The Advisers
This Brochure provides an overview of each Adviser, including the affiliated General Partner of each
private equity fund listed in the table on the following page, each of which is a separate and distinct
company that may have differing investment capabilities and functions. EMG does business as The Energy
& Minerals Group.
Adviser Name of Funds General Partner of Applicable Fund In
business
since
NGP MR Management,
LLC (the “Fund I
Adviser”)
• NGP Midstream & Resources, L.P. and NGP M&R Offshore Holdings, L.P.
(collectively, “Fund I”)
• NGP MR, LP (“Fund I GP”)
2007
M&R
Follow-On Fund
Management, LP (the
“Follow-On Fund
Adviser”)
• Midstream & Resources Follow-On Fund, L.P. (“Follow-On Fund”)
• Pallinghurst M&R SPV Cayman, LP (“Pallinghurst SPV”)
• M&R FOF GP, LP (“Follow-On Fund
GP”)
• Pallinghurst M&R SPV Cayman GP,
LLC (“Pallinghurst SPV GP”)
2009 and
2010
2009
EMG Fund II
Management, LP (the
“Fund II Adviser”)
• The Energy & Minerals Group Fund II, L.P., EMG Fund II Offshore, LP, EMG Fund II
Offshore Holdings, LP, EMG Fund II Dutch Offshore, LP, and EMG Fund II Dutch
Offshore Holdings, LP (collectively, “Fund II”)
• EMG Utica I Co-Investment, LP, EMG Utica I Offshore Co-Investment, LP, EMG
Utica II Co-Investment, LP, EMG Utica II Offshore Co-Investment, LP, and EMG
Utica, LLC (collectively, the “EMG MW Utica Co-Investment Entities”)
• EMG Fund II Ascent Co-Investment, LP, EMG Fund II Ascent Offshore Co-
Investment, LP, and EMG Fund II Ascent Holdings, LLC (collectively, the “EMG Fund
II Ascent Co-Investment Entities”)
• EMG Iron Ore Phase 2 Co-Investment, LP (“Iron Ore Phase 2 Co-Investment”)
• EMG Fund II GP, LP (“Fund II GP”)
• EMG Utica Co-Investment GP, LLC
(“MW Utica GP”)
• EMG Fund II Ascent Co-Investment GP,
LLC (“Fund II Ascent GP”)
• EMG Iron Ore Phase 2 Co-Investment
GP, LP (“Iron Ore Phase 2 GP”)
2011
2013
2013
2015
EMG Fund III
Management, LP (the
“Fund III Adviser”)
• The Energy & Minerals Group Fund III, LP, EMG Fund III Offshore, LP, EMG Fund
III Offshore Master LP, LP, and EMG Fund III Offshore Holdings, LP (collectively,
“Fund III”)
• EMG Ascent 2016 Equity, LP, EMG Ascent 2016 Offshore Equity, LP, and EMG
Ascent 2016 Equity Holdings, LLC (collectively, “EMG Ascent 2016 Entities”)
• EMG AENO Co-Investment, LP and EMG AENO Holdings, LLC (collectively, the
“EMG AENO Co-Investment Entities”)
• EMG Traverse Co-Investment, LP, EMG Traverse Offshore Co-Investment, LP and
EMG Traverse Holdings, LLC (collectively, the “EMG Traverse Co-Investment
Entities”)
• EMG Ascent Secondary Fund, LP (“EMG Ascent Secondary Fund”)
• EMG Fund III GP, LP (“Fund III GP”)
• EMG Ascent 2016 GP, LLC (“Ascent
2016 GP”)
• EMG AENO Co-Investment GP, LLC
(“AENO GP”)
• EMG Traverse Co-Investment GP, LLC
(“Traverse GP”)
• EMG Ascent Secondary Fund GP, LLC
(“Ascent Secondary GP”)
2013
2016
2014
2015
2017
EMG Fund IV
Management, LP (the
“Fund IV Adviser”)
• The Energy & Minerals Group Fund IV, LP, EMG Fund IV Offshore, LP, and EMG
Fund IV Offshore Holdings, LP (collectively, “Fund IV”)
• EMG Fund IV GP, LP (“Fund IV GP”)
Adviser Name of Funds General Partner of Applicable Fund In
business
since
• EMG Fund IV PAA Co-Investment, LP, EMG Fund IV PAA Offshore Co-Investment,
LP, and EMG Fund IV PAA Holdings, LLC (collectively, the “EMG Fund IV PAA Co-
Investment Entities”)
• EMG Coronado Strategic, LP (“Coronado Strategic”)
• EMG Fund IV Spur Co-Investment, LP and EMG Fund IV Spur Holdings, LLC
(collectively, the “EMG Fund IV Spur Co-Investment Entities”)
• EMG Fund IV PAA GP, LLC (“Fund IV
PAA GP”)
• EMG Coronado Strategic GP, LLC
(“Coronado Strategic GP”)
• EMG Fund IV Spur Co-Investment GP,
LLC (“Fund IV Spur GP”)
2016
2018
2019
EMG Fund V
Management, LP (the
“Fund V Adviser”)
• The Energy & Minerals Group Fund V, LP, EMG Fund V Offshore, LP, and EMG
Fund V Offshore Holdings, LP (collectively, “Fund V”)
• The Energy & Minerals Group Fund V Accordion, LP, EMG Fund V Accordion
Offshore, LP, and EMG Fund V Accordion Offshore Holdings, LP (collectively, the
“Fund V Accordion”)
• EMG Iron Ore Phase 3 Aggregator, LP
• EMG Fund V Iron Ore Aggregator, LLC
• EMG Iron Ore Holdco, LP
• EMG Fund V Iron Ore Phase 3 Co-Investment, LP
• EMGVSC, LP
• EMG Fund V Spur Co-Investment, LP and EMG Fund V Spur Holdings, LLC
(collectively, the “EMG Fund V Spur Co-Investment Entities”)
• EMG Iron Ore Phase 3 (Q4 19) Co-Investment, LP
• EMG Fund V GP, LP (“Fund V GP”)
• Fund V GP
• Fund V GP
• N/A
• EMG Fund V Co-Investment GP, LP
• EMG Fund V Iron Ore Phase 3 Co-
Investment GP, LLC
• EMG Fund V Co-Investment GP, LP
• EMG Fund V Spur Co-Investment GP,
LLC (“Fund V Spur GP”)
• EMG Iron Ore Phase 3 (Q4 19) Co-
Investment GP, LLC
2019
2019
2019
2019
2019
Each of the Advisers provides or will provide investment advisory services to private equity fund clients,
focusing on investments in the global natural resources industry. The Advisers are the investment advisers
to the private funds listed above, all of which are sponsored by The Energy & Minerals Group and its
affiliates (the “Firm”). The Firm was formed by John Raymond and John Calvert (the “Co-Founders”).
Each Adviser shares an office in Houston, Texas.
The Fund I Adviser has entered into an investment management agreement with Fund I and Fund I GP.
The Follow-On Fund Adviser has entered into an investment management agreement with (i) the Follow-
On Fund and Follow-On Fund GP; and (ii) Pallinghurst SPV and Pallinghurst SPV GP.
The Fund II Adviser has entered into an investment management agreement with (i) Fund II and Fund II
GP; (ii) the EMG MW Utica Co-Investment Entities and MW Utica GP; (iii) the EMG Fund II Ascent Co-
Investment Entities and Fund II Ascent GP; and (iv) Iron Ore Phase 2 Co-Investment and Iron Ore Phase 2
GP.
The Fund III Adviser has entered into an investment management agreement with (i) Fund III and Fund III
GP; (ii) the EMG Ascent 2016 Entities and Ascent 2016 GP; (iii) the EMG AENO Co-Investment Entities
and AENO GP; (iv) the EMG Traverse Co-Investment Entities and Traverse GP; and (v) EMG Ascent
Secondary Fund and Ascent Secondary GP.
The Fund IV Adviser has entered into an investment management agreement with (i) Fund IV and Fund IV
GP; (ii) the EMG Fund IV PAA Co-Investment Entities and Fund IV PAA GP; (iii) Coronado Strategic
and Coronado Strategic GP; and (iv) the EMG Fund IV Spur Co-Investment Entities and Fund IV Spur GP.
The Fund V Adviser has entered into an investment management agreement with (i) Fund V, the Fund V
Accordion, EMG Iron Ore Phase 3 Aggregator, LP, and Fund V GP; (ii) EMG Fund V Iron Ore Aggregator,
LLC; (iii) EMG Iron Ore Holdco, LP, EMGVSC, LP, and EMG Fund V Co-Investment GP, LP; (iv) EMG
Fund V Iron Ore Phase 3 Co-Investment, LP and EMG Fund V Iron Ore Phase 3 Co-Investment GP, LLC;
(v) the EMG Fund V Spur Co-Investment Entities and Fund V Spur GP; and (vi) EMG Iron Ore Phase 3
(Q4 19) Co-Investment, LP and EMG Iron Ore Phase 3 (Q4 19) Co-Investment GP, LLC.
For purposes of this Brochure, Fund I, Fund II, Fund III, Fund IV, and Fund V are collectively referred to
as the “Main Funds.” The Follow-On Fund, Pallinghurst SPV, the EMG MW Utica Co-Investment Entities,
the EMG Fund II Ascent Co-Investment Entities, Iron Ore Phase 2 Co-Investment, the EMG AENO Co-
Investment Entities, the EMG Traverse Co-Investment Entities, the EMG Ascent 2016 Entities, EMG
Ascent Secondary Fund, the EMG Fund IV PAA Co-Investment Entities, Coronado Strategic, the Fund V
Accordion, EMG Iron Ore Phase 3 Aggregator, LP, EMG Fund V Iron Ore Aggregator, LLC, EMG Iron
Ore Holdco, LP, EMGVSC, LP, EMG Fund V Iron Ore Phase 3 Co-Investment, LP, the EMG Fund IV
Spur Co-Investment Entities, the EMG Fund V Spur Co-Investment Entities, and EMG Iron Ore Phase 3
(Q4 19) Co-Investment, LP are collectively referred to herein as the “Co-Invest Funds” and together with
the Main Funds, as the “Funds.”
Ownership
The principal owners of the Fund I Adviser are the Co-Founders and NGP Energy Capital Management,
LLC (“NGP”). The principal owners of the Follow-On Fund Adviser, the Fund II Adviser, the Fund III
Adviser, the Fund IV Adviser, and the Fund V Adviser are the Co-Founders, Lee R. Raymond (the “Senior
Partner”) and other EMG employees, with the majority ownership interest held by the Co-Founders and the
Senior Partner.
Fund I GP is owned by the Co-Founders, other employees of EMG and by NGP or its affiliates, with the
majority held by the Co-Founders and NGP. Follow-On Fund GP, Fund II GP, Fund III GP, Fund IV GP,
Fund V GP, Iron Ore Phase 2 GP, AENO GP, Traverse GP, Ascent 2016 GP, Fund IV PAA GP, Ascent
Secondary GP, EMG Fund V Co-Investment GP, LP, and EMG Fund V Iron Ore Phase 3 Co-Investment
GP, LLC are owned by the Co-Founders, the Senior Partner and/or other employees of EMG, with the
majority ownership interest held by one or more of the Co-Founders. MW Utica GP, Fund II Ascent GP,
and Coronado Strategic GP, which have no economic interest in the applicable co-investment entities, but
do have the right to manage the applicable co-investment entities, are wholly owned by John T. Raymond.
Additional information related to the ownership of the Advisers and the General Partners can be found on
Schedules A, B, and R of EMG’s Form ADV Part 1.
Each of the Advisers advises only private funds and all of the Advisers are under common control. All of
the Advisers’ employees and persons acting on their behalf are subject to common supervision and control.
The Advisers operate under a single set of written policies and procedures, including a single code of ethics,
and the Advisers’ policies and procedures are administered by a single chief compliance officer.
Accordingly, the Advisers file an umbrella registration on a single Form ADV and each Adviser is identified
on Schedule R of Form ADV.
The Main Funds
In 2007, the Co-Founders established an affiliation with NGP, an energy-focused private equity firm, to
assist in raising capital commitments for Fund I. As of November 16, 2007, Fund I’s final closing date,
Fund I had $1.40 billion in capital commitments. The Fund I Adviser is the manager of Fund I. In 2009, the
Co-Founders and NGP determined that NGP would no longer be involved in any EMG investment vehicle,
other than the participation of David Albin, a managing partner of NGP, on the Investment Committee of
Fund I. Neither NGP nor its affiliates have any other relationship with the Firm except for an economic
interest in Fund I, the Fund I GP and the Fund I Adviser. NGP has an existence independent of the Firm
and conducts its operations independently of the Firm. For purposes of this Brochure, references to the
“Firm,” “EMG” and the “Advisers” do not include references to NGP or its affiliates and/or related persons.
In 2011, the Firm established Fund II, which has an investment strategy and focus substantially similar to
Fund I. Fund II is managed by the Fund II Adviser. As of December 3, 2012, Fund II’s final closing date,
Fund II had approximately $2.25 billion in capital commitments.
In 2013, the Firm established Fund III as a new fund that would succeed to the investment strategy and
focus of Fund I and Fund II. Fund III is managed by the Fund III Adviser. As of June 16, 2014, Fund III’s
final closing date, Fund III had approximately $4.08 billion in capital commitments.
In 2015, the Firm established Fund IV as a new fund that would succeed to the investment strategy and
focus of Fund I, Fund II, and Fund III. Fund IV is managed by the Fund IV Adviser. As of June 6, 2017,
Fund IV’s final closing date, Fund IV had approximately $2.38 billion in capital commitments.
In 2019, the Firm established Fund V as a new fund that would succeed to the investment strategy and focus
of Fund I, Fund II, Fund III, and Fund IV. Fund V is managed by the Fund V Adviser. As of October 17,
2021, Fund V’s final closing date, Fund V had approximately $803 million in capital commitments.
As of December 31, 2023, all of Fund I’s, Fund II’s, and Fund III’s capital was fully committed to the
respective investments made by those Funds. As of December 31, 2023, all of the Co-Invest Funds’ capital
is fully committed to their respective investments.
The General Partner of each Main Fund has established an investment committee (the “Investment
Committee”) comprised of (i) for Fund I, the Co-Founders and David Albin, a managing partner of NGP,
and (ii) for Fund II, Fund III, Fund IV, and Fund V, the Co-Founders and the Senior Partner. All investment
decisions made by the Main Funds must be approved by unanimous agreement of the members of the
respective Investment Committee. The Co-Invest Funds rely on the investment decisions made by the Fund
I, Fund II, Fund III, Fund IV, or Fund V Investment Committee, as applicable, related to the applicable
portfolio company.
Co-Invest Funds
Limited partners in the Main Funds have the right to co-invest in Fund portfolio companies that require
additional capital beyond what the Main Fund(s) have agreed to provide if the General Partner decides to
offer a co-investment. Generally, co-investment vehicles are only allocated
investment opportunities if
there are additional portfolio capital funding requirements for a particular investment opportunity. In certain
circumstances, strategic investors that are not current limited partners in the Funds also may be offered a
co-investment opportunity in a Fund’s portfolio company.
In 2009, the Firm established Follow-On Fund and Pallinghurst SPV as vehicles through which co-investors
invested in certain portfolio companies. Follow-On Fund and Pallinghurst SPV are both managed by the
Follow-On Fund Adviser. As of December 31, 2023, Follow-On Fund and Pallinghurst SPV had called
approximately $102 million of $120 million in capital commitments, collectively.
In 2013, the Firm established the EMG MW Utica Co-Investment Entities as a vehicle through which Fund
II and co-investors invested in a specific portfolio company. The EMG MW Utica Co-Investment Entities
are managed by the Fund II Adviser. As of December 31, 2023, the EMG MW Utica Co-Investment Entities
had called all of approximately $700 million in capital commitments (including approximately $350 million
called from Fund II).
In 2013, the Firm established the EMG Fund II Ascent Co-Investment Entities as a vehicle through which
Fund II and co-investors invested in a specific portfolio company. The EMG Fund II Ascent Co-Investment
Entities are managed by the Fund II Adviser. As of December 31, 2023, the EMG Fund II Ascent Co-
Investment Entities had called all of approximately $895 in capital commitments (including approximately
$338 million called from Fund II).
In 2015, the Firm established Iron Ore Phase 2 Co-Investment as a vehicle through which a strategic
investor invested in a specific portfolio company alongside Fund I and Fund II. Iron Ore Phase 2 Co-
Investment is managed by the Fund II Adviser. As of December 31, 2023, Iron Ore Phase 2 Co-Investment
had called all of approximately $38 million in capital commitments.
In 2014, the Firm established the EMG AENO Co-Investment Entities as a vehicle through which Fund III
and co-investors invested in a specific portfolio company. The EMG AENO Co-Investment Entities are
managed by the Fund III Adviser. As of December 31, 2023, the EMG AENO Co-Investment Entities had
called all of approximately $340 million in capital commitments (including approximately $241 million
called from Fund III, which is managed by the Fund III Adviser).
In 2015, the Firm established the EMG Traverse Co-Investment Entities as a vehicle through which co-
investors invested in a specific portfolio company. Fund III had already made an investment in the portfolio
company through EMG Traverse Holdings, LLC. The EMG Traverse Co-Investment Entities are managed
by the Fund III Adviser. As of December 31, 2023, the EMG Traverse Co-Investment Entities had called
all of approximately $769 in capital commitments (including approximately $500 million called and
committed from Fund III, which is managed by the Fund III Adviser).
In 2016, the Firm established the EMG Ascent 2016 Entities as a vehicle through which co-investors would
invest in a specific portfolio company. The EMG Ascent 2016 Entities are managed by the Fund III Adviser.
As of December 31, 2023, the EMG Ascent 2016 Entities had called all of approximately $702 million in
capital commitments (including approximately $209 million called and committed from Fund III, which is
managed by the Fund III Adviser, and $80 million called and committed from Fund II, which is managed
by the Fund II Adviser).
In 2017, the Firm established EMG Ascent Secondary Fund as a vehicle through which investors with pre-
emptive or take-up rights could participate in opportunities to acquire additional equity in a specific
portfolio company through secondary purchases. EMG Ascent Secondary Fund is managed by the Fund III
Adviser. As of December 31, 2023, EMG Ascent Secondary Fund had called all of approximately $10
million in capital commitments.
In 2016, the Firm established the EMG Fund IV PAA Co-Investment Entities as a vehicle through which
Fund IV and co-investors invested in a specific portfolio company. The EMG Fund IV PAA Co-Investment
Entities are managed by the Fund IV Adviser. As of December 31, 2023, the EMG Fund IV PAA Co-
Investment Entities had called all of approximately $453 million in capital commitments (including
approximately $300 million called from Fund IV, which is managed by the Fund IV Adviser).
In 2018, the Firm established Coronado Strategic as a vehicle through which investors invested in a specific
portfolio company. Coronado Strategic is managed by the Fund IV Adviser. As of December 31, 2023,
Coronado Strategic had called all of approximately $124 million in capital commitments.
In 2019, the Firm established the EMG Fund IV Spur Co-Investment Entities as a vehicle through which
Fund IV and co-investors invested in a specific portfolio company. The EMG Fund IV Spur Co-Investment
Entities are managed by the Fund IV Adviser. As of December 31, 2023, the EMG Fund IV Spur Co-
Investment Entities had called all of approximately $157 million in capital commitments (including
approximately $148 million from Fund IV, which is managed by the Fund IV Adviser).
In 2019, the Firm established the Fund V Accordion as a co-investment vehicle through which investors
will invest in specific portfolio companies. The Fund V Accordion is managed by the Fund V Adviser. As
of December 31, 2023, the Fund V Accordion had called approximately $82 million of its approximately
$109 million in capital commitments.
In 2019, the Firm established EMG Fund V Iron Ore Phase 3 Co-Investment, LP, EMG Fund V Iron Ore
Aggregator, LLC, EMG Iron Ore Phase 3 Aggregator, LP, and EMG Iron Ore Holdco, LP as a series of co-
investment vehicles through which investors invested in a specific portfolio company. These four entities
are managed by the Fund V Adviser. As of December 31, 2023, all of approximately $101 million in capital
commitments to EMG Iron Ore Phase 3 Aggregator, LP had been called. Included in the $101 million of
capital commitments is approximately $7 million from Fund IV (managed by the Fund IV Adviser), $36
million is from Fund V, $7 million is from the Fund V Accordion, and $8 million is from EMG Fund V
Iron Ore Phase 3 Co-Investment, LP. Fund V, the Fund V Accordion, and EMG Fund V Iron Ore Phase 3
Co-Investment, LP are managed by the Fund V Adviser.
In 2019, the Firm established EMGVSC, LP as a co-investment vehicle through which an investor will
invest in specific portfolio companies. EMGVSC, LP is managed by the Fund V Adviser. As of December
31, 2023, EMGVSC, LP had called approximately $27 million of approximately $101 million in capital
commitments.
In 2019, the Firm established the EMG Fund V Spur Co-Investment Entities as a vehicle through which
Fund V, the Fund V Accordion, and co-investors invested in a specific portfolio company. The EMG Fund
V Spur Co-Investment Entities are managed by the Fund V Adviser. As of December 31, 2023, the EMG
Fund V Spur Co-Investment Entities had called all of approximately $231 million in capital commitments
(including approximately $205 million from Fund V and the Fund V Accordion, which are managed by the
Fund V Adviser).
In 2019 the Firm established EMG Iron Ore Phase 3 (Q4 19) Co-Investment, LP as a vehicle through which
existing EMG Funds and co-investors invested in a specific portfolio company. EMG Iron Ore Phase 3
(Q4 19) Co-Investment, LP is managed by the Fund V Adviser. As of December 31, 2023, EMG Iron Ore
Phase 3 (Q4 19) Co-Investment, LP had called all of approximately $126 million in capital commitments
(including approximately $23 million from Fund II, $9 million from Fund IV, and $12 million from Fund
V, which are managed by the Fund II Adviser, Fund IV Adviser, and Fund V Adviser, respectively).
EMG expects to manage other co-investment vehicles formed in the future to invest in portfolio companies
of a Main Fund, or future private equity funds formed by EMG.
Parallel Investment Entities
In addition to limited partners invested in the Main Funds, the General Partner of each of the Funds typically
organize and/or manage one or more parallel investment entities (“Parallel Investment Entities”) to facilitate
participation by certain investors, including EMG employees or affiliates, in investment opportunities to
accommodate legal, tax, regulatory or other similar considerations of such investors. These Parallel
Investment Entities generally invest side-by-side with the Main Funds in each investment proportionate to
their respective committed capital.
Advisory Services
EMG tailors its advisory services to the specific investment objectives and restrictions set forth in the
limited partnership agreements and other governing documents (collectively, the “Governing Documents”)
of each Fund, not to the individualized needs of any particular investor in the Funds.
Pursuant to the investment guidelines and restrictions set forth in the Governing Documents of each Fund,
EMG invests in the entire energy industry and all facets of the mining, minerals and metals industry, with
a particular focus on non-substitutable, industrial commodities. EMG endeavors to optimize risk-adjusted
returns by allocating capital through a natural resource portfolio diversified by geography, commodity and
business function. Information about the Funds and the particular investment objectives, strategies,
restrictions and risks associated with an investment are described in each Fund’s PPM and other Governing
Documents, which are made available to investors only through each Adviser and its authorized agents. See
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss and Item 16 – Investment Discretion.
The Main Funds’ typical investment in a target company ranges from $150 million to $600 million, and
Co-Invest Funds are not bound by the investment limitations of the Main Funds. The Main Funds primarily
invest in equity of private companies, although they may invest in securities of public companies, including
listed and unlisted securities, subject to any limits set forth in the Fund’s Governing Documents. Each Main
Fund may also hold public company investments as a result of an initial public offering of a portfolio
company’s securities or following the sale of a portfolio company to a public company in exchange for
publicly-traded securities in the acquiring company. Following an investment in a portfolio company, the
Co-Founders and EMG employees often serve on the portfolio company’s board of directors, or otherwise
act to influence the management of the companies until the applicable Fund exits the investment.
EMG’s senior investment professionals have spent their entire careers in the natural resources industry and
most have significant experience as operators. Each of EMG’s senior investment professionals also has
experience investing in and/or operating natural resources assets in jurisdictions worldwide.
The Funds are offered exclusively to individuals who qualify as “accredited investors” under Regulation D
promulgated under the Securities Act of 1933, as amended (the “Securities Act”), and “qualified
purchasers” as defined under Section 2(a)(51) of the Investment Company Act of 1940, as amended
(“Investment Company Act”), and are therefore not required to register as investment companies with the
SEC in accordance with the exemption set forth in Section 3(c)(7) of the Investment Company Act. Subject
to the investment guidelines and restrictions in the Governing Documents for the Funds, EMG has broad
discretion to make investment decisions for the Funds. Investment in the Funds involves significant risks
and should be regarded as long-term in nature, forming only one portion of an investor’s diversified
investment portfolio.
EMG provides investment management services exclusively to the Funds. Outside of such services to the
Funds, EMG offers no other advisory services. EMG does not perform any type of financial planning,
quantitative analysis, tax planning or market timing services. It also does not participate in wrap fee
programs.
As of December 31, 2023, EMG had approximately $12 billion of regulatory assets under management in
respect of which EMG or an affiliate of EMG has full investment discretion (subject to each Fund’s
established investment guidelines). EMG does not manage any client assets on a non-discretionary basis.
Compliance Oversight
The Chief Compliance Officer of EMG has full responsibility to develop and enforce all compliance
policies and procedures. The Chief Compliance Officer, who also serves as Chief Financial Officer, is
assisted in compliance matters by EMG’s General Counsel, Deputy General Counsel, Controller, a third-
party compliance expert, and outside counsel. These individuals, with the exception of outside counsel,
meet on at least a monthly basis to address compliance matters that may impact EMG, including those
delegated to the Chief Compliance Officer under EMG’s compliance policies and procedures manual (the
“Compliance Manual”). The Chief Compliance Officer endeavors to ensure that compliance resources are
adequate relative to the compliance risk profile for EMG, given the Firm’s business and operations. The
Chief Compliance Officer also evaluates the results of the annual review of the Firm’s compliance program,
implements appropriate amendments to that program and reports the results to the Co-Founders.