Private company

Ionic Capital Management LLC

Limited liability company registered in the United States, active since 2006. Summary from the record

Last updated Oct 21, 2026.

Overview

  • HeadquartersNew York, United States2
  • Legal formLimited Liability Company2
  • LEI4UJF10TOKE4E4R4DA7782
  • StatusActive2
  • LEI statusIssued and current2
  • Registered addressC/O THE CORPORATION TRUST COMPANY, 19801 Wilmington, United States2
  • Registered withDivision of Corporations, Department of State, 41634852

Corporate structure

Ionic Capital Management LLC sits at the top of its group. 12 entities, 1 country on record. Switch between the flow chart and the network, and select any entity to see its details.

Major holders of Ionic Capital Management LLC

  • Bart Ethan Baum Owns 25% to 50% of Ionic Capital, since 02/2011 (Form ADV)
  • Daniel Lazard Stone Owns 25% to 50% of Ionic Capital, since 02/2011 (Form ADV)
  • Ionic Holdco Gp LLC Owns control (general partner, trustee or manager) of Ionic Capital, since 02/2011 (Form ADV)
  • Ionic Capital Management LLC New York, New York, United States
    • AST SpaceMobile Stake · Midland, Texas, United States
    • BurgerFi International, Inc. Stake · Fort Lauderdale, Florida
    • Jet.AI Inc. Stake · Las Vegas, Nevada
    • Lightning eMotors, Inc. Stake · Loveland, Colorado, United States
    • OppFi Inc. Stake · Chicago
    • IONIC CAPITAL MASTER FUND LTD. Fund · New York, New York, United States
    • Ionic Convex Strategies Master Fund II Ltd. Fund · New York, New York, United States
    • Ionic Convex Strategies Master Fund III Ltd. Fund · New York, New York, United States
    • Ionic Convex Strategies Master Fund Ltd. Fund · New York, New York, United States
    • Ionic Relative Value Volatility Master Fund Ltd. Fund · New York, New York, United States
    • IONIC VALUE MASTER FUND LTD. Fund · New York, New York, United States

Built from parent and subsidiary links from GLEIF, the Global Legal Entity Identifier Foundation (CC0); stakes of 5% or more it reported on Schedules 13D and 13G (5 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

Ionic Capital Management 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$3.9B3 21 accounts, all with discretion
  • Employees34 15 in investment advice or research
  • ClientsPooled investment vehicles (other than investment companies and: 20 ($3.9B); Investment companies: 1 ($10.4M)
  • How it is paidA percentage of assets under its management; Performance-based fees
  • What it doesPortfolio management for investment companies; Portfolio management for pooled investment vehicles (other than investment companies)
  • Holds client assetsYes: cash and securities
  • RegistrationSEC 801-72188, CRD 156400 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).

  • IONIC CAPITAL MANAGEMENTowns 75% or more, since 02/2011
  • IONIC HOLDCO GP LLCowns general partner, trustee or manager of IONIC CAPITAL, since 02/2011
  • Bart Ethan Baumowns 25% to 50% of IONIC CAPITAL, since 02/2011
  • Bart Ethan Baumowns 25% to 50% of IONIC HOLDCO GP, since 03/2012
  • Daniel Lazard Stoneowns 25% to 50% of IONIC CAPITAL, since 02/2011
  • Daniel Lazard Stoneowns 25% to 50% of IONIC HOLDCO GP, since 03/2012

In its own words: the client brochure

Form ADV Part 2A, the plain-English document an adviser must give its clients, quoted as filed 3/31/2026.4 It covers the firm’s services, fees, investment strategies and their risks, and its conflicts of interest.

Item 4: Advisory business Services

Ionic Capital Management LLC (“Ionic”) is a Delaware limited liability company founded in 2006 that provides advice on a discretionary basis to private investment funds (both commingled funds and fundsof-one) offered exclusively to sophisticated investors (collectively referred to herein as the “Ionic Funds”) as well as sub-advisory services to undertakings for collective investments in transferable securities (the “UCITs Funds”) and a registered investment company (the “Inflation Protection ETF”, referred to collectively with the UCITS Funds as the “Liquid Alternatives Funds,” and together with the Ionic Funds, the “Clients,” and each as a “Client”). Bart Baum and Daniel Stone (collectively, the “Principals”) are the principal beneficial owners of Ionic and collectively control its operations and activities. Ionic is an alternative asset manager that employs long volatility, relative value arbitrage, and value equity strategies on behalf of its Clients. Ionic provides investment advisory services tailored to the investment objectives and strategies of each Client as described in each Client’s offering or governing documentation (collectively referred herein as the “Fund Documentation”). Ionic is the investment adviser to the Ionic Funds and has been delegated primary responsibility for the day-to-day operations of the Ionic Funds.

The Liquid Alternatives Funds have engaged Ionic to serve as a sub-adviser, and Ionic is responsible only for providing discretionary investment advice for all or a portion of the assets of such funds. All information relating to Ionic’s Clients in this brochure, including but not limited to the investment strategies employed, fees and expenses, risk factors, and conflicts of interest, are qualified in their entirety by reference to such Fund Documentation. As of December 31, 2025, the total regulatory assets under management of Ionic’s Clients was approximately $7,774,609,513* 1. Ionic manages assets solely on a discretionary basis.

Item 5: Fees and compensation Fees

We do not currently have a fee schedule as the fees and expenses of our Clients vary and are specified in the Fund Documentation applicable to each Client. Each Client pays Ionic a management fee generally ranging from an annual rate of 1.00% to 1.5% of the Client’s assets. Management fees generally are paid in arrears as of the end of each month and are deducted directly from the accounts of the Ionic Funds (the Liquid Alternatives Funds are invoiced for management fees). In addition to Management Fees, the Ionic Funds are subject to performance allocations, which generally are determined as a percentage of a fund’s appreciation, subject to a “high water mark” provision. The specific terms relating to the structure and calculation of performance allocations and any related high water mark provisions, which vary among the Ionic Funds, are described in the Fund Documentation applicable to each Ionic Fund. Investors in certain of the Ionic Funds are subject to early withdrawal or redemption charges under certain circumstances, as described further in the Fund Documentation relating to such funds. In addition, to the extent applicable pursuant to the Fund Documentation, the Ionic Funds pay all operating and administrative costs and expenses they incur which include, without limitation: (i) brokerage commissions and other costs of executing transactions; (ii) investment expenses and all other expenses (including all commissions, clearing fees, interest and financing charges) related to the purchase, sale, transmittal or custody of investments and related items; (iii) legal, accounting, auditing and other professional fees and expenses, as well as the costs of negotiating trade-related and account-specific counter-party documentation; (iv) any taxes and similar amounts (including withholding and other taxes) and duties payable in any jurisdiction in connection with the Clients’ operations; (v) fees and expenses in connection with the custody of Client assets; (vi) administrative expenses (including the fees and out-ofpocket expenses of the administrator), paying agency, transfer agency, shareholder registrar services costs, costs and fees associated with the roles of tax matters partner and partnership representative, if applicable; (vii) certain software licensing fees (including, but not limited to, software licensing fees related to risk management, accounting, and risk analytics data included in Form PF), external programming or software development, purchasing and operating costs, and costs of cyber insurance; (viii) any other operating or administrative costs or expenses related to accounting, research, due diligence and reporting; (ix) costs and expenses relating to regulatory compliance, including the costs of regulatory filings (including, without limitation, filings the preparation and submission of which currently or in the future may be required of the Ionic Funds or Ionic under applicable law) and inquiries; (x) costs associated with fulfilling

Assets under management referenced herein are inclusive of notionally funded mandates.

bonding requirements under ERISA; (xi) directors’ fees and expenses; (xii) portions of premiums paid for errors and omissions insurance and any indemnification payments; and (xiii) organizational expenses. For certain Ionic Funds, we may agree to pay a portion of such operating and administrative costs to the extent such costs exceed a specific amount.

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

The investment strategies, methods of analysis, and material risks applicable to the investment strategies we employ are set forth in detail in the Fund Documentation applicable to each Client. A summary of the more significant investment strategies, and material risks associated with them is provided below. Ionic employs long volatility, relative value arbitrage, credit and value investment strategies globally across asset classes. Not all of the investment strategies and associated risks are relevant to all Clients. Certain of our Clients have very specific investment objectives and therefore we may only incorporate one of the investment strategies below whereas other Clients may utilize some combination of them. The specific investment strategies we employ on behalf of each Client are described in each such Client’s respective Fund Documentation. Long Volatility Investment Strategies: Ionic’s long volatility strategies focus on generating negatively correlated returns and outperformance during uncertain markets. Ionic utilizes both explicit and imbedded options across asset classes, including equities, interest rates, currencies, commodities and credit in order to construct a portfolio that is typically positive convexity and long volatility. Relative Value Arbitrage Investment Strategies: These strategies focus on generating capital appreciation with low volatility and reduced correlations to equities and credit. Ionic’s relative value arbitrage strategies are implemented in a market neutral manner across convertible arbitrage, credit/rates relative value arbitrage, equity arbitrage and volatility arbitrage. Value Equity Investment Strategy: Ionic’s value investment strategy incorporates rigorous fundamental analysis in an attempt to identify compelling long (and short) investment opportunities in securities of

companies that are trading at a substantial discount (or premium) to intrinsic value. The Ionic Funds pursuing this strategy expect to employ a relatively concentrated portfolio construction approach, with a flexible mandate to maintain the ability to adapt to rapidly evolving market conditions. Ionic’s value strategy emphasizes liquid investments in equity securities of companies that operate in attractive, growing industries and maintain solid balance sheets and free cash flow generation capability. Inflation Protection: Ionic’s inflation protection strategy seeks to profit from direct exposure to inflation and inflation expectations as well as increasing interest rates by utilizing inflation swaps, interest rate swaptions, and U.S. Treasuries or U.S. Treasury Inflation-Protected Securities. Hybrid and Other Strategies Ionic may implement hybrid strategies incorporating elements of directional, relative value, volatility, event-driven, credit and other approaches, as well as a variety of opportunistic investment tactics. As market conditions and profit opportunities change, so will Ionic’s market approaches and implementations. Evolving Strategies and Allocations Ionic has complete flexibility in selecting the assets traded and the investment strategies implemented for our Clients. In doing so Ionic emphasizes the investment strategies for which it believes it provides a competitive advantage. The investment strategies discussed herein may – in fact, can be expected to, evolve over time due to a number of factors, such as market developments and trends, the emergence of new investment products, changing industry practices and technological innovations. While the investments made on behalf of our Clients will be consistent with their respective investment objectives, Ionic may develop and implement new trading and investment strategies on an ongoing basis, as we seek to exploit profit and investment opportunities. General Risks The investment strategies employed by Ionic on behalf of its Clients involve substantial risk, including the risk that the entire amount invested will be lost. The following is a summary of the material risks associated with Ionic’s investment strategies. For ease of reference, the term “Ionic Funds” as used below and in Item 10 (Other Financial Industry Activities and Affiliations), should be deemed to include the portion of the assets of the Liquid Alternatives Funds sub-advised by Ionic. Not all of the risks discussed below will apply to each of the Ionic Funds and to the extent a risk applies to more than one Ionic Fund, such risk may not apply equally to such Ionic Funds. With respect to the Liquid Alternatives Funds, the risks discussed below may be applicable only to the portion of the assets of such funds sub-advised by Ionic. The risks discussed below are only a portion of the risks associated with an investment in an Ionic Fund, and is not a complete description of the risks associated with an investment in any Ionic Fund or Liquid Alternatives Fund as a whole. An investment in the Ionic Funds involves a high degree of risk. Ionic cannot assure any investor that an Ionic Fund’s investment objective will be achieved or that such investor will not lose all or substantially all of such investor’s investment. The past performance of an Ionic Fund is not necessarily indicative of its future results — particularly given the speculative nature of its strategies and the markets in which the Ionic Funds invest. Eligible investors should carefully evaluate the risks involved with an investment in an Ionic Fund before deciding whether to invest in one or more of the Ionic Funds.

FOR A COMPLETE DISCUSSION OF THE RISKS ASSOCIATED WITH IONIC’S INVESTMENT STRATEGIES, AS WELL AS THE RISKS ASSOCIATED WITH AN INVESTMENT IN AN IONIC FUND, ELIGBLE INVESTORS SHOULD REFER TO THE APPLICABLE FUND DOCUMENTATION. Possible Positive Correlation with Stocks and Bonds While Ionic intends for its investment strategies to have non-correlated returns, there can be no assurance that the Ionic Funds will, in fact, experience a low level of correlation with a traditional portfolio of stocks and bonds or with the debt or equity markets generally. Use of Leverage and Availability of Credit Certain Ionic Funds may invest on a highly leveraged basis, both through their borrowings and through the significant degree of leverage typically embedded in the derivative instruments in their portfolios. The use of leverage is integral to many of the investment strategies implemented by the Ionic Funds, and such Ionic Funds depend on the availability of credit in order to finance their portfolios. There can be no assurance that the Ionic Funds will be able to maintain adequate financing arrangements under all market circumstances. As a general matter, the banks and dealers that provide financing to the Ionic Funds can apply essentially discretionary margin, haircut, financing, security and collateral valuation policies. Changes by banks and dealers in such policies, or the imposition of other credit limitations or restrictions, whether due to market circumstances or governmental, regulatory or judicial action, may result in margin calls, loss of financing, forced liquidation of positions at disadvantageous prices, termination of swap and repurchase agreements and cross-defaults to agreements with other dealers. Any such adverse effects may be exacerbated in the event that such limitations or restrictions are imposed suddenly and/or by multiple market participants at or about the same time. The imposition of such limitations or restrictions could compel the Ionic Funds to liquidate all or a portion of their portfolios at disadvantageous prices. There can be no assurance that the Ionic Funds will be able to obtain adequate financing to pursue their investment programs and achieve their objectives. Ionic measures total leverage as a fraction with the numerator being the total long market value of all positions in the relevant Ionic Fund as calculated by Ionic in accordance with its internal models and assumptions and the denominator being the net asset value. This method of calculating leverage captures borrowings by the relevant Ionic Fund but does not capture the embedded leverage in the derivative instruments in the portfolio. Utilizing other measurements of risk or exposure, such as gross notional exposure or value at risk, could yield materially different results. In markets with fewer opportunities, Ionic anticipates decreasing leverage and in very cheap and/or dislocated markets it might increase leverage. Different strategies will have different degrees of leverage. Losses incurred on the Ionic Funds’ leveraged investments increase in direct proportion to the degree of leverage employed. Leverage includes not only increased risk but may also include substantial interest expense. Even if leveraged positions are profitable, if such positions do not generate gains in excess of the interest expense incurred, the Ionic Funds will incur losses on such positions.

Credit Analysis and Credit Risk The investment strategies to be utilized by Ionic may require accurate and detailed analysis of the capital structure of issuers, including credit analysis. There can be no assurance that Ionic’s credit analysis will be accurate or complete. The Ionic Funds may be subject to substantial losses in the event of credit deterioration, default, or bankruptcy of one or more issuers in their portfolios. While the Ionic Funds generally intend to hedge credit risk, there can be no assurance that the Ionic Funds will have the ability to establish such hedges in the marketplace or, if established, that the hedges will offset losses. Reliance on Corporate Management and Financial Reporting Many of the strategies implemented by the Ionic Funds rely on financial information made available to the public under applicable law. Ionic has no duty or ability to independently verify such information and is dependent upon the integrity of both the management of these issuers and the financial reporting process in general. Recent history has demonstrated that investors, such as the Ionic Funds, can incur material losses as a result of corporate mismanagement, fraud and accounting irregularities. Counterparty Risk Depending on the particular strategy or strategies employed, an Ionic Fund may invest in complex derivative instruments such as options, futures, forwards, and swaps. While some derivatives are traded on exchanges (e.g., options and futures), a number of complex derivative instruments still trade “over-thecounter.” Such derivative instruments generally have counterparty risk that can result in a loss of all or part of an investment. Participants in “over-the-counter” markets are typically not subject to independent credit evaluation and regulatory oversight to the same extent as are members of “exchange-based” markets. While the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) requires centralized clearing of certain derivatives, not all derivatives are subject to clearing requirements. Trading over-the-counter exposes the Ionic Funds to the risk that a counterparty will not settle a transaction or will fail to make payments or return collateral in accordance with the terms of the instrument. Past turbulence in the financial markets highlights the importance of being aware of counterparty risk resulting from OTC derivative transactions. Delays in settlement or the financial failure of a counterparty to an OTC derivative could result in substantial losses due to adverse market movements, incurring additional costs, inability to recover pledged collateral, or other reasons. Such “counterparty risk” is present in all “over-the-counter” derivative transactions, and is accentuated for contracts with longer maturities or where the Ionic Funds have concentrated their transactions with a single or small group of counterparties. Recent collapses of large derivative dealers illustrate the risks of such trading. Broker and Custodian Insolvency There are significant risks involved in dealing with the custodians or brokers who settle the Ionic Funds’ trades. Even after Dodd-Frank, if a custodian or broker were to become insolvent, the Ionic Funds may be able to recover only a portion of their assets. In broker insolvencies, customers typically have been unable to timely access assets in their accounts and/or recover the full amount of their “customer property” and/or funds. Should a broker, custodian or counterparty of the Ionic Funds become insolvent, the Ionic Funds to suffer losses and/or materially diminish the actual or potential profitability of certain positions or strategies. The Ionic Funds may trade with or hold accounts at foreign brokers registered under the laws and regulations of other countries. Such brokers and/or dealers may not be subject to the same or similar customer fund regulations (including customer segregation requirements) as those existing in the United

Read the rest in the brochure

Item 7: Types of clients

Ionic currently serves as: (i) investment advisor to private investment funds (both commingled funds and funds-of-one) offered exclusively to sophisticated investors; and (ii) investment sub-advisor to European UCITs funds and a registered investment company.

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

Ionic Funds are subject to the performance allocations described in Item 5. The potential receipt of performance-based profit allocations from the Ionic Funds may create conflicts of interests between us, on the one hand, and our Clients, on the other hand. Specifically, the potential receipt of performancebased allocations may create an incentive for us to make riskier or more speculative investments than we otherwise would in the absence of such performance-based profit allocations and/or to allocate more profitable investment opportunities disproportionately among our Clients in order to maximize the amount of performance-based allocations we receive. Such conflicts, however, generally are mitigated by our allocation policy and Code of Ethics (as defined below), each of which require us to treat all Clients in a fair and equitable manner over time. A detailed discussion of Ionic’s allocation policy is set forth in Item 10 (Other Financial Industry Activities and Affiliations).

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

Ionic Capital Management LLC is registered as a “commodity pool operator” and “commodity trading advisor” with the CFTC and is a member of the NFA. Potential Conflicts of Interest The Ionic Funds are subject to a number of actual and potential conflicts of interest, as described below: Management Time; Other Clients; Allocation of Investment Opportunities Ionic and its affiliates, owners, officers, directors, managers and employees (“Ionic Parties”) are required to devote only such business time and attention to the conduct of the business and affairs of the Ionic Funds as Ionic may deem necessary or advisable. Ionic Parties are free to devote such time and attention as they may determine to other Ionic Funds or to other activities unrelated to the affairs of a single Ionic Fund. Neither an Ionic Fund nor its investors (in its capacity as such) has any rights in or to such other activities or the income or profits derived therefrom.

Each Ionic Fund may have different terms of investment such as different fee and liquidity terms. Ionic utilizes many of the same investment strategies for each of the Ionic Funds. There are no restrictions on our ability to provide investment advisory or other services to additional clients in the future, whether or not the accounts will have the same or different investment objectives, or employ the same or different investment strategies as those used by the Ionic Funds. Further, Ionic may make investment decisions on behalf of a given Client that is identical, dissimilar or contrary to the investment decisions that Ionic makes on behalf of another Client. Ionic may determine that an investment opportunity is appropriate for a particular Ionic Fund, but not for one or more other Ionic Funds. Situations may arise in which certain Ionic Funds have made investments that would have been suitable for investment by other Ionic Funds but, for various reasons, were not pursued by, or available to, such other Ionic Funds. The ability of one or more of the Ionic Funds to invest in the same investment or to invest in the same amounts or on the same terms may be adversely affected by any limitation on the availability of the investment. In addition, Ionic may be required to choose among one or more of the Ionic Funds in allocating investments, and considers a variety of factors when choosing to allocate investments among the Ionic Funds. Notwithstanding the foregoing, Ionic allocates investment opportunities among Ionic Funds in a manner which it believes is fair and equitable to all Ionic Funds over time, taking into account necessary considerations. In the event that a determination is made that more than one Ionic Fund should participate in a trade or trades made on the same day, the securities traded will be allocated among the Ionic Funds in a manner which Ionic believes to be fair and equitable to the Ionic Funds receiving a portion of such trade(s), taking into account the circumstances of each such Ionic Fund, such as, for example, their investment strategies, current investment positions, relative capitalizations and available cash, investment time horizons, leverage ratios, etc. As a result, allocations of trades in which multiple Ionic Funds participate may not be made on a pro rata basis due to the consideration of such factors. For example, Ionic, in its good faith discretion, may determine that a particular Ionic Fund should receive less than a pro rata allocation of one or more trades for a variety of reasons, including, but not limited to, because the investment strategy of such Ionic Fund is narrower than the investment strategies of other Ionic Funds being allocated a portion of the trade, because such Ionic Fund already has reached targeted exposures or guidelines, or because such Ionic Fund has less available capital. Circumstances may occur, however, in which allocations made in a way Ionic believes to be fair and equitable still have adverse effects on one or more Ionic Funds with respect to the price or size of securities positions obtainable or saleable. The investment advisory agreements with the Ionic Funds authorize Ionic to combine purchase and sale orders on behalf of the Ionic Funds and to allocate securities or other assets so purchased or sold on an average price basis among such Ionic Funds. Therefore, when Ionic has determined that more than one Ionic Fund should participate in a specific trade, Ionic generally combines (i.e., aggregates) the quantity of securities to be traded and places an order that, once executed, will be allocated among multiple Ionic Funds on an average price basis. From the standpoint of the Ionic Funds, aggregated trades may, in certain market conditions, decrease the prices received, and increase the prices required to be paid, by the Ionic Funds for their portfolio sales and purchases. Further, even in circumstances where it is consistent with the investment objectives of multiple Ionic Funds to participate in an aggregated trade, it may not always be possible for each Ionic Fund to do so at the same time or at the same price; however, even when such circumstances exist, all transactions will be made on a “best execution” basis. Personal Trading

Personnel associated with Ionic may trade for their personal and perhaps other accounts at the same time that they will be trading for the Ionic Funds. While Ionic has adopted a code of ethics in an attempt to prevent any such trading harming the Ionic Funds, Ionic’s personnel will have a conflict of interest in devoting time to trading such other accounts (including personal accounts) and trading for the Ionic Funds. Please see Items 4 (Advisory Business), 8 (Methods of Analysis, Investment Strategies and Risk of Loss), 11 (Code of Ethics, Participation or Interest in Client Transactions and Personal Trading) and 12 (Brokerage Practices).

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

Ionic has adopted a code of ethics adopted pursuant to SEC rule 204A-1. Our code of ethics requires compliance with all applicable laws and regulations governing the provision of investment management services to our Clients. In addition, our code of ethics highlights the fiduciary duty that we owe to our Clients, including the affirmative duty to act in the best interests of our Clients and to make full and fair disclosure of all material facts. We also expect Ionic personnel to adhere to the highest standards with respect to any potential conflict of interest with Clients. Our code of ethics has specific provisions relating to identifying potential conflicts of interest. The provisions prohibit Ionic personnel from directing Client transactions in order to obtain a personal benefit as well as from conducting business dealings with Clients, investors or service providers without the prior approval of our Chief Compliance Officer or his designee. Our code of ethics also includes provisions relating to accepting offers of gifts or entertainment from third parties. Ionic personnel are required to conduct all personal securities transactions in full compliance with our code of ethics, and should not take any action in connection with personal securities transactions that could cause even the appearance of unfairness or impropriety, relative to our Clients. Ionic personnel are required to promptly bring ambiguous situations to the attention of our Chief Compliance Officer or his designee, and such situations will be resolved in favor of Client interests. Additionally, our code of ethics requires Ionic personnel, among other things, to: (i) have all personal securities transactions involving reportable securities pre-approved by our Chief Compliance Officer or his designee and are subject to a holding period; (ii) report all their personal securities transactions involving reportable securities to our Chief Compliance Officer or his designee periodically in accordance with Rule 204A-1; and (iii) certify their compliance with our code of ethics on at least an annual basis. Finally, our code of ethics requires Ionic personnel to promptly report all violations of the code of ethics to our Chief Compliance Officer or his designee, who is primarily responsible for administering and enforcing our code of ethics. We will provide any Client or prospective client with a copy of our code of ethics upon request by contacting our Chief Compliance Officer at the following address: c/o Ionic Capital Management LLC 475 Fifth Avenue, 9th Floor New York, New York 10017 Attention: Chief Compliance Officer Telephone: 212-294-8500 FormADV@ioniccap.com

Ionic does not recommend to Clients, or buy or sell for Client accounts, securities in which Ionic or our related persons have a material financial interest. Although the Principals and other Ionic personnel may buy and sell securities for their own accounts or the account of others, they may not buy securities from or sell securities to Clients. Please see Items 10 (Other Financial Industry Activities and Affiliations) and 12 (Brokerage Practices).

Item 12: Brokerage practices Conflicts of interest

Ionic determines the broker or dealer to be used for each securities transaction for our Clients. In selecting a broker for each specific transaction, we will use our best judgment to choose the broker most capable of providing “best execution” on an over-all basis taking into account the circumstances of each specific transaction. Brokers are selected on the basis of our evaluation of the overall value and quality of the services provided by the broker. No one factor controls our decision. Among other things, we consider the price of the security, commission rate, execution speed, confidentiality, market depth, capital commitment, recent order flow, knowledge of the other side of the trade and the quality of the broker’s service (including, but not limited to, accuracy, reputation, timeliness, research, responsiveness and any soft dollar arrangements, if applicable). In selecting brokers or dealers to execute transactions for Clients, we are not required to solicit competitive bids and have no obligation to seek the lowest available commission cost. We do not always negotiate “execution only” commission rates; accordingly, Clients may be deemed to be paying for other services provided by the broker to Ionic’s Clients, Ionic or their respective affiliates that are included in the commission rate. Our application and importance of the specific criteria will vary depending upon the nature of the transaction, the asset class, the market in which it is effected, and the extent to which it is possible to select from among multiple brokers or dealers capable of effecting the transaction. While we reserve the right to utilize soft dollars in the future, Ionic does not utilize soft dollars in respect of its Client accounts. Instead, research related expenses covered by the Section 28(e) “safe harbor” (described below) are directly expensed to the applicable Client in a fair and equitable manner where permitted pursuant to the Fund Documentation. Section 28(e) of the Securities Exchange Act of 1934, provides a “safe harbor” to investment managers who use soft dollars generated by their advised accounts to obtain investment research and brokerage services that provide lawful and appropriate assistance to us in the performance of investment decision-making responsibilities. The agreements we have with the Ionic Funds permit Ionic to use “soft-dollars” to pay for 28(e)-eligible expenses. We consider investor referrals in selecting or recommending the prime brokers for the Ionic Funds and have an incentive to select or recommend prime brokers based upon investor referrals, rather than just the most favorable execution. As part of the selection process for the prime brokers to be utilized for the Ionic Funds, the quality of the capital introduction services is a factor in making such decision. However, Ionic does not direct trades to the prime brokers in return for investor referrals. As explained in Item 10, above, Ionic will generally aggregate trades, unless it believes that doing so would conflict or otherwise be inconsistent with its duty to seek best execution for its Clients, and/or the terms of the respective investment advisory contracts and other agreements and understandings relating to the accounts for which trades are being aggregated. We have established a brokerage committee to, among other things, review and make determinations on a periodic basis relating to the broker-dealers with whom we execute transactions and the soft dollar benefits we receive.

Item 14: Client referrals and other compensation Conflicts of interest

Please see Items 10 (Other Financial Industry Activities and Affiliations) and 12 (Brokerage Practices).

Item 9: Disciplinary information

This item is not applicable.

Item 13: Review of accounts

We review the accounts of the Ionic Funds on a monthly basis. During the month-end reconciliation process with the administrator, our Chief Financial Officer and Controller are primarily responsible for reviewing the accounts of the Ionic Funds. As part of that process, they reconcile the internal general ledger, portfolio, and profits and losses to the administrators’ independent net asset value calculations prior to the administrator’s release of the net asset value statements to investors in the Ionic Funds. In addition, our pricing committee formally meets to approve the month-end estimates and final net asset value for each of the Ionic Funds. Ionic will furnish to each investor in the Ionic Funds a report of the applicable Ionic Fund’s estimated performance as soon as practicable after the end of each week and after the end of each month, as well as its month-end risk report and such other information as Ionic may deem appropriate. In addition, the administrator will send to each investor a monthly statement reflecting the net asset value, including any increase or decrease, of such investor’s investment during the preceding month. As soon as practicable after the end of each fiscal year, the Ionic Funds furnish to each investor audited financial statements as of the end of such fiscal year.

Item 15: Custody

Not applicable.

Item 16: Investment discretion

Pursuant to the investment advisory agreements and other similar agreements with our Clients, as applicable, Ionic has discretionary authority to manage the assets of such Clients. These agreements generally include a power of attorney given to us and our affiliates. While the Liquid Alternative Funds generally have certain investment restrictions applicable to their respective strategies, there are no limitations on Ionic’s investment authority for the Ionic Funds. Please see Item 4 (Advisory Business).

Item 17: Voting client securities

We have been delegated the authority and right to vote proxies received by Clients. Ionic’s proxy voting policy requires us to vote proxies in the manner we determine to be in the best interests of our Clients. We monitor corporate events and vote proxies on behalf of those Clients that have authorized us to do so. When considering how to vote a proxy on behalf of a Client, we analyze the issues involved with the proposals to be voted upon, including their probable impact on corporate operations, the company’s stock and the financial markets, as well as the recommendation of company management. Our proxy voting policy does not mandate that we vote every proxy that we receive, and there may be circumstances when not voting a proxy is in a Client’s best interest, such as if the costs of voting the proxy exceeds the expected benefit to the Client (such costs include the value of our time).

If a proxy vote creates a material conflict between our interests and the interests of Clients, we will resolve the conflict before voting the proxies. We will either disclose the conflict to the applicable Clients or take other steps designed to ensure that any vote cast via proxy is in the Client’s best interests. Clients cannot generally direct how we vote in a particular situation. Clients may obtain, free of charge, a copy of our proxy voting policies and procedures and/or a record of proxy votes cast since the effective date of our registration with the SEC by contacting our Chief Compliance Officer at the following address: c/o Ionic Capital Management LLC 475 Fifth Avenue, 9th Floor New York, New York 10017 Attention: Chief Compliance Officer Telephone: 212-294-8500 FormADV@ioniccap.com

Item 18: Financial information

This Item is not applicable.

Timeline

  1. May 23, 2006Founded Ionic Capital Management LLC is founded2

Filings

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

  1. Aug 14, 202613F-HR EDGAR
  2. Jul 28, 2026N-PX EDGAR
  3. May 15, 202613F-HR EDGAR
  4. Feb 17, 202613F-HR EDGAR
  5. Nov 14, 202513F-HR EDGAR
  6. Aug 28, 2025N-PX EDGAR
  7. Aug 14, 202513F-HR EDGAR
  8. May 15, 202513F-HR EDGAR
  9. Feb 14, 202513F-HR EDGAR
  10. Nov 14, 202413F-HR EDGAR
  11. Aug 14, 2024N-PX EDGAR
  12. Aug 14, 202413F-HR EDGAR
  13. May 15, 202413F-HR EDGAR
  14. Feb 14, 202413F-HR EDGAR
  15. Nov 14, 202313F-HR EDGAR
  16. Aug 14, 202313F-HR EDGAR
  17. May 15, 202313F-HR EDGAR
  18. Feb 14, 202313F-HR EDGAR
  19. Nov 14, 202213F-HR EDGAR
  20. Aug 15, 202213F-HR EDGAR

The 23 filings since October 2021 can be filtered by form type and year here when JavaScript is on.

Every filing from the last five years, summarized. The full record is on SEC EDGAR.

Stakes it holds

Ionic Capital Management LLC has told the SEC it owns more than 5% of 5 companies, latest first (Schedules 13D and 13G).