Description of the Advisory Firm
ISPartners1 is an investment management firm based in Zurich, Switzerland. We were founded in 2003 as a corporation under Swiss law. Our directors, as of the date of this Brochure, are Willi Leimer, Daniel A Wuersch and Andreas Apitz. Dr. Willi Leimer and Andreas Apitz are our owners. Dr. Willi Leimer is our Chief Executive Officer (“CEO”). Jillian MacNab is our Chief Compliance Officer (“CCO”).

We are registered with the United States Securities and Exchange Commission (“SEC”) as an investment adviser under the Advisers Act. We are licensed in Switzerland by the Swiss Financial Market Supervisory Authority (“FINMA”) to operate as distributor of collective investment schemes. In addition, we are a member of the Swiss Association of Asset Managers (“SAAM”) and a member of the Alternative Investment Management Association.

We provide asset management for separately managed accounts and private investment funds. We also facilitate wealth management, consulting and education services.

We are the 100% owner of Albis Asset Management Ltd (“Albis”), a Guernsey Financial Services Commission (“GFSC”) licensed Guernsey company. Albis serves as the investment manager of several private funds, as further described below. We also are the 100% owner of Odeon Asset Management Ltd. (“Odeon”), a Cayman Islands company. Further details are set forth in Item 10.

We provide investment management services to private funds, other investment advisers, individuals, trusts, charitable and other tax-exempt organizations, estates and corporations, including single- family offices.

This Brochure outlines our investment advisory business and how we manage assets for our U.S. Clients.
Investment Management Services
We manage U.S. Client portfolios on a discretionary basis. We are strong believers in the power of compounding and therefore aim at keeping downside volatility low and avoiding large drawdowns.

Our discretionary services are tailor-made, taking into account your desires, objectives and other preferences. Each individual investment program will be developed within the context of your total net worth, existing portfolio, investment objectives, risk tolerance and long/short term goals.

We manage portfolios based on investment guidelines that are recorded in each client’s asset management agreement (“Mandate”). This permits us to manage your cash and securities or investments. Investment guidelines include permissible securities and investment instruments, regional focus, exposure limits, restrictions and risk/return expectation. Our investment team holds regular calls and meets with Clients during which we review and discuss the respective portfolios. We tailor portfolios in (i) direct investments that include, but are not limited to, fixed income securities, equities, derivative instruments such as futures, forwards, options, or swaps, physical commodities and other capital markets instruments (“Assets”), and (ii) cash or cash equivalents. . 1We use "we", "our" and "us" refer to ISPartners, and "you" and "your" refer to you as a U.S. Client or U.S. resident prospective client of ours. While we tailor our portfolios to the needs of our clients, we do not accept U.S. Client orders to buy or sell specific Assets.
Private Investment Funds for Non-U.S. Clients
Albis serves as the investment manager, and ISPartners as the investment adviser or the investment co-adviser to two private funds organized outside of the U.S. (the “Albis Funds”).2 Albis acts as the principal manager to the Helium Special Situations Fund, and the Helium Rising Stars Fund. We serve as the investment adviser to these funds. The Xenon Liquid Fund was liquidated in 2018 and liquidation of the ISPartners Diversified Fund-Argon is in progress.

The Albis Funds are not open to investment by persons who are “U.S. Persons” as defined in Regulation S under the Securities Act of 1933, as amended (the “Securities Act”), and each investor must represent in its subscription agreement that it is not a U.S. Person.

Assets under Management

As of 31 December 2018, we manage the following assets for ten clients, of which seven are U.S. Clients:

Discretionary Assets USD 10,767,852 8 accounts Non-discretionary Assets USD 44,099,855 2 accounts
Total USD 54,867,707 10 accounts please register to get more info

We offer two fee structures. The first structure is based on a percentage of the managed assets (“Management Fee”). The second fee structure consists of two components: a Management Fee plus a performance fee based on of the net capital appreciation, if the performance exceeds the calculated return of the hurdle rate (“Performance Fee”) (together, “Fees”). Fees in Swiss francs (CHF) are as follows:
Management Fee Only
Assets under Management Annual Fee Up to CHF 5 million Negotiable CHF 5 million to 10 million 0.8% CHF 10 million to 50 million 0.7% CHF 50 million to 100 million 0.6% Over CHF 100 Million Negotiable

Management and Performance Fee
Assets under Management Annual Fee Performance Fee Up to CHF 5 million Negotiable Negotiable CHF 5 million to 10 million 0.6% 6% 2Each Albis Fund is closed to investment by “U.S. Persons” as defined in the Securities Act and is exempt from registration under the U.S. Investment Company Act of 1940, as amended. The securities of the Albis Funds are exempt from registration with the SEC under the Securities Act. Additional details regarding the Albis Funds are contained in their private placement memorandum. This Brochure is not an offer to buy or sell the securities of the Albis Funds. CHF 10 million to 50 million 0.5% 6% CHF 50 million to 100 million 0.4% 6% Over CHF 100 Million Negotiable Negotiable The Management Fee is due and payable quarterly on 31 March, 30 June, 30 September and 31 December in arrears. The amount is calculated on the notional value of the assets at the end of each management period, on 31 March, 30 June, 30 September and 31 December (“fee date”). For services beginning during a calendar quarter, the compensation for the initial period is reduced pro rata to 31 March, 30 June, 30 September and 31 December, respectively.

The Performance Fee is 6% of the net capital appreciation if the performance exceeds the calculated return of the hurdle rate on 31 March, 30 June, 30 September and 31 December. The hurdle rate is subject to negotiation and individually defined for each Client. The Performance Fee is calculated on a “High Watermark” basis. The Performance Fee is calculated quarterly on a cumulative basis and is payable quarterly in arrears but not until all prior net losses are recouped.

Fees are charged in the Client’s base currency. In all cases, we may waive, discount or negotiate fees at our sole discretion – this is stated in each Mandate.

You select the “qualified custodian” (“custodian”) to hold your Assets. We may provide you with assistance or guidance on possible custodians, but the decision is yours.

Your custodian will value your Assets.

Based on your custodian’s calculation of the notional Asset value on the fee date, we will invoice the fee agreed with you in your Mandate. We will send the invoice for the Fees due to your custodian. Your custodian, acting as your agent, will deduct the Fees due to us from your account against the invoice and pay us. Fees are not paid in advance.

You may terminate your Mandate without notice. Upon termination, Fees for the period from the first date of the quarter to the date of termination are due and payable. The custodian will take steps for the disposition or moving of assets after account closure, as required.

Our Fees are exclusive of and in addition to brokerage commissions, transaction fees, custody fees, securities exchange fees, stamp duties and any other related costs, taxes and expenses. You pay these. The investment managers of funds in which you would be invested also charge management and/or performance fees, and these funds may charge other expenses. We do not participate in any portion of these underlying fund internal fees. Neither ISPartners nor any of its officers, directors and employees accepts compensation for the sale of securities or investment products from any source. please register to get more info

As noted above in Item 5, we and our related persons receive incentive compensation. Such a fee creates a conflict of interest to the extent that a related person or we have an incentive to favour a Client from which a related person or we receive an incentive-based fee over a Client that does not pay this or that pays a lower performance-based fee. Incentive-based fees may be seen to create a desire to make riskier investment decisions on behalf of Clients paying these fees. We address this conflict by treating our Clients according to their profiles and allocating investments according to merit. We have instituted policies and procedures to ensure the fair treatment of our Clients. please register to get more info

We provide discretionary investment advisory services to U.S. individuals, trusts, charitable and other tax-exempt organizations, estates and corporations, including single-family offices. Our minimum account requirement is CHF 5 million. We reserve the right to accept smaller accounts based on individual circumstances. please register to get more info

Investment Strategy
Each strategy is tailored to a Client’s specific needs. Certain strategies may make use of the same instruments in their implementation. In such cases, ISP has strict pre- and post-trade allocation procedures in place to ensure clients are treated fairly.

Our investment analysis of assets and financial markets may include fundamental and technical analysis. Generally, our strategy consists of a Swiss/European balanced portfolio, which follows a buy and hold approach. The Swiss balanced portfolio consists of Swiss and European blue-chip stocks as well as investment grade bonds in CHF and other European currencies and may include cash or cash equivalents.

We base our asset management on our own and third party research: The resulting asset allocation is based on a broad indicator system (pricing, liquidity, momentum, sentiment).
Risk of Loss
All investments involve a degree of risk, independent from the strategy used. You may face some or all of the following risks when investing with us.

Macro-economic Conditions. General economic conditions may have an impact upon investment activities. Interest rates, the prices of securities and participation by other investors in the financial markets may affect the value of Assets that we purchase for you. The global macro-economic uncertainty may well continue and impact expected returns. Global rates of growth or economic conditions that are weak for a prolonged period may pose risks of systematic defaults by borrowers, inflationary or exchange-rate pressures or geopolitical disturbances that could adversely affect returns. Because of these factors, you could incur losses or fail to meet your objectives. Investment Risk. Investments necessarily involve a degree of risk and certain are riskier than others are, or are more or less liquid. Investing in a hedge fund involves a risk of loss, including the potential loss of a Client’s entire investment.

Market Risk. All securities may experience fluctuations in prices due to external factors that affect the overall performance of the financial markets. These external factors may be political events, natural disasters, terrorist attacks, etc. Market risk or systematic risk cannot be eliminated through diversification. Inflation Risk. In an inflationary environment, purchasing power is reduced i.e. a dollar tomorrow will buy less than a dollar today. Thus, inflation could undermine the performance of your investment. Interest Rate Risk. Fluctuations in interest rates may affect investment prices. Interest rate risk affects the value of bonds more directly than stocks. Bond prices have an inverse relationship to interest rates: As interest rates rise, bond prices fall and vice versa. Business Risk. This risk is usually specific to an industry or a company within an industry. It is a factor that may impact negatively a business’ operations or profits. For example, in the technology sector, if a company misses a new development such as flat screen television, its sales figures may drop significantly, leading to less profit and thus a lower price of the stock. Currency Risk. Your return for investing in foreign securities could be reduced due to the U.S. Dollar appreciating against foreign currencies.

Liquidity Risk. Liquidity is the ability to sell quickly an investment at an appropriate price. Usually, hedge funds and other alternative investments are less liquid than a largely traded stock.

We cannot guarantee that your financial goals or objectives will be achieved. Past performance is no indication of future performance. please register to get more info

Neither our management personnel nor we have been involved in any material legal or disciplinary events, such as court actions or regulatory or self-regulatory proceedings. please register to get more info

We and our directors, officers and employees are subject to the following conflicts of interest:

Our officers, directors or employees are engaged in activities beyond their specific roles with us. This includes board membership of listed and unlisted companies, unrelated outside business activities, charities, membership on boards of non-profit organisations or other types of associations where it may be possible to receive and review general information applicable to our investment strategies. We require these to be disclosed and, depending upon the circumstances, we may impose restrictions on such involvement. The conflicts of interest that arise from these activities are addressed by policies and procedures that require further disclosure to us, recusal from discussions or votes or, in certain instances, foregoing fees or redeeming, foregoing investments or removal.

Mr Apitz owns 4% of Crossbow Partners, a research firm specialising in the provision of alternative investment fund and manager due diligence and advisory services. ISPartners currently has no business relationship with Crossbow. Mr Apitz is also a board member of Crossbow.

Mr Gailloud, a part-time employee, is the owner and CEO of Gailloud Asset Management AG (“Gailloud AM”), a privately held asset management company located in Zurich. When working with us he provides discretionary investment management advice to our Clients. Separately, Mr Gailloud, through Gailloud AM, provides asset management to non-U.S. Clients. These activities involve the same securities and the same strategies. Policies and procedures, including monitoring, are in place to help ensure that Mr Gailloud’s activities with us, as well as the research, advice and information that he holds and that is used at ISPartners, remains with us at all times and cannot be used by him or by Gailloud AM for any reason at any time. As discussed in Item 4, we are the 100% owner of both Albis and Odeon. We serve as investment adviser to the Albis Funds pursuant to arms-length agreements. mojo.capital is a Luxembourg public limited liability company (société anonyme). mojo.capital was appointed as a fund manager of Mojo Digital One, a Luxembourg alternative investment fund, by Mojo Digital One GP, a Luxembourg entity that is the General Partner of Mojo Digital One.
• We are a 30% shareholder of mojo.capital.
• ISP is a limited partner of Mojo Digital One by its investment of USD 500,000 of its capital, which is partially financed through a loan from Odeon – our direct investment together with the Odeon loan arrangement, are the “mojo Investments”.
• ISPartners does not do the risk management for mojo.capital.
• Mr Leimer is a director of mojo.capital and a non-voting member of the Investment Committee of mojo.capital.

We negotiated these arrangements on an arms-length basis and documented these in agreements.

We disclaim control of mojo.capital, Mojo Digital One GP and Mojo Digital One. Mr Leimer will, when serving on the mojo.capital board, recuse himself from discussions and votes involving ISPartners or the mojo Investments. Mr Leimer is subject to our controls to prevent the misuse of confidential client information, and he will comply with similar requirements imposed by mojo-capital and Mojo Digital One GP.

Helvetica Capital AG (“Helvetica”) is a privately held Swiss based limited liability company registered in Zurich. Helvetica is an investor adviser with a focus on Swiss SMEs and advises both entrepreneurs and investors in financing and succession solutions.

Mr Leimer owns 10% of Helvetica Capital. He is a board member of Helvetica. We disclaim control of Helvetica. Mr Leimer complies with controls reasonably designed to prevent the passing of our confidential client information to Helvetica.

Turos Capital AG (“Turos”), a privately held Swiss based limited liability company registered in Zug, is a specialized finance boutique that supports healthcare start-ups with venture capital and advisory services across all stages of development until exit. With its multidisciplinary experience, and supported by an international network of industry experts, Turos seeks to match promising life science startups with the most relevant investors.


• We are a 16.6% shareholder of Turos Capital AG.
• Mr Leimer owns 16.6% Turos Capital AG.
• Mr Leimer is the chairman of Turos Capital AG.

The activities Mr Leimer performs or in which he engages as noted above and any information that he receives or uses for this purpose will be segregated and ring-fenced so that no information may be misused. We will monitor such activities and take appropriate action should these conditions not be followed.

Turos has a separate office within the premises of ISPartners. Turos shares certain infrastructure with ISPartners (i.e. meeting rooms, kitchen). ISP and Turos maintain policies and procedures designed to prevent the misuse of confidential client information. As we have several individuals performing multiple roles, conflicts may arise with respect to allocations of activities, personnel and investment opportunities. Our investment professionals will devote such time as will be necessary to conduct the business of their Clients in an appropriate manner, and will allocate investment opportunities in a manner that we determine to be fair to our Clients. The conflicts of interest that arise from this are addressed by policies and procedures that require recusal, restriction or withdrawal of such activities. Jillian MacNab is our Chief Compliance Officer. She is also a partner in an outside law firm which is unaffiliated with ISPartners, but for which she receives additional compensation and to which she will devote a certain amount of time beside her commitments to ISPartners. Ms. MacNab may also act as Chief Compliance Officer for other registered investment advisers. Ms. MacNab is subject to ISPartners’ Code of Ethics and Private Account Dealing obligations which are monitored and reported to the Board of Directors of ISP. As an attorney admitted to the Bar in Zurich, she is subject to comprehensive confidentiality obligations.

We permit, subject to compliance with our Code of Ethics, employees to buy and sell securities that might include investments in the funds that a related person or we advise or manage. please register to get more info

Code of Ethics
We have adopted a Code of Ethics (“Code”) pursuant to and in compliance with Advisers Act Rule 204A-1. Under our Code, our officers, directors and employees (“Staff”), as “supervised persons” and “access persons”, must comply with the U.S. federal securities laws at all times and act with competence, dignity, integrity and in an ethical manner. Recognizing that we are a fiduciary to our Clients, the Code also requires that Staff adhere to the highest standards and act in the best interests of our Clients at all times. Our Staff are required to adhere strictly to these guidelines.

Personal Trading
Our Code contains policies and procedures that are designed to address the conflicts of interest associated with personal trading activities. These include, inter alia, a personal account transaction policy and controls to prohibit (no clearance or trading) transactions in certain investments and reporting requirements. Additional policies and procedures include: the prevention of misuse of confidential client information; the delivery of the Code and a written acknowledgment of its receipt; CCO analysis of personal account activity; initial, quarterly and annual reporting of accounts and holdings; and a requirement to report promptly suspected violations of the Code to our Chief Compliance Officer.

A copy of our Code is available upon written request. please register to get more info

We do not receive research or other products or services other than execution from a broker-dealer in connection with client securities (“soft dollar benefits”).

If requested, we assist our Clients in the custodian selection and custody fee negotiation processes. However, the final decision is at our Client’s discretion. We do not take U.S. Client orders to buy or sell securities. Client accounts are treated in a fair and equal manner. We do not select third-party brokers with whom to place orders to buy or sell Assets. Instead, we place orders to buy or sell Assets, in the exercise of discretion, with the trading desks of the custodians holding Assets.
Best Execution
Best execution is seeking the most favourable total cost and proceeds, under the circumstances and in each transaction, and does not necessarily mean achieving the lowest or highest possible price or transaction cost, as the case may be. As we do not select third-party brokers with whom to trade, we require the trading desks of the custodians with whom we trade not only to provide us with best execution but to provide us with their analysis of how they have achieved and validated best execution. Where a custodian allows a client to place orders with outside brokers or counterparties directly, and such client directs us to trade through a specific third-party broker or with a specific counterparty, we do not have a best execution obligation unless we are given and accept the client’s direction “subject to best execution.” If we are offered or receive a benefit from the direction of the trade, we disclose this to the client. Where this is not the case: for equity and fixed-income securities, we measure best execution as being a trade within the high and low for that day’s trading.

Block Trades
We will not aggregate a trade for a non-U.S. client with a U.S. Client. We may trade for more than one U.S. Client where those clients have the same custodian. In this case, we may combine multiple orders for securities (“block trading”) if we believe this will help achieve best execution and result in lower commission rates or other transaction costs. When trading simultaneously for more than one Client account or portfolio with a single custodian, we allocate trades among those accounts using a pre- trade allocation that is recorded prior to placing the order to buy or sell. In determining the allocation, we act on a pro rata basis that may be adjusted by taking the following factors into account: cash; then current exposure and other documented considerations. Due to the complexity and variations of the investment guidelines among different accounts, we may adjust, post-trade, the pre-trade allocations, as pre-determined by the allocation factors mentioned above. Any post-trade adjustment will be documented and require prior written approval of the CEO and the CCO.

Trade Errors
We identify and address trade errors as soon as practicable after they are discovered. If a trade error arises, we will ensure that no Client suffers a loss. Trade errors will be documented and actions are taken, where possible, to prevent such errors in the future. We bear losses and clients receive gains. We do not net gains against losses. please register to get more info

Our portfolio managers monitor accounts on an ongoing basis. We also conduct quarterly investment committee meetings to discuss macroeconomic developments and potential investment opportunities. You will receive monthly or quarterly account statements as well as annual tax reports from your custodian(s). If you have agreed this with your custodian, they will also provide trade confirmations directly to you. please register to get more info

ISP has not entered into arrangements with any third party firm to solicit or refer U.S. Clients. please register to get more info

Client assets are maintained by qualified custodian(s), selected by the Client. However, by virtue of the definition of Custody under the Advisers Act, ISPartners is deemed to have custody over client accounts as a result of its ability to directly deduct management fees from client accounts. To comply with the Custody Rule, ISPartners ensures that all clients receive at least a quarterly account statement directly from their custodian(s), such statements should be reviewed carefully. In addition, ISPartners provides advance invoices for the management fees allowing clients to review the fee prior to it being debited from the account. please register to get more info

Generally, we manage portfolios with discretionary authority to determine the investments and the amounts thereof to be bought or sold for Clients. Such authority may be limited by our Clients’ investment profiles, e.g. investment time horizon, risk tolerance, cash needs and the like. Before we can trade your account, you must first sign our discretionary asset management agreement and a limited power of attorney document provided by your custodian(s). please register to get more info

ISPartners does not vote proxies for client accounts. Clients should arrange to have any proxy materials received by the custodian to be sent to the Client for instructions. please register to get more info

No management fees are payable to us more than six months in advance. As such, we are not required to include a balance sheet for the most recent fiscal year or disclose information about its financial position. We are not aware of any financial condition that is reasonably likely to impair our ability to meet our contractual obligations. We have not been the subject of a bankruptcy petition. please register to get more info