Firm Description
• Established in 2011, we are an independent wealth management firm located in Paris France. We provide customized investment management solutions that are tailored to our Client’s goals and objectives and are delivered with outstanding personal service.
• Our investment approach is to build broadly diversified, efficient portfolios that capture the asset class returns in accordance with the investor risk tolerance.
• We offer a broad range of investment solutions suited to the tax residency of the Client. These range from regulated Investment Funds (“UCITS”) in Europe, which we provide according to our status as a French registered Investment Manager, but to which we shall make no further reference, to individual portfolios in the U.S which form a part or all of our dedicated personalized investment programs.
• Asset under management as of December 31st 2023 stood at 532 442 850 USD. All the portfolios are managed on a discretionary basis (mandates and collective investment vehicles).
• We have a highly experienced team of advisers who boast degrees from top universities and certifications from leading professional organizations. Principal owners
• Zenith AM is now in its 13th year of operation. Its principal owner is Crystal Inter. Advisory Services We provide investment management services focused on the ongoing selection and Management of marketable security portfolios. Such services incorporate a holistic view of Client’s investment management needs.
• Based upon each Client’s situation, we help Clients understand and plan for their liquidity needs, as well as develop and maintain an appropriate long‐term investment plan. In particular, we seek a complete understanding of each client’s investment objectives.
• The investment management policy is detailed in a policy statement named the “mandate”. The mandate reflects the Client’s return objectives, risk tolerance and liquidity restraints given current market conditions, fees.
• This mandate, which may be amended from time to time as client circumstances or objectives change, implements the objectives noted above using the appropriate asset classes and instruments for the Client.
• Zenith AM monitors portfolio progress and performance through time, rebalancing the portfolio in accordance with our portfolio managers’ views and process, and reports portfolio performance and balances on at least a quarterly basis.
• The Firm invests in mutual funds where appropriate to maintain broadly diversified portfolios and have access to particular asset classes as well as in straight securities.
• Clients may put restrictions on investing in certain securities or types of securities in their portfolios. Where possible, Zenith AM will accommodate such investment restrictions. Implementing restrictions recorded in the mandate might detract from investment performance. Financial Planning
• Upon specific request by the Client, the Firm may provide either financial consulting or a comprehensive financial plan tailored to meet the client’s needs and/or investment objectives as described by the client. These services may include, but are not limited to the following:
• Identification of financial goals,
• preparation of financial condition statements, cash flow, net worth,
• asset allocation analysis,
• Client’s investment philosophy, risk tolerance and investment objectives.
• When appropriate, the firm encourages Clients to use the services of independent financial advisers and/or tax specialists and makes clear that the firm does not render legal, accounting, wrap fee program or tax advice.
• The firm will not advise the client or act for the client in any legal proceedings, including bankruptcies, involving securities held or previously held, or the issuers of those securities. The firm will not vote proxies for securities held in Client accounts. Mandate
• The mandate, which is always delivered by Zenith AM to Clients, provides details on fee structures and account services to be provided by the firm. These agreements are executed between the Client and the firm.
• Clients may pay expenses under a “traditional” payment option, meaning that advisory services are provided for a fee, but transaction services are billed separately on a per-transaction basis by the custodian bank, or under a bundled payment, meaning that advisory

services (including asset management) and transaction cost (including ticket charges) are provided for one fee. Our Asset Management Services in the US are not considered as a wrap fee program.
• You should bear in mind that fee-based accounts, when compared with commission-based accounts, often result in lower costs during periods when trading activity is heavier, such as the year an account is established. However, during periods when trading activity is lower, the fee- based account arrangements may result in a higher annual cost for transactions. Thus, depending on a number of factors, the total cost for transactions under a fee account versus a commission account can vary. Factors which affect the total cost include account size, amount of turnover, type and quantities of securities purchased or sold, commission rates and the client’s tax situation. It should also be noted that lower fees for comparable service may be available from other sources. The exact fees and other terms will be outlined in the agreement between the client and Zenith AM. The client should discuss the advantages and disadvantages of fee-based and commission- based accounts with his/her adviser.
• Zenith AM offers asset management services, which involves the firm in providing continuous and ongoing supervision over the client’s account. Zenith AM will continuously monitor the client account and make trades in the account(s) when necessary. The account will be managed by Zenith AM based on the client’s financial situation, investment objectives and risk tolerance. Zenith AM will actively monitor the account and will make management recommendations and decisions regarding buying, selling, reinvesting or holding securities, cash or other investments.
• We recommend that assets in a mandate be maintained in an advisory account with a qualified custodian. The client shall appoint Zenith AM as his/her investment adviser of record on specified accounts. The account will consist only of separate account(s) held by the qualified custodian under the client’s name. Zenith AM does not act as custodian and does not have direct access to funds and securities except to have advisory fees deducted from the client account with the client’s prior written authorization. The qualified custodian will maintain physical custody of all funds and securities of the Account, and the client will retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) for the account. The client shall authorize Zenith AM to have trading authorization on your account and we will provide asset management services. The client shall authorize either discretionary or non- discretionary management in his/her agreement for us. If the client has authorized us to provide asset management services on a discretionary basis, we will make all decisions to buy, sell or hold securities, cash or other investments in your managed account in our sole discretion without consulting with the client before making any transactions. The client shall provide us with written authorization to exercise this discretionary authority and can place reasonable restrictions and limitations on our discretionary authority. Account Termination
• Mandates (and therefore the relationship) may be terminated by either party upon written notice.
• As described in the “Mandate”, upon written receipt of notice to terminate its Client Agreement with us, we will end our advisory services in an orderly and efficient manner.
• We do not charge any fee for termination. However, the Client should be aware that certain mutual funds impose redemption fees as stated in each company’s fund prospectus in certain circumstances. Clients must also keep in mind that the decision to liquidate securities or mutual funds may result in tax consequences that should be discussed by the client with their own tax advisor.
• Investment Advisory Fees are generally billed separately and are prorated to the date of termination if the Client terminates its relationship with Zenith AM. Investment Advisory Fees are also prorated at the inception of the investment advisory agreement to cover only the period of time the account assets were under management.
• US Person Clients may decide to continue their relationship with the custodian bank. In such instances, the assets will remain on the Client’s account where we will no longer have access to the account.