Background
Polen Capital Credit, LLC (“Polen Credit”), which has operated continuously since its inception in
1996, provides investment advice directly to various institutional clients, including corporate
pension plans (both domestic and non-U.S.), public retirement plans, and Taft-Hartley plans. Polen
Credit also acts as investment sub-adviser to certain U.S. and non-U.S. investment advisers and asset
managers; in such capacity, Polen Credit serves as an investment sub-adviser on behalf of certain U.S.
open-end investment companies (mutual funds) registered with the SEC pursuant to the Investment
Company Act of 1940, as amended (the “1940 Act”). In addition, Polen Credit also serves as sole
investment adviser to certain mutual funds registered with the SEC pursuant to the 1940 Act, as well
as investment adviser to certain pooled private investment vehicles and at least one qualifying
investor alternative investment fund (“QIAIF”) within an Irish Collective Asset-management Vehicle.
Since 1997, the firm, which is organized as a Massachusetts limited liability company, has been
registered as an investment adviser with the Securities and Exchange Commission (“SEC”).
On January 31, 2022, Polen Capital Management, LLC (“Polen Capital”, and together with Polen Credit,
“Polen”), another investment adviser registered with the SEC, acquired 100% of the outstanding
equity units of Polen Credit. Accordingly, as of such date, Polen Credit became a wholly-owned
subsidiary of Polen Capital. Furthermore, upon the consummation of such transaction, Stanley Moss,
the chief executive officer of Polen Capital, became the Chief Executive Officer of Polen Credit. Shortly
following such transaction, Polen Credit changed its name from DDJ Capital Management. Please refer
to the Form ADV for Polen Capital for additional information about its respective ownership and
operations.
By virtue of owning 100% of the outstanding equity units of Polen Credit, Polen Capital controls Polen
Credit. Polen Capital, which is employee controlled, has established a management committee. This
management committee is controlled by Mr. Moss and Daniel Davidowitz, a portfolio manager and
analyst at Polen Capital. By virtue of their control over the management committee of Polen Capital,
the parent company of Polen Credit, Messrs. Moss and Davidowitz may be deemed controlling
persons of Polen Credit.
Advisory Services Offered by Polen Credit
Polen Credit offers investment advisory services that specialize in identifying investment
opportunities among high yield and financially stressed companies operating primarily in the United
States. Polen Credit’s distinctive investment style generally focuses on the lower tier of the non-
investment grade credit markets, particularly high yield bonds and bank loans as well as, to a much
lesser extent, distressed debt and reorganized and leveraged equities. In providing such advisory
services, irrespective of the specific investment strategy implemented on behalf of a client, Polen
Credit adheres to a value-oriented, “bottom-up”, fundamental investment approach with an
emphasis
on downside protection. As part of this fundamental analysis, Polen Credit attempts to create a
comprehensive overview of the company targeted for investment by examining both its current and
future business prospects. More detailed information regarding Polen Credit’s advisory services, its
method of analysis, and the significant investment strategies that Polen Credit pursues on behalf of
its clients is set forth in Item 8 of this Brochure.
Although Polen Credit pursues highly focused investment strategies, Polen Credit nonetheless
customizes its advisory services to the individual needs and requirements of its institutional clients,
which may choose to establish separately managed accounts with Polen Credit. Such clients may,
and frequently do, impose restrictions on investing in certain securities or types of securities, as
further set forth in the applicable written advisory agreement(s) entered into with Polen Credit.
In 2016, Polen Credit initially became a signatory to the United Nations-supported Principles for
Responsible Investment (“UNPRI”). In 2022, following the acquisition of Polen Credit by Polen
Capital, Polen Credit and Polen Capital elected to combine as a single UNPRI signatory (under the
Polen Capital name). The UNPRI initiative is based on six principles that address the integration of
environmental, social and governance (“ESG”) factors into investment decision-making practices. As
part of this commitment to the UNPRI, Polen Credit has agreed to integrate ESG factors, where
appropriate and consistent with its fiduciary duty to its respective clients, into its investment
research and portfolio construction process, and annually report such ESG efforts to the UNPRI on a
comprehensive basis. However, Polen Credit does not systematically apply specific ESG and/or other
socially responsible exclusionary restrictions (e.g., an investment restriction with respect to
securities issued by companies developing cluster munitions) in its client portfolios unless
specifically directed to do so by a client.
Polen Credit does not participate in a wrap fee program.
Assets Under Management
As of February 29, 2024, Polen Credit managed approximately $7.5 billion of assets held in either
separately managed accounts or pooled investment vehicles (including private investment funds as
well as proprietary U.S. mutual funds and an Irish-domiciled QIAIF). All such assets are managed by
Polen Credit on a discretionary basis, although certain funds and accounts are in their wind-down or
termination stage and accordingly Polen Credit is no longer making any new investments on their
behalf. In addition to the foregoing, Polen Credit has entered into an investment advisory agreement
with a family office client whereby Polen Credit has agreed on its behalf to execute client-directed
trades in the high yield bond primary market. As Polen Credit does not provide any continuous and
regular supervisory or management services with respect to such non-discretionary account, Polen
Credit does not manage any specific amount of assets with respect to such client.