ITEM 5 – TYPES OF CLIENTS -------------------------------------------------------------------------------------------------- 6 ITEM 6 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ---------------- 6 ITEM 7 – DISCIPLINARY INFORMATION--------------------------------------------------------------------------------- 9 ITEM 8 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ------------------------------ 9 ITEM 9 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ----------------------------------------------------------------------------------------------------------- 10 ITEM 10 – BROKERAGE PRACTICES ------------------------------------------------------------------------------------- 11 ITEM 11 – REVIEW OF ACCOUNTS ---------------------------------------------------------------------------------------- 13 ITEM 12 – CLIENT REFERRALS AND OTHER COMPENSATION ---------------------------------------------- 14 ITEM 13 – CUSTODY ------------------------------------------------------------------------------------------------------------- 14 ITEM 14 – INVESTMENT DISCRETION ---------------------------------------------------------------------------------- 14 ITEM 15 – VOTING CLIENT SECURITIES ------------------------------------------------------------------------------- 15 ITEM 16 – FINANCIAL INFORMATION ---------------------------------------------------------------------------------- 15 Item 1 – Material Changes Since our Form ADV Part 2A brochure filed in March 31, 2023, there are no material changes to report.
Item 2 – Advisory Business FTIM is a private limited company formed under the laws of Singapore which has been in the investment advisory business since 2009. FTIM has been 100% owned by FTIM’s founder, Mr. Rajesh Sachdeva, since its formation and Mr. Sachdeva acts as chief executive officer and portfolio manager. We provide discretionary investment advisory services to a long only equity oriented private fund, a private equity fund (the “FTIM Funds”), and an institutional long only separate account (the “Separate Account” and collectively with the FTIM Funds, the “FTIM Accounts”), each focused-on Asia Ex-Japan markets and companies. We seek to make long investments in companies that address large market opportunities in attractive industry structures and are run by committed management teams and generate high returns on capital. As of December 31, 2023, FTIM managed net assets of approximately $227 million on a discretionary basis in the FTIM Accounts. FTIM does not manage assets on a non-discretionary basis. FTIM provides individualized investment advice to each FTIM Account. While the long only FTIM Accounts are generally invested in the same securities long, the different FTIM Accounts have different levels of concentration and overall have different investments, and each FTIM Account client is expected to be able to impose various non-binding investment and other guidelines on FTIM. Further, certain share series of the FTIM Funds may be subject to certain separate investment restrictions or limitations. FTIM does not provide individualized advice to investors within the FTIM Funds and therefore investors should consider whether a particular FTIM Fund meets their investment objectives and risk tolerance prior to investing. FTIM may enter into “side letters” or similar agreements with certain investors in the FTIM Funds granting the investor certain specific rights, benefits, or privileges that are not made available to other investors. Investors and prospective investors in each FTIM Fund should refer to the confidential private placing memorandum and other governing documents for each FTIM Fund (the “Governing Documents”) for more complete information on the investment objectives and investment restrictions with respect to a particular FTIM Fund. There is no assurance that the investment objectives will be achieved. As used herein, the term “client” generally refers to each FTIM Fund and, if applicable, the beneficial owner of the Separate Account. Item 3 – Fees and Compensation Each investor in an FTIM Account is typically charged a management fee equal to a percentage of net assets and an annual performance fee or special allocation equal to a percentage of the net appreciation of such fund at the end of each calendar year (over an index related benchmark in certain instances), which are paid/allocated directly to FTIM or to an affiliate of FTIM. Certain expenses, which include reimbursements to FTIM, are also the responsibility of the FTIM Accounts (and thus the investors in the FTIM Funds) as described below. Similar provisions to those described in this paragraph are expected to apply to any Separate Account. FTIM’s current fee schedule is generally as follows:
• Management Fee: Long Only – 1% annually Performance Fees/Special Allocations: Long Only 10% - 30% annually Fees vary for different FTIM Accounts and investors with respect to FTIM Funds depending, for example, on the investment strategy employed, the date an investment was made or the amount invested. In calculating performance-based fees and special allocations, any loss (whether an absolute loss or a loss relative to a benchmark, depending on applicable terms) in an FTIM Account is carried forward so that no performance-based

fees or special allocations are charged to or deducted from the FTIM Account until any prior loss has been recouped, subject to certain adjustments (i.e., subject to a loss carry forward or high water mark or after deduction of management fees depending on the applicable terms governing the calculations). Management fees for the FTIM Accounts are ordinarily paid monthly or quarterly in arrears while performance-based fees and special allocations are generally also paid or deducted annually in arrears, or upon withdrawal of an investment in an FTIM Fund. Fees are invoiced by FTIM and paid by the administrator for the relevant FTIM Accounts. The management fees, performance-based fees and special allocations applicable to certain investors in an FTIM Fund or Separate Account clients, including employees, affiliates and related parties of FTIM as well as third parties, may be waived or modified down without entitling any other investors to a waiver or modification. Depending on the terms of investment, investors in the FTIM Funds may withdraw all or a portion of their investment, subject to certain minimum dollar requirements (in FTIM’s discretion), effective as of the beginning of a particular quarter with prior written notice (depending upon the terms of the particular FTIM Fund). A Separate Account agreement (if applicable) is terminable as mutually agreed by the parties or as specified in the relevant agreement. Upon termination of any Separate Account or an FTIM Fund, any prepaid, unearned fees (if applicable) are expected to be promptly refunded, and any earned, unpaid fees are expected to be due and payable. FTIM’s compensation is exclusive of brokerage commissions, transaction fees, custodial fees, and other costs and expenses that are incurred by an FTIM Account. Clients should expect to incur other charges imposed by custodians, brokers, or other counterparties, as well as interest and commitment fees on loans and debit balances, research, research-related (such as travel and communications expenses) and data service costs, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Clients also bear certain operating expenses, including administration, accounting, communications including marketing/investor relations and marketing/investor relations- related costs (including travel costs), back office and middle office services and related costs, tax, legal and regulatory costs (including but not limited to FTIM’s regulatory and legal costs in connection with registration and ongoing regulation as an investment manager in Singapore (with the Monetary Authority of Singapore), the United States (with the SEC) and other jurisdictions, as applicable, and including advice of counsel in connection with preparation of regulatory forms including this Form ADV Part 2A), software and technology consultant (including cloud consulting) fees and expenses, and directors’ fees and expenses and other costs and expenses disclosed in the relevant private placing memorandums. With respect to the FTIM Funds, certain operating expenses (generally excluding brokerage, prime brokerage and custodian fees and costs) are subject to expense caps as disclosed in the relevant private placing memorandums. Each FTIM Account pays its expenses directly or reimburses FTIM, as instructed by FTIM, for expenses paid on the FTIM Account’s behalf or for its benefit. The expenses incurred by each FTIM Account vary depending on the nature of the operations and activities of the FTIM Account, and each FTIM Account’s respective Governing Documents describe them in detail. FTIM seeks to allocate expenses attributable to the FTIM Accounts that are incurred on behalf of multiple FTIM Accounts fairly among them, in accordance with one or more allocation protocols established by FTIM from time to time. FTIM believes such allocation protocols are reasonable; however, the allocation of expenses can involve subjective determinations and conflicts of interest (e.g. allocating costs only to those FTIM Accounts which can bear them), and other reasonable options may exist that may yield different results, including results that would be more beneficial to one or more FTIM Accounts and less beneficial to FTIM. FTIM, its affiliates and FTIM Accounts derive direct and indirect benefits from these expense provision as such provisions provide for the payment of expenses (or portions thereof) that it would otherwise be required to pay entirely by itself. See Item 12 (Brokerage Practices) below for more information about the brokerage commissions that will be incurred by clients of FTIM. All investors in FTIM Funds should review the Governing Documents for the relevant FTIM Fund for more complete information on the fees payable, allocations deductible and expenses payable or reimbursable with respect to a particular FTIM Fund. The FTIM Accounts charge performance fees and deduct performance-based special allocations with respect to its clients, including the FTIM Funds. Certain clients and investors may be charged different performance-based fees and special allocations or, in certain circumstances, no performance-based charges or deductions. Performance-based compensation and other arrangements based on profitability may create an incentive for FTIM to recommend investments that may be riskier or more speculative than those that would be recommended under different arrangements. Such incentive arrangements may also create an incentive to favor higher fee-paying accounts over other client accounts in the allocation of investment opportunities. FTIM has adopted procedures designed to ensure that all investment opportunities are allocated among clients in a manner that is fair to all clients over time, and to prevent conflicts of interest from improperly influencing the allocation of investment opportunities or otherwise resulting in any client being improperly favored over any other client. Among the factors that may be considered by FTIM in allocating trades among clients are: investment strategies, policies, guidelines or restrictions applicable to each specific client; tax considerations; cash availability; liquidity requirements for payment of redemptions or other purposes; inflows of capital; risk tolerances and risk management; restrictions under ERISA or other applicable laws or regulations; available credit lines; counterparty arrangements and availability; account size; and hedging objectives and activity. FTIM staff will periodically review investment positioning between different FTIM Accounts to help ensure that any differences in investment exposures are intentional and appropriate. Investors in the FTIM Funds should refer to the Governing Documents of each FTIM Fund for information on performance-based compensation/incentive arrangements relating to each FTIM Fund.