Firm Description
KBI Global Investors (North America) Ltd. (“Registrant”), an Irish corporation, has provided discretionary investment advisory
services to funds, including mutual funds (the “Funds”) and separately managed accounts (“Separate Accounts” and,
collectively with the Funds, “Clients”) since 2001. In providing these services, Registrant directs and manages the investment
and reinvestment of assets in Client accounts. Registrant also provides non-discretionary investment advisory services in the
form of investment model provision to other clients.
Registrant is a MiFID investment firm, authorised under Regulation 8 (3) and deemed authorised under Regulation 5 (2) of
the Statutory Instrument No. 375/2017 European Union (Markets in Financial Instruments) Regulations 2017 (“MiFID II”).
Registrant is regulated by the Central Bank of Ireland. As a MiFID investment firm, amongst other requirements, Registrant
is obliged to:
• maintain and operate effective organizational and administrative arrangements with a view to taking all reasonable
steps designed to prevent conflicts of interest from adversely affecting the interests of Clients,
• maintain, operate, and review a product approval process before marketing or distributing such products,
• take reasonable steps to ensure continuity and regularity in the performance of investment services and activities
by employing appropriate and proportionate systems, resources, and procedures, including maintaining a business
continuity plan,
• ensure the firm has sound administrative and accounting procedures, internal control mechanisms, effective
procedures for risk assessment, and effective control and safeguard arrangements for information processing
systems,
• maintain the confidentiality of data at all times, guarantee the security and authentication of the means of transfer
of information, minimize the risk of data corruption and unauthorized access, and prevent information leakage,
• arrange for records to be kept of all services, activities and transactions undertaken by the firm,
• not accept and retain fees, commissions or any monetary or non-monetary benefits paid or provided by any third
party or a person acting on behalf of a third party in relation to the provision of portfolio management services to a
Client or Clients, and
• take all sufficient steps to obtain the best possible result for Clients taking into account price, costs, speed, likelihood
of execution and settlement, size, nature and any other consideration relevant to the execution of the order and,
whenever there is a specific instruction from a Client, execute the order in line with the specific instruction.
In terms of ownership, Registrant is a wholly owned subsidiary of KBI Global Investors Ltd. (“KBIGI”). KBIGI is 100% owned by
Amundi Asset Management and Amundi Asset Management is 100% owned by Amundi S.A., which is a publicly traded
company on the French stock exchange and which is majority owned by Crédit Agricole S.A. (approximately 70% at 31st
December 2023). The remaining shares of Amundi S.A. are held by institutional and retail investors.
In terms of jurisdictions, while Registrant provides investment advisory services to Clients across the U.S., Registrant is also
licensed to transact as an investment adviser in Guam (IA-10146). In Canada, Registrant is availing of the International Adviser
exemption in Ontario and Quebec.
Types of Advisory Services
A. Funds
(i) KBI Global Investors Aquarius Fund
Registrant serves as the investment adviser to the KBI Global Investors Aquarius Fund, a separate series of the Advisors’ Inner
Circle Fund III (the “Trust”). The Trust is an open-end investment management company established under Delaware law as
a Delaware statutory trust under a Declaration of Trust dated December 4, 2013 (the “Declaration of Trust”). The KBI Global
Investors Aquarius Fund is registered under the Investment Company Act of 1940, as amended (the “Investment Company
Act”) and was launched on October 12th, 2018.
Further details relating to this fund can be found at:
https://www.kbigiusmutualfunds.com/
(ii) Skellig Delaware Statutory Trust
Registrant serves as the investment adviser to the Skellig Delaware Statutory Trust (“DST”), a Delaware Business Trust.
This Trust has several sub-funds, which are as follows:
Sub funds of the Skellig Delaware Statutory Trust
1. Skellig DST Water Fund
2. Skellig Integris Emerging Markets Fund
3. Skellig DST GRS Fund (unlaunched)
4. Skellig DST Global ESG Fund (unlaunched)
Interests in the DST are not registered with the Securities and Exchange Commission (“SEC”) under the Securities Act of 1933,
as amended (the “Securities Act” or the “’33 Act”), and the DST is not registered under the Investment Company Act.
Accordingly, interests in the DST are offered and sold exclusively to investors satisfying the applicable eligibility and suitability
requirements in private transactions within the United States.
(iii) KBI Global Investors (NA) Ltd. (CIT)
Registrant serves as the investment adviser to the KBI Global Investors (NA) Ltd. CIT (“CIT”), which is a collective investment
trust, that the SEI Trust Company has established. SEI Trust Company, organized under the laws of the Commonwealth of
Pennsylvania, acts as trustee of the CIT. The Declaration of Trust of the CIT (the “Declaration of Trust”) has been filed with
the Department of Banking and Securities for the Commonwealth of Pennsylvania and the Internal Revenue Service has
approved the tax-exempt status of the CIT.
The CIT consists of separate Funds, including:
• KBI Emerging Markets Equity CIT
• KBI EAFE Markets Equity CIT (now dormant)
• KBI Global Resources Solutions CIT
The CIT is exempt from federal income taxation and from registration with the SEC under the Securities Act and the CIT is not
registered under the Investment Company Act. In order to preserve these exemptions, the CIT may only accept assets of
“Eligible Plans,” such as qualified pension and profit-sharing plans, governmental plans that provide retirement income
benefits, ERISA plans, etc. Please refer to the Declaration of Trust for more information. Accordingly, units in the CIT are
offered and sold exclusively to investors satisfying the applicable eligibility and suitability requirements in private transactions
within the United States.
(iii) Marketing of Strategies
Registrant’s business model is to market its strategies to institutional prospects and their advisors / consultants, rather than
marketing individual products. As a result, Registrant does not consider the firm to be “directly” marketing Funds. Registrant
offers several different vehicles, including Funds by means of a private placement under Regulation D. As a result, Registrant
has formed long-standing relationships with certain investors in its Funds (the “Investors”).
B. Separate Accounts
Registrant provides the following strategies, with all sub-strategies referenced available on a Separate Account basis:
Strategy 1. Global Equity Strategies 2. Natural Resource Strategies
Sub-Strategies • Developed Equity
• International Equity
• Emerging Markets Equity
• Integris- Emerging Markets Equity
(ESG)
• Global Equity (ESG)
• North America Equity
• Global Small Cap Equity
• Emerging Market Small Cap Equity
• EAFE Small Cap Equity
• Euroland Equity
• ACWI Equity
• Water
• Global Energy Transition
• Global Resource Solutions
• Global Sustainable Infrastructure
• Circular Economy
Registrant provides investment advisory services in relation to the outlined strategies, tailored to the specific needs of each
Separate Account Client. Prior to providing investment advisory services, Registrant will ascertain each Separate Account
Client’s investment objectives. Separate Account Clients may, at any time, impose reasonable restrictions, in writing, on
Registrant’s services.
As of December 31, 2023, Registrant had $3.078bn in regulatory assets under management on a discretionary basis.
C. Non-Discretionary Investment Advisory Services
Registrant also provides non-discretionary investment advisory services in the form of the provision of investment model
portfolios relating to its strategies to third party investment advisers. Registrant had no assets under management on a non-
discretionary basis as of December 31, 2023.