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Nellore Capital Management LLC: investment adviser

Nellore Capital Management LLC is an investment adviser registered with the SEC (file 801-119279, CRD 300467). What it reports on Form ADV: assets and clients, fees, owners, disciplinary history and its client brochure. From the SEC's Investment Adviser Public Disclosure site; read Oct 21, 2026.

Assets managed
$1.0B
Discretionary
100%
Accounts
3
Employees
2
In advisory roles
1
Disclosures
0

Company page · SEC adviser record · Full Form ADV (PDF)

The firm reports that it or a related person has custody of client cash and securities.

Form ADV Part 1A, Item 5, as filed on the SEC Investment Adviser Public Disclosure site; read Oct 21, 2026.

Clients and fees

Whom the firm advises and how it is paid, from Items 5.D, 5.E and 5.G.

Client typeClientsAssetsShare
Private funds and other pooled vehicles1$762.3M73.7%
Pension and profit-sharing plans0$50.9M4.9%
Other: Endowment0$220.8M21.4%

How it is paid

  • A percentage of assets under your management
  • Performance-based fees

Services

  • Portfolio 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)

Who owns it

Schedule A lists direct owners of 5% or more (and officers who own a stake); Schedule B lists the owners of those owners.

Direct owners (Schedule A)

OwnerTypeRoleStakeSinceControlPublic company
Sakya Venkat DuvvuruPersonChief compliance officer and managing memberE 75% or moreDec 2018Yes

Form ADV reports ownership in bands, not exact stakes: A means 5% to 10%, B 10% to 25%, C 25% to 50%, D 50% to 75%, E 75% or more. F marks a general partner, trustee or managing member, a role that controls the firm without a percentage. Owners of less than 5% are not listed.

Form ADV Schedules A and B, via the SEC Investment Adviser Public Disclosure site.

Disciplinary history

The firm answered No to every disciplinary question on Form ADV (Item 11).

The brochure

Form ADV Part 2A: the plain-language document an adviser must give its clients. Each item is shown as filed; open an item to read all of it.

Nellore Capital Management LLC - Form ADV Part 2A (March 2026), filed Mar 31, 2026. Brochure PDF. Items: 4 · 5 · 6 · 7 · 8 · 9 · 10 · 11 · 12 · 13 · 14 · 15 · 16 · 17 · 18

Item 4. Advisory business

A. Nellore Capital Management LLC (“Nellore Capital” or “the Firm”) began providing advisory services in January 2019. The Firm’s sole owner and Managing Member is Sakya Duvvuru. B. Nellore Capital seeks to achieve long term capital appreciation primarily through long investments in the securities of global technology companies. Though primarily long biased, the Firm retains the discretion to make short investments. The Firm invests in U.S. as well as non-U.S. based companies and may invest in emerging markets. The Firm’s investment advice is primarily limited to publicly traded common stocks, but the Firm may also invest in options and other derivatives providing exposure to publicly traded common stocks. The Firm may also engage in private market transactions.

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Nellore Capital provides discretionary asset management services to a pooled investment vehicle, Nellore Capital Partners LP (the “Fund”), and also provides discretionary asset management services through separately managed accounts (“SMA” or “SMA accounts”) for some clients (together, the Fund and the SMA accounts, the “Clients”). The Firm manages the Fund and SMA accounts using a single common investment strategy. An SMA allows increased transparency for Clients as they can view the details of their account at any time through the custodian but may have different fees or expenses associated with that account structure. An SMA also gives the Client and the Firm the ability to liquidate some or all of the Client’s assets in a timely and orderly fashion without materially impacting the investment performance of other Clients or the Fund. C. For each SMA, Nellore Capital does not tailor its advisory services by Client, but Clients may impose reasonable restrictions if necessary. The Firm employs the same capital allocation strategy across all of its accounts that it deems will provide the maximum risk adjusted return for all of its Clients. Nellore Capital’s SMA clients understand that their account holdings will closely reflect those of other Clients. As for the Fund, the Firm tailors advice to the Fund and not to the underlying beneficial owners of the Fund. The Fund’s investors are unable to impose restrictions on investing in certain securities or types of securities. D. Nellore Capital does not participate in wrap fee programs. E. As of December 31, 2025, Nellore Capital manages $1,033,998,245 in regulatory assets under management on a discretionary basis. Nellore Capital does not manage any assets on a non-discretionary basis.

Item 5. Fees and compensation

A. For SMA accounts, each account is typically subject to a management fee equal to 1.0% of the sum of the Client’s total investment value. With respect to the Fund, the Firm charges each investor a quarterly management fee equal to one-quarter of 1.0% (1.0% per annum) of the sum of an investor’s total investment value in the Fund. Nellore Capital may, in its discretion, waive, reduce, or rebate all or part of the management fee payable. Nellore Capital also charges an incentive allocation, or performance-based fee, for SMA accounts and the Fund. The performance-based fee is explained in detail in the next section. B. For both SMA accounts and the Fund, the Firm deducts fees directly from investors’ assets. Fees are deducted on a quarterly basis in advance.

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Please refer to Item 15 for more information about this practice. C. For both SMA accounts and the Fund, Clients may pay for other expenses and fees in connection with Nellore Capital’s advisory services. Clients may incur certain charges imposed by third parties in connection with investments made through the account, including, but not limited to, annual maintenance, brokerage, clearance, custody, and administrative fees. Other expenses Clients may bear, particularly investors in the Fund, include legal, compliance, administrator, audit, accounting expenses (including third party accounting services), and any other services or service provider expenses deemed necessary by Nellore Capital on behalf of its Clients. Clients should note that they will incur brokerage and other transaction costs. For more information on brokerage costs, please refer to Item 12 of this brochure. D. SMA accounts and investors in the Fund are charged management fees in advance. The management fee with respect to the capital account investor maintains in the Fund will be charged to the investor initially as of the date the investor makes the capital contribution to the Fund and in advance quarterly thereafter. For both SMA accounts, management fees will be refunded for the portion of the pre-paid fee if the advisory contract is terminated before the end of the relevant billing period. Similarly, for the Fund management fee will be prorated for any period that is less than a full calendar quarter, with any necessary amounts rebated as appropriate.

E. Nellore Capital does not accept compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds.

Item 6. Performance-based fees and side-by-side management

Nellore Capital charges performance-based fees or allocations. The Firm only charges performancebased fees or allocations to “qualified clients” as defined in Rule 205-3 under the Investment Advisers Act of 1940. For SMA accounts, Nellore Capital may be paid a management fee and/or performance fee or allocation with respect to a separately managed account in accordance with the terms of the applicable SMA account agreement.

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For the Fund, the performance allocation is calculated as set forth in the fund’s limited partnership agreement and generally is 18% of the Fund’s annual unrealized and realized net capital appreciation, subject to a 6% per annum Hurdle Rate and “high water mark.” This compensation structure creates a conflict of interest because it incentivizes Nellore Capital to favor accounts for which it receives performance-based fees. Nellore Capital might also be inclined to make riskier investments against Clients’ interest to earn performance-based fees. To address this conflict, Nellore Capital only makes investment recommendations and decisions based on the best interest of its Clients, regardless of compensation arrangements.

Item 7. Types of clients

Nellore Capital may provide investment advice to high net worth individuals, pooled investment vehicles, trusts, investment companies, endowments, or pension plans. To be an SMA Client or an investor in the Fund, one must meet accredited investor status (defined below) and qualified client status (defined above) (except in Nellore Capital’s discretion in limited circumstances).

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Investors meet “accredited” status generally if they are: • Persons with an annual income exceeding $200,000, or $300,000 for joint income, for the last two years with expectation of earning the same or higher income in the current year; • Persons with net worth exceeding $1 million, either individually or jointly with his spouse; • General partners, executive officers, directors, or a related combination thereof for the issuer of unregistered securities; • Private business development companies or organizations with assets exceeding $5 million; • Entities that consist of equity owners who are accredited investors; • Registered brokers and investment advisors; or

•

Persons who can demonstrate sufficient education or job experience showing their professional knowledge to evaluate the merits and risks of a prospective investment.

To be an investor in Nellore Capital’s Fund, the minimum subscription is $1,000,000 for initial investments and $100,000 for additional investments. In its discretion, Nellore Capital may from time to time waive, reduce, or increase such minimum initial and additional investment requirements.

Item 8. Methods of analysis, investment strategies and risk of loss

A. Nellore Capital’s investment objective is to achieve long term capital appreciation primarily through long investments in global technology companies. Though primarily long biased, the Firm retains the discretion to make short investments. The Firm may invest in both U.S. and non-U.S. based companies, including those located in emerging markets. Nellore Capital focuses on publicly traded common stocks but may also invest in options and other derivatives providing exposure to publicly traded common stocks, and private market transactions. The first part of Nellore Capital’s investment strategy is identifying trends and developments in the sectors in which the Firm invests.

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By observing companies’ strategies, customer needs, and the development of new technologies, the Firm will then build a framework based on several major investment themes. The framework helps the Firm formulate a hypothesis about how industries may evolve over the long term. The next part of the investment strategy is making investment decisions based on bottomup proprietary analysis. The goal of the analysis is to determine which companies benefit from new technology breakthroughs or standards, or which companies can reinforce their leadership through innovation and widening their competitive advantage. Research may be generated through meetings and conversations with company management, interactions with the company’s customers, suppliers, employees, competitors, consultants and organizations, and communications with contacts within the technology business community. In addition to its proprietary analysis, Nellore Capital conducts fundamental financial analysis, including forecasting key performance indicators, revenue, and free cash flow as inputs into discounted cash flow analysis, private market valuation analysis, comparable company analysis and liquidation value analysis to determine intrinsic value and risk/reward. The ultimate goal of this analysis is to compare the price at which the business is being valued by the market with the intrinsic value of the business determined by Nellore Capital’s assessment of its long-term growth prospects and the likelihood of achieving them.

Once the above steps are completed, Nellore Capital typically places a long position in a company that it believes has one or more of the following characteristics: • Superior value proposition for customers, • Best in class products or services, • Leading market share position with runway ahead, • Currently profitable or has strong unit economics and is choosing to reinvest in accelerated customer acquisition or widening its competitive advantage, • One or more competitive advantages (e.g., scale, network effects, brand, switching costs, IP), • Low customer acquisition costs and/or high customer lifetime values, • Innovative and effective management team, and • Recurring revenue and high incremental margins business model. Nellore Capital’s investment strategy generally is long-biased though it retains the ability to hold short positions at times in its discretion. Investing in securities always involves a risk of loss that investors should be prepared to bear. There can be no assurance that Nellore Capital will achieve its investment objective or avoid substantial losses. B. All prospective investors, either individually or together with their professional advisers, must have the financial sophistication and expertise to evaluate the merits and risks of an investment in Nellore Capital’s strategy. The strategy is speculative, possibly illiquid, and involves a high degree of risk. Investors must be prepared to lose all or substantially all of their investment. Market Risk. The price of any security can decline for a variety of reasons outside of Nellore Capital’s control, including, but not limited to, changes in the macroeconomic environment, unpredictable market sentiment, forecasted or unforeseen economic developments, interest rates, regulatory changes, and domestic or foreign political, demographic, or social events. If an investor has a high allocation in a particular asset class, it may negatively affect overall performance to the extent that the asset class underperforms relative to other market assets. Conversely, a low allocation to a particular asset class that outperforms other asset classes in a particular period may cause that Client to underperform relative to the overall market. Currency Risk. The value of recommended investments may be affected favorably or unfavorably by the changes in currency rates and exchange control regulations. Some currency exchange costs may be incurred when the Firm changes investments from one country to another. Currency exchange rates may fluctuate significantly over short periods of time. Currency rates generally are determined by the forces of supply and demand in the respective markets and the relative merits of investments in different countries, actual or

perceived changes in interest rates and other complex factors, as seen from an international perspective. Currency exchange rates can also be affected unpredictably by intervention by governments or central banks (or the failure to intervene) or by currency controls or political developments. Nellore Capital does not seek to mitigate the risk of currency exchange fluctuation through the active and systematic use of currency hedges. Non-U.S. Exchanges and Markets. Nellore Capital may engage in trading on non-U.S. exchanges and markets. Trading on such exchanges and markets may involve certain risks not applicable to trading on U.S. exchanges and is frequently less regulated. For example, certain of those exchanges may not provide the same assurances of the integrity (financial and otherwise) of the marketplace and its participants, as do U.S. exchanges. There also may be less regulatory oversight and supervision by the exchanges themselves over transactions and participants in such transactions on those exchanges. Some non-U.S. exchanges, in contrast to U.S. exchanges, are “principals’ markets” in which performance is the responsibility only of the individual member with whom the trader has dealt and is not the responsibility of an exchange or clearing association. Furthermore, trading on certain non-U.S. exchanges may be conducted in such a manner that all participants are not afforded an equal opportunity to execute certain trades and may also be subject to a variety of political influences and the possibility of direct government intervention. Investments in non-U.S. markets will generally also be subject to the risk of fluctuations in the exchange rate between the local currency and the dollar and to the possibility of exchange controls. NonU.S. markets may also be less liquid and more volatile than comparable U.S. markets. Foreign brokerage commissions and other fees are also generally higher than in the United States. Lack of Liquidity for Fund Investors. There are significant restrictions on a Fund investor’s right to redeem all or part of his/her or its investment, transfer the investment, and pledge or otherwise encumber the investment. An investor’s assets may not be transferred or pledged except with the Firm’s prior written consent (which may be conditioned or withheld in Nellore Capital’s discretion) and in strict compliance with federal and state securities and commodities laws (as determined by the Firm in its discretion). Nellore Capital also has the discretion to deliver redemption proceeds (in whole or in part) in investments rather than cash. These limitations, taken together, will significantly limit an investor’s ability to liquidate an investment in the Fund quickly. Thus, it is unlikely that an investor will be able to liquidate his/her assets in the event of an unanticipated need for cash. Further, an investment in the Fund would not be suitable for an investor who needs liquidity. C. Equity Securities. The market price of securities may go up or down, sometimes rapidly or unpredictably. A risk of investing in the strategy is that the equity securities in its portfolio will decline in value due to factors affecting equity securities markets generally

or particular industries or issuers represented in those markets. The values of equity securities may decline due to general market conditions that are not specifically related to a particular company, such as real or perceived adverse economic conditions, changes in the general outlook for corporate earnings, changes in interest or currency rates or adverse investor sentiment generally. Values may also decline due to factors that affect a particular industry or industries, such as labor shortages or increased production costs and competitive conditions within an industry. Other risks of investing globally in equity securities may include changes in currency exchange rates, exchange control regulations, expropriation of assets or nationalization, imposition of withholding taxes on dividend or interest payments, and difficulty in obtaining and enforcing judgments against non-U.S. entities. In addition, securities that Nellore Capital believes are fundamentally undervalued or incorrectly valued may not ultimately be valued in the capital markets at prices and/or within the anticipated time frame. As a result, Clients may lose all or substantially all of its investment in any particular instance. Investment Companies, ETFs, and Other Collective Investment Vehicles. Nellore Capital may, under certain circumstances, cause a Client to invest in registered and unregistered investment companies, ETFs, and certain other collective investment vehicles. ETFs, investment companies, and collective investment vehicles represent shares of ownership in either funds or unit investment trusts that hold portfolios of common stocks or bonds, and other asset classes, which are designed to generally correspond to the price and yield performance of their underlying indices, either broad stock market, stock industry sector, international stock, U.S. bond, commodity, or currency. Investors in such vehicles are subject to risks similar to those of holders of other diversified and non-diversified portfolios. A primary consideration is that the general level of the underlying asset prices may decline, thus affecting the value of the vehicle that tracks such asset prices. Moreover, the overall depth and liquidity of the secondary market may also fluctuate. A sector fund may also be adversely affected by the performance of that specific sector or group of industries on which it is based. Any such investments will increase the fees and expenses payable by the Client, since such investment companies, ETFs and other vehicles also generally bear fees and expenses in connection with their operations and investment activities. OTC Transactions. Nellore Capital may engage in transactions involving securities traded on “over the counter” (“OTC”) markets. In general, there is less governmental regulation and supervision in the OTC markets than of transactions entered into on an organized exchange. In addition, many of the protections afforded to participants on some organized exchanges, such as the performance guarantee of an exchange clearinghouse, will not be available in connection with OTC transactions. This exposes the Client to the risks that a counterparty will not settle a transaction because of a credit or liquidity problem or because of disputes over the terms of the contract. Therefore, to the extent that the strategy engages in trading on OTC markets, the Client could be exposed to greater risk of loss through

default than if it confined its trading to regulated exchanges. Options. Nellore Capital may engage from time to time in various types of options transactions. An option gives the purchaser the right, but not the obligation, upon exercise of the option, either (i) to buy or sell a specific amount of the underlying security at a specific price (the “strike” price or “exercise” price), or (ii) in the case of a stock index option, to receive a specified cash settlement. To purchase an option, the purchaser must pay a “premium,” which consists of a single, nonrefundable payment. Unless the price of the securities underlying the option changes and it becomes profitable to exercise or offset the option before it expires, the strategy may lose the entire amount of the premium. The purchaser of an option runs the risk of losing the entire investment. Thus, the strategy may incur significant losses in a relatively short period of time. The ability to trade in or exercise options also may be restricted in the event that trading in the underlying securities becomes restricted. Options trading may also be illiquid in the event that Client assets are invested in contracts with extended expirations. The strategy may purchase and write put and call options on specific securities, on stock indexes or on other financial instruments and, to close out its positions in options, may make a closing purchase transaction or closing sale transaction. In theory, the exposure to loss is potentially unlimited in the case of an uncovered call writer (i.e., a call writer who does not have and maintain during the term of the call an equivalent long position in the stock or other instrument underlying the call), but in practice the loss is limited by the term of existence of the call. The risk for a writer of an uncovered put option (i.e., a put option written by a writer that does not have and maintain an offsetting short position in the underlying stock or other instrument) is that the price of the underlying security or other instrument may fall below the exercise price. Cybersecurity Risk: As the use of technologies, such as the internet, has become more common in conducting business, Client accounts have become potentially more susceptible to operational, information security and related risks through breaches in cybersecurity. Generally, a cyber incident may result from either intentional attacks or unintentional events and include, but are not limited to, gaining unauthorized access to digital systems, misappropriating assets, or sensitive information, causing a Client account to lose proprietary information, corrupting data, or causing operational disruption, including denial-of-service attacks on websites. Cybersecurity failures or breaches of a third-party service provider that provides services to a Client account, such as the Custodian or an administrator, may also subject a Client account and/or the Firm to these cybersecurity risks. Nellore Capital has established policies and procedures reasonably designed to reduce the risks associated with cyber incidents, including the risk that federal securities laws are broken due to a cyber incident. However, there can be no assurance that these policies and procedures will prevent cyber incidents.

Item 9. Disciplinary information

There are no legal or disciplinary events that are material to prospective investors’ evaluation of Nellore Capital’s advisory business or the integrity of the Firm’s management. Nellore Capital has no material disciplinary facts to disclose.

Item 10. Other financial industry activities and affiliations

A. Neither Nellore Capital nor any of its management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker dealer. B. Neither Nellore Capital nor any of its management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading adviser, or as an associated person of the foregoing entities. C. Neither Nellore Capital nor any of its management persons have a relationship or arrangement that is material to the Firm’s advisory business with any of the entities below: 1. Broker-dealer, municipal securities dealer, or government securities dealer or broker, 2. Investment company or other pooled investment vehicle (e.g.

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mutual fund, private fund, etc.), 3. Another investment adviser or financial planner, 4. Futures commission merchant, commodity pool operator, or commodity trading advisor, 5. Banking or thrift institution, 6. Accountant or accounting firm, 7. Lawyer or law firm, 8. Insurance company or agency, 9. Pension consultant, 10. Real estate broker or dealer, or 11. Sponsor or syndicator of limited partnerships. D. Nellore Capital does not recommend or select other investment advisers for Clients. The Firm does not have any other business relationships that would create a material conflict of interest.

Item 11. Code of ethics, participation in client transactions and personal trading

Trading A. Nellore Capital maintains a code of ethics, which explains procedures for buying and selling securities for directors, officers, employees, and other affiliated persons. The Firm’s code of ethics covers topics such as compliance with laws, rules, and regulations; conflicts of interest; confidentiality; honest and ethical conduct and fair dealing; protection and proper use of corporate opportunities; and accuracy of books and records and public reports; and reporting and compliance procedures. The Firm will provide a copy of its code of ethics to any investor or prospective investor upon request. B. Neither Nellore Capital nor any of its related persons recommends to clients, or buys or sells for client accounts, securities in which it or they have a material financial interest.

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C. Nellore Capital’s principal, Sakya Duvvuru, is also an investor in the Fund. This may create a conflict of interest because Mr. Duvvuru has an incentive to allocate opportunities to the Fund in which he is an investor and could prioritize the interest of the Fund over other Clients. Nellore Capital will allocate investment opportunities on an equitable basis , generally pro rata, among the Fund and SMA accounts. D. Investment Allocations Except as described below, Nellore Capital, the Fund’s general partner (the “General Partner”), its respective principals, owners, or employees may invest in, directly or indirectly, or advise other investment funds or accounts that invest in, assets that may also be purchased or sold by Nellore Capital. Except as required in operative governing agreements, none of Nellore Capital, the General Partner, or their respective principals, owners, or employees are under any obligation to offer investment opportunities of which any of them becomes aware solely to the Fund or to SMA accounts in respect of (or share with them or inform them of) any such transaction or any benefit received by any of them from any such transaction, but will seek to allocate such opportunities generally on a fair and equitable basis among the Fund and SMA accounts that may be able to enter into such transaction, consistent with the allocation principles described below. Generally, purchases of investments will be allocated to the Fund and SMA accounts on the basis of available capital in such Fund or SMA accounts which, in general, will be determined by taking into account factors such as daily cash balances, projected cash requirements for trade settlements, anticipated withdrawals or redemptions, confirmed capital subscriptions, and

other commitments. Sale transactions generally will be allocated to the extent practicable pro rata according to the size of the available inventory. In certain cases, when Nellore Capital determines that pro rata allocation of purchases or sales is not appropriate under the particular circumstances, the allocation will be made based on other factors that Nellore Capital deems appropriate under the circumstances, which may include those described below, and in a manner, it deems fair and equitable. Acquired private investments will be allocated to the Fund and SMA accounts eligible to participate in such private investments pro rata based on available capital at the time of the initial investment. In general, the amount of available capital for private investments will be determined by taking into account factors such as the amount of available capital, concentration limits and sizing considerations, upcoming liquidity requirements or commitments (including follow-on reserves, if any), and other considerations applicable to the Fund and SMA accounts. For sales of private investments, transactions will generally be allocated to the extent practicable pro rata according to the size of the inventory. Where Nellore Capital deems it fair and equitable, Nellore Capital may determine to allocate private investments on a basis that deviates from available capital, taking into account factors which may include those set forth below. When Nellore Capital determines that expected opportunities may exceed some or all its Fund and SMA accounts’ capacity or desired exposure to such opportunities, Nellore Capital may offer such opportunities to investors in the Fund or SMA accounts or to third parties, in its sole discretion. Nellore Capital anticipates that pro rata allocation of investment opportunities may not always be appropriate, including as a result of assessments which may include: applicable Fund or SMA account concentration limits, other risk and portfolio concentration considerations; structuring considerations; Fund and SMA account ramp-ups and rampdowns; differing liquidity requirements of a Fund or SMA accounts; tax considerations; regulatory and legal considerations; minimum denomination/increment thresholds, avoidance of odd-lot or immaterial allocations or expense burdens relative to transaction size; and potential conflicts of interest between or related to an existing portfolio position and the investment to be purchased or sold. Nellore Capital may invest, on behalf of the Fund or SMA accounts, in investments that are impossible or impractical to subdivide and allocate among multiple clients for tax, regulatory or other reasons. Due to the weight given to these factors (and others Nellore Capital deems relevant), timing differences and other factors, the positions held by the Fund and SMA accounts are likely to be slightly different at times (even when a similar strategy among such clients is used), which may result in different performance among such Fund and SMA accounts. In such circumstances, Nellore Capital will make a good

faith effort to allocate participation in such investments on a fair and equitable basis to the Fund and SMA accounts over time, taking into account factors including those described above. Nellore Capital is authorized to combine purchase and sale orders on behalf of the Fund together with orders for SMA accounts and allocate the securities or other assets so purchased or sold, on an average-price basis, among such Fund and SMA accounts.

Item 12. Brokerage practices

1. Research and Other Soft Dollar Benefits. Nellore Capital does not receive research or other products or services other than execution from a broker-dealer or a third party in connection with client securities transactions (i.e., soft dollar benefits). 2. Brokerage for Client Referrals. Nellore Capital does not receive client referrals from broker-dealers or third parties. 3. Directed Brokerage. a. Nellore Capital does not recommend, request, or require that a client directs it to execute transactions through a specified broker-dealer. b. The Firm does not permit clients to direct brokerage.

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B. Nellore Capital may aggregate the sale and purchase orders of securities for advisory accounts, including both SMA accounts and the Fund, with similar orders in order to obtain the best pricing averages and minimize trading costs. This practice is reasonably likely to result in administrative convenience or an overall economic benefit to the Firm. Clients also benefit relatively from better purchase or sale execution prices, lower commission expenses or beneficial timing of transactions, or a combination of these and other factors. Nellore Capital’s policies and procedures mandate aggregating multiple orders where feasible. Aggregate orders will be allocated to Client accounts in a systematic, nonpreferential manner.

Item 13. Review of accounts

A. Periodic Reviews – Nellore Capital reviews the accounts of each SMA Client and Fund investor (collectively known as the “accounts”) on a monthly basis. At the end of the month, BTIG, LLC, Goldman Sachs and/or Morgan Stanley, the Firm’s prime brokers (each, a “Prime Broker”), provide trade files to the Firm’s administrator, HC Global Fund Services, LLC (the “Administrator”). Approximately ten days later, the Administrator sends a monthly financial performance report to each SMA Client and the Fund investors

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that details their account NAV. Zohaib Mardhani, Director of Operations at Nellore Capital, checks that the Administrator’s calculation of each account’s monthly P&L matches that the relevant Prime Broker by reviewing each account statement. Mr. Mardhani also ensures each account’s monthly accrued expenses are in line with the Firm’s projected expenses made at the beginning of the year. B. Intermittent Review Factors – Nellore Capital will review accounts other than on a periodic basis if an extraordinary event causes extreme price changes of an account’s holdings. C. The Administrator for the Fund sends account statements on a monthly basis to Fund investors. These statements contain the balance of each investor account.

Item 14. Client referrals and other compensation

A. Nellore Capital does not have an arrangement in which someone who is not a client provides an economic benefit to the Firm for providing investment advice or other advisory services to the Firm’s clients. B. Nellore Capital does not directly or indirectly compensate any person who is not its supervised person for client referrals.

Item 15. Custody

Separately Managed Account Clients Nellore Capital does not have custody over SMA client accounts. SMA account clients receive statements directly from their custodian no less than quarterly and such statements should be reviewed carefully. Fund Client Nellore Capital is deemed to have custody of assets of the private Fund for which Nellore Capital or an affiliate serves as general partner. Nellore Capital does not act as qualified custodian of investors’ funds or securities; however, Nellore Capital keeps the Fund and securities of its Fund investors with third-party qualified custodians. Nellore Capital has written authorization from the Fund investors to deduct fees directly from its account. Fee calculations and deductions for the Fund are processed by the Fund’s third-party administrator.

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Fund investors will receive statements directly from the Fund’s administrator and the Fund’s custodian no less than quarterly and such statements should be reviewed carefully. Fund investors are urged to review these statements against any reporting information provided by Nellore Capital. The Fund’s financial statements are audited annually by a PCAOB third-party accounting firm, and the audited financial statements are distributed to investors within 120 days of the end of the Fund’s fiscal year.

Item 16. Investment discretion

Nellore Capital maintains discretionary authority to manage securities accounts on behalf of its Clients. Clients may not place any limitations on this authority. The investment discretion is granted to Nellore Capital by the Fund’s Limited Partnership Agreement, as amended from time to time, and in the case of SMA accounts, by an investment management agreement.

Item 17. Voting client securities

Nellore Capital has the authority to vote all proxies on behalf of the Fund it advises and for Clients on the SMA platform. Nellore Capital has adopted a policy governing the voting of proxies that is designed to ensure that Nellore Capital votes proxies in the best interests of its Clients. Nellore Capital generally will vote proxies so as to promote the long-term economic value of the underlying securities. Specifically, Nellore Capital will endeavor to vote in a way that leads companies to meet the Firm’s desired characteristics, which are outlined in Item 8A of this brochure. Each proxy proposal will be considered on its own merits, and Nellore Capital will make an independent determination whether to support or oppose management’s position.

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If there is any actual or apparent conflict of interest between the interests of Nellore Capital and its Clients, Nellore Capital will endeavor to resolve such conflict in a manner that is consistent with its fiduciary duty and in accordance with its proxy voting policy. Fund investors and SMA account clients may obtain a copy of these proxy voting policies, obtain information about how Nellore Capital has voted its Clients’ proxies or discuss any particular solicitation via the contact information listed on the cover of this brochure.

Item 18. Financial information

Nellore Capital is not aware of any financial condition that is reasonably likely to impair our ability to meet our contractual commitments to clients, nor have we been the subject of a bankruptcy petition at any time during the past ten years.

Form ADV Part 2A, via the SEC Investment Adviser Public Disclosure site.