DSM was founded in March 2001 by Stephen E. Memishian and Daniel B. Strickberger. In general,
DSM employs a bottom-up, growth stock selection investment process with an intermediate to long-term
investment horizon. DSM combines fundamental research with a valuation methodology designed to
reduce risk and enhance long-term returns. DSM seeks growing businesses with attractive returns, solid
business fundamentals, and intelligent management. There is no guarantee that DSM’s investment
process will be successful or that clients will not incur losses.
DSM typically provides advisory services to a client on a discretionary basis pursuant to model
investment strategies. The model investment strategies are US Large Cap Growth, Global Growth,
Dividend Growth, Global Focus Growth and International Growth. DSM has, and expects to continue to
create, test and manage other model investment strategies with employees and employee related accounts
prior to managing client assets in the models. In general, such strategies are subject to DSM’s policy and
procedures listed herein with certain exceptions.
A client can invest in DSM model investment strategies through separately managed accounts, sub-
advisory relationships, pooled investment vehicles, and wrap-fee programs. However, not all client
accounts will match the relevant model investment strategy at all times. Clients are generally permitted to
impose reasonable restrictions on their accounts such as prohibiting or restricting certain issuers or
industries. Any restrictions could cause an account to differ from a model investment strategy and
adversely impact performance. The inception date of a client account can also cause significant
differences from the relevant model investment strategy and the differences could last for a considerable
period of time. There is no set time in which a new client account will match the relevant model
investment strategy. In addition, when contributions and withdrawals are made to or from a client
account, the transactions made to satisfy the contributions or withdrawals could cause the account to be
different than the model investment strategy for a period of time. Moreover, a client account might differ
from the relevant model investment strategy while DSM is executing investment changes to a model
investment strategy. This list is not exhaustive of all possible reasons why a client account might not
match the relevant model investment strategy.
As noted above, clients can impose reasonable restrictions on the management of their accounts,
including restricting the purchase of particular securities or types of securities. DSM has discretion to
reject a restriction that DSM believes to be unreasonable. Client imposed restrictions or guidelines that
do not expressly provide compliance evaluation periods are typically implemented by DSM at month end.
In addition, client-imposed percentage-based restrictions (e.g., do not hold more than 12% of XYZ) are
applied on a rounded, whole-number basis unless specifically stated otherwise. For example, an account
with a restriction limiting a holding of XYZ to no more than 12% could reach 12.50% in that holding
without violation and DSM would not be required to take any action until the end of the month.
Additionally, DSM shall not generally be deemed to be in breach of a restriction in a case where there is a
“passive breach” such as an action by the issuer beyond DSM’s control or as a result of market gains or
losses during a compliance evaluation period. DSM utilizes the Global Industry Classification Standard
(GICS), which was developed by MSCI and Standard & Poor's, in connection with its advisory services.
The GICS structure consists of 11 sectors, 25 industry groups, 74 industries and 163 sub-industries. The
structure applies to companies globally and is reviewed annually. DSM also utilizes self-created sectors
(e.g., Internet, Business Services, etc.) in its advisory business. DSM reserves the right to change the
methodology it uses to analyze and apply restrictions without notice to clients.
Common stocks, preferred stocks, convertible securities, rights and warrants are examples, but not all, of
the equity securities of issuers in which DSM generally invests. All investments in equity securities are
subject to market risks that can cause their prices to fluctuate over time. DSM can invest in equity
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securities of domestic and foreign issuers. In determining whether an issuer is domestic or foreign, DSM
considers, in its sole discretion, various factors including, but not limited to, where the issuer’s principal
trading market is located, where the issuer is headquartered, where the issuer’s principal operations are
located, and/or the country in which the issuer is legally organized. The weight given to each of these
factors will vary depending upon the facts and circumstances as determined by DSM and they can change
over time without notice. DSM has traditionally defined shares of foreign domiciled issuers that
primarily trade on US exchanges or over-the-counter markets (defined below) as domestic equity
securities. Although it will seek to apply determinations consistently across all model investment
strategies and client accounts, DSM could classify any security differently among strategies and there can
be material differences due to various factors, including, but not limited to, business matters, legal
restrictions, regulatory rules and taxes. While DSM primarily invests in equity securities of foreign
issuers located in developed market countries, it also invests in issuers in developing or emerging market
countries. DSM also invests in US dollar-denominated securities of foreign issuers, including, but not
limited to, American Depositary Receipts (“ADRs”).
Unless a client has specified in writing that DSM cannot hold cash of more than a specified amount, DSM
could choose from time to time to assume a temporary defensive position by investing all or a portion of a
client’s assets in cash, cash equivalents, including those of foreign countries, money market instruments,
or securities of other no-load mutual funds.
It is important to note that even where DSM advises clients with respect to the same or similar securities,
there can be timing differences related to the transmission of that advice to clients and a subsequent
determination of whether to act on that advice. DSM could execute trades for clients in advance of DSM
communicating with other clients about those trades. As a result, some clients could receive prices that
are less favorable than prices obtained for other clients. In other cases, DSM could decide to separate
advice for types of clients. These client accounts could also deviate from DSM’s model investment
strategy.
DSM does not participate in class-actions.
As of December 31, 2023, DSM’s discretionary assets under management were approximately USD
$6,600,000,000 and its non-discretionary assets under management were approximately USD
$460,000,000.
Model Investment Strategies
DSM has five published model investment strategies each designed to meet a particular investment goal.
The model strategies are US Large Cap Growth, Global Growth, Dividend Growth, Global Focus Growth
and International Growth. DSM has, and expects to continue to create, test and manage other model
investment strategies with employees and employee related accounts prior to managing client assets in the
models. In general, such strategies are subject to DSM’s policy and procedures listed herein.
US Large Cap Growth
In general, the US Large Cap Growth strategy will invest in domestic equity securities of US large
capitalization issuers. Domestic equity securities, as determined by DSM in its discretion, include, but
are not limited to, common stocks, preferred stocks, securities convertible into common stocks, rights and
warrants. Shares of foreign domiciled issuers that primarily trade on a US exchange are generally
considered by DSM to be domestic equity securities. Also as determined by DSM, issuers that issue
domestic equity securities could be domiciled and/or headquartered anywhere in the world. The US
Large Cap Growth strategy can generally invest up to 20% of its assets in equity securities of foreign
issuers. A large capitalization issuer is one that has a market capitalization of more than USD 10 billion
at the time of purchase. The US Large Cap Growth strategy can also invest in equity securities of issuers
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that have a market capitalization below USD 10 billion at the time of purchase. The US Large Cap
Growth strategy generally will contain 25 to 35 equity securities.
Global Growth
In general, the Global Growth strategy will invest in equity securities of large capitalization issuers.
Equity securities, as determined by DSM in its discretion include, but are not limited to, common stocks,
preferred stocks, securities convertible into common stocks, rights and warrants. The Global Growth
strategy has no limit on the amount of its assets it can invest in equity securities of domestic or foreign
issuers. A large capitalization issuer is one that has a market capitalization of more than USD 10 billion at
the time of purchase. The Global Growth strategy can also invest up to 20% of its net assets in equity
securities of issuers that have a market capitalization below USD 10 billion at the time of purchase. The
Global Growth strategy generally will contain 25 to 50 equity securities.
Dividend Growth
In general, the Dividend Growth strategy will invest in equity securities without regard to market
capitalization. Equity securities, as determined by DSM in its discretion include, but are not limited to,
common stocks, preferred stocks, securities convertible into common stocks, rights and warrants. The
Dividend Growth strategy has no limit on the amount of its assets it can invest in equity securities of
domestic or foreign issuers. The Dividend Growth strategy generally seeks to have an average dividend
yield in the range of 1% to 2% and generally will contain 25 to 35 equity securities.
Global Focus Growth
In general, the Global Focus Growth strategy will invest in equity securities of large capitalization issuers.
Equity securities, as determined by DSM in its discretion include, but are not limited to, common stocks,
preferred stocks, securities convertible into common stocks, rights and warrants. The Global Focus
Growth strategy has no limit on the amount of its assets it can invest in equity securities of domestic or
foreign issuers. A large capitalization issuer is one that has a market capitalization of more than USD 10
billion at the time of purchase. DSM historically purchased non-US securities (otherwise known as local
shares) for this model investment strategy. Clients can specifically authorize DSM to purchase American
Depositary Receipts or similar securities instead of non-US securities (local shares) for this strategy. The
Global Focus Growth strategy generally will contain 12 or fewer equity securities.
International Growth
In general, the International Growth strategy will invest in foreign equity securities of large capitalization
issuers. Equity securities, as determined by DSM in its discretion include, but are not limited to, common
stocks, preferred stocks, securities convertible into common stocks, rights and warrants. The
International Growth strategy can generally invest up to 20% of its net assets in equity securities of non-
foreign issuers. A large capitalization company is one that has a market capitalization of more than USD
10 billion at the time of purchase. The International
Growth strategy can also invest in equity securities
of issuers that have a market capitalization below USD 10 billion at the time of purchase. The
International Growth strategy generally will contain 25 to 50 equity securities.
Investment Vehicles
Clients and prospective clients can typically invest with DSM through separately managed accounts,
pooled investment vehicles and wrap-fee programs.
Separately Managed Accounts
In general, a separately managed account is an individual investment account held by a qualified
custodian and managed by DSM on a discretionary basis for a fee. Please see Item 5 for information
regarding DSM’s management fees for separately managed accounts. The minimum amount required to
open a separately managed account under the US Large Cap Growth strategy is USD 1,500,000, subject
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to DSM’s discretion. The minimum amount required to open a separately managed account under the
Global Growth strategy, the Global Focus Growth strategy, the Dividend Growth strategy and the
International Growth strategy is USD 5,000,000, subject to DSM’s discretion. Once a model investment
strategy has been selected by a client, the account will be managed based on that model. However, each
client will have the opportunity to place reasonable restrictions on their account. DSM can choose not to
accept an account in its sole discretion.
Pooled Investment Vehicles
A pooled investment vehicle invests in a portfolio of securities that DSM manages and issues interests to
multiple persons. DSM manages three sponsored pooled investment vehicles: two US domiciled and one
non-US domiciled, each as described below. DSM also provides advisory and sub-advisory services to
other pooled investment vehicles that are not listed herein. Where DSM is the investment adviser or sub-
advisory to a pooled investment vehicle, investment objectives, guidelines and any investment restrictions
are generally not tailored to the needs of individual investors in those vehicles, but rather are described in
the prospectus or other relevant offering documents for the vehicle.
DSM All World Growth Trust - The DSM All World Growth Trust is a Delaware Statutory Trust
organized for Accredited Investors, as defined by the Securities Act of 1933, who are also Qualified
Purchasers, as defined by the Investment Company Act of 1940. The DSM All World Growth Trust
has two investment options: the US Large Cap Growth strategy and the Global Growth strategy.
Prior to making any investment in the Trust, qualified, prospective investors should carefully review
the offering documents of the Trust for a comprehensive understanding of its terms and conditions.
This information is intended merely as a brief summary and is provided for discussion purposes only
and does not constitute an offer, agreement or binding commitment by anyone.
DSM US Large Cap Growth CIF - The DSM US Large Cap Growth CIF is a Collective Investment
Fund with an intermediate to long-term investment horizon, generally investing in domestic equity
securities of large capitalization issuers. The DSM US Large Cap Growth CIF is generally managed
under the US Large Cap Growth strategy. The Fund is not regulated under the Investment Act of
1940 but is instead under the regulatory authority of the Office of the Comptroller of the Currency.
Prior to making any investment in the Fund, prospective investors should carefully review the
offering documents of the Fund for a comprehensive understanding of its terms and conditions. This
information is intended merely as a brief summary and is provided for discussion purposes only and
does not constitute an offer, agreement or binding commitment by anyone.
DSM Capital Partners Funds – The DSM Capital Partners Funds was incorporated for an unlimited
period on February 21, 2014 as a société d’investissement à capital variable under the laws of the
Grand Duchy of Luxembourg and qualifies as an open-ended SICAV under part I of the Law of 2010.
DSM Capital Partners Funds presently has two sub-funds: the Global Growth Sub-Fund and the US
Large Cap Growth Sub-Fund. The Global Growth Sub-Fund is managed under the Global Growth
strategy with the following ESG restrictions: The Global Growth Sub-Fund may not invest its net
assets in instruments issued by issuers active in the following areas: (i) tobacco, (ii) pornography, (iii)
fossil fuel production, (iv) fossil fuel services, (v) controversial weapons, (vi) weapons and/or
munitions, (vii) alcohol, and (viii) gambling. Notwithstanding the foregoing (and subject to the
excluded investments referenced above), the Global Growth Sub-Fund may still invest in companies
having revenues up to a maximum of 5% related to (i) fossil fuel services, (ii) weapons and/or
munitions, (iii) alcohol and (iv) gambling. The US Large Cap Growth Sub-Fund is managed under
the US Large Cap Growth strategy with the following ESG restrictions: The US Large Cap Growth
Sub-Fund may not invest its net assets in instruments issued by issuers active in the following areas:
(i) tobacco, (ii) pornography, (iii) fossil fuel production, (iv) fossil fuel services, (v) controversial
weapons, (vi) weapons and/or munitions, (vii) alcohol, and (viii) gambling. Notwithstanding the
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foregoing (and subject to the excluded investments referenced above), the US Large Cap Growth
Sub-Fund may still invest in companies having revenues up to a maximum of 5% related to (i) fossil
fuel services, (ii) weapons and/or munitions, (iii) alcohol and (iv) gambling. DSM has determined
that both the Global Growth and US Large Cap Growth Sub-Funds promote ESG by investing in
companies with strong revenue growth, stable earnings stream and quality management teams, with
consideration given towards the companies’ environmental, social and governance characteristics
according to article 8 of SFDR under Regulation (EU) 2019/2088. These companies tend to have an
elevated awareness of sustainable practices and good governance, and the Sub-Funds seek to promote
climate change mitigation in their investment process. However, such investments currently do not
qualify as environmentally sustainable investments within the meaning of article 3 of regulation (EU)
2020/852 on the establishment of a framework to facilitate sustainable investment, as amended (the
“Taxonomy Regulation”). DSM is keeping this situation under active review and where sufficient
reliable, timely and verifiable data on the Sub-Funds’ investments in light of the requirements of the
Taxonomy Regulation as well as its Delegated Regulation (EU) 2021/2139 become available, DSM
will provide the descriptions referred to above, in which case the offering documents of the DSM
Capital Partners Funds will be updated. Prior to making any investment in the DSM Capital Partners
Funds, prospective investors should carefully review the offering documents of the DSM Capital
Partners Funds for a comprehensive understanding of its terms and conditions. This information is
intended merely as a brief summary and is provided for discussion purposes only and does not
constitute an offer, agreement or binding commitment by anyone.
Wrap-Fee Programs
In general, a wrap-fee program is a program under which a client is charged a fee by a “Sponsor” for
investment advisory services, execution of investment transactions, and custody. These programs are
generally sponsored either by an investment adviser or broker-dealer unaffiliated with DSM. Consistent
with applicable law, clients are permitted to impose reasonable restrictions on the management of their
accounts, including restricting particular securities or types of securities, provided DSM accepts such
restrictions. With respect to wrap-fee clients, absent specific instructions to the contrary, certain types of
restrictions, for example, prohibiting investment in particular industries or socially responsible categories,
could be defined, identified and restricted by the Sponsor. In a wrap-fee program, a representative of the
Sponsor will typically work with a client to determine his or her investment objectives, risk tolerance,
liquidity requirements, investment restrictions and other relevant suitability factors. Based on this
information and DSM’s investment philosophy and style, the representative might recommend placing all
or a portion of the client’s assets with DSM. For approved clients, DSM will manage their account in
accordance with the investment objectives established in the applicable DSM model investment strategy
as well as any reasonable restrictions imposed by the client.
DSM is paid a portion of the total wrap-fee charged by the Sponsor, typically receiving less than 0.45% of
a client’s assets. Because the wrap fee includes execution through the Sponsor or a Sponsor-designated
broker-dealer (“Program Broker”), client transactions are generally executed without commission charges
when effected by or through the Program Broker. However, if a transaction is executed through a broker
other than the Program Broker, the client bears all additional costs of commissions and other transaction
fees for the trade. As a result, DSM generally expects that it will execute most or all wrap client trades
The wrap-fee paid by clients in this program will generally exceed DSM’s management fee for a
separately managed account. In evaluating a wrap-fee arrangement, a client should recognize that
commission rates are not negotiated by DSM. In addition, the Sponsor could charge additional costs, and
the Sponsor maintains the discretion to modify the fee sharing arrangement with DSM. DSM does not
control the fees or the billing arrangements in a wrap-fee program. For a complete description of a wrap-
fee arrangement, including billing practices and account termination provisions, clients in wrap-fee
programs should review the Sponsor’s brochure. Clients in wrap-fee programs should also satisfy
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themselves that the Sponsor is able to provide best execution of transactions. Clients should be aware
that transactions in wrap-fee programs will generally produce increased trading flow for the Sponsor. In
addition, clients in wrap-fee programs should also be aware of the risks related to wrap account turnover
(i.e., reverse churning).
Because wrap client transactions are generally executed without commission charge, a disparity in
commission charges can exist between the commissions charged to a client in a wrap-fee program and
DSM’s other clients, including clients in other wrap-fee programs. A client in a wrap-fee program should
also consider that, depending upon the level of the fee charged by the Sponsor, the amount of portfolio
activity in the client’s account, the value of custodial and other services that are provided, and certain
other factors, a wrap-fee could exceed the aggregate cost of such services if they were provided
separately. DSM only manages client assets in wrap-fee programs when a client is presented to DSM by
the Sponsor of a program. DSM does not place potential clients in wrap-fee programs. The Sponsor has
the sole discretion over client acceptance. Please see the discussion on conflicts listed in this Item 4 as
well as in Item 12 – Brokerage Practices.
Portfolio Licensing
DSM also participates in portfolio licensing programs in which it does not trade a client’s account. In
such programs, DSM provides the sponsor of the portfolio licensing program with DSM’s model
investment strategy for the sponsor to implement for its clients’ accounts. Please see the discussion on
conflicts listed in this Item 4 as well as in Item 12 – Brokerage Practices.
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