the day-to-day management of a portfolio company by recruiting and installing certain 
individuals in various leadership roles, such as chief executive officer, chief operating officer, chief 
financial officer or other roles. Compass’ investment advisory services to the Funds consist of 
identifying  and  evaluating  investment  opportunities,  negotiating
                                        
                                        
                                              the  terms  of  investments, 
managing and monitoring investments and achieving dispositions of such investments.  Investments 
are made predominantly in lower middle market nonpublic companies.  
Compass  will  manage  the  Funds  pursuant  to  investment  guidelines  set  forth  in  the  relevant 
governing and offering documents of  each Fund, including any  Limited Partnership Agreement, 
Investment  Management  Agreement,  Private  Placement  Memorandum  and/or  Subscription 
Agreement (each, an “Offering Document,” and collectively, the “Offering Documents”). 
The  Offering  Documents  contain  more  detailed  information  about  the  Funds,  including  a 
description of the investment objective and strategy or strategies employed by the Funds and 
related restrictions that serve as a limitation on Compass’ advice or management.  
Compass will not tailor its advisory services to the individual investors in a particular Fund (each 
an  “Investor”  or  “Limited  Partner”  and  collectively  the  “Investors”  or  “Limited 
Partners”),  or  provide  Investors  with  the  right  to  specify,  or  restrict  a  Fund’s  investment 
objectives or any investment decisions.  
Investors in the Funds participate in the overall investment strategy for the applicable Fund and 
generally  cannot  be  excused  from  a  particular  investment  except  in  certain  circumstances 
pursuant to the terms of the applicable Offering Documents. In accordance with industry common 
practice,  Compass  has  entered  into  side  letters  or  similar  agreements  with  certain  Investors 
including those who make substantial commitments of capital or were early-stage Investors in the 
Funds, or for other reasons in the sole discretion of Compass, in each case that have the effect of 
establishing rights under, or altering or supplementing, a Fund’s Offering Documents. Examples of 
side  letters  entered  into  include  provisions  whereby  Investors  have  expressed  an  interest  in 
participating in co-investment opportunities, Limited Partner advisory committee representation, 
certain  fee  arrangements,  notification  provisions,  opt-out  rights,  reporting  requirements  and 
“most  favored  nations”  provisions,  among  others.  These  rights,  benefits  or  privileges  are  not 
always made available to all Investors, consistent with the Offering Documents and general market 
practice.  Commencing in March 2025, Compass will make required disclosure of certain side 
letters to all Investors (and in certain cases, to prospective Investors) in accordance with the new 
Private  Fund  Rule.    Side  letters  are  negotiated  at  the  time  of  the  relevant  Investor’s  capital 
commitment,  and  once  invested  in  a  Fund,  Investors  generally  cannot  impose  additional 
investment guidelines or restrictions on such Fund. There can be no assurance that the side letter 
rights granted to one or more Investors will not in certain cases disadvantage other Investors.   
Compass  does not participate in wrap fee programs. 
As  of  December  31,  2023,  Compass  managed  $430,211,313  in  regulatory  assets  under 
management (“RAUM”), all on a discretionary basis.