Polus Capital Management Limited

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Polus Capital Management Limited
CRD #139138
SEC #801-66019
CIK #0001890538
AUM 5,319.4 M (2026-03-31)
Employees 85 (42% Investors, 1% Brokers)
Fees
Minimum
Phone442072594800
AddressAsticus Building, 21 Palmer Street
London, United Kingdom
Source [IAPD] [EDGAR] [Website] [LinkedIn]
Total AUM ($B)
40322416802006201320202027
Fees and Compensation — Form ADV Part 2A (3/31/2026) [Brochure]
Item 5. Fees and Compensation

Advisory Fees and Compensation

Prospective investors may be provided with full information about fees and the Firm’s compensation
on request. While each Private Fund has a fee schedule as set out in its governing documents,
fees are negotiable. The fees charged by Polus vary from Client to Client, are negotiable and are
determined by reference to a number of factors including seeding a Private Fund, the expected
size of investment and the expected period of investment.

Payment of Fees

In accordance with the governing documents, the Firm’s fees and Private Fund expenses are
deducted from client assets. The advisory fees charged to Private Funds (and certain other
segregated mandate Clients required to be reported under Part 1A) generally include two elements,
a base fee which is typically paid monthly or quarterly by reference to the value of the assets under
management and a performance or incentive fee or carried interest which represents a percentage
of any excess returns achieved over prescribed hurdle levels. A performance fee may be paid
annually and an incentive fee or carried interest may be payable at conclusion of the discretionary
mandate. For certain Private Funds, fees are invoiced on a monthly or quarterly basis in arrear,
based on the net asset value at the end of each month or quarter, as the case may be. For CLOs,
the management fees will be accrued and paid on the interest payment dates of the relevant CLO,
in arrear based on fees outlined in each Client’s governing documents. The payments are made
by the Trustee as part of the interest payment date waterfall payments.

Other Fees and Expenses

In addition to the payment of advisory fees, Clients may pay other fees and expenses reasonably
attributable to its establishment and operation. This includes but is not limited to trading and
execution costs, research fees, custodian fees, prime brokerage fees, fees of the administrator,
directors’ fees, asset pricing or rating services fees, software provider fees, programming and data
entry services fees directly related to the management of a portfolio, taxes, regulatory and
governmental charges, costs and expenses in connection with compliance with any applicable risk
retention regime, legal expenses and out of pocket expenses incurred by the Directors or the Firm
in connection with the business of the Private Funds and regulatory fees, including Form PF, Form
D, Form 13F and Form 13H. Investors should refer to the Private Fund offering documents for a
full description of fees and expenses. Full details of actual fees and expenses incurred are also
included in the Private Funds’ audited financial statements, which are distributed to all investors
annually. See Item 9 below for a discussion of Polus’s brokerage practices.

Prepayment of Fees

Polus does not require its Clients to pay fees in advance.

No Compensation for Sale of Securities or Other Investment Products

Polus does not accept direct compensation for the sale of securities or other investment products.

One of the supervised persons of Polus, Mr. Randy S. Griffith Jr. (CRD #: 7429122) is entitled to
receive compensation from the Adviser or PCMUS for his responsibilities described in more detail
in, and in accordance with the agreements between Polus, PCMUS and Foreside Fund Services,
LLC (“Foreside”). Mr. Griffith is employed by PCMUS but he is fully seconded to Polus, and his role
and responsibilities are provided only to Polus. Therefore, he is a supervised person of Polus.
Such fees are generally determined by reference to various factors including Polus’ relative role in
sourcing the business or introduction or participating in the execution of the mandate and will be
established on an arm’s length basis and described in more detail in agreements between the
Adviser and PCMUS. Mr. Griffith is a registered representative of Foreside, a registered broker-
dealer with the SEC in the U.S. The broker-dealer is not a current Client of, or investor in a Private
Fund advised by Polus. Polus does not use the subject broker-dealer to effect trades or investments
for the Clients. Please see “Item 10: Other Financial Industry Activities and Affiliations” and “Item
Account Minimums and Types of Clients — Form ADV Part 2A (3/31/2026) [Brochure]
Item 7. Types of Clients

Polus provides investment advice to segregated mandates and Private Funds, as described above
in Item 4. Investors in the Private Funds and segregated mandate accounts are limited to
institutional investors, such as pension plans, insurance companies or endowments. All CLOs are
and, in the future, will be Qualified Purchasers within the meaning of the Investment Company Act
of 1940.

Polus requires a minimum of U.S.$15,000,000 from a segregated mandate account to build or
pursue a relationship, and a minimum of U.S.$1,000,000 of subscription into a Private Fund.

Investors in the CLOs should refer to the applicable CLO’s governing documents and subscription
materials for information on minimum investment requirements and investor suitability criteria.
Information on minimum investment requirements for the CLOs is described, as appropriate, in the
Form ADV Part 1A.
Sector Form 13F Holdings Value ($M)
Diebold Inc 3.6
 
 
 
 
 
 
 
 
 
 
Holdings by Sector ($M)
80064048032016002021202220232025
Type Form D Funds Date Sold AUM
SA Cairn CLO Xi Designated Activity Company 2026-03-31 60.2 M
SA Cairn CLO XX Designated Activity Company 2026-03-31 79.1 M
Other Polus Investment Funds ICAV - Polus Loan Investments III 2026-03-31 498.8 M
HF Bybrook Capital Hazelton Master Fund 2025-03-31 612.7 M
Other Polus Investment Funds ICAV - Fosse Fund 2024-03-28
Other Polus Special Situations Fund SCSP [2024-03-28] 856.0 M 1,236.6 M
Filed 2025-10-03 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $10,000,000 · Remaining Indefinite · Duration More than one year · Revenue Decline to Disclose
Other Westonbirt Fund LP [2024-03-28] 200.0 M 240.1 M
Filed 2025-04-15 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
HF Bybrook Capital Badminton 405 Fund LP 2021-01-07 146.0 M
Other Cairn Capital Investment Opportunities ICAV - Cairn Pathfinder Fund III 2019-04-02
Other Cairn Global Funds PLC - Cairn Strata Secured Finance Fund [2019-04-02] 78.2 M 56.0 M
Filed 2019-12-19 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $100,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
View All
AUM Breakdown Accounts AUM ($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 15 5.3
(g) Pension and profit sharing plans 0 0.0
(h) Charitable organizations 0 0.0
(i) State or municipal government entities 1 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 0.0
(n) Other 0 0.0
Total 17 5.3
By Discretionary
Discretionary 15 5.3
Non-Discretionary 2 0.0
Total 17 5.3
By Non-United States Persons
Non-United States Persons 5.3
United States Persons 0.0
Total 17 5.3
Form D Directors Role # Filings # Firms 2011 - 2026
Brian Burkholder Director 71 22
Taavi Davies Director 59 16
Richard Boleat Director 45 10
Carne Global Fund Managers Luxembourg Sa Director 18 6
Paul Sullivan Director 21 5
Eric Bertrand Director 13 3
Paul Campbell Director 15 2
Polus Capital Management Limited Promoter 7 2
Bybrook Capital Llp Promoter 5 2
Cairn Capital Limited Promoter 5 2
View All
EDGAR Form CIK 2011 - 2026
13F-HR [0001890538]
SC 13G [0001890538]
Form 13D/13G Filer Form 13D/13G Subject Filed
Polus Capital Management Ltd Algoma Steel Group Inc [2023-01-12]
Polus Capital Management Ltd Seadrill Ltd [2023-01-09]
Firm Profile (Form ADV)
Discretionary AUM$3.0B
ServesInstitutional
Fund TypesHedge Fund
LEI549300IU1B6Z4VKE3Y87
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