ADVISORY BUSINESS A. General Description of Advisory Firm. 1. Alua Capital Management LP Alua Capital Management LP (the "Investment Adviser" "we," and "us"), is a Delaware limited partnership that was formed in 2020. We only have one office, which is located in New York City. We are controlled by our principal owners, Thomas W. Purcell, Jr. and Marco A. Tablada (the "Principal Owners"), who act as the co-managing members of our general partner, Alua Capital GP LLC, a Delaware limited liability company (the "Investment Adviser General Partner"). The Investment Adviser General Partner has ultimate responsibility for our management, operations and investment decisions. 2. Alua Capital Advisors LLC Our registration on Form ADV also covers Alua Capital Advisors LLC (the "Fund General Partner"), a limited liability company organized under the laws of the state of Delaware. The Fund General Partner is an affiliate of the Investment Adviser and it serves as the general partner of Funds (as defined below) that are U.S. or offshore partnerships. The Fund General Partner's facilities and personnel are provided by the Investment Adviser. The Principal Owners are the principal owners and the managing members of, and control, the Fund General Partner. B. Description of Advisory Services. This Brochure generally includes information about us and our relationships with our clients and affiliates. While much of this Brochure applies to all such clients and affiliates, certain information included herein applies to specific clients or affiliates only. 1. Advisory Services. We serve as the investment adviser, with discretionary trading authority, to private pooled investment vehicles, the securities of which are offered to investors on a private placement basis (each, a “Fund” and collectively, the “Funds”). The Funds include:
• Alua Partners LP, a Delaware limited partnership (the “Domestic Fund”);
• Alua Offshore Fund Ltd., a Cayman Islands exempted company (the “Offshore Fund”, and together with the Domestic Fund, the “Feeder Funds”);
• Alua Intermediate Fund LP, a Cayman Islands exempted limited partnership (the “Intermediate Fund”; and
• Alua Master Fund LP, a Cayman Islands exempted limited partnership (the “Master Fund”), which serves as the master fund into which the Domestic Fund the Offshore Fund (indirectly through the Intermediate Fund) invest all of their investible assets through a “master feeder” structure. The Fund General Partner serves as the general partner of the Domestic Fund, the Master Fund, and the Intermediate Fund. This Brochure does not constitute an offer to sell or a solicitation of an offer to buy any securities. The securities of the Funds

are offered and sold on a private placement basis under exemptions promulgated under the Securities Act of 1933 and other applicable state, federal or non-U.S. laws. Significant suitability requirements apply to prospective investors in the Funds, including requirements that they be "accredited investors" as defined in Regulation D, "qualified purchasers" as defined in the Investment Company Act, or non-"U.S. Persons" as defined in Regulation S. Persons reviewing this Brochure should not construe this as an offer to sell or a solicitation of an offer to buy the securities of any of the Funds described herein. Any such offer or solicitation will be made only by means of a confidential private placement memorandum. 2. Investment Strategies and Types of Investments. We primarily seek to invest, on a global basis, in publicly-traded equities and equity- related securities (including options, futures, swaps and other equity-related derivatives); however, we continually seek the best risk-adjusted opportunities for the Funds, and may occasionally invest in fixed income products, commodity interests or currencies, as well as any other derivatives and financial instruments as we deem appropriate. We seek to accomplish the Funds' investment objectives by investing in companies across a diversified range of sectors including, without limitation, in technology, media, telecommunications, financial services, industrials, business services and consumer-related investments. The descriptions set forth in this Brochure of specific advisory services that we offer to the Funds, and investment strategies pursued and investments made by us on behalf of the Funds, should not be understood to limit in any way our investment activities. We may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that we consider appropriate, subject to each Fund's investment objectives and guidelines. The investment strategies we pursue are speculative and entail substantial risks. The Funds should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any Fund will be achieved. C. Availability of Customized Services for Individual Clients. Our investment decisions and advice with respect to each Fund will be subject to each Fund's investment objectives and guidelines, as set forth in its respective offering documents. D. Wrap Fee Programs. We do not currently participate in any Wrap Fee Programs. E. Assets Under Management. We manage, on a discretionary basis, approximately $2,689 million of client assets (rounded to the nearest $100,000), determined as of December 31, 2023.