Valuation Policy

Valuation Policy

Prepared by: TEN13

Last Updated: June 2025

1 Purpose:

This policy outlines the principles and methods applied by the TEN13 Nominee Pty Ltd (the"Nominee") to effectuate mark-to-market valuations of its investment portfolio. It aims to ensure compliance with the Australian Corporations Act 2001, and any other pertinent legal or regulatory requirements.

2 Scope

This policy is applicable to all investments made by the Nominee and managed by TEN13 Management Pty Ltd (“Manager”).

3 Valuation Principles:

  • ‍Value: The Manager shall adjust the value of its investments on a mark-to-market basis within 14 days, at the conclusion of each quarterly reporting period. ‍
  • Consistency: The Manager will employ valuation methodologies with regularity, except where the discretion of the Manager is required due to unique circumstances.

4 Valuation Methodology

Equity:

When the Nominee holds equity (shares), valuations will be adjusted:

  • Mark-to-market based on the most recent equity financing round, either upwards or downwards.
  • Adjustments will necessitate a “Materiality” threshold and should originate from arms-length transactions. Materiality will be determined by TEN13 Management.
  • Secondaries shall not impact valuations.

Convertibles:

If the Nominee invests in a company via a Convertible instrument (SAFE or Convertible Note):

  • No adjustments will be made to the valuation whilst the Nominee retains a SAFE or Convertible Note, notwithstanding subsequent funding on further convertible instruments by external parties. Pertinent information will be appended in a note to each portfolio company account, where available.
  • In the event of a qualified financing event or conversion event, the Nominee will become a shareholder of the portfolio company, and the new price will be reflected and adjusted within the TEN13 Hub.

5 External Pricing

In cases where TEN13 leads a subsequent financing round with participation from other external investors, the transaction purchase price will be marked-to-market.

In instances where the Nominee is the sole investor in the financing round, the valuation shall be at the discretion of the Manager.

6 Valuation Process

  • Valuations are examined by the Valuation Committee, potentially inclusive of independent members, for consistency, accuracy, and adherence to this policy on a quarterly basis.
  • Any conflicts of interest arising during this process are scrutinised and managed as per the guidelines established by the Australian Securities and Investments Commission (ASIC).
  • The Valuation Committee's recommendations are presented to the Manager for approval.
  • The approved valuations are used for financial reporting purposes in the TEN13 Hub.

7 Valuation Information Storage

  • TEN13 Hub: All information regarding portfolio company valuations, including but not limited to company reports, adjustments, current holding values, and approved final valuations, will be securely held and maintained on the TEN13 Hub. The TEN13 Hub serves as the central repository and access point for all valuation-related information for any investor’s portfolio and can be accessed at www.hub.ten13.vc including portfolio statements reports of current valuation of holdings.
  • Accessibility: Relevant stakeholders, as determined by the Manager’s governance and access policy, will have access to this information via secure login credentials to ensure transparency, while still maintaining the confidentiality of sensitive information.
  • Updates: The TEN13 Hub will be updated regularly to reflect the latest valuations, adjustments, and any related notes or comments made by the Manager.
  • Data Security: The TEN13 Hub will adhere to high standards of data security and confidentiality, as stipulated by the Australian Privacy Principles under the Privacy Act 1988 and the Australian Securities and Investments Commission (ASIC) guidelines.

8 Review and Update

This policy will be evaluated annually to ensure it aligns with current industry standards, legal obligations, and regulatory requirements under Australian law.

9 Disclaimer

The Nominee and Manager takes reasonable steps to source the most current, reliable, and relevant information when valuing portfolio companies. However, as these are private companies, the accuracy and completeness of valuations are inherently dependent on the timeliness, quality and access to information provided by each company. While such information is relied upon in good faith, information provided by portfolio companies is not independently verified.