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| Polus Capital Management Limited
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| CRD # | 139138 |
| SEC # | 801-66019 |
| CIK # | 0001890538 |
| AUM | 5,319.4 M (2026-03-31) |
| Employees | 85 (42% Investors, 1% Brokers) |
| Fees | |
| Minimum | |
| Phone | 442072594800 |
| Address | Asticus Building, 21 Palmer Street London, United Kingdom |
| Source | [IAPD] [EDGAR] [Website] [LinkedIn] |
| Total AUM ($B) |
|---|
| Fees and Compensation — Form ADV Part 2A (3/31/2026) [Brochure] |
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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] |
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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) |
|---|
| 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 |
| Serves | Institutional |
| Fund Types | Hedge Fund |
| LEI | 549300IU1B6Z4VKE3Y87 |
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