Founded in 2008 by its Directors, Simon D. Maher and John L. Hempton, Bronte is an SEC registered investment
adviser providing investment management services to pooled investment vehicles. The Phelbe Pty Ltd atf Rock Valley
Family Trust and Crikey Creek Pty Ltd atf BFWSK Family Trust are the principal owners of Bronte.
Bronte has $970,090,424 of regulatory assets under management as of June 30, 2023, all of which are managed on
a discretionary basis.
This Disclosure Brochure describes the business of Bronte. Certain sections will also describe the activities of
Supervised Persons. Supervised Persons are any of Bronte's officers, partners, directors (or other persons occupying
a similar status or performing similar functions), or employees, or any other person who provides investment advice on
Bronte's behalf and is subject to Bronte's supervision or control.
Investment Management Services
Bronte provides its discretionary investment management services to the Bronte Capital Callisto Fund LLC and
the Bronte Cayman Master Fund Ltd. (along with its feeder fund, Bronte Capital Ganymede Fund Pty Ltd.) (collectively,
the "Private Funds”). Bronte also provides discretionary investment management services to a pooled investment
account, Cassini Partners, L.P. (the “Cassini Fund”), and separately managed accounts (the “Separately Managed
Accounts,” together with the Cassini Fund, the “Other Accounts”). The Private Funds and the Other Accounts are
together generally referred to as Bronte’s clients.
The Private Funds are Limited Liability Companies (LLC’s), or foreign equivalents, engaged primarily in the business
of investing and trading in securities. Bronte Capital U.S. LLC, (the “Manager”) serves as the manager of Bronte Capital
Callisto Fund LLC. Interests in the Private Funds are privately offered pursuant to Regulation D under the Securities
Act of 1933, as amended. The Private Funds currently rely on an exemption from registration under the Investment
Company Act of 1940, as amended. Bronte has discretionary authority to determine the broker or dealer to be used by
the Private Funds.
Participation as an investor in the Private Funds is restricted to investors that are qualified clients pursuant to the
requirements
under Rule 205-3 under the Investment Advisers Act of 1940, as amended, as well as "accredited
investors" as defined under Rule 501 of the Securities Act of 1933, as amended.
To the extent certain of Bronte's Other Accounts qualify, they will be eligible to participate as members of the Private
Funds. Investment in the Private Funds involves a significant degree of risk. All relevant information, terms and
conditions relative to the Private Funds, including the investment strategies, compensation received by Bronte or any
affiliate as investment manager, suitability, risk factors, and potential conflicts of interest, are set forth in the Confidential
Private Offering Memorandum (the "Memorandum"), Limited Liability Company Agreement (the "Agreement'), and
Subscription Agreement (or comparable documents relevant to non USA jurisdictions) (together, the "Offering
Documents"), which each investor is required to receive and/or execute prior to being accepted as an investor in the
Private Funds.
Bronte will devote its best efforts with respect to its management of the Private Funds, the Cassini Fund, and the
Separately Managed Accounts. Bronte may give advice or take action with respect to the Private Funds that differs
from that of either the Cassini Fund or the Separately Managed Accounts. To the extent that a particular investment is
suitable for the Private Funds, the Cassini Fund, and the Separately Managed Accounts, such investments will be
allocated between the Private Funds and the Other Accounts pro rata based on the assets under management or in
some other manner which Bronte determines is fair and equitable under the circumstances to all of its clients.
For the Private Funds, investment advice is provided directly to each fund itself and not to the investors in the funds.
For the Other Accounts, Bronte ensures that clients' investments are made in accordance with the investment
restrictions and guidelines established in the applicable investment advisory agreements. Prior to engaging Bronte to
provide such services, clients will be required to enter into a written agreement with Bronte setting forth the terms and
conditions under which Bronte will render its services.