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A. Locus Investment Group Ltd.
Locus Investment Group Ltd. (“Locus”) is a Limited Company registered in the Republic of
Mauritius. Locus is controlled by Akhil Dhawan. Locus has recently registered as an investment
adviser with the Securities and Exchange Commission under the Investment Advisers Act of
1940.
For purposes of this brochure, the “Adviser” means Locus, together with its affiliates that provide
advisory services to and/or receive advisory fees from its Fund clients. Such affiliates may or may
not be under common control with Locus, but possess a substantial identity of personnel and/or
equity owners with Locus. These affiliates may be formed for tax, regulatory, or other purposes
in connection with the organization of the Fund(s).
B. Advisory Services Offered
Presently, the Adviser provides discretionary asset management services to two proprietary
funds (“Fund(s)”) and one institutional account whose investment objective is to capitalize on
the long-term growth prospects and competitive advantages of India and deliver superior long-
term returns to investors, while attempting to minimize the risk of capital loss, through a
rigorous and disciplined investment process and careful portfolio construction and
diversification. The Fund(s) invest primarily in publicly traded or listed Indian equity
and equity-
related securities, including, but not limited to, common shares, preferred shares, convertible
debt, options, warrants, and partnership or trust interests, to the extent permitted by Indian law.
The Adviser provides investment supervisory services to its Fund client(s) in accordance with a
limited partnership agreement or separate investment and advisory, investment management or
portfolio management agreements (each, a “Management Agreement”). The Adviser provides
investment advice directly to the Fund(s), subject to the discretion and control of the applicable
general partner, and not individually to the investors in the Fund(s). Investment restrictions for
the Funds, if any, are generally established in the organizational or offering documents of the
applicable Fund.
Fund(s) investment strategy, organization structure, risks, and related information concerning
such Fund client(s) are disclosed in the applicable offering and governing documents of such
Fund.
Locus may engage sub-advisers, including India domiciled sub-advisers, to assist in the
management of the Fund(s). Such sub-advisers may be affiliates and may not be subject to U.S.
laws.
C. Client Assets Under Management
As of December 31, 2023, the firm had $448,460,936 in discretionary assets under management.
Item 5: Fees and Compensation