Private company
PARTNERS CAPITAL INVESTMENT GROUP, LLP
Limited liability partnership registered in the United States, based in Boston. Summary from the record
Last updated Oct 21, 2026.
Overview
- HeadquartersBoston, United States2
- Legal formLimited Liability Partnership2
- Kind of organizationLimited liability partnership2
- LEI549300E1ZIF6Q2I5FZ832
- StatusActive2
- LEI statusLapsed (not renewed)2
- Registered addressC/O THE CORPORATION TRUST COMPANY, 19801 Wilmington, United States2
- Registered withDivision of Corporations, Department of State, 61813032
Corporate structure
PARTNERS CAPITAL INVESTMENT GROUP, LLP is part of a group headed by Partners Capital Holdings, LLP. 18 entities, 5 countries on record. Switch between the flow chart and the network, and select any entity to see its details.
- Partners Capital Holdings, LLP Wilmington, Delaware, United States
- PARTNERS CAPITAL INVESTMENT GROUP, LLP Boston, Massachusetts, United States
- PARTNERS CAPITAL INVESTMENT GROUP LIMITED London, United Kingdom
- Partners Capital LLP London, United Kingdom
- 1 more
- Partners Capital LLP London, United Kingdom
- ARES STRATEGIC INCOME FUND Stake · New York, New York, United States
- PARTNERS CAPITAL ASIA LIMITED Subsidiary · Central, Hong Kong
- PARTNERS CAPITAL EUROPE Subsidiary · Paris, France
- PARTNERS CAPITAL INVESTMENT GROUP (ASIA) PTE. LTD. Subsidiary · Singapore, Singapore
- Partners Capital Asia Co-Invest Fund Ltd. Fund · Boston, Massachusetts, United States
- PARTNERS CAPITAL FALCON FUND (A), L.P. Fund · Boston, Massachusetts, United States
- PARTNERS CAPITAL FALCON FUND (C), LTD. Fund · Boston, Massachusetts, United States
- PARTNERS CAPITAL GREYHAWK FUND, L.P. Fund · Boston, Massachusetts, United States
- PARTNERS CAPITAL HARRIER FUND (A) L.P. Fund · Boston, Massachusetts, United States
- Partners Capital Harrier Fund (C) Ltd Fund · Boston, Massachusetts, United States
- Partners Capital Phoenix Fund II Ltd - Diversified Income Fund Fund · Boston, Massachusetts, United States
- THE MASTER PORTFOLIO (A), L.P. Fund · Boston, Massachusetts, United States
- THE MASTER PORTFOLIO (B) LTD Fund · Boston, Massachusetts, United States
- PARTNERS CAPITAL INVESTMENT GROUP LIMITED London, United Kingdom
- PARTNERS CAPITAL INVESTMENT GROUP, LLP Boston, Massachusetts, 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 (1 companies). Each entity in the chart links to its source.
Investment adviser
PARTNERS CAPITAL INVESTMENT GROUP, LLP 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$50.5B4 886 accounts, $31.4B with discretion
- Employees190 102 in investment advice or research
- ClientsCharitable organizations: 147 ($21.0B); Pooled investment vehicles (other than investment companies and: 123 ($19.8B); High net worth individuals: 521 ($6.2B); Pension and profit sharing plans (but not the plan participants or: 90 ($2.3B); State or municipal government entities (including government pension: 3 ($1.1B); Investment companies: 2 ($112.1M)
- How it is paidA percentage of assets under its management; Fixed fees (other than subscription fees); Performance-based fees
- What it doesPortfolio management for investment companies
- Holds client assetsYes: cash and securities
- RegistrationSEC 801-61234, CRD 120663 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).
- PARTNERS CAPITAL INTERMEDIATE 2 LLCowns 75% or more, since 12/2023
- Arjun Raju Raghavanowns 5% to 10%, since 06/2017
- Gabriel Pierre Caillauxowns general partner, trustee or manager of GASC MGP, LLC, since 03/2024
- Knut Torbjorn Caeserowns general partner, trustee or manager of GASC MGP, LLC, since 08/2025
- Martin Escobari Lifchitzowns general partner, trustee or manager of GASC MGP, LLC, since 03/2024
- William Edward Fordowns general partner, trustee or manager of GASC MGP, LLC, since 03/2024
- GA GENPAR GP, LLCowns general partner, trustee or manager of GA GENPAR GP, LLC, since 07/2021
- GA GENPAR GP, LLCowns general partner, trustee or manager of GENERAL ATLANTIC PARTNERS 100, L.P., since 03/2017
- GASC GP, LLCowns general partner, trustee or manager of GASC MANAGEMENT HOLDCO, L.P., since 07/2021
- GASC GP, LLCowns general partner, trustee or manager of GENERAL ATLANTIC PARTNERS, L.P., since 07/2021
- GENERAL ATLANTIC GENPAR,owns general partner, trustee or manager of GENERAL ATLANTIC, since 03/2017
- David Charles Hodgsonowns general partner, trustee or manager of GASC MGP, LLC, since 03/2024
- GASC MGP, LLCowns 75% or more of GASC GP, LLC, since 01/2018
- GENERAL ATLANTIC PARTNERSowns 75% or more of GENERAL ATLANTIC, since 03/2017
- GENERAL ATLANTIC PARTNERS, L.P.owns 75% or more of GA GENPAR GP, LLC, since 07/2021
- HCP PCIG LLCowns 75% or more of PARTNERS CAPITAL INTERMEDIATE 4 INC., since 06/2024
- PARTNERS CAPITALowns 75% or more of PARTNERS CAPITAL, since 06/2024
- PARTNERS CAPITALowns 75% or more of PARTNERS CAPITAL (HOLDINGS) LLP, since 06/2024
- PARTNERS CAPITAL GROUP HOLDINGS, INC.owns 75% or more of HCP PCIG LLC, since 12/2023
- PARTNERS CAPITAL HOLDINGS,owns 75% or more of PARTNERS CAPITAL, since 12/2023
- GASC MANAGEMENT HOLDCO,owns 25% to 50% of GENERAL ATLANTIC, since 07/2021
- GENERAL ATLANTIC (PCO), L.P.owns 25% to 50% of PARTNERS CAPITAL HOLDINGS, LLP, since 07/2024
In its own words: the client brochure
Form ADV Part 2A, the plain-English document an adviser must give its clients, quoted as filed 4/28/2026.5 It covers the firm’s services, fees, investment strategies and their risks, and its conflicts of interest.
Item 4: Advisory business Services
Firm Description Partners Capital Investment Group, LLP (“Partners Capital” or the “Firm”), a Delaware limited liability partnership, is an investment adviser based in London, New York City, Boston, San Francisco, Dallas, Singapore, Hong Kong, Paris, Dubai and Switzerland. Partners Capital was founded in 2001 to deliver an institutional investment approach to endowments, foundations, and sophisticated families. We provide advice on asset allocation and what we believe to be the best of breed asset manager selection across all asset classes and geographic markets. In July 2024, certain investment funds controlled by affiliates General Atlantic Service Company, L.P. (“GA”) acquired a minority stake in the Partners Capital group by buying a portion of the equity then held by some of Partners Capital’s long-standing external shareholders and certain founding generation partners (the “Transaction”). Although (1) the Transaction did not result in any changes to the day-to-day business or operations of Partners Capital, the services Partners Capital provides or the fees Partners Capital charges to its clients, and (2) as part of the Transaction, Partners Capital and GA agreed to continue to conduct their businesses independently from one another (provided that certain employees of GA serve on the board of Partners Capital), certain information in this brochure reflects the change in ownership resulting from and other disclosures relating to the Transaction and/or Partners Capital’s ongoing relationship with GA. Types of Advisory Services Partners Capital provides investment advice related to overall asset allocation, asset allocation within asset classes and investment product recommendations. Partners Capital advises clients and serves as the general partner of privately offered domestic funds and as the investment manager to privately offered offshore funds (each a “Fund” and together the “Funds”) as well as sub-adviser to investment companies registered under the Investment Company Act of 1940, as amended (the “1940 Act”) (each a “Registered Fund”, and together the “Registered Funds”). We primarily allocate assets of clients to other pooled vehicles or separate accounts managed by third-party professional fund managers, including hedge fund managers, private equity managers, and other asset class managers (collectively, “Investment Managers”) that utilize a wide variety of strategies. Tailored Relationships We aim to provide our clients with highly customized investment advice which diversifies their portfolios across all asset classes including but not limited to public equity, private equity, property, commodities, fixed income, credit and hedge funds. Our mandates range from full discretion to purely advisory. The engagement is driven by each client’s specific circumstances and internal governance model. Clients have the ability to place limitations and restrictions on securities purchased or sold or other investments made in their account.
Investment Vehicles Typical investment vehicles we advise on generally include, but are not limited to, public registered investment companies including mutual funds, closed-end funds and business development companies, private placement vehicles (e.g., hedge funds or private equity funds), other private investments, separately managed accounts, unit trusts and exchange-traded funds. In general, we are not advising clients on individual stocks or bonds, except in the context of overall asset allocation or with respect to the co-invest strategies. The Funds, Registered Funds, and other clients (e.g., individuals, trusts, separately managed accounts, etc. referred to as “Other Clients”) are together referred to as our “Clients”. The Funds are designed as pooled vehicles and invest in certain limited partnerships or other investments. Partners Capital has the discretion to cause the Funds to invest in investments as described in each of the respective Fund’s private placement memorandum, prospectus or registration statement, advisory agreement, or limited partnership agreements. Although the Firm serves as sub-adviser to Registered Funds, most of the Funds are (a) privately placed, (b) not registered under the 1940 Act, and (c) may or may not be continuously offered. Principal Services Provided The main services provided to Clients include but are not limited to: • Research, identify, monitor, evaluate and meet with potential Investment Managers; • Select Investment Managers and/or their investment vehicles or opportunities for Clients; • Advise Other Clients as to the availability of opportunities to invest funds with particular Investment Managers; • Assess the performance of Investment Managers managing assets of Clients and make periodic recommendations to Clients with respect to such performance; and • Maintain records for Clients relating to their recommendations, retention, performance and services of Investment Managers selected and recommended by Partners Capital. Assets Under Management Partners Capital manages Client assets on a discretionary and a non-discretionary basis. As of December 31, 2025, assets under management for US Clients were: USD Discretionary $31,415,782,709 Non-Discretionary $19,091,386,581 Total (US Clients only) $50,507,169,290
Item 5: Fees and compensation Fees
Description Partners Capital does not have a standardized fee schedule. Partners Capital usually charges an advisory fee in arrears on the Client’s Assets Under Management (“AUM”). In general, we charge an annual management fee that can range up to 1% per annum on time-weighted AUM, payable quarterly. Where permitted by applicable law, Clients can elect to be charged only an advisory fee or both an advisory and a performance-based fee, or both an advisory or a relative performancebased fee. Partners Capital may receive performance based compensation of generally up to 7.5%, and relative performance based compensation of generally up to 15%, payable annually or semiannually. Fees may vary by Client size, complexity and other factors deemed appropriate by Partners
Capital. Performance-based fees for liquid products are described below in the “Performance-Based Fees” section. In some cases, a fixed annual fee may also apply. We may also charge an administrative fee on FX Hedges, which are 0.02% of the notional amount. This fee is generally charged at the inception of the hedge or when the hedge is rolled. Following termination of an agreement, in respect of each illiquid asset advised by Partners Capital, Clients may have the obligation to pay to Partners Capital a one-time only fee equal to 2% of the aggregate amount of all original commitments to those illiquid assets in which Clients still have a material interest less management fees paid to date for such illiquid assets. Partners Capital receives a portion of the Registered Funds’ management fees that are payable to the Registered Funds’ primary adviser. Partners Capital charges the Funds a management fee and, in some cases, a performance fee that is disclosed in detail in each Fund’s private placement memorandum, prospectus or registration statement, advisory agreement, limited partnership agreement and/or other documentation received by each investor prior to investment in a Fund. Fees may differ from one Fund to another, as well as among investors in the same Fund. The Funds also bear their share of expenses as set forth in the “Other Fees and Expenses” section below. Fee Billing Client fees may be collected from the Client’s custodial account with the Client’s authorization, collected via an invoice sent to the Client, or collected directly from the Funds as permitted by the relevant Fund’s private placement memorandum, prospectus or registration statement. Some Clients may have fees collected from a combination of these three sources, i.e. custody account, direct invoice and/or domestic or offshore fund entities. Other Fees and Expenses Clients may be charged fees or commissions in addition to the management fee paid to Partners Capital. These may include brokerage commissions and other custodial fees charged by third-party organizations. Clients may also be charged expenses (e.g. legal costs) incurred in relation to their direct co-investments. The Funds generally bear their own expenses set forth below: • Organizational Expenses: costs, fees and expenses incurred by or on behalf of a general partner and/or the Partners Capital in connection with the formation and organization of the Fund. • Direct Operating Expenses: legal, administrative, audit, insurance, regulatory, bookkeeping and accounting, brokerage fees, compliance service provider fees; all filing and similar fees; interest on borrowed money, real property or personal property
•
taxes on investments; costs and expenses incurred in the purchase, holding, sale or exchange of investments, fees incurred with the maintenance of bank or custodian accounts; expenses incurred by a general partner (or its designee) in serving as a “partnership representative"; out-of-pocket expenses of preparing and distributing reports and other communications to investors or associated with any Fund meetings, including, but not limited to, printing, postage, communication and travel and accommodation costs; services and expenses incurred in researching, investing, and evaluating investment opportunities, including the cost of books, databases, periodical subscriptions, research platforms, travel and accommodation costs and other research resources; services and expenses related to monitoring investments; expenses related to software acquired, licenses or otherwise obtained by a Fund or Partners Capital for use in respect of a Fund, to track investments; litigation or other extraordinary expenses relating to a Fund and its activities; costs and expenses arising out of a Fund’s indemnification obligations and cost of insurance against potential indemnification liabilities; (if any) director’s fees and expenses. Broken Deal Expenses: all out-of-pocket fees, costs and expenses, if any, incurred in developing, negotiating and structuring prospective investments that are not ultimately made, including any legal, accounting, advisory, market research, consulting or other thirdparty expenses in connection therewith and any travel and accommodation expenses.
Please refer to a Fund’s limited partnership agreement, investment management agreement, or Registered Fund’s prospectus or registration statement for details regarding the Fund’s or Registered Fund’s treatment of fees and expenses. Accounts that are part of the Partners Capital Equity Portfolios are charged a yearly expense reimbursement to cover incremental costs directly relating to the investment program, including but not limited to costs of third party providers specializing in: trade order and execution and proxy voting services.
Item 8: Methods of analysis, investment strategies and risk of loss Investment strategies and risks
Methods of Analysis Partners Capital obtains general information through meetings with Investment Managers, independent and third-party research, the internet, and periodicals and journals. Investment Strategies Partners Capital deploys an investment philosophy that embraces many of the powerful diversification benefits of the so-called “endowment model” of investing, but with a more dynamic approach to risk and asset allocation which seeks to clearly delineate between performance to be derived from market factors as opposed to the skill of individual managers. Partners Capital may utilize margin transactions to implement investment advice given to Clients. Since we are engaged primarily in seeking, monitoring, understanding and evaluating Investment Managers and their strategies, general categories of securities analysis methods for direct investment in individual securities are typically not applicable. Instead, we seek to understand the strategies and approaches of Investment Managers by interviewing Investment Managers and generally considering numerous factors including, but not limited to: • Management team's reputation and integrity • Depth and continuity of the investment team • Demonstrated superior investment skills • Review of past performance • Ability to implement investment strategies • Consistency of investment strategies and processes • Reviewing and corroborating their professional records • Operational systems and capabilities • Risk controls • Significant personal investment • Legal terms and conditions • Fees and other costs Partners Capital may request certain records of these Investment Managers, as well as corroborating information received from independent sources, in order to reach conclusions as to the Investment Manager’s potential performance characteristics. Risk of Loss Although the Firm makes every effort to preserve a Client’s capital and achieve real growth of wealth, investing involves risk of loss that each Client should be prepared to bear. Certain instruments and strategies, including those involving futures, options, and high yield securities, give
rise to substantial risk and are not suitable for all investors. Many investments described herein are speculative, involve significant risk and are suitable only for investors of substantial net worth who are willing and have the financial capacity to purchase high-risk investments which may not provide any immediate cash return and may result in the loss of all or a substantial part of their investment. An investor should be able to bear a complete loss in connection with any investment.
General Investment Risks (not specific to any one asset class) Market and Economic Risk Every investment strategy and style are based explicitly or implicitly on a premise as to how the markets work and on certain conditions being met. The stability and persistence of these premises, assuming they are intrinsically valid, is rarely if ever perfect and depend on the markets working in the expected way. Changes in market and economic factors like interest rates, inflation, monetary policy, economic growth, investor sentiment and time horizons and exogenous events (like terrorism or pandemic) can undermine the investment premise temporarily or for a long period. Pandemic Disease Events such as health pandemics or outbreaks of disease (such as the “COVID-19” coronavirus) may lead to government-imposed closures and restrictions of certain travel and businesses, as well as both increased short-term market volatility and adverse long-term effects on the U.S. and world economies and markets generally. This could have an adverse impact on Partners Capital’s ability to carry out investment strategies and objectives on behalf of its Clients, as well as on the business of Investment Managers selected by Partners Capital. Pandemics and similar events could also have an acute effect on individual issuers or related groups of issuers and could adversely affect securities markets, interest rates, auctions, secondary trading, ratings, credit risk, inflation, deflation and other factors Client portfolios or the operations of Investment Managers. Additionally, the risks related to health pandemics or outbreaks of disease are heightened due to uncertainty as to whether such an event would qualify as a force majeure event. If a force majeure event is determined to have occurred, a Client and/or a Client’s investments may be relieved of its obligations under certain contracts to which it is a party, or, alternatively, the Client may be required to meet its contractual obligations, despite potential constraints on operations and/or financial stability. Either outcome could adversely impact the performance of Client Portfolios. Economic and Political Risk To the extent the Partners Capital make investments in companies organized, headquartered, or having substantial assets, outside of the United States, such investments may be subject to additional economic and political risks. Governments of many foreign countries have exercised and continue to exercise substantial influence over many aspects of the private sector. Accordingly, future government or military actions could have a significant effect on the economic environment in such countries, which could affect the availability, purchase price, and returns of portfolio investments of companies affected by such governments. For example, investments reliant on operating centers in Russia or Ukraine will be negatively impacted by ongoing military action and may be unable to relocate resources and staff. Non-U.S. Trade Policy If the U.S. federal government continues to make significant changes in U.S. trade policy, including imposing tariffs on certain goods and raw materials imported into the United States, such actions
may trigger retaliatory actions by the affected countries, resulting in “trade wars,” which may cause increased costs for goods and raw materials imported into the United States, or in trading partners limiting their trade with businesses in the United States, either of which may have material adverse effects on the Investment Managers and companies in which they invest. Such “trade wars” may cause significant losses for Partners Capital Clients and/or the Investment Managers in which their assets are invested. U.S. -China Relations If U.S.-China relations remain a persistent and evolving source of policy volatility affecting trade, investment flows, technology supply chains, and access to capital markets. The U.S. has imposed, and may continue to impose, tariffs and other trade restrictions on a broad range of Chinese imports, and China has responded with retaliatory measures, which can increase input costs, disrupt supply chains, and adversely impact portfolio company operations and valuations. These dynamics can result in sector-wide tariff escalation, impairing profitability and exit outcomes for affected businesses. Regulatory scrutiny over Chinese issuers and China-related exposures in U.S. capital markets also continues to evolve. Heightened audit and disclosure requirements and the potential for additional listing, trading, or investment restrictions could affect the liquidity, valuation, or availability of certain securities, funds, or co-investment opportunities. This includes the risk that U.S. authorities could impose further investment limitations or diligence requirements on U.S. institutions with respect to Chinese equities or debt, which could constrain investment strategies of Investment Managers or necessitate repositioning of Client holdings. If U.S.-China tensions intensify—through renewed tariff escalation, expansion of export controls, or additional limitations on market access—the broader economy and equity markets may be adversely affected, Partners Capital Clients and/or the Investment Managers in which their assets are invested could experience higher costs, reduced opportunity sets, valuation pressure, or delays in realizations, any of which could materially and adversely affect the performance of Client Portfolios. Currency Risk Clients may invest portions of their assets in securities denominated in non-US Dollars, whereas the values of their accounts are denominated in US Dollars. Clients will be subject to currency market risks associated with fluctuations in the value of the foreign currencies in which their investments are denominated. Fluctuations in the value of a country’s currency could have an adverse impact on the profitability of the Client account. To the extent that the US Dollar appreciates relative to these currencies, the US Dollar value of these investments is likely to be adversely affected. In addition, if the currency in which a Client receives dividends, interest or other types of payments (such as liquidating payments) declines in value against the US Dollar before such payments are distributed, the US Dollar value of these payments could be adversely affected if not sufficiently hedged. Furthermore, the ability of a Client companies in which they invest to convert freely between the US Dollar and the local currencies may be restricted or limited and, in a number of instances, exchange rates and currency conversion are controlled directly or indirectly by governments or related entities. Many of the currencies of emerging markets have been subject to large fluctuations in value in the last five years and may be subject to significant fluctuations in the future. The economies of many emerging markets have been characterized by high inflation rates. Inflation in the countries where Clients may make investments may adversely affect the Client account’s results and value.
Inflation Risk Inflation and rapid fluctuations in inflation rates have had in the past, and may in the future have, negative effects on the economies and financial markets, particularly in emerging economies, but also in more developed economies, including in the U.S. economy where inflationary conditions can arise and persist for extended periods. For example, wages and prices of inputs increase during periods of inflation, which can negatively impact returns on investments, and increases in energy prices will have a ripple effect through the economy. In an attempt to stabilize inflation, countries may impose wage and price controls or otherwise intervene in the economy. Governmental efforts to curb inflation often have negative effects on the level of economic activity. There can be no assurance that inflation will not become a serious problem in the future and have an adverse impact on the returns of the Investment Managers or the portfolios of Partners Capital Clients. Interest Rate Risk Changes in interest rates may adversely affect the investments of Partners Capital Clients. Investment Managers holding debt securities are subject to interest rate risk; changes in prevailing market interest rates could negatively affect the value of credit investments in an Investment Manager’s portfolio. The ability of companies or businesses in which an Investment Managermay invest to refinance debt instruments or repay debt obligations (including making payments an Investment Manager as a creditor with respect thereto) may depend on their ability to obtain financing, including by selling new securities or instruments in the high yield debt or bank financing markets, which at certain points have been extraordinarily difficult to access at favorable rates. Volatility and instability in the credit or securities markets may also increase the risks inherent in an Investment Manager’sinvestments. Interest rate changes may affect the value of a debt instrument indirectly (especially in the case of fixed rate securities and other instruments) and directly (especially in the case of instruments whose rates are adjustable). In general, rising interest rates will negatively impact the price of a fixed rate credit instrument and falling interest rates will have a positive effect on price. Adjustable rate instruments also react to interest rate changes in a similar manner, although generally to a lesser degree. Interest rate sensitivity is generally more pronounced and less predictable in instruments with uncertain payment or prepayment schedules. Additional factors that may affect market interest rates include inflation, slow or stagnant economic growth or recession, unemployment, and instability in domestic and foreign financial markets. An Investment Manager may periodically experience imbalances in its assets and liabilities as a result of changes in interest rates. In a changing interest rate environment, an Investment Manager may not be able to manage this risk effectively. Increased interest rates could impact the ability of Investment Managers or their underlying portfolio companies or their underlying portfolio companies to obtain leverage in a manner initially contemplated and may impact the ability of an Investment Manager to execute its investment strategy. If an Investment Manager is unable to manage interest rate risk effectively, the Investment Manager’s performance could be adversely affected, which could in turn negatively impact the returns of Partners Capital Clients Availability of Investment Opportunities The identification of investment opportunities involves a high degree of uncertainty and is based on a subjective decision-making process. Thus, there can be no assurance that Partners Capital will be able to identify suitable investment opportunities or select Investment Managers with access to such opportunities and, even when an opportunity is identified, there is a risk that the opportunity will not achieve targeted rates of return. Registered Funds are subject to certain regulatory limitations relating to joint transactions with affiliates and co-investments, which in some
Item 7: Types of clients
Description
Our Clients consist of the Funds, Registered Funds, and Other Clients. The Other Clients include individuals, foundations, endowments, family offices, pension funds and other types of institutions. We may organize additional investment entities in the future. Account Minimums Partners Capital new client minimum account size is $100 million. We reserve the right to waive the minimum in certain circumstances.
Item 6: Performance-based fees and side-by-side management Conflicts of interest
Sharing of Capital Gains Partners Capital may charge performance-based fees subject to a high-water mark. Generally, a 5% performance fee is charged on gains after adjusting for the management fee. Performance fees are charged in accordance with Rule 205-3 under the Investment Advisors Act. Generally, every six months, Partners Capital will receive 5% of the net new profits, if any, attributable to each investor in the Funds, and after taking account of a high-water mark, if applicable. Certain conflicts of interest may arise when managing accounts that are charged a performancebased fee as compared to another type of fee, such as a fixed-rate/asset-based fee. There is an incentive to favor accounts from which performance-based fees are received. Partners Capital has policies and procedures in place for an annual review by the Client manager's supervisor, of Client trading, investment objectives and possible conflicts of interest. Our policies and procedures have been developed to ensure that all Clients are treated fairly and equally, and without the influence of performance-based fees on trade allocation. See Appendix 1 for detailed allocation procedures.
Item 10: Other financial industry activities and affiliations Conflicts of interest
Financial Industry Activities
Partners Capital is registered as a commodity pool operator and a commodity trading advisor with the Commodity Futures Trading Commission and is a member of the National Futures Association. Additionally, the following entities are affiliated with Partners Capital: • Pacific Way Capital Management, LLC is an investment adviser registered with the SEC, and a member of the National Futures Association; • Partners Capital LLP is authorized and regulated by the Financial Conduct Authority in the United Kingdom; • Partners Capital Asia Limited is licensed with the Securities and Futures Commission, located in Hong Kong; • Partners Capital Investment Group (Asia) Pte Ltd is regulated by the Monetary Authority of Singapore as a holder of a Capital Markets Services license for Fund Management under the Securities and Futures Act and as an exempt financial adviser; and • Partners Capital Europe SAS is regulated by the Authorité des Marchés Financiers. Partners Capital has signed a Participating Affiliates Agreement with Partners Capital LLP, Partners Capital Investment Group (Asia) Pte Ltd, Partners Capital Asia Limited and Partners Capital Europe S.A.S (each a “Participating Affiliate”). Under this agreement, Participating Affiliates provide expertise and resources to Partners Capital in reliance on positions of the SEC staff and related guidance to the effect that a non-U.S. advisory affiliate of a U.S. registered investment adviser may share personnel with, and provide certain services to U.S. clients through, the registered investment adviser without such Participating Affiliate registering as an investment adviser under the Advisers Act. Affiliations One or more affiliates of Partners Capital serve as general partner or managing members of the Funds that are not Registered Funds. From time to time, Partners Capital receives compensation from its various subsidiaries’ asset management activities (e.g. Pacific Way Capital Management, LLC), including compensation generated from direct or indirect asset management activities performed for Clients of Partners Capital. These arrangements may present a conflict for Partners Capital to promote or recommend products or services managed by Partners Capital’s subsidiaries. However, Partners Capital maintains policies and procedures designed to ensure investment recommendations are made in the best interest of Clients, and Clients do not bear additional fees relating to Funds managed by Partners Capital or its subsidiaries. Other Related Persons GA is a related person of ours. We do not believe that our relationship with GA would negatively impact Clients when considering the services provided and the compensation paid versus available and potentially comparable providers. For a description of potential material conflicts of interest created by the relationship among us and GA, as well as a description of how such conflicts are addressed, please see Item 11 below.
Item 11: Code of ethics, participation or interest in client transactions and personal trading Conflicts of interest
and Personal Trading Code of Ethics
Partners Capital has a Code of Ethics that summarizes the Firm’s standards of conducts and fiduciary duties, and monitors and limits personal trading by employees and their immediate family/household members. Among other things, we require all employees and immediate family/household members to submit periodic reporting on their personal transactions and holdings and to pre-clear personal investments certain types of securities including Reportable Securities, IPOs and private placements. The Code of Ethics also requires employees to promptly report suspected violations of the Code of Ethics or any applicable law and that they certify their compliance with the Code of Ethics periodically. Partners Capital has implemented various policies and procedures based on principles contained in the Code of Ethics, several of which are described in the “Other Conflicts of Interests” section below. Additionally, all of our personnel are subject to policies and procedures regarding the use of confidential information, market abuse and other prohibited activities. It is our policy that personnel involved in investment decision-making must act in the best interest of the Funds and Other Clients. A copy of the Code of Ethics is available upon request. Participation or Interest in Client Transactions Partners Capital serves as the general partner, investment manager, or sub-adviser of the Funds or Registered Funds. We are entitled to receive the management fees, performance-based fees and set-up fees, as described above under Fees and Compensation and Performance-Based Fees. Partners Capital may recommend Clients invest in the Funds or Registered Funds if it is appropriate for the Clients’ overall investment strategy. Clients are provided with private placement memoranda or prospectuses that provide full disclosure of terms for the Funds and other relevant matters. Certain of the Funds may charge fees, including advisory and performance fees. Where applicable, Partners Capital will credit the management and performance fees collected through the Funds or Registered Funds against fees otherwise owed to Partners Capital by Clients invested in the Funds or Registered Funds. Certain Clients, including Registered Funds, are subject to regulatory limitations on their ability to invest in the same issuer as other Clients. As a result, it is possible that a Client will not be able to participate in part or at all in an investment where other Clients are able to participate. Similarly, there could be certain circumstances in which Clients participate in the same transaction and, due to subsequent events, certain of such Clients (e.g., Registered Funds) cannot participate in followon investments in the same issuer. Additionally, the Firm and its affiliates have applied for an order (the "Co-Investment Order") from the Securities and Exchange Commission that would permit certain Registered Funds to co-invest in portfolio investments with certain other Clients. If granted, to the extent specific investment opportunities are appropriate for a Client and a Registered Fund subject to the order, the opportunity will also be subject to the conditions of the Co-Investment Order and other requirements, which could limit a Registered Fund’s ability to participate in a co-investment transaction. Reliance on the Co-Investment Order likely will be subject to certain terms and conditions, including, among others, internal notification of investment opportunities, independent determination by a Registered Fund’s portfolio managers as to the appropriateness of each applicable investment, enhanced recordkeeping and, where applicable, approval of the independent directors of the Registered Funds. There can be no assurance that the Co-Investment Order will facilitate the successful consummation of investment opportunities that a Registered Fund believes are available to Clients as a result of the Co-Investment Order. Investment
opportunities that would be subject to the Co-Investment Order would also be subject to additional policies and procedures as a result of the participation of Registered Funds, which could delay deal execution and adversely impact the ability of Clients to deploy capital. In addition, we have a number of Clients who are senior partners in asset management firms. Upon completion of our due diligence process, we may recommend to Clients an investment with one or more of such asset management firms as part of their overall investment program, including Twin Point Capital LLC, Bain Capital LLC, The Blackstone Group, Related Fund Management, The Davis Companies, Audax Management Company, LLC, Vida Ventures Advisors, LLC, Crestview Partners, L.P, Deerpath Capital Management, Lone Star Funds, Greenspring Associates, Gamma Real Estate, L Catterton, HPS Investment Partners, Audax Private Equity, Union Bancaire Privee, Clayton Dublier & Rice, LLC, Francisco Partners, Great Point Partners, AlpInvest Partners, Hunter Point Capital, Accel, Symbiotic Capital, HG Capital, Theleme Partners, Capula Global, Mesarete Capital, Nisa Investment Advisors. We also allocate to funds managed by those firms via the Funds and have recommended some of the funds managed by these firms to Other Clients for direct investment. Clients should note that one member of Partners Capital’s board of directors is affiliated with Apollo Global Management. One of our Partners, Richard Scarinci, has an indirect equity stakes in Magnetar Capital LLC, Leonard Green & Partners, Francisco Partners, New Mountain Capital, Rockpoint, Kohlberg Kravis Roberts & Co., Marathon Capital, Senator Investment Group, Solus Alternative Asset Management and GTCR. The fact that Partners Capital has Clients, shareholders, and Board members, who are employed by firms or are in an advisory capacity in which they make and recommend investments for the Funds and our Other Clients may create the appearance of a conflict of interest; however, Partners Capital makes investment decisions and recommendations based solely on its independent, objective due diligence and analysis and its belief that the investment is in the best interest of Clients. We believe it would be inappropriate to exclude or limit investments with asset management firms where a Client, director or shareholder of Partners Capital is employed, or otherwise affiliated, as doing so would limit the available investment universe and exclude firms that have proven over time to be, in our opinion, among the best in the industry. Other Conflicts of Interest Gifts and Entertainment Business entertainment and gifts accepted from Clients, prospective Clients, suppliers, service providers or Investment Managers are never solicited and are kept to minimal levels and must be reported to the Compliance Department. Service as a Director or Member of Investment Committee Employees who wish to serve as an officer or director of any public company, or of any organization where such duties might require involvement in investment decisions, or who wishes to serve on the investment committee of any organization, must obtain the prior consent from the Compliance Department, which shall be granted if such service shall not create a conflict with an employee’s fiduciary duty to Clients. Client Asset Manager Investments In several cases, Partners Capital’s Clients or other stakeholders operate or are otherwise employed by asset management businesses in which Partners Capital may choose to invest. In all cases, we will make it clear to investing clients that such a conflict exists. In cases where the conflict of interest is deemed to be material by the Partners Capital CIO or delegate, such funds will be
referred to an independent ‘External Conflicts Reviewer’. GA Transaction Although GA’s investment through the Transaction presents certain conflicts of interest, the day-today business and operations of Partners Capital are to be conducted and operated independently by Partners Capital, without any involvement from GA. In addition, GA and Partners Capital will not actively seek to participate in the same investment opportunities, nor, going forward, will Partners Capital recommend investments into GA-managed funds to its Clients. Although this limitation potentially limits the investment universe for Clients, given the limited exposure Clients have to the GA-managed funds, these restrictions are expected to have very limited impact to Clients, if any.
Item 12: Brokerage practices Conflicts of interest
Selecting Brokerage Firms Partners Capital, as the general partner, investment manager, or sub-adviser of the Funds or Registered Funds, or as adviser to Other Clients, recommends the limited partnerships, other pooled investment vehicles or entities, and separately managed accounts in which the assets of the Funds or of Other Clients are invested and withdrawn, and the amounts thereof. In making such investments, we may have the authority to negotiate the commission rates paid by the Funds or by Other Clients. We also may recommend brokers to Other Clients. The factors considered by Partners Capital in suggesting such brokers may include the experience, reputation, product offering, credit worthiness, customer service, and commission pricing of the broker. The advisor may recommend that clients establish brokerage accounts with various broker-dealers, primarily Schwab Institutional and Fidelity, to maintain custody of clients’ assets and to affect trades within their accounts. Partners Capital is independently owned and operated and is not affiliated with Schwab, Fidelity, or any other broker-dealer. Clients, including Registered Funds, that have trading restrictions and/or reporting obligations with respect to principal or agency transactions with particular brokers or dealers are required to notify us in writing of those affiliations and any associated trading restrictions for their accounts. We recommend broker dealers on the basis of, but not limited to, breadth of available investment options, low cost, and customer service. Schwab and Fidelity also make available to us products and services that benefit us but may not benefit any individual client accounts. Some of these products and services assist us in managing and administering clients’ accounts. These include software and other technology that provide access to client account data; facilitate trade execution; provide research, pricing information and other market data; facilitate payment of our fees from clients’ accounts; and assist with back-office functions, record-keeping and client reporting. Many of these services generally may be used to service all or a substantial number of accounts. While as a fiduciary, Partners Capital endeavors to act in our clients’ best interests, our recommendation that clients maintain assets in accounts at Schwab and other custodians may be based in part on the benefit to Partners Capital of the availability of some of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab or other custodians, which may create a potential conflict of interest. Partners Capital does not seek to obtain or accept inducements from Investment Managers or other service providers. We will negotiate discounts in fees and rebates of commissions to achieve the lowest possible cost for Clients, and such discounts or rebates will be passed directly back to the Clients concerned.
Directed Brokerage On occasion, Clients direct that their accounts be custodied at a particular broker and/or that all trading be executed by a specific broker. Generally, the Client agrees on a commission rate or fee with that broker. Commissions paid by Client accounts in these arrangements may be higher than those obtainable from other brokers, and Clients who use directed brokerage may not be able to participate in block trades, which may offer better execution (see below). Trade Aggregation It is Partners Capital’s policy to aggregate or block-trade transactions on behalf of Clients where it is permitted and allows for a more timely and efficient execution, or reduces overall commissions charged to Clients, provided that no Client is favored over another. In these instances, Clients will receive an average share price, and transaction costs will be allocated pro-rata based on the share allotment. Cross Trades Partners Capital may cause a Client to purchase or sell investments from or to another Client, sometimes referred to as a “cross trade”. Cross trades can provide a benefit to both Clients in the form of reduced market impact and reduced transaction costs. However, not all Clients are permitted to engage in cross trades. Cross trades also create conflicts of interests. We may execute a cross trade between Client accounts when we believe that trade is appropriate for all accounts involved and consistent with applicable law and Client guidelines. Partners Capital will not directly or indirectly receive any commission or other transaction based compensation (the receipt of customary advisory fees would not constitute indirect compensation) for effecting a cross trade. Partners Capital will also not effect a cross trade for any Fund where we may be deemed to own more than 25% of such Fund, unless such transaction complies with the requirements of our principal transactions policy, as described below. Principal and Agency Cross Transactions Section 206(3)-2 of the Advisers Act generally prohibits an investment adviser from knowingly purchasing any security from a Client, or selling any security to a Client out of its own inventory (a “principal transaction”), or effecting a transaction for a Client if the adviser acts as a broker on both sides of the transaction (an “agency cross transaction”). If the adviser knowingly engages in any of these activities, the adviser, before completion of the transaction, shall make a written disclosure to the client of the capacity in which the adviser is acting and must obtain the Client’s consent to such transaction. Partners Capital has established policies and procedures to comply with the requirements of the Advisers Act as they relate to principal transactions and agency cross transactions.
Item 14: Client referrals and other compensation Conflicts of interest
Client Referrals Partners Capital has entered into an agreement with a third party to solicit clients for the Firm. Typically, the third party will receive a portion of management fee and/or performance fee paid to Partners Capital with respect to such clients. A prospective client solicited by such a third party will be informed of any such arrangement.
Item 9: Disciplinary information
Legal and Disciplinary There have been no legal or disciplinary events related to Partners Capital or Partners Capital employees or any affiliate of Partners Capital.
Item 13: Review of accounts
Periodic Reviews The composition of the Clients’ portfolios is continually reviewed by members of the Firm’s senior management. The review includes an analysis of the strategies employed by Investment Managers, including diversification, exposure to market and other risks, and performance. We also have established several internal committees, including investment committees, that are responsible for our day-to-day operations. This includes entering into advisory agreements, establishing
investment advisory fees, selecting Investment Managers and developing new products and services. Regular Reports Clients receive quarterly reports from Partners Capital concerning the performance of the investment products on which we advise. These reports include information on each product, including inflows, outflows, ending balance and performance returns. However, statements from the Client’s custodian are the official statement of record. Clients are urged to compare the Partners Capital account statement with any account statement received from custodians. If any discrepancies are identified, or if there are any questions, Clients are encouraged to contact Partners Capital promptly. Trade Errors Trade errors may occur during the investment and trading process. Partners Capital has adopted written policies and procedures to address trade errors. Partners Capital evaluates trade errors on a case-by-case basis and seeks to resolve them expeditiously, in a fair and equitable manner. Not all trade errors are considered compensable. If an error results in a loss in a Client’s account, Partners Capital will evaluate the Firm’s failure to meet the applicable standard of care agreed upon with the Client to determine whether the error is compensable.
Item 15: Custody
Funds have arrangements with custodians as disclosed in the relevant offering and other Fund documents. Registered Funds are subject to the custody requirements of the 1940 Act. Account Statements Client assets for which Partners Capital is deemed to have “custody” within the meaning of Advisers Act Rule 206(4)-2 (the “Custody Rule”) are maintained with an independent qualified custodian and Clients should receive account statements from the qualified custodian at least quarterly. The statements received directly from the custodian are the official record of a client’s account. Partners Capital encourages its Clients to compare and verify the information provided on their statements with the information on the statements they receive from the account custodian. Financial Statements In the case of pooled investment vehicles subject to the Custody Rule, financial statements are prepared by an independent public accountant registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board (“PCAOB”) and distributed to all limited partners within 120 days of fiscal year-end in accordance with Rule 206(4)-2 under the Advisers Act. In the case of fund of funds, financial statements are required to be distributed to all limited partners within 180 days of fiscal year-end in accordance with the ABA Committee on Private
Investment Entities, SEC Staff Letter publicly available August 10, 2006.
Item 16: Investment discretion
Discretionary Authority for Trading Partners Capital may exercise discretionary authority over some Client accounts, as determined by the advisory agreements signed by Clients. This includes the discretion to determine the securities bought or sold, and the amounts of such investments, as determined in the investment advisory agreements with such Clients. The Client has the ability to place limitations and restrictions on investments made for his/her/its account. In the case of the Funds, Partners Capital exercises investment discretion. The Funds are subject to investment guidelines and/or restrictions which are described in their respective offering documents.
Item 17: Voting client securities
Partners Capital’s generally does not have authority to vote proxies on behalf of Clients. In such cases, Partners Capital will not take any action or render any advice with respect to voting of proxies solicited by or with respect to the issuers of securities in which assets of the Client may be invested from time to time. Proxies for securities may be provided to each Client by the account's respective broker/custodian. Any proxies received by Partners Capital will be immediately forwarded to the Client. In cases where Partners Capital has been delegated the authority to vote Client proxies, Partners Capital will seek to vote each proxy or similar corporate action in accordance with its fiduciary duty to its Clients, taking into consideration such factors as the Firm deems relevant in its sole discretion. Partners Capital’s proxy voting policy is designed to ensure that proxy votes are not improperly influenced by material conflicts of interests. Where consistent with such fiduciary duties and where not influenced by material conflicts of interests or where Partners Capital, acting reasonably, does not consider such an action would give rise to any meaningful risk of a material adverse effect for a Client, Partners Capital may irrevocably waive or delegate voting rights held by a Client in an investment (either with respect to a particular proxy or with respect to an investment or proposed investment more generally). Partners Capital also may choose to vote proxies for an issue or holding in the same proportion as the votes of other proxy holders (i.e., “mirror voting”). Registered Funds are subject to regulation that may in some circumstances require them to waive voting rights and/or mirror vote. In certain instances, Partners Capital may be unable to vote or may determine not to vote a proxy on behalf of one or more Clients. For example, a proxy vote might not be entered because the securities involved have been lent out under a Client’s securities lending program. In addition, proxies may not arrive in a timely fashion. We may determine that the cost of executing the proxy is excessive or may lack sufficient information to cast an appropriate vote. Partners Capital engages the services of a third-party vendor as its proxy agent. A copy of Partners Capital’s proxy voting policies and procedures are available to Clients upon request. Clients who have delegated the authority to vote proxies to Partners Capital may obtain copies of proxy records and information on how proxies were voted by contacting us at https://www.partnerscap.com/contact/.
Additionally, Partners Capital will not act or advise on any class action claims or legal proceedings pertaining to securities held or formerly held in accounts of Clients or former Clients.
Item 18: Financial information
Financial Condition Partners Capital does not require or solicit prepayment of fees. Partners Capital has never filed for bankruptcy and is not aware of any financial condition that is expected to affect its ability to manage Client accounts.
Appendix 1: Capacity Allocation Policy
Partners Capital advises separately managed accounts of individuals and institutions, serves as the general partner of privately offered domestic funds, as the investment manager to privately offered offshore funds (each a “Fund” and together the “Funds”), and as sub-adviser to investment companies registered under the Investment Company Act of 1940, as amended (the “1940 Act”) (each a “Registered Fund”, and together the “Registered Funds”), all together referred to as “Clients”. An important aspect of Partners Capital is working on our Clients’ behalf to gain access to what we believe are the best of breed asset managers in each asset class, in many cases using Clients’ attractiveness and influence to secure such access. In some cases, an investment opportunity will have limited capacity (by the amount of capital available and/or by the number of investors allowed). Partners Capital will seek to allocate limited capacity opportunities in a manner that is fair to all Clients and to mitigate conflicts of interest. All capacity should be allocated using this policy, unless explicitly approved by the Compliance Team, including the allocation of capacity created by the redemption of an existing investor in the fund (whether they are a Client of Partners Capital or not). As described below, the Capacity Allocation Tool, located in Omniscience, should be used as a ‘book-building’ tool and should be used to track demand even in cases where capacity is not constrained. 1.
The available capacity of an investment opportunity can be determined by the asset manager or Partners Capital. i. An asset manager may limit the amount of capital available to Clients’ at their discretion. ii. Partners Capital may determine that the size of an investment opportunity exceeds the amount that is appropriate for Clients. As such, Partners Capital in its sole discretion, may limit the available capacity for Clients, taking into account various criteria including but not limited to an investment opportunity’s risk parameters and operational factors.
2.
As advisors and/or discretionary managers to its Clients, Partners Capital first determines the suitability of any given investment for each Client in light of their strategy, risk profile, current allocations and ability to meet fund stated minimums.
3.
Partners Capital will also assess the Client’s ability to make the investment subscription deadlines based on the liquidity of their portfolio and their ability to agree the investment within the deadlines.
4.
Where it is deemed that the investment to be appropriate for a particular Client, Partners Capital will evaluate the appropriate size of the investment for the client independently of any possible access or capacity constraints. This evaluation will include an assessment of the minimum investment that would be relevant for the client’s portfolio (“Client Assessed Minimum”).
5.
Such investment recommendations will be aggregated across Clients and sent to the asset manager for consideration. When the total amount of the Client requested capacity is more than the available capacity (Limited Capacity), we will pro-rate the allocation across our Clients based on the individual requests. However, some asset managers may seek to use their own allocation process and criteria for accepting or rejecting individual investors or cutting back investors’ requested investment amounts. In these instances, we will defer to the asset manager’s process.
6.
If the asset manager makes their own cutbacks, we may attempt to influence the asset manager to cut back Clients’ allocation requests pro-rata in order to ensure a fair allocation to all Clients. However, there may be cases where this will not be acceptable to the manager, and we will defer to the manager’s process. In these cases, it must be recognized that we ultimately cannot over-ride an asset manager’s decision to take one Client over another or to cut back Clients in different
proportions. 7.
Where pro-ration would take a Client allocation below the fund stated minimum, at our sole discretion and to achieve the fairest outcome to Clients, we will re-allocate that below-minimum allocation to Clients with allocations at or above the fund minimum in proportion to their original capacity requests, in other words Clients below the fund stated minimum, starting with the Client furthest below the fund stated minimum, drop out of the process and the pro-ration is re-calculated until all Clients remaining in the process are above the fund stated minimum; or
8.
If the available capacity to be allocated is $3,000,000 or less, Partners Capital will allocate the capacity to Clients based on a random basis under the supervision of the Compliance Team. In this process, all Clients requesting capacity are assigned a random order. The first randomly prioritized client would be granted its entire capacity request (unless this was more than the total capacity available), then the second randomly prioritized Client would be granted its request from the remaining capacity to be allocated, and so on until all the capacity has been allocated. In cases where a randomly prioritized client’s request is greater than the remaining capacity available, Partners Capital would grant all the remaining capacity to that client, provided this allocation meets the fund stated minimum, or skip that client in favor of the next randomly selected Client if it was not an eligible subscription. Each random allocation process is independent of the others.
9.
If the available capacity to be allocated is one fifth of the aggregate demand or less, Partners Capital will allocate the capacity to Clients based on the random basis defined above, under the supervision of the Compliance Team.
10. Partners Capital Pooled Vehicles and Clients subject to a discretionary mandate will be subject to proration process and will be included along side every other Client. 11. We may recommend to certain Clients that they go direct to the asset manager and request capacity independent of Partners Capital when we deem that approach may maximize their potential allocation, and will not affect other Clients’ potential allocations. We may make such recommendations to individual Clients to pursue this approach in light of greater influence the Client may have directly with the asset manager. 12. Where capacity varies for onshore versus offshore alternatives from the same manager, this policy will be applied as though the two funds are completely independent of each other. 13. Where there is unused capacity remaining before the trade date but after the initial allocation process, remaining capacity will be available on a first-come, first-serve basis. 14. Secondaries Allocation Policy Notwithstanding the foregoing, Secondaries investment opportunities will be allocated in accordance with Partners Capital’s Secondaries Allocation Program. The Secondaries Allocation Program intends to allocate direct secondaries transactions in the following order of priority: • Participating Clients: Funds and Registered Funds with secondaries as a stated investment strategy (as detailed in their governing documents), as well as clients with separately managed accounts that opt-in to the Secondaries Allocation Program. • Standard Clients: All other Clients. In addition to the Funds and Registered Funds with secondaries as a stated investment strategy (as detailed in their governing documents), all other Clients will have the opportunity to opt into Tier 1 of the Secondaries Allocation Program at the onset of the advisory relationship with Partners Capital and at any point for so long as they remain a Client.
Separately managed accounts that elect to participate in the Secondaries Allocation Program will do so by executing an agreement that gives Partners Capital discretionary authority over a designated portion of their account to invest in direct secondaries opportunities alongside the relevant Funds and Registered Funds. The addendum will set forth terms including, but not limited to, (i) a target annual commitment to the Secondaries Allocation Program, (ii) per-deal target investment amounts, and (iii) any applicable investment restrictions. For the avoidance of doubt, Funds and Registered Funds with secondaries as a stated investment strategy are automatically included in Tier 1, and do not execute an agreement. Accordingly, they are not subject to minimum annual commitments or per deal investment amounts. When a suitable investment opportunity is identified, available capacity will be allocated first to Clients in Tier 1, and thereafter to Clients in Tier 2 if there is capacity remaining. Where the demand of Clients exceeds the available capacity within a given tier, allocations will be made pro rata based on each Clients’ demands, subject to any applicable investment restrictions or client minimums. If there is capacity remaining after all of Partners Capital client demand has been filled, the Secondaries Team may reach out to third parties at their discretion to fill any remaining capacity. 15. Partners Capital partners, employees and relatives of employees (defined as spouses, parents and children) are deemed to be an insider for the purposes of scarce capacity allocation and in certain circumstances may be excluded from the allocation process. The main situation may arise when a) an insider applies by the deadline for an allocation to a manager with constrained capacity, b) where Partners Capital client demand exceeds the capacity granted by the manager and c) Partners Capital determines the allocations to clients per our Constrained Capacity policy. In this situation, the insider would be excluded from the process to ensure clients receive the fullest allocation possible. 16. Registered Investment Companies: Partners Capital has adopted a Section 17(d) and Rule 17d-1 Policies and Procedures which is maintained under separate cover. The Section 17(d) and Rule 17d-1 Policy applies when Partners Capital and/or affiliated persons investment alongside an investment company registered under the Investment Company Act of 1940. 17. This policy will be disclosed to each client as part of our account opening process and in the firm’s Form ADV Part 2.
Appendix 2: Partners Capital Client Privacy Policy
Partners Capital Investment Group, LLP (“Partners Capital,” “we,” “our,” or “us”) provides this Privacy Policy (“Policy”) to explain our practices regarding the collection and use of Personal Information about our clients and prospective clients. Additional policies may apply in other contexts and to other relationships you may have with us. This Notice provides disclosures for current and prospective Private Clients who engage with us primarily for personal, family, or household purposes. In the event of a conflict between any other policy, statement, or notice and this Privacy Notice for Private Clients, this Notice will prevail as to Nonpublic Personal Information as defined under the Gramm-Leach Bliley Act (“GLBA”). Any terms defined in the GLBA have the same meaning when used in this Notice. If you are a Californian resident who interacts with us as a representative of a current, prospective, or former institutional client (collectively, “Client Representatives”), please see our California Privacy Notice available at https://partners-cap.com/privacy-policy/ Facts
What does Partners Capital Investment Group, LLP (“Partners Capital”) do with your personal information?
Why?
Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?
The types of personal information we collect and share depend on the product or service you have with us. This information can include: • Social security number • Assets • Risk tolerance • Income • Wire transfer instructions • Transaction history When you are no longer our customer, we continue to share information about you as described in this notice.
How?
All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Partners Capital chooses to share; and whether you can limit this sharing.
Reasons we can share your personal information For our everyday business purposes - such as to process your transactions, maintain your accounts(s) or respond to court orders and legal investigations. For our marketing purposes - to offer our products and services to you
Does Partners Capital Share?
Can you limit this sharing?
Yes
No
For joint marketing with other financial companies
No
For our affiliates' everyday business purposes - information about your transactions and experiences
We don’t shar We don’t shar
Yes
No
No
For our affiliates to market to you
Yes
Yes
For non-affiliates to market to you
No
We don’t share
To limit our sharing
• Call 617-292-2570 • Visit: https://www.partners-cap.com/contact/ Please note: If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.
Questions?
Visit: https://www.partners-cap.com/contact/
Who we are Who is providing this notice?
Partners Capital Investment Group, LLP and affiliates, including privately offered pooled investment vehicles.
Subsidiaries and ownership
Parent company (GLEIF)
Subsidiaries (GLEIF)
Ownership links from GLEIF, the Global Legal Entity Identifier Foundation (CC0); each one cites its LEI record.
Timeline
Filings
24 filings to the SEC since October 2021: 24 other. The latest 20:
- Aug 31, 2026N-PX EDGAR
- Aug 13, 202613F-HR EDGAR
- May 12, 202613F-HR EDGAR
- Feb 13, 202613F-HR EDGAR
- Oct 31, 202513F-HR EDGAR
- Aug 28, 2025N-PX EDGAR
- Aug 14, 202513F-HR EDGAR
- May 14, 202513F-HR EDGAR
- Jan 31, 202513F-HR EDGAR
- Nov 5, 202413F-HR EDGAR
- Aug 20, 2024N-PX EDGAR
- Aug 13, 202413F-HR EDGAR
- May 14, 202413F-HR EDGAR
- Feb 12, 202413F-HR EDGAR
- Nov 14, 202313F-HR EDGAR
- Aug 14, 202313F-HR EDGAR
- May 15, 202313F-HR EDGAR
- Feb 14, 202313F-HR EDGAR
- Nov 14, 202213F-HR/A EDGAR
- Nov 14, 202213F-HR EDGAR
The 24 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
PARTNERS CAPITAL INVESTMENT GROUP, LLP has told the SEC it owns more than 5% of 1 company, latest first (Schedules 13D and 13G).
- ARES STRATEGIC INCOME FUNDSCHEDULE 13G/A Feb 6, 2024 to Feb 14, 20256
Sources
The numbers on this page point here. Each one links to the record it came from.
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