Private company

HHLR ADVISORS, LTD.

Limited company registered in the Cayman Islands, active since 2012. Summary from the record

Last updated Oct 21, 2026.

Overview

  • HeadquartersGeorge Town, Cayman Islands2
  • Legal formcompany limited by shares2
  • LEI549300YXBX8YW9XQIP322
  • StatusActive2
  • LEI statusIssued and current2
  • Registered addressP.O. Box 10240, Harbour Place, 103 South Church Street, KY1-1002 George Town, Cayman Islands2
  • Registered withGeneral Registry, 2726062

Corporate structure

HHLR ADVISORS, LTD. is part of a group headed by Hillhouse Group Limited. 44 entities, 6 countries on record. Switch between the flow chart and the network, and select any entity to see its details.

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 (22 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

HHLR ADVISORS, LTD. 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.

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).

  • HILLHOUSE GROUP LIMITEDowns 75% or more, 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 3/31/2023.5 It covers the firm’s services, fees, investment strategies and their risks, and its conflicts of interest.

Item 4: Advisory business Services

Overview Founded in October 2012, HHLR Advisors, Ltd. (“HHLR”) provides investment advice to clients organized as privately-offered pooled investment vehicles or similar structures (the “Funds”) and to certain managed accounts or similar relationships. The Funds and all such HHLR-advised managed accounts are referred to herein as “clients.” HHLR is a wholly-owned subsidiary of Hillhouse Group Limited, which itself is a wholly owned subsidiary of Hillhouse Group Holdings Limited. Mr. Lei Zhang directly owns 100% of Hillhouse Group Holdings Limited. HHLR is part of the “Hillhouse Investment Group,” a multinational group of related advisory entities. To comply with local operational requirements (including the issuance of local work visas), HHLR engages local affiliates, including those based in Hong Kong (Hillhouse Investment Management Limited), the People’s Republic of China (the “PRC” or “China”) (Hillhouse (Beijing) Advisory Limited and Shanghai Gaoling Equity Investment Management Ltd.), Singapore (HHLR Management Pte. Ltd.), the Cayman Islands and the United States (“U.S.”) (Altitude Crest Partners Inc.). While these local affiliates are not registered as investment advisers with the United States Securities and Exchange Commission (the “SEC”), HHLR subjects these local affiliates’ personnel to its compliance policies and deems their books, records, and personnel to be within the scope of HHLR’s retention and production obligations. Another HHLR affiliate, Hillhouse Investment Management, Ltd. (“HIM”), which is discussed in Item 10, is registered as an investment adviser with the SEC. While the investment programs and activities of HHLR and HIM overlap, HHLR generally focuses more on publicly-listed (or similarly liquid) investment opportunities, while HIM generally focuses more on less liquid investment opportunities, including venture capital, private equity, private debt and buyout transactions. HHLR and HIM also share certain policies, personnel and resources. Accordingly, certain information on HHLR contained in this Brochure, including information regarding personnel, is presented on an aggregate basis for HHLR, HIM, and the local affiliates. Investment Philosophy and Strategies HHLR’s investment philosophy is to seek long-term, risk-adjusted returns through bottom-up analysis and fundamental proprietary research. As part of HHLR’s bottom-up analysis, it performs both qualitative and quantitative assessments of potential investments with a particular focus on opportunities upon which it can gain insights and discover value in an ever-changing world. In general, HHLR’s client portfolios generally focus on publicly-listed (or similarly liquid) investment opportunities and certain HHLR clients primarily invest in securities and other

investment instruments that are traded on exchanges within the PRC (“A Share Investments”). However, client portfolios may also hold investments in illiquid or less-liquid investments. While HHLR applies its general investment philosophy across all of its clients’ accounts, it operates numerous investment strategies by tailoring investment programs and trading and investment decisions for each client account. Investment strategies that HHLR provides vary across clients and may vary over time. Markets and Investment Opportunities HHLR primarily invests for client accounts in equity and debt securities, but could, and does, invest in a wide range of securities and other financial instruments including, without limitation: share capital; common and preferred stock (privately-placed and exchange-traded); shares of beneficial interest; partnership interests and similar financial instruments; bonds, notes, debentures and other debt instruments (whether subordinated, convertible, or otherwise); commodities; currencies; interest rate, currency, commodity, equity, debt, and other derivative products (including, without limitation, (i) futures contracts (and options on futures contracts) relating to stock indices, currencies, other financial instruments, and all other commodities, (ii) swaps, participatory notes, options, warrants, caps, collars, floors, and forward rate agreements, (iii) spot and forward currency transactions, and (iv) agreements relating to or securing such transactions); equipment lease certificates; equipment trust certificates; loans; accounts and notes receivable and payable held by trade or other creditors; trade acceptances; contract and other claims; executory contracts; participations; mutual funds; money market funds; structured securities; repurchase agreements; obligations of governments and instrumentalities; commercial paper; certificates of deposit; bankers’ acceptances; trust receipts; choses in action; real estate, including fee interests, leaseholds, mortgages, or other real estate assets; and any other obligations and instruments or evidences of indebtedness of whatever kind or nature; in each case, of any person, corporation, government, or other entity whatsoever, whether or not publicly traded or readily marketable. At times, HHLR makes investments for client accounts that are not freely tradeable or do not have a readily ascertainable market. HHLR invests client assets in a wide range of countries, markets and exchanges in Asia and throughout the world. Clients also face indirect exposure to some or all of the instruments and investments listed above through investments in special purpose vehicles and similar entities. Advisory Services HHLR manages both discretionary and non-discretionary client accounts. HHLR manages client accounts in accordance with any investment restrictions or guidelines set forth in the offering documents for each Fund or, for non-Fund clients, in accordance with the authority delegated to it (including any limits on that authority) under the applicable client’s investment management agreement or governing documents. HHLR consults with each client on its investment objectives and strategies and tailors its services and advice to those objectives and strategies. HHLR had approximately $41.43 billion of assets under management as of December 31, 2022, with approximately $0.40 billion managed on a non-discretionary basis and $41.03 billion managed on a discretionary basis. The amount of assets under management reported in this

Brochure is lower than the amount of “regulatory assets under management” that HHLR reports in Part 1, Item 5 of its Form ADV because Item 5 requires an adviser to report assets under management inclusive of any uncalled commitments and without deducting any outstanding indebtedness or other accrued but unpaid liabilities. To prevent the appearance of an overstatement of HHLR’s assets under management, HHLR has calculated assets under management in this Brochure exclusive of uncalled commitments and taking into account certain unpaid liabilities and outstanding indebtedness. Fund Structures The structure of HHLR’s advisory relationship can vary in accordance with a specific client agreement, and services can be provided by HHLR directly or through an affiliate. Many Funds are organized as master-feeder structures. A master-feeder structure is commonly used to accumulate capital raised from U.S. taxable, U.S. tax-exempt, and non-U.S. investors into one central vehicle – a master fund – in order to enhance the critical mass of investable assets, improve economies of scale under which the fund arrangements operate and enhance operational efficiencies, thereby reducing costs. Other client relationships are structured without a masterfeeder structure, such as a single partnership or company. HHLR commonly serves as, controls, or is under common control with an entity that serves as, a general partner (or similar controlling entity) of Funds organized as partnerships or other structures. The general partner of one Fund could also act as the general partner (or similar controlling entity) of other Funds or investment vehicles. HHLR and the other Hillhouse Investment Group entities advise, in addition to the Funds and accounts disclosed in Item 5.K. and Item 7.B. of Part 1A of the HHLR and the HIM Form ADVs, numerous non-U.S. accounts and vehicles (including PRC funds denominated in renminbi (“RMB”) and co-investment vehicles) which are deemed not to be advisory relationships within the scope of the U.S. Investment Advisers Act of 1940, as amended (the “Advisers Act”) and which are not discussed in this Form ADV. Managed Accounts; QFII HHLR also advises individualized managed accounts on terms that are agreed to with the applicable client. These accounts often involve HHLR providing advisory services with respect to a variety of investments based on an individual client’s specific investment objectives (including, without limitation, investments referencing bespoke requirements, applicable indices and benchmarks and/or market-specific strategies). Managed accounts can be discretionary or non-discretionary. Some managed account relationships include advice given on A Share Investments which can only be made by persons licensed as a Qualified Foreign Institutional Investor (“QFII”) by the China Securities Regulatory Commission (such investments, “QFII Investments”) as well as through the Shanghai – Hong Kong Stock Connect and the Shenzhen – Hong Kong Stock Connect programs (collectively, the “Stock Connect” programs). Other relationships involve other means of direct and indirect exposure to Chinese, emerging markets, and other assets and markets, which can be accomplished through direct investments in securities or by a variety of exchange-traded and over-the-counter derivative instruments. HHLR has a select and limited

number of managed account clients that are eligible for its A Share Investment program (“A Share Managed Account Clients”) and, thus, HHLR consults with each A Share Managed Account Client on its investment objectives and then tailors HHLR’s services and advice to those objectives. HHLR’s role is to advise its A Share Managed Account Clients in the selection of A Share Investments most suited to their investment objectives, and then to manage, monitor, and provide additional investment advice as required in connection with the applicable advisory relationship. Co-Investments HHLR and its affiliates may, from time to time, form, sponsor, manage, arrange, offer or advise investment vehicles or accounts in connection with a particular investment strategy or theme, and also establish, sponsor or advise, on a transaction-by-transaction basis, an investment vehicle or account through which certain persons could invest alongside or independently of one or more clients (each such vehicle or account, a “Co-Investment Arrangement”) in companies in which one or more clients make, or have made, an investment (each, a “Portfolio Company,” and, collectively, “Portfolio Companies”). Certain Co-Investment Arrangements participate in individual investments or a series of related or unrelated investments alongside one or more other clients of HHLR and its affiliates. Certain Co-Investment Arrangements also make investments independently of (and not alongside) other clients of HHLR and its affiliates. In addition, certain Funds (and other HHLR clients) from time to time co-invest with each other. HHLR’s fee and compensation practices for Co-Investment Arrangements are subject to a case-by-case agreement with the applicable investor. Co-investors participating in a Co-Investment Arrangement may pay no management fees or carried interest in connection with the co-investment, or may pay them at a lower rate, and the transaction fees received by HHLR or its affiliates in respect of a co-investor’s pro rata portion of any investment may not offset the management fee paid by the applicable Fund to HHLR or its affiliate. Co-investors will likely also acquire their interest in the Portfolio Company at the same time as the applicable Fund or purchase their interest from the applicable Fund after such Fund has consummated the full investment. Moreover, investors approached as potential coinvestors may not bear any transaction costs of investments that are not consummated or be subject generally to the same risks to which the applicable Fund is throughout the investment process. In sum, awarding a co-investment opportunity to an investor generally may afford it proportionately greater exposure to a particular investment at a proportionately lower cost. In addition, co-investors might have the ability to elect whether or not to participate in follow on investments. Co-investors, however, could be subject to different liquidity terms or achieve different economic returns than other investors in the applicable Fund investing in the same Portfolio Companies. For example, co-investors may not have the ability to leverage certain opportunities, or may not be able to accept or transact in certain distributions in kind available to the investors in the applicable Fund, which could impact liquidity, the timing of distributions, or returns. If HHLR determines to offer co-investment opportunities, HHLR generally will have complete discretion to determine to whom it will offer these co-investment opportunities. HHLR could offer co-investment opportunities to some investors but not all of them, could generally determine the terms and conditions of co-investments in its sole discretion, and the allocations of

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Item 5: Fees and compensation Fees

General Clients typically compensate HHLR, in part, on the basis of asset management fees calculated as a percentage of the funded and unfunded capital commitments of a client, or of a client’s assets under management. HHLR generally deducts or charges asset management fees from or to client accounts on a quarterly basis and such fee rates are individually agreed to with HHLR’s clients. In certain instances, HHLR (or its affiliate) may charge a one-time upfront fee or other aggregated fees paid in advance. Asset management fees that are deducted or charged on a quarterly basis are generally payable by clients in advance of the beginning of each calendar quarter. HHLR also enters into arrangements to receive performance-based fees/allocations, with rates and other terms being individually agreed to with the applicable client. HHLR assesses performance-based fees/allocations based on realized and unrealized capital appreciation. In certain instances, such performance fees/allocations are subject to a threshold amount, hurdle, benchmark or preferred return. In some cases, HHLR receives a portion of its clients’ realized investment profits as performance fees/allocations upon disposition of the relevant investment, but in other cases HHLR deducts or receives performance-based fees/allocations from client accounts annually, or collects them directly from clients on an annual basis, which such fees/allocations generally are rolled over or reinvested into client accounts, thereby increasing

HHLR’s proportionate interest in such client accounts. HHLR’s fee and compensation practices for Co-Investment Arrangements are subject to a case-by-case agreement with the applicable client. Neither HHLR nor any of its “supervised persons” (as defined in the glossary of terms to the SEC Form ADV) accepts compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. Performance-Based Compensation HHLR receives performance-based fees and allocations, as described above. HHLR agrees to or arranges such fees/allocations with clients before entering into advisory relationships and fees and other economic terms are agreed to on a client-by-client basis and terms vary among clients. The receipt of performance-based compensation creates an incentive for HHLR to make investments that are riskier or more speculative than those HHLR would otherwise make in the absence of such incentive compensation. HHLR addresses this conflict by focusing on long-term relationships with its clients and Fund investors, and by managing the client assets in accordance with the applicable advisory agreement and/or governing documents. HHLR charges clients both asset-based fees and performance-based fees/allocations. Charging asset-based fees and performance-based fees/allocations creates a conflict of interest because it creates an incentive to allocate the best-performing assets into client accounts on which HHLR charges performance-based fees/allocations. Additionally, the allocation of performance fees and allocations at different rates, or subject to different hurdle rates or preferred returns, creates an incentive for HHLR or its affiliates to disproportionately allocate time, services, or functions to accounts or vehicles with higher fees/allocations (or subject to a lower hurdle rate or preferred return), or to allocate investment opportunities to such accounts or vehicles. HHLR and its advisory affiliates recognize the possibility of such a conflict being detrimental to their clients and seek to address it through HHLR’s allocation policies, procedures, and processes, and other relevant measures. Please see Item 4, “Investment Allocations and Related Conflicts” for additional information on HHLR’s investment allocation policies, procedures, and processes. HHLR does not charge performance-based fees where such an arrangement would violate Section 205 of the Advisers Act, pursuant to Rule 205-3 thereunder. Valuation of Assets The asset management fees and the performance-based fees/allocations charged to or made by a client are calculated based on valuations ascribed to a client’s holdings by HHLR, which presents a conflict. Valuations are also used for determining the prices at which interests in Funds are redeemed or purchased, or at which HHLR’s performance-based fees/allocations are rolled over or reinvested in client accounts, underscoring the importance of the need to address any such conflict. HHLR addresses this conflict by adhering to its valuation practices, which include: •

Engaging third party administrators, auditors, pricing sources, and valuation agents, from time to time, to assist in certain valuation processes and confirmations; and

•

A Valuation Committee that seeks to implement HHLR’s valuation policies and procedures and to make determinations and recommendations regarding the valuations ascribed to client holdings.

HHLR’s valuation policies and procedures generally (i) seek to ensure that HHLR’s determinations of fair value of client assets is appropriate, (ii) require all such determinations to be made in good faith, and (iii) address relevant accounting standards. Specific valuation procedures differ based on the type of security and/or instrument and the observability of market inputs. Certain terms related to HHLR’s valuation policies and procedures are incorporated into written investment management agreements entered into with its clients and/or a Fund’s governing documents. There can be no assurance that the value assigned to an investment at a certain time will equal the value that a client is ultimately able to realize. Expenses and Other Fees Each client bears its own expenses and HHLR’s general policy is that it assesses expenses against client accounts to the extent that such expenses are permissible client expenses under the applicable client agreements. Allocable client expenses generally include: management fees and performance fees/allocations; organizational and administration fees and expenses; taxes; costs incurred in connection with the researching, evaluation, acquisition, monitoring and disposition of investments (whether or not consummated); transaction costs; financing costs; insurance costs; certain regulatory and tax compliance costs; and fees relating to service providers engaged for a client’s business and operations, including, without limitation, attorneys, auditors, accountants, valuation services, consultants, and custodians; and such other fees and expenses as are provided for under the arrangement with each client. HHLR (or an affiliate), in certain circumstances, will pay a client expense out-of-pocket and be reimbursed by offsetting from proceeds otherwise payable to such client. Certain expenses are charged to more than one client, in which case HHLR determines the appropriate allocation of expenses among each client depending on the nature of the expense. Certain expenses are allocated between clients on a pro rata basis (as appropriate) while others are allocated more specifically based on other factors, such as the relevant clients that have incurred the cost or received the benefit arising from the expenses. Clients incur brokerage and other transaction costs. Please see Item 12, “Brokerage Practices” below for a discussion of certain brokerage expenses. HHLR has no affiliated broker-dealers. HHLR could elect to (or to cause its affiliates to) rebate, offset, or return directly to the client account cash and non-cash consideration received or due to it as a result of actions taken with respect to a client’s investment, including, e.g., customary break-up fees, commitment fees, monitoring and directors’ fees and transaction, financing, divestment and other similar fees (all to the extent that the receipt of such monies is consistent with applicable law). HHLR’s and its affiliates’ obligations to do so will be governed by the agreements with each affected client, which could include provisions on the calculation of non-cash consideration.

HHLR or its affiliates currently, and will from time to time, provide services (including advisory services) to Portfolio Companies. In such a situation, HHLR (or an HHLR affiliate) is, and will be, entitled to compensation from these Portfolio Companies, notwithstanding the fact that HHLR (or any such affiliate) is entitled to compensation from the parent client entity. The receipt of such compensation could adversely impact the performance of the relevant Portfolio Companies, and the amount of such compensation and its financial impact on a Portfolio Company may not be specifically reported to investors or clients. In certain cases, HHLR (or a relevant affiliate) could be obligated to, in accordance with the agreements with each relevant client, or could determine to, rebate, offset, or return directly to the client account compensation owed to it by a client by some or all of the compensation payable to it by a Portfolio Company, but this will not always be the case. Please see Item 10, “Relationships and Transactions with Portfolio Companies” for additional information on HHLR’s services arrangements with Portfolio Companies. There can be no assurance that any such compensation will be established on an arm’s length basis. Out-of-pocket expenses associated with a completed investment made by the applicable client generally are borne by the relevant Portfolio Company or a related investment vehicle through which the investment is made by such applicable client and may be capitalized as part of the acquisition price of the relevant transaction to the extent not reimbursed by a third party. Where the relevant Portfolio Company bears such expenses, each direct and indirect equity owner of the company will indirectly bear a portion of such expenses. In certain transactions, however, certain expenses could be allocated to and borne by (a) holding companies or other vehicles through which certain, but not all, of the direct and indirect equity owners of the Portfolio Company invest or (b) a specific client. For instance, certain deal expenses required to be incurred due to regulatory requirements relating to a specific client may in some situations be allocated to such client. In such circumstances, this will result in such client bearing a greater portion of such costs and expenses than would be the case if such costs were paid by the relevant Portfolio Company. Refunds and Fee Waivers In the event of the termination of a client’s advisory agreement during a quarterly period, to the extent required under such client’s advisory agreement, such client, without request, will receive a pro rata refund of the portion of the asset management fee paid in advance for the remaining balance of the quarter. Certain one-time or other up-front fees may not, in accordance with the terms of the relevant client agreement, be refunded, reduced, or waived based upon a shorter service period. Additionally, unless otherwise agreed to with a client, HHLR generally assesses a pro rata asset management fee to any client account created on any date other than the first day of any calendar quarter. HHLR has the authority to, in its sole discretion, waive all or part of any fees or expenses payable by or attributable to its clients, their underlying investors, or their assets. Certain of HHLR, its affiliates and/or each of their personnel have invested in one or more of its Funds directly or indirectly through vehicles established by HHLR or its affiliates for their personnel. HHLR, its affiliates and/or many of its affiliates’ personnel are not generally subject to asset management fees or performance-based fees/allocations with respect to their investments in the Funds.

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

Methods of Analysis HHLR’s research process employs a variety of techniques, including fundamental, quantitative, qualitative, and cyclical analysis, with the specific techniques employed being determined on a client-specific basis.

HHLR focuses on developing a deep, fundamental understanding of investment opportunities through rigorous due diligence and analysis. HHLR’s bottom-up approach to analysis and research is generally conducted on a company-by-company basis but could extend to competitors and industries. HHLR evaluates the up-side and down-side of the companies and opportunities identified and monitors them closely and conducts, as appropriate, on-site visits, cross-checks, and detailed financial analysis of investment opportunities. HHLR’s analysis continues with ongoing due diligence and monitoring after an investment is entered into a client’s portfolio. Sources of Information HHLR incorporates local expertise stemming from grassroots research to generate powerful independent and proprietary views that drive its investment strategy. HHLR generally adheres to an exhaustive research framework, including, as appropriate, face-to-face communication with management, analysis of publications and other media, site visits, expert networks, analysis of data and information from clients and Portfolio Companies, and dialogue with suppliers, customers, and competitors. Please see Item 10, “Expert Networks” and “Data” below for some potential conflicts of interest that are expected to arise from using these sources of information. Investment Strategies General Strategy. HHLR invests globally and focuses on understanding fundamental risks, uncovering long-term growth potential, and targeting industries that it understands and can monitor. HHLR’s investment decisions are based on bottom-up analysis and research. HHLR generally focuses on publicly-listed (or similarly liquid) investment opportunities across multiple industries, but it could also participate in private (or otherwise less liquid) investment opportunities. Broadly speaking, HHLR’s investment recommendations and decisions are made based on fundamental analyses. However, HHLR will purchase and sell investments for clients at what it considers to be advantageous times (for example, if HHLR views the economic value of a particular company to be uncorrelated with the price at which such company’s shares trade and wants to capture a buying or selling opportunity in the market). Short Strategy and Hedging. HHLR, from time to time, utilizes short sales and maintains short positions in order to hedge risks that are present in or that could affect a client portfolio, to generate returns for a client account, or to structure and manage risks in an investment strategy. Current regulations on A Shares Investments place limits on the ability to engage in short sales with respect to such instruments, which may affect certain clients’ portfolios. These limits may or may not be revised in the future. Risk Factors Clients should be aware that any investment with HHLR involves a high degree of risk and is suitable only for investors of substantial means who have no need for liquidity with respect to the amount invested and can afford to lose all of their investment. There can be no assurances that HHLR’s clients will receive any return of, or on, their capital.

Investors are advised to review the applicable Fund’s offering materials for a more extensive description of the risks of investing in the Funds. General Risks Investment risks include, but are not limited to, the following: Risk of Loss. HHLR does not guarantee the future performance of any client portfolio, the success of any investment decision, strategy, or advice that HHLR could employ or provide, or the success of HHLR’s overall management of any client. Any investment made in connection with HHLR’s advice or management involves significant risk, including the risk of loss of all or substantially all capital invested. Investors should be prepared to bear the loss of the entire amount of their investment. International Investments Risk. HHLR’s investments include equity and debt securities in a number of international jurisdictions including securities with a substantial relationship with Asia and also securities relating to the United States and Europe. International investments involve a broad range of political, economic, legal, tax, and financial risks. Many of these risks are not typically associated with investments in securities of companies in economies that are developed and have been regulated over a longer period of time. These risks include: (i) less publicly available information; (ii) varying levels of governmental regulation and supervision; (iii) the difficulty of enforcing legal rights in a foreign jurisdiction and uncertainty as to the status, interpretation and applications of laws and (iv) foreign exchange controls. Moreover, non-U.S. companies may not be subject to the same accounting, auditing, and financial reporting standards, practices, and requirements comparable to those applicable to companies in other countries or regions, such as U.S. companies. Further, investing in securities of non-U.S. entities that are generally denominated in non-U.S. currencies and utilization of options on non-U.S. securities involves certain considerations comprising both risks and opportunities not typically associated with investing in securities of the U.S. government or entities organized or domiciled in the U.S. These considerations include, among others, changes in exchange rates and exchange control regulations; political and social instability; expropriation or confiscatory taxation; imposition of foreign taxes; less liquid markets and less publicly available information than is generally the case in the U.S.; higher transaction costs; foreign government restrictions; less government supervision of exchanges, brokers and issuers; greater risks associated with counterparties and settlement; difficulty in enforcing contractual obligations and legal rights, and uncertainty as to the status, interpretation and application of laws; and greater price volatility. Further, income or proceeds received by a client from sources within some countries could be reduced by withholding and other taxes imposed by such countries. Any such taxes paid by a client will reduce its net income or return from such investments. Emerging Markets Risk. Investing in an emerging market involves additional risks and special considerations not typically associated with investing in other more established economies or securities markets. Emerging economies differ from other large economies in many respects, including the level of development, growth rate, and allocation of resources.

Such risks could include: (i) increased risk of nationalization, expropriation of assets, or confiscatory taxation; (ii) greater social, economic, and political uncertainty, including war; (iii) higher dependence on exports and the corresponding importance of international trade; (iv) greater volatility, less liquidity, and smaller capitalization of securities markets; (v) greater volatility in currency exchange rates; (vi) greater risk of inflation; (vii) greater controls on foreign investment and limitations on repatriation of invested capital and on the ability to exchange local currencies for U.S. dollars; (viii) increased likelihood of governmental decisions to cease support of economic reform programs or to impose centrally planned economies; (ix) differences in auditing and financial reporting standards, which could result in the unavailability of material information about issuers; (x) less extensive regulation of the securities markets; (xi) longer settlement periods for securities transactions and less reliable clearance and custody arrangements; (xii) less protection through registration of assets; (xiii) less developed corporate laws regarding fiduciary duties of officers and directors and protection of shareholders and other interest holders; and (xiv) less developed laws regarding internal controls designed to ensure the accuracy of financial reporting and third-party attestation of the effectiveness of those controls. Moreover, the value of HHLR’s investments could be adversely affected by uncertainties associated with international political developments. Changes in political, economic, and social conditions and government policies in Asia could have a substantial detrimental impact on HHLR’s clients’ investments. These changes could include: (i) promulgation of new laws, regulations, and economic policies; (ii) changes in the interpretation or enforcement of laws or regulations; (iii) introduction of measures to control inflation or stimulate growth; (iv) changes in the rate or method of taxation; and (v) the imposition of additional restrictions on currency conversion and remittances abroad. Political/Sovereign Risk. With respect to any emerging market country, there is a heightened risk of nationalization, expropriation or confiscatory taxation, political changes, government regulation, economic or social instability or diplomatic developments (including war) which could affect adversely the economies of such countries and the value of clients’ investments in those countries. In addition, the inter-relatedness of the economies in emerging market countries has deepened over the years, with the effect that economic difficulties in one country often spread throughout the region. No assurance can be given that clients’ investments will not be adversely affected by circumstances in countries outside of where investments are located. Availability of Suitable Investment Opportunities and Investment Risk. For HHLR’s investment strategies to be successful, it must be able to identify and select appropriate investment opportunities. Additionally, HHLR competes for investment opportunities with operating companies, financial institutions, and other institutional investors, including private equity, hedge, and other investment funds, which could negatively impact HHLR’s ability to take advantage of suitable investment opportunities. Successful implementation of the investment strategy adopted by HHLR requires accurate assessments of general economic conditions, the detailed analysis of individual companies or industries, the relationship between a security and its derivatives, the risk correlation between a wide variety of investments, and the future behavior of other financial market participants. Even with the most careful analysis, the direction of the financial markets is often driven by unforeseeable economic, political, and other events and the reaction of market participants to these events. HHLR’s clients should be aware that the value of their investments and the return derived from them could fluctuate. There can be no

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Item 7: Types of clients

HHLR serves as an investment adviser to pooled investment vehicles whose underlying investors are “accredited investors” (as defined in Rule 501(a) of Regulation D under the U.S. Securities Act of 1933, as amended) and/or “qualified purchasers” (as defined in Section 2(a)(51) of the U.S. Investment Company Act of 1940, as amended) and/or “knowledgeable employees” (within the meaning of Rule 3c-5 under the U.S. Investment Company Act of 1940, as amended). Underlying investors in the pooled investment vehicles HHLR advises include endowments, foundations, non-profit organizations, pensions, corporates, government entities, family offices, trusts, and other businesses or institutions. As noted in Item 4, HHLR and the other Hillhouse Investment Group entities also advise non-U.S. accounts and vehicles (including co-investment vehicles) that are not deemed advisory clients under the Advisers Act and not discussed in this Brochure. HHLR also provides investment advice to institutional clients such as endowments, foundations, non-profit organizations, pensions, corporates, government entities, family offices, trusts, and other businesses or institutions. Minimum Account Size Certain of the Funds require a minimum capital commitment or investment amount, but the general partners of such Funds may accept capital commitments or investment amounts in lesser amounts in their sole discretion. HHLR generally does not require clients or investors to maintain a minimum investment to continue an advisory relationship or to remain invested in the Funds. Advisory Agreements HHLR’s clients typically enter into a written investment management, advisory, or similar agreement (and/or enter into or become subject to a limited partnership or similar organizational agreement with HHLR or one of its affiliates) in establishing an advisory relationship with HHLR or its affiliates. HHLR will not assign any advisory agreements without client consent.

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

HHLR receives performance-based compensation as described in Item 5, “Fees and Compensation” above. As described above, HHLR does not engage in side-by-side management practices.

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

Neither HHLR nor any member of its management is registered, or has an application pending to register, as a broker-dealer, a registered representative of a broker-dealer, a futures commission merchant (an “FCM”), a commodity pool operator (a “CPO”), a commodity trading advisor (“CTA”), or an associated person of a registered FCM, CPO, or CTA. HHLR and/or certain of its affiliates act as CPOs for their clients, but they are exempt from registration with the Commodity Futures Trading Commission (the “CFTC”) pursuant to CFTC Rule 4.13(a)(3) under the U.S. Commodity Exchange Act. This exemption is based primarily upon clients’ limited commodity interest trading. Unlike registered CPOs, HHLR and its relevant affiliates are not required to deliver to investors disclosure documents or certified annual reports contemplated by CFTC rules applicable to registered CPOs. Likewise, HHLR and/or certain of its affiliates act as CTAs for some of their clients, but are exempt from registration as CTAs and therefore are not required to satisfy certain requirements contemplated by CFTC rules applicable to registered CTAs. All qualifying HHLR personnel (and qualifying personnel of the non-U.S. affiliates discussed in Item 4) are treated as “access persons” by HHLR within the meaning of Rule 204A-1 under the Advisers Act, and are subjected to HHLR’s Code of Ethics. Please see Item 11, “Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading” below for additional information about HHLR’s Code of Ethics. An HHLR affiliate, HIM, is also an SEC-registered investment adviser. While HHLR and HIM, from time to time, invest in similar strategies or companies, HHLR generally focuses on publicly-listed (or similarly liquid) investment opportunities, while HIM generally focuses on private (or otherwise less liquid) investment opportunities, including venture capital, private equity, private debt and buyout transactions. Therefore, investment results could differ as between HHLR’s clients and HIM’s clients. To address these conflicts of interests, HHLR has

adopted policies and procedures, including an allocation policy. Please see Item 4, “Investment Allocations and Related Conflicts” for more information. HHLR, HIM and other entities are members of what is referred to as “Hillhouse Investment Group,” which is a multinational group of related advisory entities. Hillhouse Investment Group could engage in and provide a broad range of banking, advisory and investment services to their clients and customers. HHLR believes that clients will generally benefit from the relationships and activities resulting from these services, which are expected to generate attractive investment opportunities and analytics. Nevertheless, situations arise in which the interests of Hillhouse Investment Group will conflict with the interests of clients or Fund investors, including those set forth below. Investments by Other Hillhouse Investment Group Clients. As a result of the expansive nature of Hillhouse Investment Group’s business, clients of the various members of Hillhouse Investment Group will invest in companies that could compete with, are customers of, or are service providers or suppliers to, the Portfolio Companies of one or more other clients. This would give rise to certain conflicts of interest. First, the various members of Hillhouse Investment Group could take actions for their clients and their Portfolio Companies for commercial reasons that have adverse consequences for other clients or their Portfolio Companies, such as seeking to increase market share at the expense of a Portfolio Company of another client (as a competitor), withdrawing business from a Portfolio Company of another client in favor of a competitor that offers the same product or service at a more competitive price (as a customer), increasing prices in lock step with other enterprises in the industry (as a supplier) or commencing litigation against a Portfolio Company of another client (in any capacity). Secondly, one member of Hillhouse Investment Group could obtain information while dealing with its clients and Portfolio Companies that it is prohibited from acting on or disclosing to another member of Hillhouse Investment Group as a result of confidentiality requirements or securities laws restricting activities while in possession of material non-public information, even though such action or disclosure would be in the clients’ interests. In such circumstances, HHLR might not pursue certain actions on behalf of a client or a portfolio company, which could result in a benefit to another client. In addition, to the extent not restricted by confidentiality requirements, Hillhouse Investment Group would ordinarily seek to apply the experience obtained by managing each client to benefit other clients. Investing with Related Parties. Clients often make investments in the same Portfolio Company. Differences between each client, including their respective terms, investment periods, structures and investment strategies, could result in a given client making or exiting its investment at a different time, at a different effective price or with differing costs or terms than other clients. Situations could arise where other clients co-investing with a client invest on different (and more favorable) terms than those applicable to such client and have interests or requirements that conflict with and adversely impact such client (for example, with respect to the timing of acquisitions and disposals or control rights) and, accordingly, investments could be acquired at different times in different parts of the capital structure at lower or higher prices or valuations and on different terms than those upon which a given client acquires an investment. The different prices paid for, or terms of, securities held by clients will create conflicts of interest. The other clients’ view of the investment and their interests could diverge from those of

a given client and the other clients will be acting in their own interests and could take actions that are adverse to the interests of such client, including actions that could affect the value of such client’s investment. Further, there can be no assurance that a given client and the other clients would exit such investment at the same time or on the same terms. This could cause the other clients to dispose of, increase their exposure to or continue to hold the investment at a time when a given client has adopted a different strategy. For example, following the initial public offering of a Portfolio Company in which both a given client and another client hold an interest, such client could exit at a different time and at a different valuation from another fund. As a result, the actions of the other clients could affect the value of such client’s investment. For example, a sale by another client of its investment could put downward pressure on the value of a given client’s interest if such client opts to hold such interest for a longer term. In addition, certain client investments are often pooled with one or more other clients (an “Asset Pool”), including for the purposes of seeking a full or partial exit from one or more investments, or obtaining leverage or other financing. For example, there could be situations in which it would be advantageous to the clients to pool certain investments together to obtain or access certain rights in respect to certain portfolio companies. In such circumstances, an Asset Pool could be managed or controlled by HHLR or any of its affiliates (or controlled by a Fund). The consummation of any such transaction might not require the consent of the LP Advisory Committee (as defined below) or the investors and will involve the exercise of HHLR’s and its affiliates’ discretion with respect to a number of material matters, which are likely to create actual or potential conflicts. For example, in determining the proportionate interest of each client in the Asset Pool (or particular classes or tranches of securities or other interests in the Asset Pool), HHLR and its affiliates will be required to determine the relative value of assets contributed to the Asset Pool, and value of securities or interests (or particular classes or tranches thereof) issued by the Asset Pool. In making this determination HHLR and its affiliates could, but are not required to, engage or seek the advice of any third party independent expert. However, even if such advice was sought, valuing such assets and interests and, therefore, the value of each client’s interest in, or proceeds received from, any Asset Pool, will be subjective. While HHLR will seek to make allocation determinations in accordance with its policies and its duties, the appropriate allocation among each client of expenses and fees incurred or generated in the course of evaluating potential investments often will not be clear, in particular with respect to an investment that was not consummated and may not be proportional to invested capital or other metrics in specific instances or over time. Investing in Different Levels of the Capital Structure. Clients currently (and will in the future) invest in a broad range of asset classes throughout the corporate capital structure. As HHLR, HIM and their affiliates (“Hillhouse Investment Group”) establish more funds, vehicles and accounts, including those that focus on different parts of the corporate capital structure (for example, preferred equity, convertible debt, subordinated debt or senior debt), both the range of asset classes in the corporate capital structure in which clients invest and the extent of such investments by clients will increase. A given client could make investments in other parts of the capital structure of a company in which another client has or will have an investment in an equity or debt tranche. As an investment adviser to both clients, HHLR would owe a fiduciary duty to both clients. Consequently, given the differing tranches and corresponding priorities in the capital structure of a single company, HHLR would face a conflict of interest in respect of the advice it gives to, and the actions it takes on behalf of, one client and the other client (e.g., with

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

General Code of Ethics HHLR expects its employees to be responsible for maintaining the highest ethical standards when conducting business. In keeping with these standards, HHLR’s employees must always place its clients’ interests ahead of their own. Moreover, HHLR’s employees should adhere to the spirit as well as the letter of the law and be vigilant in guarding against anything that could inappropriately skew their judgment. Pursuant to Rule 204A-1 under the Advisers Act, HHLR has adopted a Code of Ethics (the “Code”) which sets forth standards of business and personal conduct for all HHLR employees, and addresses conflicts of interest that could arise from personal trading by employees or gifts and entertainment received or provided by employees. The Code sets forth, among other things, standards for the purpose of deterring wrongdoing and promoting: (i) honest and ethical reporting; (ii) full, fair, accurate, timely, and understandable disclosure in reports and documents; (iii) compliance with applicable laws, rules, and regulations; (iv) prompt internal reporting of violations of the Code; and (v) accountability for adherence to the Code. Clients or potential clients can obtain a copy of the Code by writing to HHLR’s Chief Compliance Officer at the address on the cover page of this Brochure. As discussed in Item 10, qualifying personnel of the non-U.S. affiliates discussed in Item 4 are treated as “access persons” by HHLR within the meaning of Rule 204A-1 under the Advisers Act, and are subjected to the Code. Interest in Client Transactions Clients of HHLR and its affiliates (such persons, the “Other Hillhouse Investors”) from to time to time hold investments similar to or the same as those made or proposed to be made by other HHLR clients. Investments held by Other Hillhouse Investors could be in the same or similar securities as those held by HHLR’s other clients, but acquired at different times, at lower or higher prices or valuations, and on different terms than those upon which HHLR’s clients acquire an investment. The different prices paid for, or terms of, securities held by the Other Hillhouse Investors creates conflicts of interest. HHLR has adopted an aggregation and allocation policy to help assure investment opportunities are recommended or allocated in a fair and equitable manner. As described more fully in Item 5,“Fees and Compensation,” HHLR takes various factors into account in making recommendation and allocation decisions.

Please see Item 5, “Fees and Compensation,” and Item 10, “Other Financial Industry Activities and Affiliations,” above for a discussion of the conflict of interest created by allocating investment opportunities among client accounts and how HHLR addresses the conflict of interest. Personal Trading The Code is designed to assure that the personal securities transactions, activities, and interests of HHLR’s employees do not interfere with their judgment in advising HHLR’s clients. HHLR discourages its employees from excessive personal trading due to the conflicts of interest (real and apparent) that such trading could present. Employees are required to seek pre-clearance for all reportable personal securities transactions and provide post-trading details of all approved personal trades. Employees are also required to provide HHLR with detailed information regarding their reportable personal securities holdings, which they are required to update on a quarterly basis. Although employees are not prohibited from personal trading, employees are prohibited from short-term trading or speculation, and employees must present any investment opportunities suitable for any investment strategy of HHLR’s clients to such clients prior to engaging in any transaction related thereto for personal benefit. To minimize the risk of conflicts of interests, employees and their immediate family members are not permitted to make personal trades in any security, company, asset, or investment product under research, traded in, or contemplated to be traded in by HHLR, in each case without the consent of the Compliance Officer. Service on Boards of Directors Representatives of HHLR, HIM, or their other affiliates, from time to time, serve on the boards of directors of Portfolio Companies and other companies. A HHLR representative serving as a director for a company has fiduciary duties to the company, as well as to HHLR’s clients. These separate fiduciary obligations could create conflicts of interest that must be addressed to ensure the HHLR representative serving as director does not breach his or her fiduciary obligations. In addition, if HHLR obtains material, non-public information by virtue of a representative serving as a director of a company, HHLR generally would be precluded from trading or making a recommendation with respect to the securities of such company. HHLR has adopted internal policies and procedures to address conflicts of interest that arise from time to time in connection with service on the board of directors of a company. Other Business Ventures HHLR, its affiliates, and its clients will engage in other business ventures to the extent not prohibited by agreements with its clients, independently or with others, including ventures involving investing in securities or managing or participating in other investment funds, or pursuing co-investments with HHLR’s clients or otherwise investing in Portfolio Companies independently of its clients. Other ventures undertaken by HHLR and its affiliates in certain circumstances are competitive with its clients. Conflicts of interest arise as a result of such activities, including in allocating management time, services or functions and allocating investment opportunities.

In addition, as discussed above, HHLR and its affiliates provide investment advisory services to Co-Investment Arrangements and/or Portfolio Companies, and also invest directly or indirectly in investment opportunities. HHLR recognizes the conflicts in these situations and relies upon its allocation and other internal policies and procedures to ensure fair and equitable allocation of investment opportunities, and to address other potential conflicts of interest. Conflicted Transactions For a number of the Funds, HHLR and its affiliates are and will be among the largest investors. As a result, certain transactions by such Funds could constitute “principal transactions” (as such term is used under the Advisers Act). With respect to principal transactions, cross trades, related-party transactions and other transactions and relationships involving potential conflicts of interest (collectively, “Conflicted Transactions”), the general partner of the relevant Fund will act in accordance with the policies and procedures established by HHLR to address these potential conflicts of interest and to authorize or ratify such transactions. HHLR expects that any Conflicted Transaction for which consent is required under its policies and procedures or applicable law to be submitted for review and approval to the relevant LP Advisory Committee or board of directors of the general partner of the relevant Fund (so long as the majority of the members of such board is comprised of independent directors) and the decision of the LP Advisory Committee or such board will be binding on the relevant Fund. Other conflicts not discussed above could arise in connection with the management and operation of HHLR’s clients.

Item 12: Brokerage practices Conflicts of interest

HHLR provides discretionary and non-discretionary advice to its clients. HHLR makes broker recommendations to certain of these clients. HHLR chooses various brokers for more efficient and/or less expensive transactions, or for non-financial relationship reasons. HHLR endeavors to recommend or select brokers that provide the best execution for securities transactions so that a client’s total costs or proceeds in each transaction are the most favorable under the circumstances (“Best Execution”). In recommending and/or selecting brokers to effect portfolio transactions, HHLR considers various factors, including, without limitation: price; quality of execution, including the reliability, promptness, level of accuracy and confidentiality in executing orders; extensiveness of the broker’s distribution network; commission rates or other transaction costs; HHLR’s access to the broker’s trading desk; the broker’s familiarity with HHLR’s investment practices; and the value of certain brokerage or research services. HHLR does not consider whether it receives client referrals from a broker-dealer or third party in recommending or selecting a broker. In any event, non-discretionary account clients are not under any obligation to select the broker that HHLR has recommended. Directed Brokerage Clients sometimes request that HHLR use a particular broker-dealer to effect transactions in recognition of services clients receive from the broker-dealer or from a third party. Any such request by a client must be accepted by HHLR prior to implementation. A client’s direction of

brokerage services could cost such client more money and could prevent such client from receiving the most favorable execution of such client’s transactions. Soft Dollar Arrangements While HHLR currently does not have any formal soft dollar arrangements, HHLR or its affiliates could enter into arrangements whereby HHLR receives research or other products or services (other than execution) from a broker or other third party in connection with client securities transactions, known as “soft dollar benefits.” These soft dollar benefits would be received in connection with commission fees paid to those brokers to execute client transactions. These research products and services would be intended to provide HHLR with valuable research and services that HHLR would otherwise have to produce or purchase from third parties with its own funds. Any transaction in which soft dollar benefits are being received will be carefully evaluated to determine that the transaction complies with HHLR’s duty to seek Best Execution. However, as a result of any soft dollar benefits HHLR receives, HHLR could have an incentive to select or recommend a broker based on receipt of soft dollar benefits. Section 28(e) of the Securities Exchange Act of 1934 establishes a safe harbor allowing investment managers to use client funds, by way of commission dollars, to purchase certain “brokerage and research” services. Pursuant to this safe harbor, the brokerage and research services, if any, must provide HHLR with lawful and appropriate assistance in the performance of its investment decision-making responsibilities. Further, HHLR will make a good faith determination that the amount of commissions paid by clients is reasonable in light of the value of the brokerage or research services received. This means that clients could pay commissions to a broker in an amount greater than the amount another broker might charge. HHLR would only enter into soft dollar arrangements if it believes that the products or services it could obtain through soft dollar arrangements would benefit all of its relevant client accounts, rather than benefitting just one account. HHLR currently does not require soft dollar benefits to be allocated proportionately to the amount of soft dollar benefits generated by each client account. Therefore, it is possible that such soft dollar benefits could provide a benefit to some clients who have not generated a proportionate share of commissions used to pay for these benefits. However, it is also possible that clients could benefit from these arrangements to a greater extent than the commissions they generated. Trade Aggregation HHLR generally aggregates its client orders when doing so will result in a better overall price for its clients’ trades and as otherwise consistent with the terms of its allocation policies. Aggregation or “bunching” describes a procedure whereby an investment manager combines the orders of two or more clients into a single order for the purpose of obtaining better prices and lower execution costs. Aggregation opportunities generally arise when more than one client is capable of purchasing or selling a particular security based on investment objectives, net asset value, available cash, lifespan of HHLR’s clients and other factors. HHLR will not aggregate orders among clients of HHLR and/or its affiliates where such activity is inconsistent with or is

prohibited by local law, regulations or exchange rules. HHLR does not aggregate or bunch certain client orders of A Share Investments since A Share Investments are generally processed separately with respect to each client. This could lead to the inability for clients to participate in certain transactions due to market, regulatory, or deal-specific restrictions and requirements.

Item 14: Client referrals and other compensation Conflicts of interest

Neither HHLR nor any related person of HHLR, directly or indirectly, compensates any person for client referrals. Should HHLR determine to enter into a solicitation arrangement for client referrals, HHLR will disclose the arrangement in writing as required by Rule 206(4)-3 under the Advisers Act and will comply with all other applicable requirements of the Rule. No person, other than HHLR’s clients, provides HHLR with an economic benefit for providing advisory services to its clients. Please see Item 12, “Brokerage Practices,” above for a discussion of certain soft dollar benefits that HHLR could receive in connection with certain brokerage relationships. Related persons of HHLR serve as directors on the boards of public and private companies in which one or more of HHLR’s clients invest. In certain circumstances, HHLR receives director’s fees in connection with such service. Please see Item 11, “Code of Ethics, Participation or

Interest in Client Transactions, and Personal Trading,” for a description of HHLR’s process for addressing conflicts of interest created by its related persons serving as directors.

Item 9: Disciplinary information

To HHLR’s knowledge, after due inquiry, there are no legal or disciplinary events that would be material to a client’s or prospective client’s evaluation of HHLR’s advisory business or the integrity of HHLR’s management.

Item 13: Review of accounts

HHLR reviews and evaluates its clients’ investment objectives and performance on a regular basis. HHLR also reviews strategies to ensure compliance with investment objectives and restrictions. Reviews are primarily conducted by the relevant portfolio manager and could periodically be conducted by an investment committee that is comprised of HHLR’s Chief Investment Officer, and other senior members of HHLR’s research team. Fund investors receive an annual report containing audited financial statements, generally within 120 days following the end of the Fund’s fiscal year. Fund investors also receive relevant tax information for the Fund in which they are invested. In addition, clients and investors receive unaudited statements with information on their account activity on a quarterly basis (or on a more frequent basis, depending on the Fund terms or the client agreement). These written financial statements and reports typically do not include a listing of portfolio investments. In connection with making QFII Investments, HHLR’s clients are required to engage a custodian to assist with holding client assets, reporting, and other related activities. HHLR urges clients to carefully review statements and reports received from their broker-dealers, banks and other qualified custodians and to compare any account statements received from HHLR against information received from their qualified custodian. To the extent requested by HHLR’s managed account clients’ or its managed account clients’ custodian, HHLR provides a written copy of its transaction reports or records related to such client’s accounts to assist such client or clients’ custodian with reconciliation of information. Within 30 days after the end of each calendar month or as soon thereafter as is reasonably possible, HHLR or one of its affiliates delivers an unaudited statement of an estimate of such client’s account and account balance(s) and any capital contributions or withdrawals by such client since the preceding month-end.

Item 15: Custody

HHLR is deemed to have custody over certain of its clients’ assets under Rule 206(4)-2 of the Advisers Act (the “Custody Rule”) because of its authority to access client assets and its role as a general partner of a Fund. The term “custody” is defined under the Custody Rule as holding, directly or indirectly, client funds or securities, or having any authority to obtain possession of them. HHLR does not physically hold client assets. Instead, for clients within the scope of the Custody Rule, HHLR maintains client securities and funds over which it has custody with a “qualified custodian” in accordance with the Custody Rule. Client funds and securities are held with a bank, broker-dealer, or other independent, qualified custodian. HHLR’s Chief Compliance Officer is responsible for ensuring that any qualified custodian with custody of client assets that fall under the Custody Rule is properly qualified. Further, HHLR could satisfy the audit provision of the Custody Rule through an annual audit of the relevant clients. Where required, audited financial statements are prepared and delivered to underlying investors in accordance with the Custody Rule. Item 13, “Review of Accounts” above describes the content and frequency of other reports delivered to underlying Fund investors.

Item 16: Investment discretion

HHLR provides advisory services to managed account clients on both a discretionary and nondiscretionary basis. As noted above under Item 7, “Types of Clients,” clients generally enter into written investment advisory agreements with HHLR before establishing an advisory relationship with HHLR and these agreements can contain limitations on HHLR’s authority. For Funds and other categories of clients, limitations on HHLR’s authority or other material terms of the advisory relationship can be found in written investment management agreements, in the organizational or governing documents of the applicable clients or in disclosure documents applicable to such clients.

Item 17: Voting client securities

HHLR has and will accept proxy voting authority to vote client securities. This creates a potential conflict of interest because of the possibility of HHLR voting client securities to further its own interests at the expense of its clients’ interests. HHLR takes seriously its responsibility to exercise proxies on behalf of clients and have adopted written policies and procedures to do so in a manner consistent with Rule 206(4)-6 promulgated under the Advisers Act. These policies and procedures are reasonably designed to ensure that proxies are voted in the best interest of HHLR’s clients, which generally means voting proxies with a view to enhancing the value of client securities. The financial interest of HHLR’s clients is the primary consideration in determining how proxies should be voted. Further, as the decision to invest in a company normally represents confidence in the company’s management, HHLR will typically give serious consideration to management recommendations. HHLR will generally support management recommendations regarding

internal operations and those without significant economic effects. Conversely, management proposals that are likely to have significant economic effects, involve management interests or where HHLR lacks confidence in the management team will be subject to greater scrutiny on a case-by-case basis. The following is a brief summary of principles, rather than rules, that reflect the long-term approach that guides (but does not obligate) HHLR’s investment and proxy voting decisions regarding common proxy proposals. 1. Board of Directors: HHLR will generally support resolutions that promote the effectiveness of boards in acting in the best interest of shareholders. HHLR generally supports the election of a majority of independent directors. 2. Auditors and Auditor Compensation: Where all members of a company audit committee are independent, HHLR will generally support the election of directors, the appointment of auditors, and the approval of the auditor compensation recommended by the board of directors. 3. Changes in Capitalization: HHLR recognizes the need for the management of a company to have flexibility to issue or repurchase shares to meet changing financial conditions. HHLR will generally support changes in capitalization when a reasonable need for change is demonstrated. HHLR is, however, aware that new shares could dilute the ownership interest of shareholders, and HHLR will not generally support changes resulting in excessive dilution of existing shareholder value. 4. Corporate Restructuring, Mergers, and Acquisitions: HHLR believes proxy votes dealing with corporate reorganizations are an extension of the investment decision. Accordingly, HHLR will analyze such proposals on a case-by-case basis, weighing heavily the views of its research analysts that cover the company and its investment professionals managing the portfolios in which the stock is held. 5. Management Compensation: HHLR’s goal is to support compensation arrangements that are tied to long-term corporate performance and shareholder value. These arrangements should better align management’s interests with those of shareholders and should induce management to purchase and hold equity in the company. Stock option plans that are overly generous or excessively dilutive to other shareholders generally will not be supported. 6. Other Issues: HHLR will address business issues specific to a company or those raised by shareholders of a company on a case-by-case basis with a focus on the potential impact of the vote on value for its clients. Procedurally, HHLR will take reasonable measures under the circumstances to obtain knowledge of meetings and other events giving rise to solicitation of proxies, assure that proxies are received in sufficient time for HHLR to take action, vote proxies, and return the proxies to the parties soliciting them in time to be counted. Clients could direct (in certain cases) the vote of HHLR in a particular solicitation, obtain information from HHLR about how it voted clients’ securities, and obtain a copy of HHLR’s proxy voting policies and procedures by writing to

HHLR Advisors, Ltd., Attn: Chief Compliance Officer, at the address on the cover page of this Brochure. If an HHLR representative serves on the board of directors for a Portfolio Company in which a client invests, unique conflicts of interest in relation to proxies could exist. In such circumstances, HHLR’s Chief Compliance Officer or its designee will undertake a review prior to any vote by the proxy recipient to determine whether a material conflict of interest exists between the applicable HHLR representative and the interests of such client, or between the HHLR representative and such client and company shareholders. In the event a material conflict of interest is identified, the Chief Compliance Officer or his or her designee will take such steps as he or she deems necessary to determine how to vote the proxy in the best interests of the relevant client. In each instance, when exercising their voting discretion, HHLR’s representatives will seek to avoid any direct or indirect conflict of interest between a client(s) and their voting decisions.

Item 18: Financial information

There is no financial condition that is reasonably likely to impair HHLR’s ability to meet its contractual commitments to clients.

Subsidiaries and ownership

Funds it manages

Ownership links from GLEIF, the Global Legal Entity Identifier Foundation (CC0); each one cites its LEI record.

Timeline

  1. Oct 23, 2012Founded HHLR ADVISORS, LTD. is founded2

Filings

23 filings to the SEC since October 2021: 23 other. The latest 20:

  1. Aug 31, 2026N-PX EDGAR
  2. Aug 14, 202613F-HR EDGAR
  3. May 15, 202613F-HR EDGAR
  4. Feb 17, 202613F-HR EDGAR
  5. Nov 14, 202513F-HR EDGAR
  6. Sep 2, 2025N-PX EDGAR
  7. Aug 14, 202513F-HR EDGAR
  8. May 15, 202513F-HR EDGAR
  9. Feb 14, 202513F-HR EDGAR
  10. Nov 14, 202413F-HR EDGAR
  11. Aug 30, 2024N-PX EDGAR
  12. Aug 14, 202413F-HR EDGAR
  13. May 14, 202413F-HR EDGAR
  14. Feb 14, 202413F-HR EDGAR
  15. Nov 14, 202313F-HR EDGAR
  16. Aug 14, 202313F-HR EDGAR
  17. May 15, 202313F-HR EDGAR
  18. Feb 14, 202313F-HR EDGAR
  19. Nov 14, 202213F-HR EDGAR
  20. Aug 15, 202213F-HR EDGAR

The 23 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

HHLR ADVISORS, LTD. has told the SEC it owns more than 5% of 22 companies, latest first (Schedules 13D and 13G).

Sources

The numbers on this page point here. Each one links to the record it came from.

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