Genesis Investment Management, LLP (the “Firm” or “Genesis”) specialises in managing investments in emerging market equities for institutional investors. Please see Item 7 of this Brochure for more information with respect to the Firm’s clients. The Firm provides such investment management services on a discretionary basis.
The Firm was organised in the United Kingdom in 2004 but taking into account its predecessor entities, the Firm has been in business since 1989. The Firm currently has a corporate partner, individual partner(s) (whose number may vary from time to time, but as of the date of this Brochure is one) and a trust (the “Trust”, together with the corporate partner and individual partner(s), the “Genesis Partners”) and operates through a series of boards/committees and appointments described below. The Firm has a single office at 16 St James’s Street, London, SW1A 1ER United Kingdom. The Firm serves as an investment manager, investment adviser or sub-adviser to various clients, including, but not limited to, pension plans, endowments, foundations, investment companies and governmental entities.
Principal Ownership Affiliated Managers Group, Inc. (“AMG”), a publicly-traded company (NYSE: AMG) with equity investments in boutique investment management firms, owns a majority of the equity interests of the Firm. AMG holds its majority interest in the Firm indirectly through three wholly owned subsidiaries: AMG Genesis, LLC, AMG Atlantic Holdings Ltd and AMG New York Holdings Corp.
AMG also holds equity interests in other investment management firms (“AMG Affiliates”). Each of the AMG Affiliates, including the Firm, is operated autonomously and independently, except, with respect to the Firm, as described in this Brochure. Further information on both AMG and AMG’s Affiliates is provided in Item 10.
The remaining interest in the Firm is owned by the Genesis Partners. Genesis Investment Management, LLP Continuation Trust, acts as the Trust and facilitates the recycling of partnership interests and future awards for the benefit of the individual partner(s). The Genesis Partners in aggregate own approximately 46.5% of the equity in issue and AMG owns approximately 53.5%. The individual partner(s) have each contributed capital to the Firm and entered into a commitment to remain in the Firm for a minimum fixed period. The ownership percentage of the individual partner(s) varies based on their tenure in the Firm. When an individual partner retires, they are required to sell their ownership back to the Trust. Further details on these individual partner(s) are included in the Brochure Supplement.
The Firm The Firm is registered in England and Wales as a limited liability partnership and has 48 employees, including clerical, part-time staff and contractors, working in its London office as of the 31st December 2023.
The Firm’s Governing Board is comprised of two AMG representatives and one Genesis representative. The Governing Board deals by exception with major corporate matters only. Authority to set policy on all other matters, including investment management policy, is delegated to the Firm’s Operating Board (“GIM Operating Board”) under the Firm’s partnership agreement.
The Firm is managed by the GIM Operating Board which is comprised of a Non-Executive Chair, the Managing Partner, an additional Non-Executive Member and an Executive Member. The GIM Operating Board has overall responsibility for managing the Firm. The day-to-day business is overseen by certain formal committees which include the Portfolio Coordination Team (“PCT”). Such committees meet regularly and are comprised of partners, associate partners and certain members of staff. Further details of the role and responsibility of the PCT is set forth below.
Advisory Services The Firm aims to generate excellent long-term investment performance in emerging market equities for institutional clients. In general, the Firm may invest client assets in the following securities and instruments: equity securities, listed and unlisted securities, securities traded over the counter, non-U.S. securities, warrants, private placements, rights offerings, open-end funds, convertible bonds and preferred stock. The Firm primarily utilises its own independent research and analysis and uses a bottom-up investment approach to create a diversified portfolio of emerging market equities. The Firm does not construct portfolios with reference to an index. The Firm believes that it can best deliver excellent long-term investment performance by working as a team to make investments in quality businesses at attractive prices.
The Firm’s emerging markets opportunity set consists of countries defined as low- and middle-income economies by the World Bank as well as high income economies (such as South Korea and Taiwan) included in the major emerging markets benchmark indices. In addition, the Firm’s client portfolios may also contain companies that are listed on the stock markets of high-income economies, but that generate a significant proportion of their revenues, profits or cashflow from, or whose assets or intellectual property are mostly located in emerging markets.
As a general principle, the Firm does not use derivatives to supplement investment strategy and the Firm does not short stock. The Firm may invest in depositary receipts, synthetics or participation notes if direct local holdings in a market are not permitted or are less advantageous. In addition,

the Firm may engage in a securities lending programme for its sponsored pooled investment vehicles (each, a “Genesis Fund” and, collectively, the “Genesis Funds”). The Firm does not hedge directly against currency fluctuations between the currencies of emerging markets stocks and its base currency of US$.
As a specialist manager in emerging market equities, the majority of client portfolios follow a similar global emerging market equity strategy. However, the Firm recognises that the investment needs of our clients may be different in light of their differing profiles. As such, we may modify our core global emerging market equity strategy, as necessary, in order to accommodate the particular investment objectives and accompanying restrictions requested by our clients. At the commencement of the client relationship for a separate account client, each such client executes an investment management agreement, which sets forth their investment objectives, investment strategy and any investment restrictions that will be applicable to the Firm’s management of the assets in the client’s account. Prior to the execution of the agreement, the requested objectives and restrictions are reviewed and, if required, refined to both meet the client’s needs and provide the Firm with sufficient discretion to properly invest the client’s assets. For example, some clients do not permit investment in the securities of companies which operate in certain countries or sectors. With respect to the management of the Genesis Funds, the investment objectives and restrictions are set forth in the relevant offering document and governing agreements of such Genesis Fund. Wrap Fee Programmes The Firm does not have any involvement in wrap fee programmes whereby clients select an investment adviser to manage funds through an investment programme presented to the clients by a third-party programme sponsor and clients generally pay the wrap programme sponsor a single fee (called a “wrap fee”) for consulting, brokerage, custodial, portfolio monitoring, and investment management services and such sponsor pays a portion of the wrap fee to the investment adviser.
Foreign Exchange (“FX”) Transactions FX transactions for client accounts are generally limited to those necessary to settle trades in emerging market securities which are not denominated in US Dollar. The key factors in informing the Firm’s approach on FX are: FX is not a discretionary part of the investment management process; FX transactions are undertaken to minimise operational risk and maximise efficiency and best execution. The Firm does not hedge directly against currency fluctuations between the currencies of emerging markets stocks and uses a base currency of US Dollar.
For the Genesis Funds and as instructed by several segregated account clients, the Firm has the ability to execute FX transactions in certain currencies through an FX trading platform operated by a third-party provider. For the majority of its segregated account clients, it is the responsibility of the client’s appointed custodian to handle FX transactions. The Firm can instruct a third-party provider to execute FX transactions on a client account’s behalf if requested by the client.
For clients who have not elected to use the FX platform, the Firm will instruct the client’s custodian to execute the necessary FX transaction. This is done either through standing instructions communicated to the custodian when the account is established or at the time settlement instructions are sent to the custodian for a particular transaction. The custodian is responsible for executing FX transactions, including the timing and applicable rate of such execution pursuant to its own internal processes. Where a client has arrangements in place with its custodian regarding the execution of FX transactions, such arrangements may impact the overall fees and expenses charged to the client by the custodian. Therefore, all such FX transactions are effected with the client’s custodian, and the Firm does not seek to obtain different FX rates from other sources.
Because of various local limitations regarding transactions for some restricted currencies, transactions in restricted currencies are often effected by each client’s custodian pursuant to standing instructions (both the Genesis Funds and separate account clients). The Firm also instructs other types of FX transactions, such as those related to dividend and interest repatriation. Where possible such FX activity will utilise an FX trading platform. Where required the Firm will issue standing instructions to each client’s custodian to fulfil these FX transactions.
Assets Under Management As of 31st December 2023, the Firm’s assets under management (“AUM”) on a discretionary basis were US$3.4 billion. The Firm does not have any AUM on a non-discretionary basis. Please see the Firm’s Form ADV Part 1A – Item 5.F for more information.
Other Jurisdictions The Firm also provides financial services to institutional clients in other countries including Australia where it is exempt from the requirement to hold an Australian financial services licence under the Corporations Act 2001 in respect of the financial services it provides. The Firm is registered with the SEC under the Investment Advisers Act of 1940, as amended and the financial services that the Firm provides are regulated by the Financial Conduct Authority under UK laws, which differ from Australian laws.