Sparx Asia Investment Advisors Limited

Item 5 – Fees and Compensation
Fees paid by the Funds generally consists of management fee based on a percentage of assets
under management, which is 0.35% - 1% per annum (“Management Fees”). Management Fees are
either paid to SAIA directly or through SACM, which reimburses SAIA at cost. Management Fees
are generally payable monthly or semi-annually in arrears.

In addition to Management Fees, expenses such as custody, administration, legal, accounting,
professional, and other incidental fees and expenses are payable by the Funds. The fees and
expenses payable by each Fund are described in Fund’s offering documents. Employees of the
Company and its affiliates who invest in the Funds may be entitled to rebates on Management
and/or Performance Fees.

For a complete description of fees and expenses, please refer to each Fund’s prospectus or
private placement memorandum or Investment Management Agreement which can be
provided upon request.

Form ADV Part 2A Brochure | SPARX Asia Investment Advisors Limited                       Dec 2025

Item 6 – Types of Clients
SAIA provides investment management services to non-U.S. domiciled pooled investment
vehicles. The Funds are not required to register under the Investment Company Act of 1940, as
amended, or register their securities under the Securities Act of 1933, as amended, pursuant to
various exceptions and exemptions thereunder.

Please refer to each Fund’s prospectus or private placement memorandum or investment
management agreement for the minimum investment amount. Minimum investment amount may
be waived at the sole discretion of the Company.

Details concerning applicable investor suitability criteria are set forth in each Fund’s private
placement memorandum and subscription materials. Each Fund investor is required to meet
certain suitability qualifications, such as being a “qualified purchaser” as defined in the
Investment Company Act or being a non-U.S. person as defined in Regulation S under the
Securities Act.

Item 7 – Methods of Analysis, Investment Strategies and Risk of Loss