Aubrey Capital Management Limited

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Aubrey Capital Management Limited
CRD #285802
SEC #801-108789
CIK #0001730754
AUM 1,152.0 M (2026-02-03)
Employees 26 (35% Investors, 0% Brokers)
Fees
Minimum
Phone441312262083
Address10 Coates Crescent
Edinburgh Mid Lothian, United Kingdom
Source [IAPD] [EDGAR] [Website] [LinkedIn] [Facebook]
Total AUM ($M)
17001360102068034002010201520212027
Fees and Compensation — Form ADV Part 2A (8/7/2026) [Brochure]
Item 5 - Fees and Compensation

A.    Fees for Asset Management

      1.        Standard Fee Schedule

      Fees are generally in the range from 0.4% to 1.5% and can be the subject of individual negotiation
      with clients, are dependent on the nature of the investment strategy and the amount of funds to
      be managed. Aubrey serves as sub-manager to a Luxembourg based European mutual fund
      whose fee structure is different from the general range outlined above. However, the fund has
      not been, nor will be, open to outside investors. Additionally, Aubrey serves as the asset manager
      to a U.S. based Private Fund whose fee structure also differs from the range outlined above.

      2.        Performance Based Fees

      Under appropriate circumstances, Aubrey may charge performance-based fees to US clients as
      discussed in Item 6. When charging such fees for US based clients, Aubrey complies with Rule
      205-3 of the Advisers Act.

      3.        Negotiability

      Fees can be subject to negotiation with individual clients.

      4.        Valuation, Payment, and Proration

           Management
           Fees are generally payable quarterly in arrears although there are a few exceptions
           where the fee is payable monthly. Our general approach to money being added to or
           withdrawn from funds in between billing periods is that this is taken account of within
           the fee calculation. Information on specific fee arrangements is available on request
           and is as noted in the investment management agreement. With respect to the non-
           U.S. Luxembourg based European mutual Fund and the remaining U.S. based Private
           Fund managed by the Firm, valuations are performed by the respective unaffiliated
           fund administrators in accordance with the respective Prospectus or Offering
           Memorandum.

           The Firm’s management fees are paid quarterly in arrears, based on the accrued daily
           net asset value, for the Luxembourg based European mutual fund it manages. For the
           US Private fund, the fees are based on the month end net asset value after taking
           account of contributions or withdrawals during the billing period.

B.    Billing

      Aubrey bills clients directly for its fees. Aubrey sends statements to clients within fifteen (15)
      days following the end of the billing period. The statements describe the fees charged and the
      basis on which the fees were calculated. All fees are due and payable by clients within 10 days
      of the date of the statement. Aubrey does not deduct its fees from client assets, although how
      Aubrey collects its fees will differ for the non-U.S. European Private Fund and the U.S. based
      Private Fund.

C.      Other Fees and Expenses

        1.      Other Fees Charged by Aubrey

       Aubrey does not generally charge any additional fees in connection with providing management
       services to clients. Aubrey reserves the right to charge additional fees for out of the ordinary
       services clients may request, such as detailed analyses of transactions or copies of historical
       information.

        2.      Custody

       The custodian of the assets managed by Aubrey charges fees for its custodial services. Clients will
       be responsible for payment of those fees.

        3.      Brokerage and Other Costs

       Clients are also responsible for fees charged by brokers executing transactions in their accounts
       and other transaction costs. See Item 12.

D.      Payments and Refunds

Aubrey does not charge any fees in advance. If a client were to pay for any service in advance and the
fees were not earned when the services are terminated, Aubrey would refund all unearned fees following
the date the services were terminated.

E.      Compensation for Sale of Securities or Other Investment Products

No commissions or other compensation are paid to, or earned by, Aubrey or any of its supervised persons
in connection with the sale of any securities or investment products to clients.
Account Minimums and Types of Clients — Form ADV Part 2A (8/7/2026) [Brochure]
Item 7 - Types of Clients

Aubrey offers its asset management services to clients in the United States, the United Kingdom and
other countries where it is qualified to do so. The Firm offers portfolio management services to
institutional investors, high net worth individuals, endowment funds, pension plans, and pooled
investment vehicles (such as United Kingdom and Luxembourg mutual funds, a Chilean registered fund
and a U.S. based Private Fund, in each case for which the Firm serves as the asset manager or subadvisor).

There is no specific minimum account size for a client.
Sector Form 13F Holdings Value ($B)
Embraer Sa 0.0
Alibaba Group Holding Ltd 0.0
Latam Airlines Group Sa 0.0
China Lodging Group Ltd 0.0
Nu Holdings Ltd 0.0
New Oriental Education & Technology Group Inc 0.0
Laureate Education Inc 0.0
Comfort Systems USA Inc 0.0
Intl FCStone Inc 0.0
Interdigital Inc 0.0
View All
Holdings by Sector ($B)
4.03.22.41.60.80.02018202120242027
Type Form D Funds Date Sold AUM
Other Aubrey GEMS Partners LP [2021-12-20] 85.6 M 82.9 M
Filed 2025-03-31 (D/A) · Exemption 506(b), 3(c), 3(c)(1) · Minimum $100,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
AUM Breakdown Accounts AUM ($M)
By Client Type
(a) Individuals (other than high net worth individuals) 0 0.0
(b) Individuals (high net worth individuals) 193 225.4
(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 8 649.3
(g) Pension and profit sharing plans 7 277.3
(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 0 0.0
(n) Other 0 0.0
Total 208 1,152.0
By Discretionary
Discretionary 208 1,152.0
Non-Discretionary 0 0.0
Total 208 1,152.0
By Non-United States Persons
Non-United States Persons 971.8
United States Persons 180.2
Total 208 1,152.0
Form D Directors Role # Filings # Firms 2011 - 2026
Ramona Bowry Director 31 10
Greg Farrington Director 4 3
Aubrey Gems Partners GP LLC Executive Officer 1 1
Ivan Blair Director 1 1
Aubrey Capital Management Limited Executive Officer 1 1
EDGAR Form CIK 2011 - 2026
13F-HR [0001730754]
Firm Profile (Form ADV)
Discretionary AUM$0.5B
ServesInstitutional, Retail
LEI54930003QJIRTKDMN877
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