Sands Capital Management, LLC (“Sands Capital”) is an independent investment management
firm. Sands Capital Management, LP (“Sands Capital LP”) is the principal owner of Sands Capital
and, in turn, is principally owned directly and indirectly by several limited liability companies and
estate planning trusts as identified in Schedule B of Part 1. Sands Capital and Sands Capital LP
are ultimately controlled by Frank M. Sands.
Sands Capital is registered with the SEC as an investment adviser under the Investment Advisers
Act of 1940, as amended (the “Advisers Act”). We are headquartered in Arlington, Virginia, and
manage approximately $45,003.5 million in discretionary assets (Regulatory Assets Under
Management) as of December 31, 2023.
Sands Capital also provides recommendations for non-discretionary clients for whom we do not
execute trades but for whom we provide changes to strategy model portfolios (“Model Clients”),
which account for approximately $5,253.3 million in additional fee-paying assets as of December
31, 2023.
Since 1992, Sands Capital has provided investment advisory and management services to taxable
and tax-exempt clients, primarily on a discretionary basis, and in certain circumstances as
described herein, to Model Clients. Clients include, among other types, investment companies and
other pooled investment vehicles, pension and profit-sharing plans, charitable organizations, state
and municipal government entities, sovereign wealth funds and foreign official institutions,
corporations, non-U.S. pension funds, superannuation funds, banking or thrift institutions and
individuals.
Sands Capital Ventures, LLC is an advisory affiliate of Sands Capital (“Advisory Affiliate”). The
Advisory Affiliate provides investment advisory and management services to its clients, primarily
regarding venture capital, growth equity, and related investments. Under personnel-sharing and
other arrangements, Sands Capital staff members act on behalf of the Advisory Affiliate for
purposes of providing services to its clients and provide other back office and administrative
services to the Advisory Affiliate. Certain Sands Capital staff members are also officers of the
Advisory Affiliate.
Sands Capital believes that harnessing the collective capabilities of Sands Capital and the Advisory
Affiliate benefits its clients. These joint teams use expanded and shared capabilities, including the
sharing of research and other information by investment staff members relating to economic
perspectives, market analysis and securities research.
Investment Philosophy and Strategies
Sands Capital embraces the fundamental investment philosophy that stock prices tend to reflect
the earnings power and growth of the underlying businesses over the long term. As such, we
attempt to identify and invest in high quality companies that have the capacity to generate
sustainable, above-average earnings growth over time. The strategies we offer are typified by
deep, proprietary, business-focused global research, concentrated and conviction weighted
portfolios and a long-term investment horizon.
We invest for our clients in what we believe are the leading growth businesses that meet our six
investment criteria:
Sustainable above-average earnings growth;
Leadership position in a promising business space;
Significant competitive advantages or a unique business franchise;
Clear mission and value-added focus;
Financial strength; and
Rational valuation relative to the market and business prospects.
The primary risk we seek to manage is the risk of permanent loss of capital resulting from a
negative business or investment outcome. Risk management is integrated throughout our entire
research and portfolio construction process. Please see Item 8 – Methods of Analysis, Investment
Strategies and Risk of Loss for more information.
The research team conducts proprietary, bottom-up, fundamental research on businesses of all
market capitalizations located around the world. This analysis includes formulating a “sell case”
for each investment. We typically sell when any of the following is identified:
Significant change in fundamentals;
Flaw in original investment case;
Meaningful overvaluation vs. underlying business;
Funding source for a new opportunity; or
Risk management decision.
We apply the above criteria to each of the following investment strategies, which have overlapping
investments. Please refer to Item 6 – Performance-Based Fees and Side-By-Side Management and
Item 12 – Brokerage Practices for additional information.
Select Growth
The Select Growth strategy is a concentrated portfolio of primarily large- and mid-capitalization
growth businesses. The portfolio normally consists of the equity securities of 25 to 30 issuers.
Portfolio companies are primarily domiciled in the United States (“U.S.”) but also include the
equity securities of foreign issuers traded on U.S. exchanges. Eligible securities include equity
and equity-related securities, such as American depositary receipts (“ADRs”) or shares of publicly
traded real estate investment trusts for U.S. or Non-U.S. tax purposes (“REITs”). The portfolio’s
cash allocation is determined by Sands Capital and is monitored and managed in accordance with
client guidelines. The portfolio remains fully invested (i.e., residual cash is generally less than
5%) and is most commonly benchmarked to the Russell 1000® Growth Index.
Global Growth
The Global Growth strategy is a concentrated portfolio of primarily large- and mid-capitalization
growth businesses. The portfolio normally consists of the equity securities of 30 to 50 issuers.
Portfolio companies are domiciled in both developed and emerging markets. Eligible securities
include equity and equity-related securities, such as ADRs, exchange-traded funds (“ETFs”),
global depositary receipts (“GDRs”), China A-shares (whether traded cross-boundary via the Hong
Kong Stock Connect or directly via exchanges in mainland China, “China A-shares”), or REITs.
Low exercise price warrants (“LEPWs”), participation notes (“P-Notes”), or other access products
are used to gain exposure to certain foreign markets where direct investment is not always practical
or cost efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored
and managed in accordance with client guidelines. The portfolio remains fully invested (i.e.,
residual cash is generally less than 5%) and is most commonly benchmarked to the MSCI All
Country World Index.
Global Leaders
The Global Leaders strategy is a concentrated portfolio of primarily large- and mid-capitalization
growth businesses. The portfolio normally consists of the equity securities of 30 to 50 issuers.
The strategy employs a portfolio construction approach that intends to balance growth and
volatility. Portfolio companies are domiciled in both developed and emerging markets. Eligible
securities include equity and equity-related securities, such as ADRs, ETFs, GDRs, China A-
shares, or REITs. LEPWs, P-Notes, or other access products are used to gain exposure to certain
foreign markets where direct investment is not always practical or cost efficient. The portfolio’s
cash allocation is determined by Sands Capital and is monitored and managed in accordance with
client guidelines. The portfolio remains fully invested (i.e., residual cash is generally less than
5%) and is most commonly benchmarked to the MSCI All Country World Index.
International Growth
The International Growth strategy is a concentrated portfolio of primarily large- and mid-
capitalization growth businesses. The portfolio normally consists of the equity securities of 25 to
40 issuers. Generally, portfolio companies are domiciled or derive a significant portion of their
revenues, profits, or productive assets outside of the United States. Eligible securities include
equity and equity-related securities, such as ADRs, ETFs, GDRs, China A-shares, or REITs.
LEPWs, P-Notes, or other access products are used to gain exposure to certain foreign markets
where direct investment is not always practical or cost efficient. The portfolio’s cash allocation is
determined by Sands Capital and is monitored and managed in accordance with client guidelines.
The portfolio remains fully invested (i.e., residual cash is generally less than 5%) and is most
commonly benchmarked to the MSCI All Country World ex USA Index.
International Leaders
The International Leaders strategy is a concentrated portfolio of primarily large- and mid-
capitalization growth businesses. The portfolio normally consists of the equity securities of 25 to
40 issuers. The strategy employs a portfolio construction approach that intends to balance growth
and volatility. Generally, portfolio companies are domiciled or derive a significant portion of their
revenues, profits, or productive assets in both developed and emerging markets outside the United
States. Eligible securities include equity and equity-related securities, such as ADRs, ETFs,
GDRs, China A-shares, or REITs. LEPWs, P-Notes, or other access products are used to gain
exposure to certain foreign markets where direct investment is not always practical or cost
efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored and
managed in accordance with client guidelines. The portfolio remains fully invested (i.e., residual
cash is generally less than 5%) and is most commonly benchmarked to the MSCI All Country
World ex USA Index.
Emerging Markets Growth
The Emerging Markets Growth strategy
is a concentrated portfolio of primarily large- and mid-
capitalization growth businesses. The portfolio normally consists of the equity securities of 30 to
50 issuers. Generally, portfolio companies are domiciled in or derive significant exposure (
e.g.,
substantial portion of revenues, profits, or productive assets) outside of developed markets.
Eligible securities include equity and equity-related securities, such as ADRs, ETFs, GDRs, China
A-shares, or REITs. LEPWs, P-Notes, or other access products are used to gain exposure to certain
foreign markets where direct investment is not always practical or cost efficient. The portfolio’s
cash allocation is determined by Sands Capital and is monitored and managed in accordance with
client guidelines. The portfolio remains fully invested (
i.e., residual cash is generally less than
5%) and is most commonly benchmarked to the MSCI Emerging Markets Index.
Emerging Markets ex China
The Emerging Markets ex China strategy is a concentrated portfolio of primarily large- and mid-
capitalization growth businesses. The portfolio normally consists of the equity securities of 25 to
45 issuers. Generally, portfolio companies are domiciled in or derive significant exposure (
e.g.,
substantial portion of revenues, profits, or productive assets) outside of developed markets and
China. Eligible securities include equity and equity-related securities, such as ADRs, ETFs,
GDRs, or REITs. LEPWs, P-Notes, or other access products are used to gain exposure to certain
foreign markets where direct investment is not always practical or cost efficient. The portfolio’s
cash allocation is determined by Sands Capital and is monitored and managed in accordance with
client guidelines. The portfolio remains fully invested (
i.e., residual cash is generally less than
5%) and is most commonly benchmarked to the MSCI Emerging Markets ex China Index.
Emerging Markets Discovery
The Emerging Markets Discovery strategy is a concentrated portfolio of primarily mid- and small-
capitalization growth businesses. The portfolio normally consists of the equity securities of 30 to
50 issuers. Generally, portfolio companies are domiciled in or derive significant exposure (e.g.,
substantial portion of revenues, profits, or productive assets) outside of developed
countries. Eligible securities include equity and equity-related securities, such as ADRs, ETFs,
GDRs, China A-shares, or REITs. LEPWs, P-Notes, or other access products are used to gain
exposure to certain foreign markets where direct investment is not always practical or cost
efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored and
managed in accordance with client guidelines. The portfolio remains fully invested (i.e., residual
cash is generally less than 10%) and is most commonly benchmarked to the MSCI Emerging
Markets Mid Cap Index. Technology Innovators
The Technology Innovators strategy is a concentrated portfolio of primarily large- and mid-
capitalization growth businesses which are publicly or privately held, with a particular emphasis
placed on companies facilitating or benefitting from powerful secular shifts enabled by
technologies. The portfolio normally consists of the equity securities of 20 to 35 issuers. Portfolio
companies are domiciled in both developed and emerging markets. Eligible securities include
equity and equity-related securities, such as ADRs, stock or convertible debt issued by private
companies, ETFs, GDRs or REITs. LEPWs, P-Notes, or other access products are used to gain
exposure to certain foreign markets where direct investment is not always practical or cost
efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored and
managed in accordance with client guidelines. The portfolio remains fully invested (
i.e., residual
cash is generally less than 5%) and is most commonly benchmarked to the MSCI All Country
World Information Technology and Communication Services Index.
Global Shariah
The Global Shariah strategy is a concentrated portfolio of primarily large- and mid-capitalization
growth businesses that meet Islamic investment principles, as determined by Sands Capital. The
portfolio normally consists of the equity securities of 30 to 50 issuers. Portfolio companies are
domiciled in both developed and emerging markets. Eligible securities include equity and equity-
related securities, such as ADRs, ETFs, GDRs, China A-shares, or REITs. LEPWs, P-Notes, or
other access products are used to gain exposure to certain foreign markets where direct investment
is not always practical or cost efficient. The portfolio’s cash allocation is determined by Sands
Capital and is monitored and managed in accordance with client guidelines. The portfolio remains
fully invested (
i.e., residual cash is generally less than 5%) and is most commonly benchmarked
to the S&P Global BMI Shariah Index.
Focus Strategies
The Focus strategies are concentrated portfolios of primarily large-capitalization growth
businesses. Portfolio guidelines specifying the number of holdings are customized by clients, and
Sands Capital manages portfolios of generally between five and twenty issuers. The eligible
universe is limited to companies selected from our other strategies. Eligible securities include
equity and equity-related securities, such as ADRs, ETFs, GDRs or REITs. LEPWs, P-Notes, or
other access products are used to gain exposure to certain foreign markets where direct investment
is not always practical or cost efficient. The portfolio’s cash allocation is determined by Sands
Capital and is monitored and managed in accordance with client guidelines. The portfolios remain
fully invested (
i.e., residual cash is generally less than 5%) and are most commonly benchmarked
to the MSCI All Country World Index unless a different Index is requested.
Client-Tailored
Sands Capital manages and develops client-tailored growth strategies on a case-by-case basis.
These portfolios are often similar to the firm’s primary strategies but contain variations based on
client type, to meet specific client mandates, or to meet anticipated industry needs.
Additionally, Sands Capital provides discretionary investment management services in respect of
securities received as in-kind distributions from investment funds managed by the Advisory
Affiliate or others. Client objectives and fees are determined on a case-by-case basis.
Discretionary Advisory Services
For discretionary clients, Sands Capital constructs and maintains model portfolios for each
strategy. Client accounts are generally invested in the same portfolio businesses and at
approximately the same weights as the applicable strategy model unless client guidelines prohibit
or restrict an investment. Client guidelines or restrictions must be provided to Sands Capital for
consideration in writing and in advance as they may limit Sands Capital’s ability to act and, as a
result, performance will vary from those of other accounts not bound by similar restrictions.
Non-standard securities instruments issued as a result of corporate actions (e.g., fixed income) are
generally liquidated into cash as soon as reasonable.
Our investment strategies are available through various distribution channels. We provide
investment management services to separately managed accounts and to advised and sub-advised
pooled vehicles, such as mutual funds, UCITS funds, and private funds. Our clients are primarily
institutional investors, intermediaries, and other sophisticated investors with long-term investment
objectives. Please see
Item 7 – Types of Clients for additional information.
Model Client Advisory Services
Sands Capital provides non-discretionary advisory services to select Model Clients. In these
arrangements, we periodically provide a strategy model but do not exercise investment discretion
or execute trades. Model Clients are notified of changes to the relevant strategy model as described
in
Item 12 – Brokerage Practices.
Investment Performance
Sands Capital claims compliance with the Global Investment Performance Standards (GIPS®) and
prepares and presents its investment results in compliance with GIPS®. A firm that claims
compliance with the GIPS standards must establish policies and procedures for complying with all
the applicable requirements of the GIPS standards. The standards set forth methods of calculating
and presenting investment performance in a fair and consistent manner. The CFA Institute is not
involved with the preparation or review of our investment results information.
To receive a complete list and description of our composites and/or investment results information,
contact the Compliance Team at (703) 562-4000; write to us at 1000 Wilson Blvd., Suite 3000,
Arlington, VA 22209; or email us at
complianceteam@sandscap.com.
Conditions for Managing Accounts; Termination of Services
The minimum account size for institutional separate accounts is generally $50 million. Minimum
account sizes are negotiable.
From time to time, Sands Capital permits clients to contribute or retain unsupervised securities in
their account. We do not provide investment advisory services for these securities and the value
of these unsupervised securities are not included in the calculation of our advisory fee. However,
we have the right to reject management of any security that was not purchased with our advice.
Clients can terminate our investment management services by providing written notice to us.