Private company

HM International

HM International, LLC (HMI) is a partnership representing the joint interests of the Hojel and Meinig families. The partnership was initiated in 1979 with the objective of acquiring undervalued assets and creating value through strong, decentralized management and long-term investment focus. Peter C. Meinig was the company's chairman and chief executive officer.2 It is headquartered in Tulsa.1 Wikipedia text CC BY-SA 4.0

Last updated Oct 21, 2026.

Overview

1979Founded1
  • Industryholding company1
  • HeadquartersTulsa1

HM International, LLC (HMI) is a partnership representing the joint interests of the Hojel and Meinig families. The partnership was initiated in 1979 with the objective of acquiring undervalued assets and creating value through strong, decentralized management and long-term investment focus. Peter C. Meinig was the company's chairman and chief executive officer.2

Corporate structure

HM International is part of a group headed by Pm Operating Ltd.. 2 entities on record. Switch between the flow chart and the network, and select any entity to see its details.

Major holders of HM International

  • Meinig Gst For Anne M. Smalling Owns 25% to 50% of Pm Operating Ltd. Partner, since 01/2006 (Form ADV)
  • Meinig Gst For Kathryn M. Geib Owns 25% to 50% of Pm Operating Ltd. Partner, since 01/2006 (Form ADV)
  • Meinig Gst For Sarah M. Snipes Owns 25% to 50% of Pm Operating Ltd. Partner Kathryn M. Geib, since 01/2006 (Form ADV)
  • Anne M. Smalling Owns control (general partner, trustee or manager) of Meinig Gst For Anne M. Smalling Sarah M. Snipes, since 07/1993 (Form ADV)
  • Pmop Gp LLC Owns control (general partner, trustee or manager) of Pm Operating Ltd. Partner, since 07/1993 (Form ADV)
  • Ams Gp LLC Owns 75% or more of Pmop Gp LLC, since 07/1993 (Form ADV)
  • Pm Operating Ltd.
    • HM International Tulsa

Built from major holders from Schedules 13D and 13G; 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

HM International is registered with the SEC as an investment adviser. This is what it reports on Form ADV, the registration every adviser files and keeps current.

  • Assets it manages$1.1B3 5 accounts, all with discretion
  • Employees8 5 in investment advice or research
  • ClientsPooled investment vehicles (other than investment companies and: 5 ($1.1B)
  • How it is paidA percentage of assets under its management
  • What it doesPortfolio management for pooled investment vehicles (other than investment companies)
  • Holds client assetsNo
  • RegistrationSEC 801-126227, CRD 321885 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).

  • PM OPERATING LTD.owns 75% or more, since 07/2004
  • PMOP GP LLCowns general partner, trustee or manager of PM OPERATING LTD. PARTNER, since 07/1993
  • Anne M. Smallingowns general partner, trustee or manager of MEINIG GST FOR ANNE M. SMALLING SARAH M. SNIPES, since 07/1993
  • AMS GP LLCowns 75% or more of PMOP GP LLC, since 07/1993
  • Anne M. Smallingowns 75% or more of AMS GP LLC, since 07/1993
  • MEINIG GST FOR ANNE M. SMALLINGowns 25% to 50% of PM OPERATING LTD. PARTNER, since 01/2006
  • MEINIG GST FOR KATHRYN M. GEIBowns 25% to 50% of PM OPERATING LTD. PARTNER, since 01/2006
  • MEINIG GST FOR SARAH M. SNIPESowns 25% to 50% of PM OPERATING LTD. PARTNER KATHRYN M. GEIB, since 01/2006

In its own words: the client brochure

Form ADV Part 2A, the plain-English document an adviser must give its clients, quoted as filed 7/24/2026.4 It covers the firm’s services, fees, investment strategies and their risks, and its conflicts of interest.

Item 4: Advisory business Services

A. The Firm HM International L.L.C. is an Oklahoma limited liability company that was formed in 2004 to provide tax, financial reporting and administrative services to the Funds and other entities owned by members of the Meinig Family (as defined below) and the Hojel Family (as defined below). Prior to the registration of the Firm under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), the Firm’s activities have been limited to providing such services. Upon the registration of the Firm under the Advisers Act, the Firm commenced providing investment advisory services to the Funds as described in more detail below. The Firm’s principal place of business is located in Austin, Texas. As used herein, the term “Meinig Family” means (i) Nancy E. Meinig, (ii) all lineal descendants (by birth or adoption before age 18) of Peter C. Meinig and Nancy E. Meinig and (iii) all spouses of lineal descendants described in clause (ii) above. The term “Hojel Family” means (i) Phyllis S. Hojel, (ii) all lineal descendants (by birth or adoption before age 18) of Richard C. Hojel Sr. and Phyllis S. Hojel and (iii) all spouses of lineal descendants described in clause (ii) above. The principal and sole owner of HM International is PM Operating Ltd., a Texas limited partnership.

B. Advisory Services Investment Management Services Based on a client’s goals, objectives and risk tolerance, HM International provides investment strategy, asset allocation analysis, third-party investment manager analysis and performance monitoring and consulting services. The Firm provides clients with information and research on various investments and assists its clients in selecting investment products that best fit each client’s individual investment objectives, strategies and investment criteria. HM International provides the investment advisory and investment management services described above to privately placed pooled investment vehicles, which in some cases may be funds of funds. In most cases, the primary investments made by these pooled investment vehicles fall within one of the following categories: (i) investments in interests in or securities of hedge funds and private equity funds, (ii) direct investments in interests in or securities of private companies, (iii) investments in publicly traded equity securities, (iv) fixed income investments, (v) credit investments, (vi) investments in mutual funds and (vii) investments in real estate. HM International currently provides discretionary investment advisory and investment management services to the following six privately placed pooled investment vehicles that are owned exclusively by members of either the Meinig Family or the Hojel Family: PM Operating, Ltd., NPM Family Partnership, Ltd., Power of One LP, Hook Investments LP, Hojel Interests LP, and PSH Investments, Ltd. (the “Funds”). The first three entities listed above are owned exclusively by members of the Meinig Family. The last three entities listed above are owned exclusively by Members of the Hojel Family. At the present time, HM International does not have any clients other than the Funds.

Family Offices Services In addition to investment advisory and investment management services, HM International may also provide one or more of the following family offices services:

Tax return preparation and other tax services Financial reporting and administrative services Bill paying Cash management Estate planning Philanthropy planning; and Coordination of professional and other services (i.e., accounting, legal, insurance, home repair, property management, public relations).

HM International was notified in November 2024 by NPM Family Partnership, Ltd. that effective January 1, 2025, it is terminating its Advisory Agreement with HM International.

C. Client Tailored Services and Client Imposed Restrictions HM International creates a customized investment strategy to meet a client’s individual investment objectives, by providing clients with information and research on various investments and assisting each client in selecting tailored investment products. The respective governing documents of the Funds specify the types of investments to be made by or on behalf of each Fund. In addition, clients may impose reasonable restrictions on investing in certain securities or types of securities on their behalf; provided, however, that some restrictions applicable to other investment categories may not extend to indirect investments utilizing Exchange Traded Funds, private funds or with respect to certain third-party investment managers. In addition, a restriction or investment request may not be approved by the Advisor if it is fundamentally inconsistent with HM International’s investment philosophy, runs counter to the client’s stated investment objectives, or would prevent HM International from properly servicing client accounts.

D. Wrap Fee Programs HM International does not provide portfolio management services to a wrap fee program(s).

E. Assets Under Management As of December 31, 2025, after giving effect to the registration of the Advisor under the Advisers Act, the Advisor had approximately $1,133,060,099 discretionary assets under management as of December 31, 2025. The Advisor does not manage any client assets on a non-discretionary basis.

Item 5: Fees and compensation Fees

A. Advisory Fees HM International is compensated through fees paid by the Funds. The type and amount of fees payable to HM International is negotiated between the Firm and each Fund. Management Fees Each of the Funds the Firm advises pays a management fee (the “Management Fee”) to the Firm. The Management Fee to which HM International is entitled is in an annual amount equal to the product of (i) a specified number of basis points and (ii) the assets under management (as defined by the applicable Fund documents) at the beginning of the calendar year. The Management Fee is paid in advance in quarterly installments equal to one-fourth of the annual amount described above on the first day of each calendar quarter, or as otherwise agreed to between a Fund and the Firm. Performance Fees Currently, the Firm is not entitled to a performance fee for any Fund it advises. It is expected, however, that the Firm will charge a performance fee to one or more Funds in the future, as agreed to between the Firm and such Funds. Family Office Service Fees The fee charged by the Firm for the family offices services is a fixed fee for each Fund and other entities owned by members of the Meinig Family and the Hojel Family to which such services are provided. The amount of the fixed fee is determined on a case-by-case basis and is intended to approximate the general and administrative costs incurred by HM International in providing family office services. HM International reserves the right to waive the fee for the family offices services in its entirety on a client-by-client basis.

B. Payment Method HM International notifies each Fund of the amount of the fees due and payable to HM International pursuant to the Firm’s advisory agreement with such client. Each Fund then directs its qualified custodian to pay such fees to HM International to defray the applicable fees for investment management, investment advisory or family office services, as the case may be. The fees are typically paid on a quarterly basis as agreed upon with each client.

C. Additional Fee Information and Expenses Fees Negotiable Subject to limitations in its advisory agreements with each client, HM International retains the right to modify fees in its sole and absolute discretion, on a client-by-client basis. Factors considered include the complexity and nature of the advisory services provided, anticipated amount of assets to be placed under management, anticipated future additional assets, related accounts, portfolio style, and account composition. The specific fee schedule is identified in the advisory agreement entered into with the client. Miscellaneous Expenses HM International’s Management Fee with respect to each Fund does not include certain other charges and expenses to be paid by its clients, including (a) brokerage and other transactional charges, which are paid on a transactional basis, (b) dealer mark-ups or mark-downs on securities purchased or sold for an account through third party dealers, (c) custodian fees and (d) taxes. Professional Fees The investment advisory, investment management and family office fees charged by the Firm do not include the costs, fees or expenses associated with the services of any co-fiduciaries, accountants, broker-dealers or attorneys. Accordingly, the fees of any additional professionals engaged on behalf of a client will be allocated among the Funds in a manner that HM International considers to be reasonable. Fund Fees and Expenses HM International provides investment advice to the Funds. To the extent permitted under the applicable Fund’s governing documents, each Fund bears its own expenses, including, but not limited to, the investment advisory fee; investment expenses (e.g., expenses that the general partner or manager of the Fund reasonably determines to be related to the investment of the Fund’s assets, such as brokerage commissions (see Item 12 for more information on brokerage expenses), research expenses, interest on margin accounts, administration fees, expenses relating to short sales, clearing and settlement charges, custodial fees, bank service fees and interest expenses); legal expenses; insurance expenses; compliance expenses; professional fees (including, without limitation, expenses of consultants) relating to investments; accounting expenses (including the cost of accounting software packages); auditing and tax preparation expenses; applicable outside director fees, costs of printing and mailing reports and notices; entity-level taxes; corporate licensing; regulatory expenses (including filing fees);

organizational expenses; indemnification payments and insurance expenses and other similar expenses related to the Funds; and extraordinary expenses. Please refer to the governing documents for each Fund for additional information. Third-Party Investment Managers Fees and Expenses All fees paid to HM International for its investment advisory, investment management and family office services are separate and distinct from the fees and expenses that may be charged by third-party investment managers. Each third-party investment manager used involves different custodial, administrative, and fee arrangements, and may require certain minimum initial account investments. These fees may include performance-based fees, management fees and possible other fees. The fees charged by third-party investment managers may differ from and be higher or lower than the fees charged by the Firm.

D. Termination and Refunds Clients should consult the applicable advisory agreement with respect to any termination rights. As a general matter, if an account is terminated during a calendar quarter, fees will be adjusted pro rata based upon the number of calendar days in the calendar quarter that the investment management agreement was effective. When possible, HM International will credit a client’s account for the amount of the refund.

E. Additional Compensation Neither HM International nor its supervised persons receive commissions or other compensation for the sale of securities or other investment products in which clients invest, or on the sale of mutual funds to its clients.

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

A. Methods of Analysis and Investment Strategies

HM International provides investment advisory and investment management services to its clients pursuant to the client’s individual investment objectives, policies and strategies as described in the advisory agreement with such client. As described in Item 4 above, HM International pursues a specially pooled vehicle strategy and a fund-of-fund strategy and selects underlying third party managers of funds (the “portfolio investments”) on behalf of the clients. This investment strategy involves significant risk and is suitable only for investors who can bear the economic risk of the loss of their entire investment and who have limited need for liquidity in their investment. There can be no assurance HM International will achieve the investment objectives of each of its clients. Each prospective Fund investor should carefully review the applicable governing documents and related investment documents of a Fund prior to investing in such Fund. B. Risks Associated with Investment Strategies and Methods of Analysis

Investment decisions made by HM International by or on behalf of the Funds involve a high degree of risk and prospective investors and clients should carefully consider the below risks, among other risks, that are inherent in and affecting the Fund’s investments and strategies. Any of the below-described risks could adversely affect the Fund’s investments, financial condition and returns or losses on such investments. HM International cannot guarantee that any investment decisions that it makes will ever achieve the desired results. Risk Associated with Methods of Analysis All investment analysis requires subjective assessments and decision-making by experienced investment professionals. There is, however, always the risk of an error in judgment and decision-making. HM International’s investment analysis methods rely on the assumption that HM International is provided complete, accurate and unbiased data. While HM International is alert to indications that data may be incorrect or incomplete, there is always the risk that the Firm’s analysis, judgment and decision-making may be compromised by incomplete, inaccurate or misleading information. A risk associated with all investment analysis of the type performed by HM International is that the past performance of specific types of investments does not guarantee future results. In addition, HM International’s subjective judgment may prove incorrect or unanticipated future events may result in a failure to deliver desired results or result in substantial losses for the clients. Investing in securities involves substantial risk of loss that each client should be prepared to bear. The value of a client’s investment may be affected by one or more of the following risks, any of which could cause the return achieved on the investments with respect to which HM International provides investment advisory and investment management services to fluctuate:

Market Risk. The value of certain types of portfolio assets will fluctuate as the stock market or bond market fluctuates. The value of investments may decline, sometimes rapidly and unpredictably, simply because of economic changes or other events that

affect large portions of the market and are outside of the control of the Firm or its clients.

Management Risk. A client’s portfolio is subject to management risk because it is actively managed by HM International’s investment professionals. HM International will apply its investment strategies and techniques and risk analysis in making investment decisions for a client’s portfolio, but there is no guarantee that these strategies, techniques and analysis will produce the intended results.

Interest Rate Risk. Changes in interest rates will affect the value of a portfolio’s investments in certain types of securities, including fixed-income securities. When interest rates rise, the value of investments in fixed-income securities tend to fall and such decrease in value may not be offset by higher income from new investments. Interest rate risk is generally greater for fixed-income securities with longer maturities or durations.

Credit Risk. An issuer or guarantor of a fixed-income security, or the counterparty to a derivatives or other contract, may be unable or unwilling to make timely payments of interest or principal, or to otherwise honor its obligations. The issuer or guarantor may default causing a loss of the full principal amount of a security. The degree of risk for a particular security may be reflected in its credit rating. There is the possibility that the credit rating of a fixed-income security may be downgraded after purchase, which may adversely affect the value of the security. Investments in fixed-income securities with lower ratings tend to have a higher probability that an issuer will default or fail to meet its payment obligations. Allocation Risk. The allocation of investments among different asset classes may have a significant effect on portfolio value when one of these asset classes is performing more poorly than the others. As investments will be periodically reallocated, there will be transaction costs associated therewith which may be, over time, significant. In addition, there is a risk that certain asset allocation decisions may not achieve the desired results and, as a result, a client’s portfolio may incur significant losses.

Foreign (Non-U.S.) Risk. A portfolio’s investments in securities of non-U.S. issuers may involve more risk than those of U.S. issuers. These non-U.S. securities may be more volatile and experience greater price fluctuations, may be less liquid and may be affected by adverse market, economic, political, regulatory or other factors.

Emerging Markets Risk. Securities of companies in emerging markets may be more volatile than those of companies in developed markets. By definition, markets, economies and government institutions are generally less developed in emerging market countries. Investment in securities of companies in emerging markets may entail special risks relating to the potential for social instability and the risks of expropriation, nationalization or confiscation. Investors may also face the imposition of restrictions on foreign investment or the repatriation of capital and a lack of hedging instruments.

Currency Risk. Fluctuations in currency exchange rates may negatively affect the value of a portfolio’s investments or reduce its returns.

Derivatives Risk. Certain strategies involve the use of derivatives to create market exposure. Derivatives may be illiquid, difficult to price and leveraged so that small changes may produce disproportionate losses for a client’s portfolio and may be subject to counterparty risk to a greater degree than more traditional investments. Because of their complex nature, some derivatives may not perform as intended. As a result, a portfolio may not realize the anticipated benefits from a derivative it holds or it may

realize losses. Derivative transactions may create investment leverage, which may increase a portfolio’s volatility and may require the portfolio to liquidate portfolio securities when it may not be advantageous to do so.

Capitalization Risk. Investments in small- and mid-capitalization companies may be more volatile than investments in large-capitalization companies. Investments in smallcapitalization companies may have additional risks because these companies have limited product lines, markets or financial resources.

Liquidity Risk. Liquidity risk exists when particular investments are difficult to purchase or sell, possibly preventing HM International from selling such illiquid securities at an advantageous price. Derivatives and securities involving substantial market and credit risk also tend to involve greater liquidity risk.

Issuer Specific Risk. The value of an equity security or debt obligation issued by a specific issuer may decline in response to developments affecting such issuer, even if the overall industry or economy is unaffected. These developments may be attributable to a number of different factors, including, but not limited to, management issues or other corporate disruption, political factors adversely affecting governmental issuers, a decline in revenues or profitability, an increase in costs, or an adverse effect on the issuer’s competitive position.

Concentrated Portfolios Risk. Certain investment strategies focus on particular asset classes, countries, regions, markets, industries, sectors or types of investments. Concentrated portfolios are an aggressive and highly volatile approach to trading and investing. Concentrated portfolios hold fewer different stocks than a diversified portfolio and are much more likely to experience sudden dramatic prices swings. In addition, the rise or drop in price of any given holding is likely to have a larger impact on portfolio performance than a more broadly diversified portfolio.

Leverage Risk. While leverage presents opportunities for increasing a client’s total return, it has the effect of potentially increasing losses as well. Accordingly, any event which adversely affects the value of an investment of a client’s account would be magnified to the extent the investment is leveraged. The cumulative effect of the use of leverage in a market that moves adversely to such client’s investments could result in a substantial loss to such client which would be greater than if such account was not leveraged. • Legal or Legislative Risk. Legislative changes or court rulings may impact the value of investments or the securities’ claim on the issuer’s assets and finances. • Artificial Intelligence Risk. The Adviser’s employees and consultants and a Fund’s portfolio companies may under certain circumstances use third-party and open-source AI tools, such as ChatGPT. These tools can pose risks relating to the protection of proprietary data, including the potential exposure of the Adviser’s or such portfolio companies’ confidential information to unauthorized recipients and the misuse of the Adviser’s or third-party intellectual property, which could adversely affect the Adviser, a Fund, or its portfolio companies. AI tools may also produce inaccurate, misleading, or incomplete responses that could lead to errors in the Adviser’s and its employees’ and consultants’ business activities, which could have a negative impact on the Adviser or on the performance of a Fund and its portfolio companies. As the use and availability of AI tools has grown, the U.S. Congress and a number of U.S. federal and state agencies have been examining AI tools and their use in a variety of industries, including financial services. These agencies have issued, proposed, or adopted a variety of rules and other guidance regarding the use of AI. AI similarly faces an uncertain regulatory

landscape in many foreign jurisdictions. Ongoing and future regulatory actions with respect to AI generally or AI’s use in any industry in particular may alter, perhaps to a materially adverse extent, the ability of the Adviser, a Fund, or its portfolio companies to utilize AI. To help mitigate this risk and the unintended release of investor data outside of the Firm, the Adviser has instituted policies and procedures to guard against the misuse of AI. The Adviser has also instituted recurring employee training reminding all employees of the Firm’s acceptable use of AI tools. C. Risks Associated with Specific Securities Utilized

Read the rest in the brochure

Item 7: Types of clients

A. Clients

HM International provides investment advisory services to the Funds as described in Item 4, above. Interests in the Funds are offered only to sophisticated and qualified investors, all of whom are members of the Meinig Family or the Hojel Family. It is not expected that interests in the Funds will be offered to persons who are not members of the Meinig Family or Hojel Family, with the possible exception of one or more professionals who are employed by HM International. Investors are generally required to be sophisticated in financial matters, “accredited investors” within the meaning of Regulation D under the Securities Act of 1933, as amended, and “qualified purchasers” under the Investment Company Act of 1940, as amended, and the regulations thereunder. B. Engaging the Services of HM International

Any new clients that engage HM International for investment management or other services must first sign the applicable advisory agreement and other required documentation provided by the Firm. The advisory agreement will describe the services and responsibilities of HM International to the client. The advisory agreement will also outline HM International’s fees in detail. C. Conditions for New Clients

HM International intends to continue to limit its clients to entities owned by the Meinig Family or Hojel Family. As a condition for starting and maintaining a relationship, HM International or its affiliates may impose a minimum requirement for assets under management. If such a requirement is imposed, HM International may, in its sole discretion, require a larger amount or accept a smaller amount of initial assets from a potential client depending on the complexity and nature of the investment advisory or investment management services provided, or for any other reason deemed appropriate by HM International.

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

At the present time, HM International does not charge any fees based on a share of the capital gains or capital appreciation (i.e., growth in value) of the investments held by a Fund (also known as “performance-based fees”). It is expected, however, that the Firm will charge a performance fee to one or more Funds in the future as agreed to by such Fund and the Firm. In addition, since the Firm provides investment advisory and investment management services to multiple clients with similar investment strategies and different or potentially different fee levels on a side-by side basis, the Firm may have conflicts of interest in: (i) allocating its time, attention and activity among the multiple investment portfolios; (ii) allocating investments among the multiple portfolios; and (iii) effecting transactions among the multiple investment portfolios, including ones in which principals, and/or affiliates of HM International may have a greater financial interest. These conflicts of interest may create an incentive for the Firm to favor one Fund in which affiliates of the Firm have a greater financial interest with respect to allocation of time, attention and activity, limited investment opportunities, or, if HM International implements a performance-based fee, investments that the Firm regards as more attractive or better performing investments.

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

A. Broker-Dealer Registration and Registered Representatives

HM International is not registered, nor does it have an application pending to register, as a broker-dealer. B. Futures and Commodity Registration

HM International is not registered, nor does it have an application pending to register, as a futures commission merchant, commodity pool operator or a commodity trading advisor. No management person of HM International is registered, nor does any management person have an application pending to register, as an associated person of a futures commission merchant, commodity pool operator or a commodity trading advisor. C. Financial Industry Affiliations

HM International’s primary business is as an investment advisor as described in this brochure. D. Selection of Other Advisers

HM International does not receive, directly or indirectly, compensation from investment managers that it selects for its clients.

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

Trading A. Code of Ethics HM International has adopted a written Code of Ethics adopted pursuant to Rule 204A-1 under the Advisers Act that is intended to prevent violations of applicable federal and state securities laws. HM International’s Code of Ethics is predicated on the principle that the Firm owes a fiduciary duty to its clients. Accordingly, HM International expects all of its associated persons to act with honesty, integrity and professionalism and to adhere to federal and state securities laws. All officers, managers, directors, members and employees of the Firm and any other persons who provide advice on behalf of HM International and are subject to HM International’s control and supervision are required to adhere to the Code of Ethics. At all times, the firm and its associated persons must (i) place client interests ahead of the Firm’s; (ii) engage in personal investing that is in full compliance with the Firm’s Code of Ethics; and (iii) avoid taking advantage of their position. A copy of HM International’s Code of Ethics is available to any client or prospective client upon request. For a copy, please contact HM International at (918)-664-1914. B. Invest in Same Securities as Clients From time to time, individuals associated with HM International may buy, sell, or hold in their personal accounts the same securities that are held in client accounts. To minimize conflicts of interest, and consistent with the fiduciary responsibility HM International has to its clients, the firm has established a personal securities transaction policy that allows it to monitor the personal securities transactions and securities holdings of each of HM International’s “access persons.” HM International’s securities transaction policy requires that access persons must provide the Chief Compliance Officer with a written report of their current securities holdings within ten (10) days after becoming an access person. Additionally, each access person must provide the Chief Compliance Officer with a written report of the access person’s current securities holdings at least once each twelve (12) month period thereafter on a date HM International selects. The Chief Compliance Officer is required to review these reports to verify that personal securities transactions are conducted in accordance with the Code of Ethics. In addition, HM International and its eligible personnel or related persons may also invest in private equity and other private Funds of its or their choosing but are not required to invest in the Funds. It is expected that, if such investments are made, the size and nature of these investments will change over time. Neither HM International nor its personnel are required to keep any minimum investment in any of the Funds.

C. Engaging in Transactions at Same Time as Client From time to time, individuals associated with HM International may, at or about the same time, buy, sell, or hold in their personal accounts the same securities that the Firm recommends to its clients. This practice may create a situation where such individuals are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a potential conflict of interest. As indicated above in Item 11.B, HM International has a personal securities transaction policy in place to mitigate any potential conflicts of interest.

D. Additional Information From time to time, HM International or its related persons may purchase securities that it deems appropriate only for its or their own account. Based on the experience of HM International or its related persons holding the securities and on further research and due diligence, HM International may at a later time purchase such securities for client accounts at prices which might be higher or lower than those originally paid.

Item 12: Brokerage practices Conflicts of interest

Except for the general investment guidelines set forth in the governing documents of each Fund, there are no limitations on the authority of the Firm with respect to investment or brokerage discretion. HM International does not intend to enter into agreements with brokerdealers regarding specific amounts of brokerage, nor does HM International intend to enter into soft-dollar arrangements. HM International selects broker-dealers based on the overall benefit and quality of the services that they provide and not solely based on the amount of their fees. In some cases, federal and state laws may limit or restrict the selection of broker-dealers.

A. Brokerage Selection For those situations where HM International makes discretionary decisions regarding a direct securities investment (e.g., publicly traded equity, ETFs, money market funds) in a client’s account, HM International will direct transactions through broker-dealers that it reasonably believes will provide “best execution.” Best Execution Best execution has been defined by the SEC as the “execution of securities transactions for clients in such a manner that the client’s total cost or proceeds in each transaction is the most favorable under the circumstances.” The best execution responsibility applies to the circumstances of each particular transaction and an investment adviser must consider the full range and quality of a broker-dealer’s services, including, among other things, execution capability, commission rates, the value of any research, financial responsibility and responsiveness. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including among others, the value of research provided, execution capability, commission rates, and responsiveness. Consistent with the foregoing, while HM International will seek competitive rates, it may not necessarily obtain the lowest possible commission rates for client transactions. HM International will periodically and systematically review its policies and procedures regarding recommending broker-dealers to its clients in light of its duty to obtain best execution. Broker Analysis HM International evaluates a wide range of criteria in seeking the most favorable price and

market for the execution of transactions. These include the broker-dealer’s trading costs, efficiency of execution and error resolution, financial strength and stability, capability, positioning and distribution capabilities, information in regard to the availability of securities, trading patterns, statistical or factual information, opinion pertaining to trading and prior performance in serving HM International. HM International are responsible for continuously monitoring and evaluating the performance and execution capabilities of brokers that transact orders for client accounts to ensure consistent quality executions. In addition, HM International periodically reviews its transaction costs in light of current market circumstances and other relevant information. Soft Dollar Benefits HM International does not have any commitments or understandings to trade with specific brokers or to generate a specific level of brokerage commission with a particular broker to receive discounted brokerage or research services.

B. Trade Aggregation and Allocation HM International does not aggregate client trades. For the Funds or Fund accounts which do trade, trades generally will be processed in the order that they are placed with the broker or counterparty selected by HM International. As a result, certain trades in the same security for one client (including a client in which HM International and its personnel may have a direct or indirect interest) may receive more or less favorable prices or terms than another client, and orders placed later may not be filled entirely or at all, based upon the prevailing market prices at the time of the order or trade. The use of derivative instruments for certain client accounts may also result in different effective net prices from other accounts.

C. Investment Allocation HM International may give advice or take action with respect to the investments of one or more client accounts that may not be given or taken with respect to other client accounts with similar investment programs, objectives and strategies. Accordingly, client accounts with similar strategies may not hold the same securities or instruments or achieve the same performance. HM International also may advise accounts with conflicting programs, objectives or strategies. These activities also may adversely affect the prices and availability of other securities or instruments held by or potentially considered for one or more client accounts. Finally, HM International and its personnel may have conflicts in allocating their time, attention and services among the client accounts. HM International will devote as much time and attention to each client account as HM International deems appropriate to perform its duties in accordance with the applicable advisory agreements. HM International manages investments on behalf of a number of clients. Certain clients have investment programs that are similar to or overlap and may, therefore, participate with each other in investments. It is the policy of HM International to allocate investment opportunities among its clients fairly and equitably, to the extent possible, over a period of time. HM International, however, will have no obligation to purchase, sell or exchange any security or financial instrument for an account which HM International may purchase, sell or exchange for

another client account if HM International believes in good faith at the time the investment decision is made that such transaction or investment would be unsuitable, impractical or undesirable for a particular account. HM International generally makes investment decisions among clients depending on the particular investment strategy pursued by each client. Allocations are made in a manner that is consistent with the investment strategy outlined in the governing documents of the client. In cases where clients have the same or a substantially similar investment strategy, allocations among client accounts are then made generally on a pro rata basis in proportion to the relative value of each account eligible net assets, or on a pro rata basis in proportion to the actual position size held by each client account. However, HM International may take into consideration a number of additional factors, including, among others, the nature and size of the proportion of a securities issue likely to be available HM International or the nature and size of the proposed sale; the investment objectives and investment strategy, tax consequences (if applicable), risk tolerances, time horizons and restrictions and guidelines of client accounts; the eligibility to invest in initial public offerings; the relative size and cash availability of the applicable strategy within the account; the ability to borrow and the cost of borrowed funds; legal restrictions, including those that may arise in foreign jurisdictions; the liquidity of the investment relative to the need of each account; the degree of specialization of a client account relative to the investment offered; the relative historical participation of a client account in the investment; the difficulty of liquidating an investment for more than one client; the possibility that an allocation may result in a small or odd lot; new clients with a substantial amount of investable cash; and other factors that may be considered relevant. Investment opportunities considered by HM International to be appropriate for client accounts following similar investment strategies will generally, over time, be equitably allocated based on considerations such as relative capital, specific investment guidelines, composition of the portfolios at the time of purchase and tax considerations. HM International’s investment professionals are responsible for the investment decisions made by them on behalf of clients.

Item 14: Client referrals and other compensation Conflicts of interest

HM International does not receive an economic benefit from third parties for providing investment advisory or other advisory services to its clients. HM International does not pay any third parties for referrals and does not receive any special or added compensation from any sub-advisers or other unrelated third parties for client referrals.

Item 9: Disciplinary information

HM International is required to disclose any legal or disciplinary events that are material to a client’s or a prospective client’s evaluation of the Firm’s advisory business or the integrity of HM International’s management. As of the date of this brochure, neither HM International nor any member of its management has been involved in a material criminal or civil action in a domestic, foreign or military jurisdiction, an administrative enforcement action, or self-regulatory organization preceding that would reflect poorly upon HM International’s advisory business or the integrity of the Firm.

Item 13: Review of accounts

A. Periodic Reviews

HM International and its management personnel performs various periodic reviews of each Fund portfolio and arranges for the delivery of reports to investors in each Fund of the type and at such intervals as described below. B. Other Reviews

More frequent reviews may be triggered by material changes in variables such as a client’s individual circumstances, or the market, political or economic environment. C. Reports

HM International will generally provide annual audited financial statements of the relevant Funds, among other things, to their partners/shareholders within 120 days of the applicable Fund’s fiscal year end (or 180 days for those Funds designated as “fund-of-funds”). In addition, as soon as practicable after the end of each fiscal year, each investor will be provided the information necessary to complete federal and state tax or information returns. HM International’s personnel may participate in periodic portfolio reviews with clients at HM International’s discretion, which are attended by the appropriate members of HM International’s investment staff. While all investors generally receive similar information, to the extent an investor receives additional information (that other investors have not received), which is in addition to information provided in a Fund’s regular reports to investors, such information may provide such investor with greater insight into the Fund’s activities.

Item 15: Custody

Funds HM International may be deemed to have custody over the assets of the Funds because it is the investment adviser of the Funds and HM International or its related persons have access to such assets. Funds in which HM International serves as investment adviser are subject to audit at least annually (commencing with the year ending December 31, 2022) and audited financial statements prepared in accordance with generally accepted accounting principles are to be distributed to all limited partners within 120 days of the end of its fiscal year (or 180 days for those Funds designated as “fund-of-funds”).

Item 16: Investment discretion

HM International exercises discretion in managing its client’s investments based on the investment objectives, policies, and strategies disclosed in the applicable governing documents of each Fund. HM International generally will consult with the general partner or manager of each Fund, but not the Fund’s investors, to make investment decisions as to when the investments are to be entered into or exited as well as the total dollar amount to be invested.

Item 17: Voting client securities

HM International has adopted and implemented policies and procedures for voting proxies with respect to portfolio securities held by HM International on behalf of its clients. The policies and procedures are reasonably designed to ensure that proxies are voted in the clients’ best interest, in accordance with the Firm's fiduciary duties and Rule 206(4)-6 under the Advisers Act. HM International considers the “best interests” of its clients to mean their best long-term economic interests. General Statement of Policies and Procedures HM International votes proxies for the exclusive benefit, and in the best economic interest, of its clients. Such exercise of voting rights shall be subject to the same standard of care as is generally applicable to HM International’s performance of its duties, as set forth in the advisory agreement with each client. The policies and procedures described here are designed to be guidelines. However, each vote is ultimately cast on a case-by-case basis, taking into

consideration the relevant facts and circumstances at the time of the vote. HM International endeavors to resolve any material conflicts that may arise in the best interests of its clients. Clients may obtain a copy of HM International’s complete proxy voting policies and procedures upon request. Clients may also request and obtain additional information from the Firm on any proxies voted by HM International on behalf of their account(s).

Item 18: Financial information

A. Prepayment of Fees

Because HM International does not require, solicit or accept prepayment of more than $1,200 in fees six months or more in advance, HM International is not required to include a balance sheet with this Firm brochure. B. Financial Condition

HM International does not have any financial condition that is reasonably likely to impair the Firm’s ability to meet contractual and fiduciary commitments to its clients. C. Bankruptcy

HM International has never been the subject of a bankruptcy petition.

Timeline

  1. 1979Founded Founded1