Private company

Delos Capital Management, LP

Last updated Oct 21, 2026.

Overview

Corporate structure

Delos Capital Management, LP sits at the top of its group. 2 entities, 1 country on record. Switch between the flow chart and the network, and select any entity to see its details.

Major holders of Delos Capital Management, LP

  • Matthew Robert Constantino Owns 75% or more of Delos Capital Management, LP, since 08/2013 (Form ADV)

Built from major holders from Schedules 13D and 13G; stakes of 5% or more it reported on Schedules 13D and 13G (1 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

Delos Capital 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$169.6M2 3 accounts, all with discretion
  • Employees12 6 in investment advice or research
  • ClientsPooled investment vehicles (other than investment companies and: 3 ($169.6M)
  • 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 assetsYes: cash and securities
  • RegistrationSEC 801-100478, CRD 170010 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).

  • Matthew Robert Constantinoowns 75% or more, since 08/2013
  • Matthew Robert Constantinoowns 75% or more of DELOS CAPITAL, LLC, since 10/2012

In its own words: the client brochure

Form ADV Part 2A, the plain-English document an adviser must give its clients, quoted as filed 3/31/2026.3 It covers the firm’s services, fees, investment strategies and their risks, and its conflicts of interest.

Item 4: Advisory business Services

Delos is a private equity firm established in September 2013 under the laws of the State of Delaware as a Limited Partnership. Headquartered in New York, New York, the firm is led by Matthew Constantino who is the principal owner of Delos and controls the policies of Delos. Delos serves as an investment adviser that provides investment advisory services to Delos Investment Fund, LP (“Fund I”) and Delos Investment Fund II, LP (“Fund II” together with Fund I, and, in certain cases, Co-Investment Funds referred to below, each a “Fund” and collectively the “Funds”). Delos has also established other private pooled investment vehicles that co-invest alongside the Funds in certain investments (each a “Co-Investment Fund,” collectively the “Co-Investment Funds,” and together with the Funds, each a “Client” and collectively the “Clients. Delos LSI Co-Investors, LP (“LSI CoInvestors’) invests parallel with Fund II into a single portfolio company. Delos Pioneer Co-Investors LP is a stand-alone Co-Investment Fund. The Funds target equity returns by investing in complicated processes through control buyouts, strategic partnerships and distressed buyouts in companies with approximately $10 to $40 million of EBITDA. The Firm is a limited partnership organized under the laws of Delaware. The limited partners in the Funds and other Clients are the “Investors.” Delos Fund GP, LLC is the general partner of Fund I and Delos Fund II GP, LLC is the general partner of Fund II (together with Delos Fund GP, LLC, the “General Partners”). Each Client is managed in accordance with its own investment objectives, strategies, restrictions, and guidelines and is not tailored to the needs of any individual any individual Investor. Information about each Fund can be found in its respective offering documents (the “Offering Documents”). We do not participate in wrap fee programs. As of December 31, 2025, the Firm’s regulatory assets under management were approximately $169.6 million, all of which are managed on a discretionary basis.

Item 5: Fees and compensation Fees

We generally are compensated for our advisory services to the Funds based on a percentage of assets under management and performance-based compensation. Compensation terms for Clients other than Funds are negotiated with the participating Investors and generally differ from the arrangements applicable to the Funds. Management Fee Each Fund generally pays us an annual advisory fee (“Management Fee”) equal to 2.0% of the capital commitments during its specified investment period. Following the end of the investment period, each Fund’s Management Fee is equal to 1.5% of the cost basis of each Fund’s investments. We have waived or reduced the Management Fee for certain Investors and may in the future agree with other Investors or prospective investors to waive, reduce or otherwise alter the Management Fee. The Management Fee charged by any Fund may be reduced by all or a portion of any origination, transaction, break-up or similar fees that we may receive as described in the relevant Offering Documents.

Each Fund’s Management Fee is payable quarterly in advance from drawdowns of the Investors’ unfunded capital commitments or by withholding the amount of such fee from the investment proceeds that would otherwise be distributable to the Investors. For Fund II, we expect to make periodic elections to waive a portion of the Management Fee in exchange for a contingent “profits interest” in the Fund representing a pro rata share (based on the amount of waived fees) of future Fund profits after return to the Investors of all invested capital (including amounts contributed by Investors in lieu of the waived fees). Carried Interest The General Partners, affiliates of the Firm, are apportioned carried interest distributions from the respective Fund (“Carried Interest”) based on the net cash proceeds attributable to such Fund’s investments. We have waived or reduced the Carried Interest as to certain Investors and may in the future agree with an Investor or prospective Investor to waive, reduce or otherwise alter the Carried Interest. The Carried Interest is typically 20% of the profits earned by the relevant Fund on investments following a preferred return to the Investors. The Carried Interest is also subject to a catch-up on the preferred return and a clawback if the aggregate distributions exceed the stated carried interest rate. Investors and prospective investors should refer to the Fund’s Offering Documents for additional or supplementary information regarding the Fund as well as the fees paid by the Fund. Expenses Organizational Expenses

Each Fund bears all legal and other expenses incurred in the formation of the Fund and the offering of the interests up to an amount of $750,000, with respect to Fund I, and $1,250,000, with respect to Fund II. Organizational expenses in excess of this amount, and any placement fees, are paid by the relevant Fund but borne by the Firm through a 100% offset against the Management Fee. Operating Expenses

The Firm pays all normal operating expenses incidental to the provision of the day-to-day administrative services to its Clients, including its own overhead. To the extent practicable, third-party costs are charged to each Fund and its portfolio companies. Each Fund pays all costs, expenses and liabilities in connection with its operations, including: fees, costs and expenses related to the purchase, holding and sale of portfolio investments (to the extent not reimbursed); expenses incurred in connection with transactions not consummated; maintenance of books and records; transaction fees; travel costs; research and other trading costs; expenses of internal staff of Delos and its affiliates; insurance premiums; taxes; fees and expenses of accountants, counsel, advisers, finders, search companies and consultants; costs and expenses of the advisory committee and the annual meeting; regulatory filings by the Firm related to the activities of the Funds; litigation expenses; and other extraordinary expenses. The Firm and its affiliates generally charge each Fund’s portfolio companies transaction fees and monitoring fees and may charge portfolio companies advisory fees, break-up fees and other similar fees. An amount equal to the Fund’s allocable share of all such fees and of all directors’ fees paid by portfolio companies that are received by the Firm, its affiliates or any of their employees, net of any unreimbursed expenses incurred by the Firm or its affiliates in connection with unconsummated transactions and net of a pro rata portion allocable to the investment in the Fund by the General Partner and its principals, will be applied to reduce the Management Fee otherwise payable by the relevant Fund. All such fees will be

allocated among the Fund and any related Co-Investment Funds on the basis of capital committed by each to the relevant investment. If the Co-Investment Fund is not charged a management fee, the portion of such fees that would otherwise offset the Co-Investment Fund’s management fee may be retained by the Firm and its affiliates and will not be used to further reduce the Management Fee. Management Fee reductions will be carried forward if necessary and any unapplied balance will be refunded to the relevant Fund and returned to Investors upon termination of such Fund. In addition, the Funds may enter into letter agreements or other similar arrangements (collectively, “Side Letters”) with one or more Investors that have the effect of establishing rights under, or altering or supplementing the terms of the governing documents of the Funds as they apply to a particular Investor. As a result of such Side Letters, certain Investors may receive additional benefits that other Investors will not receive, including without limitation better economic terms such as a reduced or otherwise more favorable management fee and/or carried interest, co-investment rights, information rights and transfer rights. The other Investors will have no recourse against the Funds or any of its affiliates in the event that certain Investors receive additional or different rights or terms as a result of such Side Letters. Investors will be required to make certain representations when investing in a Fund, including but not limited to: (i) they are acquiring an interest for their own account, (ii) they received or had access to all information they deem relevant to evaluate the merits and risks of the prospective investment, and (iii) they have the ability to bear the economic risk of an investment in the Fund. Each Investor will be furnished with a copy of the Offering Documents other agreements.

Item 8: Methods of analysis, investment strategies and risk of loss Investment strategies and risks

Methods of Analysis and Investment Strategies Each Fund targets equity returns by investing in complicated processes through control buyouts, strategic partnerships and distressed buyouts in companies with approximately $10 to $40 million of EBITDA. The Funds invest primarily in equity securities that provide control over key decisions at the portfolio level but maintain the flexibility to invest through alternative securities with a specific objective of achieving equity-like returns and substantive control in each investment. Delos seeks to be more flexible and opportunity-driven than traditional lower-middle market private equity funds and the investment team also brings a large-cap private equity perspective, innovative solutions and best practices to targeted lower-middle market companies. The Funds target investments in companies in well-established businesses with high return on invested capital in areas including the chemicals, packaging, industrials and consumer sectors. The Funds focus on complex situations, including capital structure complexities, comprehensive structured solutions, assetspecific complexities, multi-party negotiations (debt and equity), niche business models and governance challenges. Through the investment team’s deal experience, they have developed strong core competencies in the structuring, negotiation and execution of such complex processes and have demonstrated the ability to execute on opportunities through all market cycles. In addition, Delos seeks to grow portfolio companies through strategic acquisitions and organic growth investments. Risk of Loss Factors Investing in securities involves risk of loss that Investors should be prepared to bear. Investors should consider the following factors before investing in a Fund. The following list of risk factors does not purport to be a complete enumeration or explanation of the risks involved in an investment in the Funds. Prospective investors are urged to consult their professional advisers and review the legal documents for the Funds, including the relevant Fund’s Offering Documents and informational materials, before deciding to invest. References to “the Fund” below should be deemed to include references to Fund I, Fund II, and, as context requires, USF Co-Investors. Speculative Nature of Investments. The Funds’ investments are subject to the risks inherent in all private equity investments. Portfolio companies may not be profitable at the time of investment and may experience substantial fluctuations in their operating results. Certain portfolio companies may not have significant operating revenues. The success of some portfolio companies will depend on the management talents and efforts of one person or a small group of persons whose death, disability or resignation would adversely affect the business. Portfolio companies may have highly leveraged capital structures that make them more vulnerable to adverse financial or business developments than less highly leveraged companies. Investments in Troubled and Leveraged Companies. A Fund may invest in securities of financially troubled companies and securities of highly leveraged companies. While these securities are likely to be particularly risky, they also may offer the potential for high returns that correspond with the level of risk. Under certain circumstances, payments to the Fund and distributions by the Fund to its Investors may be reclaimed if any such payment is later determined to have been a preferential payment or a fraudulent

conveyance. Such instances generally occur when a company enters, or is forced into, bankruptcy proceedings or otherwise defaults on their debt obligations. Portfolio Company Size. Companies with smaller market capitalizations, including small- and mid-cap companies, may have limited product lines, markets or financial resources, may lack the competitive strength of larger companies or may lack managers with experience or depend on a few key employees. These less established companies may face intense competition, including competition from established companies with much greater financial and technical resources, more extensive development, manufacturing, marketing, and service capabilities, and a greater number of qualified personnel. Less established companies tend to have lower capitalizations and fewer resources and, therefore, often are more vulnerable to financial failure. These companies require considerable additional capital to develop, acquire customers and achieve or maintain a competitive position. This capital may not be available at all or on acceptable terms. Further, such companies may not develop as anticipated, even after substantial expenditures of capital. Service on Boards of Directors, Material Non-Public Information, Etc. Individual members of the Firm may serve as officers or directors of portfolio companies. In their capacity as officers or directors (or even simply by virtue of a Fund’s status as a significant owner of a portfolio company), such individuals may become subject to fiduciary or other duties which adversely affect a Fund. For example, a Fund may be unable to sell or otherwise dispose of an investment if a member of the Firm is in possession of material, non-public information relating to the issuer thereof. Significant Positions. In the event a Fund acquires a significant position in a company, the Fund’s position could become illiquid due to the thinness of any secondary market for the security and/or the Fund having obtained inside information regarding the company which could make it difficult from a legal perspective to sell the securities involved. The illiquid nature of such securities would limit, or prevent, the Fund from realizing what the Firm believes to be an accurate valuation resulting in positive, or any, returns to investors. In addition, maintaining a significant position could require the Fund to make various disclosure filings in the jurisdictions in which the subject company’s securities are traded. Multi-Jurisdictional Accounting and Financial Reporting. A Fund may invest in securities issued by companies located in various jurisdictions and each jurisdiction may have its own system of accounting and financial reporting. The systems may differ from that of the Fund’s jurisdiction or from that of each Investor’s home country, causing difficulties in reconciling accounting and financial reports. Such difficulties may make it difficult for the Firm to accurately assess the profitability of its investments. Minority Investments. A Fund may make minority equity investments in portfolio companies where the Fund may not be able to protect its investment or effectively control or influence the business or affairs of such entities. The Fund may be adversely affected by action taken by the owners exerting significant influence and/or control of the portfolio companies in which it invests. Opposition of management or existing shareholders of portfolio companies, especially in the absence of an effective legal framework to protect minority shareholder rights, could jeopardize a Fund’s ability to maximize the value of its investments. Lack of Diversification. Since each Fund may only make a limited number of investments, and since a Fund’s investments generally will involve a high degree of risk, poor performance by a few of the investments or even one investment could severely affect the total returns to the Investors. There is no guarantee that portfolio investments will be completely geographically diversified, so even localized downturns or disruptions in the market could have significant adverse consequences for the Fund’s portfolio.

Liabilities Upon Disposition. In connection with the disposition of an investment, a Fund may be required to make representations about the business and financial affairs of a portfolio company typical of those made in connection with the sale of any business or be responsible for the content of disclosure documents under applicable securities laws. It may also be required to indemnify the purchasers of such investment or underwriters to the extent that any such representations or disclosure documents turn out to be inaccurate. These arrangements may result in contingent liabilities, which might ultimately have to be funded by the Investors to the extent that the Investors have received prior distributions from a Fund. Each Fund’s limited partnership agreement provides that if there is any such liability in respect of a portfolio company, it will be funded by the Investors to the extent that they received distributions from the Fund. Difficulty in Valuing Funds’ Investments. The Funds’ investments in many cases will be difficult to value due to various factors, including absence of readily ascertainable market values and limited sources of useful valuation information. In addition, the appraised value of an asset may not always be consistent with, and therefore may be higher or lower than the price at which the asset could ultimately be sold. The Firm will use its judgment when determining the valuation of investments which may in certain instances be highly subjective. There can be no guarantee that the Firm will be able to realize an investment at stated valuations. Restrictions on Transfer and Withdrawal. The interests in the Funds are subject to restrictions on transferability and resale and may not be transferred or resold without either registration under the Securities Act, any applicable state securities laws and any non-U.S. securities laws, or pursuant to an exemption therefrom. In addition, transfers are subject to the consent of the relevant General Partner (which may be withheld at its sole discretion) and other terms and conditions of the partnership agreement. Investors should expect to bear the financial risks of an investment in the Fund for an indefinite period of time. There is no public market for the interests in the Funds and none is expected to develop. These interests have not been and will not be registered under the Securities Act or any other securities laws. Moreover, these interests will not be listed on any public exchange; therefore, Investors may not be able to liquidate their investments prior to the end of each Fund’s term. Investors may not withdraw capital from the Funds. Passive Investment. To safeguard their limited liability, the limited partnership agreement prohibits the Investors (as limited partners) from controlling or managing the affairs of the Funds, including investment and disposition decisions. Generally, Investors will not be able to implement limitations upon the Firm’s ability to manage the Funds. Investors must rely entirely on the General Partners and the Firm to conduct and manage the affairs of the Funds. Dependence on Key Personnel. The Funds’ success depends in large part on the performance of the relevant General Partner, the Firm, and key employees. The loss of any key personnel could have a material adverse effect on the Funds. Regulation & Litigation. The Firm participates in a highly regulated industry and is subject to regulatory examinations in the ordinary course of business. There can be no assurance that the Firm will avoid regulatory investigation and possible enforcement actions stemming therefrom. There is a material risk that applicable governmental authorities and regulators in the United States and other jurisdictions will continue to adopt new laws or regulations, change existing laws or regulations or enhance the interpretation or enforcement of existing laws and regulations in a manner that is burdensome for the Firm and the Funds. Such risks are often difficult or impossible to predict, avoid or mitigate in advance. As a result, there can be no assurance that any of the foregoing will not have an adverse impact on the

Read the rest in the brochure

Item 7: Types of clients

Delos provides investment advisory services to pooled investment vehicles. Investors in our Clients may include a variety of institutional investors and high-net-worth individuals satisfying the exceptions and exemptions under which each Client operates. We require prospective investors to make representations concerning their financial sophistication and ability to bear the risk of loss of their entire investment. The minimum initial investment in each Client is generally $5,000,000; however, lesser amounts may be accepted in our sole discretion. Generally, the limited partnership agreement has restrictions on raising successor funds until the specified investment period ends or until existing funds are sufficiently invested; however, parallel funds may be created for Investors with certain investment requirements. Our Investors must be “accredited investors” under Regulation D of the Securities Act of 1933 (the “Securities Act”), as amended, be able to enter into a performance fee arrangement under the Advisers Act (i.e., they must

be qualified clients under Rule 205-3 of the Advisers Act) and be “qualified purchasers” under Section 2(a)(51)(A) of the Investment Company Act of 1940, as amended.

Item 6: Performance-based fees and side-by-side management Conflicts of interest

As described above, the General Partners receive performance-based compensation in the form of Carried Interest distributions from their respective Funds. For a discussion of our Carried Interest and performance-based compensation received from the Funds, please refer to Item 5 above. Compensation based on performance will only be charged in accordance with the provisions of Rule 205-3 under the Investment Advisers Act of 1940, as amended (“Advisers Act”). Performance-based compensation may create an incentive for a General Partner to make more speculative investments and make different decisions regarding the timing and manner of the realization of such investments than would be the case if such carried interest were not allocated to the General Partner. However, the Firm believes that the capital the Firm invests alongside Investors mitigates this risk.

Item 10: Other financial industry activities and affiliations Conflicts of interest

Delos nor its management persons have an application pending to register as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor or an associated person of the foregoing entities. Delos is affiliated with the General Partners. These affiliates provide investment management services to the Funds and are included in Delos’s investment adviser registration with the SEC. Delos or its General Partners will be responsible for all decisions regarding portfolio transactions of the Funds and have full discretion over the management of each Fund’s investment activities. The General Partners’ investment advisory activities are subject to the Advisers Act and the rules thereunder. In addition, employees and persons acting on behalf of the General Partners are subject to the supervision and control of Delos. Thus, the General Partners, all of their employees and the persons acting on their behalf would be "persons associated with" the registered investment adviser so that the SEC could enforce the requirements of the Advisers Act against the General Partners. In addition, supervised persons of Delos may serve as directors and officers of certain portfolio companies and, in that capacity, will be required to make decisions that consider the best interests of such portfolio companies and their respective shareholders. In certain circumstances, for example in situations involving bankruptcy or near-insolvency of a portfolio company, actions that may be in the best interests of the portfolio company may not be in the best interests of the respective Fund and vice versa. Accordingly, in these situations, there will be conflicts of interest between such individuals’ duties as a supervised person of Delos and such individuals’ duties as a director or officer of such portfolio company. Delos does not recommend or select other investment advisers for Clients.

Item 11: Code of ethics, participation or interest in client transactions and personal trading Conflicts of interest

Trading Code of Ethics & Personal Trading Pursuant to Rule 204A-1 of the Advisers Act, we have adopted a Code of Ethics and employee investment policy that establish various procedures with respect to investment transactions in accounts in which employees of Delos or related persons have a beneficial interest or accounts over which an employee has investment discretion. The foundation of the Code of Ethics is based on the underlying principles that: -

Employees must at all times place the interests of the Clients first; Employees must make sure that all personal securities transactions are conducted consistent with the Employee Investment Policy; and Employees should not take inappropriate advantage of their position at Delos.

Delos’s supervised persons, as defined by Rule 204A-1, must have written clearance for all transactions involving initial public offerings, private placements and certain publicly traded securities before completing the transactions. Delos may disapprove any proposed transaction, particularly if the transaction appears to pose a conflict of interest or otherwise appears improper. Delos also endeavors to maintain current and accurate records of all personal securities accounts of its supervised persons in an effort to monitor all such activity. Under the Code of Ethics Supervised Persons must also disclose certain trading activity, outside business activities, gifts and entertainment and political contributions. In addition, employees are subject to annual and quarterly reporting requirements for personal investment accounts. All supervised persons are required to certify their compliance with the Code of Ethics upon hire and on at least an annual basis thereafter. Our Code of Ethics is available to Clients upon request. Participation or Interest in Client Transactions Delos or its related persons may engage in securities transactions with certain Investors or may recommend investments in portfolio companies in which the Firm or a related person has a beneficial or financial interest. Such transactions may include co-investment opportunities in portfolio companies which are offered to some but not all Investors, and/or our advisory personnel or employees. Key personnel of the Firm generally will also be invested directly or indirectly in the Funds offered to outside Investors, subject to applicable law, and the performance-based compensation and/or management fees payable by such vehicle may be separately negotiated by us. In addition, our assets may be invested in securities of portfolio companies in which one or more other Clients hold positions. We will disclose these potential conflicts of interest to Investors and prospective investors in the Offering Documents of the particular Client. Delos and its employees generally do not intend to buy securities from or sell securities to its Clients (i.e., engage in principal transactions). Engaging in principal transactions could create a conflict of interest between Delos and its Clients because Delos and/or its employees could benefit from such a purchase or sale by a Client. Delos has established policies and procedures relating to principal transactions in accordance with the Advisers Act and will not engage in a principal transaction without first providing

appropriate disclosure, determining the valuation and obtaining the informed consent of such Client prior to the consummation of such transaction.

Item 12: Brokerage practices Conflicts of interest

As an adviser to private equity funds, we generally do not make investments in securities listed on national exchanges. While we primarily make investments directly with private issuers, there may be situations where we place a trade(s) through a broker, particularly if there has been a liquidity event in a portfolio holding. In such an event, we will seek “best execution” in light of the circumstances involved in transactions. In selecting a broker for any transaction, we may consider a number of factors, including, for example, the broker’s reputation, net price or spread, financial strength and stability, market access, efficiency of execution and error resolution, and the size of the transaction. We will not be obligated to obtain the lowest commission or best net price for a client on any particular transaction. We will monitor transaction results as orders are executed to evaluate the quality of execution provided by the various brokers and dealers that we would use in order to determine that commission rates are competitive and otherwise to evaluate the reasonableness of the commission rates paid to those brokers and dealers in light of all the factors described above. We do not have any formal or informal soft dollar arrangements, nor do we receive any soft dollar benefits from any broker, dealer or other counterparty. Additionally, we do not permit Clients to direct brokerage to any particular broker.

Item 14: Client referrals and other compensation Conflicts of interest

Compensation by Non-Clients We or our affiliates receive certain fees from portfolio companies in connection with the purchase, monitoring or disposition of investments or in connection with unconsummated transactions (e.g., transaction, directors’, consulting, management, investment banking, advisory, closing, topping, break-up and other similar fees). A portion of these amounts, net of related expenses, will be credited against the Management Fee payable to us by the relevant Fund. Please see the Management Fee section of “Item 5: Fees and Compensation” above. Such fees give the Firm an incentive to manage investments in a manner that leads to the continuation of the fee income. Delos manages such conflict by acting at all times consistent with the Firm’s fiduciary duty to its Clients and through aligning Firm interest with Fund interests via investment in the Funds. Compensation for Client Referrals Delos does not compensate any person for client referrals. However, during future fundraising cycles, Delos may compensate placement agents who introduce new Investors that commit capital to a Fund. Any fees and expense reimbursements payable to any such placement agents are generally borne by Delos through an offset against management fees payable by the relevant Fund.

Item 9: Disciplinary information

Neither we nor any of our management personnel are subject to or have in the past been subject to any criminal or civil action in any domestic or foreign court and neither we nor any of our management personnel have been subject to any administrative proceedings before the SEC or any other state, federal or foreign financial regulatory authority.

Item 13: Review of accounts

Review of Accounts We review each Client’s portfolio on a continual basis. We engage in active management of our Clients and, accordingly, our chief financial officer reviews our transactions, positions and cash balances on a monthly basis. Reporting In addition to receiving periodic reports from Delos, such as quarterly unaudited financial statements, each Investor in a Fund or other Client for which we have actual or constructive custody of cash or securities will receive the relevant Client’s audited financial statements within 120 days of such Fund’s fiscal year end (see Item 15: Custody).

Item 15: Custody

Certain Fund assets are held in custody by unaffiliated broker/dealers or banks, however Delos has access to client accounts since it or an affiliate serves as the General Partner of each Fund. Delos is therefore deemed to have custody under the Advisers Act. To ensure compliance with Rule 206(4)-2 under the Advisers Act, we will be required to provide all Investors in such Clients with audited financial statements for the Funds within 120 days of each Fund’s fiscal year end. In addition, the financial statements must be audited by an independent accounting firm that is registered with, and subject to review by, the Public Company Account Oversight Board in accordance with U.S. Generally Accepted Accounting Principles. Investors and prospective investors should carefully review the audited financial statements of the relevant Fund.

Item 16: Investment discretion

Subject to any investment restrictions set forth in the Offering Documents, we have discretionary authority to make investment decisions for the Clients. Our discretionary authority is derived from our authority as the investment manager of each Client and pursuant to an investment management agreement entered into by Delos, the General Partner and the relevant Client. Any limitations on authority are included in the Fund’s Offering Documents, including Side Letters with particular Investors.

Item 17: Voting client securities

Delos has adopted and implemented written policies and procedures governing the voting of client securities in accordance with its fiduciary duty to clients and Rule 206(4)-6 of the Advisers Act. Each Client is primarily invested in privately-held portfolio companies that do not typically issue proxies. However, in the event proxies are required to be voted, the proxies/corporate actions will be reviewed and analyzed by our investment professionals. Prior to voting, we will make a determination, in our opinion, as to what vote is in the best interest of the Client. We will maintain a written record of the proxy/corporate action vote on each occasion that a vote is required. If there is a material conflict present the Chief Compliance Officer of the Firm will discuss such conflict with the investment team members responsible for voting such proxy and document the outcome. In certain instances, if a conflict should be fully avoided, the Firm may abstain from voting a proxy. Upon request, we will provide our Clients and prospective clients with a copy of our proxy voting policies and procedures and/or a record of all proxy votes cast by the Funds.

Item 18: Financial information

Delos does not require or solicit prepayment of more than $1,200 in fees per client six months or more in advance. We have never filed for bankruptcy and are not aware of any financial condition that is reasonably likely to impair our ability to meet our contractual obligations to our Clients.

Stakes it holds

Delos Capital Management, LP has told the SEC it owns more than 5% of 1 company, latest first (Schedules 13D and 13G).