Our Firm Aberdeen Standard Investments Inc. (“ASI Inc.”) is headquartered in Philadelphia, Pennsylvania, and is a wholly-owned subsidiary of Aberdeen Asset Management PLC (“Aberdeen PLC”). As of August 14, 2017, further to the merger with Standard Life plc (the “Merger”), Aberdeen PLC is a wholly owned subsidiary of Standard Life Aberdeen plc (“SLA”), which acts as parent to existing Aberdeen and Standard Life business units. The asset management business of SLA operates under the name Aberdeen Standard Investments (“ASI”). This document has been updated to reflect the current integration status of the legacy advisory businesses.

In addition to ASI Inc., Aberdeen Standard Investments (Asia) Ltd., Aberdeen Standard Investments Management Australia Ltd., and Aberdeen Asset Managers Ltd. are all wholly owned subsidiaries of Aberdeen PLC. Aberdeen Capital Management LLC and Aberdeen Standard Investments ETFs Advisors LLC are wholly owned subsidiaries of ASI Inc. Standard Life Investments (Corporate Funds) Limited and SL Capital Partners LLP, both based in Edinburgh, Scotland, are also subsidiaries of SLA. ASI Inc., Aberdeen Standard Investments (Asia) Ltd., Aberdeen Standard Investments Management Australia Ltd., Aberdeen Asset Managers Ltd., Aberdeen Capital Management LLC and Aberdeen Standard Investments ETFs Advisors LLC , Standard Life Investments (Corporate Funds) Limited, and SL Capital Partners LLP (collectively, “ASI” or “the Advisers”) are registered as investment advisers with the Securities and Exchange Commission (the "SEC"). In rendering investment advisory services, the Advisers may share resources, including personnel and facilities, and research information. The Advisers may also use the resources of other SLA subsidiaries. The Advisers have entered into a Memorandum of Understanding (“MOU”), and have elected to appoint as associated persons certain individuals who are employed by affiliated offshore unregistered advisers. These individuals render portfolio management, research and trading services to the Advisers' clients.

ASI Inc. has been registered with the SEC as an investment adviser since 1995 and has offices in: Philadelphia, PA; New York, NY; Stamford, CT; Boston, MA; and Toronto, Ontario.

Advisory Services ASI Inc. provides its clients with discretionary and non-discretionary asset management and related services across a broad range of investment strategies and asset classes. Our business is predominantly the active management of financial assets, using first-hand research to make our investment decisions. Active investment spans equities, fixed income securities, and property. ASI Inc. also offers an alternative platform which encompasses multi-manager research, selection and portfolio management for hedge funds strategies (“Hedge Funds” or “Alternative Investment Strategies”). ASI Inc.’s subsidiary, Aberdeen Capital Management LLC, offers multi-manager research, selection and portfolio management for private equity and debt, venture capital, real asset investments, direct investments in infrastructure projects, and an Asset Manager Minority Investments strategy (“AMMI”), a direct private equity strategy with a focus on acquiring minority equity interests in alternative asset managers. ASI Inc.’s subsidiary, Aberdeen Standard Investments ETFs Advisors LLC , is a specialist commodity exchange traded product provider, offering commodity ETFs.

We may also serve as a manager of managers, in which circumstance we hire sub-advisers to provide day-to- day securities selection. We are responsible for selecting sub-advisers and determining the portion of a fund’s assets to be allocated to each sub-adviser. Additionally, we have a solutions business that can blend our abilities across different asset classes to provide tailored investment outcomes to meet specific client needs. This can incorporate skills in both quantitative equities and alternatives. See Item 8 (Methods of Analysis, Investment Strategies and Risk of Loss) for additional information regarding our advisory services. Our investment expertise is delivered through both segregated and pooled products – allowing us to serve a range of clients from institutions to private investors. We offer investment advisory services with regard to investments in both domestic and global securities to a variety of clients, insurance products, and pooled funds, including investment companies registered under the Investment Company Act of 1940, as amended (“1940 Act”). We provide a variety of asset management capabilities, including:
• managing or sub-advising various open-end or closed-end investment companies registered under 1940 Act;
• offering professional money management services for separately managed accounts, which include providing continuous advice to clients based on individual needs concerning the investment of funds and related activities including, but not limited to trading, cash management, and recordkeeping;
• providing investment services to international open-end and closed-end funds, collective investment trusts, and various private or institutional mandates sourced globally;
• offering investment services to certain limited partnerships and similar private funds;
• offering segregated and pooled vehicles focusing on European, or other global property mandates;
• offering global and regional fund of funds products (hedge fund, private equity, venture capital, real assets and property); and
• customizing solutions for clients, including but not limited to those seeking specific exposure or risk/return characteristics within their alternative investment allocations.

Tailoring Services to Client Needs We typically manage client accounts on a discretionary basis; however, we will manage client accounts on a non-discretionary basis subject to client instruction.

We make investments for clients in accordance with mutually agreed upon written investment guidelines and provide continuous supervision of client portfolios. Investment services may be tailored for each client’s specific needs and objectives, and clients may impose reasonable restrictions on investing in certain securities or types of securities. We have established procedures and controls to help ensure compliance with each client’s specific investment guidelines and any client-imposed restrictions.

Where we are the investment adviser to a pooled investment vehicle, investment objectives, guidelines and any investment restrictions are not typically tailored to the needs of individual investors in those vehicles, but rather are described in the prospectus or other relevant offering document for the vehicle. We create and maintain files supporting the rationales for these recommendations. The advisory or sub-advisory fee is subject to negotiation and is fully disclosed to clients. Upon request, clients may also receive investment advice on a more limited basis through advisory or consulting-like services, including advice on isolated areas of concern such as special projects or a specific topic. Clients wishing to engage ASI for consulting services will be required to enter into a written agreement and may be subject to certain fees and conditions.

We may, directly or indirectly, and without notice to other investors, enter into “side letter” agreements with certain prospective or existing investors (including investors affiliated with ASI) granting them, among other things, greater portfolio transparency, fee waivers or reductions, future capacity rights in a fund, interests or shares having different voting rights or restrictions, reduced minimum subscription amounts, additional rights to reports and other information and other more favorable terms than the terms that are described in the relevant offering memorandum. The funds that enter into these arrangements have no obligation to offer such differing or additional rights, terms or conditions to all interest holders, and ASI may or may not offer similar differing or additional rights, terms or conditions to other clients in customized discretionary accounts it manages or to non-discretionary accounts to which it provides investment advice. In rare instances where ASI is provided with enhanced portfolio disclosure (including potentially material non- public information concerning the portfolio holdings of an underlying fund pursuant to a confidentiality agreement with the underlying fund or its manager), ASI will not be able to share information concerning such holdings or information or the fact of the existence of such a confidentiality agreement with advisory clients unless specifically authorized to do so by the underlying fund or its manager. The relevant markets, risks, strategy, benchmarks, fees, expenses and other investment details will be detailed in the offering memorandum of the vehicle. Model Delivery/UMA ASI Inc. may provide non-discretionary investment advice whereby ASI Inc. provides investment recommendations in the form of a model portfolio to a sponsor or overlay manager which then utilizes all or part of the model in managing its clients’ accounts. Model delivery programs are often referred to as a Unified Managed Accounts (“UMAs”). In such programs, the sponsor typically charges the client a comprehensive fee, inclusive of the advisory fee charged by ASI Inc. together with the fee for all other services being provided by the sponsor. The sponsor generally executes client portfolio transactions on behalf of ASI and provides custodial services for the client’s assets. Except for execution charges for certain transactions executed away from the sponsor, clients pay a single, all-inclusive (or “wrap”) fee charged by the sponsor based on the value of the client’s account assets for asset management, trade execution, custody, performance monitoring and reporting through the sponsor. The wrap fee often, but not always, includes the advisory fees charged by ASI Inc. and other participating managers through the program. The Sponsor typically assists the client in defining the client’s investment objectives based on information provided by the client, aids in the selection of one or more investment managers to manage the client’s account, and periodically contacts the client to ascertain whether there have been any changes in the client’s financial circumstances or objectives that warrant a change in the management of the client’s assets. In certain Wrap Programs, the Sponsor contracts with other investment advisers to perform these services. In a Wrap Program, the Sponsor pays the investment advisers, such as ASI Inc., a fee based on the assets of clients invested in the applicable strategy in the Wrap Program. In certain cases, ASI Inc. may instead be paid fees based on the size of the total Wrap Program assets under management. ASI Inc. may retain a portion of the wrap program fee when it participates as manager in wrap program arrangements.

Wrap fee accounts and other client accounts following a strategy with the same name managed by the same portfolio management team may be managed differently. For example, the Sponsor may impose investment restrictions or administrative requirements upon us in managing accounts that could cause those accounts to be managed differently from other client accounts in the same strategy managed by the same portfolio management team that were not subject to those restrictions or requirements. For example, if a Wrap Fee Program sponsor or client imposes investment restrictions on an account which prohibits investment in a security that is held in the selected strategy, the security may not be replaced with a comparable security and the client’s account may be overweight other positions or hold a larger cash position than other clients in that strategy.

Please also see the “Fees and Compensation” and “Brokerage Practices” items of this Brochure for more information on differences between wrap program arrangements and other types of client accounts. Assets under Management As of December 31, 2018, ASI Inc. had approximately $29.1 billion in assets under management (AUM) on a discretionary basis, and approximately $10.3 billion in assets under advisement on a non-discretionary basis, and total assets under management/advisement of approximately $39.4 billion. please register to get more info

Open Brochure from SEC website

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