Private company
Condire Management, LP
Limited partnership registered in the United States, active since 2017. Summary from the record
Last updated Oct 21, 2026.
Overview
- HeadquartersDallas, United States2
- Legal formLimited Partnership2
- Kind of organizationLimited partnership2
- LEI5493003Y899TYQJBRT832
- StatusActive2
- LEI statusIssued and current2
- Registered address1717 McKinney Ave., Ste. 850, 75202 Dallas, United States2
- Registered withCorporations Section (Texas Secretary of State), 08028319932
Corporate structure
Condire Management, LP is part of a group headed by Tough-oakes Partners, LP. 12 entities, 2 countries on record. Switch between the flow chart and the network, and select any entity to see its details.
Major holders of Condire Management, LP
- Ryan Edmund Schedler Owns 50% to 75% of Tough-oakes, since 04/2014 (Form ADV)
- Bradley Jay Shisler Owns 25% to 50% of Tough-oakes, since 04/2014 (Form ADV)
- Tough-oakes Partners, LP
- Condire Management, LP Dallas, Texas, United States
- Gatos Silver, Inc. Stake · Vancouver, Canada
- Golden Star Resources Stake · Toronto, Ontario, Canada
- i-80 Gold Corp. Stake · Toronto, Ontario, Canada
- NexMetals Mining Corp. Stake · Toronto, Ontario, Canada
- Osisko Gold Group Inc. Stake · Z4
- Rayonier Advanced Materials Stake · Jacksonville, Florida, United States
- CONDIRE ALPHA PARTNERS, LP Fund · Dallas, Texas, United States
- Condire Resource Master Partnership, LP Fund · Dallas, Texas, United States
- CONDIRE RESOURCE PARTNERS, LP Fund · Dallas, Texas, United States
- SILVER TEAL, LP Fund · Dallas, Texas, United States
- Condire Management, LP Dallas, Texas, United States
Built from parent and subsidiary links from GLEIF, the Global Legal Entity Identifier Foundation (CC0); major holders from Schedules 13D and 13G; stakes of 5% or more it reported on Schedules 13D and 13G (6 companies); owners and owned firms from Form ADV, the registration investment advisers file with the SEC. Each entity in the chart links to its source.
Investment adviser
Condire Management, LP is registered with the SEC as an investment adviser. This is what it reports on Form ADV, the registration every adviser files and keeps current.
- Assets it manages$1.9B3 5 accounts, all with discretion
- Employees11 7 in investment advice or research
- ClientsPooled investment vehicles (other than investment companies and: 5 ($1.9B)
- How it is paidA percentage of assets under its management; Performance-based fees
- What it doesPortfolio management for pooled investment vehicles (other than investment companies)
- Holds client assetsNo
- RegistrationSEC 801-120022, CRD 311762 IAPD record
Who owns it
Owners of 5% or more as the firm lists them (Schedule A), and the owners of those owners up the chain (Schedule B).
- TOUGH-OAKES PARTNERS, LPowns 75% or more, since 11/2020
- Ryan Edmund Schedlerowns 50% to 75% of TOUGH-OAKES, since 04/2014
- Bradley Jay Shislerowns 25% to 50% of TOUGH-OAKES, since 04/2014
In its own words: the client brochure
Form ADV Part 2A, the plain-English document an adviser must give its clients, quoted as filed 3/31/2026.4 It covers the firm’s services, fees, investment strategies and their risks, and its conflicts of interest.
Item 4: Advisory business Services
Condire Management, LP, a Texas limited partnership and private investment advisory firm (“Condire” or “we,” “us,” or “our”), is the management company associated with Condire Investors, LLC (“Condire Investors”), the General Partner of the funds Condire advises. Condire Investors was organized in 2012 to be the general partner in several funds directed by Ryan Schedler and Brad Shisler (the “Condire Principals”). From inception until December 31, 2020, we operated as a wholly-owned subsidiary of another SEC-registered investment adviser. As of January 1, 2021, we became a standalone SEC-registered investment adviser. We provide investment management services with respect to affiliated private pooled investment vehicles and generally have full discretionary authority with respect to investment decisions. Our investment advisory services are provided in accordance with the investment objectives and guidelines set forth in the applicable offering, governing and/or account documents, and the information in this brochure is qualified in its entirety by the information set forth in such documents. PRINCIPAL OWNERS The controlling members of Condire are Ryan E. Schedler and Bradley J. Shisler. TYPES OF ADVISORY SERVICES We serve as investment manager to the following affiliated private pooled investment vehicles: Condire Resource Partners, LP, a Texas limited partnership (the “Domestic Fund”), Condire Resource Offshore Partners, Ltd., a Cayman Islands exempted company (the “Offshore Fund” and, together with the Domestic Fund, the “Feeder Funds”), Condire Resource Master Partnership, LP, a Cayman Islands exempted limited partnership (the “Master Fund” and, together with the Feeder Funds, collectively, the “CRP Funds”), as well as, Condire Alpha Partners, LP, a Texas limited partnership (“Condire Alpha”). In addition, we serve as investment manager to Silver Teal, LP, a Texas limited partnership (“Silver Teal (together with CRP Funds and Condire Alpha, the “Funds” and each a “Fund”). One of our affiliates serves as the general partner of the Domestic Fund, the Master Fund, Condire Alpha and Silver Teal. Each of the Feeder Funds invests all or substantially all its assets in, and conducts its investment activities through, the Master Fund. Accordingly, the Master Fund serves as a centralized investment vehicle for the Feeder Funds and an investment in a Feeder Fund is an indirect investment in the Master Fund. We serve as investment manager with respect to each of the Funds and are responsible for investing and re-investing the assets of each Fund in securities, financial instruments and/or other assets in accordance with the investment objectives, policies and guidelines set forth in the applicable offering memoranda and/or governing documents. See Item 8 below. We provide investment advice to the Funds in accordance with the investment objectives, policies and guidelines set forth in the offering and governing documents, and not in accordance with the individual needs or objectives of any particular investor in the Funds. Investors generally are not permitted to impose restrictions or limitations on the management of the Funds.
ASSETS UNDER MANAGEMENT Condire had approximately $1,860,020,618 in regulatory assets under management as of December 31, 2025. This amount consisted of $1,744,396,339 in CRP Funds, $81,870,254 in Condire Alpha and $33,754,025 within Silver Teal. All regulatory assets under management are managed on a discretionary basis.
Item 5: Fees and compensation Fees
In consideration of our advisory services, we receive management fees and/or performance-based fees or allocations with respect to the Funds. While our fees are described in detail in the applicable governing, account and/or offering documents, a brief summary of our fees is set forth below. We generally are entitled to receive a management fee from our clients, at an annual rate of 1.50% per annum of the capital account balance of each limited partner as outlined in each Fund’s offering documents. Management fees generally are payable by investors quarterly, in advance, as of the beginning of each calendar quarter. Management fees are deducted directly from the capital account of each investor. For the avoidance of doubt, the calculation of the management fee is made with respect to each limited partner but is paid at the level of the Master Fund. In addition, one of our affiliates generally is entitled to receive a performance allocation of 20% of each qualified limited partner’s allocable share of net profits for the applicable performance period. Performance allocations are subject to a high-water mark limitation. Performance allocations generally are calculated and accrued on a monthly basis. Performance allocations are crystallized and allocated as of the end of each fiscal year (and at such other times as set forth in the applicable partnership agreement). With respect to certain illiquid or otherwise segregated assets or securities (“Special Investments”), such allocations are not crystallized until the occurrence of a Special Investment “recognition event,” as such term is defined in the applicable partnership agreement. Performance allocations are allocated directly from the capital account of each applicable investor. Each investor is required to certify that it is, among other things, an “accredited investor” (as such term is defined in Rule 501(a) of Regulation D under the Securities Act of 1933, as amended), a “qualified client” (as such term is defined in Section 205-3 under the Advisors Act) and a “qualified purchaser” under the Investment Company Act of 1940, as amended. Our advisory fees with respect to each investor generally are not negotiable. However, subject to certain conditions and limitations, the management fee and/or performance allocation with respect to any investor may have been and may in the future be waived or reduced by us or our affiliate. Certain side letter arrangements, such as those for seed or large institutional limited partners based on commitment size or other factors, may also contain modifications to the management fee and/or performance allocation for that investor. These arrangements are evaluated for fairness and are subject to most-favored-nation (MFN) provisions where applicable, ensuring eligible investors can elect equivalent terms. OTHER FEES AND EXPENSES In addition to management fees and/or performance allocations (as applicable), each Fund generally bears all costs and expenses relating to the Fund’s activities, including, but not limited to, (i) legal, auditing and accounting expenses (including the maintenance of books and records), (ii) costs for the preparation of the Fund’s financial statements, tax returns, and Schedule K-1s, (iii) interest expense, (iv) research expenses, and (v) other expenses associated with the acquisition, holding and disposition of investments including all brokerage, borrowings and custodial fees and expenses. In addition, certain expenses may be allocated among the Funds and/or other client accounts or affiliated entities based on our assessment of the relative benefit to each account, considering factors such as the nature of the expense, the activities of client accounts and reasonable allocation methodologies (e.g., based on assets under management, exposure to the activity creating the expense, or similar considerations). We seek to allocate such expenses in a manner that we believe is fair and equitable over time and consistent with our policies and procedures. See Item 12 below. WITHDRAWALS Subject to the terms and conditions set forth in the applicable offering documents, each limited partner generally may make a complete or partial withdrawal of its limited partnership interest (except with respect to some Special Investments) as of the close of business on the last business day of any calendar quarter; provided, however a newly admitted limited partner to certain funds may not withdraw some or all of its interest prior to the expiration of the twelfth (12th) calendar month-end following the date of contribution of such capital without being subject to an early
withdrawal fee equal to 7% of the amount withdrawn. Notice of any requested withdrawal must be in writing and received by us at least forty-five (45) days’ prior to the requested withdrawal date. Management fees with respect to Condire Partners are refunded proportionately as of the date of withdrawal to any limited partner permitted or required to withdraw as of any time other than at the end of a calendar quarter. For avoidance of doubt, our policy is to treat investors equally with respect to liquidity and redemption provisions; to the extent any investor has received favorable terms, such terms will be extended to all other eligible investors in the same Fund. COMPENSATION FOR THE SALE OF SECURITIES OR OTHER INVESTMENT PRODUCTS Neither we nor any of our supervised persons accept compensation for the sale of securities or other investment products.
Item 8: Methods of analysis, investment strategies and risk of loss Investment strategies and risks
We generally seek to earn a risk-adjusted rate of return on capital through fundamental research and portfolio management. The Funds are long/short equity focused pursuing fundamental, deep value investments in the broad resources sector and allied industries. The primary focus is on commodity producers with an emphasis on precious metals, mining, energy and other niche segments that the Investment Manager believes are overlooked by most fundamental investors. The Funds may purchase or sell short equities, debt securities, derivative instruments and contracts and other investments. The Funds may take positions in companies with various sized market capitalizations, depending upon the Investment Manager’s analysis of the particular investment opportunity. As a part of their strategy, the Funds may also acquire substantial ownership positions in a company, whether private or publicly traded, and may sell short a substantial percentage of the outstanding shares of a company. The Funds may also invest in Special Investments. Special Investments may involve the purchase of securities of companies involved in publicly announced corporate transactions such as spin-offs, tender offers, mergers, special dividends, restructuring and liquidations, partnership interest, or a variety of other investment vehicles. For a more detailed description of the investment strategy applicable to the Funds, please refer to the Fund’s governing and/or offering documents. CERTAIN RISK FACTORS There can be no assurance that investors will achieve their investment objectives or that investments will be successful. Our investment strategies involve a substantial degree of risk, including risk of complete loss. Nothing in this brochure is intended to imply, and no one is or will be authorized to represent, that our investment strategies are low risk or risk free. Our investment strategies are appropriate only for sophisticated persons who fully understand and are capable of bearing the risks of investment. Prospective investors should consider the following risks, among others, before making any investment decisions. The various risks outlined below are not the only risks associated with our investment strategies and processes and may not necessarily apply to each investor. Investors are urged to consult with their own independent financial, legal and tax advisors before making any investment decisions. With respect to the Funds, the following risks are qualified in their entirety by the risks set forth in the applicable offering documents. Conflicts of Interest and Related Risks. Our activities involve various conflicts of interest, including those related to fees and expenses, allocation of investment opportunities, valuation of portfolio investments, and transactions between client accounts. We seek to address these conflicts through disclosure, policies and procedures, and alignment of interests; however, such measures may not fully eliminate all conflicts. General Economic and Market Conditions. The success of the Funds’ activities is affected by general economic and market conditions, including changes in interest rates, credit availability, inflation, economic uncertainty, changes in laws, trade barriers, currency fluctuations, and national or international political events (including wars, terrorism, or natural disasters). These factors may increase volatility, reduce liquidity, and impair the Funds’ profitability, potentially resulting in material losses even if the Investment Manager reacts quickly. Regulatory Changes Risk. Changes in laws, regulations, or interpretations (e.g., on derivatives, banking, or environmental standards) may increase costs, restrict strategies, or affect portfolio companies, potentially reducing returns. Cross Transactions and Preferential Terms Risk. We may effect cross transactions between client accounts in limited circumstances where we determine that such transactions are in the best interest of both participating clients. These transactions present conflicts of interest because we represent both the buyer and seller and therefore have an incentive to favor one client over another. To address these conflicts, cross transactions are subject to our policies and procedures, which include: (i) a determination that the transaction is appropriate for both clients and consistent with their respective investment objectives; (ii) execution at an independent market price (typically the prevailing closing price) without the payment of any commission or other compensation to us; (iii) documentation of the rationale for the transaction and the benefits to each participating client; and (iv) review and approval in accordance with our compliance policies, including oversight by designated personnel. We maintain records of such transactions, including
the basis for determining that the transaction was effected in the best interest of each client. We do not receive any compensation in connection with such transactions. Additionally, side letters with certain investors may grant preferential terms (e.g., reduced fees). We address these arrangements through most-favored-nation (MFN) provisions where applicable, independent reviews, and fair allocation policies. Underlying Investment Risks Investment Risks in General. All securities investments risk the loss of capital. No guarantee or representation is made that the Funds’ program will be successful. The Funds’ investment program involves, without limitation, risks associated with limited diversification, leverage, interest rates, currencies, volatility, tracking risks in hedged positions, security borrowing risks in short sales, credit deterioration or default risks, systems risks and other risks inherent in the Funds’ activities. Certain investment techniques of the Funds can in certain circumstances substantially increase the impact of adverse market movements to which the Funds may be subject. In addition, the Funds’ investment in securities may be materially affected by conditions in the financial markets and overall economic conditions occurring globally and in particular countries or markets where the Funds invests its assets. The Funds’ methods of minimizing such risks may not accurately predict future risk exposures. Risk management techniques are based in part on the observation of historical market behavior, which may not predict market divergences that are larger than historical indicators. Also, information used to manage risks may not be accurate, complete or current, and such information may be misinterpreted. Concentration. The Funds will invest a substantial portion of its portfolio in companies that are in the natural resource sector, however the Funds may make investments in companies in any industry. Additionally, the Funds are not subject to any diversification restrictions and may at times allocate a substantial portion of its capital to a limited number of securities or other investments. This lack of diversification may expose the Funds to substantial losses in the event the mining sector or one or more concentrated positions experience substantial losses. Silver Teal will invest all or substantially all of its assets in a few securities. As a consequence of this lack of diversification, the aggregate return of the Funds will be substantially adversely affected by the unfavorable performance of the particular securities held by the fund. Limited Diversification and Risk Management Failures. The Investment Manager intends to cause investments by the Funds to be concentrated in a limited number of investments. As a result, the Funds’ portfolio could become significantly concentrated in a limited number of issuers, types of financial instruments, industries, sectors, strategies, countries, or geographic regions, and any such concentration of risk may increase losses suffered by the Funds. At any given time, it is possible that the Funds’ investments or portfolio risks could be concentrated in only a few industries, companies, countries, asset types, strategies or other areas of risk. This limited diversity could expose the Funds to losses disproportionate to market movements in general. Even when the Investment Manager attempts to control risks and diversify the portfolio, risks associated with different assets may be correlated in unexpected ways, with the result that the Funds faces concentrated exposure to certain risks. In addition, many other investment funds pursue similar strategies, which creates the risk that many funds would be forced to liquidate positions at the same time, reducing liquidity, increasing volatility and exacerbating losses. Although the Investment Manager attempts to identify, monitor and manage significant risks, these efforts do not take all risks into account and there can be no assurance that these efforts will be effective. Many risk management techniques are based on observed historical market behavior, but future market behavior may be entirely different. Any inadequacy or failure in the Investment Manager’s risk management efforts could result in material losses for the Funds. Financial and Business Risk of Portfolio Companies. Portfolio investments will involve a significant degree of financial and/or business risk. Companies may be highly leveraged and therefore may be more sensitive to adverse business or financial developments or economic factors. The profitability and survival of portfolio companies may depend on their ability to access sufficient sources of equity or debt at attractive rates, which may or may not be available at any particular time. Portfolio companies also may face intense competition, changing business or economic conditions or other developments that may adversely impact their performance. Business risks may be more significant in lower middle-market companies or those embarking on a build-up or operating turnaround strategy. Some portfolio companies may operate at a loss or have significant variations in operating results, may be engaged in a rapidly changing business or business environment, may require substantial additional capital to support their operations, finance expansion or maintain their competitive position, may be in an early stage of development or may otherwise have a weak financial position. If for any of these or other reasons a portfolio company is unable to generate cash flow to meet its operating or project expenses and working capital requirements, make principal or interest
Item 7: Types of clients
We currently provide investment advisory services to affiliated private pooled investment vehicles (the Funds). The underlying investors in the Funds are typically institutional investors, including but not limited to foundations and endowments, pension plans, fund of funds, and high net worth individuals. In the future, we may provide investment advisory services to additional private pooled investment vehicles or directly to institutional investors. ACCOUNT REQUIREMENTS The minimum initial capital contribution or subscription amount required for an investor in the Funds is generally $1,000,000, although capital contributions or subscriptions of lesser amounts may be accepted at our discretion (subject to applicable law). To invest in the Funds, each investor is required to certify that it is, among other things, an “accredited investor” (as such term is defined in Rule 501(a) of Regulation D under the Securities Act of 1933, as amended), a “qualified client” (as such term is defined in Section 205-3 under the Advisors Act) and a “qualified purchaser” under the Investment Company Act of 1940, as amended. Each investor is required to complete and return various subscription documents to the applicable Fund, which are designed to provide the applicable Fund, the administrator, us and our affiliates and agents with important information about the investor. Subscriptions may be accepted or rejected, in whole or in part, in the sole discretion of the general partner or directors of a Fund.
Item 6: Performance-based fees and side-by-side management Conflicts of interest
As noted under Item 5 above, certain of our affiliates are entitled to receive performance-based fees or allocations from certain of our clients. Performance-based fees or allocations could motivate us, due to our affiliation with such persons, to make investment decisions that are riskier or more speculative than would be the case if these arrangements were not in effect. The method of calculating the performance-based fee or allocation may result in conflicts of interest with respect to the management and disposition of investments, including the sequence of dispositions. In addition, because performance-based fees or allocations with respect to our clients may be calculated on a basis that includes both realized and unrealized appreciation in portfolios based upon values assigned by us, we face a conflict of interest in valuing those portfolios. Our individual employees and affiliates who are compensated to some extent based upon trading profits for which they are responsible face the same potential conflicts. These arrangements present inherent conflicts of interest, including incentives to take greater investment risk and to influence valuation determinations. We seek to address these conflicts through disclosure, internal policies and procedures, valuation controls, and alignment of interests through co-investment by us and our affiliates alongside investors. We address this conflict through full and fair disclosure in applicable governing, offering and/or account documents and/or this brochure, as well as through side letter reviews for fairness and MFN provisions that allow eligible investors to receive equivalent terms.
Item 10: Other financial industry activities and affiliations Conflicts of interest
COMMODITY POOL OPERATOR, COMMODITY TRADING ADVISER, FUTURES COMMISSION MERCHANT REGISTRATION With respect to the Funds, we and our affiliates are exempt from registration with CFTC as a commodity pool operator pursuant to an exemption provided by CFTC Rule 4.13(a)(3). AFFILIATED GENERAL PARTNER Condire Investors, LLC, a Texas limited liability company (the “General Partner”), serves as the general partner of the Domestic Fund, the Master Fund, Condire Alpha and Silver Teal. Accordingly, the General Partner relies or will rely on our registration instead of separately registering as an investment adviser with the SEC under the Advisers Act. ACTIVITIES OF PRINCIPALS Certain principals and employees may serve as directors, officers or committee members (a “Director”) of companies and their activities on behalf of those companies present certain conflicts of interest (including conflicting fiduciary duties) with respect to clients. Board fees and stock received (“Director Compensation”) pursuant to serving as a Director at the request of Condire in support of an existing investment will be for the benefit of the relevant investors in accordance with applicable regulations. From time-to-time, the Principals may serve as a Director of companies in which the Funds have no interest, and in which case any Director Compensation will not benefit any of the Funds. In several instances, the Funds may later take an interest in such companies, which presents certain conflicts of interest (including conflicting fiduciary duties) with respect to clients. Currently, Mr. Schedler or Mr. Shisler serve as Directors (Strategic Metals Ltd., Rockhaven Resources Ltd., and Trifecta Gold Ltd.) where the relationships pre-date investments by the Funds, and in which cases the Director Compensation is retained by the persons serving as Director.
Item 11: Code of ethics, participation or interest in client transactions and personal trading Conflicts of interest
We have adopted and implemented a code of ethics, which sets forth standards of business conduct for our employees and principals. Our code of ethics is primarily designed to educate employees about our philosophy regarding ethics and professionalism, emphasize our fiduciary duties to our clients, require employees to comply with applicable laws, prevent the misuse of material non-public information, the circulation of rumors and other forms of market abuse, and address certain conflicts of interest that could arise from, among other things, personal trading by our employees. In our code of ethics, we impose certain restrictions on all employees and principals relating to the purchase or sale of securities for their own accounts and the accounts of certain affiliated persons. Our code of ethics requires preclearance and quarterly reporting of most personal securities transactions. In addition, our code of ethics requires that all employees submit an annual report of personal securities holdings, except for certain exempt securities. These quarterly and annual reports are reviewed on a regular basis by the Chief Compliance Officer or his delegate. Further, we maintain certain policies and procedures designed to prevent employees and principals from misusing material non-public information, trading the same security ahead of clients and circulating rumors. A copy of our code of ethics is available upon request. PERSONAL TRADING Our code of ethics outlines the policies and procedures that apply to the holding and trading of securities by our employees, principals and access persons (together, the “Covered Persons”). To monitor compliance, personal trades of securities must be approved by the Portfolio Manager and the CCO. While discouraged, our Covered Persons are allowed to hold and trade securities that are also held by the funds and accounts managed by Condire. Such personal trades may be denied if the Portfolio Manager and CCO determine that those trades could have any detrimental effect on the value of the managed fund or account or could be perceived as “frontrunning,” which is the practice of attempting to benefit from recommendations to clients. To prevent this practice, we require pre-approval of, and closely monitor, the investments made by our employees, principals and other access persons. Personal trade pre-approval is generally granted for securities that are not: (i) on our restricted list, (ii) actively being traded by the Funds, (iii) likely to be traded by the Funds during the requested trade window, or (iv) expected to create a conflict of interest or the appearance of “front-running.” Our Covered Persons are generally permitted to invest in private offerings only after the Funds have received their desired allocation to the offerings or the offerings are determined to be unsuitable for the Funds. Private offerings are generally considered unsuitable for the Funds if they: (i) offer exposure considered outside of the investment mandates of the Funds, (ii) offer no or limited prospects for future liquidity, (iii) are a pooled investment vehicle that carries a promoted interest for the manager, or (iv) are generally considered unsuitable for the Fund. Such personal investments require prior CCO pre-approval, including documentation of the rationale, to ensure they are consistent with our fiduciary duties and client interests are not disadvantaged. TRANSACTIONS INVOLVING CONFLICTS OF INTEREST Several of our principals and employees also invest in the Funds as limited partners and may, from time to time, allocate a portion of their compensation to capital contributions to such Funds. We do not generally engage in any principal transactions. Principal transactions require the prior written consent of the CCO and will be conducted in accordance with Rule 206(3) under the Advisers Act. Even if the consent of the CCO is obtained, prior to the initiation and execution of a principal transaction, each Fund must (i) provide information to the client sufficient to identify and explain the potential conflict of interest inherent in such transactions and (ii) obtain the client’s written consent before execution of the transaction. As disclosed above in Item 4, we have caused and may from time to time in the future cause a Fund to invest a portion of its assets in one or more other Funds. In limited circumstances we may engage in cross transactions between client accounts when such transactions are evaluated to be fair and in the best interest of the participating clients, such as being the optimal method of rebalancing a specific position across multiple funds.. Cross transactions are effected at independent market prices and without charging any commission or other fee. All cross transactions require prior written approval of the CCO and are conducted in accordance with the Advisers Act. We ensure fairness through documentation, independent pricing verification, and pro-rata allocations with no preferential treatment to any client.
Item 12: Brokerage practices Conflicts of interest
In general, we have authority to determine the brokers and other counterparties to be used for client transactions and to negotiate commission rates and other monies paid by clients. We select broker-dealers on the basis of obtaining the best overall terms available, which we evaluate based on a variety of factors, including among other things: the ability to achieve prompt and reliable executions at favorable prices; the operational efficiency with which transactions are effected; the financial strength, integrity and stability of the broker; the quality, comprehensiveness and frequency of available research and related services considered to be of value; and the competitiveness of commission rates in comparison with other brokers satisfying our other selection criteria. Research and related services furnished by brokers include written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; statistics and pricing services; discussions with research personnel; and software, databases and other news, technical and telecommunications services utilized in the investment management process. We may pay a commission in excess of that which another broker might have charged for effecting the same transactions, in recognition of the value of the brokerage or research services provided by the broker. Selecting brokers on the basis of considerations which are not limited to applicable commission rates may at times result in higher transaction costs than would otherwise be obtainable. BEST EXECUTION In placing orders for the purchase and sale of securities, we seek best net execution, which includes both commissions and execution prices. Orders are placed with brokers or dealers which we believe to be responsible and provide effective execution of client orders under conditions most favorable to client accounts. SOFT DOLLAR PRACTICES As we are permitted to do so by our clients, Condire may use soft dollars generated by client accounts to pay for certain research and/or related services provided by brokers described above. The term “soft dollars” refers to the receipt by an investment manager of products and services (including research) provided by brokers without any cash payment by the investment manager, which is paid with brokerage commissions for transactions executed for clients of the investment manager. The products and services available from brokers include both internally generated items (such as research reports prepared by employees of the broker) as well as items acquired by the broker from third parties (such as market price quotation services). Using soft dollars to obtain investment research and/or related services creates a conflict of interest between us and our clients. Soft dollars may be used to acquire products and services that are not exclusively for the benefit of clients which paid the commissions and that may primarily or exclusively benefit us. If we are able to acquire these products and services without expending our own resources (including management fees and asset-based fees paid by clients), our use of soft dollars would tend to increase our profitability. Furthermore, we may have an incentive to select or recommend brokers based on our interest in receiving research or other products or services, rather than on our clients’ interest in receiving most favorable execution. We currently have a soft dollar arrangement in place, as we generally have the authority to participate in soft dollar arrangements of general availability through brokers that provide us with research and related services as described above. We may cause clients to pay commissions (or markups or markdowns) higher than those charged by other brokers in return for soft dollar benefits. We will not, however, negotiate higher rates on fees and expenses to be paid by client accounts in exchange for lower rates on fees and expenses to be paid by us. Any soft dollar benefits generally will be used to service all of our clients. We will seek to allocate soft dollar benefits among clients in a fair and equitable manner under the circumstances, but there can be no assurance that we will be successful in this regard. Section 28(e) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), provides a safe harbor to advisers who use soft dollars generated by client accounts to obtain investment research and brokerage services that provide lawful and appropriate assistance to us in the performance of investment decision-making responsibilities. We believe that any soft dollars that we receive in connection with client-related matters are within the limitations set forth in Section 28(e) of the Exchange Act. BROKERAGE FOR CLIENT REFERRALS
In selecting or recommending brokers, we generally do not consider whether we or our related persons receive client or investor referrals from such brokers. ORDER AGGREGATION We aggregate client transactions when possible (i.e., generally, buying or selling the same security for multiple clients on the same day), when advantageous to clients, when not favoring certain clients over other clients and when consistent with the duty of best execution. Our primary consideration is fair and equitable treatment of all clients over time (i.e., average pricing, efficient and effective execution pricing), and not simply lowering commissions. Whenever possible, the discretionary purchase or sale (execution) price of a security bought or sold during the same day effected by the same broker-dealer will be equitably averaged and aggregated with similar discretionary purchases and sales for all participating clients, including our related persons. ALLOCATION OF INVESTMENT OPPORTUNITIES We generally allocate investment opportunities among Funds with a goal of being fair and equitable over time. Each trade ordered by our authorized employee is for the aggregate number of shares for all applicable Funds. At the conclusion of trading each day, our back-office staff receives the trade records from both the online trading tools and executing brokers. Our back-office staff then allocates the number of shares to each applicable Fund or account using our trade allocation spreadsheet model. Profits and losses from “new issues,” as such term is defined under Financial Industry Regulatory Authority (“FINRA”) rules, are allocated only to investors who have represented that they are eligible to participate in such new issues, as contemplated by applicable FINRA rules. Exercising its judgement in good faith, the Investment Committee determines a target portfolio for each Fund that reflects the desired portfolio composition as informed by the overall investment objective and strategy of the Fund and account. Additional factors considered may include an account’s exposure guidelines and available liquidity, regulatory and beneficial ownership constraints, tax considerations, characteristics of the securities involved, the liquidity of the specific opportunity and the markets in which the securities trade, the risks involved, and other factors relevant to each account. The target portfolio model is used to calculate target portfolio weightings as a percentage of capital for each investment position in the account. The target portfolio weightings for each account are compared with the weighting of actual portfolio holdings to determine which positions within an account are under- or overweighted (i.e. out of balance). The Portfolio Manager will only make trades in investments when one or more accounts are out of balance. Each trade is allocated across accounts in order of need, beginning with the account furthest out of balance, progressing to the next most out-of-balance account, and continuing until the trade has been fully allocated. This allocation methodology is designed to bring under or overweight accounts back into balance as equitably as possible. In situations where trades are allocated to only one account, that account will still be the most out-of-balance after receiving the allocation. In situations where trades are allocated to multiple accounts, each of those accounts will be equally out-of-balance after receiving the allocation. TRADE ERRORS We may from time to time make trade errors in the course of managing the Funds’ investments. Trade errors are not errors in judgement, strategy, market analysis, economic outlook or the like, but rather errors in implementing specific trades which we have determined to make. Examples of trade errors include ordering the wrong quantity of shares to be traded, ordering that securities be traded long rather than short, clerical errors, or a miscommunication with the executing broker. It is our general practice to require our personnel to make and implement investment management decisions with the utmost care. Nevertheless, if a trade error occurs, we endeavor to correct the error as soon as possible and in a manner that minimizes losses to our clients. We will determine whether the costs arising from trade errors will be borne either by us or by the respective Funds by applying the standard of liability set forth in each Fund’s respective partnership agreement. In general, however, the Funds will bear the cost of any trade errors.
Item 14: Client referrals and other compensation Conflicts of interest
Except as otherwise described in this brochure, we currently do not receive any compensation from any non-client for providing investment advice or other advisory services to our clients. Condire has previously engaged Old City Securities LLC (“Old City”) to solicit investors for certain Funds. Although our agreement with Old City has lapsed, we continue to pay Old City a fee with respect to certain investors that were previously introduced to the Funds. Investors referred by Old City do not pay higher fees as a result of the referral.
Item 9: Disciplinary information
Not applicable.
Item 13: Review of accounts
Our accounting staff and Investment Committee conduct reviews of all Funds and their investments on at least a monthly basis. With respect to accounting matters, we have engaged a nationally-recognized, independent public accounting firm to conduct an annual audit of the Funds. Fund accounts generally are reviewed monthly to verify total securities held in each brokerage account and confirmed with the totals on our in-house portfolio accounting system. Reviews are performed on asset allocations and performance on a regular basis, in order to maintain the consistency of our investment philosophy and strategy. While we generally conduct reviews of Fund accounts and their investments on at least a monthly basis, we may conduct additional or more frequent reviews in the event of certain material events or circumstances, such as market developments, additions or closings of significant positions in the portfolio and withdrawals or contributions of capital by an investor or client. We generally will provide reports and/or other information to clients upon request. We generally provide investors in the Funds annual audited financial statements, monthly and/or quarterly investor statements, quarterly performance reports and annual U.S. income tax information.
Item 15: Custody
We are deemed to have custody of the Funds’ cash and securities under Rule 206(4)-2 because we or our affiliates serve as general partner and have authority over fund assets. In accordance with the rule, the Funds’ cash and securities (except for certain privately placed securities and private interests) are held with one or more qualified custodians. We may change the custodians at any time and from time to time without the consent of, or notice to, investors. We have engaged a nationally-recognized, independent public accounting firm to conduct an annual audit of the Funds, and audited financial statements (prepared in accordance with generally accepted accounting principles) are provided to investors on an annual basis. Qualified custodians do not provide statements directly to investors in the Funds.
Item 16: Investment discretion
With respect to assets for which we have discretionary authority, we generally have discretionary power and authority over the types of financial instruments to be bought or sold, as well as the amount to be bought or sold on behalf of our clients. We generally have authority to determine the broker-dealer, futures commission merchant or other counterparty to be used for client transactions and the negotiation of commission rates and other consideration to be paid by each of our clients. LIMITED POWER OF ATTORNEY Each investor in the Funds generally grants us or our affiliate a limited power of attorney to enable us to execute the applicable partnership agreement and certain other documents relating to the Funds on its behalf.
Item 17: Voting client securities
We generally have the authority to vote proxies on behalf of our clients. Rule 206(4)-6 under the Advisers Act requires registered investment advisers that exercise voting authority over client securities to implement proxy voting policies and procedures. In accordance with such rule, we have adopted proxy voting policies and procedures in our compliance manual. In general, our policy is to vote proxy proposals, amendments, consents or resolutions in a manner that serves the best interests of our clients, as determined in our discretion, and without regard to our own interests. Investors generally may not direct or otherwise influence our vote with respect to any particular proxy solicitation. We may determine not to vote proxies in respect of securities of an issuer if we determine that it would be in the client’s overall best interest not to vote. Clients may obtain copies of our proxy voting policy, together with information regarding how we have voted past proxies, by contacting us. CONFLICTS OF INTEREST Where a material conflict of interest has been identified, we will take into account the interests of the applicable clients, vote securities in a manner that serves the best interests of such clients, as determined in our discretion, and document the basis for our decision.
Item 18: Financial information
Not applicable.
General Information PRIVACY POLICY We have adopted policies and procedures that we believe are reasonably designed to protect various records and information of clients and investors. Except as set forth in the applicable offering materials and/or account documents and as otherwise authorized by each client and/or investor, private information about clients and investors is disclosed only as permitted by applicable law to our affiliates and service providers, including our accountants, attorneys, brokers, custodians, transfer agents and any other parties whose services are necessary or convenient to the operation of the Funds. Notice of our privacy policy is provided to clients and investors and is available to clients and investors upon request.
Timeline
- Oct 6, 2017Founded Condire Management, LP is founded2
Filings
26 filings to the SEC since October 2021: 26 other. The latest 20:
- Aug 24, 2026N-PX EDGAR
- Aug 20, 202613F-HR/A EDGAR
- Aug 14, 202613F-HR EDGAR
- May 15, 202613F-HR EDGAR
- Feb 17, 202613F-HR EDGAR
- Nov 14, 202513F-HR EDGAR
- Aug 29, 2025N-PX EDGAR
- Aug 14, 202513F-HR EDGAR
- May 15, 202513F-HR EDGAR
- Feb 14, 202513F-HR EDGAR
- Nov 14, 202413F-HR EDGAR
- Aug 30, 2024N-PX EDGAR
- Aug 14, 202413F-HR EDGAR
- May 15, 202413F-HR EDGAR
- Feb 15, 202413F-HR EDGAR
- Nov 15, 202313F-HR EDGAR
- Aug 14, 202313F-HR EDGAR
- May 15, 202313F-HR EDGAR
- Feb 14, 202313F-HR EDGAR
- Nov 21, 202213F-HR/A EDGAR
The 26 filings since October 2021 can be filtered by form type and year here when JavaScript is on.
Every filing from the last five years, summarized. The full record is on SEC EDGAR.
Stakes it holds
Condire Management, LP has told the SEC it owns more than 5% of 6 companies, latest first (Schedules 13D and 13G).
- NexMetals Mining Corp.SCHEDULE 13G Feb 3, 20265
- i-80 Gold Corp.SCHEDULE 13G/A Aug 14, 2025 to Nov 14, 20256
- Osisko Gold Group Inc.SCHEDULE 13D/A Feb 4, 2025 to Aug 19, 20257
- Gatos Silver, Inc.SC 13G/A Feb 14, 2024 to Nov 8, 20248
- Rayonier Advanced MaterialsSC 13G/A Feb 14, 2022 to Feb 14, 20249
- Golden Star ResourcesSC 13G/A Feb 14, 202210
Sources
The numbers on this page point here. Each one links to the record it came from.
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