A. Firm Information
Seeds Investor LLC (“Seeds” or the “Advisor”) is a registered investment advisor with the U.S. Securities and
Exchange Commission (“SEC”). The Advisor was organized as a Limited Liability Company (“LLC”) under the
laws of the State of Delaware and located in the state of New York. Seeds was founded in December 2018 and
became a registered investment advisor in May 2020. Seeds is a wholly-owned subsidiary of Seeds Investor
Holdings LLC. The Principal Officer of Seeds is Zachary A. Conway (Founder, Chief Executive Officer and Chief
Compliance Officer).
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by Seeds. For information regarding this Disclosure Brochure, please contact Mr. Conway at
(212) 287-7370.
B. Advisory Services Offered
Seeds primarily offers investment management and related services to other financial institutions through sub-
advisory engagements (each referred to as a “Client”). Seeds does not provide these services directly to
individual investors. Advisory Persons of the Client will serve as the primary Advisor and manage all aspects of
their relationship with the underlying investor.
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. Seeds’ fiduciary commitment is further described in the Code of Ethics. For more information
regarding the Advisor’s Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Investment Management Services
Seeds provides customized investment advisory solutions for its Clients including discretionary investment sub-
advisory services and investment model management. Seeds develops and maintains its internal investment
models and may also assist the Client with the design, oversight and maintenance of models designed by the
Client. The Advisor also makes available its services via an investment management software that provides the
Client with various financial management services, such as tracking of financial data and reporting.
Seeds offers values-aligned investment solutions through proprietary strategies. These strategies focus on
investing in companies that, relative to their industry group peers, are both seeking to mitigate environmental,
social, governance (ESG) risks and exhibiting strong underlying fundamentals. Seeds will typically construct
investment models and portfolios utilizing stocks, exchange-traded funds (“ETFs”) and mutual funds. Seeds may
also utilize individual bonds, American Depository Receipts (ADRs), options contracts, and other types of
derivatives or investments, as appropriate, to meet the needs of a specific Client mandate.
Seeds’ investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held for less than one year to meet the objectives of the Client or due to market conditions. The
Client is responsible for the selection of the appropriate investment strategy for each underlying investor. The
Client is further responsible to ascertain the goals, objectives, circumstances, risk tolerance and financial
situation for each of their underlying investors. Seeds assumes no responsibility to obtain such information from
the underlying investor of the Client. The Client will have the opportunity to place reasonable restrictions on the
types of investments to be held in accounts for their investors, subject to acceptance
by the Advisor.
Seeds evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. Seeds may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. Seeds may recommend specific positions to increase sector or asset class weightings, however
typically the strategies will seek to be in line with respective broad market benchmarks. Seeds may recommend
selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or
sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s]
in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed
unacceptable for the Client’s risk tolerance.
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At no time will Seeds accept or maintain custody of a Client’s or Investor’s funds or securities, except for the
limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated
account[s] at the Custodian, pursuant to the terms of the advisory agreement, please see Item 12 – Brokerage
Practices.
Investment Platform - Seeds may utilize the turn-key portfolio and practice management software platform
(“Platform”) of Adhesion Wealth Advisor Solutions, Inc. (“Adhesion Wealth”). Adhesion Wealth has developed a
customized single-source managed account solution which it makes available to its clients and the clients of
third-party investment advisers such as the Firm. The Platform assists investment advisers with highly intuitive
tools to provide SMA and UMA portfolios, bringing an increased scale and flexible wealth management solutions
to assist in providing better outcomes. Seeds utilizes Adhesion Wealth, depending on its relationship with its
Clients, for trade order management, order aggregation, and other administrative and operational services.
The Advisor may also enter into arrangements with other independent third party investment advisory firms
permitting them to utilize Seeds’ strategies and/or “White-Label” (or re-brand) any of Seeds’ investment
strategies, and the Advisor will charge fees as appropriate for the type of securities and style of investment
management implemented in these managed portfolios.
C. Client Account Management
Prior to engaging Seeds to provide investment advisory services, each Client is required to enter into a written
agreement with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
• Establishing an Investment Strategy – Seeds, in connection with the Client, will define the investment
mandates as required by the Client.
• Asset Allocation – Seeds will develop a strategic asset allocation models to assist the Client in
recommending a portfolio for their investors.
• Portfolio Construction – Seeds will implement an investment portfolio for each Investor account assigned
to Seeds as a Sub-Advisor.
• Investment Management and Supervision – Seeds will provide investment management and ongoing
oversight of the accounts placed under its management and supervision. The Client will assume
responsibility for communications with its underlying Investors.
D. Wrap Fee Programs
Seeds does not manage or place Client assets into a wrap fee program.
E. Assets Under Management
As of December 31, 2022, Seeds manages $71,738,816 in Client assets, all of which is on a discretionary basis.
Clients may request more current information at any time by contacting the Advisor.