Advisory Firm
Blue Swell Asset Management Private Limited (“Blue Swell” or the “Firm”) is an exempt
private company limited by shares, incorporated in Singapore on January 02, 2018. The Firm
is wholly owned and controlled by Tomofumi Oda (“Mr. Oda”) who serves in the roles of
Director, Chief Executive Officer and Chief Investment Officer for the Firm. Further, Mr. Oda
serves as Director of Blue Swell Japan Market Neutral Master Fund (the “Master Fund”) and
Blue Swell Japan Market Neutral Fund (the “Feeder Fund”) respectively, together with two
other independent directors. Both the Master Fund and Feeder Fund (collectively, the
“Fund”) are exempted companies with limited liability, incorporated under the laws of the
Cayman Islands.
Currently, the Firm acts as the Investment Manager of the Fund. Subject to control and
supervision of the Fund’s Directors, the Firm has full discretion to manage and invest the assets
of the Fund.
Further, the Firm acts as the Investment Adviser to certain private pooled investment vehicles
which are managed by unaffiliated SEC registered investment advisers (“Sub-Advised
Funds”).
No registration statement has been or will be filed with the U.S. Securities and Exchange
Commission (the “SEC”) or any state securities authority with respect to any offering of the
Fund. The Shares have not been and will not be registered under the United States Securities
Act of 1933, as amended (the “1933 Act”) or the securities laws of any of the states of the
United States. Furthermore, the Fund has not been and will not be registered under the
United States Investment Company Act of 1940, as amended (the “1940 Act”) since Shares
will only be sold to US Persons who meet the status of “qualified purchasers”, as defined in
the 1940 Act. Each subscriber for Shares that is a US Person will be required to certify that
it is an “accredited investor” and a “qualified purchaser”, in each case as defined under
applicable US federal securities laws, thereby also qualifying as a “qualified eligible person” as
defined in Rule 4.7 under the United States Commodity Exchange Act, as amended (the
“CEA”).
Types of Services Offered
The principal activity of the Firm is to provide discretionary investment management services.
including investment advisory services, specializing in Asia and with predominant focus on
Japan related investments.
The Firm provides
investment management services to the Fund based on specific investment
objectives and strategies. The Fund’s offering documents (as amended and supplemented from
time to time) set forth the investment guidelines and/or the types of investments to be
transacted in by the Firm on behalf of the Fund. Together with its affiliates, the Firm also
provides investment advisory services to the Sub-Advised Funds. Collectively, both the Fund
and Sub-Advised Funds are referred to as “Clients”.
Ability to Tailor Services and Impose Restrictions
The investment objective of the Fund is to achieve absolute returns through emphasis on deep
fundamental understanding of investment ideas, analysis of companies across all industries and
sectors from large cap to small cap, predominantly in Japan, in corporate research and investing
across market cycles. The Firm provides investment management services to the Fund based
on the specific investment objectives and strategies of the Fund and not individually to
investors in the Fund (the “Investors”). Since the Firm does not provide tailored advice to
the Fund’s Investors, such investors should consider whether the Fund’s investment strategies
are in line with their risk tolerance. The Firm and/or the Fund may from time to time enter
into side letter agreements or other similar agreements (“Side Letters”) providing certain
seed or strategic investors with additional and/or different rights.
The Firm has entered into Side Letters with certain investors of the Fund. The Side Letters
with certain investors of the Fund do not provide preferential liquidity or redemption rights
to the respective investors of the Fund. In addition, there are no material potential conflicts
to the Fund or its investors as the mentioned arrangements do not in any way serve as a
detriment to the Fund or its investors. The Fund’s Directors may reduce the minimum
subscription amounts to the Fund in consultation with the Firm, subject to requirements under
applicable laws.
Wrap Fee Programs
The Firm does not participate, sponsor or act as a portfolio manager for any wrap fee
programs.
Client Assets
As of December 31, 2023, the Firm has approximately US$1,187,508,987 regulatory assets
under management, all of which it manages on a discretionary basis.
Performances, fees and capital activity (i.e., subscriptions and redemptions) are denominated
in US dollars (US$).