Global X is a Delaware limited liability company with its principal offices located at 605 Third Avenue,
24th and 43rd floors, New York, New York 10158, 1 Gateway Center, Newark, NJ 07102, 201 South
Biscayne Blvd, St 2850 Miami, FL 33131, 10 Earlsfort Terrace, Dublin 2, D02 T380, Ireland and
123 Buckingham Palace Road, London, SW1W 9SH, United Kingdom. Global X started operations
in 2008.
The Adviser is registered as an investment adviser under the Advisers Act.
The Adviser serves as the investment adviser of Global X Funds (the “Trust”) and each series of the
Trust (the “Global X U.S. ETFs”) and the Global X ETFs ICAV, a UCITS fund range with segregated
liability between each UCITS fund, registered in Ireland and authorized by the Central Bank of
Ireland (each a “Global X UCITS ETF” and collectively with the Global X U.S. ETFs, the “Global X
ETFs”).
Global X Digital Assets, LLC (“GXDA”) is a Delaware limited liability company with its principal offices
located at 605 Third Avenue, 43rd Floor, New York, NY 10158. GXDA’s focus is on the development,
operation and management of digital asset investment funds, exchange traded debt securities and
separately managed accounts. GXDA is an affiliate of Global X Management Company LLC and has
no dealings with its principal business. However, the two entities share some internal resources such
as portfolio management, operations, legal, and compliance.
GXDA offers investment advisory services to additional separate managed accounts on a model
portfolio delivery and sub-advisory services basis (collectively, “Digital Asset Strategies”). The sub-
advisory services for digital asset separately managed accounts is contemplated to be to unaffiliated
investment advisers. In these cases, the third-party adviser (“TPA”) selects GXDA to manage separate
accounts overseen by the TPA. The agreement is with the TPA, not with the end client, and the TPA
retains the discretionary authority to hire GXDA, as well as to terminate services with GXDA. The TPA
is responsible for determining that GXDA’s digital assets are appropriate for the TPA’s client and for
ongoing monitoring of our management in light of the end-client’s needs. While contemplated Digital
Asset Strategies are still currently being formed, certain statements in this brochure, including those
made in the present tense, describe the prospective business activities of GXDA.
GXDA also acts as arranger to a crypto exchange traded product program (the “Program”) for the
issue of undated, limited recourse, non-interest bearing exchange traded debt securities issued by
Global X Digital Assets Issuer Limited (the “Issuer”). The Issuer is incorporated and registered in
Jersey under the Companies (Jersey) Law 1991 (as amended), with registered number 139150 and
GXDA provides certain administrative and operational services in respect of the Program. GXDA is
paid a fee by the Issuer in respect of such services.
As of December 31, 2023, Global X had approximately $42,500M assets under management, nearly
all of which on a discretionary basis.
Adviser to the Trust
Global X serves as the investment adviser and the administrator for the Trust. The Trust is a registered
open-end management investment company registered under the Investment Company Act of 1940
as amended (the “1940 Act”) that currently consists of one hundred twelve exchange-traded funds,
one hundred of which are operational.
The shares of each currently operational Global X U.S. ETF are listed on a U.S. national securities
exchange such as the Cboe BZX, NYSE Arca, Inc. or the NASDAQ. Certain of the Global X U.S.
ETFs could be registered in non-U.S. jurisdictions or cross-listed on non-U.S. exchanges.
Subject to the supervision of the Trust’s Board of Trustees, Global X is responsible for managing the
investment activities of each Global X U.S. ETF and its business affairs and other administrative
matters. The Adviser has created both passively managed ETFs that attempt to track either proprietary
or non-proprietary indexes (each, an “Underlying Index”) and actively managed ETFs designed to
provide exposure to U.S. and global options, fixed income, commodity, digital assets and equity
markets. The Trust includes, but is not limited to, ETFs pursuing the following general investment
strategies:
Thematic. Solutions focusing primarily on emerging and disruptive technologies.
Income. Aiming to deliver alternative, higher-yielding income solutions.
Core. Portfolio building blocks that aim to deliver exposure to specific values or factors.
International Access. Solutions designed for investors seeking to chart a different course.
Commodities. Exposure to metals and mining companies.
Global X also works with sub-advisers to facilitate portfolio management of certain Funds.
Global X UCITS ETFs
The Adviser acts as the investment adviser and the distributor for the Global X UCITS ETFs, a series
of Irish domiciled funds, regulated by the Central Bank of Ireland pursuant to the European
Communities (Undertakings for Collective Investment in Transferable Securities) Regulations 2011 as
amended by European Union (Undertakings for Collective Investment in Transferable Securities)
(Amendment) Regulations 2016 as may be amended or replaced. Information about the Global X
UCITS ETFs, including a description of the management fees and investor eligibility, is generally
contained in each fund’s prospectus, key investor information document and supplements, which can
be found on the Global X UCITS ETFs’ website as applicable.
Sub-advisory Services
As compensation for the sub‐advisory services provided to the Funds, the Adviser may pay to the
applicable sub‐adviser a sub‐advisory fee based upon a percentage of that Fund’s daily net assets.
The level of the sub‐advisory fee paid with respect to a Fund is negotiated between the Adviser and
the applicable sub‐adviser and will vary, depending on, among other things, the types of assets in
which the Fund invests. Sub‐advisory fees are generally accrued daily and are billed and paid in
arrears. In some cases, the Sub-Adviser may be an affiliate of the Adviser.
Conversely, the Adviser and GXDA serve as sub-advisers to other investment vehicles. In these
arrangements, the level of the sub‐advisory fee paid to the Adviser or GXDA is negotiated between
the Adviser or GXDA and the counterparty and will vary, depending on, among other things, the types
of assets in which the Fund invests. In some cases, the Adviser may act as a sub-adviser of an affiliate
of the Adviser.
Separately Managed Accounts
The Adviser provides investment advisory services to certain separately managed accounts, either
affiliated or otherwise, and pooled investment vehicles (some of which may include financial
institutions and their customers and clients).
GXDA intends to offer investment advisory services to separate managed accounts on a model
portfolio delivery and advisory basis (collectively, “Digital Asset Strategies”). While contemplated
Digital Asset Strategies are still currently being formed, certain statements in this brochure, including
those made in the past and present tense, describe the prospective business activities of GXDA.
Digital Model Portfolio Delivery of Digital Asset Strategies
Global X Digital Assets LLC creates and provides non-discretionary model portfolios (“Digital Model
Portfolios”), comprised of digital assets. Digital Model Portfolios seek to track indexes (“Indexes”)
designed by the Global X Digital Assets team. The Indexes are calculated and administered by the
index provider(s).
The Digital Model Portfolios are provided to or otherwise made available to investment advisers,
broker-dealers and other financial intermediaries or platform providers (“Third-Party Providers”) for
such Third-Party Providers to use at their discretion, or at the discretion of their clients, in the provision
of investment advisory services to their own clients. Such Third-Party Providers may utilize software
platforms to aid in their provision of investment advisory services and may choose to make the Digital
Model Portfolios available to clients as options on such platforms. Third-Party Providers and their
respective clients have sole investment discretion with respect to the selection of underlying
investment options for such investors’ accounts, including the recommendation, selection, and
management of an investment strategy based on a Model Portfolio. Global X does not have investment
discretion or trading responsibilities with respect to such arrangements and does not have an advisory
relationship with Third-Party Providers’ clients or manage the implementation of Digital Model
Portfolios on the basis of the investment objectives of individual clients that participate in these
programs. Third-Party Providers may use numerous strategies, including strategies of other
investment advisers. The implementation of any such investment strategy, including one based on a
Model Portfolio, will be conducted by the applicable Third-Party Provider or its respective clients. Third-
Party Providers are responsible for using their own judgments with respect to the implementation of a
Model Portfolio for an underlying client and, as such, may deviate from the allocations recommended
for a Model Portfolio at their discretion.
GXDA may make updates to the Digital Model Portfolios from time to time. In the event of an update
to the Digital Model Portfolios, GXDA will make such update available to the Third-Party Providers,
who in their sole discretion may determine whether to implement such updates on behalf of their
clients. GXDA may receive compensation from Third-Party Providers for use of the Digital Model
Portfolios. For a further discussion, see Item 5 of this brochure.
Sub-Advisory Services of Digital Asset Strategies
Global X Digital Assets, LLC is contemplating providing sub-advisory services for digital asset
strategies to unaffiliated investment advisers. In these cases, the third-party adviser (“TPA”) selects
GXDA to manage separate accounts overseen by the TPA. The agreement is with the TPA, not with
the end client, and the TPA retains the discretionary authority to hire us, as well as to terminate our
services. The TPA is responsible for determining that GXDA’s digital
assets are appropriate for the
TPA’s client and for ongoing monitoring of our management in light of the end-client’s needs.
The TPA has the ability to invest their clients’ assets directly into digital assets through the use of a
separately managed account investment partner platforms (“Investment Platforms”) which allows for
client onboarding via an advisor portal (the “Advisor Portal”), and the delivery of various digital asset
investment models and allocation modules, execution of transactions in digital assets and the
integration and reporting of holdings and trade information to Advisor’s portfolio management
system. Clients of GXDA are Advisors and their respective clients (“Clients”) which include retail and
high-net worth individuals as well as institutional clients. Together, the Advisor Portal and the Client
Portal are referred to as the “Investment Platform.”
“Digital assets” includes cryptographically derived assets, referred to as cryptoassets,
cryptocurrencies, and/or blockchain tokens, virtual currencies or digital currencies, such as bitcoin
and ether, as well as other assets available on public, private or permissioned blockchains and/or
ledger systems, including decentralized application tokens and protocol tokens, and other digital
assets that are based on a cryptographic protocol of a computer network that can be (i) centralized
or decentralized, (ii) closed or open-source, and/or (iii) used as a medium of exchange, store of
value, and/or represent ownership in some asset, interest or object, whether real or intangible.
Digital assets are a digital representation of value that function as a medium of exchange, a unit of
account, or a store of value, but they do not have legal tender status in the United States. Digital
assets are not backed nor supported by any government or central bank (except for Central Bank
Digital Currencies (“CBDCs”)). The prices of digital assets are derived by market forces of supply
and demand, and digital assets are more volatile than traditional currencies and financial assets.
Many of the Digital Asset Strategies have exposure to bitcoin and ether; however, other digital asset
holdings in these strategies are anticipated to grow.
Bitcoin is a digital asset the ownership and behavior of which are determined by participants in an
online, peer-to-peer network that connects computers that run publicly accessible, or “open source,”
software that follows the rules and procedures governing the Bitcoin network, commonly referred to
as the Bitcoin protocol. The value of bitcoin, like the value of other digital assets, is not backed by any
government, corporation or other identified body. Ownership and the ability to transfer or take other
actions with respect to bitcoin is protected through public-key cryptography. The supply of bitcoin is
constrained or formulated by its protocol instead of being explicitly delegated to an identified body
(e.g., a central bank or corporate treasury) to control. Units of bitcoin are treated as fungible. Bitcoin
and certain other types of digital assets are sometimes referred to as digital currencies or
cryptocurrencies. No single entity owns or operates the Bitcoin network, the infrastructure of which is
collectively maintained by (1) a decentralized group of participants who run computer software that
results in the recording and validation of transactions (commonly referred to as “miners”), (2)
developers who propose improvements to the Bitcoin protocol and the software that enforces the
protocol and (3) users who choose what Bitcoin software to run. Bitcoin was released in 2009 and, as
a result, there is little data on its long-term investment potential. Bitcoin is not backed by a government-
issued legal tender.
Ether is a digital asset that is created and transmitted through the operations of the peer-to-peer
Ethereum Network, a decentralized network of computers that operates on cryptographic protocols.
No single entity owns or operates the Ethereum Network, the infrastructure of which is collectively
maintained by a decentralized user base. The Ethereum Network allows people to exchange tokens
of value, called ether, which are recorded on a public transaction ledger known as a blockchain.
Ether can be used to pay for goods and services, including computational power on the Ethereum
network, or it can be converted to fiat currencies, such as the U.S. dollar, at rates determined on
digital asset exchanges or in individual end-user-to-end-user transactions under a barter system.
Furthermore, the Ethereum Network also allows users to write and implement smart contracts—that
is, general-purpose code that executes on every computer in the network and can instruct the
transmission of information and value based on a sophisticated set of logical conditions. Using smart
contracts, users can create markets, store registries of debts or promises, represent the ownership
of property, move funds in accordance with conditional instructions and create digital assets other
than ether on the Ethereum Network. Smart contract operations are executed on the Ethereum
Blockchain in exchange for payment of ether. The Ethereum Network is one of a number of projects
intended to expand blockchain use beyond just a peer-to-peer money system.
Investment Platforms that GXDA have onboarded are a technology platform which operates like a
traditional trade execution system and allows Advisors to open a Separately Managed Account
(“SMA”) on behalf of each of their Clients and to place digital asset trades for their Clients in their
SMAs which are routed directly to a digital asset exchange for execution and processing. The
Investment Platforms provides transactional reporting of the Client’s digital assets in the SMA which
can be integrated into the Advisor’s or representative’s third-party performance reporting system and
used by the Advisor or Representative for their Client communications and overall performance
reporting to their Clients.
Because the Investment Platform integrates with various industry-standard portfolio management
and reporting systems, Advisors and Representatives can see each of their Client’s digital asset
exposures directly in the portfolio management system alongside the client’s other asset holdings.
Advisors and Representatives can also view their Client’s holdings, unofficial performance, Client
documents, research, and educational materials directly by logging into the Investment Platform.
The Investment Platform allows Advisors and Representatives, on behalf of their Clients, to open
accounts directly with a digital asset custodian. GXDA only partners with digital asset custodians that
are “qualified custodians.” A qualified custodian is a type of institution that is approved by regulators
to hold assets on behalf of clients. The Investment Platform integrates with the digital asset
custodian to allow Advisors and Representatives, on behalf of their Clients, to add funds or in-kind
contributions, withdraw funds, enter orders to purchase and sell digital assets, build a custom
allocation module and/or make investment selections of various investment models.
Model Portfolio Services
Global X also creates, manages, and provides non-discretionary model portfolios, comprised of
recommended allocations of individual exchange traded funds (“ETFs”), either regulated pursuant to
the 1940 Act or the Undertakings for Collective Investment in Transferable Securities (“UCITS”),
including, but not limited to, Global X ETFs (each, a “Model Portfolio,” and collectively, “Model
Portfolios”). Each Model Portfolio is designed to pursue a particular investment strategy and to have
a specified risk tolerance level. Each Model Portfolio is intended to achieve such strategy through
investment in ETFs, in accordance with the target allocations established for the Model Portfolio.
Global X will not be limited to using Global X ETFs in the Model Portfolios; however, a Model Portfolio
may have up to a 100% allocation in Global X ETFs.
The Model Portfolios are provided to or otherwise made available to investment advisers, broker-
dealers and other financial intermediaries or platform providers (“Third-Party Providers”) for such
Third-Party Providers to use at their discretion, or at the discretion of their clients, in the provision of
investment advisory services to their own clients. Such Third-Party Providers may utilize software
platforms to aid in their provision of investment advisory services and may choose to make the Model
Portfolios available to clients as options on such platforms. Third-Party Providers and their respective
clients have sole investment discretion with respect to the selection of underlying investment options
for such investors’ accounts, including the recommendation, selection, and management of an
investment strategy based on a Model Portfolio. Global X does not have investment discretion or
trading responsibilities with respect to such arrangements and does not have an advisory relationship
with Third-Party Providers’ clients or manage the implementation of Model Portfolios on the basis of
the investment objectives of individual clients that participate in these programs. Third-Party Providers
may use numerous strategies, including strategies of other investment advisers. The implementation
of any such investment strategy, including one based on a Model Portfolio, will be conducted by the
applicable Third-Party Provider or its respective clients. Third-Party Providers are responsible for using
their own judgments with respect to the implementation of a Model Portfolio for an underlying client
and, as such, may deviate from the allocations recommended for a Model Portfolio at their discretion.
Global X may make updates to the recommended allocations to ETFs that comprise the Model
Portfolios from time to time. In the event of an update to the Model Portfolios, Global X will make such
update available to the Third-Party Providers, who in their sole discretion may determine whether to
implement such updates on behalf of their clients. Global X may receive compensation from Third-
Party Providers for use of the Model Portfolios and will be indirectly compensated by investments in
the Global X ETFs based on the Model Portfolios. For a further discussion, see Item 5 of this brochure.