9AT: SPARX ASSET MANAGEMENT CO., LTD.

SPARX ASSET MANAGEMENT CO., LTD.

SPARX ASSET MANAGEMENT CO., LTD.

Adviser Profile

As of Date	06/08/2026
Registration	SEC, Approved, 08/16/2005
ADV Location	TOKYO, Japan
Contact Info	813 xxxxxxx
Websites

AUM^*	11,713,911,895 13%
of that, discretionary	11,129,928,967 10%
Number of Employees	145 1%
of those in investment advisory functions	35 -5%
Private Fund GAV^*	0
Avg Account Size	119,529,713 10%
% High Net Worth	1.79% -1%
SMA’s	Yes
Private Funds	0

Adviser Type

- Large advisory firm
- Outside the United States
- An investment adviser (or subadviser) to an investment company

Client Types

- Investment companies
- Pooled investment vehicles
- Pension and profit sharing plans
- State or municipal government entities
- Corporations or other businesses not listed above
- Other

Advisory Activities

- Portfolio management for investment companies
- Portfolio management for pooled investment vehicles
- Portfolio management for businesses

Compensation Arrangments

- A percentage of assets under your management
- Performance-based fees

Reported AUM

11B 9B 8B 6B 5B 3B 2B

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025

Discretionary

Non-discretionary

Private Funds

No private funds

Employees

Brochure Summary

Overview

SPARX Asset Management Co., Ltd. (“SPARX”) was founded in April 2006 and is a wholly owned subsidiary of SPARX Group Co., Ltd. (“SPARX Group”), a listed company traded on TSE Prime Section (Code: 8739). As of March 31, 2023 Mr. Shuhei Abe, President and CEO of SPARX and SPARX Group, owned approximately 40% of SPARX Group. Founded in 1989, SPARX Group is an independent financial services company headquartered in Tokyo. In 2006, the company renamed itself from SPARX Asset Management Co., Ltd. to SPARX Group Co., Ltd. and all asset management activities were transferred to the new company known as SPARX Asset Management Co., Ltd., which is registered with Japanese authority for Investment Management Business, Investment Advisory and Agency Business, Type 1 and Type 2 Financial Instruments Business. SPARX provides portfolio management services and manages client accounts and funds on either a discretionary or non-discretionary basis subject to investment policies and restrictions established by our clients or funds, as the case may be. For select funds, SPARX has a sub-advisory

agreement with an affiliated registered investment advisor (“sub-advisor”) for specific expertise to manage client assets. The sub-advisor will make recommendations to SPARX regarding potential portfolio investments, follow-on investments, and the opportunity for divestment. SPARX specializes in investing in Japanese equities, but can and does invest in other jurisdictions which may include common stocks and related derivative instruments, such as convertible bonds, warrants, future and options, swaps as well as shares in hedge funds and other privately offered investment vehicles. Equity index futures and equity index options may be utilized for liquidity, risk control and other purposes. Currencies, bonds, and related derivatives such as futures, options and swaps may be utilized for investments. As of March 31, 2023, SPARX managed USD $8,396,406,582 in regulatory assets under management on a discretionary basis, and USD $159,944,985 in regulatory assets under management on a non-discretionary basis.