NWI Management, LP (“NWI” or the “Investment Manager”) is a Delaware
limited partnership owned and controlled by Mr. Nellapalli (“Hari”) Hariharan and
Ms. Jayachandrika (“Chandrika”) Hariharan (either directly or indirectly through its
general partner, NWI, LLC). The Investment Manager’s principal place of business is at
623 Fifth Avenue, 23rd Floor, New York, New York 10022. NWI has been in business
since 1999 and provides investment advisory services to private and offshore collective
investment funds and other pooled investment vehicles, which are intended for
institutional and high net worth investors. NWI’s advisory business is primarily in the
area of “global macro” investing with an emphasis on emerging markets. As of midnight
December 31, 2023, the Investment Manager had approximately $2,384 million in net
assets under management. All assets are managed on a discretionary basis.
The Investment Manager provides investment advice to several collective
investment vehicles organized to invest in and to trade securities and other financial
instruments, including private investment partnerships and foreign investment companies,
sponsored and/or managed by NWI or by third-party investment firms (each, a “Fund”).
(An affiliate of the Investment Manager serves as general partner to certain of these
Funds organized as limited partnerships.) In providing these services to each Fund, the
Investment Manager formulates its investment objective, directs and manages the
investment and reinvestment of each Fund’s assets, and provides reports to management
and/or investors. Investment advice is provided directly to each Fund and not individually
to the limited partners or shareholders of the Fund. The Investment Manager manages the
assets of each Fund in accordance with the terms of the governing documents applicable
to the Fund.
The offerings of shares or limited partnership interests in the Funds are not
registered under the U.S. Securities Act of 1933, as amended (the “Securities Act”), and
the Funds are not registered under the U.S. Investment Company Act of 1940, as
amended (the “Investment Company Act”). NWI is registered as a commodity pool
operator under the U.S. Commodity Exchange Act, as amended (the “Commodity
Exchange Act”), with respect to certain of the Funds it advises. However, NWI has
submitted notice filings stating its intent to operate certain of these Funds pursuant to an
exemption available under Regulation 4.7(b) adopted by the U.S. Commodity Futures
Trading Commission (“CFTC”). In addition, certain other Funds are operated as “exempt
pools” pursuant to CFTC Regulation 4.13(a)(3). NWI is also registered as a commodity
trading advisor under the Commodity Exchange Act. Further, NWI has submitted a
notice filing stating its intent to advise its advisory clients pursuant to an exemption from
certain obligations under CFTC Regulation 4.7(c). Accordingly, offers and sales of
interests or shares in the Funds are made exclusively to investors satisfying the applicable
eligibility and suitability requirements of the Securities Act, Investment Company Act,
Commodity Exchange Act and CFTC Regulations, either via private
transactions within
the United States or in offshore transactions.
The Investment Manager advises certain client accounts that are sponsored and/or
managed by third-party investment firms, which may and do share or replicate the
investment objectives or strategies employed by the Funds sponsored by NWI. In these
cases, the Investment Manager may and does also tailor its advisory services to the
individual needs of each client, and the clients may and do impose restrictions on trading
and investing in certain types of securities or other financial instruments. Clients may and
do have investment objectives that vary, and may be identical to, or substantially similar
to, or different from, another client’s investment objective. It cannot be assured that
advisory clients having identical or substantially similar investment objectives will have
identical or substantially similar investment portfolios or trading positions.
Consistent with SEC Advisers Act Release No. IA-4509, as used in this Brochure,
a “separately managed account” is an advisory account for a client other than a pooled
investment vehicle.
As used in this Brochure, the word “may” and other similar words implying
contingency should be understood to be a disclosure that the Investment Manager is
permitted to engage in the practice described and could actually be doing so at the present
time, or could have done so in the past, or may do so in the future, in connection with all
or some client accounts and transactions.
The descriptions set forth in this Brochure of specific advisory services that are
offered to advisory clients, and investment strategies pursued and the investment and
trading activities conducted on behalf of advisory clients, should not be understood to
limit in any way the investment and trading activities of NWI, which may offer any
advisory services, engage in any investment strategy and make any investment, including
any not described in this Brochure, that it considers appropriate, subject to each
advisory client’s investment objectives and guidelines. The investment strategies pursued
are speculative and entail substantial risks. Advisory clients should be prepared to bear
the risk of a substantial loss of capital. There can be no assurance that the investment
objectives of any advisory client will be achieved.
The securities of the Funds may be and are offered and sold in the United States
on a private placement basis under exemptions promulgated under the Securities Act and
other applicable state laws. Significant suitability requirements apply to prospective
investors in the Funds, including requirements that they be “accredited investors” as
defined in Regulation D, “qualified purchasers” as defined in the Investment Company
Act, or “non-U.S. persons” as defined in Regulation S. Persons reviewing this Brochure
should not construe this as an offer to sell or a solicitation of an offer to buy the
securities of any of the Funds described herein. Any such offer or solicitation will be
made only by means of a confidential memorandum.