A. Old Bridge Capital Management Private Limited (the “Firm”) is a private limited
company incorporated in India on December 15, 2015. The majority shareholder of the
Firm is Kenneth Andrade (the “Principal”). The Firm is controlled by the Principal.
The Firm is registered with The Securities and Exchange Board of India (“SEBI”) as a
Portfolio Manager vide registration no. INP000005174 dated June 22, 2016. In addition,
the Firm has been approved by SEBI to act as an Investment Manager to Old Bridge
Capital AIF (the “Trust”), which is an alternative investment fund established in India
as a trust under the Indian Trusts Act 1882 and is registered as Category III Alternative
Investment Fund under the Securities and Exchange Board of India (Alternative
Investment Funds Regulations, 2012). Further the Firm has received in-principle
approval from SEBI for sponsoring a mutual fund in India on October 12, 2022.
The Firm advises primarily on listed Indian equity securities.
B. As a portfolio manager, the Firm provides discretionary and non-discretionary
advisory services to certain individuals and entities (collectively, “Separate Clients”).
Separate Clients include individuals, high net worth individuals, businesses, third-
party investment managers, institutional clients and other entities. Separate Client
services will be structured to address the requirements of those clients, and the Firm
may either (a) accept discretionary management authority for a Separate Client or (b)
offer only non-binding investment recommendations and investment research for a
Separate Client. These non-binding recommendations and research may, as instructed
by the Separate Client, be provided to another investment manager hired by the
Separate Client to consider and effect non-discretionary advice provided by the Firm.
Provision of non-discretionary research service to a third-party investment manager
may create certain conflicts of interest, since the Firm also provides discretionary
advisory services based on the same research. In order to address these potential
conflicts of interest, the following procedure has been implemented:
• For existing ideas, i.e. when the Firm has already taken position for its discretionary
clients, the advice provided to non-discretionary clients includes appropriate
disclosures with respect to the Firm’s existing positions.
• For new ideas, the delivery of investment recommendations to non-discretionary
clients and execution for its discretionary clients are simultaneous.
As an investment manager to the Trust, the Firm currently manages following two
schemes of the Trust:
i. Micro Strategies Fund (“MSF”), an open – ended scheme of the Trust. MSF was
established in May 2018 and offers its units only to non- U.S. investors.
ii. Long Term Equity Fund (“LTEF”), an open-ended scheme of the Trust. LTEF was
established in February 2019 and offers its units to Non-resident Indians and Indian
investors.
Note: Vantage Equity Fund (“VEF”) and NRI Vantage Equity Fund (“NRI VEF”), close–
ended schemes of the Trust had matured and closed on July 23, 2021 and March 20,
2022 respectively.
Schemes of the Trust, launched from time to time, including the schemes referred above
are hereinafter collectively referred as the “Fund.”
The Firm has discretionary authority over the assets of the Fund. This document is not an
offer to sell or a solicitation of offers to buy any units or other securities of the Fund.
Full information on the investment strategy, fees, expenses, risks, and potential
conflicts of interest of the Fund are set forth in the governing documents of the Fund.
C. The Firm tailors its advisory services to the Fund in accordance with the Fund’s
investment objective and strategy as disclosed in the governing documents of the Fund.
The Firm tailors its discretionary advisory services that it provides to Separate Clients
in accordance with each Separate Client’s individual circumstances, including the tax
profile of the client, client goals and risk tolerances, and the needs of the client for,
among other things, cash flow and investment stability. Separate Clients may impose
restrictions on investing in specified securities or types of securities, as mutually
agreed with the Firm.
D. The Firm does not participate in any wrap fee programs.
As of March 31, 2023, the Firm manages $ 276,881,598 of client (Separate Clients and
Fund) assets on a discretionary basis. The Firm does not manage any client assets on a
non- discretionary basis; however, the Firm does provide non-discretionary research
advice to Separate Clients that it does not manage.