The Company
Insight Investment International Limited (“IIIL”) is a limited liability company, formed in 1991, organized under
English law and was originally known as Pareto Partners until it became a limited liability company previously
called Pareto Investment Management in 2005 after it became wholly owned by The Bank of New York Mellon
Corporation (“BNY Mellon”). IIIL became a subsidiary of Insight Investment Management Limited (“IIML”),
another wholly owned subsidiary of BNY Mellon on January 1, 2013.
IIIL is part of the group of affiliated companies that individually or collectively provide investment advisory
services under the brand ‘Insight’ or ‘Insight Investment’ (“Insight”). Insight includes, among others, the following
affiliated entities: IIIL, Insight North America LLC (“INA”), Insight Investment Management Limited (“IIML”),
Insight Investment Funds Management Limited (“IIFM”) and Insight Investment Management Global Limited
(“IIMG”) (each an “Insight Affiliate” and collectively, “Insight Affiliates”). Insight Affiliates are also affiliated with
other BNY Mellon subsidiaries (“BNY Mellon Affiliates” and, collectively with Insight Affiliates, “Affiliates”).
IIIL is authorized and regulated in the UK by the Financial Conduct Authority (“FCA”) and registered as a
portfolio manager and a commodity trading manager in Ontario , Canada and as a portfolio manager in Alberta,
British Columbia, Manitoba, Nova Scotia, Quebec and Saskatchewan. In addition, IIIL is registered in the
United States with the Securities and Exchange Commission (“SEC”) as an investment adviser and with the
Commodity Futures Trading Commission as a Commodity Trading Advisor, and is a member of the National
Futures Association (“NFA”). In addition, in providing services to non-US clients, IIIL is also subject to other
foreign registration and regulatory requirements. IIIL has clients in the US, Canada, Europe, Asia and Australia.
Clients include state and corporate pension funds, insurers, financial institutions and registered investment
companies. IIIL has a branch registered in Tokyo, Japan, that provides client servicing to Japanese clients.
Assets under Management
As of December 31, 2022, IIIL managed approximately $1.5 billion of regulatory assets under management
(“AUM”) on a discretionary basis and $443 million on a non-discretionary basis.
IIIL AUM is generally aggregated with the AUM of its Insight Affiliates in advertisements, marketing and other
promotional materials (“Marketing Materials”). The AUM used in the Marketing Materials is calculated differently
than the regulatory AUM listed herein. The marketing AUM represented by the value of the client’s assets or
liabilities
IIIL is asked to manage. These will primarily be the mark-to-market value of securities managed on
behalf of clients, including collateral, if applicable. Where a client mandate requires IIIL to manage some or all
of a client’s liabilities (e.g., LDI strategies), AUM will be equal to the value of the client specific liability
benchmark and/or the notional value of other risk exposure through the use of derivatives.
A substantial amount of the Insight AUM is represented by IIMG and IIFM and its use of their derivatives
managed in client accounts. In addition, the Insight AUM includes any liabilities that the client has mandated
Insight to manage. IIMG and IIFM are investment managers registered with the Financial Conduct Authority
and are domiciled in the United Kingdom. IIMG and IIFM are not currently registered with the Securities &
Exchange Commission.
6 INSIGHT INVESTMENT
Our Services
IIIL provides discretionary and non-discretionary investment advisory services to institutional investors in the
form of separate account and pooled vehicles across a wide variety of fixed income risk management strategies
including currency risk management and liability driven investing, absolute return and multi -asset capabilities.
Additional information regarding its strategies, including the methods of analysis, fees, and certain material
risks, is included under Item 8, ‘Methods of Analysis, Investment Strategies and Risk of Loss’.
IIIL provides tailored investment advisory services. Discretionary separate account clients may impose
investment restrictions and other guidelines on the management of the account; however, doing so will limit
IIIL’s ability to act for the account and, therefore, the performance of the account will differ and could be lower
than the performance of other discretionary accounts managed in the same or similar strategy. Under certain
circumstances, IIIL will decline to accept certain client-imposed guidelines or restrictions. Please see Item 16 for
additional information about investment guidelines and restrictions.
Similarly, some clients may limit IIIL’s discretion with respect to the management of their account assets (non-
discretionary accounts). In these instances, IIIL’s ability to transact will be limited .
Therefore, the performance of such accounts may differ and may be lower than the performance of
discretionary accounts managed in the same or similar strateg y. Under certain circumstances, IIIL may decline
to accept certain non-discretionary accounts.
For more information on non-discretionary accounts, please see ‘Potential Conflicts Relating to Non-
Discretionary Advisory Services’ in Item 11.
7 INSIGHT INVESTMENT