Private company
IBEX INVESTORS LLC
Limited liability company registered in the United States, active since 2003. Summary from the record
Last updated Oct 21, 2026.
Overview
Corporate structure
IBEX INVESTORS LLC is part of a group headed by Ibex Investment Holdings LLC. 15 entities, 3 countries on record. Switch between the flow chart and the network, and select any entity to see its details.
Major holders of IBEX INVESTORS LLC
- Jbb Holdings Inc. Owns 75% or more of Ibex, since 04/2016 (Form ADV)
- Ibex Investment Holdings LLC
- IBEX INVESTORS LLC Denver, Colorado, United States
- BARFRESH FOOD GROUP INC. Stake · Los Angeles, California
- Core Scientific Stake · Miami, Florida, United States
- Galmed Pharmaceuticals Ltd. Stake · L3
- Gauzy Ltd. Stake · L3
- Ituran Stake · תל אביב-יפו
- Legacy Education Alliance, Inc. Stake · Cape Coral, Florida
- RedHill Biopharma Ltd. Stake · L3
- Riskified Stake · Tel-Aviv, Israel
- Silicom Stake · Guyancourt, France
- Tufin Software Technologies Ltd. Stake
- Ibex Israel Fund LLLP Fund · Denver, Colorado, United States
- IBEX ISRAEL PUBLIC-ONLY LP Fund · Denver, Colorado, United States
- Ibex Mobility Revolution Fund LP Fund · Denver, Colorado, United States
- IBEX INVESTORS LLC Denver, Colorado, United States
Built from parent and subsidiary links from GLEIF, the Global Legal Entity Identifier Foundation (CC0); major holders from Schedules 13D and 13G; stakes of 5% or more it reported on Schedules 13D and 13G (10 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
IBEX INVESTORS LLC 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$1.2B3 27 accounts, all with discretion
- Employees23 10 in investment advice or research
- ClientsPooled investment vehicles (other than investment companies and: 27 ($1.2B)
- How it is paidA percentage of assets under its management; Performance-based fees
- What it doesPortfolio management for pooled investment vehicles (other than investment companies)
- Holds client assetsYes: cash and securities
- RegistrationSEC 801-108035, CRD 126496 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).
- IBEX INVESTMENT HOLDINGS LLCowns 75% or more, since 04/2016
- JBB HOLDINGS INC.owns 75% or more of IBEX, since 04/2016
In its own words: the client brochure
Form ADV Part 2A, the plain-English document an adviser must give its clients, quoted as filed 3/31/2026.4 It covers the firm’s services, fees, investment strategies and their risks, and its conflicts of interest.
Item 4: Advisory business Services
Ibex Investors LLC (“Ibex”, “we” or the “Firm”) is a Colorado limited liability company, founded in February 2003. Ibex provides investment management services primarily to privately offered limited partnerships and corporate investment vehicles (collectively, the “Ibex Funds” or individually, an “Ibex Fund”) and, to a limited extent and upon request, to separately managed accounts and through sub-advisory relationships (along with the Ibex Funds, referred to herein collectively as the “clients” or individually, as a “client”). The Firm provides investment advice to its clients with respect to their portfolio investments. The Ibex Funds are managed in accordance with the investment objectives, guidelines and restrictions set forth in each Ibex Fund’s respective offering memorandum, partnership agreement, memorandum and articles of association, or similar agreement, subscription agreement and related governing documents (collectively, for each Ibex Fund, the “Governing Documents”). As of the date of this Brochure, the Firm’s primary investment strategies, which are described more fully in Item 8 below, are: (i) Israel Flagship Growth VC and Public Equity, (ii) Israel Early-Stage VC, (iii) Israel Secondary, (iv) Israel Public-Only Equity; (v) Mobility Early-Stage VC, (vi) Select Co-Investments, and (vii) Microcaps. With respect to these primary investment strategies, the Firm may execute such strategies through Ibex Funds organized as hedge funds, private equity funds, venture capital funds or other forms of private investment funds. Additionally, a strategy may be executed through separately managed accounts or sub-advisory relationships. Ibex provides investment advice to the Ibex Funds on a discretionary basis based on each Ibex Funds’ specific investment objective and strategy and does not tailor investment advice to the individual needs of any Investor nor may any Investor impose restrictions on investing in certain securities or types of securities. Ibex provides services to each Ibex Fund in accordance with the Governing Documents of such Ibex Fund and, where applicable, a management agreement by and among Ibex, an affiliated general partner of such Ibex Fund, and the Ibex Fund. Such management agreements may be terminated by Ibex or the applicable Ibex Fund with notice to the other party. The Firm considers the Ibex Funds, and not the Investors in those Ibex Funds, its clients. Certain Ibex Funds were formed as co-investment vehicles to allow Investors to invest alongside an existing Ibex Fund or the Firm in a specific portfolio company. The Firm also has the right to form one or more parallel investment funds for certain types of Investors who seek to invest in an existing Ibex Fund. There is no guarantee that Investors in a given Ibex Fund (including any parallel funds) will share in the same investment opportunities available to Investors in other Ibex Funds. The Ibex Funds based in the U.S. are offered on a private placement basis and only to persons who qualify as “accredited investors” under the Securities Act of 1933, as amended (the “Securities Act”), “qualified clients” under the Advisers Act, and with respect to certain Ibex Funds, “qualified purchasers” under the Investment Company Act of 1940, as amended (the “Investment Company Act”). The Ibex Funds based outside of the U.S. are offered on a private placement basis and only to (i) Non-US Persons (as such term is defined in the Securities Act) and (ii) U.S. investors who are “qualified purchasers” and exempt from federal income taxation.
Ibex does not participate in wrap-fee programs. See Item 7 below for information about the Firm’s authority to enter into “side letters” with certain Investors. Such Investors may receive terms that differ from the terms applicable to other Investors in a given Ibex Fund. The Firm may also offer separately-managed accounts to high-net-worth individuals and institutional clients (“separate accounts”) and may serve as sub-adviser to private investment funds or corporate investment vehicles sponsored by non-affiliated investment managers (“sub-advised funds”). A separate account or sub-advised fund may choose a strategy similar to that of an Ibex Fund or a customized strategy as agreed upon by the Firm and the client that is based on one of the Ibex Funds’ strategies. The Firm works with each separate account or sub-advised fund client to understand its investment objectives and to establish the elements of its relationship as the client’s investment adviser. This process culminates with the negotiation and preparation of an investment management agreement that outlines the terms of the client-adviser relationship, including, but not limited to, investment strategy, investment limitations and fees. The sole member and owner of Ibex is Ibex Investment Holdings LLC (“Holdco”). The principal owner of Holdco is JBB Holdings Inc., an entity wholly-owned by Justin B. Borus, who is the Chief Executive Officer, Chief Investment Officer, Manager and Founder of the Firm. As of December 31, 2025, the Firm had approximately $1,160,462,894 of regulatory assets under management, all of which are managed on a discretionary basis.
Item 5: Fees and compensation Fees
As compensation for our advisory services, the Firm receives an investment management fee based on assets under management (the “Management Fee”) and/or a performance-based incentive allocation or carried interest, which may be paid and/or allocated to either the Firm or an affiliated entity serving as the general partner of an Ibex Fund (the “Performance Fee”). Such Management Fees and Performance Fees are charged to the Investors in the Ibex Funds. The Ibex Funds also bear each of their own operating expenses. As described generally below, and more specifically in each Ibex Fund’s Governing Documents, the fees are as follows: The Management Fee, which ranges from 0.0% to 2.0% per annum depending on the Ibex Fund, is calculated and collected either monthly, quarterly or annually, in advance or in arrears depending on the Ibex Fund. Depending on the Ibex Fund and strategy, the Management Fee is based either on (i) the net asset value of each Investor’s capital account as of the first day (when paid in advance) or as of last day (when paid in arrears) of each month or quarter, as applicable, (ii) the capital commitment of an Investor, or (iii) the Investor’s pro rata portion of the aggregate capital deployed in an Ibex Fund. Fees are prorated for any partial period. The Management Fee is deducted from each Investor’s capital account in the applicable Ibex Fund and paid to the Firm directly from the Ibex Fund’s brokerage or custody account. Ibex has the right to waive or reduce Management Fees in its sole discretion with respect to any Investor, including employees of the Firm who do not pay any fees with respect to personal investments
in an Ibex Fund. Management fees are not refunded in the event of a withdrawal during any month. For certain of the Ibex Funds, the Performance Fees range from 0.0% to 50.0% of the net increase, if any, in the net value of an Investor’s capital account in the applicable Ibex Fund on an annual basis for the preceding year, subject to a loss carry-forward commonly referred to as a “high-water mark.” In certain Ibex Funds, the Performance Fee is also subject to an annual performance hurdle, below which no Performance Fee is made. The Performance Fee is generally earned and allocated at year end, upon a liquidity event, and/or or upon withdrawals by an Investor. With respect to certain other Ibex Funds, the Performance Fee is in the form of a carried interest based on distributable proceeds of the Ibex Fund. In these Ibex Funds, a carried interest is received by the general partner after the Investors have received distributions in an amount equal to their cumulative capital contributions and thereafter net proceeds are split between the Investor and general partner with the general partner receiving a carried interest between 17.5% to 50%. In certain Ibex Funds, the carried interest is subject to a performance hurdle rate. If the hurdle rate is exceeded, the general partner will receive a carried interest on the full amount of distributions, not solely on the distributed amount in excess of the hurdle rate. Performance Fees in the Ibex Funds are allocated to the Firm or an affiliated entity through a re-allocation from the capital accounts of Investors in the applicable Ibex Funds to the capital account of the Firm or the affiliated entity, as applicable. The Firm, or the affiliated entity, as applicable, has the right to waive or reduce its Performance Fee with respect to any Investor in its sole discretion, including employees of the Firm who do not pay any fees on personal investments in an Ibex Fund. Investors in some of the Ibex Funds benefit from a “clawback,” calculated and due upon the Ibex Fund’s liquidation that, subject to certain limitations, requires Ibex to restore to the Investors amounts by which the Performance Fees Ibex receives over the life of the Ibex Fund exceed the stated Performance Fee percentage. Certain Ibex Funds in the Select Co-Investment strategy that do not charge fees or charge reduced fees, also charge investors a withdrawal fee which is applicable if the investor withdrawals from one of the other fee-paying Ibex Funds. These withdrawal fees result in the investor being charged Management Fees between 1.5% to 2% and Performance Fees between 15% to 20% instead of the reduced fees in effect prior to the trigger of the withdrawal fee. Investors should refer to the Ibex Fund Governing Documents for more information as to the circumstances when there may be an early withdrawal fee in a particular Ibex Fund. Other fees and expenses that the Ibex Funds may pay directly, or reimburse the Firm or its affiliated entity for, include, without limitation: (i) organizational expenses; (ii) all expenses incurred in connection with the ongoing offer and sale of Ibex Fund interests, including, but not limited to, the preparation and printing of Governing Documents and any supplements and exhibits thereto, marketing expenses (including travel and travelrelated expenses) and documentation of performance and the admission of Investors; (iii) investment expenses related to the purchase, sale, trade, custody or transfer of Ibex Fund assets, including brokerage costs and commissions, finders’ fees, clearing and settlement charges, custodial fees, investment advisory fees, markups and markdowns, transfers, capital and other taxes, duties and costs and interest expense; (iv) expenses related to consultants, brokers and other professionals, and advisors who
provide research, advice or due diligence services (including fees for research and investment reports, studies and analyses); (v) research-related costs and expenses (including fees for news, market data, data feeds, software and databases (including costs of computer terminals and other equipment used primarily for research), related maintenance or other technology fees, quotation and similar information, execution and pricing services); (vi) due diligence expenses, including travel and travel-related expenses related to investment selection, monitoring and administration (including travel to professional conferences in connection with potential investments and travel expenses related to meetings with management teams); (vii) the Ibex Fund’s proportionate share of the fees and costs assessed by other investment vehicles and/or accounts in or through which the Ibex Fund invests assets; (viii) any costs and expenses incurred by the Ibex Fund in connection with converting the Ibex Fund from its current structure or otherwise restructuring the Ibex Fund; (ix) expenses for professional services, such as accounting, asset valuation, audit and third-party administration fees, legal expenses (including, without limitation, the costs of on-going legal advice and services, blue sky filings and all costs and expenses related to or incurred in connection with the Firm’s compliance obligations under applicable federal and/or state securities, investment adviser and commodity pool operator laws arising out of its relationship to the Ibex Fund, as well as extraordinary legal expenses) and other professional services; (x) all expenses for preparation of the Ibex Fund’s financial statements, tax returns and filings, including Investor’ Schedule K-1s, tax preparation and any applicable tax liabilities (including transfer taxes and withholding taxes), and expenses related to maintenance of the Ibex Fund’s books and records; (xi) (A) expenses and fees incurred in connection with the registration, qualification or exemption of the Ibex Fund under any applicable laws and expenses related to the maintenance thereof; (B) all expenses incurred in connection with the preparation of, and alterations and amendments to, the partnership agreement or the certificate of limited partnership; (C) all taxes, fees or other governmental charges or fees levied against the Ibex Fund and all expenses incurred in connection with any tax audit, investigation, settlement or review of the Ibex Fund or its activities; (D) all principal, interest, fees, expenses and other amounts payable in respect of or in connection with borrowings, pledges or other financings by the Ibex Fund; (E) all expenses incurred in connection with the collection of amounts due to the Ibex Fund from any person; (F) all expenses incurred in connection with any litigation involving an Ibex Fund and the amount of any judgment or settlement paid in connection therewith; (G) all liabilities for indemnity or contribution to any person whether payable under the Governing Documents or otherwise and whether payable in connection with any litigation involving the Ibex Fund or otherwise; and (H) all expenses incurred in connection with administrative proceedings relating to the determination of items at the partnership level undertaken by the partnership representative; (xii) director and officer and/or errors and omissions liability insurance premiums or fiduciary liability insurance premiums for directors, officers and personnel of the Firm or an affiliated entity; (xiii) expenses of Investor communications, including, but not limited to, preparing and distributing any statements, reports and notices to the Investor; (xiv) expenses incurred in connection with transactions not consummated and all other reasonable expenses related to the management and operation of the Ibex Fund or the purchase, sale or transmittal of Ibex Fund assets; (xv) all costs and expenses associated with preparing, negotiating and entering into contracts and arrangements in the ordinary course of the Ibex Fund’s business, including services agreements with counterparties (e.g., brokerdealers and placement agents); (xvi) indemnifications, costs of litigation and other
extraordinary expenses; (xvii) fees incurred in connection with the maintenance of bank or custodian accounts; and (xviii) expenses associated with the termination, dissolution and winding up of the Ibex Fund (in each case, as the general partner determines in its sole discretion). See the applicable Ibex Fund’s Governing Documents for additional detail on fees and expenses. See Item 12 below for more information on certain fees charged by broker-dealers and the Firm’s use of soft dollars. The expenses listed above that are directly attributable to a specific Ibex Fund will be borne by such Ibex Fund. All other expenses listed above will be allocated amongst the Ibex Funds in the Firm’s discretion using various allocation methodologies, including in proportion to their respective net asset values, based on the amount invested in a position, equally across participating Ibex Funds, or in such other manner as determined by the Firm. The Firm has the discretion to allocate such expenses using these and other methodologies that may vary from time to time. Choosing an expense allocation methodology involves conflicts of interest based on account sizes, impact on performance, the amount of investments by the Firm or its affiliates in the relative Ibex Funds and differing fee amounts. Expenses borne by one Ibex Fund may disproportionately benefit another Ibex Fund to the extent position sizes differ. See Item 7 for additional information about the Firm’s authority to enter into “side letters” with certain Investors that may result in such Investors being charged reduced fees or expenses when compared to other Investors. The Firm may allocate a portion of an Ibex Fund’s assets to unaffiliated money market funds, exchange-traded funds or similar products that bear certain fees and expenses including those payable to their investment managers and service providers. To the extent we make such allocations, the applicable account will indirectly bear these fees and expenses in addition to the other fees and expenses described herein. The Firm may pay or advance to one or more Ibex Funds amounts necessary to pay for the Ibex Fund’s organizational expenses and expenses incurred in connection with the initial offering and sale of the interests and other similar expenses related to an Ibex Fund. The Firm is entitled to reimbursement from the applicable Ibex Funds for all such amounts. All fees and expenses are accrued or paid when incurred and therefore there are no substantial prepaid expenses. Neither the Firm nor its employees receive any compensation for the purchase or sale of any securities which could create a conflict of interest with the investors of the Ibex Funds. As compensation for the Firm’s advisory services, each separate account or subadvised fund client may pay an investment management fee based on assets under management, a performance-based incentive fee, or both. Performance fees are established in compliance with Rule 205-3 under the Advisers Act. See Item 6 below for a further discussion of such fees. Management fees and performance fees for separate accounts and sub-advised funds are negotiable and may be subject to a performance hurdle and/or high-water mark treatment. In addition to the management fee and performance fee, separate accounts and sub-advised funds bear trading costs and custodial fees associated with their accounts. These expenses may include ticket charges, commissions, execution and clearing fees and costs, financing costs on the
Item 8: Methods of analysis, investment strategies and risk of loss Investment strategies and risks
Methods of Analysis and Investment Strategies The Firm’s methods of analysis and investment strategies are described in more detail below. Each investment strategy may be employed by one or more Ibex Funds, managed accounts or sub-advised funds. Israel Flagship Growth VC and Public Equity. This strategy invests and trades in a wide variety of securities and financial instruments of all kinds and descriptions, both public and private, primarily of companies based in or related to Israel, though the strategy may also make investments unrelated to Israel. The strategy’s investments may include, but are not limited to, common and preferred stocks, bonds and other debt securities, convertible securities, limited partner interests, options, warrants, contracts for differences, commodities, futures, derivatives (including swaps, forward contracts and structured instruments), royalty agreements, currencies, monetary instruments, initial public offerings (“IPOs”), secondary offerings, exchange-traded funds, exchangetraded notes, special purpose acquisition companies (“SPACs”), securities associated with long lending programs, short sales, margin programs, and cash and cash equivalents. While the strategy has the ability to engage in short selling and hedging (and may do so), the strategy focuses principally on taking long positions. The Firm may trade in derivative securities, including options and may purchase and write “put” and “call” options that are traded on national securities exchanges or over-the-counter markets, as well as on electronic communications networks, or created through an arrangement with a counterparty. Options can be used in many ways, such as to increase market exposure (i.e., for purposes of leverage), to reduce overall market company-specific exposure (i.e., for hedging purposes), to increase the portfolio’s current income, or to reduce the cost basis of a new position. The strategy may also utilize certain options, such as various types of index or “market basket” options, in an effort to hedge against certain market-related risks, as the Firm deems appropriate. The investment objective of the strategy is to maximize long-term capital appreciation while managing the inherent risk within the investment portfolio as a whole. The focus of the strategy’s investments shall generally be public and private companies (and securities related thereto) based in or related to Israel, regardless of the company’s domicile, headquarters, office locations, primary place of business, or listing exchange. The strategy may also invest or participate in securities, financial instruments, or business arrangements unrelated to Israel. The strategy shall generally make investments that the Firm believes offer attractive risk/reward characteristics or serve a function within a portfolio, such as cash management, risk management, hedging, tax management, market factor capture, or another function. The strategy: (i) focuses on
Israeli companies, which the Firm believes represent a segment that has been underappreciated and overlooked by the investment community; (ii) employs a hybrid strategy of investing in both public and private companies; (iii) benefits from pricing inefficiencies caused by a lack of information and apathy within the financial community; (iv) capitalizes on the selectivity afforded to a small fund relative to larger public equity funds; and (v) seeks to follow a disciplined approach to selecting attractive companies at appealing prices. The Firm pursues an opportunistic investment strategy across a variety of sectors, including but not limited to: Information Technology, Communications, Defense (including Security), Life Sciences (including Medical Devices and Pharmaceuticals), Energy, Financial Services, Media (including Advertising), Retail and Consumer Products, Industrials, and Services. The strategy’s portfolio companies may be listed on stock exchanges not only in Israel but also in the United States, Canada, the United Kingdom, Switzerland, Germany, or other global markets. The Firm believes industry-specific knowledge is crucial for success in any investment strategy and generally employs a disciplined investment philosophy, investing in industries where the Firm has prior investment experience or is able to leverage the industry expertise of its advisors or other resources. The Firm may invest in companies that are at all stages of development and the strategy is not constrained by a predetermined allocation between public company and private company investments or between public companies that have large capitalizations or small capitalizations, but will seek to capitalize on attractive opportunities taking into account its overall portfolio. The Firm’s investment process for the strategy involves consideration of some of the following steps which in the opinion of the Firm are applicable to a given investment: Idea Generation: (i) Leverage extensive network of industry experts, both in Israel and globally; (ii) attend conferences focused on Israeli companies or industries of particular interest; (iii) maintain an office in Israel to meet with companies, investors, intermediaries and advisers; (iv) proactively seek out and review independent and trusted research; (v) filter through varied sources of public information to understand key drivers of supply and demand, competition, emerging technologies and market conditions; (vi) conduct screening using available software; and (vii) review public filings from companies listed on U.S., Israeli or other relevant international exchanges. Identification of Attractive Companies: (i) poised for growth but have not yet realized their potential; (ii) top quality technology or products whose business potential has not been fully exploited; (iii) unfulfilled potential expansion into U.S., European, and/or Asian markets; (iv) undervalued or orphaned by the investment community; (v) fundamentally strong with recent earnings shortfalls or delayed milestone achievements; and (vi) premature IPOs or changes in management teams. Filtering for Target Characteristics: (i) strong business fundamentals; (ii) unique technology, products, or competitive advantages; (iii) top and bottom line growth; (iv) recurring revenue and strong sales pipeline; (v) rational cost structure; (vi) attractive balance sheets: (vii) catalysts that will force investment community to take notice; and (viii) under the radar of the investment community.
Analysis of Fundamentals: (i) management team; (ii) business model; (iii) customer base and revenue stream: (iv) balance sheet and financial statements; (v) cost structure; (vi) opinions of customers, industry experts, investors and detractors; (viii) potential upside; (ix) risks and potential downside; (x) competitive landscape; and (xi) attractive entry and exit valuations. Investment and Monitoring of Positions: (i) valuation models; (ii) financial statements; (iii) quarterly earnings calls; (iv) research reports; (v) comparisons to peer group; (vi) in-depth discussions with management team and executive officers; (vii) site visits; and (viii) 3 to 5-year industry outlook. Closing of Positions: (i) company has approached or reached the Firm’s internal target price and risk-to-reward makes valuation no longer compelling; (ii) exit achieved through acquisition or management buy-out, (iii) deterioration in investment thesis or business fundamentals or management execution; (iv) sector outlook has fundamentally deteriorated; and (v) consideration of additional information or analysis after investment initiation. Israel Public-Only Equity. The Firm’s Israel Public-Only strategy’s focus is on investments in public companies (and securities related thereto) based in or related to Israel, regardless of the company’s domicile, headquarters, office locations, primary place of business, or listing exchange although some investments may also be in securities, financial instruments, or business arrangements unrelated to Israel. Target investments are in companies that are at all stages of development and the strategy is not constrained by a predetermined allocation between public companies that have large capitalizations or small capitalizations, but will seek to capitalize on attractive opportunities taking into account the overall portfolio. Investments may include common and preferred stocks, bonds and other debt securities, convertible securities, limited partner interests, options, warrants, contracts for differences, commodities, futures, derivatives (including swaps, forward contracts and structured instruments), royalty agreements, currencies, monetary instruments, IPOs, secondary offerings, exchange-traded funds (“ETFs”), exchange-traded notes, special purpose acquisition companies (“SPACs”), securities associated with long lending programs, short sales, margin programs, and cash and cash equivalents. The Firm pursues an opportunistic investment strategy across a variety of sectors, including but not limited to: Information Technology, Communications, Defense (including Security), Life Sciences (including Medical Devices and Pharmaceuticals), Energy, Financial Services, Media (including Advertising), Retail and Consumer Products, Industrials, and Services. Companies may be listed on stock exchanges not only in Israel but also in the United States, Canada, the United Kingdom, Switzerland, Germany, or other global markets. While the strategy may engage in short selling and hedging, the focus is principally on taking long positions and trading in derivative securities, including options. The strategy may purchase and write “put” and “call” options that are traded on national securities exchanges or over-the-counter markets, as well as on electronic communications networks, or created through an arrangement with a counterparty. Options can be used in many ways, such as to increase market exposure (i.e., for purposes of leverage), to reduce overall market company-specific exposure (i.e., for hedging purposes), to increase the portfolio’s current income, or to reduce the cost basis of a new position. The strategy may also utilize certain options, such as various types of index or “market
Item 7: Types of clients
The client accounts of the Firm as of December 31, 2025 were the Ibex Funds. The Firm has in the past and may in the future provide the same or similar services to other privately placed investment funds, separately managed accounts or sub-advisory relationships. Separately-managed accounts are offered on a limited basis to highnet-worth individuals and institutions, upon request, and the minimum account size for a separately-managed account is negotiable. Similarly, sub-advisory services are offered to institutional investors, upon request, and the minimum account size is negotiable. Investors in the Ibex Funds include high net-worth individuals, family offices and institutional investors. In order to be eligible to invest in a U.S.-based Ibex Fund, an Investor must be (1) an “accredited investor” within the meaning of Regulation D under the Securities Act, and (2) a “qualified client” within the meaning of the Advisers Act or a “qualified purchaser” within the meaning of the Investment Company Act. In order to invest in an Ibex Fund based outside of the U.S., an Investor must be (1) a Non-U.S. Person (as defined in the Securities Act) or (2) a U.S. investor that is a “qualified purchaser” and exempt from federal income taxation. Each Investor is required to represent that its investment in the Ibex Fund is being acquired for its own account, for investment, and not with a view to resale or distribution. Investments in the Ibex Funds are suitable only for sophisticated Investors for whom an investment in the Ibex Fund does not constitute a complete investment program and who fully understand, are willing to assume, and who have the financial resources necessary to withstand the risks involved in the Ibex Fund’s specialized investment program and to bear the potential loss of their entire investment in those investments. The Ibex Funds generally have stated minimum initial investment requirements ranging from $25,000 to $1,000,000 as set forth in the applicable Governing Document. These minimum initial investment thresholds can be waived at the Firm’s discretion. The Firm on behalf of the Ibex Funds may enter into separate agreements, commonly referred to as “side letters,” or other similar agreements with a particular Investor in connection with its admission to an Ibex Fund without the approval of any other Investor (other than an Investor whose share rights would be materially and adversely changed by such separate agreement), which would have the effect of waiving, altering, or otherwise modifying the terms of the applicable Ibex Fund’s Governing Document to the benefit of such Investor. Other Investors in the applicable Ibex Fund will not be entitled to receive the terms of such side letter. Such rights or terms in any such side
letter may include, without limitation: (i) more frequent reporting obligations, (ii) reduced fees, (iii) liquidity and notice, (iv) minimum investment amounts, (v) most favored nation provisions, and (vi) preferred access to co-investment opportunities. While the ability of an Ibex Fund or its general partner to enter into a side letter or similar agreement affording preferential rights to certain investors is generally disclosed to other investors in an Ibex Fund, the terms of such “side letters” or similar agreements are generally not disclosed to other investors in the Ibex Fund, except to investors that have separately negotiated for the right to review such agreements.
Item 6: Performance-based fees and side-by-side management Conflicts of interest
As discussed in Item 5, the Firm or an affiliated entity is entitled to receive performance-based fees, allocations, or carried interest (collectively, the “Performance Fees”) from the Ibex Funds, separate account clients and sub-advised funds. Conflicts of interest may arise from the payment of the Performance Fees. The existence of Performance Fees may motivate the Firm to make investments that are riskier or more speculative than it would if it was not eligible to receive the Performance Fees. See Item 10 for additional information about the conflict of interest that this compensation structure creates for the Firm’s investment personnel. This conflict is heightened when the Performance Fee is payable or allocable only upon exceeding a high-water mark or performance hurdle and the value of an Investor’s investment in an Ibex Fund, separate account or sub-advised fund is below such high-water mark or performance hurdle. Furthermore, because the Performance Fee is calculated differently for different Ibex Funds, separate accounts or sub-advised funds and each Ibex Fund, separate account and sub-advised fund has different returns, the Firm may be incentivized to place its best investments into those Ibex Funds, separate accounts or sub-advised funds where the largest Performance Fee may be taken. The allocation of expenses also may result in similar conflicts. The Firm has implemented procedures intended to address conflicts relating to the management of multiple Ibex Funds, separate accounts and sub-advised funds, including Ibex Funds, separate accounts and sub-advised funds with differing fee
arrangements, and the allocation of investment opportunities. The investment professionals review investment decisions for the purpose of ensuring that all Ibex Funds, separate accounts and sub-advised funds with substantially similar investment objectives are treated equitably. Additionally, the performance of the Ibex Funds, separate accounts and sub-advised funds is reviewed and compared by the investment professionals to determine whether there are any unexplained significant discrepancies. Finally, the Firm’s procedure relating to the allocation of investment opportunities require that similarly managed Ibex Funds, separate accounts and subadvised funds participate in investment opportunities in a fair and equitable manner. For a description of how the Firm allocates investments amongst the Ibex Funds, separate accounts and sub-advised funds, see Item 12.
Item 10: Other financial industry activities and affiliations Conflicts of interest
Certain Ibex Funds are formed as limited partnerships and as such require a general partner. As of December 31, 2025, and depending on the Ibex Fund, either the Firm, Ibex GP LLC, Ibex Israel VC GP LLC, Ibex Israel VC GP II, LLC, Ibex Mobility Revolution VC GP LLC, Ibex Israel Secondary GP, LLC or Ibex Select Co-Investment GP, LLC, affiliates of the Firm, serve as general partners. The manager and executive officers of Ibex are also the manager and executive officers of Ibex GP LLC, Ibex Israel VC GP LLC, Ibex Israel VC GP II, LLC, Ibex Mobility Revolution VC GP LLC, Ibex Israel Secondary GP, LLC and Ibex Select Co-Investment GP LLC. As discussed in Items 5 and 6, this relationship and the Performance Fee to which the Firm or the affiliated general partners are entitled to receive, creates an incentive for Ibex to make investments that are riskier or more speculative than would be the case in the absence of performancebased compensation. Such conflict of interest is addressed as set forth in Items 5 and 6 above.
Item 11: Code of ethics, participation or interest in client transactions and personal trading Conflicts of interest
Trading The Firm and its employees are permitted to buy or sell securities for their own accounts that the Firm also purchases or sells for clients, consistent with the Firm’s policies and procedures. Additionally, the Firm and certain of its employees have a financial interest in the Ibex Funds through a performance-based fee, allocation, carried interest and/or direct investment. To address potential conflicts of interest, the Firm has adopted a Code of Ethics (the “Code”) that obligates the Firm and its employees to put the interests of the Firm’s clients before its own interest and to act honestly and fairly in all respects in its dealings with clients. All employees are also required to comply with applicable federal securities laws. Clients, prospective clients and Investors may obtain a copy of the Code by contacting the Firm’s Chief Compliance Officer by telephone at (303) 500-8821, by email at compliance@ibexinvestors.com, or by sending a written request to Ibex Investors LLC, Attention: Chief Compliance Officer, 101 S Madison St, Denver, Colorado 80209. The Code sets forth the standards of conduct expected of Firm employees and contains written policies reasonably designed to prevent the unlawful use of material non-public information by the Firm and its employees. The Code also requires that access persons report their personal securities holdings and transactions and obtain pre-approval of specified personal securities transactions from the Chief Compliance Officer. The Chief Compliance Officer may restrict employee trading for any reason, including if: (i) the Firm is in possession of material non-public information about a company; (ii) an employee’s trading could present a conflict of interest vis-à-vis a client account or cause a client account to be harmed; or (iii) the employee’s trading could be considered improper and/or illegal, as determined by the Chief Compliance Officer. Subject to applicable regulatory restrictions, senior management and employees of the Firm may choose to personally invest, directly and/or indirectly, in certain Ibex Funds managed by or advised by the Firm. The senior management and employees are not required to keep any minimum investment in any of the Ibex Funds, and the size and nature of the investments change over time. Investments by the senior management
and employees in a particular Ibex Fund could incentivize the senior management and employees to increase or decrease the risk profile of such Ibex Fund. The Firm and its management persons will devote as much of their time to the activities of each Ibex Fund as they deem necessary and appropriate. The Firm and its management persons are not restricted from forming and advising additional pooled investment vehicles, from entering into other investment advisory relationships or from engaging in other business activities, even if such activities involve substantial time and resources of the Firm and its management persons. These activities could be viewed as creating a conflict of interest in that the time and effort of the Firm and its management persons will not be devoted to the business of specific Ibex Funds but will be allocated among the business of all of the Firm’s clients.
Item 12: Brokerage practices Conflicts of interest
We have adopted the following policies and practices to meet the Firm’s fiduciary responsibilities and to ensure our trading practices are fair to all clients and that, except where noted below, no client is advantaged or disadvantaged over any other. Best Execution The following policies apply to transaction costs, whether related to equity, fixed income, derivative or currency transactions, and whether in the form of a commission, spread or other compensation, relating to portfolio transactions for client accounts. The Firm’s overriding objective in effecting portfolio transactions is to seek best execution for its clients’ securities transactions. It is not necessary to select the broker offering the lowest commission rate. The Firm may cause a client account to pay a broker a commission in excess of that which another broker might have charged for effecting the same transaction in recognition of the value of the brokerage and other services provided by the broker. The Firm should seek to obtain the most favorable terms reasonably available under the circumstances by taking into consideration the following qualitative and quantitative factors: research; liquidity/pricing; price and commission rate; transactional considerations; reliability/responsiveness; financial stability; regulatory history and industry reputation; and other factors suggested by the SEC for determining best execution. All of the foregoing procedures cannot be rigidly applied to every trade. Rather the Firm should assess these procedures in the context of each trade and apply them appropriately. In certain cases, the circumstances of a trade may dictate the type of broker used for execution. For example, depending on the size or type of transaction, some brokers may offer lower commission rates, but be unable to provide the same level of liquidity or quality of execution as full-service brokers. In unique transactions, other criteria may influence the Firm’s decision to use a certain broker. The factors above, among other factors, are monitored by the Firm. Based upon all factors considered, the Firm is responsible for making a good faith determination that the brokerage and commissions paid are reasonable in relation to the value of the brokerage and research services provided by brokers that are used to execute trades for the Firm’s clients. The Firm reviews trading activity to monitor brokers utilized to
effect client transactions, as well as to assess the Firm’s ongoing best execution obligation to its clients. Soft Dollars In the event that the Firm utilizes soft dollars, it will do so solely to pay for products or services that qualify as “research and brokerage services” within the meaning of Section 28(e) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”). Section 28(e) of the Exchange Act provides a “safe harbor” to investment advisers who use soft dollars generated by their advised accounts to obtain investment research and brokerage services that provide lawful and appropriate assistance to such investment advisers in the performance of investment decision-making responsibilities. The term “soft dollars” refers to the receipt by an investment adviser of products and services provided by brokers, without any cash payment by such investment adviser, based on the volume of revenues generated from brokerage commissions for transactions executed for clients. The products and services available from brokers include both internally generated items (such as research reports prepared by employees of the broker) as well as items acquired by the broker from third parties. Research services furnished by brokers may include (but are not limited to) written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; statistics and pricing or appraisal services; discussions with research personnel; and invitations to attend conferences or meetings with management or industry consultants. To monitor the Firm’s use of research and brokerage products and services, all requests for research or brokerage products or services require approval from the Firm’s operations and compliance groups. Aggregation and Allocation As a matter of policy, the Firm’s allocation procedures must be fair and equitable to all clients with no particular client(s) being favored or disfavored over any other clients. The Firm will allocate investment opportunities in a fair and equitable manner and not based upon account performance, applicable fee structures or other conflicts of interest that may give rise to preferential treatment. The Firm will avoid any action that could result in an unfair or inequitable disadvantage to any client account. The Firm’s obligation is to treat all client accounts fairly, but not necessarily identically. Allocation decisions will be based on a consideration of matters such as portfolio composition and investment objectives of a particular client account. Allocation decisions should not be based on a consideration of such matters as fee arrangements, or relationships to an employee of the Firm. The Firm may make such allocations among client accounts in any manner which it considers to be fair under the circumstances, including but not limited to allocations based on relative account sizes, the degree of risk involved in the securities acquired, the extent to which a position in such securities is consistent with the investment policies and strategies of the client accounts involved, the extent to which the position affects the overall liquidity of the accounts involved, and the materiality of the potential position size relative to overall account capital. Trade allocation and aggregation activities are reviewed by portfolio managers, operations and compliance.
When possible, the Firm will execute transactions on an aggregated basis if it believes that to do so will allow it to negotiate more favorable commission rates or reduce or avoid other transaction costs that might have otherwise been paid had such orders been placed independently. When aggregating orders, all client accounts will be treated in a fair and equitable manner. The following procedures will apply to all aggregated transactions: • Seek Best Execution. The Firm will not aggregate orders unless aggregation is consistent with our duty to seek best execution and the terms of the investment guidelines and restrictions of each client account for which trades are being aggregated. • Fair Treatment. No client account will be favored over any other account; each account that participates in an aggregated order will participate at the average price for all transactions in that security on a given business day, with transaction costs allocated pro rata unless otherwise determined in the discretion of the Firm. • Safeguarding Fund Assets. Each account’s assets will be deposited with one or more custodians, and the account’s assets will not be held collectively any longer than is necessary to settle the purchase or sale in question; cash or securities held collectively for the client will be delivered to the custodian as soon as practicable following settlement. Strategy portfolio managers, in consultation with the investment committee for each strategy and the Chief Investment Officer, are responsible for selecting investments on behalf of the client accounts. Once they determine that a particular security or other instrument should be purchased or sold for the account, the portfolio managers are responsible for determining the availability of the particular investment and allocating the investment among participating accounts. Employees of the Firm may not engage in principal transactions between a personal account (including the account of a family member) and any client account. An employee may not cause one client account to sell a security to another client account in a cross transaction if any employee or other affiliate of the Firm will receive any compensation from any source for acting as broker. If the Firm elects to engage in cross trading, it will only engage in cross transactions (causing one client account to buy or sell securities from or to another client account) when the transaction is in the interests of, and consistent with the investment objectives and policies of, both accounts involved in the transaction. If a cross transaction is considered, it is the Firm’s policy to effect all cross transactions in an equitable and fair manner for all clients involved. No brokerage commission, fee (except for customary transfer fees) or other remuneration shall be paid in connection with any cross transactions between client accounts.
Item 14: Client referrals and other compensation Conflicts of interest
As discussed in Item 12, the Firm may receive research or services from broker-dealers through a soft-dollar arrangement. Please see Item 12 for full disclosure. With respect to one or more of the Ibex Funds, the Firm may enter into arrangements with placement agents pursuant to which the placement agents will be compensated by the Firm based on a percentage of the fees received by the Firm from Investors that the placement agents are responsible for introducing to the Firm. The fees paid to the placement agent do not result in an increase in fees paid by Investors and no Investor pays fees directly to the placement agent. The Firm requires that, to the extent applicable, all agreements with placement agents comply with Rule 206(4)-1 under the Advisers Act and that all placement agents be properly registered with all relevant regulatory bodies as may be required, including the SEC and FINRA, if applicable, and comply with all applicable laws.
Item 9: Disciplinary information
Neither Ibex nor any management person has reportable disciplinary information.
Item 13: Review of accounts
The client accounts managed by the Firm are reviewed on a continual basis by the portfolio manager of the particular account and the other members of the investment committee for each strategy to assure conformity with investment objectives and guidelines. The investment committee for each strategy is composed of the investment professionals and portfolio managers for each respective strategy. More extensive review of particular securities in an account may be performed on a daily or weekly basis depending upon the nature of the investment and the status of various factors that are used by us to monitor, rebalance and effect transactions in the accounts. The Firm provides Investors with account statements, market commentary, performance information, and annual audited financial statements for the applicable Ibex Fund. The frequency of reporting varies depending upon the Ibex Fund and the applicable Ibex Fund Governing Documents. Any separately managed accounts and sub-advisory relationships will receive reporting and further information as set forth in the applicable management agreement governing the relationship.
Item 15: Custody
All client accounts and assets are held in custody by unaffiliated broker/dealers or banks. However, the Firm or an affiliated general partner is deemed to have custody of each of the Ibex Funds in its role as the general partner of each Ibex Fund or because a Firm principal serves as a director of a particular Ibex Fund even though the Firm does not physically hold the securities and other assets of the Ibex Funds, except consistent with certain regulatory guidance regarding private stock certificates in certain limited circumstances. A qualified custodian serves as the custodian of the securities and uninvested cash of each of the Ibex Funds, which securities and cash are held directly by the custodian in a segregated account in the name of the applicable Ibex Fund. In addition, the Firm utilizes unaffiliated administrators to provide certain financial, accounting, administrative and other services on behalf of the Ibex Funds, including disbursing payment of Ibex Fund expenses, maintaining a registry for the ownership and transfer of Ibex Fund interests, maintaining the books and records of the Ibex Funds, coordinating with the auditors for the audit of the books and records
and preparing and distributing reports to each Investor. The Firm encourages all clients and Investors to carefully review all statements and reports provided to them in connection with their investment. The books and records of each Ibex Fund are audited at the end of each fiscal year by a firm of independent certified public accountants registered with the Public Company Accounting Oversight Board. Investors are furnished with audited year-end financial statements prepared in accordance with generally accepted accounting principles within 120 days of year-end. Investors are also furnished with other periodic information concerning their investment in an Ibex Fund as set forth above in Item 13. In the event of a liquidation of an Ibex Fund, each Investor will receive a final liquidation audit report prepared in accordance with generally accepted accounting principles.
Item 16: Investment discretion
Prior to assuming full discretion in managing a client’s assets, Ibex enters into an investment management agreement or other agreement that sets forth the scope of Ibex’s discretion. As investment adviser to the Ibex Funds, and pursuant to each Ibex Fund’s Governing Documents or investment management agreement, the Firm has full discretion with respect to securities transactions affected for the Ibex Funds and exercises its investment discretion consistent with each of the Ibex Fund’s respective investment strategies as set forth in the applicable Governing Documents. The Firm has the authority to determine (i) the securities to be purchased and sold for an Ibex Fund, and (ii) the amount of securities to be purchased or sold for an Ibex Fund.
Item 17: Voting client securities
The Firm has established policies and procedures to address voting procedures and any conflicts of interests involved in a proxy vote between the Firm and a client. The Firm’s proxy voting procedures are designed to ensure that proxies are voted in a manner that is in the best interest of the client. The Firm will generally vote in favor of matters that follow an agreeable corporate strategic direction, support an ownership structure that enhances shareholder value without diluting management’s accountability to shareholders and/or present compensation plans that are commensurate with enhanced manager performance and market practices. While proxy voting on all issues presented should be considered, voting on all issues is not required. Some issues presented for a proxy vote of security holders are not deemed relevant to the Firm’s voting objective, or it is not reasonably possible to ascertain what effect, if any, a vote on a given issue may have on a client’s investment. Additionally, the Firm may decide that avoiding further expense and investigation and not voting at all on a presented proposal may be in the best interest of a client. Accordingly, the Firm may abstain from voting in certain circumstances. The Firm endeavors to identify conflicts of interest in a proxy vote and if a material conflict of interest exists, the Firm will determine how to vote the proxy consistent with the best interests of the client account. The Firm retains records of (i) proxy voting policy and procedures, (ii) proxy statements received for client securities, (iii) records of votes cast on behalf of clients, (iv) written client requests for proxy voting information and written adviser responses to any client
request (whether oral or written) for proxy voting information, and (v) any documents prepared by the Firm that were material to making a proxy voting decision or that memorialized the basis for the decision. The Firm will provide clients with a copy of the Firm’s proxy voting policy upon request. Questions related to the policy, the proxy voting process and/or information regarding how the Firm voted proxies relating to the client’s portfolio securities may be obtained by clients, free of charge, by contacting the Chief Compliance Officer at compliance@ibexinvestors.com.
Item 18: Financial information
The Firm is not required to provide a balance sheet in response to this item and is not subject to any financial condition that is reasonably likely to impair its ability to meet its financial obligations to its clients.
Privacy Policy This privacy policy explains the manner in which the Firm collects, utilizes and maintains nonpublic personal information about the Firm’s clients and Investors, as required under federal legislation. This privacy policy only applies to nonpublic information of clients and Investors who are individuals (not entities). The Firm collects personal information about its clients and Investors mainly through the following sources: §
Subscription forms, investor questionnaires and other information provided by the client or Investor in writing, in person, by telephone, electronically or by any other means. This information includes name, address, nationality, tax identification number, and financial and investment qualifications; and
§
Transactions within the Firm, investments and withdrawals.
including
account
balances,
The Firm does not sell or rent client or Investor information. The Firm does not disclose nonpublic personal information about its clients or Investors to nonaffiliated third parties or to affiliated entities, except as permitted by law. For example, the Firm may share nonpublic personal information in the following situations: §
To service providers in connection with the administration and servicing of the Firm, which may include attorneys, accountants, administrators, auditors and other professionals. The Firm may also share information in connection with the servicing or processing of Firm transactions;
§
To affiliated companies in order to provide clients and Investors with ongoing personal advice and assistance with respect to the products and services purchased through the Firm and to introduce them to other products and services that may be of value to them;
§
To respond to a subpoena or court order, judicial process or regulatory authorities;
§
To protect against fraud, unauthorized transactions (such as money laundering), claims or other liabilities; and
§
Upon consent of a client or an Investor to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on behalf of the client or Investor.
The Firm’s policy is to require that all employees, financial professionals and companies providing services on its behalf keep client information confidential.
The Firm maintains safeguards that comply with federal standards to protect client or Investor information. The Firm restricts access to the personal and account information of its clients and Investors to those employees who need to know that information in the course of their job responsibilities. Third parties with whom the Firm shares client or Investor information must agree to follow appropriate standards of security and confidentiality. The Firm’s privacy policy applies to both current and former clients and Investors. The Firm may disclose nonpublic personal information about a former client or Investor to the same extent as for a current client or Investor.
Timeline
- Feb 3, 2003Founded IBEX INVESTORS LLC is founded2
Filings
26 filings to the SEC since October 2021: 26 other. The latest 20:
- Aug 21, 2026N-PX EDGAR
- Aug 11, 202613F-HR EDGAR
- May 12, 202613F-HR EDGAR
- Feb 11, 202613F-HR EDGAR
- Nov 6, 202513F-HR EDGAR
- Aug 20, 2025N-PX EDGAR
- Aug 8, 202513F-HR EDGAR
- May 7, 202513F-HR EDGAR
- Feb 13, 202513F-HR EDGAR
- Nov 12, 202413F-HR EDGAR
- Aug 29, 2024N-PX EDGAR
- Aug 12, 202413F-HR EDGAR
- May 14, 202413F-HR EDGAR
- Feb 14, 202413F-HR EDGAR
- Nov 8, 202313F-HR EDGAR
- Aug 11, 202313F-HR EDGAR
- Aug 11, 202313F-HR/A EDGAR
- Aug 11, 202313F-HR/A EDGAR
- Aug 11, 202313F-HR/A EDGAR
- May 8, 202313F-HR EDGAR
The 26 filings since October 2021 can be filtered by form type and year here when JavaScript is on.
Every filing from the last five years, summarized. The full record is on SEC EDGAR.
Stakes it holds
IBEX INVESTORS LLC has told the SEC it owns more than 5% of 10 companies, latest first (Schedules 13D and 13G).
- Gauzy Ltd.SCHEDULE 13G/A Nov 13, 2024 to May 13, 20265
- BARFRESH FOOD GROUP INC.SCHEDULE 13G Aug 1, 2023 to Apr 9, 20266
- IturanSC 13G/A Oct 15, 2021 to Nov 13, 20247
- Core ScientificSC 13G Feb 1, 20248
- RiskifiedSC 13G/A Jun 24, 2022 to Jan 25, 20239
- Galmed Pharmaceuticals Ltd.SC 13G/A Jan 27, 202210
- Legacy Education Alliance, Inc.SC 13G/A Jan 27, 202211
- RedHill Biopharma Ltd.SC 13G/A Jan 27, 202212
- SilicomSC 13G/A Jan 27, 202213
- Tufin Software Technologies Ltd.SC 13G/A Jan 27, 202214
Sources
The numbers on this page point here. Each one links to the record it came from.
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