href="http://www.sevencanyonsadvisors.com/">), and on the EDGAR database on the SEC’s website
(www.sec.gov).
Global Emerging Companies Strategy
The Global Emerging Companies Strategy, at this time, is employed for SMA and for the Ark
Global Emerging Companies, L.P. (the “EC Fund”) that Seven Canyons serves as the
investment manager and general partner to. The Global Emerging Companies Strategy is
identical to the investment objectives set forth in the EC Fund’s confidential offering
memorandum and such investments are not tailored to the induvial needs of any particular
limited partner or SMA.
Client-Tailored Strategies
Seven Canyons also employs client-tailored strategies. These strategies are negotiated on
a case-by-case basis. These portfolios are similar to the IM’s primary strategies but are
managed with a particular emphasis on fewer holdings and/or on a specific geographic area,
industry, or sector. Client objectives and fees are determined on a case-by-case basis.
When we provide investment advice to you regarding your retirement plan account, we are
fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act
and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way we make money creates some conflicts with your interests, so we
operate under a special rule that requires us to act in your best interest and not put our
interest ahead of yours.
• Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put our financial interests ahead of yours when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your
best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
As of December 31, 2022, the IM had $177,711,020 in assets under management
.