Firm Description
Aperture Investors, LLC (the “Adviser” or “Aperture”), a Delaware limited liability company founded in 2018,
serves as the investment adviser to multiple series of The Advisors’ Inner Circle Fund III (the “Trust”), each
series a separate fund (the “Mutual Funds”) registered under the Investment Company Act of 1940, as
amended (the “1940 Act”). Aperture has been appointed investment manager to multiple sub-funds (each
a “UCITS”) of the Aperture Investors SICAV (the “SICAV”), a single legal entity incorporated as an umbrella
fund and authorized by the Commission de Surveillance du Secteur Financier (the “CSSF”) which is the
Luxembourg supervisory authority of the financial market. Aperture Investors UK, Ltd (“Aperture UK”), an
investment firm licensed by the Financial Conduct Authority (“FCA”), is a wholly-owned subsidiary of
Aperture and serves as the investment manager to certain UCITS. Aperture acts as the sub-adviser to a
portion of an open-end investment company under the 1940 Act, a portion of an Undertaking for Collective
Investment in Transferable Securities authorized by the Central Bank of Ireland, and an exempted company
formed under the laws of the Cayman Islands (together, the “Sub-Advised Funds”). Aperture provides
advisory services to United States and Cayman Islands-domiciled privately placed investment vehicles (the
“Private Funds”, collectively with the Mutual Funds, UCITS, and Sub-Advised Funds the “Clients” or the
“Funds”).
Aperture is jointly owned by Peter Kraus, Chairman and Chief Executive Officer (the “CEO”) of the Adviser,
and Generali Alpha Corp, a wholly owned subsidiary of Generali Holding S.p.A., which is an entity owned
jointly by Generali France S.A., Generali Deutschland AG, and Assicurazioni Generali S.p.A. (collectively,
“Generali”). Assicurazioni Generali S.p.A. is an Italian insurance company. As of February 1, 2023, the
Adviser had approximately $4,319,022,384 in net assets under management. Please note that this is an
unaudited estimate and the methodology used to calculate net assets under management differs from the
methodology used to calculate “regulatory assets under management” for purposes of responding to Item
5.f(2) of Part 1 of Aperture’s SEC Form ADV. Additional detail concerning the methodology is available
upon request.
Overview of Aperture’s Advisory Services
Aperture’s advisory services are typically provided on a discretionary basis, meaning that Aperture has full
discretion to determine, consistent with Clients’ investment objectives and restrictions, which securities and
the total amount of securities that should be bought or sold for Clients’ accounts. Aperture may buy, sell, or
otherwise trade securities or engage in transactions around the globe, including, but not limited to, equity,
debt, derivatives, securities of other investment companies, illiquid investments, convertible securities,
American depository receipts (“ADRs”), restricted securities, securities lending, and short sales. Aperture
provides advisory services in several investment styles, including international equity, global equity,
European equity, European small cap equity, North American small cap equity, long/short credit, emerging
markets credit, and short duration credit.
In general, Aperture manages the following types of products:
Mutual Funds
The Trust and the Adviser have entered into an investment advisory
agreement (the “Advisory Agreement”)
with respect to the Mutual Funds. Under the Advisory Agreement, the Adviser serves as the investment
adviser and makes investment decisions for each Mutual Fund and continuously reviews, supervises, and
administers the investment program of each Mutual Fund, subject to the supervision of, and policies
established by, the Board of Trustees of the Trust (the “Board of Trustees”). Aperture advises Mutual Funds
that are diversified and that are non-diversified, as those terms are defined in the 1940 Act. Non-diversified
means that a greater percentage of the total assets of the Mutual Fund may be invested in the securities of
fewer issuers than a diversified fund, which increases the risk that a change in the value of any one
investment held by a fund could affect the overall value of the fund more than it would affect that of a
diversified fund holding a greater number of investments. Accordingly, the value of the shares of a non-
diversified fund may be more susceptible to any single economic, political, or regulatory event than the
shares of a diversified fund would be.
Aperture’s discretionary investment authority in managing the Mutual Funds may be limited by contractual
terms, applicable laws and regulations (e.g., the 1940 Act), and internal risk guidelines.
UCITS
Generali Investments Luxembourg S.A. (the “Management Company”), with the consent of the Board of
Directors of the UCITS, has delegated to Aperture the discretion, on a daily basis, but subject to the overall
control and responsibility of the Management Company and the SICAV, to purchase and sell securities as
agent for the SICAV for certain UCITS and to otherwise manage the portfolios of such UCITS for the account
and in the name of the SICAV. As discussed above, Aperture UK serves as the investment manager to
certain UCITS.
Aperture’s discretionary investment authority in managing the UCITS may be limited by contractual terms,
applicable laws and regulations (e.g., the Luxembourg law of 17 December 2010 relating to undertakings
for collective investment, as may be amended from time to time, the “UCI Law”), and internal risk guidelines.
Sub-Advised Funds
Aperture has entered into an investment sub-advisory agreement with a registered investment adviser to
render portfolio management services to the Sub-Advised Funds, subject to the oversight and direction of
the investment adviser and the respective boards of directors for each Sub-Advised Fund. Aperture manages
the assets in accordance with investment strategies, as agreed to by Aperture and the investment adviser.
Private Funds
Aperture has entered into an investment management agreement (the “Management Agreement”) with the
Private Funds and their general partner (the “General Partner”), a related person of Aperture. The
Management Agreement grants Aperture discretionary investment and trading authority over the assets of
the Private Funds. Aperture’s management of, and the terms of any investor’s investment in, the Private
Funds are governed by the organizational documents, offering memorandum, limited partnership agreement
and subscription agreement (collectively, the “Governing Documents”). Specific investment objectives and
strategies are detailed in the respective Governing Documents. The Private Funds are privately placed
investment vehicles intended for sophisticated investors and institutional investors.