Overview
General Description of Advisory Firm
Complus (the “Investment Manager” or the “Firm”) was founded by Kam Kwok Ching and is a
limited company incorporated in Hong Kong and registered under the business registration
ordinance of Hong Kong on January 24, 2011. It is also licensed with the Securities and Futures
Commission in Hong Kong and the U.S. Commodity Futures Trading Commission in the United
States. Complus is beneficially owned by Complus Investment Limited, Complus Holdings
Limited, and Kam Kwok Ching.
Complus has an affiliate adviser, Complus Asset Management (Singapore) Pte. Ltd. with a
Monetary Authority of Singapore Capital Markets Services License (License No. CMS100986),
(“CAMS”, the “Manager” or the “Sub-Adviser”) which is also an SEC approved Registered
Investment Adviser. Complus also has an affiliate entity, Complus Asset Management (UK)
Limited (“CAMUK”) that is authorised (reference number: 999167) by the Financial Conduct
Authority in the United Kingdom, registered with the National Futures Association (“NFA”) as
Commodity Pool Operator and approved by SEC as a Registered Investment Adviser.
Description of Advisory Services
Complus provides discretionary investment management services for interest rate and currency
markets in Asia for investors that invest in managed accounts (“Managed Accounts”). Complus
also operates certain pooled investment vehicles, which are the Complus Asia Fixed Income Fund,
Complus Asia Macro Master Fund Ltd and Complus Asia Macro JPY Fund
(collectively “Funds”).
The Funds are not registered under the Securities Act of 1933, as amended (the “Securities Act”),
and the Funds are not registered under the Investment Company Act of 1940, as amended (the
“Investment Company Act”). Accordingly, shares in the Funds are offered exclusively to investors
satisfying the applicable eligibility and suitability requirements to private placement transactions
within the United States or in non-United States transactions, and only by means of an offering
memorandum.
All discussions of clients’ investment terms in this document, including but not limited to their
investments, strategies, fees and other costs, conflicts of interest and relevant material risks are
qualified in their entirety by reference to the relevant offering memorandum and governing
documents (with regard to the Funds) and the relevant investment management agreements and
disclosure documents (with regard to the Managed Accounts).
Wrap Fee Programs
Complus does not participate in or offer wrap fee programs.
Clients Assets
As of 31 December 2023, Complus, CAMS, and CAMUK had regulatory assets under
management of approximately US$ 4,070,000,000 and managed net assets under management of
approximately US$ 2,685,000,000.
All assets are managed on a discretionary basis.
As set out in Item 10 “Other Financial Industry Activities and Affiliations” in rendering investment
management services Complus also uses the resources of its affiliates, CAMS and CAMUK.