CAMIL is based in Dublin and is a wholly owned subsidiary of the Comgest Group (“Comgest” or
“Comgest Group”). It serves as the investment manager for a range of Dublin-based UCITS V funds, U.S.
private funds, collective investment trusts and separately managed accounts. As explained further
below in Item 10, CAMIL uses the investment advisory services of its affiliates. As a discretionary
manager, CAMIL also provides trading and middle office support for its clients.
The shareholding structure of the Comgest Group is presented below:
As referenced in the structure chart above, the principal owner of CAMIL is Comgest Global Investors
SAS.
Comgest was founded in Paris in 1985 and is an independent equity manager. Since its creation, the
Comgest Group has focused on:
i. delivering performance for Comgest’s clients by investing in quality growth companies
with a long-term investment horizon; and
ii. adhering to a disciplined, fundamental investment strategy.
The firm’s founders, Jean-François Canton and Wedig von Gaudecker, and the generations that
followed, have ensured that this independent structure and focused strategy have remained firmly in
place.
The Comgest Group manages over 15 equity strategies including global, regional and single country
portfolios covering developed and emerging markets. Comgest launched its first Pan-European and
Asian equity strategies in 1989. Global equity was added in 1991 and Global Emerging Markets equity
was added in 1994, following the opening of a Hong Kong -based entity in 1993. As the firm’s research
activities, product range and client base developed, Comgest opened further entities in Dublin,
Düsseldorf, Amsterdam, Tokyo, Singapore, Boston, Sydney and offices in London, Milan, Brussels and
Vienna.
As of September 30th, 2023, the Comgest Group employs over 200 professionals of which 51 comprise
the investment teams. Comgest Global Investors S.A.S. is 100% owned by its employees and founders
and equity is held broadly across the firm. Approximately 80% of employees are currently
shareholders.
Comgest has attracted an international client base spanning Europe, Asia Pacific, the Middle East, North
America and Latin America. In addition to advising pooled investment vehicles in the form of UCITS V
funds, U.S. private funds and U.S. collective investment trusts, Comgest can also create bespoke
portfolios to suit clients’ specific needs or investment restrictions in separately managed accounts.
CAMIL manages client assets based on the individual needs of the client, which are stated in the written
objectives and guidelines of the client’s account. In a typical discretionary separate account relationship
(that is, an investment portfolio pursuing a particular investment strategy, established in the client’s
name at its custodian), the client authorizes CAMIL to supervise, manage and direct the investment of
the assets of the portfolio without prior consultation with the client. For non-discretionary accounts,
an adviser must consult with the client prior to implementing any investment decisions. As described
further below, CAMIL is a discretionary asset manager, and generally does not provide general
investment advice or planning services to its clients on a non-discretionary basis.
With respect to CAMIL’s management of Comgest funds, like separate accounts, investment funds are
managed in accordance with written investment objectives, strategies and guidelines. However, a fund
is a pooled vehicle, and its investment
program cannot be tailored to the individual needs of any
particular investor. Investment in a fund does not create an advisory client relationship between the
investor and CAMIL. Therefore, investors should consider whether a fund meets their investment
objectives and risk tolerance prior to investing. Investors in pooled funds receive an offering
memorandum, prospectus, or similar document (each, an “Offering Document”) that describes the fund,
including its risks, fees, and the qualifications needed to invest. Some investment funds may be offered
on a private placement or other limited basis and may not be available to, or appropriate for, all
prospective investors.
CAMIL may manage accounts of employee benefit plans, such as corporate pension, profit sharing and
money purchase pension plans, that are subject to the fiduciary responsibility provisions of Title I of
the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and of plans, such as
individual retirement accounts (“IRAs”) and Keogh plans, that are subject to Section 4975 of the U.S.
Internal Revenue Code of 1986, as amended (the “Revenue Code”) (collectively, “Plans”) on a separately
managed account basis or through a pooled product, such as a collective investment trust. When CAMIL
manages assets of Plans, CAMIL will be subject to the prohibited transaction provisions of Section 406
of ERISA and/or Section 4975 of the Revenue Code, which provisions, among other things, might affect
the manner in which CAMIL may be compensated by such accounts and its ability to enter into certain
kinds of transactions, such as cross-trading and certain transactions with, or for the benefit of, CAMIL
or its affiliates. Further, with respect to Plans that are subject to ERISA, CAMIL also will be subject to
ERISA fiduciary responsibility, reporting and disclosure, and bonding rules, as well as requirements
relating to maintenance of the indicia of ownership of Plan assets. To the extent that CAMIL is managing
any such Plan accounts, CAMIL intends to comply with all applicable provisions of ERISA and the
Revenue Code. Notwithstanding the foregoing, CAMIL and its affiliates do not intend to enter into any
transactions with clients (also known as principal transactions). In addition, certain issuers of
securities and other investment products may limit the ability of Plans to invest in them, which may
affect the composition of the portfolios of Plan accounts and result in a variance between the
investments of Plan accounts and the investments of non-Plan accounts that otherwise might have
similar mandates.
Certain of CAMIL’s subsidiaries and affiliates, which are companies not registered with the SEC (each,
a “Participating Affiliate”), may have access to information (such as through employees who work for
both CAMIL and an unregistered CAMIL subsidiary or affiliate) concerning securities recommendations
for the related adviser’s U.S. clients. Please see Item 10 for a more detailed discussion of such
Participating Affiliate arrangements.
As of September 30th, 2023, CAMIL has $17,580,730,345 in discretionary assets under management and
does not have non-discretionary assets under management.
Limitation on Services
As an asset manager, CAMIL provides a specific service. CAMIL does not provide tax, legal, or accounting
advice, and clients should note that, unless otherwise specifically agreed or disclosed in writing, CAMIL
will not take tax considerations into account in managing a client’s portfolio.