Voloridge Investment Management, LLC, a Florida limited liability company, (the “Company”, the “�irm”,
“we”, “us” or “our”) is a quantitative investment manager founded by David Vogel in 2009. The �irm is
registered as an investment adviser with the United States Securities and Exchange Commission (“SEC”).
The Company is controlled by the following persons:
Name Title CRD# David S. Vogel Manager, CEO and Chief Scientist 5750880
Barry S. Miller Manager and President 2729056
Sean M. Hayes Manager and VP of Business Development 5866555
Our mission is to deliver superior risk-adjusted returns driven by an entrepreneurial environment that
inspires unyielding passion, imagination and commitment to excellence. Our proprietary investment
strategies are designed to calculate risk and probability with the overall objective of preserving assets
while delivering appreciation regardless of the performance of broad �inancial markets.
In January 2020, the �irm launched its third multi strategy program, VSF complex, that allocates capital to
strategies developed and managed by the �irm. Similarly to the existing programs, this master-feeder fund
complex has two feeder funds: VSF, LP, a Delaware limited partnership, and VSF, Ltd a Cayman Islands
exempted company. VSF, LP and VSF, Ltd will contribute all of their investible assets to VSF Master, LP
(“Intermediate Fund”), a Cayman Islands exempted limited partnership. The Intermediate Fund will invest
all of its investible assets to Voloridge ESG Fund Master, LP (“ESG Master”), a Cayman Islands exempted
limited partnership and Voloridge CC Fund Master, LP (“CC Master”), a Cayman Islands exempted limited
partnership, in the aggregate. Initially, this program will allocate capital to four strategies including a
customized ESG version of our intermediate-term US equity market neutral strategy through ESG Master
and three climate change strategies through CC Master. The standard version of the intermediate-term US
equity market neutral strategy has been used by VF Master, which is the master fund of the Voloridge Fund
complex. Additional strategies are intended to be added over time. Investors will be able to invest in VSF,
LP and VSF, Ltd.
The �irm has two existing multi strategy programs, VF complex and VTAF complex, that allocates capital to
strategies developed and managed by the �irm. Each master-feeder fund complex has two feeder funds.
Investors may invest in the feeder funds, which will in turn invest directly into their master funds,
respectively. The VF complex’s feeder funds: Voloridge Fund, LP (“VF, LP”), a Delaware limited
partnership, and Voloridge Fund, Ltd. (“VF, Ltd.”), a Cayman Islands exempted company, will invest directly
into the Voloridge Fund Master, LP (“VF Master”), a Cayman Islands exempted limited partnership. The
VTAF complex’s feeder funds: Voloridge Trading Aggressive Fund, LP, (“VTAF, LP”), a Delaware limited
partnership, and Voloridge Trading Aggressive Fund, Ltd., (“VTAF, Ltd.”) a Cayman Islands exempted
company, will invest directly into the Voloridge Trading Fund Master, LP, (“VTF Master”), a Cayman Islands
exempted limited partnership. The VF complex allocates capital to an intermediate-term US equity market
neutral and a global futures strategy. The VTAF complex allocates capital to a short-term and intermediate-
term US equity market neutral and global futures strategy. The return pro�ile of the strategies is designed
PART 2A OF FORM ADV Page 5 of 17
with the goal of delivering an attractive risk/return relationship when compared to other investment
alternatives. Investors will be able to invest in VF, LP, VF, Ltd., VTAF, LP, and VTAF, Ltd.
VTAF, LP, VTAF, Ltd., VF, LP, VF, Ltd., VSF, LP, and VSF, Ltd., may be referred to individually as a Fund and
collectively as the Funds. VTF Master, VF Master, ESG Master and CC Master may be referred to individually
as the Master Fund and collectively as the Master Funds.
VTAF, LP, VF, LP, and VSF, LP are primarily suitable for US taxable investors, while VTAF, Ltd., VF, Ltd., and
VSF, Ltd. are primarily suitable for US tax exempt investors and non-US investors. The �irm also has a
proprietary fund, Voloridge Global Fund, LP, (“VGF, LP”), a Delaware limited partnership, and provides
advisory services to one separately managed account.
As of December 31, 2019, our regulatory assets under management totaled: $10.08 billion. We do not offer
non-discretionary investment management services.
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MANAGEMENT FEE AND INCENTIVE ALLOCATION/FEE The Company in its capacity as general partner of VSF, LP shall receive a management fee equal to a
percentage of the month-end net asset value of the Fund investor’s capital account, prior to the deduction
of any accrued management fee or incentive allocation and after any distributions or withdrawals made
for such month. The management fee is paid monthly in arrears by the Fund and will be calculated as
follows: (i) 1.5% per annum in the case of each capital account attributable to class A interests; and (ii) 2%
per annum in the case of each capital account attributable to class B interests. The Intermediate Fund GP
will receive an incentive allocation equal to (i) 15% of the net new pro�it in respect of each capital account
attributable to class A interest; and (ii) 20% of the net new pro�it in respect of each capital account
attributable to class B interest, as of the end of each calendar year and as of any date on which an investor
makes a withdrawal or receives a distribution from VSF, LP. The Company in its capacity as Investment
manager of the Intermediate Fund on behalf of VSF, Ltd. shall receive a management fee equal to a
percentage of the month-end net asset value of the Fund investor’s capital account, prior to the deduction
of any accrued management fee or incentive allocation and after any distributions or redemptions made
for such month. The management fee is paid monthly in arrears by the Fund and is calculated as follows:
(i) 1.5% per annum in the case of each capital account attributable to a series of class A shares; and (ii) 2%
per annum in the case of each capital account attributable to a series of class B shares. The Intermediate
Fund GP will receive an incentive allocation equal to (i) 15% of the net new pro�it in respect of the each
capital account attributable to class A shares; and (ii) 20% of the net new pro�it in respect of each capital
account attributable to class B shares, as of the end of each calendar year and as of any date on which an
investor redeems shares or receives a distribution from VSF, Ltd. subject to limitations as set forth in the
Administrative Services Agreement.
The Company in its capacity as general partner of VF, LP shall receive a management fee of 2% per annum
of the month-end net asset value of the Fund investor’s capital account, prior to the deduction of any
accrued management fee or incentive allocation and after any distributions or withdrawals made for such
month. The management fee is paid monthly in arrears by the Fund. The Master Fund GP will receive an
incentive allocation equal to 20% of the net new pro�it in respect of each capital account as of the end of
PART 2A OF FORM ADV Page 6 of 17
each calendar year and as of any date on which an investor makes a withdrawal or receives a distribution
from VF, LP. The Company in its capacity as Investment manager of VF Master on behalf of VF, Ltd. shall
receive a management fee of 2% per annum of the month-end net asset value of the Fund investor’s capital
account, prior to the deduction of any accrued management fee or incentive allocation and after any
distributions or redemptions made for such month. The management fee is paid monthly in arrears by the
Fund. The Master Fund GP will receive an incentive allocation equal to 20% of the net new pro�it in respect
of each capital account as of the end of each calendar year and as of any date on which an investor redeems
shares or receives a distribution from VF, Ltd. subject to limitations as set forth in the Administrative
Services Agreement.
The Company in its capacity as general partner of VTAF, LP shall receive the greater of a 1.75%
management fee or an incentive allocation equal to 35% of the net new appreciation in the capital accounts
of the Fund investor upon withdrawal and on the last day of the calendar year subject to limitations as set
forth in the LPA. The Company in its capacity as Investment manager of VTF Master on behalf of VTAF, Ltd.
shall receive the greater of a 1.75% management fee or an incentive fee equal to 35% of the net new pro�its
of each share for each calendar year and as of any date on which a Fund investor redeems shares or receives
a distribution from VTAF, Ltd. subject to limitations as set forth in the Administrative Services Agreement.
The management fee component of this structure will be paid monthly in arrears and credited against
accrued and crystalized incentive allocation/fees within each annual period.
The management fee and performance fee will be billed to the separately managed account at the end of
the calendar year as described in the investment management agreement (‘the “Investment Management
Agreement”).
The above fees for all our investment management services are exclusive of any charges imposed by the
custodial �irm, such as: (i) any Exchange/SEC fees; (ii) certain transfer taxes; (iii) service or account
charges, including, postage/handling fees, electronic fund and wire transfer fees, debit balances, margin
interest; (iv) and brokerage and execution costs associated with securities and futures held in your
account.
FUND EXPENSES The Funds will bear all costs and expenses associated with: (i) the Fund’s ongoing offering fees and
expenses including, without limitation, the legal fees and expenses incurred in connection with the
preparation and updating of the con�idential private placement memoranda (“PPM”) and securities law
and blue sky �iling fees and expenses, and other regulatory �iling fees and expenses incurred by the Funds,
the general partner and the investment manager, fees and expenses related to Form CPO-PQR, Form PF,
Form ADV and other regulatory �ilings that seek information about the Fund; accounting expenses; printing
and mailing costs; travel; and out-of-pocket expenses; (ii) direct operating costs and expenses, including,
without limitation, administrative, legal, accounting, auditing, tax form preparation, record-keeping,
compliance and consulting costs, fees and expenses; fees, costs and expenses of third-party service
providers that provide such services; insurance costs and expenses; bank service fees; travel; printing and
mailing costs; and expenses related to entering into and compliance with side letters; (iii) costs, fees and
expenses of any appraisers, accountants, tax advisors, outsourced �inancial of�icers or other experts
engaged by the general partner or the investment manager; (iv) fees and taxes imposed by any Federal,
state, local or foreign government, governmental agency or regulatory body or self-regulatory
PART 2A OF FORM ADV Page 7 of 17
organization, including licensing, �iling, registration and exemption fees and withholding, transfer and
franchise taxes; (v) costs, fees and expenses associated with reporting and providing information and
reports to existing and prospective investors; (vi) meeting expenses for any meeting of investors; (vii) the
Fund’s indemni�ication obligations and any costs, fees and expenses of any litigation, government inquiry,
investigation or proceeding involving the Fund’s activities, including the amount of any judgments,
settlements or �ines paid in connection therewith, except, however, to the extent such expenses or amounts
have been determined to be excluded from the indemni�ication provided for in the limited partnership
agreements (“LPA”), the Intermediate Fund partnership agreement, each Master Fund’s partnership
agreement, the Intermediate Fund investment management agreement, the Master Fund investment
management agreements, the administrative services agreement or any management or services
agreement entered into with the investment manager or its af�iliates; (viii) expenses of winding up and
liquidating the Funds; and (ix) extraordinary costs and expenses, if any. The Fund is also subject to
management fees, research expenses, if applicable and an incentive allocation, when applicable.
In addition, as an investor in the Master Funds and Master Funds through the Intermediate Fund, the Funds
bears its allocable share of the costs and expenses of the Intermediate Fund and each Master Fund. As such
certain research and brokerage expenses such as software, research through Bloomberg terminals,
software services, tools and functionality to assist with the Company’s data mining and predictive modeling
and software used in connection with the Company’s portfolio composition, and trade processing and
similar products or services, which are otherwise eligible to be purchased with soft dollars may be paid for
by the Master Funds if the vendor of such services is unwilling or unable to accept soft dollars as payment
for such research and brokerage expenses or computer services.
The Funds will bear their pro rata share of certain fees and expenses payable to third-party contractors
related to the research and development of such investment and/or trading strategies including, without
limitation, bonuses, research and development fees, licensing fees and performance-based compensation
paid or reimbursed to independent third party contractors engaged by the investment manager to provide
alpha signals and investment and/or trading strategies to which all or a portion of the capital of the Master
Fund or Intermediate Fund through one or both of the Master Funds is directly allocated to (collectively,
“Research Expenses”). The Funds will bear Research Expenses up to an amount equal to 2% of the Funds’
NAV (the “Research Expense Cap”). Any Research Expenses incurred by the Fund more than the Research
Expense Cap will be borne by the investment manager or an af�iliate.
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The �irm receives a management fee and a performance allocation/fee from the Funds and the separately
managed accounts as discussed in Item 5, “Fees & Compensation.”
TERMINATION OF PERFORMANCE-BASED INVESTMENT MANAGEMENT SERVICES The Fund investor may withdraw all or any part of the balance of its capital account as of the �irst day of
any calendar month, giving at least a 30-day written notice for the VF and VTAF complex and 90-day
written notice for the VSF complex, to the Company (in its capacity as either general partner or manager
PART 2A OF FORM ADV Page 8 of 17
of a Fund) and the administrator. The Company may require a Fund investor to withdraw all or any portion
of its capital account as of month end, giving at least a 5-day written notice.
The Company or the separately managed account may terminate the investment management agreement
at any time, provided such written noti�ication is received at least 30 days prior to the date of termination
(i.e.; terminate services on October 1st, a request for termination should be received in our of�ice by
September 1st). Such noti�ication must comply with the notice provision in the Investment Management
Agreement. In addition, if your separately managed account value exceeds the annual high watermark, we
will bill your account for the performance fee.
Once the termination of investment management services has been implemented, neither party has any
obligation to the other – we no longer earn an incentive allocation/fee or give investment advice and you
become responsible for making your own investment decisions.
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The Company provides investment advice to six clients, VTF Master, VF Master, ESG Master, CC Master, and
VGF, LP, and the separately managed account (“Clients”).
The Company, as the general partner of VTAF, LP, VF, LP, and VSF, LP and as the manager of VTAF, Ltd., VF,
Ltd., and VSF, Ltd. will determine if you �it the criteria to invest in our Funds, and a PPM will be provided
to you. The Company reserves the right to be selective on who can invest in our Funds based on criteria
including investor suitability, investor time horizon, prospective capital an investor may commit, and the
relationship of the investor to the �irm. The PPM discloses possible con�licts of interest and inherent risks.
You may invest in VTAF, LP, VF, LP, and/or VSF, LP if you are (i) an “accredited investor “as de�ined in Rule
501(a) of Regulation D under the U.S. Securities Act of 1933 and (ii) a “quali�ied purchaser “as de�ined in
Section 2(a)(51) of the Investment Company Act and the regulations promulgated thereunder. In addition
to being an accredited investor and a quali�ied purchaser, you must be a non-US or a US tax-exempt investor
to purchase shares in VTAF, Ltd., VF, Ltd., and/or VSF, Ltd.
If the capacity limit has been reached, the Company has broad discretion to determine whether investors
will be forced to withdraw from the Fund(s). This broad discretion includes the ability to force
withdrawals of some investors while permitting others to stay invested. Advisors, af�iliates and friends
and families; as well as strategic investors will take precedence regarding available capacity.
In addition, the Company reserves the right to be selective while choosing separately managed accounts.
The VTAF complex is currently closed to new Fund investors. In addition, the �irm is not accepting new
separately managed accounts.
This brochure is not an offer to invest in our Funds.
PART 2A OF FORM ADV Page 9 of 17
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In analyzing equities and futures contracts, we will use a combination of proprietary quantitative analysis
techniques to gather information and to guide us in our investment decisions. We conduct technical
analysis using current and historical pricing information to help us identify trends in the broader U.S.
equity and global futures markets, and in the underlying assets themselves. This may involve the use of
various technical indicators, such as moving averages and trend-lines, among many others. In addition, we
conduct quantitative analysis to understand the behavior of a security using mathematical and statistical
modeling to identify consistent patterns. Mathematical and statistical modeling helps us to ascertain
potential security price movement and risk, to ultimately help identify pro�itable opportunities.
INVESTMENT STRATEGY The Company’s investment strategies are generally based on quantitative research, quantitative analysis,
and capital market opportunities. The strategies may be internally developed or licensed or acquired from
third-party researchers and developers. Through careful analysis, the Company has created and/or may
acquire strategies from third parties that seek to identify price movements in securities and other asset
classes.
Using a range of quantitative tools and analysis, the Company seeks to identify pro�it opportunities, to
construct portfolios in a cost-ef�icient manner and to manage the overall risk of the Master Funds’ portfolio
consistent with the aim of producing superior risk-adjusted returns. The Company will implement
systematic-based trading strategies utilizing a variety of securities, futures contracts, other asset classes
and �inancial instruments.
Continued instability in the �inancial markets requires a proactive approach to investment management.
Our investment management philosophy is comprised of three basic premises:
Preserve Capital – Employ tactics to decrease potential for losses;
Liquidity – Invest in securities that are actively traded in the �inancial markets; and
Diversi�ication – Establish positions across a wide range of industries and futures markets.
The Master Funds may engage in block transactions. VF, LP and VF, Ltd may invest in new issues as de�ined
under the rules of the Financial Industry Regulatory Authority, see the PPM for further information and
risk disclosures.
MANAGING RISK Regardless of the quantitative analysis we use to guide us in the management of our Client’s accounts or
the risk protections we employ with our investment strategies, the most important thing for you to
understand is that investing in a �inancial instrument involves a signi�icant risk of loss that you should be
willing and prepared to bear; and furthermore, past performance is no guarantee that you will see equal
or better future returns on your investment. Risk factors are discussed in detail in the PPM.
PART 2A OF FORM ADV Page 10 of 17
Here are some of the risk factors related to our investment strategies that investors should take into
consideration:
General Investment Risk – You are aware that no approach to investing can guarantee pro�its or avoid
losses, and past performance is no guarantee of future results. Therefore, we cannot, and do not, guarantee
or otherwise represent that your investment objectives will be realized. You understand that investment
decisions made by us are subject to various business, market, economic, political and legal risks, that those
investment decisions will not always be pro�itable, and that your assets may experience a loss of all, a
substantial portion of, or in some cases more than, their value.
Strategy Risk – the risk that the Fund’s investment strategies and/or investment techniques may not work
as intended.
Institutional Risk – the risk that the Funds could incur losses due to: (i) the failure of counterparties to
perform their contractual commitments to the Funds (if any) or the Master Funds or (ii) the �inancial
dif�iculty of brokerage �irms, banks or other �inancial institutions that hold the assets of the Funds or the
Master Funds.
Fund Structure Risk – the special considerations and risks arising from the operation of certain provisions
of the Fund’s governing documents.
Operational Risk – the special considerations and risks arising from the day-to-day management of a
pooled investment vehicle like the Funds.
Tax Risk – the special considerations and risks arising from the operations of an investment vehicle treated
as a partnership for Federal tax purposes.
Currency Risk – Your funds will be held in US dollars and are subject to currency �luctuations as compared
to a global basket of currencies, which may adversely impact value.
Hardware and Software Risk – Our trading model relies on signi�icant hardware and software capacity,
which we may not be able to manage. No system is foolproof. Our access to execute trades is through the
internet and we may not be able to execute trades in a timely manner or at all for a signi�icant period.
Cybersecurity Risk – With the increased use of technologies such as the internet to conduct business, a
portfolio (such as the Funds and the Master Funds) is susceptible to operational, information security and
related risks. In general, cyber incidents can result from deliberate attacks or unintentional events and are
not limited to gaining unauthorized access to digital systems, and misappropriating assets or sensitive
information, corrupting data, or causing operational disruption, including the denial-of-service attacks on
websites. Cyber security failures or breaches by a third party service provider and the issuers of securities
in which the portfolio invests, have the ability to cause disruptions and impact business operations,
potentially resulting in �inancial losses, the inability to transact business, violations of applicable privacy
and other laws, regulatory �ines, penalties, reputational damage, reimbursement or other compensation
costs, and/or additional compliance costs, including the cost to prevent cyber incidents in the future.
PART 2A OF FORM ADV Page 11 of 17
Governmental Regulation – We are subject to a signi�icant amount of government regulation, particularly
with respect to securities regulation. Furthermore, compliance with certain government-imposed
regulations may prove to be very costly and time consuming and may have a material adverse effect on
performance.
Intense Competition – The market for �inancial services is highly competitive and subject to intense
competition. We will be competing against managers with more experience and greater resources.
Dependence on Key Personnel – We believe our success will depend to a signi�icant extent on the efforts
and abilities of our principals, particularly our founder, David Vogel. If he or any of those persons is unable
to perform for any reason, the likelihood of success would be reduced unless a person or persons with
similar experience and management experience could be hired.
Our strategies are highly dependent on pricing theories and valuation models that generally have not been
independently tested or otherwise reviewed (“Models”), which we use to evaluate trading opportunities.
Models employ assumptions that abstract a limited number of variables from complex �inancial markets
or instruments which they attempt to replicate. Any one or all of these assumptions, whether or not
supported by past experience, could prove over time to be incorrect. For example, Models may postulate,
or their ef�icacy may depend on assumptions regarding the existence of relationships that appear to hold
true or in fact held true in the past but that may not exist or hold true in the future. Inputs into various
Models may be composed of or derived from facts or data, the accuracy of which may not have been
independently veri�ied by us or any third party. In particular, if material factors are not incorporated into
Models, or are incorporated inaccurately, substantial losses could result, including on the basis of
theoretical Models (that later prove incorrect) that identify positions that appear to have minimal risk. The
outputs of Models may differ substantially from the reality of the markets, resulting in major losses.
Additionally, there is no assurance that we have appropriately incorporated the Models into our strategies.
Trading Cost – You will be subject to substantial fees and transaction costs due to frequent trading of our
strategy. Accordingly, you must earn substantial trading pro�its to avoid depletion of account due to such
costs.
Model Degradation Over Time – Predictive models degrade over time and must be continually monitored
and upgraded.
Inability to Execute at Favorable Prices – We employ sophisticated trading techniques to execute at
favorable prices, but there can be no assurance that these techniques are able to purchase and sell
securities at ideal prices.
Extreme Market Movements – Financial markets are very dif�icult to predict and may move rapidly in a
very short period. There is no assurance that we will be able to protect against adverse market changes.
Side Letter Risk - We may enter into side letters with some but not all of the investors in the Fund, granting
certain investors more favorable special terms than other investors.
PART 2A OF FORM ADV Page 12 of 17
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The Company is registered with the National Futures Association (“NFA”) as a commodity pool operator
(“CPO”). The Company operates the Funds and Master Funds pursuant to an exemption under Section
4.13(a)(3) of the Commodity Exchange Act.
The following management persons of our �irm are registered with the National Futures Association
Name Title Registration Registration Number David Vogel Chief Executive Officer and Chief Scientist Principal and Associated Person 0452838
Barry Miller President Principal and Associated Person 0452840
Sean Hayes Vice President of Business Development Principal and Associated Person 0470590
Todd King Vice President of Systems and Research Principal and Associated Person 0494903
Mark M. Kamp General Counsel and Chief Compliance
Officer
Principal 0499969
Jock T. Jones Chief Operating Officer Principal and Associated Person 0499940
David Vogel has been asked to serve as a member of the CFTC’s Market Risk Advisory Committee - Climate-
Related Market Risk Subcommittee. In addition, of�icers, directors and employees of the investment
manager, the brokers and their respective af�iliates from time to time may serve on various committees
and boards of the CFTC, United States futures exchanges and the NFA and assist in making rules and
policies of the CFTC, exchanges and the NFA. In such capacity they have a �iduciary duty to the CFTC, the
exchanges on which they serve and the NFA and are required to act in the best interests of such
organizations, even if such action may be averse to the interests of the Fund and the Master Fund.
PRIVATE INVESTMENT PARTNERSHIP AFFILIATION The Company is the general partner of VTAF, LP, VF, LP, VSF, LP and VGF, LP. VSF Intermediate GP, LLC, a
Delaware limited liability company (“Intermediate Fund GP”), which is wholly owned by the Company,
serves as the general partner for the Intermediate Fund. VSF Trading GP, LLC, a Delaware limited liability
company (“VSF Master Fund GP”), which is wholly owned by the Company, is the general partner for ESG
Master and CC Master. Voloridge GP OS, LLC, a Delaware limited liability company (the “Master Fund GP”),
which is wholly owned by the Company, serves as the general partner for the VF Master and VTAF Master.
The Company acts as the investment manager to the Master Funds. The Company is also the investment
manager of VTAF, Ltd., VF, Ltd., and VSF, Ltd., pursuant to an Administrative Services Agreement. The
Intermediate Fund GP and Master Fund GP has delegated the �irm as the CPO. All investing, trading and
operating decisions are made by the Company as the investment manager of the Master Funds.
PART 2A OF FORM ADV Page 13 of 17
We are responsible for the day-to-day business operations of the master-feeder structures, as well as
management of the Master Funds’ investment portfolio and trading strategies that we deem possess the
optimal combination of return potential. The investment trading strategies of the Master Funds are
intended to achieve consistent capital growth, which is uncorrelated to the market, the S&P 500 Index, or
with other major hedge fund indices.
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TRADING CODE OF ETHICS As a �iduciary, we have an af�irmative duty to render continuous, unbiased investment advice, and always
act in your best interest. To maintain this ethical responsibility, our Code of Ethics (the “Code”) establishes
the fundamental principles of conduct and professionalism expected by all personnel in discharging their
duties. This Code is a value-laden guide committing such persons to uphold the highest ethical standards,
rooted in the most elementary maxim. Our Code is designed to deter inappropriate behavior and heighten
awareness as to what is right, fair, just, and good by promoting:
Honest and ethical conduct,
Full, fair and accurate disclosure,
Compliance with applicable rules and regulations,
Reporting of any violation of the Code; and
Accountability.
To help you understand our ethical culture and standards, how we control sensitive information and what
steps have been taken to prevent personnel from abusing their inside position, a copy of the Code is
available for review upon request.
We have a �iduciary duty to ensure that your welfare is not subordinated to any interests of ours or any of
our personnel. The following disclosures are internal guidelines we have adopted to assist us in protecting
our clients.
CLASS ACTION POLICY As a general policy, we do not elect to participate in class action lawsuits related to the securities we
purchase.
PERSONAL TRADING Our employees are permitted to personally invest their own monies in securities and futures, which may
also be, from time to time, purchased or sold in the Funds or separately managed account. To ensure our
�iduciary integrity we implemented the following guidelines:
PART 2A OF FORM ADV Page 14 of 17
No employee shall buy or sell securities for their personal portfolio(s) where their decision is
substantially derived, in whole or in part, because of his or her employment, unless the
information is also available to the investing public on reasonable inquiry.
No employee shall prefer his or her own interest over yours.
We maintain a list of all securities holdings for all our employees. Our Compliance Department
reviews these holdings on a quarterly basis.
We require that all employees act in accordance with all applicable Federal and State
regulations governing registered investment advisory practices.
Bunched orders (See “Aggregating Trade Orders” below) will not include employee accounts.
Any individual not in observance of the above is subject to termination.
Personal trading activities are monitored by our Compliance Department to ensure that such activities do
not negatively impact your account or create con�licts of interest.
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CUSTODIAL SERVICES The Company has sole discretion over the purchase and sale of investments and the broker dealer used to
effect transactions for the Master Funds. The Company will seek the best price and execution available
except to the extent it may be permitted to pay higher brokerage commissions in exchange for brokerage
and research services. The Company’s selection of a broker-dealer is based, in part, on the circumstances
of the transaction and the quality and reliability of the executing broker-dealer. We have selected Morgan
Stanley & Co., LLC (“Morgan Stanley”), and JP Morgan Securities, Inc. (“JP Morgan”), licensed broker-dealers
(members of FINRA/SIPC), to provide brokerage services. We have selected Morgan Stanley, JP Morgan
and Credit Suisse Securities (USA) LLC (“Credit Suisse”) as Futures Clearing Merchants.
These brokers were selected based on the following:
Competitive transaction charges, the speed of execution, trading platform, and on-line services for
account administration and operational support; and
General reputation, trading capabilities, investment inventory, their �inancial strength, and our
personal experience working with these brokers.
We are not a subsidiary of or af�iliated with these brokers, in any manner. We have sole responsibility for
investment advice rendered, and advisory services are provided separately and independently from these
brokers.
We receive economic bene�its through our relationship with these brokers, that are typically not available
to their retail clients. These bene�its include the following products and services (provided without cost
or at a discount): consulting services; access to a dedicated trading desk; and access to an electronic
communications network for order entry and account information.
SOFT DOLLARS PART 2A OF FORM ADV Page 15 of 17
The receipt of brokerage and research products from broker-dealers through client commission payments
is commonly referred to as “soft dollars.” Broker-dealers may provide products and services paid for
through soft dollars either directly or through credits deposited into an account that may be used for
research developed by the broker-dealer, third-party research or data and brokerage services. We have
soft dollar arrangements with Morgan Stanley and JP Morgan that is used to obtain research, data and other
services. Section 28(e) of the United States Securities Exchange Act of 1934, as amended, (the “Exchange
Act”), provides “safe harbor” to investment advisors who use soft dollars generated by their advised
accounts to obtain investment research and brokerage services that provide lawful and appropriate
assistance to us in the performance of investment decision-making responsibilities.
The use of “soft dollars” generated by brokerage commissions to obtain products such as investment
research services for us may create a con�lict of interest between the investment manager, the Funds, the
Intermediate Fund and the Master Funds. To the extent that we can acquire these products and services
without expending our own resources, the use of “soft-dollars” would tend to increase our pro�itability.
The availability of these resources may in�luence us to select a broker-dealer, in this case Morgan Stanley
and/or JP Morgan, to provide services to you and the Fund.
Access to, and use of, such products and services, however, will be for the bene�it of both our separately
managed account and the Funds and not just limited to only those accounts that may have generated
commissions/transaction fees to Morgan Stanley and/or JP Morgan.
AGGREGATING TRADE ORDERS Our objective in order execution is to act fairly, impartially, and to take all reasonable steps to obtain the
best possible results (known as “best execution”) for the Master Funds and separately managed account.
Therefore, we generally bunch eligible orders with the guideline that: (i) the bunching of orders is done for
achieving best execution; and, (ii) the Master Funds or separately managed account is not systematically
advantaged or disadvantaged by bunching the orders. That said, we may still execute orders for fewer than
all accounts for a given order due to changes in asset levels in accounts and the pari passu nature of tying
accounts.
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The Funds, Master Funds and separately managed account are reviewed by our back of�ice and operations
team daily. All accounts are reviewed in the context of our investment strategy.
The Funds’ investors will receive monthly statements regarding the investments in the Fund(s) they’re
invested in and annual audited �inancial statements. Separately managed accounts will receive, at least
quarterly, statements from the custodians.
You are encouraged to compare the �inancial data contained in any report we may prepare for you with the
�inancial information disclosed in your account statement to verify the accuracy and correctness of our
reporting. In addition, you are encouraged to review each statement that summarizes the speci�ic
PART 2A OF FORM ADV Page 16 of 17
investments held, the value of your portfolio and account transactions. You are also encouraged to review
with us investment strategies and account performance on an annual basis. Material changes in your
personal circumstances, the general economy, or tax law changes can trigger more frequent reviews.
However, it is your responsibility to communicate these changes to us so that the appropriate adjustments
can be made.
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CLIENT REFERRALS We do not pay third parties to solicit clients.
OTHER COMPENSATION We receive an indirect economic bene�it from Morgan Stanley and JP Morgan (See “Custodial Services”
above under Item 12, “Brokerage Practices” for more detailed information on these services and products.)
Our �iduciary duty binds us to an ethical standard of complete care and loyalty and to avoid circumstances
that might affect, or appear to affect, this standard unless we act transparently and provide you full and
fair disclosure on any potential con�lict.
As part of this full disclosure, we will receive economic bene�its from your investment in the Fund(s). These
bene�its could be, but are not limited to, an increase in: advisory/consulting fees, salaries, and incentive
allocation/fees should you choose to invest in the Fund(s). Therefore, before investing in any of our Funds,
you should consider other investment opportunities to compare expenses and returns to other private
investment vehicles.
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We do not take possession of or maintain custody of your funds or securities. Physical possession and
custody of your funds and/or securities shall be maintained with quali�ied custodians.
We are, however, de�ined as having custody of the assets of the Master Funds, since we have the authority
to deduct our incentive allocation directly from your account. Therefore, in accordance with SEC Rule
206(4)-2), we have implemented the following regulatory safeguards:
Your funds and securities will be maintained with a quali�ied custodian in a separate account in the
name of the Fund(s) in which you invested or separately managed account; and
Authorization to withdraw our fees directly from your account will be approved by you prior to
engaging in any account management services.
PART 2A OF FORM ADV Page 17 of 17
The custodian is required to send the separately managed account, at least quarterly, brokerage statements
summarizing the speci�ic investments currently held in your account, the value of your portfolio, and
account transactions.
Fund investors will not receive statements from the custodian. Instead the Funds are subject to an annual
audit and the audited �inancial statements are distributed to you. The audited �inancial statements will be
prepared in accordance with generally accepted accounting principles and distributed within 120 days of
the Funds’ �iscal year end.
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The Fund’s governing documents sets forth our authority to buy and sell securities or futures contracts in
amounts that are determined to be appropriate. By completing the subscription documents to acquire
interests or shares in one of the Funds, you give us the authority to manage your investments in accordance
with the Fund’s governing documents. Interests or shares may be issued in classes and sub-classes as the
general partner or investment manager may determine, as set forth in the PPM.
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We will exercise voting authority with respect to the securities held in your account. Due to the short-term
nature of the holding period (generally 1-30 days) for securities held by our clients, it is our policy not to
vote proxies.
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We are not required to include �inancial information in our Disclosure Brochure since we will not take
physical custody of client funds or securities or bill client accounts six (6) months or more in advance for
more than $1,200. We are not aware of any current �inancial conditions that are likely to impair our ability
to meet our contractual commitments to you.
END OF DISCLOSURE BROCHURE
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Open Brochure from SEC website