Overview
- HeadquartersStamford, United States1
- Websitelykosglobal.com
- Legal formlimited partnership1
- Kind of organizationHedge fund1
- LEI254900K2JJLV3FRURM642
- StatusActive2
- LEI statusIssued and current2
- Registered addressC/O Cogency Global Inc., 19904 Dover, United States2
- Registered withDivision of Corporations, Department of State, 74771732
Corporate structure
Lykos Global Management sits at the top of its group. 2 entities, 1 country on record. Switch between the flow chart and the network, and select any entity to see its details.
Major holders of Lykos Global Management
- Nicholas Brett Laster Owns 75% or more of Lykos Global Management, since 05/2023 (Form ADV)
- Lykos Global Management Stamford, Connecticut, United States
- Lykos Global Portable Alpha Offshore Partners LP Fund · Stamford, Connecticut, United States
Built from parent and subsidiary links from GLEIF, the Global Legal Entity Identifier Foundation (CC0); 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
Lykos Global Management 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$1.4B4 9 accounts, all with discretion
- Employees11 6 in investment advice or research
- ClientsPooled investment vehicles (other than investment companies and: 9 ($1.4B)
- 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 801-129373, CRD 329441 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).
- Nicholas Brett Lasterowns 75% or more, since 05/2023
- Nicholas Brett Lasterowns 75% or more of LYKOS GLOBAL, since 05/2023
In its own words: the client brochure
Form ADV Part 2A, the plain-English document an adviser must give its clients, quoted as filed 6/12/2026.5 It covers the firm’s services, fees, investment strategies and their risks, and its conflicts of interest.
Item 4: Advisory business Services
Lykos was formed in 2023 under the laws of the State of Delaware as a limited partnership, has been a registered investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) since 2024, and its principal owner is Nicholas B. Laster (the “Principal”). The Firm has a principal place of business in Stamford, Connecticut. The principal owners and executive officers of Lykos are listed in the Firm’s Form ADV, Part 1A on Schedule A and Schedule B, respectively. We serve as the investment adviser, with discretionary trading authority, to private, pooled investment vehicles (each a “Fund” and collectively, the “Funds”), the securities of which are offered through a private placement memorandum to accredited investors, as defined under the Securities Act of 1933, as amended, and qualified purchasers, as defined under the Investment Company Act of 1940, as amended (the “Investment Company Act”). Lykos provides discretionary investment advisory services to the Funds and designs, structures and implements investment strategies for the Funds through master-feeder structures. We do not tailor our advisory services to the individual needs of any particular investor. Lykos manages the following private, pooled investment vehicles: Lykos Global Offshore Partners, LP, a Cayman Islands exempted limited partnership (the “Offshore Fund”); Lykos Global Onshore Partners, LP, a Delaware limited partnership (the “Onshore Fund”); Lykos Global Master Fund, LP, a Cayman Islands exempted limited partnership (the “Master Fund”); Lykos Global Portable Alpha Offshore Partners LP, a Cayman Islands exempted limited partnership (the “Portable Alpha Fund”); and Lykos Portable Alpha Offshore Feeder LP, a Cayman Islands exempted limited partnership (the “Portable Alpha Feeder Fund”). The Master Fund, Offshore Fund, and the Onshore Fund are hereinafter collectively referred to as the “Lykos Global Funds”. The Portable Alpha Fund and the Portable Alpha Feeder Fund are hereinafter collectively referred to as the “Portable Alpha Funds.” Lykos Global Partners GP, LLC serves as the “General Partner” to the Funds. Our investment decisions and advice with respect to the Funds are subject to each Fund’s investment objectives, guidelines, limitations and risks, as set forth in the respective “Offering Documents.” Lykos also provides investment management services to privately placed pooled investment vehicles (the “Sub-Advised Funds,” and collectively with the Funds, the “Clients”) that are managed according to investment advisory agreements (the “Advisory Agreements” and collectively with the Offering Documents, the “Governing Documents”). Lykos refers to each of the limited partners of the Funds with other prospective limited partners of the Funds, and Sub-Advised Funds collectively, as “Investors.” The Clients’ investment strategies are described in more detail in each Client’s Governing Documents, and are further described below under “Item 8. Methods of Analysis, Investment Strategies and Risk of Loss.” The general investment guidelines and restrictions applicable to any particular Client are negotiated at the time that the particular Client is formed, although there may be subsequent revisions with the consent of Investors. We do not currently participate in any Wrap Fee Programs. As of December 31, 2025, Lykos managed approximately $1,378,000,000 in Regulatory Assets Under Management (“RAUM”), on a discretionary basis. Lykos does not manage Client assets on a nondiscretionary basis.
Item 5: Fees and compensation Fees
Lykos receives compensation based on assets under management and performance. The fees applicable to each of the Funds are set forth in detail in the corresponding Governing Documents. All Investors should review the Governing Documents of the relevant Fund in conjunction with this brochure for complete information on the fees and compensation payable with respect to that particular Fund. A brief summary of such fees is provided below. Management Fee The Clients will pay to the Firm a fee for its services (the “Management Fee”) that is negotiated and agreed upon in that Client’s respective Governing Document. “Management Fee Rate” ranges from 1.0 - 1.5% per annum for founders class interests in the Funds. The Management Fee is calculated on a quarterly basis and paid in advance by multiplying the Management Fee Rate by the balance of each capital account of an Investor as of the beginning of such fiscal quarter (before taking into account the estimated accrued Incentive Allocation, if any). The Management Fee Rate for the Sub-Advised Funds, ranges from 1.0 – 1.5% per annum and is paid either monthly in arrears or quarterly in advance as detailed in each Sub-Advised Fund’s Governing Document. For the Funds, the Management Fee is not generally negotiated separately with each Investor; however, the Firm or its affiliates can negotiate, waive or agree to a reduction of amounts of the Management Fees with individual Investors at its discretion in consideration of the size of such Investor’s capital commitment or other factors. In the sole discretion of the Firm, the Management Fee has in the past and may in the future be waived, reduced or calculated differently for Lykos-related Investors. For a discussion of potential conflicts of interest, please see “Item 6. Performance-Based Fees and Side-bySide Management.”. Other Types of Fees or Expenses Lykos is authorized to incur and pay in the name and on behalf of the Clients all expenses which they deem necessary or advisable. The Firm is responsible for and shall pay, or cause to be paid, all of their own ordinary administrative and overhead expenses, including, without limitation, all costs and expenses related to rent, furniture, fixtures, equipment, office supplies, clerical expenses and all salaries, bonuses and benefits paid to, or on behalf of, personnel of the Firm. The Funds will bear its own expenses, the expenses of any intermediate entity through which it invests, and its pro rata share of the other vehicles expenses, including the following: (i) the Management Fee; (ii) expenses related to the research, due diligence, financing, monitoring and disposition of actual and prospective Fund investments, whether or not such investment is consummated, including the following: third-party investment sourcing fees (including performance-based fees); fees and expenses related to obtaining research and market data (including any information technology hardware, software or other technology incorporated into the cost of obtaining such research and market data, and including fees and expenses related to obtaining, processing and analyzing research or market data that may be considered “big data” or “alternative data”, including fees and expenses related to performing due diligence on potential providers of any of such research or market data services); due diligence expenses, including consulting and appraisal fees; brokerage, prime brokerage and futures commission merchant fees, commissions and expenses (including fees, commissions and expenses of any outsourced trading desk); expenses relating to block trades; expenses relating to short sales; clearing and settlement charges; custodial fees and expenses; bank service fees; interest expenses and fees related to financings or refinancings; fees and expenses of proxy research and voting and class action-related services; (iii) the Funds’ direct or indirect pro rata share of any compensation payable in connection with the
management of any Private Investment by an unaffiliated third party or management team, which may include both asset-based fees and performance-based fees (which, for the avoidance of doubt, will not reduce the Management Fee or Incentive Allocation payable or allocable to the Firm and the General Partner, respectively); (iv) operational expenses, including the following: fees and expenses relating to information technology hardware, software or other technology (including costs of software licensing, implementation, data management and recovery services and custom development) used to research investments, evaluate and manage risk, facilitate valuations, facilitate accounting functions and/or facilitate compliance with the rules of any self-regulatory organization or applicable law (including reporting obligations), facilitate and manage the order execution of investments or otherwise manage or monitor investments, such as Bloomberg terminals, portfolio management systems, risk management systems and order management systems; fees and expenses of third-party risk management products, models and services; fees and expenses of any outsourced trading firms; (v) fees and expenses of thirdparty professionals, including consultants, valuation service providers, attorneys, accountants and thirdparty administrative fees and expenses (including any “shadow” administrator) and including the costs of engaging or appointing a Money Laundering Reporting Officer, a Deputy Money Laundering Reporting Officer and an Anti-Money Laundering Compliance Officer; (vi) the costs of any litigation or investigation involving activities of the Funds; (vii) taxes and third-party audit and tax preparation expenses; (viii) insurance expenses, including premiums for cybersecurity insurance and liability insurance covering the General Partner, the Firm and the members, partners, officers, employees and agents of any of them, and each member of the Advisory Board; (ix) fees and expenses of the independent members of the Advisory Board; (x) costs of preparing and distributing reports and notices; (xi) expenses incurred in connection with negotiating and complying with provisions of any Side Letter Agreement, and expenses incurred in connection with any Transfers of Interests or an Investor’s admission or withdrawal, unless otherwise charged to or borne by the applicable transferee or Investor; (xii) fees and expenses related to compliance with the rules of any self-regulatory organization or applicable law in connection with the activities of the Funds, including any governmental, regulatory, licensing, filing or registration fees or taxes (including fees and expenses incurred in connection with the preparation and filing of Form PF, Form SHO, Section 13 filings, Section 16 filings and other similar regulatory filings); (xiii) expenses incurred in connection with the offering and sale of the Interests and other similar expenses related to the Funds; (xiv) expenses incurred in connection with any amendments, modifications, revisions or restatements to the constituent documents of the Funds; (xv) expenses incurred in connection with meetings with investors and prospective investors; (xvi) extraordinary expenses, including indemnification expenses and fees and expenses incurred in connection with any tax audit by any tax authority, including any related administrative settlement and judicial review; (xvii) fees and expenses incurred in connection with the organization, reorganization, termination, winding-up or dissolution of the Funds and (xviii) other similar expenses of the Funds. The Funds will also indirectly bear any similar expenses of any trading subsidiary or special purpose vehicle of a master fund. In general, each Investor bears its proportionate share of the Funds expenses on a pro rata basis with respect to the size of such Investor’s capital account(s) or with respect to the relative net asset value of the shares held by such Investor, as applicable. Notwithstanding the foregoing, General Partner and/or the Firm, as applicable, may specially allocate the expenses described herein in any other manner, including by allocating certain expenses to certain (but not all) Investors in the Fund, if the General Partner and/or the Firm, as applicable, reasonably determines, in its discretion, that it is more equitable to do so. To the extent that expenses to be borne by the Clients are paid by the Firm or its affiliates, the Funds and/or Sub-Advised Funds will reimburse the Firm or its affiliates for such expenses in accordance with their Governing Documents. We may waive any such reimbursement with respect to any Fund or Account expense. Any waiver by us for reimbursement of any Fund expenses shall not serve as a waiver of reimbursement for any future Fund expenses to be paid by us or our affiliates. Neither the Firm nor its employees accept compensation, including sales charges or service fees, from any person for the sale of securities or other investment products.
Item 8: Methods of analysis, investment strategies and risk of loss Investment strategies and risks
The descriptions set forth in this Brochure of specific advisory services that we offer to Clients, and investment strategies pursued and investments made by us on behalf of our Clients, should not be understood to limit in any way our investment activities. We may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that we consider appropriate, subject to each Client’s investment objectives and guidelines as set forth in the Governing Documents. The investment strategies we pursue are speculative and entail substantial risks. Clients should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any Client will be achieved. Investment Objective The investment objective of the Clients is to seek to generate superior, risk-adjusted absolute returns throughout the market cycle. The Firm will employ a flexible, global mandate focused on equity capital markets and adjacent opportunities within late stage privates and event-driven tactical opportunities. Lykos believes that late-stage privates and tactical opportunities are natural extensions of the Clients’ core equity capital markets strategy and that the integrated evaluation of available opportunities across public and private strategies enables (i) a broader perspective on optimal capital allocation, (ii) an expanded, less-cyclical opportunity set and (iii) reinforcing benefits across the platform. The Clients’ will employ a flexible and opportunistic mandate that may encompass a variety of subsectors, geographies and a broad range of investment instruments. The Clients’ portfolio will consist primarily of equity and equity-related instruments (which may include, without limitation, preference shares, convertible debt instruments, equity-related and equity-linked notes and warrants). The Clients will emphasize or deemphasize certain investment strategies depending on market conditions, the perceived opportunity sets and their relative risk-adjusted returns. The Portable Alpha Funds will maintain direct exposure to the SPDR S&P 500 ETF Trust (Ticker Symbol: SPY) (or such other similar ETF selected by the Investment Manager, the “SPY”) via one or more total return swaps (the “Swap”). The Firm intends to manage the Swap such that the Portable Alpha Funds maintain a 1:1 ratio between the net asset value of the assets of the Portable Alpha Fund that (i) invest in the Swap (the “Beta Portfolio”) and (ii) the SPY. Therefore, the Firm generally will increase or decrease the notional amount of the Swap when there are subscriptions to the Portable Alpha Funds, withdrawals from the Portable Alpha Funds, or a crystallization of the Incentive Allocation. However, there may be times where the Firm is unable to maintain this ratio. Risk Management The foundation of the Firm’s risk management framework across both liquid and illiquid strategies is a consistent, intensive and fundamental underwriting process. The Firm believes that this approach enables a differentiated assessment of intrinsic value, return potential and security-specific risk factors. By selecting securities for which prices reflect compelling discounts to internally-derived estimates of fair value and for which the risk factors are well-understood, the Firm seeks to establish positions at levels that afford a significant ‘margin of safety’. If the Firm determines that there has been a material change to any of the key assumptions underpinning the Clients’ investment thesis, the investment team will re-underwrite the position without any regard for prior conclusions or current positions. This analysis demands intellectual honesty, probabilistic
pragmatic thinking, and an open-minded willingness to consider counterfactuals. This process may lead the Firm to increase, decrease or exit a position entirely. Risk of Loss Factors The following risk factors do not purport to be a complete list or explanation of the risks involved in an investment in the clients advised by us. These risk factors include only those risks we believe to be material, significant or unusual and relate to particular significant investment strategies or methods of analysis employed by us. An investment involves significant risks, and is suitable only for those persons who can bear the economic risk of the loss of their entire investment, who have limited need for liquidity in their investment, and who have met the conditions set forth in the Governing Documents. There can be no assurances that we will achieve our investment objectives. An investment carries with it the inherent risks associated with investments in publicly-traded stocks and bonds, options, and related instruments, including, without limitation, the risks described below. Each prospective investor should carefully review the Governing Documents and the documents referred to herein before deciding to invest with any Client. Capital Structure Arbitrage: The success of the Clients’ capital structure arbitrage strategy depends upon the Firm’s ability to identify and exploit the relationships between movements in different securities within an issuer’s capital structure (including, bank debt, convertible and non-convertible senior and subordinated debt and preferred and common stock). Identification and exploitation of these opportunities involve uncertainty. There can be no assurance that the Firm will be able to locate investment opportunities or to correctly exploit price discrepancies. A reduction in the pricing inefficiency of the markets in which the Clients will seek to invest will reduce the scope for the Clients’ investment strategies. In the event that the perceived mispricings underlying the Clients’ positions fail to materialize, these investment strategies could be unsuccessful or result in losses. Convertible Arbitrage: The success of the Clients’ convertible arbitrage strategy depends upon the Firm’s ability to identify convertible securities that appear incorrectly valued relative to their theoretical value, purchase (or sell short) such a convertible security and sell short (or purchase) the underlying security for which the convertible security can be exchanged to exploit price differentials. There can be no assurance that the Firm will be able to identify convertible arbitrage opportunities or that changes in price differentials will not cause losses. Borrowing and lending against such investments involves substantial risks. The prices of these investments can be volatile, market movements are difficult to predict, and financing sources and related interest and exchange rates are subject to rapid change. Certain corporate securities may be subordinated (and thus exposed to the first level of default risk) or otherwise subject to substantial credit risks. Event-Driven: The success of the Clients’ event-driven investment strategy depends upon the Firm’s ability to make predictions about (i) the likelihood that an event will occur and (ii) the impact such event will have on the value of a company’s securities. If the event fails to occur or it does not have the effect foreseen, losses can result. For example, the adoption of new business strategies or completion of asset dispositions or debt reduction programs by a company may not be valued as highly by the market as the Firm had anticipated, resulting in losses. In addition, a company may announce a plan of restructuring which promises to enhance value, but fail to implement it, which can result in losses to investors. In liquidations and other forms of corporate reorganization, the risk exists that the reorganization either will be unsuccessful, will be delayed or will result in a distribution of cash or a
new security, the value of which will be less than the purchase price to the Clients of the security in respect of which such distribution was made. The consummation of mergers and tender and exchange offers can be prevented or delayed by a variety of factors, including: (i) opposition of the management or stockholders of the target company, which will often result in litigation to enjoin the proposed transaction; (ii) intervention of a U.S. federal or state regulatory agency; (iii) efforts by the target company to pursue a “defensive” strategy, including a merger with, or a friendly tender offer by, a company other than the offeror; (iv) in the case of a merger, failure to obtain the necessary stockholder approvals; (v) market conditions resulting in material changes in securities prices; (vi) compliance with any applicable U.S. federal or state securities laws; and (vii) inability to obtain adequate financing. Because of the inherently speculative nature of event-driven investing, the results of the Clients’ operations may be expected to fluctuate from period to period. Accordingly, Investors should understand that the results of a particular period will not necessarily be indicative of results that may be expected in future periods. Long/Short: The success of the Clients’ long/short investment strategy depends upon the Firm’s ability to identify and purchase Securities that are undervalued and identify and sell short Securities that are overvalued. The identification of investment opportunities in the implementation of the Clients’ long/short investment strategies is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. In the event that the perceived opportunities underlying the Clients’ positions were to fail to converge toward, or were to diverge further from values expected by the Firm, the Clients may incur a loss. In the event of market disruptions, significant losses can be incurred which may force the Clients to close out one or more positions. Furthermore, the valuation models used to determine whether a position presents an attractive opportunity consistent with the Firm’s long/short strategies may become outdated and inaccurate as market conditions change. Short Selling: The success of the Clients’ short selling investment strategy depends upon the Firm’s ability to identify and sell short Securities that are overvalued. A short sale creates the risk of a theoretically unlimited loss, in that the price of the underlying Security could theoretically increase without limit, thus increasing the cost to the Clients of buying those Securities to cover the short position. There can be no assurance that the Clients will be able to maintain the ability to borrow Securities sold short. In such cases, the Clients can be “bought in” (i.e., forced to repurchase Securities in the open market to return to the lender). There also can be no assurance that the Securities necessary to cover a short position will be available for purchase at or near prices quoted in the market. Purchasing Securities to close out a short position can itself cause the price of the Securities to rise further, thereby exacerbating the loss. Short strategies can also be implemented synthetically through various instruments and be used with respect to indices or in the over-the-counter market and with respect to futures and other instruments. In some cases of synthetic short sales, there is no floating supply of an underlying instrument with which to cover or close out a short position and the Clients may be entirely dependent on the willingness of over-the-counter market makers to quote prices at which the synthetic short position may be unwound. There can be no assurance that such market makers will be willing to make such quotes. Short strategies can also be implemented on a leveraged basis. Lastly, even though the Clients secures a “good borrow” of the Security sold short at the time of execution, the lending institution may recall the lent Security at any time, thereby forcing the Clients to purchase the Security at the then-prevailing market price, which may be higher than the price at which such Security was originally sold short by the Clients. Long-Term: The success of the Clients’ long-term investment strategy depends upon the Firm’s ability to identify and purchase Securities that are undervalued and hold such investments so as to maximize value on a long-term basis. In pursuing any long-term strategy, the Clients may forego value in the short-term or
Item 7: Types of clients
Our Clients consist of the Funds and the Sub-Advised Funds, as described in Item 4 above; however, Lykos may in the future serve as investment manager to other client accounts. At this time, it is not anticipated that we will provide advice to advisory clients that are “retail investors” as defined by Rule 204-5(d)(2) under the Advisers Act. The Funds, which are private pooled investment vehicles that are exempt from registration under the Investment Company Act are generally open to, among others, institutions, pension plans, endowments, high net-worth individuals, financially sophisticated individuals, and other sophisticated investors. Clients require Investors to meet certain suitability qualifications, such as being (A) “accredited investors” under SEC Regulation D of the Securities Act of 1933 or (B) “qualified purchasers,” as defined in Section 2(a)(51)(A) of the Investment Company Act of 1940. It is anticipated that any future advisory clients managed Lykos by will have similar eligibility standards as the Clients. Investors in the Funds should refer to the applicable Fund’s Governing Documents and subscription materials for information on minimum investment requirements and investor suitability criteria. Information on minimum investment requirements for the Funds is described, as appropriate, in the Form ADV, Part 1A. For each of the Funds, the minimum initial commitment is subject to the discretion
of the applicable Fund’s general partner. With respect to the Sub-Advised Funds, investment advice is provided directly to the Sub-Advised Funds and not individually to Investors in the Sub-Advised Funds.
Item 6: Performance-based fees and side-by-side management Conflicts of interest
Each Investor in the Funds that the Firm advises is subject to a performance-based compensation calculation to the General Partner or an affiliated entity in the form of Incentive Allocations based on the investment performance of the applicable Fund. Generally, at the end of each fiscal year, an amount equal to a specified percentage of net capital appreciation allocated to an Investor’s capital account, subject to applicable hurdle or benchmark provisions and adjustments for Management Fees and other expenses, is reallocated from the applicable Investor capital accounts to the capital account of the General Partner as an Incentive Allocation. Incentive Allocations may also be determined in connection with Investor withdrawals, distributions, transfers of interests, or upon termination of a Fund. The Incentive Allocation varies by Fund and share class by range from 15% of net capital appreciation above an applicable hurdle amount, subject to loss recovery provisions to up to 30% of performance in excess of a specified benchmark amount, subject to adjustments for Management Fees. The Sub-Advised Funds pay an incentive fee to Lykos, generally at the end of each fiscal year, in an amount equal to a specified percentage according to that Sub-Advised Fund’s Governing Documents. Performance-based compensation creates an incentive for the Firm to make investments that are riskier or more speculative than those which we would recommend under a different arrangement. We have adopted and implemented policies and procedures intended to address conflicts of interest relating to the management of multiple accounts, including accounts with multiple fee arrangements, the allocation of investment opportunities and expenses. In addition to the Funds, the Firm provide investment management services to the Sub-Advised Funds. Certain of these Investors may not pay performancebased compensation. These Investors still participate pro rata in their applicable Fund’s overall investment program. As a result, the Firm may manage accounts that pay performance-based compensation alongside accounts that do not. This creates a potential conflict of interest because the Firm may have an incentive to allocate investment opportunities to accounts that pay performancebased compensation over accounts that do not. The Firm seeks to mitigate these conflicts through policies and procedures designed to allocate investment opportunities among clients in a manner that the Firm believes is fair and equitable over time, taking into account the investment objectives, strategies, restrictions, capital availability, and other relevant factors of each Client.
Item 10: Other financial industry activities and affiliations Conflicts of interest
Neither we nor our management persons are registered as broker-dealers, and neither of us has any application pending to register with the SEC as a broker-dealer or registered representative of a brokerdealer, respectively. Lykos Global Partners GP, LLC serves as the General Partner to the Funds, is affiliated with Lykos and meets the definition of an exempt Commodity Pool Operator. It files for CFTC Rule 4.13(a)(3) exemptions for each of the Funds. Lykos and its affiliates engage and retain consultants (“Consultants”) to provide a variety of services. In certain cases, Consultants have attributes of Lykos “employees” (e.g., they may be expected to have dedicated offices at Lykos, receive administrative support from Lykos, and participate in Lykos’ meetings and events). These Consultants generally provide services to Lykos through separate business entities and also provide services to other clients. Lykos evaluates and monitors these arrangements to identify and address potential conflicts of interest.
Item 11: Code of ethics, participation or interest in client transactions and personal trading Conflicts of interest
Code of Ethics Lykos has adopted a “Code of Ethics” that establishes the high standard of conduct that we expect of our employees and procedures regarding our employees’ personal trading of securities. Our employees are required to certify their adherence to the terms set forth in the Code of Ethics upon commencement of employment and annually thereafter. Employees also are required to provide quarterly certifications of compliance with certain Code of Ethics provisions. The foundation of our Code of Ethics is based upon the following underlying fiduciary principles: •
Employees must at all times place the interests of the Clients and Investors first;
•
Employees must ensure that all personal securities transactions are conducted consistent with the Code of Ethics’ Employee Personal Investment Policy (described below); and
•
Employees should not take inappropriate advantage of their position at the Firm.
Employees are not permitted to maintain personal brokerage accounts for the purpose of trading “Reportable Securities” (as defined in the Code of Ethics, and which includes a wide variety of investments such as stocks, bonds, fixed income, options, warrants, futures, and derivatives) except for the purpose of holding or liquidating any such holdings after the commencement of employment. Employees are permitted to liquidate positions held at the time of employment in Reportable Securities (a “Liquidating Trade”) subject to pre-clearance by the CCO. Employees are prohibited from participating in Initial Public Offerings (“IPOs”). Employees are also prohibited from personally, or on behalf of a Client, purchasing or selling securities that appear on the Firm’s Restricted List. The Firm on occasion comes into possession of material nonpublic or other confidential information about public companies which, if disclosed, might affect an Investor’s decision to buy, sell or hold a security. Under applicable law, the Firm is prohibited from improperly disclosing or using such information for its personal benefit or for the benefit of any person, including the Clients. Accordingly, should the Firm or any of its supervised persons come into possession of material nonpublic or other confidential information with respect to any company, they would be prohibited from using such information on behalf of the Clients or disclosing it to the Investors, and they will have no responsibility or liability for failing to use or disclose such information. Similar restrictions could be applicable as a result of the Firm’s supervised persons serving as directors of public companies and restrict disposition of such companies’ securities by the Clients. Employees must obtain pre-approval from the CCO before: (i) engaging in any outside business activities; or (ii) making any private investments. The Firm’s Code of Ethics also contains policies and procedures regarding gifts and entertainment with business associates and political contributions. We will provide a copy of our Code of Ethics to our Investors or Clients, or any prospective investor or client, upon request, to be viewed on the premises.
Item 12: Brokerage practices Conflicts of interest
Selecting or Recommending Broker-Dealers Lykos is authorized to determine the broker-dealer to be used for executing securities transactions for the Clients. In selecting broker-dealers to execute transactions, we do not need to solicit competitive bids and do not have an obligation to seek the lowest available commission cost. It is not our practice to negotiate “execution only” commission rates; therefore, the Clients may be deemed to be paying for research, brokerage or other services provided by the broker which are included in the commission rate. We shall also have the authority to select and appoint custodians of the assets of the Funds. The Firm’s authority is limited by its own internal policies and procedures and each Clients’ investment guidelines. Best Execution In selecting an appropriate broker-dealer to effect a client trade, we seek to obtain “Best Execution,” meaning generally the execution of a securities transaction for a client in such a manner that a client’s total costs or proceeds in the transaction are most favorable under the circumstances. Accordingly, in seeking Best Execution, we will take into consideration the price of a security offered by the brokerdealer, as well as a broker-dealers’ full range and quality of their services including, among other things, their facilities, reliability and financial responsibility, execution capability, commission rates, responsiveness to us, brokerage and research services provided to us (for example, research ideas,
analysis, and investment strategies), special execution and block positioning capabilities, clearance, and settlement and custodial services. Research and Other Soft Dollar Benefits The Firm may use “Soft Dollars”. In such cases, Soft Dollar credits, generated by the Clients’ trading activities, could be used to purchase brokerage and research services or products that would otherwise have been an expense to the Client. We intend to keep any such arrangements within the parameters of the safe harbor of Section 28(e) of the Exchange Act. Neither Lykos nor any related person receives client referrals from any broker-dealer or third party. However, subject to best execution, we may consider, among other things, capital introduction and marketing assistance with respect to Investors in the Funds in selecting or recommending broker-dealers for the Clients. The provision by a broker of research and other services and property to us creates an incentive for us to select such broker since we would not have to pay for such research and other services and property as opposed to solely seeking the most favorable execution for a client. Any research, services or property provided by a broker may benefit any client and such benefits may not be proportionate to commission dollars related to the provision of such research, services or property. Directed Brokerage Lykos determines the selection of broker-dealers for securities transactions of the Clients subject to the Firm’s policy to seek best execution for such transactions. Lykos does not recommend, request or require that a Client direct it to execute transactions through a specified broker-dealer, nor does Lykos permit a Client to direct brokerage. Trade Aggregation The Firm’s “Trade Aggregation Policy” provides that, for multiple client accounts, the Firm will aggregate trades only in accordance with the SEC’s guidance. In addition, trades should only be aggregated if by doing so the Firm is facilitating Best Execution, including negotiating more favorable prices, obtaining more timely or equitable execution, or reducing overall commission charges. Trade Errors The Firm’s “Trade Error Policy” provides that any Trade Error should be corrected as soon as possible following discovery of the Trade Error in accordance with the principles and procedures described below. The Firm generally will seek to detect such Trade Errors prior to settlement and promptly correct and/or mitigate them. A Trade Error may not be resolved by reallocating the trade to another Client. Soft Dollar credits, if any, may not be used to pay for correcting Trade Errors.
Item 14: Client referrals and other compensation Conflicts of interest
We do not receive economic benefits from non-clients for providing investment advice and other advisory services. Neither we nor any of our related persons, directly or indirectly, compensate any person who is not a supervised person of the Firm for Client referrals.
Item 9: Disciplinary information
To the best of our knowledge, there are no legal or disciplinary events that are material to a Client or an Investor’s or prospective investor's evaluation of our advisory business or the integrity of our management.
Item 13: Review of accounts
Our Portfolio Manager and investment professionals continuously monitor and analyze the transactions, positions, and investment levels of the Clients to ensure that they conform with the investment objectives and guidelines that are stated in each Clients’ Governing Documents. In these reviews, the Firm pays particular attention to any changes in the investment’s fundamentals, overall risk management and changes in the markets that may affect price levels. Account Reporting
We perform various periodic reviews of each Clients’ portfolios. Such reviews are conducted by our officers and professionals, including the relevant members of our investment team. For the Funds, we distribute an audited financial report with respect to the previous fiscal year to all Investors within 120 days of fiscal year end. The independent administrator of the Funds will also distribute, no less frequently then every quarter an unaudited net asset value statements to all Investors.
Item 15: Custody
We serve as the General Partner to the Funds for which we provide investment advisory services. Accordingly, we are deemed to have custody of funds and securities for such Funds. However, we do not send quarterly (or more frequent) statements to the Funds. We do not maintain custody of funds or securities for the Sub-Advised Funds because we do not have possession or have authority to obtain possession of such funds or securities. Clients should review any statements received from us or a custodian carefully, and to the extent they receive statements from both us and a custodian, they are urged to compare such statements carefully.
Item 16: Investment discretion
We have full discretionary investment authority with respect to our Clients, including authority to make decisions with respect to which securities to be bought and sold, as well as the amount and price of those securities.
Item 17: Voting client securities
In compliance with Rule 206(4)-6 of the Advisers Act (i.e., the “proxy voting rule”), we have adopted proxy voting policies and procedures. The Firm’s policy is to not vote on any proxies as it has determined it is in the best interests of each of its Clients not to vote proxies with respect to Client Securities.
Item 18: Financial information
We are not required to include a balance sheet for our most recent fiscal year, are not aware of any financial condition reasonably likely to impair our ability to meet contractual commitments to Clients, and have not been the subject of a bankruptcy petition at any time during the past ten years.
Timeline
- 2024Founded Founded1
Links
- Websitelykosglobal.com1
- LinkedInwww.linkedin.com/company/lykos-global-management-lp1
- WikidataQ136689096
Sources
The numbers on this page point here. Each one links to the record it came from.
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- 3Company websiteLykos Global Management logo
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