• S&P 500 7,659.44 −1.09%
  • Dow Jones 52,002.41 −0.34%
  • Nasdaq 26,713.03 +0.08%
  • VIX 19.99 +21.45%
  • 10-year Treasury 5.09% −0.01
  • Dollar index 121.40 −0.14%
  • WTI crude $101.91 +1.04%

Life Cycle Investment Partners Limited: investment adviser

Life Cycle Investment Partners Limited is an investment adviser registered with the SEC (file 801-134273, CRD 337788). 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
$29.4B
Discretionary
100%
Accounts
27
Employees
14
In advisory roles
8
Disclosures
0

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

The firm reports no custody of client cash or 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 vehicles9$6.5B22.2%
Pension and profit-sharing plans9$19.3B65.5%
State and local governments4$2.4B8.3%
Sovereign wealth funds1$566.3M1.9%
Other: Sma4$587.1M2.0%

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
Akureyri Holdings LimitedCompany (outside the U.S.)ShareholderC 25% to 50%May 2025Yes
Pinnacle Investment Management LimitedCompany (outside the U.S.)ShareholderC 25% to 50%May 2025Yes
9TB LimitedCompany (outside the U.S.)ShareholderB 10% to 25%May 2025Yes
Jec PM LimitedCompany (outside the U.S.)ShareholderB 10% to 25%May 2025Yes
Kingsmead Capital LimitedCompany (outside the U.S.)ShareholderB 10% to 25%May 2025Yes
Lancelot Equity LimitedCompany (outside the U.S.)ShareholderA 5% to 10%May 2025Yes

Indirect owners (Schedule B)

OwnerOwns a stake inTypeStakeControlPublic company
James Edward ClarkeJec PM LimitedPersonE 75% or moreYes
Nikolai Christoper Lucian De WaldenLancelot EquityPersonE 75% or moreYes
Peter Lee RutterAkureyri HoldingsPersonE 75% or moreYes
Pinnacle Investment ManagementPinnacleCompany (outside the U.S.)C 25% to 50%Yes

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.

Life Cycle Investment Partners - Form ADV Part 2A (Brochure), filed Sep 16, 2026. Brochure PDF. Items: 4 · 5 · 6 · 7 · 8 · 9 · 10 · 11 · 12 · 13 · 14 · 15 · 16 · 17 · 18

Item 4. Advisory business

Advisory Business and Ownership Life Cycle Investment Partners Limited is a private limited company incorporated at Companies House in the United Kingdom in 2024 (Company Number 15633723), and acts as the London based investment manager to a number of private investment vehicles including Australian Unit Trusts, European Union UCITS, United Kingdom UCITS and Separately Managed Accounts (“SMAs”). These will be known collectively as the “Funds” and each a “Fund”). The Firm is majority owned by its employees, with Peter Rutter, CEO, owning the largest stake through Akureyri Holdings Limited, a UK private limited company (Company Number 15945219). Another significant shareholder is Pinnacle Investment Management Limited (“Pinnacle”).

Read the rest of Item 4 (339 more words)

Pinnacle is wholly owned by Pinnacle Investment Management Group Limited in Australia. The remaining minority owners are employees of the Firm. The Firm’s Supervised Persons are: Peter Rutter – CEO and Director (SMF1 and SMF3) James Clarke – Director (SMF3) Will Kenney – Director (SMF3) Christopher Parr – Director (SMF3) Ian Macoun – Director (SMF3) Andrew Chambers – Director (SMF3) Marek Bonham – Head of Trading & Business Operations Jessica Freckleton – US Chief Compliance Officer (SMF 16 and 17) Luke Stalder – Trader Niko de Walden – PM Joseff Thomas – PM Szymon Motyka - PM Services Offered The principal activity of LCIP is to provide discretionary investment management and portfolio management services specializing in global long-only equity investments. The Firm provides investment management services based on specific investment objectives and strategies. The Funds’ offering documents (as amended and supplemented from time to time) set forth the investment guidelines and/or the types of investments in which the assets of the Funds may invest. Ability to Tailor Services and Impose Restrictions The investment objectives and strategy for the Funds are described in the relevant offering documents. LCIP provides investment advisory services based on the specific investment objectives and strategies and not individually to investors (the “Investors”). Since the Firm does not provide tailored advice to Investors, such Investors should consider whether the investment strategies are in line with their risk tolerance. Each Fund may from time to time enter into side letter agreements or other similar agreements (“Side Letters”) providing investors with additional and/or different rights and benefits. The Fund’s Board of Directors may also reduce the minimum subscription amounts in consultations with the Firm, subject to requirements by applicable laws. Client Assets

As of June 30th, 2026, LCIP had approximately USD $29,380,000,000.00 of regulatory assets under management on a discretionary basis. The performance of the Funds will be reported, fees will be calculated, and all subscriptions and redemptions will be transacted, in US dollars (US$). Base currency of any potential SMAs can be in currencies other than US$.

Item 5. Fees and compensation

Management Fee LCIP charges the Funds a fee for its investment management services based on assets under management (the “Management Fee”), which are set forth in the Fund’s offering documents. With respect to the Funds, the Firm receives an annual management fee ranging up to 1.50% per annum in respect of the net asset value (“NAV”) of the relevant class of issue. The Management Fee is payable, depending on the terms agreed with each client, but most commonly monthly or quarterly in arrears as soon as practicable after the end of each calendar month or quarter. LCIP may, in its sole discretion, waive, rebate, or decrease the Management Fee that is payable in whole or in part, in respect of certain Investors.

Read the rest of Item 5 (259 more words)

Each Fund may from time to time enter into Side Letters providing for changes in management fees and performance allocation. Investors with SMAs will generally pay Management Fees in a similar range as stated above. Performance Based Compensation In addition to Management Fees, LCIP may receive performance-based compensation in the form of a performance fee (the “Performance Fee”) equal to a percentage of the appreciation in the value of the shares above an agreed performance hurdle. LCIP, in its sole discretion, may reduce, waive, rebate, or modify the Performance Fee with respect to certain Investors. This may be effected through the creation of additional classes, subclasses, or series of shares, which will not require Investor approval. Brokerage Fees The Funds are responsible for paying any and all brokerage fees including, without limitation, commissions, annual fees, brokerage charges, bank charges, registration fees, clearing and settlement charges, taxes and/or duties. Other Fees and Expenses The Funds may incur ongoing operational expenses, including but not limited to, accounting, auditing, tax preparation, legal, administration, and trading costs up to a fixed, predetermined expense limit which will be no greater than 50bps of Funds or SMAs Assets Under Management. Research and any additional expenses over the expense limit will be covered by the Firm. Sales Compensation The Firm and its Supervised Persons do not receive (directly or indirectly) any compensation from the purchase or sale of securities or investments for the Funds. LCIP and its Supervised Persons do not receive (directly or indirectly) sales commissions in connection with sales of interests in the Funds.

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

As discussed in Item 5 above, the Firm may be entitled to receive performance-based compensation in connection with investment advisory services provided. LCIP negotiates or arranges such performance fees with Investors before entering any advisory relationships. The receipt of performance-based compensation may create an incentive for the Firm to make investments that are riskier or more speculative than those the Firm would otherwise make in the absence of such incentive compensation. LCIP has addressed this conflict by focusing on long-term relationships with its Investors, by managing the Funds in accordance with the applicable advisory agreement and/or governing documents. LCIP has adopted a policy to allocate transactions and investment opportunities across multiple Funds on what the Firm believes to be a fair and equitable basis.

Item 7. Types of clients

LCIP provides investment management services to the Funds. Investors in the Funds primarily consist of institutional investors and other sophisticated investors including, but not limited to, pension funds, endowments, financial institutions, foundations, fund of funds, high net worth individuals and insurance companies. The minimum initial investment amount for the Funds and any additional subscription minimums is disclosed in the offering memorandum for the relevant pooled investment vehicle. In certain circumstances, minimum investment amounts may be amended by the Fund’s Board of Directors in consultation with the Firm but will never be lower than any applicable regulatory minimum.

Read the rest of Item 7 (66 more words)

Investors with SMAs will be required to enter into a separate Investment Management Agreement (“IMA”) with the Firm. The minimum initial or additional subscription amounts are set forth in the IMA or other governing documents, where applicable. LCIP may require a minimum account size, which will be determined on a case-by-case basis. The minimum initial investment amount in an SMA will not be lower than US$10,000,000.

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

Investment Objective The strategies (detailed below) aim to participate in the long-term total return of Global Equity Markets. The target is to outperform the MSCI USA Net Total Return Index USD (the "Benchmark"), or global variations of the Benchmark where specified, after deducting charges, over rolling five-year periods. The strategies will seek to achieve this objective by predominantly investing in the shares of companies that are listed on Regulated Markets. All Funds will employ a long-only strategy.

Read the rest of Item 8 (2,483 more words)

The strategies referenced in this brochure include the following:  Global Equity Select Strategy  Global Equity Strategy  Global Equity Income Strategy  US Equity Strategy Investment Philosophy The strategies will invest at least 80% of its Net Asset Value in shares of companies globally, including those in Developed Markets and Emerging Markets. There are no restrictions regarding sector and market capitalization. However, country and sector weights, including investment in the United States, will generally align with those of the Benchmark. A Fund may allocate up to 20% of its Net Asset Value to shares of listed companies in Developed and Emerging Markets outside of the United States. The strategies may also invest up to 10% of its Net Asset Value in other investment funds, known as collective investment schemes. A limited amount of assets, approximately 20% or less, may be held in cash for efficient portfolio management purposes and to manage the flow of investors' money in and out of the strategies. Investment and Research Process The investment strategies are focused on selecting investments using the corporate life cycle concept. The stages of the corporate life cycle, that LCIP uses in its investment selection process is based on the level of return on capital by companies and the evolution of this return. LCIP recognises that there are attractive investment opportunities at each stage of the corporate life cycle. Each company in the investible universe is classified by LCIP into one of the below five stages and this classification of individual stocks informs how investment opportunities are identified, and the investment portfolio is built.  Accelerating – companies with returns on capital that are improving rapidly irrespective of current level;  Compounding – companies which have either i) relatively stable returns on capital or ii) high returns on capital (i.e., returns which are well in excess of the cost of capital);  Fading – companies with high but fading returns on capital;  Mature – companies with returns on capital similar to the cost of capital; and  Turnaround – companies with returns on capital below the estimated cost of capital and where those returns are not materially improving.

The strategies will invest in companies that LCIP believes can create wealth for shareholders and are currently undervalued. An undervalued company is one whose price does not reflect the strength of its underlying business. LCIP identifies suitable companies by first using in-house screening tools which are quantitative scorecards that use a variety of financial metrics on individual companies (e.g. cash flow, margins, growth, return on capital) to rate stocks 1-100 on a series of dimensions primarily ‘Wealth Creation’, Valuation and Momentum. LCIP uses this quantitative information combined with some qualitative analysis to narrow down the investment universe from over 5,000 shares to around 600 for further qualitative analysis based upon the potential for shareholder wealth creation. LCIP then conducts deeper analysis to identify companies with the strongest evidence of long-term wealth creation. This involves researching publicly available information, such as annual, semi-annual and quarterly financial reports and sector analysis, supplemented with direct company contact when necessary. From this process, approximately 300 companies are selected for a valuation analysis to assess their intrinsic value. The most attractively priced companies from this group are considered for potential investment. The strategies do not intend to track the Benchmark, and investors should note that the Benchmark is being used for performance comparison purposes only. While the strategies may invest in investments which are constituents of the Benchmark, they will be actively managed, and portfolios will not be constrained by reference to any index. LCIP may use its discretion to invest in instruments which are not included in the Benchmark. The strategies will usually be invested in a concentrated portfolio of 25-45 holdings. The strategies may employ exchange traded or over-the-counter FDI, as more specifically described under Financial Derivative Instruments. The strategies may not enter into Securities Financing Transactions. LCIP employs a risk management process which helps it to accurately measure, monitor and manage the various risks associated with its investment in FDI (as detailed further below). The strategies will use the commitment approach to measure global exposure. While the strategies may use FDIs, such FDIs will only be used for Efficient Portfolio Management (“EPM”). The strategies are suitable for professional and institutional investors with an investment horizon of at least five years that seek capital growth via exposure to global equity and equity-related securities and who are willing to accept shorter-term fluctuations in price typically associated with such investments. Investors should have an understanding of investments in the securities listed above and note that there is a high risk of short-term capital loss compared to other investment types but with the potential to deliver higher investment returns over the minimum suggested timeframe. Please refer to the risk factors below. The general investment restrictions as set out in any IMA shall apply. The strategies are allowed to borrow up to 10% of its total Net Asset Value on a temporary basis. Risk Factors An investment in the strategies carry a high degree of risk including, but not limited to, the risks referred to below. There can be no assurance that the investment objective will be achieved. The following risks should be carefully evaluated before making an investment in the Strategies. All the risks discussed below apply equally to the strategies. Prospective investors should carefully evaluate the merits and risks of an investment in the context of their overall

financial circumstances. These are speculative securities. LCIP attempts to assess the following risk factors, and others, in determining the extent of the position the Funds will take in the relevant securities and the price it is willing to pay for such securities. However, such risks cannot be eliminated. Investment Risk Investments in securities are subject to normal market fluctuations and other risks inherent in investing in securities. Security prices may decline over short or extended periods due to general market conditions (e.g. economic, technological or political). Equities as a class have historically outperformed other types of investments over the long term. Individual stock prices, however, tend to go up and down more dramatically over the short term. These price movements may result from factors affecting individual companies or industries, or the securities market as a whole. Those assets with potentially higher long-term returns may also have a higher risk of losing money in the shorter term. LCIP's careful analysis of each company it invests in, aims to minimise this risk. Interest Rate Risk Changes in interest rates can influence the value and returns of investments. LCIP's careful analysis of detailed research in combination with diversified holdings, aims to reduce this risk. Liquidity Risk Funds may not be able to purchase or sell a security in a timely manner or at desired prices or achieve its desired weighting in a security. The risk management guidelines adopted by LCIP are designed to minimise liquidity risk through;  

Ensuring that there is no significant exposure to illiquid or thinly traded financial instruments; and Applying limits to ensure there is no undue concentration of liquidity risk to a particular counterparty or market.

Currency Risk Investing in assets denominated in a currency other than the Fund’s base currency may cause losses resulting from exchange rate fluctuations. Foreign governments may impose currency exchange restrictions, which could limit the ability to buy and sell certain foreign investments and could reduce the value of the foreign securities held. Foreign Investment Risk Investments in foreign companies may decline in value because of sovereign, political, economic or market instability; the absence of accurate information about the companies; risks of unfavourable government actions such as expropriation and nationalisation. Some countries may have different legal systems, taxation regimes, auditing and accounting standards with less governmental regulation and transparency and certain financial markets may be less liquid. In general, securities issued by companies in more developed markets, such as the U.S. and Western Europe, have lower foreign market risk. Securities issued in emerging or developing markets, such as Southeast Asia or Latin America, tend to have a higher foreign market risk. Some foreign exchanges are "principals' markets" in which performance with respect to a contract is the responsibility only of the individual member with whom the trader has entered

into a contract and not of the exchange or clearinghouse, if any. In the case of trading on such foreign exchanges, Funds will be subject to the risk of the inability of, or refusal by, the counterparty, to perform with respect to such contracts. Funds may not have the same access to certain trades as do various other participants in foreign markets. Due to the absence of a clearinghouse system on certain foreign markets, such markets are significantly more susceptible to disruptions. These risks may be higher when investing in emerging markets as set out further below under "Emerging Markets Risks". Market Risk Some of the recognised exchanges may prove to be illiquid or highly volatile from time to time and this may affect the price at which the Funds may liquidate positions to meet redemption requests or other funding requirements. Emerging Markets Risks The investment policy allows investment in emerging market countries and investors should be aware of risks attached to investing in such markets which could have a limited impact on the performance of the Funds. (a)

Political Risk

Performance may be affected by changes in economic and market conditions, uncertainties such as political developments, changes in government policies, the imposition of restrictions on the transfer of capital and in legal, regulatory and tax requirements. Funds may also be exposed to risks of expropriation, nationalisation and confiscation of assets and changes in legislation relating to the level of foreign ownership (b)

Settlement, Credit and Counterparty Risks

Settlement risk occurs when a transaction is not completed as duly agreed between the parties. This may be due to an error or omission in the necessary settlement, clearing or registration processes or due to the lack of creditworthiness of one of the parties to the transaction. Settlement systems in emerging markets may be less well organised than in developed markets. Thus, there may be a risk that settlement may be delayed and that cash or securities may be in jeopardy because of failures of or defects in the systems. In particular, market practice may require that payment shall be made prior to receipt of the security, which is being purchased, or that delivery of a security must be made before payment is received. In such cases, default by a broker or bank through whom the relevant transaction is effected might result in a loss being suffered by investing in or exposed to the performance of emerging market securities. Where Funds invest in markets where custodial and/or settlement systems are not fully developed, the assets which are traded in such markets and which have been entrusted to sub-custodians, in the circumstances where the use of such sub-custodians is necessary, may be exposed to risk in circumstances whereby the Depositary will have no liability. Counterparty risk occurs when a party to a contract fails to honour and defaults on its obligations thereunder. Funds which are party to these risks can incur considerable losses. LCIP aims to keep this risk to a minimum by regularly monitoring the counterparties. Funds will seek, where possible, to use counterparties whose financial status is such that this risk is reduced. However, there can be no certainty it will be successful in eliminating this risk,

particularly as counterparties operating in emerging markets frequently lack the substance or financial resources of those in developed countries. There may also be a danger that, because of uncertainties in the operation of settlement systems in individual markets, competing claims may arise in respect of securities held by or to be transferred to the Funds. Furthermore, compensation schemes may be non-existent or limited or inadequate to meet claims in any of these events. ( ) Liquidity Risk

Certain securities may be difficult or impossible to sell at the time and the price that the seller would like. The seller may have to lower the price to effect a secondary market sale, sell other securities instead or forego an investment opportunity, any of which could have a negative effect on fund management or performance. (a) Currency Risk

The Net Asset Value per Share will be computed in the Base Currency, whereas the Fund’s investments may be acquired in a wide range of currencies, some of which may be affected by currency movements of a more volatile nature than those of developed countries and some of which may not be freely convertible. It may not be possible or practical to hedge against the consequent currency risk exposure and in certain instances LCIP may consider it desirable not to hedge against such risk. Cross currency hedging transactions may be entered into solely for the purpose of efficient portfolio management. (b) Regulatory Risks and Accounting Standards

Disclosure and regulatory standards may be less stringent in certain securities markets than they are in developed countries and there may be less publicly available information on the issuers than is published by or about issuers in such developed countries. Consequently, some of the publicly available information may be incomplete and/or inaccurate. In some countries the legal infrastructure and accounting and reporting standards do not provide the same degree of shareholder protection or information to investors as would generally apply in many developed countries. In particular, greater reliance may be placed by the auditors on representations from the management of a company and there may be less independent verification of information than would apply in many developed countries. The valuation of assets, depreciation, exchange differences, deferred taxation, contingent liabilities and consolidation may also be treated differently from international accounting standards. (c) Custody Risks

Local custody services may be underdeveloped in the emerging market countries in which a Fund may invest and there is a transaction and custody risk involved in dealing in such markets. In certain circumstances the Funds may not be able to recover or may encounter delays in the recovery of some of its assets. Such circumstances may include uncertainty relating to, or the retroactive application of legislation, the imposition of exchange controls or improper registration of title. In some emerging market countries evidence of title to shares is maintained in "book-entry" form by an independent registrar who may not be subject to effective government supervision, which increases the risk of the registration of the Fund’s holdings of shares in such markets being lost through fraud, negligence or mere oversight on the part of such independent registrars. The costs borne by the Funds in investing and holding investments in such markets will generally be higher than in organised securities markets. (d) Increased Risk of Fluctuation in Value

The value of the Funds may fluctuate more than those that invest predominantly in developed markets.

Item 9. Disciplinary information

LCIP has not been subject to any disciplinary action, whether criminal, civil, or administrative (including regulatory) in any jurisdiction. Likewise, no Supervised Persons of LCIP has been subject to such action.

Item 10. Other financial industry activities and affiliations

Broker Dealer Registration Status LCIP nor any of its Supervised Persons are registered as broker-dealers or registered representatives of broker-dealers, and no applications are pending to register the Firm or any of its Supervised Persons with the SEC as a broker-dealer or registered representative of a broker-dealer. Commodity Pool Operator, Commodity Trading Adviser, Futures Commission Merchant Registration Neither LCIP nor any of its Supervised Persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities.

Read the rest of Item 10 (377 more words)

Financial Conduct Authority LCIP is authorised and regulated by the Financial Conduct Authority (“FCA”) in the UK as a Collective Portfolio Management Investment Firm (“CPMI”) which is only permitted to carry on the activities specified in FUND 1.4.3R (1) to (6) or any successor provision. LCIP’s Firm Reference Number is 1024338. The authorisation that LCIP holds means it is neither permitted to deal with retail investors, nor permitted to hold investor money. The rules of the Financial Conduct Authority require all persons performing a senior management function to be registered as holding a “Senior Management Function” under the FCA’s Senior Managers and Certification Regime. LCIP maintains a record of any potential conflicts of interest, including external appointments held by all staff, including the Supervised Persons listed above. This list is updated as necessary, and completeness is confirmed on an annual basis. None of the relationships notified by the individuals concerned create a material conflict of interest between LCIP and its Investors or between the Funds. As outlined in Item 4, Pinnacle is a minority shareholder in LCIP. Pinnacle is an Australianbased multi-affiliate investment management firm. Its mission is to establish, grow and support a diverse stable of world-class investment management firms. Pinnacle is authorised by the Australian Securities & Investments Commission, AFSL 322140, authorising it to carry on a financial services business. Pinnacle provides services to LCIP including but limited to; distribution/sales, finance, middle office support, risk and compliance and IT infrastructure. Other Material Relationships LCIP does not have other relationships or arrangements that are material to its advisory business or to its Investors and neither the Firm nor any of its Supervised Persons have relationships with any of the following related persons: (i) a broker-dealer, municipal securities dealer, or government securities dealer or broker; (ii) an investment company or other pooled investment vehicle; (iii) a futures commission merchant or commodity trading advisor; (iv) a banking or thrift institution; (v) an accountant or accounting firm; (vi) a lawyer or law firm; (vii) an insurance company or agency; (viii) a pension consultant; and (ix) a real estate broker or dealer sponsor or syndicator of limited partnerships.

LCIP does not recommend or select other investment advisers for its Investors in return for compensation directly or indirectly from those advisers.

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

Personal Trading Code of Ethics In order to address conflicts of interest, the Firm has adopted a Code of Ethics pursuant to Rule 204A-1 under the Investment Advisers Act of 1940 (the “Advisers Act”) which is applicable to all partners, officers, managers, members, and employees (collectively, “Employees”). The Code of Ethics generally sets the standard of ethical and professional business conduct that LCIP requires of its Employees, requires Employees to comply with applicable federal securities laws and regulations, and sets forth provisions regarding personal securities transactions by Employees.

Read the rest of Item 11 (438 more words)

Additionally, the Code of Ethics sets forth the Firm’s policies and procedures with respect to material, non-public information and other confidential information, and the fiduciary obligations that LCIP and each of its Employees owe to each Investor. The Code of Ethics is circulated at least annually to all Employees, and each Employee at least annually must certify in writing that he or she has received and followed the Code and any amendments thereto. The Firm will provide a copy of the Compliance Manual and Code of Ethics to any Investor or prospective Investor, free of charge, upon request. Participation or Interest in Client Transactions The Firm serves as the investment adviser to the Funds. Employees, affiliates of the Employees, and relatives of the Employees may make investments in the Funds. The Firm may or may not receive any compensation from such investments from employees. LCIP and its Employees have a financial interest in the Funds through an incentive allocation or a direct investment interest in the Funds. As such, LCIP could be considered to have recommended to Investors that they buy or sell securities or investments in which the Firm or a related person has some financial interest. Personal Account Dealing All applicable employees of LCIP must provide duplicate copies of brokerage statements or quarterly attestations to Compliance. These records are used to monitor compliance with the Compliance Manual and Code of Ethics. The personal account dealing policy requires that:

  

Trades are subject to a general 4 weeks minimum holding period; Securities cannot be traded if they are on the Firm’s restricted list; Securities cannot be traded in collective investment vehicles managed by a client of LCIP, where LCIP acts as investment manager or investment adviser;  If permission to trade is granted, the trade must be executed within 24 hours (with certain exceptions which are 48 hours); and  Employees must seek pre-approval to acquire beneficial ownership of a security in an initial public offering (“IPO”) or limited offering. The above policy extends to the trading of employees and certain other persons who have a relationship with the Firm or its personnel (“Covered Persons”). Covered Persons must obtain written authorization from the Chief Compliance Officer (“CCO”) prior to purchasing, selling, or transferring certain types of securities, or exercising any option which

is traded on exchanges in certain markets. Employees may not engage in any outside business activities or invest in private companies without obtaining prior authorisation from the Chief Compliance Officer. Any request for an exception under this policy must be submitted in writing to the Chief Compliance Officer with sufficient information for consideration.

Item 12. Brokerage practices

Best Execution In effecting securities transactions, LCIP will take all sufficient steps to obtain best execution of orders for the Funds on a consistent basis. LCIP will assess best execution by considering execution factors which include price, costs, speed, likelihood of execution and settlement, order size, execution reliability of executing broker, nature, venue, or any other consideration relevant to the execution of the order. Accordingly, the commissions charged by any such broker may be greater than the amount another firm might charge if the Firm determines in good faith that the amount of such commissions is reasonable in relation to the value of the brokerage services and research information provided by such brokers.

Read the rest of Item 12 (405 more words)

Trade Aggregation The aggregation of transactions allows an investment adviser to execute transactions in a more timely, equitable, and efficient manner and seeks to reduce overall commission charges to Investors. LCIP’s policy is to aggregate transactions where possible and when advantageous to Investors. In these instances, Investors participating in any aggregated transactions will receive an average share price and transaction costs will be shared equally and on a pro-rata basis. Trade Allocation LCIP’s policy prohibits any allocation of trades in a manner that would allow Investors to receive more favourable treatment than other Investors. Principal Transactions / Cross Trades In a “principal transaction,” an investment adviser, acting for its own account, buys a security from, or sells a security to, an Investors account. LCIP does not engage in principal transactions. Cross Trades will only be undertaken where it can be shown that the cross trade is not likely to be to the detriment of any relevant Investor and is consistent with the investment objectives and strategy, for example, a cross trade cannot be undertaken merely to provide liquidity to one Investor. Any cross trade will be executed via an approved counterparty. If LCIP wishes to engage in a cross trade, it will first obtain the Investor’s consent prior to engaging in such transaction. LCIP may, however, rely on an Investor’s general "blanket" approval for cross trades and is not required to obtain approval for each such trade unless this is a requirement of the Investor. To the extent that cross trades may be viewed as principal transactions due to the ownership interest in the Funds or other Investors by the Firm and/or its Employees, the Firm will comply with the requirements of Section 206(3) of the Advisers Act. Soft Dollars At this time, LCIP has not entered into any formal soft dollar arrangements with brokerage firms and does not intend to pay for broker research through trading commissions as LCIP wishes to avoid any potential conflict between broker choice for execution purposes and broker research obtained. Should any soft dollar arrangements be entered into in the future, the Firm will establish an appropriate soft dollar policy and will adhere to the procedures set

out in the policy when engaging in soft dollar practices to ensure that such arrangements comply with the safe harbour requirements of Section 28(e) of the Exchange Act. The Firm’s soft dollar policy will also be disclosed in the relevant offering documents.

Item 13. Review of accounts

Review of Accounts The Funds are reviewed and reconciled on a daily basis by the investment team to ensure that the structure and individual securities held are suitable and consistent with the objectives and strategies. In addition, LCIP also monitors the Funds to help ensure conformity with investment objectives and guidelines. The Firm engages in active management and frequent transactions and, accordingly, performs daily trade and cash reconciliation. The Firm has also engaged an independent administrator to prepare monthly unaudited investor statements reviewing the Fund’s performance for the month. Reporting to Clients The Funds prepare the annual financial statements in accordance with UK GAAP or US GAAP in the case of US domiciled funds.

Read the rest of Item 13 (66 more words)

Copies of the audited financial statements will be issued to all US investors within 120 days of the Fund’s fiscal year-end. The Firm will prepare and issue an investor newsletter on a quarterly basis. Fund Administrator’s will issue periodic account statements to Investors consistent with the offering documents. SMAs may receive weekly and/or monthly reporting from LCIP, among other reporting, as specified in the governing documents.

Item 14. Client referrals and other compensation

Currently, the Firm does not receive any economic benefit from anyone, other than its Investors, for providing investment advice and other advisory services. The Firm does not compensate third parties who provide referrals for Investors. LCIP currently has an agreement with its related party, Pinnacle whereby Pinnacle is compensated for providing marketing and distribution services. Pinnacle receives a fee based on a percentage of management fee revenues actually received by LCIP from Investors who allocate capital to the Firm to invest via a separately managed account or an established private fund investment vehicle. Such fees are paid by the Firm and will not be charged to its Investors.

Read the rest of Item 14 (41 more words)

Due diligence has been carried out, and regular reviews continue to be undertaken, on Pinnacle to ensure that applicable regulatory registrations are in place and that Pinnacle has adequate controls and procedures to monitor compliance with selling procedures and suitability requirements.

Item 15. Custody

LCIP does not maintain direct custody over Investor funds or securities. All assets are held at qualified custodians. The Funds have their own fund administrator and the Funds have their own custodian, who are independent of the Firm. Investors will receive monthly account statements from each administrator. The Firm urges investors to carefully review such statements and compare such official records to the reports that LCIP may provide to such investors.

Item 16. Investment discretion

LCIP possesses discretionary portfolio management authority over the Funds with respect to asset allocations and direct investments as per the advisory agreements and offering documents in place. The Firm has the authority to determine (i) the securities to be purchased and sold for the Investor account and (ii) the amount of securities to be purchased or sold for the Investor account.

Item 17. Voting client securities

Where LCIP has the responsibility for voting proxies, the Firm will take measures reasonably designed to ensure that they are voted in the best interest of its Investors, which generally means voting with a view to enhancing the value of Investor securities. Financial interest of Investors is the primary consideration in determining how their proxies should be voted. The Firm may also refrain from voting in certain circumstances. The Firm may generally also accept the authority to vote proxy or corporate actions on behalf of any potential SMAs.

Item 18. Financial information

LCIP is not aware of any financial condition that is likely to impair its ability to meet contractual and fiduciary commitments to Investors. The Firm has not been the subject of any bankruptcy proceeding.

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