Advisory Firm
Open Door Investment Management Ltd. (“ODIM”) was co-founded in 2011 by Shifeng Ke and is
wholly-owned by Open Door Capital Management Ltd. (“ODCM”). ODCM is the holding company for
several operating investment management and consulting businesses. ODIM provides investment advice
to clients organized as privately-offered pooled investment vehicles or similar structures (the
“Funds”) and to certain managed accounts or similar relationships. The Funds and all such ODIM
advised managed accounts are referred to herein as “clients.”
ODIM has engaged local affiliates based in US, the People’s Republic of China (the “PRC” or
“China”) (Open Door Capital Advisor (US), LLC (“ODCA”) and Heartland Capital Investment
Consulting (SH) Limited (“HCIC”), respectively). ODIM affiliates’ personnel who provide advisory
or operational services to ODIM are subject to ODIM’s compliance policies and procedures and such
affiliates’ books and records relating to ODIM’s clients’ advisory services are deemed to be within
the scope of ODIM’s books and records retention and production obligations. Accordingly, certain
information on ODIM contained in this Brochure, including information regarding personnel, is
presented on an aggregate basis for ODIM and these affiliates.
ODIM and Shanghai Heartland Private Fund Management Limited (“SHL”), a private fund investment
advisor based in the People’s Republic of China, partially share common beneficial ownership with
HCIC, and members of HCIC provide certain services to SHL, which are governed by a Shared Service
Agreement.
Additional information about ODIM’s affiliates entities, including potential conflicts of interest, are
described in Item 10 of this Brochure.
Advisory Services
As a specialty, ODIM serves as a discretionary investment manager, sub-investment manager or
investment advisor which focuses on investment research and portfolio management for Greater China
mandates of institutional and professional investors, such as pension funds and foundations, as well
as financial intermediaries, including fund of funds, private wealth management, family offices and
high net worth individuals. ODIM provides investment advisory services with respect to absolute
return long-biased funds and long-short hedge funds (each, a “Private Fund”) and for institutional
investors and high net worth individuals accounts (collectively, the “Managed Accounts”) on both a
discretionary and non-discretionary basis, subject to any investment policies and restrictions
established by its clients. ODIM also provides non-discretionary portfolio selection advisory services
to investment managers of private funds investing in Greater China securities. ODIM’s headquarters
and principal place of business are located in San Francisco.
The disclosures contained in this Brochure are designed solely to provide information about ODIM
and the investment management/advisory business it conducts. None of the discussions regarding the
Private Funds or Managed Accounts shall constitute a solicitation of an offer to buy or an offer to sell
the securities of these offerings.
ODIM manages the Funds in accordance with the investment guidelines set forth in
the offering
documents for each Fund and manages other client accounts in accordance with the authority
delegated to it (including any limits on that authority) under the applicable client’s investment
management agreement or governing documents. ODIM consults with each client on its investment
objectives and tailors its services and advice to those objectives.
ODIM primarily invests in a wide variety of investment instruments, including publicly traded and
privately placed securities of companies incorporated, established, based, operating or having
substantial business with or in Greater China (For these purposes including Mainland China, the Hong
Kong and Macau Special Administration Regions and Taiwan).
ODIM invests client assets in a wide range of countries, markets and approved exchanges in Asia and
throughout the world, including, without limitation, markets in the Mainland China, the Hong Kong
and Macau Special Administration Regions, Taiwan, the United States (“U.S.”), the United Kingdom,
Singapore, and elsewhere.
ODIM’s investment team has many years of experience investing in Greater China equities. The firm
employs fundamental analysis with a bottom-up stock picking approach to seek long-term, risk-
adjusted returns, and believes management ownership is key in aligning company interests with those
of investors. ODIM performs both qualitative and quantitative assessments of potential investments
with a particular focus on opportunities upon which it can gain insights and discover value in an ever-
changing world. ODIM’s investment process includes initial company screening, preliminary review,
detailed analysis and company visits, cross checking company information with their competitors,
peers, suppliers and customers, due diligence and evaluation, review of portfolio and sector allocation,
pre trade compliance checking, stock execution, mandate adherence monitoring and risk management
monitoring.
ODIM draws upon the expertise of its US affiliate, Open Door Capital Advisors (US), LLC and
ODCA’s team of experienced financial service professionals in San Francisco, familiar with the
complexities and risks of investing in Greater China, to handle matters such as risk management,
trading, legal, compliance and client services. ODIM has contracted with an affiliated entity, HCIC,
to provide research and other investment services. HCIC has a Shanghai-based research team which
focuses on fundamental and technical analysis of a variety of companies in the Greater China region.
ODIM generally manages advisory accounts independently based on a determination of each client’s
financial situation, needs and investment objective and pursuant to an investment management
agreement with each client, which may include certain investment restrictions imposed by clients.
ODIM also provides non-discretionary advice and accepts advisory accounts with limited discretion
or where investments or brokerage arrangements are client-directed pursuant to an agreement between
ODIM and the client.
Assets Under Management
As of December 31, 2023, ODIM had approximately $145.3 million of client regulatory assets under
management, all of which was managed on a discretionary basis.