Cape Ann Asset Management Limited

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Cape Ann Asset Management Limited
CRD #284056
SEC #801-107996
CIK #0001768237
AUM 3,779.7 M (2026-06-17)
Employees 21 (43% Investors, 0% Brokers)
Fees
Minimum
Phone011442034438480
Address1 Dukes Mews
London, United Kingdom
Source [IAPD] [EDGAR] [Website] [LinkedIn]
Total AUM ($B)
4.03.22.41.60.80.02010201520212027
Fees and Compensation — Form ADV Part 2A (6/17/2026) [Brochure]
Item 5.            Fees and Compensation

Cape Ann provides discretionary investment management services to Unitholders in the
following commingled funds

         (i)       the Cape Ann Global Developing Markets Fund, a US domiciled Delaware
                   Statutory Trust (“the GDM US Fund”);
         (ii)      the Cape Ann Global Developing Markets (Ireland) Fund, an Irish domiciled
                   UCITS vehicle which is offered to non-US investors and certain tax-exempt U.S.
                   investors (“the GDM Irish Fund”);
         (iii)     the Cape Ann Perivallon Fund, a US domiciled Delaware Statutory Trust (“the
                   Perivallon US Fund”) (collectively the “Funds”).

The GDM Irish Fund (the “Irish Fund”) is a sub-fund of the overarching UCITS Trust, The
Cape Ann (Ireland) Trust, which is an umbrella unit trust established as an undertaking for
collective investment in transferable securities. UCITS stands for Undertakings for Collective
Investment in Transferable Securities, which is a regulatory framework created by the
European Union for investment funds.

The Funds are privately offered commingled funds that are invested in global developing
market equity securities according to the following fee scales:

                                  GDM US Fund and GDM Irish Fund
                                First US$50,000,000               1.25%
                                Next US$50,000,000                 1.15%
                                Next US$100,000,000               1.00%
                                Thereafter                        0.90%

                                             Perivallon US Fund
                                       Subscription for Units     Subscription for Units on
                                       before January 1, 2025      or after January 1, 2025
 First US$50,000,000                                1.10%                    1.25%
 Next US$50,000,000                                 1.05%                    1.15%
 Next US$100,000,000                                1.00%                    1.00%
 Thereafter                                         0.90%                    0.90%

Fees paid by each Unitholder invested in the Funds are based upon the market value of the
Units held by the Unitholder rather than the value of the Funds. Fees will not generally be
negotiable. Fees are payable monthly in arrears, although the actual timing of fee payments
will depend on the underlying legal domicile of the Fund and the terms of its operating
agreements. Fees are deducted directly from each investor’s capital account.

Cape Ann staff, and their related parties hold interests in the Funds. Such investments are
made on the same terms and are subject to the same fees and liquidity rights as other

June 2026                                                                                      -5-
Cape Ann Asset Management Limited – ADV Part 2A Brochure

Unitholder investments. Cape Ann pays for the costs of all third party research directly out of
its own financial resources. No bundled brokerage commissions are incurred.

The Funds pay their own direct trading expenses. Direct trading expenses include brokerage
commissions related to trade execution, “bid-ask” spreads, mark-ups, clearing fees, exchange
fees, registration and transfer fees, regulatory and governmental charges and duties and
transactional fees and expenses related to their investments. The Funds pay all income,
dividend withholding, capital gains and other taxes related to their underlying investments.
In addition, the Funds may be required to reimburse Cape Ann or third party service providers
to the Funds for extraordinary legal expenses (i.e. expenses incurred to protect or promote the
investment rights or obligations of the Funds). Commission rates typically vary by country.
Cape Ann may occasionally negotiate a further reduction in commission rates and/or
periodically “step out” and pay a higher rate if, as an example, it costs a counterparty more to
trade a given security than the normal execution only rate of commission or if a higher rate
must be paid in order to participate in a placement or secondary offering of securities.

Cape Ann pays all routine legal, audit and accounting fees related to the Funds from its own
financial resources. Cape Ann pays any fees payable to the Custodians, Trustees, Fund
Administrators, Managers, Auditors, Tax Advisors and other similar service providers of the
Funds. Cape Ann has paid all expenses incurred in connection with the organisation and the
formation of the Funds and pays all costs associated with the ongoing issuance of the Units of
the Funds. The Funds are not required to raise a minimum amount in order to defray these
costs and expenses. The Funds are not required to reimburse Cape Ann in the event that the
investment management fees are insufficient to cover the expenses borne by Cape Ann.

Separate Account Clients

Clients invested in separate accounts to which Cape Ann is the appointed investment manager
pay their own direct trading expenses. Direct trading expenses include brokerage
commissions, bid-ask spreads, mark-ups, clearing fees, exchange fees, stock loan expenses,
registration and transfer fees, regulatory and governmental charges and duties, and other fees
and expenses relating to investments. Clients invested in separate accounts pay all income
and other taxes related to their underlying investments. Clients invested in separate accounts
may be required to reimburse Cape Ann for legal expenses incurred to protect the investor that
Cape Ann determines are not routine (e.g., extraordinary legal expenses such as those incurred
in connection with litigation to protect or promote the investment rights or obligations of the
investors invested in separate accounts (as applicable) and legal or accounting expenses
...
Account Minimums and Types of Clients — Form ADV Part 2A (6/17/2026) [Brochure]
Item 7.            Types of Clients

Each Fund, and not the underlying Unitholders in each Fund, is considered a Client pursuant
to the Investment Advisers Act of 1940. Cape Ann makes investments on behalf of the Funds
for the benefit of the underlying Unitholders in each respective Fund. Units in the GDM US
Fund and the Perivallon US Fund (the “US Funds”), and the Irish Fund with respect certain
eligible tax-exempt US investors, are sold only to Unitholders that qualify as “Accredited
Investors” and “Qualified Purchasers” as defined under applicable U.S. federal securities
laws. Separate account clients must normally be considered a “Qualified Institutional
Buyer”. An investment in Units of a Fund or separate account involves the risk of loss. Cape
Ann, in its capacity as investment manager, is responsible for reviewing and managing the
holdings and for making appropriate recommendations to satisfy the respective investment
goals of the Funds. Additional information is available in the respective offering
memorandum of each Fund and the Investment Management Agreements (“IMAs”) in place
between Cape Ann and the separate account clients.

Conditions for Managing Accounts

The minimum initial subscription for Units in the Funds is US$2 million. The minimum
additional investment is US$100,000. Cape Ann may, in its sole discretion, accept or reject,
in whole or in part, any investment or impose conditions or restrictions on these investments
subject to any restrictions set out in the Funds’ respective offering memoranda and governing
documents.

There is no minimum holding period for Units. Unitholders may redeem all or part of their
Units in the Funds on any Dealing Day by providing Cape Ann with written notice ordinarily
at least fifteen (15) Business Days prior to the Dealing day upon which the redemption is to be
effective. Certain documentation must also ordinarily be returned at least ten (10) Business
Days prior to such Dealing day. Any redemption must ordinarily equal or exceed $500,000
and following any such redemption, a Unitholder must ordinarily maintain Units with a
minimum market value of US$1 million. Additional information is available in the Funds’
offering memoranda. Cape Ann may modify these deadlines at its sole discretion, subject to
any restrictions set out in the Funds’ offering memorandum and governing documents.

Unitholders in the Irish Fund, are permitted to subscribe for units and/or redeem from the
Irish Fund on the first calendar day of the month as well as on or immediately after the 15th
calendar day of the month.

Transition Accounts

Cape Ann has the ability to direct current or prospective Unitholders making cash
contributions to or redemptions from the US Funds to use transition accounts. Transition
accounts are temporary custody accounts that are opened under the US Funds’ general legal
structure. They are used to facilitate large subscriptions and withdrawals. The transition
account structure allows Cape Ann to invest cash contributions outside of the US Funds’ direct
assets or to liquidate holdings outside of the US Funds’ direct assets (and therefore avoid
impacting existing investors or remaining investors, as the case may be). By investing new
cash flows or liquidating the securities separately, the incoming or outgoing investors bear
their own market risk during the investment or redemption period (usually one month or less,
but this can be longer depending on market conditions), as well as their own dealing costs.
Cape Ann believes that these procedures safeguard the benefits of commingled investing for
all participants and represent a fair and equitable way of accommodating periodic
subscriptions and withdrawals. Prospective investors should refer to the specific provisions of
the US Funds’ respective Offering Memorandum for a complete discussion of Transition
Accounts and the risks involved therein.

June 2026                                                                                   -7-
Cape Ann Asset Management Limited – ADV Part 2A Brochure

Transition accounts cannot be used to facilitate contributions to or redemptions from the Irish
Fund.

Anti-Dilution Levy

Unitholders making cash contributions to or redemptions from the Funds may be subject to
an anti-dilution levy (“ADL”) which, except in certain extraordinary circumstances, will not
exceed 125 basis points (1.25%) of the value of the transacting unitholder’s subscription or
redemption. The ADL is credited directly to the Fund to protect remaining unitholders from
the impact associated with processing contributions and redemptions. ADLs are not a “load”
and are not payable directly or indirectly to Cape Ann. The ADL paid by a transacting
Unitholder is calculated by Cape Ann and is based on the actual transaction and market impact
costs incurred by the Fund. In months when the Fund has direct inflows or outflows which
can be used to offset contributions or redemptions it may be possible to accommodate
significant and direct unitholder transactions with a reduced anti-dilution levy. If the
aggregate costs of implementing a unitholder transaction is zero or negative, then no anti-
dilution levy will be assessed. If the costs are less than 125bps, then the lesser cost will be
applied.

If a unitholder transaction is processed without the need for equity trading, Cape Ann will
apply a notional ADL. This ensures that existing investors receive the same protection, and
transacting investors do not unfairly benefit, from situations where the Fund’s investment
strategy or market volatility mean a transaction is satisfied from the Fund’s existing cash or
equity holdings. The notional figure is updated on a quarterly basis and is calculated using
both internal and third-party data analysis.

Sideletter Agreements

Cape Ann generally will consider entering into a sideletter agreement only when rules
governing the investment by a specific Unitholder (such as state law or the governing
...
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Holdings by Sector ($M)
4503602701809002019202120242027
Type Form D Funds Date Sold AUM
Other Cape Ann Ireland Trust - Cape Ann Global Developing Markets Ireland Fund [2026-06-17] 714.9 M
Other Cape Ann Perivallon Fund [2021-06-29] 42.2 M 47.6 M
Filed 2026-03-02 (D/A) · Exemption 3(c)(7), 506(b), 3(c) · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
Other Cape Ann Global Developing Markets Fund [2016-06-13] 2,855.7 M 2,913.2 M
Filed 2026-03-02 (D/A) · Exemption 3(c)(7), 506(b), 3(c) · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
AUM Breakdown Accounts AUM ($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 3 3.7
(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 1 0.1
(n) Other 0 0.0
Total 4 3.8
By Discretionary
Discretionary 4 3.8
Non-Discretionary 0 0.0
Total 4 3.8
By Non-United States Persons
Non-United States Persons 0.1
United States Persons 3.7
Total 4 3.8
Form D Directors Role # Filings # Firms 2011 - 2026
Timothy Linehan Director 14 5
Michael Cowan Executive Officer 12 5
Stephen Butt Executive Officer 9 5
John Lynch Director 29 4
Chris Cowie Executive Officer 7 4
Jonathan Bell Director 113 3
Ivana Vilicnik Director 2 1
Peter Lockey Executive Officer 2 1
Geoffrey Summers Director 2 1
Timothy Lineham Director 1 1
View All
EDGAR Form CIK 2011 - 2026
13F-HR [0001768237]
Firm Profile (Form ADV)
ServesInstitutional
LEI5493001HUJTE0WEMJN22
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