A. JOHCM (USA) Inc. and the JOHCM Group
JOHCM (USA) Inc. (“JOHCM USA”) is a registered investment adviser with the Securities and
Exchange Commission (the “SEC”), under the Investment Advisers Act of 1940. It was
established in early 2013 as a wholly owned subsidiary of J O Hambro Capital Management
Limited (“JOHCML”), a company organized under the laws of England and Wales in 1993,
which is also registered as an investment adviser with the SEC. JOHCM USA is an indirect
wholly owned subsidiary of Perpetual Limited (“Perpetual”), an Australian listed diversified
financial services company (ASX code: PPT), headquartered in Sydney.
In January 2023, Perpetual Limited (“Perpetual”) acquired the parent company of JOHCM USA
Pendal Group Limited (“Pendal”). As a result of the acquisition, JOHCM USA, and its affiliates,
JOHCML, JOHCM (Singapore) Pte Ltd., (“JOHCM Singapore”), Perpetual Investment Services
Europe Limited (“PISEL”), the management company for JOHCM’s Irish domiciled UCITS,
formerly known as JOHCM Funds (Ireland) Limited (“JOHCMI”), and JOHCM Funds (UK)
Limited (“JOHCMF”), the authorized corporate director of JOHCM’s UK domiciled UCITS, (in
this Form ADV, collectively referred to as “JOHCM Group”), and Thompson, Siegel &
Walmsley (“TSW”), an SEC registered investment advisor based in Richmond, Virginia, became
indirect wholly-owned subsidiaries of Perpetual.
In August 2023, Perpetual announced the establishment of a global asset management structure
and leadership team, to form one global asset management division. Perpetual’s global asset
management division is itself divided into separate boutiques that provide asset management
services globally, including JOHCM Group, TSW, Barrow Hanley Global Investors, and
Trillium Asset Management, (together “Perpetual Asset Management”). J O Hambro Capital
Management will continue to be managed by its long-standing executive committee, to be led
going forward (pending regulatory approval) by Clare Forster, the newly appointed CEO and
Global Head of Business Management and Strategic Delivery.
To the extent allowed by law, arrangements among all members of JOHCM Group and its
employees, including portfolio managers, may take a variety of forms, including but not limited
to dual employee, delegation, participating affiliate, sub-agency or other servicing arrangements.
Certain directors and executive officers of one entity within Perpetual Asset Management may
also serve as directors and executive officers of one or more other entities within Perpetual Asset
Management. This practice is designed to make Perpetual Asset Management’s global
capabilities available to clients in a coherent and uninterrupted manner within the varied global
framework. In these circumstances, the member of Perpetual Asset Management with which the
client has its investment management agreement will remain fully responsible for the account
from a legal and contractual perspective. No additional fees are charged for the affiliate’s
services except as set forth in the investment management agreement.
JOHCM USA has entered into a personnel-sharing arrangement with each of JOHCM Singapore
and JOHCML (each a “Participating Affiliate”). The personnel-sharing arrangements are based
on the “Unibanco” line of no-action letters issued by the staff of the SEC that permit an SEC-
registered investment adviser to rely on and use the resources of advisory affiliates, subject to the
supervision of the SEC-registered investment adviser. Under this arrangement, certain employees
of the Participating Affiliate serve as “associated persons” of JOHCM USA and, in this capacity,
are subject to the oversight of JOHCM USA and its Chief Compliance Officer (“CCO”). These
associated persons may, on behalf of JOHCM USA, participate in providing investment
management services (including acting as portfolio managers), trading, research and related
services to clients of JOHCM USA. Please see Item 10 for additional details regarding the nature
of the relationship amongst members of the JOHCM Group.
Regulatory assets under management (“RAUM”) for JOHCM USA as of September 30, 2023,
were $9.342 billion. Total assets under management, for JOHCM Group as of September 30,
2023, were $27.787 billion (including RAUM and the model portfolios described above).
B. JOHCM’s Advisory Services
The JOHCM Group specializes in providing discretionary investment advisory services across a
diverse range of equity strategies, including sustainable and impact strategies. The JOHCM Group
generally offers its investment advisory services through pooled vehicles (or investment funds) and
to clients that establish separately managed accounts. These equity strategies cover UK, Pan and
Continental Europe, Japan, Global, International, Asian, Emerging Markets, and Sustainable and
Impact strategies, and are described in greater detail in Item 8, below.
When advising clients that are investment funds, the investment advice JOHCM USA provides to such
funds is dependent on and limited to the investment objectives of the respective fund as set forth in the
entity’s governing documents. Such investment advice is not based upon the individual needs of the
investors in the fund. The information in this Brochure that describes or relates to the funds is qualified
in its entirety by the offering documents of the respective entity. When providing investment services
to segregated mandates, JOHCM USA will generally tailor its advisory services to the individual needs
of such clients, including any specific guidelines or restrictions such clients may request.
We do not participate in wrap fee programs.
JOHCM USA, in addition to these advisory services, provides client service, sales, distribution,
marketing, trading, compliance, investor relations and business development services to US clients
of JOHCM Group. JOHCM USA also provides administrative services to a family of mutual
funds (the “Perpetual Americas Funds”). When JOHCM USA subcontracts portfolio
management services to affiliated registered investment advisers to act in such capacity to
Perpetual Americas Funds, JOHCM USA does so under the name Perpetual Americas Funds
Services (“PAFS”).
C. JOHCM Group’s approach to investment advisory services
JOHCM Group offers an alternative to the traditional investment management firms that have
dominated the market for many years. We hire portfolio managers who are able to remain true to their own
investment style. without being held to invest in a company preferred list of stocks. JOHCM Group has
an excellent record of investment professional retention.
JOHCM Group, including JOHCM USA, has an entrepreneurial culture that aims to attract portfolio
managers who have great confidence in their stock-picking skills. These are people who often have
worked for major investment firms where they were bound to a corporate process or restricted to core
stock lists and set asset allocations. JOHCM Group’s managers are free to invest - within agreed-
upon portfolio construction criteria - where they choose.
JOHCM Group expects portfolio managers to deploy their proven and individual talents to their full
extent for the benefit of investors.
JOHCM Group’s culture is investment-led. JOHCM Group is protective of investment integrity.
Talented portfolio managers join the JOHCM Group because they recognize that JOHCM Group
cares about protecting their performance records via capacity discipline and is active in aligning their
interests with those of investors and the firm.
The definition of success for many investment houses is to attract the largest possible amount of assets in
each offered strategy. Every time JOHCM Group launches a strategy, the portfolio manager determines the
maximum amount of money that he or she is prepared to run in that strategy (including any investment
funds and segregated mandates). Once any strategy reaches its predetermined size limit, it is closed to new
investors, giving the portfolio manager the conditions in which they can deliver and sustain outperformance
and stay focused on the interests of our clients.
Talented people, excellent research and hard work are every investment manager's stock in trade.
However, we believe that it requires more than just exceptional asset management skills to exceed
benchmarks; it also takes a special environment where all the supporting conditions and incentives that
portfolio managers need to outperform are in place. JOHCM Group aims to provide that environment.
Unlike the other investment houses, JOHCM Group’s portfolio managers spend little time on office
management and marketing-related activities. Being heavily involved in such matters does little to
engender investment outperformance. By distancing managers from some of the peripheral activities
associated with investment management and giving them the degree of scope and total support they
need, we make our portfolio managers more accountable for the performance of the funds they
manage. Also, when portfolio managers have all they need to get results, they have no reason to
move on and every reason to stay. All of the above coupled with our unceasing drive for
outperformance, the self-imposed limits on strategy asset sizes and firmly committed portfolio
managers, directly aligns our interests with those of our clients.