Wellington Alternative Investments LLC (WAI) is an indirect subsidiary of Wellington Management
Group LLP (WMG), which is the parent holding company of the Wellington Management group of
companies (collectively, Wellington Management). WAI is a Delaware limited liability company that
acts as the general partner or manager of several privately-offered pooled investment vehicles exempt
from registration under the Investment Company Act of 1940 (collectively, the Funds). The Funds
pursue a range of investment strategies, including equity long / short, market neutral, quantitative
equity, macro, relative value, multi-strategy, credit long / short and private equity. WAI is registered
as a commodity pool operator (CPO) with the Commodity Futures Trading Commission (CFTC).
WAI provides discretionary investment management services directly to the Funds employing a multi-
strategy investment approach (the Multi-Strategy Funds). The Multi-Strategy Funds invest in other
Funds and accounts managed by Wellington Management affiliates. WAI manages each Multi-
Strategy Fund in accordance with the investment strategies and restrictions set forth in its limited
partnership agreement or management agreement, as applicable.
WAI also provides discretionary investment management services and non-discretionary portfolio
advisory services to other clients (Accounts) who seek to pursue an investment strategy similar to one
or more of the Multi-Strategy Funds. Accounts are often customized to meet a client’s specific
requirements. For example, WAI may recommend or select different allocations for an Account than
those of a similar Multi-Strategy Fund based on that client’s requirements or guidelines. Initial account
requirements or guidelines are generally established by agreement between WAI or an affiliate and the
Account client and are typically stated in the portfolio advisory or management agreement. From time
to time, WAI or its affiliate negotiates changes these agreements with an Account client.
WAI is the general partner or manager to the other Funds (the Single Strategy Funds). In that capacity
it sets the investment objective, guidelines and restrictions for the Single Strategy Funds. WAI has
appointed its affiliate, Wellington Management Company LLP (WMC), a Delaware limited liability
partnership and indirect subsidiary of WMG, as investment manager to provide discretionary
investment management and related services to the Single Strategy Funds. WMC is registered as an
investment adviser with the Securities and Exchange Commission (SEC) and as a commodity trading
advisor with the CFTC.
WAI may appoint other Wellington Management affiliates as investment manager to one or more
Funds in the future, including Wellington Management International Ltd, a limited company registered
in England and Wales and an indirect subsidiary of WMG, Wellington Management Hong Kong Limited,
a private limited company organized under the laws of the Hong Kong Special Administrative Region of
the People’s Republic of China and an indirect subsidiary of WMG, Wellington Management Japan Pte
Ltd, a limited liability company organized under Singapore law, and Wellington Management Singapore
Pte Ltd, a limited liability company organized under Singapore law. Details on these affiliates have
been provided in the Appendix.
As of 31 December 2018, WAI had approximately $14.6 billion in assets under management on a
discretionary basis.
Discussions of the Funds in this brochure, including but not limited to their investments, the strategies
used in managing the Funds, the fees and other costs associated with an investment in the Funds, and
conflicts of interest faced by WAI and its affiliates in connection with management of the Funds and
Accounts, are summaries intended only to provide required information on our business and practices
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to our advisory clients. These discussions are not intended for use in evaluating an investment in a
Fund. Investors and prospective investors in a Fund should read the Fund’s confidential offering
memorandum and governing documents (“offering documents”) for complete information on these
matters.
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WAI receives asset-based fees from the Multi-Strategy Funds. It also receives asset-based fees from
some Funds with regard to illiquid securities held by those Funds in side pocket accounts. WMC
receives an asset-based fee from each Single Strategy Fund.
WAI receives performance-based compensation from the Funds.
WAI also receives asset-based fees and performance-based compensation from Account clients. WAI
negotiates fees and compensation in light of a client’s special circumstances, asset levels, service
requirements or other factors. Asset-based fees for Account clients are typically calculated in arrears
based on the portfolio value. Account clients generally do not pay asset-based fees to underlying
Funds and accounts in which they maintain an investment. These clients can choose to receive an
invoice generated by WAI or they can calculate and remit fee payments directly to the firm.
See Item 6 for a description of the performance-based compensation applicable to both Funds and
Account clients.
Each Fund and account also bears the fees and expenses charged by its custodian and other service
providers, brokerage costs related to investments, and other expenses incurred in operating the Fund
or account. For more information, please see Item 12 – Brokerage Practices.
Fees and expenses are charged to and deducted from the Funds in arrears. Additional information on
each Fund’s fees and expenses is provided in the offering documents.
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WAI receives performance-based compensation from most of the Funds and Accounts. The
performance compensation typically is a percentage of the total net increase in the value of the Fund
or Account, including both realized and unrealized profits, subject to recoupment of previous losses.
Some Funds or Accounts calculate the performance allocation based on the excess return above a
specified benchmark. Other Funds calculate the performance allocation based on realized net profits
only. If earned, the performance compensation typically is paid annually (or on another agreed-upon
performance period) in arrears or, with respect to the Funds, upon a withdrawal or redemption.
WAI has an incentive to favor Funds and Accounts that pay it performance-based compensation over
Funds and other clients that either do not pay performance-based compensation or that pay
performance-based compensation at lesser rates. For all Multi-Strategy Funds and for Account clients,
WAI also has an incentive to invest in riskier or more speculative underlying Funds and accounts. WAI
manages these conflicts through internal review processes that are designed to provide for allocations
to the underlying Funds and accounts based on the investment strategy of the Funds and accounts,
and not on the fee structures.
If a Single Strategy Fund holds an investment with respect to which market quotations and/or other
independent pricing information are not readily available, WMC recommends a valuation to the Funds
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based on fair valuation methodologies. WAI faces a conflict of interest in accepting these valuations for
the Funds because these valuations affect WAI’s compensation. WAI manages this conflict through
internal review and oversight processes and policy.
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WAI provides discretionary advisory services only to investment vehicles that are private investment
funds exempt from registration under the Investment Company Act of 1940 and discretionary
Accounts. WAI also provides non-discretionary, portfolio advisory services to public funds and other
large institutions.
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WAI manages the Multi-Strategy Funds using a multi-strategy allocation approach involving both
strategic and active asset allocation decisions. Some Multi-Strategy Funds include diversified
exposure to a range of asset classes and strategies, while others are concentrated on specific asset
classes or strategies. WAI implements its investment approach by allocating the assets of each Multi-
Strategy Fund to various Funds and accounts managed by Wellington Management affiliates.
WAI also provides discretionary investment management services and non-discretionary investment
advice to Accounts that seek to pursue an investment strategy similar to one or more of the Multi-
Strategy Funds. Services to discretionary Accounts generally consist of allocating assets among
various Funds and accounts managed by Wellington Management affiliates to seek to achieve an
Account’s investment objective. Non-discretionary investment advice to portfolio advisory Accounts
generally consists of recommendations on the allocation of assets among various Funds and accounts
managed by Wellington Management affiliates to seek to achieve an Account’s investment objective.
Underlying Funds and accounts selected or recommended by WAI for a particular Account may
provide exposure to a range of asset classes and strategies or may be concentrated on specific asset
classes or strategies.
Investing in securities and other financial instruments involves risk of loss that clients should be
prepared to bear. The Multi-Strategy Funds and Accounts are subject to all of the risks associated with
each of the underlying Funds and accounts in which they invest, as well as the risk that the asset
classes or strategies do not perform as expected. Additional information on each Fund’s risks, and the
types of investments it may hold, is provided in the offering documents.
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There are no legal or disciplinary events that are material to WAI’s clients’ or prospective clients’
evaluation of WAI’s advisory business.
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The following is a list of WAI’s investment advisory affiliates:
o Wellington Management Company LLP (WMC), manages Wellington Management’s business in
the United States and Latin America and coordinates global operations.
o Wellington Management Australia Pty Ltd manages Wellington Management’s business in
Australia and New Zealand.
o Wellington Management Canada ULC manages Wellington Management’s business in Canada.
o Wellington Management Hong Kong Limited manages Wellington Management’s business in
greater China and Korea.
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o Wellington Management International Ltd manages Wellington Management’s business in
Europe, the Middle East and Africa.
o Wellington Management Japan Pte Ltd manages Wellington Management’s business in Japan.
o Wellington Management Singapore Pte Ltd manages Wellington Management’s business in
the remainder of Asia ex-Japan.
o Wellington Management Switzerland GmbH services clients in Switzerland.
In addition to WAI, the following affiliates sponsor pooled investment vehicles.
o Wellington Funds (US) LLC
o Wellington Luxembourg S.à r.l.
o Wellington Management Funds LLC
o Wellington Trust Company, NA.
Wellington Management Advisers, Inc., (WMA) a limited-scope broker/dealer registered with the US
Financial Industry Regulatory Authority (FINRA), introduces prospects to the Funds, to other
investment vehicles sponsored by Wellington Management affiliates and to certain SEC-registered
investment companies. WMA does not execute securities transactions or engage in any other
business.
For additional information on the Wellington Management group companies, please refer to the
Appendix.
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Code of Ethics / Personal Securities Trading
WAI has adopted the Wellington Management Code of Ethics, which applies to all Wellington
Management personnel worldwide. The Code describes the standard of conduct Wellington
Management requires of its personnel and sets forth certain restrictions on activities, including with
regard to personal trading and gifts and entertainment. Compliance with the Code is a condition of
employment for all personnel. A serious violation of the Code or related policies may result in
dismissal. Key provisions of the Code are summarized below. A copy of the entire document is
available upon request.
All Wellington Management personnel are considered “access persons” under the Code. They must
preclear their personal transactions in covered securities prior to execution, except as specifically
exempted under the Code. Some personal securities transactions that are not subject to pre-
clearance must nonetheless be reported, including transactions in open-end mutual funds and variable
insurance products that Wellington Management manages. The Code’s restrictions on personal
trading apply to accounts over which an access person and/ or certain immediate family members
have investment discretion, or from which they enjoy economic benefits. Portfolio managers are
subject to additional restrictions on their personal transactions.
The pre-clearance process tests proposed transactions against a number of substantive restrictions
designed to prevent Wellington Management personnel from taking advantage of the firm’s
investment activity on behalf of its clients. Wellington Management prohibits all personnel from buying
or selling securities issued by broker/dealers that are approved for execution of client trades or by
securities markets or exchanges on which Wellington Management affiliates trade on behalf of clients.
Likewise, Wellington Management does not allow its personnel to engage in personal transactions
involving the direct purchase of any security in an initial public offering. All personnel are required to
provide quarterly reports and certifications regarding their securities transactions and annual reports
regarding their securities holdings. The WMC Chief Compliance Officer (or his or her designee) may
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grant an exception from pre-clearance, other trading restrictions, and certain reporting requirements
on a case-by-case basis, if he or she determines that the proposed conduct involves no opportunity for
abuse and does not conflict with client interests.
Gifts and entertainment
The Code places restrictions on receipt of gifts, travel, and entertainment opportunities by Wellington
Management personnel. Wellington Management personnel occasionally participate in entertainment
opportunities that are for legitimate business purposes, subject to limitations set forth in the Code.
Investments by Wellington Management personnel in the Funds
Wellington Management personnel, including portfolio managers and other investment personnel,
often invest in the Funds. WAI does not limit the percentage of a Fund that Wellington Management
personnel can own. Wellington Management personnel are often the first participants in a new Fund
and in some instances will be the only participants for one or more years. However, the vast majority of
total assets in the Funds belong to unaffiliated investors. In some cases, a portfolio manager owns a
substantial portion of the interests in a Fund that he or she manages. While personnel who invest in
Funds have an incentive to favor such Funds in order to obtain a personal benefit, these investments
also help to align those individuals’ interests with those of the applicable Fund. Where Wellington
Management thinks it appropriate, it has adopted procedures to manage conflicts that arise from
Wellington Management personnel’s investment in the Funds.
By virtue of their responsibilities, Wellington Management personnel have access to information that is
not available to other participants in the Funds. WAI has adopted policies and procedures to identify
and disclose material information to all investors in the Funds and to manage conflicts that arise from
Wellington Management personnel’s investment in the Funds. Those procedures include information
barriers and restrictions on transactions in Funds by Wellington Management personnel.
Investments by WAI and its affiliates in the Funds
WAI, in its capacity as general partner, invests a minimal amount of capital in each Fund that is a
partnership.
From time to time, a WMG affiliate provides seed capital in connection with the launch of a Fund. WMG
affiliates also invest capital in one or more Funds that are designed to develop new investment
approaches and do not accept external investments.
Wellington Management offers a deferred compensation plan to some employees through which the
employees can make a notional investment in the Funds. A WMG affiliate invests in the Funds in order
to hedge the liabilities associated with the deferred compensation plan.
These investments by WAI or WMG’s affiliates are not significant (either individually or collectively) to
WAI’s or WMG’s financial position.
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Client investments in the Funds and other Accounts
WAI also recommends investments in the Funds and other accounts managed by Wellington
Management affiliates. WAI monitors these arrangements to ensure that allocation recommendations
are based solely upon an account’s investment objectives, guidelines, and risk tolerance.
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The Multi-Strategy Funds and portfolio advisory accounts invest in other Funds and accounts
managed by Wellington Management. Consequently, WAI does not directly engage brokers or
execute trades.
WAI has authorized the investment manager to select brokers and dealers to place and execute
portfolio transactions on behalf of the Single Strategy Funds. WAI receives information from the
investment manager regarding its exercise of that discretion, including its research and soft dollar
practices.
WAI selects prime brokers for the Single Strategy Funds. The services to be performed under each
prime broker agreement include the provision of leverage, margin financing, clearing, settlement,
securities lending, short selling facilities and foreign exchange facilities. Prime brokers also will
provide custody services for investments held on the books of the prime brokers in accordance with
the terms of the respective agreements and applicable law.
Additional information on each Fund’s brokerage practices is provided in the offering documents.
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WAI management and members of a risk team supporting WAI periodically review performance and
exposures for each Fund and Account, including leverage and margin, different exposure and
diversification metrics, transaction activity, and liquidity. WAI’s goal is to understand the exposures in
each Fund to confirm that the exposures are in line with WAI’s expectations.
WAI provides Fund Investors and Account clients a variety of reporting, including monthly written
reporting on performance and holdings. WAI also periodically provides commentary on current
allocations and positioning, and portfolio manager views on the economy, markets and other
investment topics. Clients may receive different levels of service from WAI and have varying access to
investment and other personnel.
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WAI does not enter into arrangements with third parties to solicit new advisory clients.
WAI utilizes the business development and marketing activities of its affiliates to solicit investors for all
Funds. In addition, WAI and some Funds have also entered into arrangements to pay third parties to
distribute interests in those Funds.
From time to time, the prime brokers to the Funds introduce potential investors for the Funds.
Introductions are made either at conferences sponsored by the prime broker or through private
meetings. Neither WAI nor the Funds pay the prime brokers fees for making these introductions.
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The assets of each Fund are maintained at qualified third-party custodians where required.
WAI generally does not maintain physical possession of the assets of any Fund. Because WAI serves as
general partner of, or holds another comparable position with respect to, the Funds, it takes additional
measures to safeguard Fund assets.
Each Fund provides audited financial statements prepared in accordance with US generally accepted
accounting principles to all investors in the Fund, typically within 90 days of the applicable fiscal year
end or as otherwise required to meet certain regulatory obligations. Investors should review these
statements carefully.
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WAI exercises investment discretion on behalf of each Multi-Strategy Fund and discretionary Accounts
in accordance with such fund’s or account’s particular investment objectives, policies and strategies
as set forth in its limited partnership agreement, management agreement, or other relevant governing
agreement, as applicable. WAI has delegated investment discretion for the Single Strategy Funds to
the investment manager, which in turn may delegate some of its portfolio management responsibilities
to another Wellington Management affiliate.
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WAI does not vote proxies directly on behalf of the Funds. It has delegated proxy voting responsibility
for the Funds to WMC.
WAI does not have authority to vote securities held in Accounts. These clients will receive proxies and
other solicitations with respect to the Funds from WAI or the Fund’s transfer agent and may reach out
to their relationship team with questions about a particular solicitation.
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Not applicable.
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Appendix:
Description of WAI’s Affiliates
WELLINGTON MANAGEMENT GROUP LLP (the Partnership), the parent company of the Wellington
Management global organization, is a Massachusetts limited liability partnership.
WELLINGTON MANAGEMENT COMPANY LLP (WMC) is a Delaware limited liability partnership and a registered
investment adviser with the US Securities and Exchange Commission (SEC). WMC is also registered with the US
Commodity Futures Trading Commission (CFTC) as a commodity trading advisor (CTA) and serves as a CTA to
certain clients including registered commodity pools and their operators. WMC provides commodity trading
advice to all other clients in reliance on exemptions from CTA registration. WMC is an indirect subsidiary of the
Partnership.
WMC serves as the investment manager for our clients in the US and Latin America and for some clients in other
regions. WMC may delegate some functions, including portfolio management, trading and/or account
administration in whole or in part to another investment advisory affiliate.
WELLINGTON MANAGEMENT AUSTRALIA PTY LTD (WM Australia) is an Australian proprietary limited
company. WM Australia is an indirect subsidiary of the Partnership and is authorized to provide investment
management services in Australia under an Australian Financial Services Licence.
WM Australia serves as the contractually named manager for certain clients in Australia and New Zealand. In
those cases, certain functions, including portfolio management, trading and/or account administration are
delegated in whole or in part to WMC or another investment advisory affiliate.
WELLINGTON MANAGEMENT CANADA ULC (WM Canada ULC) is a British Columbia unlimited liability company
which is registered in ten Canadian provinces (Alberta, British Columbia, Manitoba, New Brunswick,
Newfoundland and Labrador, Nova Scotia, Ontario, Prince Edward Island, Québec, and Saskatchewan) in the
categories of Portfolio Manager and Exempt Market Dealer. WM Canada ULC is an indirect subsidiary of the
Partnership.
WM Canada ULC provides client liaison, investment monitoring and business development services for Wellington
Management and its clients in Canada. WM Canada ULC also serves as the contractually named investment
manager for our Canadian clients. Certain functions, including portfolio management, trading and/or account
administration are delegated in whole or in part to WMC or another investment advisory affiliate.
WELLINGTON MANAGEMENT HONG KONG LIMITED (WM Hong Kong) is a private limited company organized
under the laws of the Hong Kong Special Administrative Region of the People’s Republic of China. WM Hong Kong
is an indirect subsidiary of the Partnership. WM Hong Kong is authorized to provide investment management
services in Hong Kong by the Securities and Futures Commission. WM Hong Kong is also registered with the SEC
as an investment adviser and has a representative office in Beijing, the People’s Republic of China, which is
authorized and regulated by the China Securities Regulatory Commission.
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WM Hong Kong provides client liaison, investment monitoring and business development services for Wellington
Management and its clients in Northern Asia including Hong Kong, mainland China, Taiwan and Korea. WM Hong
Kong also provides research, portfolio management and trading services for Wellington Management and its
clients.
WM Hong Kong serves as the contractually named investment manager for certain clients in Hong Kong and for
certain Sponsored Funds. In those cases, certain functions, including portfolio management, trading and/or
account administration may be delegated in whole or in part to WMC or another investment advisory affiliate.
WELLINGTON MANAGEMENT INTERNATIONAL LTD (WMIL) is a limited company registered in England and
Wales and an indirect subsidiary of the Partnership. WMIL is authorized to provide investment management
services in the UK by the Financial Conduct Authority (FCA) and is also authorized to provide similar services in
numerous other European jurisdictions. WMIL has a branch in Frankfurt, Germany, which is authorized and
regulated by the FCA and, in respect of certain of its activities, by the Bundesanstalt für
Finanzdienstleistungsaufsicht (BaFin). WMIL has a branch in Dublin, Ireland, which is authorized and regulated by
the FCA and, in respect of certain of its activities, by the Central Bank of Ireland. WMIL is also registered with the
SEC as an investment adviser.
WMIL provides client liaison, investment monitoring and business development services for Wellington
Management and its clients in Europe (ex-Switzerland), the Middle East, and Africa (EMEA). WMIL also provides
research, portfolio management and trading services to Wellington Management and its clients.
WMIL serves as the contractually named investment manager for certain EMEA clients and for certain Sponsored
Funds. In those cases, certain functions, including portfolio management, trading and/or account administration
may be delegated in whole or in part to WMC or another investment advisory affiliate.
WELLINGTON MANAGEMENT JAPAN PTE LTD (WM Japan) is a limited liability company organized under
Singapore law, with its main office in Tokyo, Japan. WM Japan is an indirect subsidiary of the Partnership. WM
Japan is authorized in Japan by the Financial Services Agency to conduct investment management, investment
advisory and agency business and investment trust management, as well as limited marketing of sponsored
funds. WM Japan is also registered with the SEC as an investment adviser.
WM Japan serves as the contractually named manager for certain clients in Japan and for certain Sponsored
Funds. In those cases, certain functions, including portfolio management, trading and/or account administration
may be delegated in whole or in part to WMC or another investment advisory affiliate.
WELLINGTON MANAGEMENT SINGAPORE PTE LTD (WM Singapore) is a limited liability company organized
under Singapore law. WM Singapore is an indirect subsidiary of the Partnership. WM Singapore is regulated by the
Monetary Authority of Singapore under a Capital Markets Services Licence to conduct fund management
activities and is an exempt financial adviser. WM Singapore is also registered with the SEC as an investment
adviser. WM Singapore provides client liaison, investment monitoring and business development services for
Wellington Management and its clients in the Asia-Pacific region ex-Japan. WM Singapore also provides research
and portfolio management services to Wellington Management and its clients.
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WM Singapore serves as the contractually named manager for certain clients in Singapore and for certain
Sponsored Funds. In those cases, certain functions, including portfolio management, trading and/or account
administration may be delegated in whole or in part to WMC or another investment advisory affiliate.
WELLINGTON MANAGEMENT SWITZERLAND GMBH is a limited liability company incorporated under Swiss law
and an indirect subsidiary of the Partnership. It provides client liaison and business development services for
Wellington Management and its clients in Switzerland and is authorized under Swiss law as a distributor of
collective investment schemes.
WELLINGTON ALTERNATIVE INVESTMENTS LLC (WAI) is a Delaware limited liability company and an indirect
subsidiary of the Partnership. WAI is registered as a commodity pool operator with the CFTC and is registered
with the SEC as an investment adviser. WAI is the general partner or manager of privately offered pooled
investment vehicles. WAI is owned by WMFH.
WELLINGTON FUNDS SERVICES LLC (WFS) is a Delaware limited liability company which provides
administrative and operational support, including trading settlement, account reconciliation and performance
reporting, to certain of our Sponsored Funds. WFS is owned by WMFH.
WELLINGTON FUNDS (US ) LLC (WFUS) is a Delaware limited liability company and an indirect subsidiary of the
Partnership. WFUS is registered with the SEC as an investment adviser. WFUS is the general partner or manager
of privately offered pooled investment vehicles. WFUS is owned by WMFH.
WELLINGTON GLOBAL ADMINISTRATOR, LTD. (WGA) is a limited liability company organized under the laws of
Bermuda and an indirect subsidiary of the Partnership. WGA serves as the distributor for certain Wellington
Management-sponsored investment funds.
WELLINGTON LUXEMBOURG SARL (Wellington Luxembourg) is a company in the form of a Société à
responsabilité limitée organized under the laws of the Grand Duchy of Luxembourg and an indirect subsidiary of
the Partnership. Wellington Luxembourg is authorized under Luxembourg law as a management company and
AIFM for mutual investment funds domiciled in Luxembourg. Several Wellington Management affiliates serve as
investment managers for certain portfolios domiciled in Luxembourg and, upon the request of Wellington
Luxembourg, may provide other general management services for those portfolios.
WELLINGTON MANAGEMENT ADVISERS, INC. (WMA) is a limited-scope broker/dealer registered with FINRA
and organized under the laws of Delaware. WMA is an indirect subsidiary of the Partnership. WMA’s sole line of
business is introducing prospects to certain SEC-registered investment companies and Wellington Management-
sponsored investment funds offered within the United States.
WELLINGTON TRUST COMPANY, NA (WTC) is a limited-purpose nationally chartered trust company and a
subsidiary of the Partnership. WTC provides a range of trust services, including asset management, asset
allocation and account custody and administration. WTC sponsors common trust funds and collective investment
funds that are exempt from registration under the US Investment Company Act of 1940, as amended. Several
Wellington Management affiliates provide investment advice on a nondiscretionary basis to WTC with respect to
client assets managed by WTC.
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WELLINGTON MANAGEMENT FUNDS LLC (WMF LLC) is a Delaware limited liability company and an indirect
subsidiary of the Partnership. WMF LLC is the manager of privately offered pooled investment vehicles. WMF LLC
is owned by WMFH.
WELLINGTON FINANCE & TREASURY LLC (WFT) is a Delaware limited liability company which serves in a cash
management function for certain of its affiliates. WFT is owned by the Partnership.
WELLINGTON GROUP HOLDINGS LLP (WGH) is a Delaware limited liability partnership which serves as the
managing partner of WIAH and WMFH. WGH is owned by the Partnership.
WELLINGTON HOLDINGS, INC. (WH, Inc.) is a corporation organized under the laws of Massachusetts. WH, Inc.
is owned by the Partnership.
WELLINGTON INVESTMENT ADVISORS HOLDINGS LLP (WIAH) is a Delaware limited liability partnership which
serves as the managing partner of WMC, the sole member of WM Canada LLC and the majority owner of WMGH.
WIAH is owned by WGH and the Partnership.
WELLINGTON MANAGEMENT CANADA LLC (WM Canada LLC) is a Delaware limited liability company. WM
Canada LLC is the sole owner of WM Canada ULC. WM Canada LLC is owned by WIAH.
WELLINGTON MANAGEMENT FUNDS HOLDINGS LLP (WMFH) is a Delaware limited liability partnership which
serves as the owner of WMA and WMF Inc., sole member of WFS, member of WMF LLC and WAI and majority
owner of WGA and Wellington Luxembourg. WMFH is owned by WGH and the Partnership.
WELLINGTON MANAGEMENT GLOBAL HOLDINGS, LTD. (WMGH) is a Bermuda limited company. WMGH
serves as a holding company for operating entities organized in Australia, Hong Kong, Singapore, Switzerland and
the United Kingdom. WMGH is owned by WIAH and WH, Inc.
WELLINGTON MANAGEMENT INVESTMENT, INC. (WMII) is a corporation organized under the laws of
Delaware. WMII serves as the manager of WAI and WFT and holds common shares of WGA. WMII is owned by the
Partnership.
WELLINGTON MANAGEMENT FUNDS INC. (WMF Inc.) is a corporation organized under the laws of Delaware.
WMF Inc. serves as the manager of WMF LLC and WFUS. WMF Inc. is owned by WMFH.
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