Fees and Compensation — Form ADV Part 2A (6/29/2026)
[Brochure]
Item 5. Fees and Compensation
Management Fees
The Firm charges a monthly management fee in arrears equal to one-twelfth of 1.00% per
annum of the month-end net asset value of the relevant fund (pro-rated for periods of less
than one month), accrued daily and calculated as at each valuation date. The management
fee is payable within 14 days after the relevant month-end valuation date.
The Firm also offers a relative benchmark fee structure with a monthly management fee
(paid in arrears) equal to one-twelfth of 0.50% per annum of the market value of the
account. The fees applicable to separately managed accounts are detailed in the relevant
investment advisory or management agreement for each account and may vary slightly (in
terms of mechanics) from the fees paid by the funds.
Performance Fees
The Firm is entitled to receive a performance fee from the funds, calculated on a series-by-
series basis so that each series of shares is charged a performance fee that equates precisely
with the performance of that series. This method ensures that any performance fee paid to
the Firm is charged only to the series that have appreciated above both a high-water mark
and the target NAV (hurdle).
For each performance period (commencing on the first business day after the close of the
initial offer period or the dealing day for subscriptions on which the relevant series is issued,
and ending on December 31 of the year in which the period commences; thereafter, each
period of 12 calendar months commencing January 1), the performance fee in respect of
each series equals to 20% of the appreciation in the net asset value of that series above the
higher of (i) high-water mark and (ii) the applicable target NAV for the relevant performance
period. The performance fee is accrued as at each valuation point, calculated after accrual
of the management fee and before deduction for any accrued performance fee.
For the relative benchmark fee structure, the Firm is entitled to a performance fee equal to
20% of the amount by which performance exceeds the applicable benchmark return plus
2%.
The performance fee arrangements applicable to separately managed accounts are detailed
in the relevant investment advisory or management agreement. These arrangements may
vary in calculation methodology from those applicable to the funds. If the management
agreement is terminated before December 31 in any year, the performance fee for the then-
current performance period will be calculated and paid as though the date of termination
were the end of the relevant period.
AROHI ASSET MANAGEMENT PTE. LTD.
2 Battery Road, #24-01 Maybank Tower, Singapore 049907
Tel: (65) 6535 6171 | www.arohi.com | adviserinfo.sec.gov
85575096;4; 00194-002
AROHI ASSET MANAGEMENT PTE. LTD. | FORM ADV PART 2A – FIRM BROCHURE
Expenses
The Firm and the funds’ administrator are responsible for providing and paying for all office
personnel, office space, and office facilities required for the performance of their respective
services to the funds. The funds bear all of their operating and administrative expenses,
including (without limitation):
Management fees and performance fees payable to the Firm
Administrator fees and custodian fees
Auditor fees
Director fees
Local tax advisor fees
Brokerage and execution charges, commissions, and custodial charges related to
fund investments
Regulatory filing fees
Legal and consulting fees incurred in the operation of the funds
Insurance premiums for directors’ and officers’ liability insurance
Costs of publishing net asset values and printing and distributing annual reports and
investor statements
Each feeder fund bears its pro-rata share of the applicable master fund’s operating
expenses. Expenses relating to primary due diligence on investee companies (including
travel costs and other direct costs of company and industry research) are borne by the Firm
and are not charged to the funds or separately managed accounts.
Where services are provided between the Firm and its wholly owned Indian subsidiaries
pursuant to inter-company service agreements, the fees payable under those agreements
are determined on arm’s length principles. The Firm does not charge to client accounts any
fees or costs arising from inter-company service arrangements.
Billing and Payment
Management fees payable by the funds are deducted from fund assets and paid to the Firm.
Fees for separately managed accounts are billed to the client in accordance with the
relevant investment management agreement. Further details of how fees are calculated for
each fund are contained in the offering documents of the relevant fund.
AROHI ASSET MANAGEMENT PTE. LTD.
2 Battery Road, #24-01 Maybank Tower, Singapore 049907
Tel: (65) 6535 6171 | www.arohi.com | adviserinfo.sec.gov
85575096;4; 00194-002
AROHI ASSET MANAGEMENT PTE. LTD. | FORM ADV PART 2A – FIRM BROCHURE
Account Minimums and Types of Clients — Form ADV Part 2A (6/29/2026)
[Brochure]
Item 7. Types of Clients
The Firm provides discretionary investment advisory services to private investment funds
and institutional separately managed accounts. Most of the Firm’s fund investors and
separately managed account clients are long-term institutional investors, including
university endowments, foundations, pension and sovereign wealth funds, and family
offices. The Firm does not currently provide investment advisory services to retail investors.
Minimum Investment Amounts
The current minimum investment size for a separately managed account is generally USD
200 million, subject to waiver at the Firm’s discretion. Each fund has a minimum initial
investment amount of USD 100,000; additional investments must be made in increments of
USD 100,000. These minimums may be reduced or waived by the Firm or board of directors
of the relevant fund, subject to any applicable statutory minimums.
Client Composition
The following table summarise the composition of investors in funds managed by the Firm
and separately managed accounts as of March 31, 2026:
Geography % of AUM
North America and Canada 50%
Asia Pacific (including Singapore) 46%
Others (Europe & Australia) 4%
Type of Investor % of AUM
Endowments 47%
Internal Capital 20%
High Net Worth Individuals 16%
Sovereign Wealth Fund 10%
Foundation 7%
Others 0% (<1%)
Note: Internal Capital represents the investments made by Arohi Asset Management Pte. Ltd. and its
employees
Investment Company Act Exclusions
Each fund that accepts U.S. investors relies on an exclusion from the definition of
“investment company” under the Investment Company Act of 1940. The applicable
exclusion for each fund is either:
AROHI ASSET MANAGEMENT PTE. LTD.
2 Battery Road, #24-01 Maybank Tower, Singapore 049907
Tel: (65) 6535 6171 | www.arohi.com | adviserinfo.sec.gov
85575096;4; 00194-002
AROHI ASSET MANAGEMENT PTE. LTD. | FORM ADV PART 2A – FIRM BROCHURE
Section 3(c)(1), which is available to issuers whose outstanding securities are
beneficially owned by not more than 100 persons and that do not make or propose
to make a public offering of their securities; or
Section 3(c)(7), which is available to issuers whose outstanding securities are owned
exclusively by persons who, at the time of acquisition, are “qualified purchasers” as
defined in Section 2(a)(51) of the Investment Company Act, and that do not make or
propose to make a public offering of their securities.
The applicable exclusion for each fund is disclosed in the relevant fund’s offering
documents. U.S. investors in Section 3(c)(1) funds are required to be accredited investors
within the meaning of Rule 501(a) of Regulation D. U.S. investors in Section 3(c)(7) funds are
required to be accredited investors within the meaning of Rule 501(a) of Regulation D and
qualified purchasers. The Firm does not admit U.S. investors into any fund except in
accordance with these requirements.
AROHI ASSET MANAGEMENT PTE. LTD.
2 Battery Road, #24-01 Maybank Tower, Singapore 049907
Tel: (65) 6535 6171 | www.arohi.com | adviserinfo.sec.gov
85575096;4; 00194-002
AROHI ASSET MANAGEMENT PTE. LTD. | FORM ADV PART 2A – FIRM BROCHURE
Filed 2025-09-04 (D) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $100,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Filed 2025-06-11 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $100,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Filed 2025-06-11 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $100,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Filed 2017-05-19 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $100,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
AUM Breakdown
Accounts
AUM ($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
0.7
(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
0.0
(k) Insurance companies
0
0.0
(l) Sovereign wealth funds and foreign official institutions
0
0.0
(m) Corporations or other businesses not listed above