Item 5 – Fees and Compensation
Sands Capital earns investment management fees for separately managed accounts based upon
standard fee schedules shown below. We negotiate these fees individually with clients, and not
all clients pay the fee listed in the schedules below. The standard fee for investment management
services varies based on the investment strategy being employed, a particular client’s profile, or as
otherwise negotiated with the client or its intermediaries. These differences depend on various
factors including but not limited to, the type of client, the client’s asset levels, the existence of an
intermediary relationship, a pre-existing relationship, the amount of servicing required for the
client’s account, and the inception date of an account, among other things. Fees are typically billed
quarterly, in advance or arrears, and are calculated as a percentage of the account’s assets under
management. In some cases, a performance-based fee is received. Clients with performance-
based fees are likely to pay higher fees than those listed in the standard investment management
fee schedule below during certain time periods. Please see Item 6 – Performance-Based Fees and
Side-By-Side Management for additional information on performance-based fee arrangements.
Our standard investment management fee schedules are as follows:
Select Growth
Assets Under Management Annual Percentage
First $50 million 0.75%
All over $50 million 0.50%
Select Growth (Wealth Management)
Assets Under Management Annual Percentage
First $10 million 1.00%
Next $40 million 0.75%
All over $50 million 0.50%
Global Growth
Assets Under Management Annual Percentage
First $50 million 0.85%
Next $200 million 0.65%
All over $250 million 0.55%
Global Leaders
Assets Under Management Annual Percentage
First $250 million 0.65%
All over $250 million 0.55%
International Growth
Assets Under Management Annual Percentage
First $50 million 0.85%
Next $200 million 0.65%
All over $250 million 0.55%
International Leaders
Assets Under Management Annual Percentage
First $250 million 0.65%
All over $250 million 0.55%
Emerging Markets Growth
Assets Under Management Annual Percentage
First $50 million 0.85%
Next $200 million 0.65%
All over $250 million 0.55%
Emerging Markets ex China
Assets Under Management Annual Percentage
First $50 million 0.85%
Next $200 million 0.65%
All over $250 million 0.55%
Technology Innovators
Assets Under Management Annual Percentage
All assets 0.85%
Global AI Innovators
Assets Under Management Annual Percentage
All assets 0.65%
Global Shariah
Assets Under Management Annual Percentage
First $50 million 0.85%
Next $200 million 0.65%
All over $250 million 0.55%
Focus Strategies
Assets Under Management Annual Percentage
All assets 0.85%
The investment management fee schedules for client-tailored strategies are not standard and are
negotiated on a case-by-case basis.
Unless otherwise negotiated, we calculate investment management fees based upon the valuation
of an account’s assets as of the last business day of each calendar quarter, generally without taking
into consideration deposits or withdrawals during the quarter, as valued by our portfolio
management system. The valuation on which fees are based may differ from the value reported
by a client’s custodian. Please refer to “Valuation Risk”, “Private Company Risks” and
“Valuation” under Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss for
additional risks associated with the valuation. Any unearned, prepaid fees will be returned upon
termination of investment management services to a client billed in advance. If a client terminates
within five business days after signing a contract, Sands Capital will fully refund all prepaid fees.
Similar client accounts have different fee schedules based on the historical nature of the accounts
or through negotiation with the client. Fee arrangements include performance-based fees. From
time to time, and under agreed-upon specific situations, we have in the past and may in the future
waive, reduce, and/or rebate all or a portion of a client’s management fee on a case-by-case basis
for any period of time. For fee calculation purposes, Sands Capital has agreed to aggregate the
assets of related accounts that are being managed for the same client or in connection with a
common third-party relationship. In such circumstances, the aggregated accounts will receive the
benefit of a lower effective fee due to the total amount of assets being managed. Any such
negotiated fee arrangement is done at the sole discretion of Sands Capital and is entered into
generally without notice to, or consent from, any other client.
Sands Capital has relationships with various financial intermediaries, and, in some cases, the fees
assessed against the underlying clients are based on a fee schedule applicable to the relevant
intermediary. Such fee schedule may or may not aggregate underlying client assets, depending on
the type of relationship with the intermediary and other factors.
If authorized, we will deduct our management fee directly from a client’s account, but only if such
account is held with a “qualified custodian” as defined under the Advisers Act. A statement will
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