NewGen Asset Management Limited (the “Firm”) is a Canada domiciled corporation, which was
formed on September 25, 2009. The Firm is a U.S. Securities and Exchange Commission (“SEC”)
registered investment adviser. Registration as an investment adviser does not imply a level of
skill or training. The Firm is wholly owned by NewGen Holdco Limited. NewGen Holdco
Limited is 55% owned by 2716492 Ontario Inc., which is wholly owned by David Dattels.
The Firm currently provides portfolio management services to pooled investment vehicles and
separately managed accounts. Currently, the Firm provides portfolio management services for
NewGen Equity Long/Short Fund Ltd., a Cayman Islands domiciled exempted company, NewGen
Equity Long-Short Fund LP, Newgen (Offshore) LP, NewGen Equity Long-Short Fund RRSP,
NewGen Alternative Income Fund, NewGen Focused Alpha Fund, and NewGen Credit Strategies
Fund (collectively, the “Funds”), and one or more managed accounts or sub-advised accounts (the
“Managed Accounts”, and together with the Funds, the “Clients”), pursuant to investment advisory
agreements. Of the Funds, only NewGen Equity Long/Short Fund Ltd. is available to U.S.
investors; references herein to the Funds and their Offering Documents generally refer only to
NewGen Equity Long/Short Fund Ltd. Investors should carefully review all Fund Offering
Documents prior to investment.
The Firm does not hold itself out as specializing in a particular type of advisory service. Advisory
services include among other things, providing advice regarding asset allocation and the selection
of investments. Decisions relating to investment
advice are based on an analysis of the merits of
the investment involved and on the investment guidelines and restrictions of the Client. The Firm
provides discretionary investment advisory services to all fee paying Client accounts. Lower fees
for comparable services may be available from other sources. In certain circumstances,
particularly with respect to Managed Accounts, the Firm will tailor its advisory services.
Additionally, Clients may impose restrictions on investing in certain securities or certain types of
securities.
The principals of the Firm have ownership of, and operate an independent company, AXE2
Acquisitions Inc. ("AXE2"), which is incorporated in BC, Canada for the purpose of potential
acquisitions. AXE2 does not perform any advisory function and is not related to the Clients of the
Firm.
The principals of the Firm have ownership of, and operate an independent company, NewGen
Capital Limited, which is incorporated in ON, Canada, a personal investment company. NewGen
Capital Limited does not perform any advisory function and is not related to the Clients of the
Firm. David Dattels is a president and a director of NewGen Capital Limited.
The Firm does not participate in wrap fee programs.
As of December 31, 2023, the Firm managed approximately $780,951,000 on a discretionary basis
and $0 on a non-discretionary basis. Approximately $47,781,000 of such assets are attributable to
U.S. investors in NewGen Equity Long/Short Fund, which currently is the only Fund available to
U.S. investors, and approximately $40,390,700 of such assets are attributable to Managed
Accounts.