A. General Description of Advisory Firm
Kopernik is an employee-owned investment adviser focused on global equity investing. Kopernik
provides investment advisory services to individual and institutional clients on a discretionary and non-
discretionary basis. The Firm, a Delaware limited liability company, was founded by David Iben. Mr.
Iben serves as the managing member, Chief Investment Officer and Lead Portfolio Manager of the
Firm. Previously, he headed the Global Value investment team at Vinik Asset Management, L.P. Mr.
Iben formerly served as Chief Investment Officer, Co-President and lead portfolio manager of
Tradewinds Global Investors, LLC, a subsidiary of Nuveen Investments. Kopernik commenced
investment operations on July 1, 2013, and is based in Tampa, Florida. Kopernik’s principal owner is
Kopernik Holdings, LLC. Mr. Iben is the principal owner of Kopernik Holdings, LLC.
Kopernik is organized to ensure a culture of client success. In an effort to ensure alignment with our
clients, our senior professionals have meaningful investment in our investment funds, most employees
have some investment in our funds, we are 100% employee-owned (through Kopernik Holdings, LLC),
most of our employees have an ownership stake, and all employees are eligible to participate in the
success of Kopernik.
As of January 31, 2024, Kopernik managed over $5.49 billion in regulatory assets under management.
In addition to the regulatory assets under management listed above, Kopernik advised an additional
$352.96 million in advisory only services assets (please refer to Item 4.B. for a description of advisory
only services).
B. Description of Advisory Services
Kopernik implements its global investment strategies through an active, fundamentals-based, value-
oriented process. Kopernik’s investment discipline seeks to identify potential investments that trade at
significant discounts to their intrinsic value (as determined by Kopernik’s analysis). For investment
strategies that permit short positions, Kopernik will short securities of companies that Kopernik
believes are overvalued by the market, with an emphasis on securities selling at significant premiums
to their intrinsic values (as determined by Kopernik’s analysis).
Kopernik typically invests in equity securities, with large, mid- or small capitalizations, but may invest
in other securities such as bonds, commodities, currencies, derivatives and other financial instruments.
Kopernik invests in securities issued by companies domiciled in developed markets as well as
emerging and frontier markets. For additional information regarding Kopernik’s investment strategies,
please refer to Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss.
Kopernik provides investment advisory services to three main types of clients: (i) registered investment
companies, (ii) institutional asset management clients: separately managed accounts, unregistered
investment companies, a bank collective investment trust, and other collective investment vehicles,
and (iii) other advisors (on a sub-advisory basis). Kopernik offers separately managed accounts to
pension plans, charitable organizations, educational institutions, high net worth individuals, trusts,
estates, corporations and other business entities, banks and thrift institutions, insurance companies,
foreign sovereigns and domestic governmental entities. For additional information regarding
Kopernik’s clients, please refer to Item 7 - Types of Clients.
Kopernik’s investment decisions and advice with respect to each investment vehicle (“Fund”) or
account it manages are subject to that Fund’s or account’s investment objectives and guidelines, as set
forth in its offering documents or investment management agreement.
Services for Registered Investment Companies
Subject to the supervision of each client’s board of directors or trustees, Kopernik provides
management and certain related administrative services necessary for the operation of registered
investment company clients, including Kopernik Global All-Cap Fund and Kopernik International
Fund. Kopernik’s responsibilities include, without limitation, investment advisory services, research
services, recommending and placing of orders for the purchase and sale of securities for registered
investment company client portfolios (based
on the investment objectives and guidelines of each
client), working with custodians, transfer and pricing agents, accountants, auditors, underwriters and
other persons, and furnishing reports, evaluations and analysis on a variety of subjects.
Institutional Asset Management Services
Kopernik provides asset management and related services to the institutional market. Kopernik
manages separately managed accounts for institutional investors, unregistered investment funds and
other collective investment vehicles. The strategies, policies, and procedures governing these accounts
and collective investment vehicles are generally similar, but not necessarily identical, to those of
Kopernik’s registered investment company clients.
Kopernik currently provides investment advisory services to a number of privately-offered
unregistered investment funds (collectively, the “Kopernik Private Funds”). Securities of the Kopernik
Private Funds are offered to eligible investors exclusively on a private placement basis. The Kopernik
Private Funds include the following open-end funds: Kopernik Global All-Cap Fund, LP and Kopernik
Global Unconstrained Fund, LP, which are both Delaware limited partnerships, and Kopernik Global
All-Cap Offshore Fund, Ltd. and Kopernik Global Unconstrained Offshore Fund, Ltd., which are
Cayman Islands exempted companies. Kopernik Global All-Cap Fund, LP and Kopernik Global All-
Cap Offshore Fund, Ltd. invest in Kopernik Global All-Cap Master Fund, LP. Similarly, Kopernik
Global Unconstrained Fund, LP and Kopernik Global Unconstrained Offshore Fund, Ltd. invest in
Kopernik Global Unconstrained Master Fund, LP. In addition, Kopernik advises the Kopernik Global
Long-Term Opportunities Fund, LP, which is organized as a Guernsey limited partnership and
Kopernik Global Long-Term Opportunities Fund, Limited, a Guernsey Non-Cellular Company, which
invests in Kopernik Global Long-Term Opportunities Fund, LP.
Kopernik provides investment advisory services to funds in the Kopernik Global Collective Investment
Trust (collectively, the “CITs”) including the Kopernik Global All-Cap CIT and Kopernik
International CIT, which are available only to certain eligible plans and exempt from registration under
the Investment Company Act of 1940. The portfolios are offered by SEI Trust Company, the trustee,
based on investment advice of Kopernik, the trust investment adviser.
Sub-Advisory Services
Kopernik provides sub-advisory services to other investment advisers, which may include those
located outside the United States and those with large sub-advisory fund platforms. The strategies and
policies and procedures governing these mandates are currently similar to those of Kopernik’s Global
All-Cap Strategy.
Kopernik also acts as sub-adviser to Kopernik Global All-Cap Equity Fund (the “UCITS”), a sub-fund
(portfolio) of Heptagon Fund ICAV, which is an investment company operating pursuant to the
European Union’s UCITS (Undertakings for Collective Investment in Transferable Securities)
Regulations.
Advisory Only Services
Kopernik provides advisory only services whereby Kopernik delivers to a third party model investment
portfolios where Kopernik provides a list of recommended investments and weightings for
consideration by the client. Kopernik is not responsible for arranging or effecting the purchase or sale
of the recommended investments and model weightings, nor does Kopernik control the implementation
of investment decisions.
C. Availability of Customized Services for Clients
For separately managed accounts, Kopernik tailors its investment advisory services to the specific
needs of clients. A client may select an investment strategy with existing, standard investment
guidelines and request reasonable restrictions on the management of its account. If Kopernik agrees to
those restrictions, it will manage the account in accordance with the revised investment guidelines.
Kopernik will not be able to accommodate proposed investment restrictions that are onerous or
incompatible with Kopernik’s standard investment strategies and investment philosophy, and Kopernik
may decline to accept or terminate client accounts with such restrictions.
D. Wrap Fee Programs
Not Applicable. Kopernik does not participate in any wrap fee programs.