Firm Ownership Mondrian Investment Partners Limited (“Mondrian”) was founded and SEC registered in 1990 under the name Delaware International Advisers Limited. It was then affiliated with Delaware Investments. Mondrian is also authorized and regulated by the Financial Conduct Authority (“FCA”) in the United Kingdom.
On September 24, 2004, a senior management team, together with private equity funds sponsored by Hellman & Friedman LLC, a private equity firm (“Hellman & Friedman”), completed the acquisition of Delaware International Advisers Limited. Upon closing of the transaction, Delaware International Advisers Limited’s name was changed to Mondrian Investment Partners Limited.
Between the periods of September 24, 2004 and July 12, 2011 Mondrian was ultimately controlled by a partnership of senior management and private equity funds sponsored by Hellman & Friedman. Over this period, Hellman & Friedman became a minority investor.
In July 2011, senior management purchased the minority investor’s investment and the business became 100% employee owned through an employee partnership (Atlantic Value Investment Partnership LP) consisting of its senior employees, including the majority of investment professionals, senior client service officers and senior operations personnel. AVGP Limited is its general partner. Approximately half of employees are currently partners.
Mondrian Investment Partners (U.S.), Inc. (an indirectly owned subsidiary of Atlantic Value Investment Partnership LP), is a Pennsylvania Department of Banking and Securities registered investment adviser and is the entity that carries out the marketing and client services activities for Mondrian in North America. Mondrian Investment Partners (U.S.), Inc. does not provide investment advisory services.
In 2023, Mondrian Investment Partners Singapore Private Limited was incorporated to provide client servicing and institutional marketing services in Asia. Mondrian Investment Partners Singapore Private Limited is an indirectly owned subsidiary of Atlantic Value Investment Partnership LP.
Investment Advisory Services Generally, Mondrian will manage assets on a fully discretionary basis. Advisory services are provided either on a Directly Managed basis or as a Managed Account Program through a third-party Sponsor. Securities will be selected on a global basis including marketable securities of issuers that are domiciled in both developed and developing countries. Equity and fixed income securities are utilized (according to client investment objectives) in the management of such accounts.
Investment Advisory Services - Directly Managed Directly Managed accounts are those where Mondrian contracts directly with the client and has end-to- end investment and administrative responsibilities. Trades for Directly Managed accounts are typically executed by the Mondrian centralized Trading Desk. For a limited number of Directly Managed accounts, clients execute their own trades. These relationships are described as ‘Directly Managed Portfolio Consulting Clients’ who receive specific trade and implementation instructions from Mondrian which they in turn execute for their own account. This is distinct from Managed Account Programs described below where Mondrian contracts with a third party Sponsor. Investment Advisory Services - Managed Account Programs: SMA and Model Delivery Mondrian provides discretionary and non-discretionary investment advisory services to certain Managed Account Programs (“Programs”) sponsored by third parties. These services will be provided through a manager traded separately managed account or through non-discretionary model portfolio investment services where the sponsor retains investment discretion.
5 Sponsors of these Programs include various broker-dealers, investment advisers, consultants, or other organizations (collectively referred to as ‘Sponsors’). Through these Programs, the Sponsors typically provide a package of

services to their clients, which include assistance in determining investment objectives, choosing a strategy or strategies offered by participating investment advisers, trade execution and custodial services, performance monitoring, periodic reporting, and other related services. A client of the Sponsor, with assistance and/or advice from the Sponsor, typically selects one or more investment advisers, such as Mondrian, from a list of Sponsor-approved advisers to provide investment advisory services for all or a portion of their assets allocated to their program. All Program clients and prospective Program clients should carefully review the terms of the agreement with the Sponsor and the relevant Program brochure provided by the Sponsor and/or other disclosure documents to understand the terms, services, minimum account size, and any additional fees or expenses that may be associated with a Program account. Managed Account Programs: Manager Traded SMA Sponsors may offer different types of accounts through their Programs. One type of account is called a Manager Traded Separately Managed Account (‘Manager Traded SMA’). For Manager Traded SMAs, the Program client has a contract with the Program Sponsor and Mondrian enters into a management agreement with the Sponsor to provide discretionary investment advisory services to the Sponsor’s Program clients. The Sponsor then typically pays Mondrian a portion of the fee paid to the Sponsor by the client. Mondrian participates in such Programs with single and dual-contract agreements. Under a single contract, the client contracts directly with the Sponsor. In a dual contract, the client executes agreements with the Sponsor as well as directly with Mondrian; such clients will typically pay Mondrian an advisory fee in addition to the fee they pay to the Sponsor.
Managed Account Programs: Model Delivery Mondrian provides non-discretionary or model portfolio investment services and recommendations to Sponsors, or their designee, through the provision of model portfolios. For such accounts, the Sponsor retains investment discretion and Mondrian is responsible only for providing the model portfolios. Consequently Mondrian classifies such assets as “assets under advisement.” Managed Account Programs: Operational Support Mondrian has engaged a third-party service provider to provide operational and administrative support in maintaining the Programs for which Mondrian provides investment advisory services. This third- party provider will perform certain functions on a day-to-day basis, such as new account setup and maintenance, trade order generation and routing, confirmation and settlements, account asset cash reconciliation, guideline monitoring and recordkeeping, and other related services. Investment Guideline Restrictions For separate account clients, Mondrian may agree to certain mutually acceptable investment parameters and guidelines.
Additionally, separate account clients may occasionally request that Mondrian avoid investments based on specific criteria e.g. no tobacco. Such clients are required to provide Mondrian with either a recognized industry classification or a list of prescribed issuers with identifiers. Clients are responsible for updating this list of restricted names and furnishing Mondrian with a copy.
Clients must deliver their investment guidelines and restrictions in writing, and Mondrian will endeavor to adhere to such guidelines and restrictions when making investment decisions. These restrictions may have an adverse effect on performance relative to similar or equivalent accounts. 6 Total Discretionary and Non-Discretionary Assets Under Management As of December 31, 2023, firm discretionary regulatory assets under management totaled USD 45,343,864,910. Additionally, Mondrian has approximately USD 3,714,625,888 in assets under advisement via Model Delivery Managed Account Programs arrangements with financial intermediaries and institutional clients.