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Adviser Profile

As of Date 07/09/2024
Adviser Type - Large advisory firm
- An investment adviser (or subadviser) to an investment company
- Related adviser
Number of Employees 181
of those in investment advisory functions 66 -5.71%
Registration SEC, Approved, 11/4/2005
AUM* 45,003,485,534 15.67%
of that, discretionary 45,003,485,534 15.67%
Private Fund GAV* 803,577,972 6.47%
Avg Account Size 127,128,490 31.35%
% High Net Worth 12.15% 4.57%
SMA’s Yes
Private Funds 3
Contact Info (70 xxxxxxx
Websites

Client Types

- Individuals (other than high net worth individuals)
- High net worth individuals
- Banking or thrift institutions
- Investment companies
- Pooled investment vehicles
- Pension and profit sharing plans
- Charitable organizations
- State or municipal government entities
- Insurance companies
- Sovereign wealth funds and foreign official institutions
- Corporations or other businesses not listed above
- Other

Advisory Activities

- Portfolio management for individuals and/or small businesses
- Portfolio management for investment companies
- Portfolio management for pooled investment vehicles
- Portfolio management for businesses

Compensation Arrangments

- A percentage of assets under your management
- Performance-based fees

Recent News

Reported AUM

Discretionary
Non-discretionary
73B 63B 52B 42B 31B 21B 10B
2015 2016 2017 2018 2019 2020 2021 2022 2023

Private Funds



Employees

Private Funds Structure

Fund Type Count GAV
Fund TypeOther Private Fund Count3 GAV$803,577,972

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Stck Ticker594918104 Stock NameMICROSOFT CORP $ Position$1,429,981,663 % Position4.00% $ Change1.00% # Change-5.00%
Stck Ticker58733R102 Stock NameMERCADOLIBRE INC $ Position$1,286,093,615 % Position4.00% $ Change-1.00% # Change-9.00%
Stck Ticker92826C839 Stock NameVISA INC $ Position$1,386,198,401 % Position4.00% $ Change-20.00% # Change-15.00%
Stck Ticker30303M102 Stock NameMETA PLATFORMS INC $ Position$1,003,731,594 % Position3.00% $ Change-5.00% # Change-8.00%
Stck TickerG6683N103 Stock NameNU HLDGS LTD $ Position$1,022,706,508 % Position3.00% $ Change-3.00% # Change-10.00%

Brochure Summary

Overview

Sands Capital Management, LLC (“Sands Capital”) is an independent investment management firm. Sands Capital Management, LP (“Sands Capital LP”) is the principal owner of Sands Capital and, in turn, is principally owned directly and indirectly by several limited liability companies and estate planning trusts as identified in Schedule B of Part 1. Sands Capital and Sands Capital LP are ultimately controlled by Frank M. Sands. Sands Capital is registered with the SEC as an investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). We are headquartered in Arlington, Virginia, and manage approximately $45,003.5 million in discretionary assets (Regulatory Assets Under Management) as of December 31, 2023. Sands Capital also provides recommendations for non-discretionary clients for whom we do not execute trades but for whom we provide changes to strategy model portfolios (“Model Clients”), which account for approximately $5,253.3 million in additional fee-paying assets as of December 31, 2023. Since 1992, Sands Capital has provided investment advisory and management services to taxable and tax-exempt clients, primarily on a discretionary basis, and in certain circumstances as described herein, to Model Clients. Clients include, among other types, investment companies and other pooled investment vehicles, pension and profit-sharing plans, charitable organizations, state and municipal government entities, sovereign wealth funds and foreign official institutions, corporations, non-U.S. pension funds, superannuation funds, banking or thrift institutions and individuals. Sands Capital Ventures, LLC is an advisory affiliate of Sands Capital (“Advisory Affiliate”). The Advisory Affiliate provides investment advisory and management services to its clients, primarily regarding venture capital, growth equity, and related investments. Under personnel-sharing and other arrangements, Sands Capital staff members act on behalf of the Advisory Affiliate for purposes of providing services to its clients and provide other back office and administrative services to the Advisory Affiliate. Certain Sands Capital staff members are also officers of the Advisory Affiliate. Sands Capital believes that harnessing the collective capabilities of Sands Capital and the Advisory Affiliate benefits its clients. These joint teams use expanded and shared capabilities, including the sharing of research and other information by investment staff members relating to economic perspectives, market analysis and securities research. Investment Philosophy and Strategies Sands Capital embraces the fundamental investment philosophy that stock prices tend to reflect the earnings power and growth of the underlying businesses over the long term. As such, we attempt to identify and invest in high quality companies that have the capacity to generate sustainable, above-average earnings growth over time. The strategies we offer are typified by deep, proprietary, business-focused global research, concentrated and conviction weighted portfolios and a long-term investment horizon. We invest for our clients in what we believe are the leading growth businesses that meet our six investment criteria: Sustainable above-average earnings growth; Leadership position in a promising business space; Significant competitive advantages or a unique business franchise; Clear mission and value-added focus; Financial strength; and Rational valuation relative to the market and business prospects. The primary risk we seek to manage is the risk of permanent loss of capital resulting from a negative business or investment outcome. Risk management is integrated throughout our entire research and portfolio construction process. Please see Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information. The research team conducts proprietary, bottom-up, fundamental research on businesses of all market capitalizations located around the world. This analysis includes formulating a “sell case” for each investment. We typically sell when any of the following is identified: Significant change in fundamentals; Flaw in original investment case; Meaningful overvaluation vs. underlying business; Funding source for a new opportunity; or Risk management decision. We apply the above criteria to each of the following investment strategies, which have overlapping investments. Please refer to Item 6 – Performance-Based Fees and Side-By-Side Management and Item 12 – Brokerage Practices for additional information. Select Growth The Select Growth strategy is a concentrated portfolio of primarily large- and mid-capitalization growth businesses. The portfolio normally consists of the equity securities of 25 to 30 issuers. Portfolio companies are primarily domiciled in the United States (“U.S.”) but also include the equity securities of foreign issuers traded on U.S. exchanges. Eligible securities include equity and equity-related securities, such as American depositary receipts (“ADRs”) or shares of publicly traded real estate investment trusts for U.S. or Non-U.S. tax purposes (“REITs”). The portfolio’s cash allocation is determined by Sands Capital and is monitored and managed in accordance with client guidelines. The portfolio remains fully invested (i.e., residual cash is generally less than 5%) and is most commonly benchmarked to the Russell 1000® Growth Index. Global Growth The Global Growth strategy is a concentrated portfolio of primarily large- and mid-capitalization growth businesses. The portfolio normally consists of the equity securities of 30 to 50 issuers. Portfolio companies are domiciled in both developed and emerging markets. Eligible securities include equity and equity-related securities, such as ADRs, exchange-traded funds (“ETFs”), global depositary receipts (“GDRs”), China A-shares (whether traded cross-boundary via the Hong Kong Stock Connect or directly via exchanges in mainland China, “China A-shares”), or REITs. Low exercise price warrants (“LEPWs”), participation notes (“P-Notes”), or other access products are used to gain exposure to certain foreign markets where direct investment is not always practical or cost efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored and managed in accordance with client guidelines. The portfolio remains fully invested (i.e., residual cash is generally less than 5%) and is most commonly benchmarked to the MSCI All Country World Index. Global Leaders The Global Leaders strategy is a concentrated portfolio of primarily large- and mid-capitalization growth businesses. The portfolio normally consists of the equity securities of 30 to 50 issuers. The strategy employs a portfolio construction approach that intends to balance growth and volatility. Portfolio companies are domiciled in both developed and emerging markets. Eligible securities include equity and equity-related securities, such as ADRs, ETFs, GDRs, China A- shares, or REITs. LEPWs, P-Notes, or other access products are used to gain exposure to certain foreign markets where direct investment is not always practical or cost efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored and managed in accordance with client guidelines. The portfolio remains fully invested (i.e., residual cash is generally less than 5%) and is most commonly benchmarked to the MSCI All Country World Index. International Growth The International Growth strategy is a concentrated portfolio of primarily large- and mid- capitalization growth businesses. The portfolio normally consists of the equity securities of 25 to 40 issuers. Generally, portfolio companies are domiciled or derive a significant portion of their revenues, profits, or productive assets outside of the United States. Eligible securities include equity and equity-related securities, such as ADRs, ETFs, GDRs, China A-shares, or REITs. LEPWs, P-Notes, or other access products are used to gain exposure to certain foreign markets where direct investment is not always practical or cost efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored and managed in accordance with client guidelines. The portfolio remains fully invested (i.e., residual cash is generally less than 5%) and is most commonly benchmarked to the MSCI All Country World ex USA Index. International Leaders The International Leaders strategy is a concentrated portfolio of primarily large- and mid- capitalization growth businesses. The portfolio normally consists of the equity securities of 25 to 40 issuers. The strategy employs a portfolio construction approach that intends to balance growth and volatility. Generally, portfolio companies are domiciled or derive a significant portion of their revenues, profits, or productive assets in both developed and emerging markets outside the United States. Eligible securities include equity and equity-related securities, such as ADRs, ETFs, GDRs, China A-shares, or REITs. LEPWs, P-Notes, or other access products are used to gain exposure to certain foreign markets where direct investment is not always practical or cost efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored and managed in accordance with client guidelines. The portfolio remains fully invested (i.e., residual cash is generally less than 5%) and is most commonly benchmarked to the MSCI All Country World ex USA Index. Emerging Markets Growth The Emerging Markets Growth strategy
is a concentrated portfolio of primarily large- and mid- capitalization growth businesses. The portfolio normally consists of the equity securities of 30 to 50 issuers. Generally, portfolio companies are domiciled in or derive significant exposure (e.g., substantial portion of revenues, profits, or productive assets) outside of developed markets. Eligible securities include equity and equity-related securities, such as ADRs, ETFs, GDRs, China A-shares, or REITs. LEPWs, P-Notes, or other access products are used to gain exposure to certain foreign markets where direct investment is not always practical or cost efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored and managed in accordance with client guidelines. The portfolio remains fully invested (i.e., residual cash is generally less than 5%) and is most commonly benchmarked to the MSCI Emerging Markets Index. Emerging Markets ex China The Emerging Markets ex China strategy is a concentrated portfolio of primarily large- and mid- capitalization growth businesses. The portfolio normally consists of the equity securities of 25 to 45 issuers. Generally, portfolio companies are domiciled in or derive significant exposure (e.g., substantial portion of revenues, profits, or productive assets) outside of developed markets and China. Eligible securities include equity and equity-related securities, such as ADRs, ETFs, GDRs, or REITs. LEPWs, P-Notes, or other access products are used to gain exposure to certain foreign markets where direct investment is not always practical or cost efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored and managed in accordance with client guidelines. The portfolio remains fully invested (i.e., residual cash is generally less than 5%) and is most commonly benchmarked to the MSCI Emerging Markets ex China Index. Emerging Markets Discovery The Emerging Markets Discovery strategy is a concentrated portfolio of primarily mid- and small- capitalization growth businesses. The portfolio normally consists of the equity securities of 30 to 50 issuers. Generally, portfolio companies are domiciled in or derive significant exposure (e.g., substantial portion of revenues, profits, or productive assets) outside of developed countries. Eligible securities include equity and equity-related securities, such as ADRs, ETFs, GDRs, China A-shares, or REITs. LEPWs, P-Notes, or other access products are used to gain exposure to certain foreign markets where direct investment is not always practical or cost efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored and managed in accordance with client guidelines. The portfolio remains fully invested (i.e., residual cash is generally less than 10%) and is most commonly benchmarked to the MSCI Emerging Markets Mid Cap Index. Technology Innovators The Technology Innovators strategy is a concentrated portfolio of primarily large- and mid- capitalization growth businesses which are publicly or privately held, with a particular emphasis placed on companies facilitating or benefitting from powerful secular shifts enabled by technologies. The portfolio normally consists of the equity securities of 20 to 35 issuers. Portfolio companies are domiciled in both developed and emerging markets. Eligible securities include equity and equity-related securities, such as ADRs, stock or convertible debt issued by private companies, ETFs, GDRs or REITs. LEPWs, P-Notes, or other access products are used to gain exposure to certain foreign markets where direct investment is not always practical or cost efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored and managed in accordance with client guidelines. The portfolio remains fully invested (i.e., residual cash is generally less than 5%) and is most commonly benchmarked to the MSCI All Country World Information Technology and Communication Services Index. Global Shariah The Global Shariah strategy is a concentrated portfolio of primarily large- and mid-capitalization growth businesses that meet Islamic investment principles, as determined by Sands Capital. The portfolio normally consists of the equity securities of 30 to 50 issuers. Portfolio companies are domiciled in both developed and emerging markets. Eligible securities include equity and equity- related securities, such as ADRs, ETFs, GDRs, China A-shares, or REITs. LEPWs, P-Notes, or other access products are used to gain exposure to certain foreign markets where direct investment is not always practical or cost efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored and managed in accordance with client guidelines. The portfolio remains fully invested (i.e., residual cash is generally less than 5%) and is most commonly benchmarked to the S&P Global BMI Shariah Index. Focus Strategies The Focus strategies are concentrated portfolios of primarily large-capitalization growth businesses. Portfolio guidelines specifying the number of holdings are customized by clients, and Sands Capital manages portfolios of generally between five and twenty issuers. The eligible universe is limited to companies selected from our other strategies. Eligible securities include equity and equity-related securities, such as ADRs, ETFs, GDRs or REITs. LEPWs, P-Notes, or other access products are used to gain exposure to certain foreign markets where direct investment is not always practical or cost efficient. The portfolio’s cash allocation is determined by Sands Capital and is monitored and managed in accordance with client guidelines. The portfolios remain fully invested (i.e., residual cash is generally less than 5%) and are most commonly benchmarked to the MSCI All Country World Index unless a different Index is requested. Client-Tailored Sands Capital manages and develops client-tailored growth strategies on a case-by-case basis. These portfolios are often similar to the firm’s primary strategies but contain variations based on client type, to meet specific client mandates, or to meet anticipated industry needs. Additionally, Sands Capital provides discretionary investment management services in respect of securities received as in-kind distributions from investment funds managed by the Advisory Affiliate or others. Client objectives and fees are determined on a case-by-case basis. Discretionary Advisory Services For discretionary clients, Sands Capital constructs and maintains model portfolios for each strategy. Client accounts are generally invested in the same portfolio businesses and at approximately the same weights as the applicable strategy model unless client guidelines prohibit or restrict an investment. Client guidelines or restrictions must be provided to Sands Capital for consideration in writing and in advance as they may limit Sands Capital’s ability to act and, as a result, performance will vary from those of other accounts not bound by similar restrictions. Non-standard securities instruments issued as a result of corporate actions (e.g., fixed income) are generally liquidated into cash as soon as reasonable. Our investment strategies are available through various distribution channels. We provide investment management services to separately managed accounts and to advised and sub-advised pooled vehicles, such as mutual funds, UCITS funds, and private funds. Our clients are primarily institutional investors, intermediaries, and other sophisticated investors with long-term investment objectives. Please see Item 7 – Types of Clients for additional information. Model Client Advisory Services Sands Capital provides non-discretionary advisory services to select Model Clients. In these arrangements, we periodically provide a strategy model but do not exercise investment discretion or execute trades. Model Clients are notified of changes to the relevant strategy model as described in Item 12 – Brokerage Practices. Investment Performance Sands Capital claims compliance with the Global Investment Performance Standards (GIPS®) and prepares and presents its investment results in compliance with GIPS®. A firm that claims compliance with the GIPS standards must establish policies and procedures for complying with all the applicable requirements of the GIPS standards. The standards set forth methods of calculating and presenting investment performance in a fair and consistent manner. The CFA Institute is not involved with the preparation or review of our investment results information. To receive a complete list and description of our composites and/or investment results information, contact the Compliance Team at (703) 562-4000; write to us at 1000 Wilson Blvd., Suite 3000, Arlington, VA 22209; or email us at complianceteam@sandscap.com. Conditions for Managing Accounts; Termination of Services The minimum account size for institutional separate accounts is generally $50 million. Minimum account sizes are negotiable. From time to time, Sands Capital permits clients to contribute or retain unsupervised securities in their account. We do not provide investment advisory services for these securities and the value of these unsupervised securities are not included in the calculation of our advisory fee. However, we have the right to reject management of any security that was not purchased with our advice. Clients can terminate our investment management services by providing written notice to us.