A. Firm Description
We are a disciplined, value-oriented, global investment management firm committed to capital
preservation and long-term growth. Since Dalton Investments LLC (a predecessor of Dalton
Investments, Inc.) was founded in 1999, our strategies have focused on investments in Asian and
Global equity securities, and in 2018, we initiated an Emerging Markets equities strategy. We
generally look for less crowded areas of the markets with the objective of generating positive long-
term returns on an absolute and relative basis.
We were formed as a Nevada corporation in 2019. Mr. James B. Rosenwald III serves as the Chief
Investment Officer, Founding Partner, and the Chairman of the Board of the Directors of Dalton.
Gifford Combs, who also was one of the Founding Partners of Dalton Investments LLC (along
with Mr. Rosenwald), serves as the Treasurer, the Secretary, and a Director of Dalton’s Board and
has portfolio management responsibilities. We also have established a Management Committee
to run the firm’s day-to-day business, composed of our most senior executives: (i) the Chief
Executive Officer/President, (ii) the Chief Operating Officer/Chief Financial Officer, (iii) the
Chief Marketing Officer, (iv) the Chief Research Officer and Chief Sustainability Officer and (v)
the Chief Compliance Officer and Counsel. As of the date of this document, Dalton is wholly
owned by Dalton Investments LLC. Rosenwald Capital Management, Inc., for which Mr.
Rosenwald serves as the President, is a majority-owner and the sole Managing Member of Dalton
Investments LLC.
B. Advisory Services
We provide discretionary investment advisory services to a select group of domestic and foreign
institutional clients including pension plans, charitable organizations and endowments. The
investment parameters of each such separately managed account will vary by strategy, client
specific guidelines and applicable regulations.
In addition, we also provide discretionary investment advisory services to commingled funds. The
investors for the funds include domestic and foreign institutional investors, high net-worth family
offices and individuals.
Certain of our commingled funds are structured as “master-feeders” with a domestic feeder,
whereby U.S. taxable investors are admitted as limited partners to a Delaware limited partnership
and a foreign feeder, whereby U.S. tax exempt entities and foreigners are admitted as shareholders
of a Cayman corporation.
The “feeder” funds generally contribute all their assets to a master (Delaware or Cayman Islands)
limited partnership which trades
and holds investments on behalf of the feeder funds.
In addition to the “master-feeders,” Dalton has also established various other structures for its
commingled funds, including one that is structured as a Delaware statutory trust.
Commingled funds are offered only by private placement and are limited to accredited and
qualified investors as defined by the SEC.
We have included in our ADV Part 1A the list of our private funds managed on a discretionary
basis. In addition to the fund disclosures, Part 1A includes information about our affiliated entities
that are the general partners to funds. Part 1A is available on the SEC’s website or by contacting
us.
As of the date of this document, we also serve as a sub-adviser or delegated investment manager
to certain UCITS funds formed in the European Union, which are distributed by the applicable
investment company (or their affiliates) to qualified investors subject to each country’s laws and
regulations.
C. Customized Services
Our advisory services will vary by client, but we typically have broad and flexible investment
parameters and may make investments outside of the core strategies when the opportunity arises
and the investment fits our investment philosophy.
For example, certain client accounts and funds may utilize margin borrowing and other forms of
leverage. Our client mandates may permit us to invest in long and short positions as well as certain
illiquid securities and jurisdictions. Investment parameters and limitations are described in each
client’s respective advisory contract.
Similarly, the holdings for the pooled investment vehicles which Dalton advises will vary by and
within a strategy. The variance is attributable to differing investment strategies, various
investment restrictions and tailoring for certain investor limitations or requests.
We may emphasize or deemphasize, add, develop or eliminate different investments and strategies
from time to time depending upon, among other factors, our view of new market opportunities or
regulatory changes.
To the extent that our clients are commingled funds, we provide advisory services to the
commingled funds and not to the individual investors in such funds.
In addition, we may enter into separate agreements with certain investors in our commingled funds
which may provide more favorable terms than those provided to our other investors.
D. Wrap Fee Programs
None.
E. Client Assets
As of December 31, 2023, the regulatory assets under management of Dalton and its affiliates were
$4,059,517,878 (based on unaudited numbers). We also manage a non-discretionary account.