Aflac Asset Management LLC

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Aflac Asset Management LLC
CRD #304316
SEC #801-120174
CIK #0001882466
AUM 133.47 B (2026-03-31)
Employees 110 (35% Investors, 0% Brokers)
Fees
Minimum
Phone212-510-4600
Address100 Wall Street, 29th Floor
New York, NY 10005
Source [IAPD] [EDGAR]
Total AUM ($B)
14011284562802010201520212027
Fees and Compensation — Form ADV Part 2A (3/31/2026) [Brochure]
Item 5 - Fees and Compensation
Aflac GI provides investment advisory services to its Clients pursuant to separate Investment Management
Agreements (“IMAs”) with each Client. The IMAs for each of its Clients, including the Fund, along with the
Governing Fund Documents, set forth in detail the fee structure relevant to each Client. Aflac GI receives
asset-based management fees for providing discretionary and non-discretionary investment advisory and
consultancy services to clients. Fees for investment advisory services are payable quarterly in arrears, based
on a percentage of the value of assets under management as shown on Client’s accounting books of record.
Fees are individually determined based on the type of asset class for which management services are being
provided, and will be calculated as a percentage of the assets under management within each asset class in
a particular Client’s account. Fees are negotiable based on the individual Client. Fees will range within a given
asset class, as described in the applicable fee schedule.

Derivatives transactions, if any, are generally charged based on the quarter-end notional value, but may also
be charged based on the absolute value of the quarter-end market value, as outlined in each Client’s
agreement. Fees for public and private equity will be based on fair market value as determined in accordance
with our valuation policies and procedures, and fees for all other assets will be based on book value. In addition
to Aflac GI’s investment management fees, Clients are generally responsible for other trading costs and
custodial fees related to their accounts, unless described otherwise in the applicable governing documents.
Clients invested in the Fund are generally responsible for the portfolio’s expenses, including but not limited to
management fees, fees and expenses of the directors, custodians, administrators, independent pricing
vendors and other agents, transaction fees, taxes and fees for tax reporting. For more information on trading
costs, please see Item 12 – Brokerage Practices below. To the extent that Clients’ accounts are invested in
mutual funds, private funds or other collective investment vehicles, these funds charge a separate layer of
management, performance, trading, and administrative expenses, which are borne indirectly by the investors
in each such fund. Accordingly, where a Client invests in such funds, it will bear its share of such costs.

                                                                                                      5|Page

Aflac GI bills its Clients for its investment advisory services and does not deduct the fees from Clients’ assets.
Aflac GI’s fees are exclusive of other fees and expenses that are incurred by, or on behalf of, the Client as
documented in a written agreement with the Client. If any such expenses are paid by Aflac GI, Aflac GI will
provide Client an invoice reflecting such expenses and the Client will reimburse Aflac GI or its affiliates for
those expenses.

In certain instances, our supervised persons will recommend that an Insurance Company Client invest in a
private fund or other products that we or an affiliate sponsor, advise or otherwise provide services to. In such
instances, the Client will generally pay two layers of fees, including underlying fees and expenses associated
with the product, in addition to advisory fees charged by Aflac GI. Aflac GI has a conflict of interest to
recommend that Clients invest in affiliated products, as Aflac GI and/or its affiliates will receive additional
compensation in connection with such investments than if the Client invested in an unaffiliated product. Aflac
GI addresses such conflicts of interests through disclosure and policies and procedures to ensure that any
investment recommendation made to a Client is in accordance with its fiduciary duty. Further, in certain
instances, Aflac GI will waive its advisory fee in connection with a Client’s investment in an affiliated product.
Please see Item 10 of this Brochure for additional information.
Account Minimums and Types of Clients — Form ADV Part 2A (3/31/2026) [Brochure]
Item 7 - Types of Clients
As outlined in Item 4 – Advisory Business above, Aflac GI generally provides investment advice to its parent
company, Insurance Company Clients and pooled investment vehicles in which Insurance Company Clients
invest. Aflac GI does not currently provide advisory services to unaffiliated institutional investors. Further,
Aflac GI does not currently, and does not have any expectation that it will in the future, provide advisory
services to retail investors.

While Aflac GI does not have any specific requirements for opening or maintaining an advisory account (other
than “know your customer” or other applicable regulatory eligibility requirements), Aflac GI generally only offers
investment advisory services to institutional investors as described above.
Sector Form 13F Holdings Value ($M)
Trupanion Inc 93.1
Pagaya Technologies Ltd 1.5
Ethos Technologies Inc 0.1
Pagaya Technologies Ltd 0.0
 
 
 
 
 
 
 
Holdings by Sector ($M)
50040030020010002020202220242027
Type Form D Funds Date Sold AUM
PE Global Alternatives Fund SPC 2020-12-16 2,541.5 M
PE Global Alternatives Trust I 2020-12-16 176.6 M
AUM Breakdown Accounts AUM ($B)
By Client Type
(a) Individuals (other than high net worth individuals) 0 0.0
(b) Individuals (high net worth individuals) 0 0.0
(c) Banking or thrift institutions 0 0.0
(d) Investment companies 0 0.0
(e) Business development companies 0 0.0
(f) Pooled investment vehicles 4 2.5
(g) Pension and profit sharing plans 0 0.0
(h) Charitable organizations 0 0.0
(i) State or municipal government entities 0 0.0
(j) Other investment advisers 0 90.7
(k) Insurance companies 5 21.4
(l) Sovereign wealth funds and foreign official institutions 0 0.0
(m) Corporations or other businesses not listed above 0 3.9
(n) Other 0 14.9
Total 12 133.5
By Discretionary
Discretionary 11 118.6
Non-Discretionary 1 14.9
Total 12 133.5
By Non-United States Persons
Non-United States Persons 112.7
United States Persons 20.7
Total 12 133.5
EDGAR Form CIK 2011 - 2026
13F-HR [0001882466]
13F-NT [0001882466]
Firm Profile (Form ADV)
Discretionary AUM$106.3B
ServesInstitutional
Fund TypesPrivate Equity
LEI549300282HBRKF96QS61
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