Complus Asset Management Singapore PTE Ltd

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Complus Asset Management Singapore PTE Ltd
CRD #319703
SEC #801-126426
CIK #
AUM 5,866.6 M (2026-03-31)
Employees 10 (60% Investors, 0% Brokers)
Fees
Minimum
Phone656-622-5440
AddressOcean Financial Centre, Level 4
Singapore, Singapore
Source [IAPD] [Website]
Total AUM ($B)
6.04.83.62.41.20.02010201520212027
Fees and Compensation — Form ADV Part 2A (3/31/2026) [Brochure]
ITEM 5: FEES AND COMPENSATION
Performance and Management Fees
Complus typically charges a monthly management fee based on the percentage of assets under
management, and a performance fee based on the percentage of net capital appreciation. The
management and performance fees vary, but are generally up to 1.5% and 20%, respectively.
Complus is only entitled to performance fees if cumulative profits generated exceed the previous
highest level of cumulative profits (high water mark). This method of calculating the performance
fee is prevalent in the alternative investment field.

Neither Complus nor any of its “supervised persons” (as defined in the glossary of terms to SEC
Form ADV) accept compensation for the sale of securities or other investment products, including
asset-based sales charges or service fees from the sale of funds. In limited circumstances, Complus
may negotiate specific terms of investment for certain investors in the Funds differing from the
terms applicable to other clients.

Charging asset-based fees and performance-based fees may create a potential conflict of interest
because it creates an incentive to allocate the best-performing assets into Funds and Managed
Accounts on which Complus charges performance-based fees. Also, the allocation of performance
fees at different rates, or subject to different hurdle rates (if any), may create an incentive to
disproportionately allocate time, services or functions to Funds or Managed Accounts allocating
such fees at a higher rate (or subject to a lower hurdle rate, if any), or to allocate (profitable)
investment opportunities to such accounts.

Complus recognizes the possibility of such a conflict and addresses it through its allocation policy.
In particular, Complus’ policy is to allocate investment opportunities in a fair and equitable
manner. To ensure fairness in the allocation of investment opportunities amongst its clients,
Complus considers various factors including but not limited to: the client’s investment objectives
and strategies, investment restrictions, net asset value, existing portfolio composition, risk limits,
base currency; cash availability and liquidity; tax status and other tax considerations. For example,
where an investment opportunity is suitable for two or more clients, Complus generally seeks to
allocate investment opportunities on a pro-rata basis by reference to the relative assets under
management of such clients.

Valuation of Assets
The management fees and the performance-based fees charged to clients are calculated based on
valuations ascribed to their portfolio holdings. There can be no assurance that the value assigned
to an investment at a certain time will equal the value that each portfolio is ultimately able to
realize. Complus addresses this conflict by adhering to its valuation policies by employing an
independent third party to support valuation matters, and employing an independent third-party
pricing sources to the extent practicable. Each Fund has also appointed a third party fund
administrator to value its portfolio, as further set out below.

Complus Asset Management (Singapore) Pte. Ltd. – Form ADV, Part 2A Brochure

Fee Waivers
Complus may, in its sole discretion, waive all or part of any fees or expenses payable by or
attributable to clients.

Expenses and other Fees
Clients (such as the Funds and Managed Accounts) generally bear certain expenses. Such expenses
may include, but are not limited to: brokerage commissions and charges; all fees and expenses of
transactional, risk, market data and trade-related services; all administrative expenses; fees and
charges of custodians and clearing agencies; income taxes, withholding taxes, and other charges
and duties of governments, agencies or regulatory bodies; fees and expenses of legal advisers,
administrators, net asset value calculation agents, accountants and independent auditors; Directors’
fees and expenses; the costs of printing and distributing any memorandum and subscription
materials and any reports and notices to investors or prospective investors. Each client also will
bear its own organizational fees and expenses. The relevant documents relating to the Funds and
Managed Accounts set out further specific details regarding the expenses which may be borne by
them.

Please see Item 12, “Brokerage Practices,” below for a discussion of certain brokerage expenses.
Complus has no affiliated broker-dealers.

Complus does not ask or require its clients to pay any fees in advance of the related advisory
services.

Sales Compensation
Complus and its supervised persons do not receive (directly or indirectly) any compensation from
the purchase or sale of securities or investments for the Funds or Managed Accounts.
Account Minimums and Types of Clients — Form ADV Part 2A (3/31/2026) [Brochure]
ITEM 7: TYPES OF CLIENTS
Complus provides investment advisory services in accordance with the requirements of client
specific investment management agreements. The Funds generally impose minimum investment
requirements, such as minimum initial investments, as further specified in their offering materials.
In addition, investors in the vehicles that are offered to U.S. persons are generally subject to certain
qualification standards, including status as “accredited investors” as defined in Rule 501(a) of
Regulation D under the Securities Act of 1933 and, at least in certain cases, as “qualified
purchasers” as defined in Section 2(a)(51)(A) of the Investment Company Act.

Complus Asset Management (Singapore) Pte. Ltd. – Form ADV, Part 2A Brochure
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 6 3.1
(g) Pension and profit sharing plans 0 0.0
(h) Charitable organizations 0 0.0
(i) State or municipal government entities 0 2.8
(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 8 5.9
By Discretionary
Discretionary 8 5.9
Non-Discretionary 0 0.0
Total 8 5.9
By Non-United States Persons
Non-United States Persons 5.0
United States Persons 0.9
Total 8 5.9
Firm Profile (Form ADV)
Discretionary AUM$3.2B
ServesInstitutional
Fund TypesHedge Fund
LEI5493000G0VMLPSYTSM34
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