PGIM Wadhwani LLP (“PGIM Wadhwani”) is a limited liability partnership organized in England and Wales,
UK and is authorized and regulated by the Financial Conduct Authority, UK.
In addition to being an SEC-registered investment adviser, PGIM Wadhwani is a member of the National
Futures Association (“NFA”) and is registered with the U.S. Commodity Futures Trading Commission
(“CFTC”) as a commodity trading advisor and a commodity pool operator (“CPO”). PGIM Wadhwani is an
indirect, wholly-owned subsidiary of Prudential Financial, Inc. (“Prudential Financial”), a U.S. publicly held
company (NYSE Ticker “PRU”). Prudential Financial, Inc. of the United States is not affiliated in any
manner with Prudential plc, a company incorporated in the United Kingdom or with Prudential Assurance
Company, a subsidiary of M&G plc, incorporated in the United Kingdom.
PGIM Wadhwani was founded in October 2002 as Wadhwani Asset Management and was acquired by
PGIM, the global investment management business of Prudential Financial in January 2019.
This brochure describes PGIM Wadhwani’s business, and hereinafter when we use the terms “we”, “us”,
and “our”, we are referring to PGIM Wadhwani unless we specify otherwise.
As described in Section 7 below, PGIM Wadhwani primarily provides investment advisory services to
pooled investment vehicles (collectively referred to herein as the “Funds” and individually a “Fund”) on a
discretionary basis. PGIM Wadhwani also provides discretionary investment advisory services to
separately managed accounts (“Managed Accounts”). Collectively, the Funds and Managed Accounts are
referred to herein as “Clients”.
PGIM Wadhwani generally has broad and flexible investment authority with respect to its Clients. PGIM
Wadhwani utilizes a disciplined, systematic approach, which focuses on harnessing fundamental macro
forces and exploiting behavioral biases. This investment approach is expressed through quantitative
systems which have been used by the firm since 2005, and built on models that have been developed over
the course of 29 years. PGIM Wadhwani employs various strategies and can invest or trade in a wide
variety of financial instruments,
including, but not limited to: equity, bond, currency and commodity market
futures, currency forwards and exchange traded funds (ETFs), among others. The models that support
these strategies use both price and non-price factors, as they are complementary to each other. Likewise,
they use complementary styles – such as value and momentum. The models or subsets of the models are
used for Client accounts based on their investment management agreements or the Fund governing
documents.
PGIM Wadhwani typically tailors its advisory services to the individual needs of a Managed Account by
negotiating the terms of its investment management agreement. Managed Accounts can also be tailored
for legal, regulatory or tax purposes. Each investment management agreement and related account
documentation for a Managed Account will specify the particular investment strategy and any related
investment restrictions.
PGIM Wadhwani does not tailor its advisory services to the individual or particular needs of investors in
the Funds. Such investors will accept the terms of advisory services as set forth in each Fund’s governing
documents, however, as described further in Item 6, below, we have entered into side letters with some
underlying investors. PGIM Wadhwani expects to have broad investment authority with respect to the
Funds and, therefore, investors should consider whether the investment objectives of the Funds will be in
line with their individual objectives and risk tolerance prior to investment.
P a g e5
All discussions of Clients’ investment terms in this document including, but not limited to, their investments,
strategies, fees and other costs, conflicts of interest and relevant material risks are qualified in their entirety
by reference to the relevant investment management agreements (as regards the Managed Accounts) and
the relevant offering memorandum and governing documents (as regards the Funds).
PGIM Wadhwani does not currently participate in wrap fee programs.
As of December 31, 2023, PGIM Wadhwani managed regulatory assets in the amount of
US$1,595,745,790 on a discretionary basis. PGIM Wadhwani does not currently manage any client assets
on a non-discretionary basis.