New Silk Road Investment Pte Ltd (“NSR” or the “Firm”) is a private limited company
incorporated in Singapore in August 2008. Our founders and our principal shareholders are
Raymond Goh Wee Hock and Hoong Yik Luen. We are an employee-owned firm and we are built
upon the premise that every employee will eventually become a shareholder. Accordingly, several
of our employees currently hold non-voting shares in the firm.
We are licensed as an Accredited/Institutional Licensed Fund Manager Company (“A/I LFMC”)
with the Monetary Authority of Singapore (“MAS”). We are registered as an investment adviser
with the U.S. Securities and Exchange Commission (“SEC”) under the U.S. Investment Advisers
Act of 1940 (“Advisers Act”).
We pride ourselves on our own ability to generate investment ideas from our research analysts.
Nevertheless, we do leverage research reports and computer models of sell-side analysts to help
narrow research directions. We believe that intensive, bottom-up research is pivotal to the success
of our investment process. Once we identify an attractive investment opportunity, we carry out
detailed company analysis where the emphasis will be on identifying the long-term drivers of
shareholder value. We conduct company visits and conference calls to understand and assess the
key drivers of the business model, the strength and robustness of the balance sheet, as well as the
health of its cash flows.
We provide discretionary investment advisory services to long-only funds that are primarily
focused on investing in Asia ex-Japan equity securities (each a “Fund”). We currently manage four
Funds, with each Fund having a master-feeder fund structure.
• Asia Landmark Master Fund Ltd (“ALF Master Fund”);
• Asia Landmark (S) Fund Pte Ltd (wholly-owned subsidiary of ALF Master Fund);
• Asia Landmark Fund Ltd (“ALF Feeder Fund”).
• New Silk Road China Master Fund Pte Ltd (“NSR China Master Fund”);
• New Silk Road China Fund Ltd (“NSR China Feeder Fund”).
• NSR SEA Master Fund Pte Ltd (“NSR SEA Master Fund”);
• NSR SEA Fund Ltd (“NSR SEA Feeder Fund”).
• New Silk Road Investment Master Funds VCC on behalf of sub-fund China New Century
Master Fund (“CNC Master Fund”)
• New Silk Road Investment Funds VCC on behalf of sub-funds China New Century (Non-US)
Fund and China New Century (US) Fund (“CNC Feeder Funds”)
We also provide discretionary investment advisory services to separately managed accounts and
act as a non-discretionary sub-adviser to a pooled investment vehicle (these are referred to herein
as “Accounts”) (the Funds and Accounts are collectively referred to herein as “Clients”).
Investments for each Fund are managed in accordance with that Fund’s particular investment
objectives, strategies, restrictions and guidelines. Our client is the Fund, in particular, we advise
the master fund in each structure, and not the underlying investors of the Fund (each an “Investor”),
though certain Funds may take into consideration the general characteristics (e.g.,
tax status) of
certain of its Investors. Information about each Fund and the particular investment objectives,
strategies, restrictions, guidelines and risks associated with an investment in the Fund, is described
in the private placement memorandum (“PPM”), constitutional documents and/or investment
management agreement of the Fund (together the “Governing Documents”), which are made
available to Investors only through us or another authorized party.
The investment advisory services we provide to Accounts are tailored to each Client’s needs. All
Accounts, whether managed on a discretionary or non-discretionary basis, must sign an Investment
Management Agreement (“IMA”) that will set out the applicable investment strategy and
restrictions. Accounts are managed in accordance with the investment objectives, strategies,
restrictions and guidelines set out in the IMA.
We generally provide investment management services in accordance with applicable investment
guidelines and restrictions, including applicable restrictions on investing in certain securities, or
types of securities or other financial instruments, that are developed in consultation with the Client,
or in accordance with the mandate selected by the Client. With respect to Funds, each Fund is
managed in accordance with its investment guidelines and restrictions as set forth in the Fund’s
PPM and generally is not tailored to the individualized needs of any particular Investor, and an
investment in a Fund does not, in and of itself, create an advisory relationship between the Investor
and us. With respect to Accounts, NSR will allow Clients to customize their investments, upon
their request, to implement reasonable investment restrictions on certain securities, industries or
sectors. These requests are typically received at account inception and documented in the respective
IMAs but reasonable restrictions may be requested, in writing, at any time thereafter.
We provide monthly newsletters and/or factsheets to existing and prospective investors of our
Funds. The newsletters/factsheets contain the performance returns of the Funds as well general
market and portfolio updates. We also provide introduction packs to prospective investors
containing an overview of each Fund’s investment objectives and strategy, fund terms and
performance. Such communication is construed as advertisements under the Marketing (Rule
206(4)-1 of the Advisers Act).
We manage funds that may invest part of their portfolio in other private funds also managed by us
and to avoid double counting those assets, the RAUM was calculated looking through those
investments. As of 31 December 2023, our regulatory assets under management are as follows:
Regulatory Assets Under Management USD
Managed on a Discretionary basis $519,976,000
Managed on a Non-discretionary basis $141,259,000
Total Regulatory Assets Under Management $661,235,000
This Brochure contains disclosures relevant only to our U.S. resident Clients.