Polen Capital is a limited liability company and is organized under the laws of the State
of Delaware.
Polen Capital is employee controlled. Polen Capital is controlled by Stanley C. Moss,
Chief Executive Officer; Daniel Davidowitz, Portfolio Manager and Analyst; and Damon
Ficklin, Head of Team, Portfolio Manager, and Analyst. Polen Capital is registered as an
Investment Adviser with the United States Securities and Exchange Commission in order
to provide the investment advisory products and services described within this document.
We have been registered since April 1980.
As of December 31, 2023, our assets consisted of:
Amount of Assets
Discretionary1 $43,238,955,480
Non-Discretionary $0
Assets under Advisement2 $14,837,283,888
Total3 $58,076,239,369
We have a subsidiary, Polen Capital UK LLP (“Polen Capital UK”), with its principal place
of business in London, primarily in order to employ individuals residing in the UK who are
members of our Emerging Markets Growth Team or who are involved with the distribution
of Polen Capital products outside of the Americas. As disclosed in this Brochure, Polen
Capital UK subadvises funds invested in the Emerging Markets Growth Strategy, in which
case Polen Capital UK provides portfolio management services and we, as investment
manager, provide other services, such as trading. Polen Capital HK Limited (“Polen
Capital HK”), with its principal place of business in Hong Kong, is a wholly-owned
1 This is equivalent to the regulatory assets under management disclosed in Item 5.F of Adviser’s Form
ADV Part 1A.
2 Assets under advisement represent our UMA or Model assets, for which we have neither discretionary
authority nor responsibility for arranging or effecting the purchase or sale of recommendations provided to
and accepted by the ultimate client. Inclusion of these assets will make our total assets number different
from regulatory assets under management disclosed in Item 5.F of Adviser’s Form ADV Part 1A due to
specific calculation instructions for Regulatory Assets Under Management. Please note that based on
certain contractual provisions, our “discretionary” assets include one UMA.
3 Assets in this table do not include any assets in accounts solely managed or advised by Polen Capital
Credit, Polen Capital UK or Polen Capital HK. Information regarding Polen Capital Credit’s assets may be
found in the Part 2A of Polen Capital Credit’s Form ADV.
subsidiary of Polen Capital UK and employs members of our Emerging Markets Growth
Team who manage assets for a China Growth strategy.
We also have a subsidiary, Polen Capital Credit, LLC (“Polen Capital Credit”), which is
based in Waltham, Massachusetts. Polen Capital Credit offers investment advisory
services that specialize in identifying investment opportunities among high yield and
financially stressed companies operating primarily in the United States and, to a much
lesser extent, Canada. Polen Capital Credit has been registered with the SEC since 1997
and continues to maintain its own registration with the SEC. Additional information about
Polen Capital Credit is available on the SEC’s website at www.adviserinfo.sec.gov (go to
the link, select “Investment Adviser Search” and type in Polen Capital Credit). Results
will provide you with both Parts 1A and 2A of Polen Capital Credit’s Form ADV.
Please contact Polen Capital at 1 (561) 241-2425; facsimile 1 (561) 241-2710; or
compliance@polencapital.com if you have any questions about this Brochure. This
Disclosure Brochure provides you with information regarding our qualifications, business
practices, and the nature of advisory services that should be considered before becoming
our advisory client.
Below is a description of the investment advisory services we offer. For more detail on
any product or service please reference the advisory agreement or contact Polen at 1
(561) 241-2425; facsimile 1 (561) 241-2710; or info@polencapital.com.
DESCRIPTION OF SERVICES PROVIDED
We are a disciplined, bottom-up, concentrated equity investment manager. Our sole focus
has been high quality growth investments since 1989. Clients may impose reasonable
restrictions on investing in certain securities, types of securities, or industry sectors. Our
investment team maintains our model portfolios based on preferred weights or other
guidelines. Investment guidelines that differ significantly from our preferred guidelines
may result in exclusions or variances in holdings from our model portfolios that may take
additional time for the team to determine alternative holdings or weights for more
restricted accounts. As a result, trades for accounts with materially different restrictions
could experience different execution prices and different performance than less restricted
accounts based on the exclusions and time delay in trade placement. Such restricted
accounts also may be placed in a performance composite separate from less restricted
accounts in our strategies. We manage separately managed and wrap accounts for
various client types including high net worth individuals and family offices, endowments
and foundations, corporations, Taft Hartley accounts, sovereign nations, and public funds.
In addition to our separately managed and wrap accounts, our strategies are also
available through registered investment companies, Undertaking for Collective
Investment in Transferable Securities (“UCITS”) funds, private funds, and a collective
investment trust.
Separately Managed and Wrap Accounts
Polen Capital offers clients the opportunity to open an individually managed account with
investment management services provided by Polen Capital. Polen Capital also serves
as a portfolio manager for certain clients of unaffiliated investment advisors in connection
with wrap fee programs. After consulting with the unaffiliated investment advisors, some
of those advisors’ clients select Polen Capital to manage equity accounts. The unaffiliated
investment advisors serve as the primary client contact with regard to such clients, and
work with their clients to develop, and keep current, investment guidelines and to
determine the amount to be allocated to their clients’ account managed by Polen Capital.
These clients pay a single fee covering the services rendered by both the unaffiliated
investment advisor and Polen Capital, and Polen Capital receives a portion of this fee for
its services. Investment management services provided to wrap fee clients are
substantially the same as those provided to non-wrap fee clients. However, practical
restraints to the management of wrap fee accounts may exist. Most notably, the smaller
asset value of certain wrap fee accounts may result in slightly different returns due to
investment limitations imposed by investment restrictions, administrative restrictions, and
the wrap fees imposed by wrap fee sponsors.
Polen Capital also participates in model delivery programs whereby Polen Capital will not
place trades for clients’ accounts in connection with its investment recommendations.
Rather, Polen Capital will provide its recommendations to the client’s adviser or broker
and such adviser or broker will be responsible for implementing the recommendations.
U.S. Mutual Funds
Polen Capital is the Investment Adviser to FundVantage Trust’s Polen Growth Fund,
Polen Global Growth Fund, Polen International Growth Fund, Polen U.S. Small Company
Growth Fund, Polen U.S. SMID Company Growth Fund, Polen Global SMID Company
Growth Fund, Polen Emerging Markets Growth Fund, and Polen Emerging Markets ex
China Growth Fund, (each, a “Fund” and together, the “Funds”), each an open-ended
investment company; and receives a fee for its services. Polen Capital UK provides
services to the Polen Global Emerging Markets Growth Fund, the Polen Emerging
Markets ex China Growth Fund, and the Polen Global SMID Company Growth Fund
through a “participating affiliate” arrangement, under which Polen Capital uses portfolio
management and research resources of Polen Capital UK. Refer to the relevant Fund’s
prospectus for details of its fees and expenses.
Polen Capital does not directly advise on or trade in any fixed-income securities; however,
its subsidiary Polen Capital Credit, subadvises an account that invests in both global
equities selected by Polen Capital and fixed-income instruments by Polen Capital Credit.
Irish UCITS Funds
Polen Capital is the investment manager and distributor of Polen Capital Investment
Funds plc and Polen Capital Investment Funds II plc (each a “UCITS Fund” and together,
the “UCITS Funds”), each a UCITS product for non-U.S. investors. Each UCITS Fund
operates as an open-ended umbrella investment company incorporated with variable
capital and segregated liability between funds incorporated with limited liability in the
Republic of Ireland and authorized by the Central Bank of Ireland. Polen Capital entered
into an Investment Management Agreement with each UCITS Fund and is responsible
on a discretionary basis for managing the assets and the investments of each UCITS
Fund in accordance with the investment objective and policies of each sub-fund of the
UCITS Funds. Each UCITS Fund is structured as an umbrella fund and is comprised of
several portfolios of assets divided into different classes of shares each representing a
separate portfolio of assets. The sub-funds include Polen Capital Focus U.S. Growth
Fund, Polen Capital International Growth Fund, Polen Capital U.S. Small Company
Growth Fund, Polen Capital Global SMID Company Growth Fund, Polen Capital
Emerging Markets Growth Fund, Polen Capital Emerging Markets ex China Growth Fund,
and the Polen Capital China Growth Fund. Polen Capital UK is the sub-investment
manager of the Polen Capital Emerging Markets Growth Fund and Polen Capital
Emerging Markets ex China Growth Fund. Polen Capital HK, is the sub-investment
manager of the Polen Capital China Growth Fund.
Polen Capital Master Collective Investment Trust
Polen Capital is the investment advisor for the Polen Focus Growth Collective Investment
Trust and the Polen International Growth Collective Trust, each a collective investment
fund under the Polen Capital Master Collective Investment Trust (the “Trust”). SEI Trust
Company serves as Trustee of the Trust. The Trust is regulated by the Department of
Banking and Securities for the Commonwealth of Pennsylvania and is available only to
certain eligible plans.