Solas Capital Management, LLC (the “Adviser”, “Solas” or “we”) is a Delaware limited liability company
and has its principal place of business in Darien, Connecticut. The Adviser has been in the investment
advisory business since 2004. The Adviser currently provides investment advisory services to a private
investment fund which is offered to sophisticated investors, a private investment fund that is offered to a
particular investor and its affiliates and a sleeve of a pooled investment vehicle operated by a third party.
The private investment funds and pooled investment vehicle are sometimes referred to together as
“Clients.” The Adviser may provide investment advisory services to other funds, pooled investment
vehicles and to separately managed accounts in the future.
Frederick Tucker Golden (the “Portfolio Manager”) indirectly owns and controls the Adviser and the
General Partner (defined below) and has overall responsibility for investment decisions regarding the
Clients’ portfolios.
The private investment funds we manage are Solas Capital Partners, LP and Solas Capital Partners II, LP,
each a Delaware limited partnership (each a “Fund” and together, the “Funds”). Solas Capital, LLC (the
“General Partner”), an affiliate of the Adviser, serves as each Fund’s general partner. The interests in the
Funds are offered on a private placement basis, pursuant to Section 3(c)(1) of the Investment Company
Act of 1940, as amended, (the “Investment Company Act”) to persons who generally are “accredited
investors” as defined under the Securities Act of 1933, as amended, and “qualified clients” as defined
under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and subject to certain other
conditions, which are set forth in the applicable Fund’s Offering Documents (defined below).
Solas has discretion with respect to investment decisions made for the Funds, and with respect to the
selection of brokers, dealers and other counterparties for such transactions, and the amount of
commissions or other compensation to be paid by the Funds. Solas provides investment advisory services
to the Funds tailored towards the particular investment objectives, restrictions, and strategies described
in the applicable Fund’s Offering Documents. Please refer to Item 8 of this brochure for a more
detailed
description of the Adviser’s investment strategies, as well as a description of the types of securities and
other investments purchased by the Funds under the management of the Adviser. Investment advice is
provided directly to the Funds, not individually to its underlying investors.
All discussions of a Fund in this brochure, including but not limited to its investments, the strategies
used in managing the Fund, the fees and other costs associated with an investment in the Fund, and
conflicts of interest faced by the Adviser and its affiliates in connection with management of the Fund
are qualified in their entirety by reference to the Fund’s confidential offering memorandum, limited
partnership agreement and other governing documents (referred to collectively as “Offering
Documents”).
In addition to the Funds, Solas provides investment advisory services to a sleeve of a pooled investment
vehicle operated by a third party (the “Pool”). These services are provided on a discretionary basis, as set
forth in a written investment advisory agreement. Solas invests the Pool’s assets in accordance with the
same investment objectives and strategies and similar restrictions applicable to the Funds. As well, the
Pool is subject to similar terms and conditions that are applicable to the Funds.
Solas also provides investment research and position sizing, which is anonymized through an
intermediary, on a delayed basis to a third-party investment manager. In return, Solas receives
compensation based on a variety of factors, including the fees generated by such third-party investment
manager and performance of positions for which Solas provided information. Solas also receives research
credits to be applied toward certain portfolio optimization and risk management software products.
Separately managed account Clients may impose, in the written investment advisory agreements,
reasonable restrictions, objectives, and/or guidelines on investing in certain securities or types of
securities.
As of December 31, 2023, Solas had discretionary Regulatory Assets Under Management of approximately
$599,105,000 which is attributable to the Funds and Pool. Solas does not manage any assets on a non-
discretionary basis.