Private company
SAMLYN CAPITAL, LLC
Limited liability company registered in the United States, active since 2006. Summary from the record
Last updated Oct 21, 2026.
Overview
Corporate structure
SAMLYN CAPITAL, LLC is part of a group headed by Samlyn, LP. 19 entities, 2 countries on record. Switch between the flow chart and the network, and select any entity to see its details.
Major holders of SAMLYN CAPITAL, LLC
- Samlyn Gp, LLC Owns control (general partner, trustee or manager) of Samlyn, LP, since 01/2016 (Form ADV)
- Robert Scott Pohly Owns 75% or more of Samlyn, LP, since 01/2016 (Form ADV)
- Samlyn, LP
- SAMLYN CAPITAL, LLC New York, New York, United States
- Applied Minerals, Inc. Stake · Eureka, Utah
- Climb Bio, Inc. Stake · Wellesley Hills, Massachusetts
- Corvus Pharmaceuticals, Inc. Stake · Burlingame, California, United States
- Glass Houses Acquisition Corp. Stake · Dallas, Texas
- Inozyme Pharma, Inc. Stake · Boston, Massachusetts
- Merus N.V. Stake · P7
- Nektar Therapeutics Stake · San Francisco, California, United States
- Perella Weinberg Partners Stake · New York, New York
- PureCycle Technologies, Inc. Stake · Orlando, Florida
- Satsuma Pharmaceuticals, Inc. Stake · South San Francisco, California, United States
- Sculptor Capital Management Stake · New York, New York, United States
- STR Sub Inc. Stake · Denver, Colorado
- Vinci Compass Investments Ltd. Stake · George Town, Cayman Islands
- SAMLYN LONG ALPHA MASTER FUND, LTD. Fund · New York, New York, United States
- Samlyn Net Neutral Master Fund, Ltd. Fund · New York, New York, United States
- SAMLYN OFFSHORE MASTER FUND, LTD. Fund · New York, New York, United States
- Samlyn Portable Alpha, Ltd. Fund · New York, New York, United States
- SAMLYN CAPITAL, LLC New York, New York, United States
Built from parent and subsidiary links from GLEIF, the Global Legal Entity Identifier Foundation (CC0); major holders from Schedules 13D and 13G; stakes of 5% or more it reported on Schedules 13D and 13G (13 companies); owners and owned firms from Form ADV, the registration investment advisers file with the SEC. Each entity in the chart links to its source.
Investment adviser
SAMLYN CAPITAL, LLC is registered with the SEC as an investment adviser. This is what it reports on Form ADV, the registration every adviser files and keeps current.
- Assets it manages$9.7B3 11 accounts, all with discretion
- Employees33 12 in investment advice or research
- ClientsPooled investment vehicles (other than investment companies and: 10 ($9.6B)
- 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); Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investment vehicles)
- Holds client assetsYes: cash and securities
- RegistrationSEC 801-74035, CRD 158296 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).
- SAMLYN, LPowns 75% or more, since 01/2016
- SAMLYN GP, LLCowns general partner, trustee or manager of SAMLYN, LP, since 01/2016
- Robert Scott Pohlyowns 75% or more of SAMLYN, LP, since 01/2016
In its own words: the client brochure
Form ADV Part 2A, the plain-English document an adviser must give its clients, quoted as filed 3/31/2026.4 It covers the firm’s services, fees, investment strategies and their risks, and its conflicts of interest.
Item 4: Advisory business Services
Samlyn is a New York-based investment management firm that commenced operations in 2006 and has been registered with the SEC since March 30, 2012. Samlyn, LP, a Delaware limited partnership, is the sole owner of Samlyn. Robert Pohly indirectly principally owns and controls Samlyn through his ownership interests in Samlyn, LP and its general partner, Samlyn GP, LLC, a Delaware limited liability company for which Mr. Pohly serves as the managing member. Samlyn provides advisory services on a discretionary basis to: (i) private pooled investment vehicles intended for sophisticated investors (each, a “Fund” and collectively, the “Funds”); and (ii) a separately managed account (the “SMA”, and together with the Funds, the “Clients”). Samlyn currently utilizes four distinct investment strategies on behalf of the Funds: (i) a long/short investment strategy for certain Funds (collectively, the “Flagship Funds”); (ii) a predominantly “long-only” investment strategy for certain Funds (collectively, the “Long Alpha Funds”); (iii) a long/short, market-neutral investment strategy for certain Funds (collectively, the “Net Neutral Funds”); and (iv) a portable alpha investment strategy for a Fund that invests its assets in (A) shares of a Net Neutral Fund, and (B) shares of an exchange-traded fund (“ETF”) and options thereon (the “Portable Alpha Fund”), in each case, as further described in the relevant Fund’s offering memorandum. The SMA is managed to make large, concentrated investments in single stock positions that are typically also held in the portfolio of one or more of the Funds. Samlyn generally has broad and flexible investment authority with respect to its management of the Funds’ assets. Samlyn provides investment advisory services to the Funds with respect to a wide range of investments, although the Funds primarily invest (directly or indirectly) in equity securities issued by U.S. and international companies. In respect of the SMA, Samlyn makes investment recommendations to the holder of the SMA in accordance with the terms of Samlyn’s investment management agreement with the SMA (the “SMA IMA”). Upon receiving the prior written consent of the SMA holder to pursue a particular investment recommendation, Samlyn has discretionary authority to determine the amount of the relevant issuer’s securities to be purchased or sold and the timing of those transactions, subject in each case to compliance with the investment guidelines, restrictions and other parameters set forth in the SMA IMA. The SMA’s assets are also primarily invested in equity securities issued by U.S. and/or international companies. Samlyn generally does not: (i) tailor its advisory services to the individual needs of investors in the Funds (“Fund Investors”); or (ii) accept Fund Investor-imposed investment restrictions. While Samlyn does not tailor its advisory services to the individual needs of the holder of the SMA, all investment decisions are pre-approved by the SMA holder. If Samlyn manages additional separately managed accounts in the future, such accounts will be subject to investment objectives, guidelines and restrictions, fee arrangements and other terms individually negotiated with such separate account holders. Any such additional separately managed account relationship would generally involve a significant minimum account size. As of December 31, 2025, Samlyn had $9,684,832,071 of regulatory assets under management, all of which it managed on a discretionary basis.
Item 5: Fees and compensation Fees
Asset-Based Compensation Samlyn charges each Fund an investment management fee based on the value of the Funds’ assets under management (collectively, the “Management Fees”). The Management Fees range from 0.80% to 2.0% (per annum) of the Funds’ respective net assets; provided, however, that the portion of the Portable Alpha Fund’s net assets that are invested in (A) shares of a Net Neutral Fund is charged the Management Fee solely at the Net Neutral Fund level, and (B) shares of an ETF and options thereon are charged a Management Fee at a rate equal to 0.10% per annum. In addition, a particular series of interests and subclass of shares in the Long Alpha Funds do not pay Management Fees. The Management Fees are: (i) charged quarterly in advance on the first business day of each calendar quarter; (ii) prorated for any period that is less than a full quarter; (iii) prorated for any capital contributions to a Fund during a quarter; and (iv) prorated and refunded in the event of any withdrawals or redemptions, as applicable, from a Fund during a quarter based on the number of days remaining in the quarter. For more detailed information and a complete description of the Management Fees paid to Samlyn by Fund Investors in a particular Fund, refer to the relevant Fund’s offering memorandum. The rates of the Management Fees paid to Samlyn are generally non-negotiable; however, Samlyn has waived or reduced the Management Fees for Fund Investors that are members, principals, employees or affiliates of Samlyn, and for relatives of such persons. The Management Fees are generally deducted from each Fund account by the Funds’ administrator upon Samlyn’s proper instructions. Performance-Based Compensation Samlyn (or an affiliate) is entitled to receive performance-based compensation from certain of the Funds, which is compensation that is based on a share of capital gains on or capital appreciation of the assets of a Fund. This compensation may be paid or allocated to Samlyn (or an affiliate) and ranges from 15% to 30% of the net profits (including net unrealized gains) allocated to a Fund Investor holding a particular series of interests or sub-class of shares subject to performance-based compensation within a Fund, subject to a loss carryforward provision or a hurdle carryforward provision in the case of the Long Alpha Funds, provided, however, that a particular series of interests and sub-class of shares in the Long Alpha Funds do not pay performance-based compensation. Further, receipt of performance-based compensation is subject to a noncumulative hurdle in respect of those series of interests and sub-classes in the Long Alpha Funds that pay performance-based compensation. For more detailed information and a complete description of the performance-based compensation, if any, paid to Samlyn (or an affiliate) by Fund Investors in a particular Fund, refer to the relevant Fund’s offering memorandum. The rates of the performance-based compensation paid to Samlyn (or an affiliate) are generally non-negotiable; however, Samlyn has waived or reduced the amount of performance-based compensation for Fund Investors that are members, principals, employees or affiliates of Samlyn, and for relatives of such persons. Samlyn is entitled to receive performance-based compensation from the SMA on such terms as negotiated and agreed to by Samlyn and the holder of the SMA. Expenses In addition to paying Management Fees and performance-based compensation (if applicable), the Funds bear other expenses in accordance with their respective governing documents, which expenses may include: Fund legal, auditing, accounting, tax preparation and other tax-related expenses (including preparation costs of financial statements, tax returns and reports to Fund Investors), consulting and other professional expenses; administration expenses (including administrator fees and expenses); the Funds’ pro rata share of Fund-related insurance costs (including directors’ and officers’ insurance, errors and omissions insurance, fidelity insurance, cybersecurity insurance and other similar policies); research-related expenses (including, without limitation, news and quotation equipment and services and artificial intelligence-related
subscriptions for Samlyn’s investment personnel); investment-related expenses (i.e., expenses other than investment-related travel expenses that, in Samlyn’s discretion, are related to the investment of the Funds’ assets, whether or not such investments are consummated), such as commissions, interest on margin accounts and other indebtedness, investment-related legal costs; the cost of portfolio exposure and performance reporting, risk management and trade order management expenses; fees of third party valuation agents; cloud-based data storage expenses; certain compliance (including all fees and expenses incurred in connection with the Fund’s registration with the Cayman Islands Monetary Authority and fees and expenses of anti-money laundering officers appointed in accordance with Cayman Islands law, as applicable) and reporting expenses and expenses related to regulatory filings which are made with respect to the relevant Fund’s assets (including, without limitation, Form PF (and associated filing fees), Section 13, Section 16 and non-U.S. position reporting filings); fees paid to the Fund’s board of directors (as applicable); proxy and securities class action advisory firms; the Fund’s organizational expenses; the Fund’s pro rata share of the expenses of any master fund through which it invests (which expenses may include expenses of the Fund and other feeder vehicles that invest in that same master fund); custodial fees; bank service fees and other expenses related to the purchase, sale or transmittal of the Fund’s assets and other expenses associated with the operation of the Funds, as determined by Samlyn. Fund assets may also be invested in money market mutual funds, ETFs or other registered investment companies from time to time. In such cases, the Funds will also bear their pro rata share of the investment management fees and other expenses of such investment entities, which are in addition to the compensation paid to Samlyn. Each Fund Investor in the Portable Alpha Fund also bears the Portable Alpha Fund’s pro rata share of the expenses of a Net Neutral Fund in respect of the Portable Alpha Fund’s investment therein (including Management Fees paid by the Net Neutral Fund to Samlyn and incentive allocations made by the Net Neutral Fund to an affiliate of Samlyn). The SMA pays or reimburses Samlyn for all expenses related to the SMA, including: legal, auditing, accounting, tax preparation and other tax-related expenses (including preparation costs of financial statements, tax returns and reports to investors therein); consulting and other professional expenses; administration expenses (including administrator fees and expenses); SMA-related insurance costs (including directors’ and officers’ insurance, errors and omissions insurance, fidelity insurance and other similar policies); research-related expenses (including, without limitation, news and quotation equipment and services); investment-related expenses (i.e., expenses other than investment-related travel expenses that, in Samlyn’s discretion, are related to the investment of the SMA’s assets, whether or not such investments are consummated) such as commissions, interest on margin accounts and other indebtedness, investment-related legal costs; the cost of portfolio exposure and performance reporting, risk management and trade order management expenses; certain compliance and reporting expenses and expenses related to regulatory filings which are made with respect to the assets of the SMA (including, without limitation, Section 13, Section 16 and non-U.S. position reporting filings); proxy and securities class action advisory firms; custodial fees, bank service fees and other expenses related to the purchase, sale or transmittal of the SMA’s assets. The allocation of expenses by Samlyn between it and any Client and among Clients represents a conflict of interest for Samlyn. To address this conflict, Samlyn has adopted and implements policies and procedures for the allocation of expenses. Samlyn allocates expenses to each Client in accordance with the Client’s arrangements with Samlyn (including applicable investment management agreements, limited partnership agreements or other organizational documents, as well as applicable Client disclosures). Samlyn seeks to allocate shared expenses for products and services benefitting Samlyn and a Client that are not covered in the Client’s arrangements in a fair and reasonable manner.
Item 8: Methods of analysis, investment strategies and risk of loss Investment strategies and risks
Samlyn utilizes a variety of investment strategies and has broad discretion in making investments for the Funds. The investment strategies summarized below are set forth in detail in the governing documents for each Fund. In respect of the SMA, Samlyn makes investment recommendations to the holder of the SMA in accordance with the terms of the SMA IMA. Upon receiving the prior written consent of the SMA holder to pursue a particular investment recommendation, Samlyn has discretionary authority to determine the amount of the relevant issuer’s securities to be purchased or sold and the timing of those transactions, subject in each case to compliance with the investment guidelines, restrictions and other parameters set forth in the SMA IMA. Methods of Analysis In general, Samlyn draws on numerous resources to generate ideas, including public financial statements, industry conferences, traditional Wall Street research and industry contacts, consultants and bankers. Research typically includes reviewing the prospectus of the company and conducting an analysis of a company’s reported earnings as well as financial statements and SEC filings. Samlyn also develops and closely reviews internal valuations for potential investment targets, including revenues, margins, operating income, cash flow and earnings per share. Samlyn also uses channel checks, visits with company management, valuation assessments and financial and other modeling as analysis tools. Investment Strategy Overview in respect of the Flagship Funds. In respect of the Flagship Funds, Samlyn seeks to generate superior risk-adjusted returns over time by employing a long/short investment strategy focused primarily on investing in global equity securities. The investment strategy does not place any restriction on Samlyn’s ability to invest any portion of the Flagship Funds’ assets in a single industry, sector, market capitalization or geographic area. While the U.S. and offshore Flagship Funds employ substantially the same investment strategies, their respective portfolios will at times trade differently from each other (e.g., one portfolio may hold a position that the other portfolio does not hold or a position may be weighted differently in the respective portfolios) because of, among other things, tax considerations. Overview in respect of the Long Alpha Funds. In respect of the Long Alpha Funds, Samlyn seeks to generate returns that are superior to the returns of the MSCI World Index over the long term by employing a “long-only” investment strategy that covers a wide universe of securities in search of superior risk-reward opportunities. However, the Long Alpha Funds are not managed to mirror the geographic or industry composition of any index and the investment strategy does not place any restriction on Samlyn’s ability to invest any portion of the Long Alpha Funds’ assets in a single industry, sector, market capitalization or geographic area. Further, while the Long Alpha Funds’ portfolios generally mirror the long positions held by the Flagship Funds, their respective long portfolios will at times trade differently from each other (e.g., one portfolio may hold one or more long positions that the other portfolio does not hold or a position may be weighted differently among the respective portfolios) because of, among other things, differences in their respective strategies, trading restrictions, liquidity profiles, cash flows, the amount of capital available for investment, preservation of capital for other investment opportunities, current portfolio compositions and risk management considerations, tax considerations, the need for cash to satisfy expenses and/or other considerations or parameters. Accordingly, there may be times where the Long Alpha Funds do not establish a position that is in the portfolio of one or more of the other Clients, or maintain or increase a position that is being covered or reduced in the portfolio of one or more of the other Clients. There may be instances where the Long Alpha Funds have short exposure to issuers by purchasing put options or writing call options for purposes of hedging existing long positions with respect to those issuers.
Further, although it is not a significant component of the Long Alpha Funds’ investment strategy, the Long Alpha Funds may from time to time, in Samlyn’s sole discretion, engage in short selling in order to offset long positions in arbitrage transactions in circumstances in which Samlyn determines that investments in two separate issuers constitute a single long position. However, other than as contemplated by the preceding sentence, it is not anticipated that the Long Alpha Funds will hold any net short positions with respect to any issuers. In addition, the Long Alpha Funds from time to time engage in foreign currency hedging activities, such as entering into forward contracts or other derivative instruments, or by directly purchasing foreign currencies. Overview in respect of the Net Neutral Funds. In respect of the Net Neutral Funds, Samlyn seeks to generate superior risk-adjusted returns over time by employing a market-neutral investment strategy that involves making long and short investments primarily in global equity securities. The investment strategy does not place any restriction on Samlyn’s ability to invest any portion of the Net Neutral Funds’ assets in a single industry, sector, market capitalization or geographic area. While the Net Neutral Funds’ portfolios generally mirror both the long and short positions held by the Flagship Funds, as the Net Neutral Funds’ portfolios are managed to be market-neutral, the positions held by the Net Neutral Funds are weighted differently than the same positions held in the respective portfolios of the Flagship Funds to: (i) neutralize the Net Neutral Funds’ net exposures; and (ii) achieve higher gross exposures for the Net Neutral Funds through the use of increased leverage. The respective portfolios of the Net Neutral Funds and one or more of the other Clients will at times trade differently from each other because of, among other things, differences in their respective strategies, trading restrictions, liquidity profiles, cash flows, the amount of capital available for investment, preservation of capital for other investment opportunities, current portfolio compositions and risk management considerations, tax considerations, the need for cash to satisfy expenses and/or other considerations or parameters. Accordingly, there may be times where the Net Neutral Funds do not establish a position that is in the portfolio of one or more of the other Clients, or maintain or increase a position that is being covered or reduced in the portfolio of one or more of the other Clients. The Net Neutral Funds’ portfolio’s gross exposure typically ranges from 300% to 400%. The Net Neutral Funds’ portfolios maintain short basket hedges that are typically adjusted by Samlyn on a daily basis in order to neutralize net exposure resulting from daily trading activity and market movements. Short index and customized basket hedges may also be used in an effort to mitigate certain sector and factor exposures, as well as to address macro risks, in each case, as Samlyn determines to be appropriate in its discretion. The short basket hedge may also be used to offset net exposure resulting from pair-trades and mergerarbitrage transactions. The Net Neutral Funds’ short basket hedges typically consist of broad-based stock indices, sector indices and factor baskets and generally do not exceed 15% of the Net Neutral Funds’ equity. The Net Neutral Funds’ long and short ratios are generally maintained as long as the Net Neutral Funds’ total gross exposure is between its typical range of 300% to 400% of equity and the short basket hedge exposure is typically between 5% to 15% of equity. In the event the total gross exposure and short basket hedge exposure fall outside the aforementioned ranges, Samlyn will typically rebalance the Net Neutral Funds’ portfolios to restore the target levels. Overview in respect of the Portable Alpha Fund. In respect of the Portable Alpha Fund, Samlyn seeks to generate superior risk-adjusted returns over time by investing a portion of the Portable Alpha Fund’s net assets based on a specified target ratio (the “Target Ratio”) in: (i) shares of a Net Neutral Fund; and (ii) shares of an ETF and options thereon. Samlyn rebalances the Portable Alpha Fund’s portfolio as of the end of any month in which the Portable Alpha Fund’s portfolio has deviated from the then current Target Ratio by more than 5% as a result of the relative performance of the Portable Alpha Fund’s investment in shares of a Net Neutral Fund vis-à-vis the Portable Alpha Fund’s investment in shares of an ETF and its other direct investments. Samlyn may also rebalance the Portable Alpha Fund’s portfolio at such other times as it determines in its sole discretion in seeking to maintain the Target Ratio. The Target Ratio may only be changed with the mutual written consent of Samlyn and the holders of a majority-in-interest of the Portable Alpha Fund’s shares, and any such newly-adopted Target Ratio will become effective as of the beginning
of the first calendar quarter that is at least 45 days after the relevant consent date, unless Samlyn agrees to adopt and implement such new Target Ratio on an earlier date. The investment objective and strategy of the Net Neutral Fund through which a portion of the Portable Alpha Fund’s net assets are invested are summarized above and fully described in the Net Neutral Funds’ offering memoranda. Overview in respect of the SMA. In respect of the SMA, Samlyn recommends to the holder of the SMA specific investment opportunities that it believes will generate superior returns over time. In that regard, (i) the SMA is managed to make large, concentrated investments in single stock positions that are typically also held in the portfolio of one or more of the Funds and (ii) the SMA’s assets are primarily invested in equity securities issued by U.S. and/or international companies. Fundamental Analysis. Samlyn engages in a fundamental analysis investment strategy wherein Samlyn attempts to invest Client assets in securities Samlyn believes are undervalued by the market. Relative Value. In respect of the Flagship Funds and the Net Neutral Funds, Samlyn pursues relative value strategies by causing those Clients to take long positions in securities believed to be undervalued and short positions in securities believed to be overvalued. Short Selling. Samlyn engages in short selling for certain of its Clients. In a short sale transaction, a Client sells a security it does not own in anticipation that the market price of that security will decline. Samlyn engages in short selling for certain of its Clients: (i) as a form of hedging to offset potential declines in long positions in similar securities; (ii) in order to maintain flexibility; and/or (iii) for profit. Option Trading. Samlyn engages in tactical option trading from time to time on behalf of its Clients as a broader part of its investment strategies. Options are investments whose ultimate value is determined from the value of the underlying investment. Hedging. Samlyn may utilize a variety of financial instruments such as derivatives, options, swaps, swaptions or any combination thereof (whether or not exchange traded), caps and floors, futures and forward contracts for speculative and risk management purposes for certain of its Clients. There can be no assurances that a particular hedge is appropriate, or that a certain risk is measured properly. Further, while Samlyn may cause a Client to enter into hedging transactions to seek to reduce risk, such transactions may result in poorer overall performance and increased (rather than reduced) risk for the Client’s investment portfolio than if Samlyn did not engage in any such hedging transactions. Moreover, the Clients’ investment portfolios will always be exposed to certain risks that cannot be hedged, such as credit risk (relating both to particular securities and counterparties). In addition, Samlyn may choose not to enter into hedging transactions on behalf of a Client with respect to some or all of its portfolio positions. Leverage. Samlyn's investment program utilizes leverage, which includes the borrowing of funds from brokerage firms, banks and other institutions in order to be able to increase the amount of capital available for investments. Arbitrage Transactions. Samlyn may engage in one or more types of arbitrage strategies for certain of its Clients. Arbitrage strategies attempt to take advantage of perceived price discrepancies of identical or similar financial instruments, on different markets or in other forms. Samlyn engages in the following arbitrage strategies for certain of its Clients: (i) event-driven arbitrage; (ii) merger arbitrage; and/or (iii) capital structure arbitrage. Material Risks Relating to Investment Strategy Investing in securities involves significant risks, including the risk of loss of some or all of an investment. Prospective Fund Investors should speak with their legal, tax and financial advisors prior to making an investment with Samlyn. The following summary identifies certain material risks related to Samlyn’s
Item 7: Types of clients
As previously described in Item 4, Samlyn’s Clients currently consist of the Funds and the SMA. With respect to the Funds, any initial and additional subscription minimums are disclosed in the relevant offering documents for each Fund. Minimum investment amounts have been, and may in the future be, reduced in the sole discretion of Samlyn (or by such Fund, as applicable). Although Samlyn does not maintain a specific minimum dollar value of assets or other conditions for opening a separately managed account, any such additional account relationship would generally involve a significant minimum account size.
Item 6: Performance-based fees and side-by-side management Conflicts of interest
Samlyn (or an affiliate) is entitled to receive performance-based compensation from certain of its Clients. In addition, Samlyn’s investment personnel are typically compensated on a basis that includes a performance-based component. Such performance-based compensation may create an incentive for Samlyn to make investments on behalf of the applicable Clients that are riskier or more speculative than would be the case in the absence of such performance-based compensation arrangements. In addition, since the performance-based compensation received by Samlyn (or an affiliate) from certain of the Funds is calculated on a basis that includes unrealized appreciation of those Funds’ assets, such compensation may be greater than if it were based solely on realized gains. As a result, Samlyn may receive performance-based compensation from a Fund reflecting unrealized gains at the end of a year or upon a Fund Investor’s withdrawal or redemption from a Fund, as applicable, that are not subsequently realized by the Funds. Samlyn is involved with the valuation of securities held by the Funds, which in turn determines the calculation of the Management Fees and the performance-based compensation it receives from those Funds. This creates an incentive for Samlyn to increase the value of the Funds’ assets during the valuation process. Samlyn addresses this conflict of interest by using readily available market quotations (and a third party valuation agent for positions where there is no readily available market price) and other commonly used and recognized valuation methods in making valuation determinations in consultation with the Funds’ third party administrator. Since Samlyn and its investment personnel manage multiple Client accounts, including accounts with different fee arrangements, a potential conflict of interest exists for one Client account to be favored over another Client account. In that regard, Samlyn and its investment personnel have a greater incentive to favor Client accounts that pay Samlyn (and indirectly its investment personnel) higher performance-based compensation and Management Fees, or in which Samlyn’s personnel have more significant investments in their respective personal capacities. Accordingly, Samlyn has adopted and implements policies and procedures intended to address conflicts of interest relating to the management of multiple Client accounts. In particular, Samlyn reviews investment decisions for its Clients on a regular basis in order to ensure that Clients with substantially similar investment objectives are treated fairly. The performance of similarly managed portfolios is also regularly compared to determine whether there are any unexplained significant discrepancies. In addition, Samlyn has implemented an investment allocation policy and Samlyn regularly reviews its trade allocations to ensure they are made in a manner that is fair to all Clients (as described in Item 12). In that regard, while the U.S. and offshore Flagship Funds employ substantially the same investment strategies, their respective portfolios will at times trade differently from each other (e.g., one portfolio may hold a position that the other portfolio does not hold or a position may be weighted differently in the respective portfolios) because of, among other things, tax considerations. It should also be noted that, while the Long Alpha Funds’ portfolios generally mirror the long positions held by the Flagship Funds, their respective long portfolios will at times trade differently from each other (e.g., one portfolio may hold one or more long positions that the other portfolio does not hold, or one or more positions may be weighted differently among the respective portfolios) because of, among other things, differences in their respective strategies, trading restrictions, liquidity profiles, cash flows, the amount of capital available for investment, preservation of capital for other investment opportunities, current portfolio compositions and risk management considerations, tax considerations, the need for cash to satisfy expenses and/or other considerations or parameters. Accordingly, there may be times where the Long Alpha Funds do not establish a position that is in the portfolio of one or more of the other Clients, or
maintain or increase a position that is being covered or reduced in the portfolio of one or more of the other Clients. Finally, it should be noted that, while the Net Neutral Funds’ portfolios generally mirror both the long and short positions held by the Flagship Funds, as the Net Neutral Funds’ portfolios are managed to be marketneutral, the positions held by the Net Neutral Funds are weighted differently than the same positions held in the respective portfolios of the Flagship Funds to: (i) neutralize the Net Neutral Funds’ net exposures; and (ii) achieve higher gross exposures for the Net Neutral Funds through the use of increased leverage. The respective portfolios of the Net Neutral Funds and one or more of the other Clients will at times trade differently from each other because of, among other things, differences in their respective strategies, trading restrictions, liquidity profiles, cash flows, the amount of capital available for investment, preservation of capital for other investment opportunities, current portfolio compositions and risk management considerations, tax considerations, the need for cash to satisfy expenses and/or other considerations or parameters. Accordingly, there may be times where the Net Neutral Funds do not establish a position that is in the portfolio of one or more of the other Clients, or maintain or increase a position that is being covered or reduced in the portfolio of one or more of the other Clients. As previously described in Item 4, the SMA is managed to make large, concentrated investments in one or more single stock positions that are typically also held in the portfolio of one or more of the Funds.
Item 10: Other financial industry activities and affiliations Conflicts of interest
This Item is inapplicable.
Item 11: Code of ethics, participation or interest in client transactions and personal trading Conflicts of interest
Samlyn has adopted and implements a Code of Ethics (the “Code”) that sets forth Samlyn’s standard of business conduct that takes into account Samlyn’s status as a fiduciary. The Code generally requires Samlyn and its “Access Persons” to place the interests of Clients and Fund Investors above their own interests and the interests of Samlyn. Among other things, the Code requires Access Persons to comply with applicable federal securities laws. Further, Access Persons are required to promptly bring violations of the Code or applicable securities laws to the attention of Michael Barry, Samlyn’s General Counsel and Chief Compliance Officer (the “Chief Compliance Officer”). All Access Persons are provided with a copy of the Code and are required to acknowledge receipt of the Code upon hire and on at least an annual basis thereafter. Access Persons include, generally, any partner, officer or director of Samlyn and any employee or other supervised person of Samlyn who, in relation to the Clients: (i) has access to non-public information regarding any purchase or sale of securities or non-public information regarding securities holdings; or (ii) is involved in making securities recommendations, executing securities recommendations or has access to such recommendations that are non-public. The Code also sets forth certain reporting and preclearance requirements with respect to personal trading by Access Persons. Access Persons are prohibited from engaging in transactions for personal accounts other than: (i) purchases or sales that are non-volitional on the part of the Access Person such as purchases that are made pursuant to a merger, tender offer or exercise of rights; (ii) purchases or sales pursuant to an automatic investment plan; (iii) purchases or sales of securities that are not “reportable securities” (i.e., direct obligations of the government of the United States, municipal bonds, bankers’ acceptances, bank certificates of deposit, commercial paper and high quality short-term debt instruments, including repurchase agreements, shares issued by money market funds, 529 education savings plans and shares of open-end investment companies registered under the Investment Company Act of 1940 (e.g., an open-end ETF or an open-end mutual fund) that employ investment strategies of exclusively investing in one or more of the securities that are not “reportable securities”); (iv) transactions effected in, and the holdings of, any account over which the Access Person has no direct or indirect influence or control (i.e., blind trust, discretionary account or trust managed by a third party); (v) purchases or sales of shares of ETFs or mutual funds that are reportable securities, except where the Chief Compliance Officer determines, in his sole discretion, that any such purchase or sale may disadvantage a Client or may result in a conflict (or the appearance of a conflict) with a Client; (vi) purchases or sales of interests in privately-offered investment vehicles; and (vii) purchases or sales of securities owned prior to the commencement of the Access Person’s employment with Samlyn. Transactions described in (i)–(iv) above are exempt from the preclearance requirement. An Access Person who wishes to engage in any transaction described in (v), (vi) and (vii) above must obtain prior written approval from the Chief Compliance Officer. In addition, Access Persons must provide the Chief Compliance Officer with a list of their personal accounts and an initial holdings report within 10 days of becoming an Access Person. In addition, Access Persons must provide annual holdings reports and quarterly transaction reports in accordance with Rule 204A-1 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Samlyn and its Access Persons may give and/or receive gifts, services or other items to/from any person or entity that does business with or potentially could conduct business with or on behalf of Samlyn. Samlyn has adopted and implements policies and procedures governing gifts and business entertainment, which include a quarterly disclosure of gifts and business entertainment in excess of certain de minimis thresholds and the requirement to obtain written approval from the Chief Compliance Officer prior to giving/receiving gifts above a certain de minimis threshold. From time to time, Samlyn engages in principal transactions. With respect to those transactions, Samlyn discloses to the relevant Client in writing before the completion of the transaction the capacity in which Samlyn is acting and obtains the relevant Client’s consent to such transaction as required by Section 206(3) of the Advisers Act.
Samlyn and its personnel may have conflicts in allocating their time and services among the Clients. Samlyn will devote as much time to each of the Clients as it deems appropriate to perform its duties in accordance with its investment management agreements with the Clients. In addition, Samlyn, its affiliates and employees may conduct outside business activities. In the course of its investment management and other activities, Samlyn may come into possession of confidential or material non-public information about issuers, including issuers in which Samlyn or its personnel have invested or seek to invest on behalf of Clients. Samlyn is prohibited from improperly disclosing or using such information for its own benefit or for the benefit of any other person, regardless of whether such other person is a Client. Samlyn has adopted and implements written policies and procedures that prohibit the communication of such information to persons who do not have a legitimate need to know such information and to ensure that Samlyn is meeting its obligations to its Clients and remains in compliance with applicable law. In certain circumstances, Samlyn may possess certain confidential or material, non-public information that, if disclosed, might be material to a decision to buy, sell or hold a security, but Samlyn will be prohibited from communicating such information to its Clients or using such information for a Client benefit. In such circumstances, Samlyn will have no responsibility or liability to a Client for not disclosing such information to the Client (or the fact that Samlyn possesses such information), or not using such information for the Client’s benefit, as a result of following Samlyn’s policies and procedures designed to provide reasonable assurances that it is complying with applicable law. The Code also seeks to ensure the protection of non-public information about the activities of its Clients. Clients, Fund Investors and prospective Fund Investors may obtain a copy of the Code by contacting Michael Barry (General Counsel and Chief Compliance Officer) at (212) 848-0534.
Item 12: Brokerage practices Conflicts of interest
Selection of Broker-Dealers for Client Transactions Samlyn is authorized to determine the broker-dealer to be used for each securities transaction for a Client. Samlyn considers a number of factors in selecting a broker-dealer to execute transactions (or series of transactions) and determining the reasonableness of the broker-dealer’s compensation, but Samlyn need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Such factors include, but are not limited to: (i) execution capability, including the actual executed price of the security and the broker’s commission rates and spreads, efficiency of execution, the size and type of the transaction, the difficulty of execution and the ability to handle a block order; (ii) value of research provided by the broker to Samlyn; (iii) services and value provided by the broker other than execution, including custodial services provided by brokers, operational facilities of brokers and overall responsiveness of broker; (iv) reputation and stability of the broker; (v) offering to Samlyn on-line access to data regarding a Client’s accounts; and (vi) numerical rating for each broker prepared by Samlyn. Samlyn’s Best Execution Committee meets quarterly to evaluate the broker-dealers used by Samlyn to execute Client trades using the foregoing factors, among others. Samlyn receives research or other products or services other than execution from a broker-dealer and/or a third party in connection with Client securities transactions. This is known as a “soft dollar” relationship. Samlyn limits the use of “soft dollars” to obtain research and brokerage services to services that constitute research and brokerage within the meaning of Section 28(e) of the Securities Exchange Act of 1934, as amended (“Section 28(e)”). Research services within Section 28(e) may include, but are not limited to, research reports (including market research); certain financial newsletters and trade journals; software providing analysis of securities portfolios; corporate governance research and rating services; attendance at certain seminars and conferences; discussions with research analysts; corporate access (including, without limitation, meetings with corporate executives); consultants’ advice on portfolio strategy; data services (including services providing market data, company financial data and economic data); advice from brokers on order execution; and certain proxy services. Brokerage services within Section 28(e) may include, but are not limited to, services related to the execution, clearing and settlement of securities transactions and functions incidental thereto (i.e., connectivity services between an adviser and a broker-dealer and other relevant parties such as custodians); trading software operated by a broker-dealer to route orders; software that provides trade analytics and trading strategies; software used to transmit orders; clearance and settlement in connection with a trade; electronic communication of allocation instructions; routing settlement instructions; post trade matching of trade information; and services required by the SEC or a self-regulatory organization such as comparison services, electronic confirms or trade affirmations. In the past year, research and related services furnished by brokers included, among other things, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; financial publications; and statistical and pricing services, as well as discussions with research personnel. When Samlyn uses Client commissions to obtain Section 28(e) eligible research and brokerage products and services, Samlyn’s Best Execution Committee meets quarterly to review and evaluate its soft dollar practices and to determine in good faith whether, with respect to any research or other products or services received from a broker-dealer, the commissions used to obtain those products and services were reasonable in relation to the value of the research, brokerage or other products or services provided by the brokerdealer. This determination will be viewed in terms of either the specific transaction or Samlyn’s overall responsibilities to the accounts or portfolios over which Samlyn exercises investment discretion. The use of Client commissions (or markups or markdowns) to obtain research and brokerage products and services raises conflicts of interest. For example, Samlyn will not have to pay for the products and services itself. This creates an incentive for Samlyn to select or recommend a broker-dealer based on its interest in
receiving those products and services. Samlyn may cause Clients to pay commissions (or markups or markdowns) higher than those charged by other broker-dealers in return for soft dollar benefits (known as paying-up), resulting in higher transaction costs for Clients. Research and brokerage services obtained by the use of commissions arising from a Client’s portfolio transactions may be used by Samlyn in its other investment activities, including for the benefit of other Client accounts. Samlyn does not allocate soft dollar benefits to Client accounts proportionately to the soft dollar credits the accounts generate. In some instances, Samlyn obtains a product or service that is used, in part, by Samlyn for Section 28(e) eligible purposes and, in part, for other purposes. In such instances, Samlyn will make a good faith effort to determine the relative proportion of the product or service used to assist Samlyn in carrying out its investment decision-making responsibilities and the relative proportion used for administrative or other purposes outside Section 28(e). Such determination will be based on the actual use of the product or service by Samlyn’s personnel. The proportion of the product or service attributable to assisting Samlyn in carrying out its investment decision-making responsibilities will be paid through brokerage commissions generated by Client transactions and the proportion attributable to administrative or other purposes outside Section 28(e) will be paid for by Samlyn from its own resources. The determination of the appropriate allocation of “mixed use” products and services creates a potential conflict of interest between Samlyn and the Clients. Samlyn may participate in “client commission arrangements” pursuant to which Samlyn may execute transactions through a broker-dealer and request that the broker-dealer allocate a portion of the commissions or commission credits to another firm that provides research and other products to Samlyn. Samlyn excludes from use under these arrangements those products and services that are not eligible under Section 28(e) and applicable regulatory interpretations. In selecting brokers to execute transactions on behalf of the accounts of certain of its Clients, Samlyn may place transactions with a broker or dealer that: (i) provides Samlyn with the opportunity to participate in capital introduction events sponsored by the broker-dealer; or (ii) refers prospective Fund Investors to a Fund, if otherwise consistent with seeking best execution. While Samlyn recognizes that it may have an incentive to favor broker-dealers that provide capital introduction services to Samlyn or otherwise refer prospective Clients or Fund Investors, Samlyn does not select broker-dealers in recognition of the opportunity to participate in such capital introduction events or the referral of prospective Fund Investors. Samlyn often purchases or sells the same security for many Clients contemporaneously and using the same executing broker. It is Samlyn's practice, where possible, to aggregate Client orders for the purchase or sale of the same security submitted contemporaneously for execution using the same executing broker. Samlyn will also aggregate in the same transaction, the same securities for accounts where Samlyn has brokerage discretion. Such aggregation may enable Samlyn to obtain for Clients a more favorable price or a better commission rate based upon the volume of a particular transaction. When an aggregated order is filled (completely or partially), Samlyn allocates the securities purchased or proceeds of sale pro rata among the participating Clients, based on the purchase or sale order. Adjustments or changes may be made under certain circumstances, such as to avoid odd lots or excessively small allocations. If the order at a particular broker is filled at several different prices, through multiple trades, generally all such participating Clients will receive the average price and pay the average commission, subject to odd lots, rounding and market practice. Investment Allocations Samlyn will act in a fair and equitable manner in allocating investment opportunities among the Clients. Samlyn has adopted and implements policies and procedures for the allocation of investment opportunities among its Clients, as described herein.
In general, Samlyn initially determines the Flagship Funds' target allocation for a proposed transaction by allocating to each Flagship Fund pro rata based on that fund's assets under management. Samlyn then calculates target allocations for other Client types as follows: (i) the Long Alpha Master Fund receives an allocation based on a fixed ratio reflecting the fund's net asset value relative to the Flagship Funds' target net long exposure, subject to certain sector-based adjustment factors that account for the Long Alpha Funds' benchmark and sector weighting considerations; (ii) the Net Neutral Master Fund receives, for long positions, an allocation based on a fixed ratio reflecting its target long position size relative to the Flagship Funds' target long exposure and, for short positions, an allocation based on the target short position size relative to the Flagship Funds' target short exposure; and (iii) Clients for which Samlyn makes large, concentrated investments in positions that are also held by one or more of Samlyn's other Clients (“CoInvestment Clients”) receive allocations based on a target allocation determined by Samlyn in consultation with such Co-Investment Clients. Samlyn's allocation procedures are subject to certain exceptions, including with respect to the following: (i) certain Rule 144A and Regulation S securities and initial public offerings, which may not be suitable for all Clients and in which Co-Investment Clients generally will not participate; (ii) side pocket investments and potential side pocket investments, where Samlyn has discretion to allocate disproportionately among Clients and in which Co-Investment Clients generally will not participate; (iii) arbitrage positions, restricted list securities, and securities with regulatory or liquidity constraints that may limit allocations to certain Clients; (iv) directional fixed income positions, which may be allocated only to the Flagship Funds; (v) hedging positions where the primary thesis is short, which may be limited to the Flagship Funds and Net Neutral Funds; (vi) certain benchmark-related positions for the Long Alpha Funds; and (vii) tax harvesting strategies in the Flagship Onshore Fund. Samlyn may deviate from its allocation procedures based on a variety of factors, including: (i) the investment objectives and guidelines of each Client; (ii) each Client's risk profile and tolerance; (iii) the tax status or tax objectives of each Client; (iv) regulatory restrictions applicable to each Client; (v) the size and nature of each Client's account; (vi) the composition and liquidity of each Client's existing portfolio; (vii) the availability and liquidity of a particular investment opportunity; (viii) prevailing market conditions; (ix) the potential transaction costs for a particular Client; (x) the nature of an investment (e.g., whether it involves co-investment rights or side pocket treatment); and (xi) such other factors as Samlyn deems relevant. Because of the differences in Client investment objectives and strategies, risk tolerances, tax status and other criteria of the Clients, there will be differences among clients in invested positions and investment opportunities held.
Item 14: Client referrals and other compensation Conflicts of interest
Samlyn receives certain research or other products or services from broker-dealers through “soft-dollar” arrangements. These “soft-dollar” arrangements create an incentive for Samlyn to select or recommend broker-dealers based on Samlyn’s interest in receiving the research or other products or services and may result in the selection of a broker-dealer on the basis of considerations that are not limited to the lowest commission rates and may result in higher transaction costs than would otherwise be obtainable by Samlyn on behalf of the Clients. Please see Item 12 for further information on Samlyn’s “soft-dollar” practices.
Item 9: Disciplinary information
This Item is inapplicable.
Item 13: Review of accounts
Robert Pohly serves as the Portfolio Manager for the Funds and is principally responsible for making investment recommendations to the holder of the SMA. Mr. Pohly is assisted by Samlyn’s team of investment professionals (the “Investment Team”). Mr. Pohly and the Investment Team review each Client account on an ongoing basis to determine whether securities positions should be maintained in light of current market conditions. Matters reviewed include specific securities held, adherence to investment guidelines and the performance of each Client account. Generally, Samlyn sends or arranges for Fund Investors to receive unaudited monthly net asset value statements, letters regarding the performance of the Fund at least quarterly and audited year-end financial statements annually. The holder of the SMA receives written performance reports from Samlyn in accordance with the terms of the SMA IMA.
Item 15: Custody
Samlyn is deemed to have custody of the Funds’ assets. In addition, an affiliate of Samlyn is deemed to have custody of the assets of those Funds for which it serves as general partner. Samlyn and such affiliate comply with Rule 206(4)-2 under the Advisers Act by meeting the conditions of the pooled vehicle annual audit provision thereunder.
Item 16: Investment discretion
Samlyn provides investment advisory services to the Clients on a discretionary basis. In respect of the Funds, as further described in Item 4, Fund Investors may not impose any limits on Samlyn’s discretionary authority. In respect of the SMA, once an investment recommendation is preapproved in writing by the holder of the SMA, Samlyn has discretionary authority to determine the amount of the relevant issuer’s securities to be purchased or sold and the timing of those transactions, subject in each case to compliance with the investment guidelines, restrictions and other parameters set forth in the SMA IMA. Prior to assuming discretion in managing a Client’s assets, Samlyn enters into an investment management agreement or other agreement that sets forth the scope of its discretion. Samlyn may provide to certain Fund Investors, and from time to time does provide the holder of the SMA, with the opportunity to co-invest in certain Fund investments based on Samlyn’s consideration of certain factors, including, without limitation: (i) whether the potential co-investor has expressed an interest in participating in co-investment opportunities; (ii) Samlyn’s evaluation of the potential co-investor’s size and financial resources; (iii) the ability of the potential co-investor to expeditiously participate in the investment opportunity without harming or otherwise prejudicing the other Clients participating; (iv) Samlyn’s perception of whether the investment opportunity may subject the potential co-investor to legal, regulatory or other burdens that make it less likely that the potential co-investor would accept the investment opportunity; (v) whether Samlyn believes that allocating the investment opportunity to a potential coinvestor will help establish, recognize or strengthen relationships that may provide indirectly longer-term benefits to current or future Clients or to Samlyn; (vi) any confidentiality concerns Samlyn has that may arise in connection with providing the potential co-investor with specific information regarding an investment opportunity in order to allow it to evaluate the opportunity; and (vii) other factors deemed relevant by Samlyn. Co-investment opportunities may not be made available to all of the Clients or Fund Investors. Samlyn may effect cross transactions between Client accounts, except where prohibited under applicable law. Cross transactions enable Samlyn to effect a trade between two Clients for the same security at a set price, thereby possibly avoiding an unfavorable price movement that may be created through entrance into the market and saving commission costs for both Client accounts. Cross transactions include rebalancing transactions that are undertaken so that, after withdrawals or contributions have occurred, the portfolio compositions of the relevant Client accounts remain substantially similar. Samlyn has a potentially conflicting division of loyalties and responsibilities regarding both parties to cross transactions, including with respect to a decision to enter into such transactions and with respect to pricing and other terms. Because Samlyn represents the interests of both the seller and the buyer in a cross transaction, Clients for which Samlyn executes cross transactions bear the risk that the other Client in the cross transaction will be treated more favorably, especially where the other Client pays higher Management Fees or performancebased compensation. Clients also bear the risk that the price of a security bought or sold through a cross transaction may be less favorable than it might have been had the transaction been executed in the open market, and the risk that they receive a security that is difficult to dispose of in a market transaction. Samlyn will only engage in a cross transaction between Clients when Samlyn has determined that the cross transaction is in the best interest of each Client. If it appears that a trade error has occurred, Samlyn will review the relevant facts and circumstances to determine an appropriate course of action. To the extent that trade errors occur, Samlyn's error correction procedure is to ensure that Clients are treated fairly. Samlyn has discretion to resolve a particular error in any appropriate manner that is consistent with the above-stated policy. In the event that a Client account incurs a trade error resulting in a loss as a result of Samlyn’s gross negligence, willful misconduct or fraud, such trade error will be corrected by Samlyn as soon as practicable, in a manner such that the Client incurs no loss. Losses arising from trade errors that result from circumstances other than by breach of the standard
of care above will be borne by the relevant Client. All gains resulting from trade errors will be retained by the Clients. To the extent Samlyn has authority, pursuant to the investment management agreement or other governing documents of a Client account, to participate in class action claims (each, a “Claim”), it will do so on a case-by-case basis. Once Samlyn receives a Claim, it will determine whether any of its Clients or former clients owned the security during the period covered by the Claim. Appropriate personnel of Samlyn will determine whether they agree with the basis of the Claim and whether or not to participate in the Claim depending upon: (i) the nature of the Claim; (ii) prospects for recovery; (iii) resources required to pursue the Claim; (iv) other relevant factors pertaining to the particular Claim; and (v) any other factors that Samlyn deems relevant. To the extent Samlyn receives proceeds from a Claim on behalf of a Client, Samlyn’s general policy is that only current Clients or Fund Investors at the time of receipt of the proceeds will participate in the proceeds. Samlyn may from time to time, retain third parties to assist in identifying potential Claims, making a decision as to whether to participate in a Claim, and pursuing any Claims.
Item 17: Voting client securities
Samlyn’s investment management agreements with the Clients grant Samlyn the authority to cast all proxy votes. Samlyn has adopted and implements a proxy voting policy, as required by the Advisers Act. The policy provides that Samlyn will act in the best interests of each Client in determining whether and how to vote on any proxy voting matter. To assist Samlyn in its responsibility for voting proxies, Glass Lewis & Co (“Glass Lewis”) has been retained as an expert in the proxy voting and corporate governance area. Glass Lewis is an unaffiliated, third party proxy voting service. Samlyn’s Chief Compliance Officer has reviewed and approved Proxy Voting Guidelines prepared by Glass Lewis and its designees and has determined that these guidelines accurately reflect Samlyn’s standards in voting proxies. Samlyn generally votes proxies based upon the recommendations of Glass Lewis consistent with the Proxy Voting Guidelines. In addition, Samlyn’s proxy voting policies and procedures include guidelines regarding: (i) the process in place to override a vote recommendation from Glass Lewis; (ii) responsibilities of certain parties with regard to the proxy voting process; (iii) how material conflicts of interest are resolved to ensure that all proxies are voted in the best interests of Clients; and (iv) recordkeeping issues. In respect of the Funds, individual Fund Investors are not able to direct Samlyn on how to cast a proxy vote. Clients may obtain a copy of Samlyn’s proxy voting policies and procedures and information about how Samlyn voted a Client’s proxies by contacting Michael Barry (General Counsel and Chief Compliance Officer) at (212) 848-0534.
Item 18: Financial information
This Item is inapplicable.
Timeline
- Nov 9, 2006Founded SAMLYN CAPITAL, LLC is founded2
Filings
23 filings to the SEC since October 2021: 23 other. The latest 20:
- Aug 31, 2026N-PX EDGAR
- Aug 14, 202613F-HR EDGAR
- May 15, 202613F-HR EDGAR
- Feb 17, 202613F-HR EDGAR
- Nov 14, 202513F-HR EDGAR
- Aug 29, 2025N-PX EDGAR
- Aug 14, 202513F-HR EDGAR
- May 15, 202513F-HR EDGAR
- Feb 14, 202513F-HR EDGAR
- Nov 14, 202413F-HR EDGAR
- Aug 30, 2024N-PX EDGAR
- Aug 14, 202413F-HR EDGAR
- May 15, 202413F-HR EDGAR
- Feb 14, 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 EDGAR
- Aug 15, 202213F-HR EDGAR
The 23 filings since October 2021 can be filtered by form type and year here when JavaScript is on.
Every filing from the last five years, summarized. The full record is on SEC EDGAR.
Stakes it holds
SAMLYN CAPITAL, LLC has told the SEC it owns more than 5% of 13 companies, latest first (Schedules 13D and 13G).
- Vinci Compass Investments Ltd.SCHEDULE 13G Feb 14, 2023 to Aug 14, 20265
- PureCycle Technologies, Inc.SCHEDULE 13G/A Feb 14, 2023 to May 15, 20266
- Corvus Pharmaceuticals, Inc.SCHEDULE 13G/A Feb 14, 2024 to Aug 14, 20257
- Nektar TherapeuticsSCHEDULE 13G/A Feb 14, 2025 to May 15, 20258
- Inozyme Pharma, Inc.SCHEDULE 13G/A Feb 14, 2024 to Feb 14, 20259
- Merus N.V.SC 13G/A Feb 14, 2024 to Nov 14, 202410
- Applied Minerals, Inc.SC 13D/A Jan 11, 2023 to Nov 1, 202411
- Climb Bio, Inc.SC 13G/A Feb 14, 2022 to Feb 14, 202312
- Glass Houses Acquisition Corp.SC 13G/A Feb 14, 2022 to Feb 14, 202313
- Perella Weinberg PartnersSC 13G/A Feb 14, 2022 to Feb 14, 202314
- Satsuma Pharmaceuticals, Inc.SC 13G/A Feb 14, 2022 to Feb 14, 202315
- STR Sub Inc.SC 13G/A Feb 14, 202216
- Sculptor Capital ManagementSC 13G/A Feb 14, 202217
Sources
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