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UNITED KINGDOM PRIVATE CLIENT
Fisher Investments (CRD 107342), brochure dated February 11, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
Form ADV 2A
Brochure
6500 International Pkwy, Ste 2050
Plano, TX 75093
Phone: 00-1-800-851-8845 / 00-1-650-851-3334
Fax: 00-1-650-529-1436
www.fisherinvestments.com
11 February 2026
This brochure provides information about the qualifications and business practices of Fisher Investments. If you
have any questions about the contents of this brochure, please contact us at 00-1-800-851-8845, or by email at
pcg@fi.com. The information in this brochure has not been approved or verified by the United States Securities
and Exchange Commission (“SEC”), or by any state securities authority.
Fisher Investments is registered with the SEC as an investment adviser. Being registered with the SEC or any
other regulatory authority does not imply Fisher Investments has a certain level of skill or training.
Additional information about Fisher Investments is available on the SEC’s website at www.adviserinfo.sec.gov.
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Material Changes
This section provides a summary of material changes that were made to this brochure since the last annual update
and is intended to help Clients determine if they want to review this brochure in its entirety, or contact Fisher
Investments with questions about the changes.
No material changes since the last Form ADV update.
Information about Fisher Investments is also available on the SEC’s website at www.adviserinfo.sec.gov. To
request a copy of the most recent disclosure brochure, contact us at:
Fisher Investments
6500 International Pkwy, Ste 2050
Plano, TX 75093
Phone: 00-1-800-851-8845
Email: pcg@fi.com
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Table of Contents
Advisory Business ............................................................................................................................... 4
Fees and Compensation ....................................................................................................................... 5
Performance-Based Fees and Side-By-Side Management ............................................................... 7
Types of Clients ................................................................................................................................... 7
Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 7
Disciplinary Information ..................................................................................................................... 9
Other Financial Industry Activities and Affiliations ......................................................................... 9
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 12
Brokerage Practices ........................................................................................................................... 13
Review of Accounts ........................................................................................................................... 16
Client Referrals and Other Compensation ....................................................................................... 17
Custody ............................................................................................................................................... 17
Investment Discretion ........................................................................................................................ 18
Voting Client Securities ..................................................................................................................... 18
Financial Information ........................................................................................................................ 18
Additional Information: Fair Valuation ........................................................................................... 19
Additional Information: Privacy ....................................................................................................... 19
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Advisory Business
Firm Description
Fisher Asset Management, LLC, doing business as Fisher Investments (“FI”), a privately held limited
liability company, is an investment adviser with primary offices in California, Florida, Texas and
Washington. FI is registered with the U.S. Securities and Exchange Commission (“SEC”); in Canada with
the Alberta Securities Commission, British Columbia Securities Commission, Manitoba Securities
Commission, New Brunswick Securities Commission, Newfoundland and Labrador Financial Services
Regulation Division, Nova Scotia Securities Commission, Ontario Securities Commission, Prince Edward
Island Securities Office, Quebec Autorité des Marchés Financiers, and Saskatchewan Financial Services
Commission; and with the Netherlands Authority for the Financial Markets. FI has a branch office registered
with the Dubai International Financial Centre. Being registered with the SEC or any other regulatory
authority does not imply FI has a certain level of skill or training.
FI manages assets within different client groups: Institutional (including Personalized Retirement Outcomes)
and Private Client – including private clients in the US, UK, Canada, Europe, Saudi Arabia, Australia, New
Zealand, and Singapore. Collectively, these groups comprise a global client base of diverse investors
including corporate, public and multi-employer pension plans, foundations and endowments, insurance
companies, healthcare organizations, governments, investment companies and high-net-worth individuals.
The firm offers a broad array of US, non-US, and global equity and fixed income strategies with various
capitalization and style orientations. Founded in 1979, all strategies are supported by the firm’s global
research platform developed over its 45+ year history. Investment decisions are made by the firm’s five-
member Investment Policy Committee (“IPC”). In the mid-1990s, FI began offering separate portfolio
management directly to high-net-worth individuals.
The bedrock of FI’s business is based on maintaining a culture of ethics and integrity with the highest
possible emphasis on clear and transparent communications with the investing public. Embedded within the
firm’s culture is its embrace of the fiduciary duty to put client interests first. FI fosters a culture that hires,
trains, and rewards employees in direct support of the values of openness, honesty, integrity, and trust.
A culture that fosters transparency is core to FI’s client service model. Every private client is assigned an
Investment Counselor who is available to answer questions in as much detail or as frequently as the client
would like. FI supplies clients with quarterly statements and written reviews from the Investment Policy
Committee. FI also regularly creates written commentary and multimedia with its Investment Policy
Committee detailing the firm’s market outlook, which expands on many of the themes in the quarterly
reviews and gives clients a chance to hear directly from portfolio decision-makers. For clients who are
interested in greater detail, FI offers a variety of additional market commentary through its website
(fisherinvestments.com) and social media channels.
For clients who would like to meet and hear from senior FI representatives directly, FI offers client seminars
which allow clients to review our market forecast and ask questions in an in-person presentation setting. FI
also offers online communication and education opportunities through Fisher Connect Webinars and Client
Video Conferences.
Principal Owners
Fisher Investments, Inc. owns more than 75% of the voting interests in FI, with legal entities controlled by
Advent International and the Abu Dhabi Investment Authority, respectively, owning the rest. In addition, the
CEO (as co-trustee, with his spouse, of a family trust) holds non-voting interests. Ken Fisher owns more than
75% of the shares of Fisher Investments, Inc.
Types of Advisory Services
FI provides investment management services for clients within the categories of equity, fixed interest, and
blended accounts. All accounts have the goal of maximizing returns relative to risk compared to particular
benchmarks.
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• Equity accounts seek to do this using primarily Open Ended Investment Companies or common
stock and cash equivalents.
• Fixed income accounts use various fixed income Exchange Traded Funds and cash.
• Blended accounts use primarily a combination of open-ended investment companies or stock,
fixed income Exchange Traded instruments, and cash seeking to maximize returns to risk.
FI manages money for clients in one of these three fashions based on individual discussions with each client
about the client’s overall financial goals. FI also may engage in various defensive strategies in each of these
styles in an effort to minimize losses or to seek investment returns. However, there are special risks involved
with those defensive strategies. Refer to the Methods of Analysis, Investment Strategies and Risk of Loss
section below.
FI serves as sub-manager to Fisher Investments Europe Limited (with respect to its Institutional clients),
Fisher Investments Ireland Limited, Fisher Investments Luxembourg, Sàrl, and Fisher Investments GmbH,
which manage assets for clients in various European countries, and for Fisher Investments Australasia Pty
Ltd and Fisher Investments Japan. FI provides investment management support to Fisher Investments
Arabia.
Throughout the client relationship, FI strives to keep clients apprised of its strategy and current market
outlook. The firm fosters a culture that focuses on maintaining transparency and openness for successful
relationships and stresses this as both a core company value and an expectation of all employees in their
dealings with clients and each other.
Assets under Management
FI manages client assets on a discretionary basis. As of 31 December 2025, FI managed a total of:
Private Client
Institutional
Total
Discretionary
Non-Discretionary
$331,230,543,932
$0
$331,230,543,932
$55,439,180,106
$0
$55,439,180,106
$386,669,724,038
$0
$386,669,724,038
Total
Assets under management are provided in $USD.
Fees and Compensation
Description
While at times FI may negotiate rates other than specified below, the following schedule sets out FI’s billing
rates for UK Private Clients that are invested in non-Fisher OEIC investments (e.g. individual securities,
ETFs, etc.):
UK Private Client Accounts
Annual Management Fee
First £500,000
Next £500,000
Next £9 million
Next £10 million
1.50%
1.25%
1.125%
0.90%
To the extent UK Private Clients are invested in a Fisher OEIC, the following schedule applies:
Assets Invested
Annual Management Charge as % of Assets Invested
Up to £1,999,999
£2,000,000 and above
B Shares
(1.50% Annual Rate)
A Shares
(1.25% Annual Rate)
UK Private Client accounts will also be billed a non-refundable initial fee for initial funding and subsequent
additions as detailed below:
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Fisher Initial Fee
OEIC Initial Fee
Aggregate Funding
Amount of the Account(s)
OEIC Initial Fee Discount
(from the Initial Fee in the
Prospectus)
Up to £299,999
£300,000 to £499,999
£500,000 to £999,999
£1,000,000 to £1,999,999
£2,000,000 to £2,999,999
Above £3,000,000
2.25%*
1.50%*
1.00%*
0.50%*
0.25%*
Nil
-5.25%
-5.25%
-5.25%
-5.25%
-5.25%
-5.25%
Nil
Nil
Nil
Nil
Nil
Nil
*For Accounts up to £2,999,999, the Initial Fee for each Account will be reduced by a pro rata portion of
Fisher Investments UK’s initial adviser charge of £825. The Initial Fee and the pro rata reduction will be
calculated on the billing date following the earlier of full funding of the Account(s) or six months after the
Client(s) signs an agreement with Fisher Investments (“Adjustment Date”). Additional contributions
received after the Adjustment Date will be subject to the full Initial Fee.
FI may negotiate certain fixed rates with clients that can apply to all asset levels. FI provides advisory
services to clients in a limited number of special situations for substantially reduced or no advisory fees.
These include certain accounts for friends of the firm, relatives or children of other clients, and legacy
accounts that have been clients for many years. Certain clients who become clients of FI as a result of its
merger and acquisition activities may retain their prior fee schedules and therefore pay higher or lower fees
than other FI clients.
Fee Billing
Investment management account fees are normally based on a percentage of total assets managed for long
positions (including cash balances) and do not deduct for margin debit balances (margin loans). For accounts
invested in the Long/Short strategy, investment management account fees are based on the combined market
value of the separate long and short positions (short positions do not reduce the value of long positions for
this purpose), less the credit or proceeds received from the short sales that are not reinvested. For accounts
with short positions not invested in the Long/Short strategy, both the current value of the short position and
proceeds from the short sale are included when determining the combined market value (short positions do
reduce the value of the long positions for this purpose). Fees are generally calculated and charged quarterly.
Fees are based on the market value using closing prices at quarter end, at one-quarter of the annual rates
listed above. The quarter ending value includes accrued interest and/or dividends. Fees are billed and paid
after they are earned. Fees will be calculated and charged beginning on the first trade date of the account.
The fee will be calculated and deducted from the client’s account each calendar quarter following the billing
date as stated in the client’s Confidential Client Agreement with FI (“CCA”). The client may instead pay
fees from another account or via invoice by completing and submitting written instructions to FI.
Unless the first trade date of the accounts is on the first day of the calendar quarter, fees for the initial billing
period will be calculated based on the number of calendar days from that date until the end of the quarter. A
fee will not be calculated and billed for an initial billing period if there are no assets in the client’s account or
the number of billing days in the period is less than 16. Instead, the following calendar quarter may be
combined with the initial billing period, making the billing period longer than the one calendar quarter
depending upon when assets are received into the account and FI begins trading in the client’s account. The
fee will be calculated for that entire longer period based on the account value at the end of the following
calendar quarter. Any net contributions or withdrawals made after the initial billing period that is equal to or
greater than £50,000 will be prorated if the fee adjustment is greater than .0025% of the client’s quarter-end
assets under management by FI and the fee adjustment for the transaction is greater than or equal to £100.
In general, a client may terminate the CCA with FI at any time by notifying FI in writing. At such time, FI
will bill the client for services already rendered, prorated through the calendar day prior to the date of
termination. Since FI does not bill in advance, a refund of fees is not applicable.
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Other Fees
Clients will incur fees in addition to the management fee paid to FI, as stated above. Such fees can
include brokerage commissions, other custodian fees, and expenses for investing in exchange-traded
funds or structured notes. FI does not earn such other fees. Please refer to the Brokerage Practices on
pages below for additional information on how FI selects brokers.
FI will waive its separate account advisory fee to the extent accounts indirectly pay an advisory fee by
investing in shares of the United Kingdom or Jersey-based open ended investment companies that pay FI an
advisory fee. FI may instead reduce its advisory fee payable by the funds. Clients would pay for all the
operating and other expenses associated with an investment in the funds as well as with the separate account.
The use of defensive strategies may increase trading activity, and thus, the recognition (for income tax
purposes) of gains and losses, and increase other expenses (such as brokerage charges) compared to accounts
that do not use these techniques. Refer to the Methods of Analysis, Investment Strategies and Risk of Loss
section below.
Performance-Based Fees and Side-By-Side Management
FI does not typically charge performance-based fees for private client accounts, but may for institutional
clients who specifically request it if appropriate. Performance-based fee arrangements permit FI to
receive compensation for unrealized appreciation as well as realized gains and may create an incentive
for FI to make riskier or more speculative investments. Managing accounts that are charged a
performance-based fee and accounts that are charged another type of fee, such as a fixed-rate fee,
presents certain conflicts of interest in managing these accounts at the same time. There is an incentive to
favor performance-based fee accounts. FI’s policies and procedures have been developed to ensure that
all clients are treated fairly and equally, and without regard to the fee type in determining trade allocation.
Refer to the Order Aggregation section below. FI reviews trade aggregation and allocation policies and
procedures at least annually to ensure adherence to firm procedures and that no client is being
systematically favored.
Types of Clients
Description
FI has a global client base of diverse investors in an advisory and sub-advisory role including corporations,
retirement plans, public and multi-employer pension funds, foundations, endowments, governments,
investment companies, and high-net-worth individuals across America, Europe, Canada, Asia, Australia,
and the Middle East.
Account Minimums
At present, Fisher Investments Europe Limited, trading as Fisher Investments UK (“FIUK”) targets
accounts with at least £250,000 in investable assets.
Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
FI uses both qualitative and quantitative tools to analyze markets, sectors, and securities. FI makes extensive
use of computers, computer peripherals, software, and computer databases in screening for securities worthy
of investment consideration. FI uses a centralized portfolio management system, which includes block
trading, portfolio management, and securities price data collection.
Investment Strategies
Private clients are generally invested in an equity, fixed income, or blended account based on their individual
financial goals and objectives, restrictions, or investment limitations as expressed by the client. FI can adjust
its investment strategy for each client as appropriate depending on its forward-looking view of market
conditions. For equity and blended accounts, FI seeks to maximize opportunity and manage risk by investing
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globally to take advantage of worldwide opportunities by investing in equities, fixed income securities,
structured products, or other derivatives that can include leverage. However, if FI forecasts a bear market on
the horizon, a defensive approach may be taken. FI’s goal is simply to help clients achieve their financial
goals, regardless of market conditions.
FI uses investment benchmarks as a framework for constructing client portfolios, managing portfolio risk,
and monitoring client portfolio performance by comparing rates of return over time. FI can provide
information about particular investment benchmarks and how they are selected and constituted upon
request.
FI conducts tax-loss harvesting each year, at its discretion, in taxable accounts to help potentially lower client
tax burdens. Tax-loss harvesting is the process of selling securities that have declined in value to realize
losses for the tax year. The securities sold to harvest losses will be temporarily restricted for a short period in
order to avoid forfeiture of the realized losses and increasing the deferred tax liability for clients (the “wash-
sale rule”). In order to maintain market exposure during the wash-sale rule restriction period, FI will invest
in replacement securities which may deviate from FI views as an optimal pre-tax portfolio allocation. The
replacement securities may be sold and the original securities repurchased which could also potentially
increase the tax liability for clients if gains are realized, or FI may choose to keep the replacement securities
if it believes those securities are appropriate for the client’s situation. The use of tax-loss harvesting will
increase trading activity and potentially increase transaction expenses. Clients will receive notice well in
advance of the implementation of this process each year and can opt-out at that time or request to opt out of
the service entirely. Clients can also mandate tax-loss harvesting in their taxable accounts managed by FI at
any time.
If FI forecasts a prolonged and substantial downturn for the U.S. and/or the foreign stock markets, it may
adopt a defensive strategy for clients’ equity accounts by investing substantially in fixed income securities,
money market instruments, structured or exchange traded notes, put options or other derivatives on securities
or indexes or exchange-traded funds, selling short securities or exchange traded funds, and other hedging
techniques. There can be no guarantee that FI will accurately forecast any prolonged and substantial
downturn in the market, or that the use of derivatives and other defensive techniques would be successful in
avoiding losses. These defensive strategies may be used for a client’s account only to the extent not
prohibited by the CCA, custodial limitations, and applicable law. Clients may specifically request, in writing,
FI to limit or avoid the use of these defensive techniques in their accounts.
Derivatives typically derive their value from the performance of an underlying asset, interest rates or index.
A client’s account would lose the premium or other transaction costs related to the purchase of an option – a
type of derivative - that expires worthless. The price movements of derivatives may be more volatile than
those of other securities, and result in increased investment risk. Many of these investments do not enjoy as
much liquidity as other securities; although, consistent with its investment strategy FI will seek to invest in
liquid investments to the extent they represent the best investment option in FI’s view. FI will normally cause
client accounts to “cover” options they write with the underlying security and other liquid assets.
Short sales may be used to fully or partially hedge other investments in a client’s equity or blended account
or to seek returns unrelated to other investments. “Short sales” means borrowing a security and selling it.
Short sales result in profits or losses depending on whether the price of the security increases versus the price
at the time of the short sale (which results in a loss) or decreases versus the price at the time of the short sale
(which results in a gain). The loss from a short sale is theoretically unlimited depending on how much the
security sold short increases in value. Clients may specifically request, in writing, FI to limit or avoid the use
of short sales in their accounts.
Structured and exchange traded notes are debt instruments whose return is derived from the performance of a
reference index or other underlying securities or investments. The performance of a note is determined
primarily by the performance of the underlying investments; therefore, despite technically being a corporate
debt instrument, notes can be designed to provide returns similar to other asset classes. These notes include
leverage, which potentially increases risk and volatility. These notes are issued by third-party financial
institutions and thus bear the credit risk of those entities. Though FI may choose the nature of the note and
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define the underlying investments, the third-party financial institution will manage the note and charge a
management fee to do so. Financing and other charges also apply depending on the nature of the note and its
construction.
Risk of Loss
Investing in capital markets involves risk of loss that each client should be prepared to bear. Investing in
foreign stock markets involves additional risks including political, economic and currency risks, as well as
differences in accounting methods. Investing in fixed income instruments may involve certain costs and risks
such as liquidity risk, interest rate risk, and credit risk. Portfolios investing in derivatives could lose more
than the principal amount invested in those instruments. There can be no guarantee that a portfolio will meet
its investment objectives or that it will not suffer losses.
Disciplinary Information
Legal and Disciplinary
There have been no disciplinary events and no material legal events related to FI or any management person.
Other Financial Industry Activities and Affiliations
Financial Media
Ken Fisher, Aaron Anderson, and other senior members of the firm are regular contributors to various media
and publications globally. Fisher Investments can hold some or all of the securities mentioned in a particular
article in client portfolios.
Affiliations
FI owns Fisher Investments Europe Limited, doing business as Fisher Investments UK (“FIUK”), an
investment firm headquartered in the United Kingdom whose main activities are marketing FI’s and its own
investment management services to prospective private clients in the United Kingdom, including providing
investment and pension transfer recommendations and marketing its own investment management services
to and managing assets for institutional clients in the United Kingdom, Switzerland, and Belgium, which are
sub-managed by FI. FI earns a sub-management fee for the sub-management services it provides to FIUK.
FI acts as the investment adviser for the Tactical Multi-Purpose Fund (“Tactical Fund”), organized as a non-
diversified series of Unified Series Trust established under the laws of Ohio by an Agreement and
Declaration of Trust dated October 17, 2002. FI may recommend to clients, or use its discretionary authority
over clients’ accounts, to invest client assets in shares of the Tactical Fund. Clients may also restrict or
prohibit investment of their accounts in the Tactical Fund in writing. Additionally, FI acts as the investment
adviser for the FI Institutional Group Stock Fund for Retirement Plans, the FI Institutional Group ESG Stock
Fund for Retirement Plans, the FI Institutional Group Fixed Income Fund for Retirement Plans, and the FI
Institutional Group ESG Fixed Income Fund for Retirement Plans, each a diversified series of Unified Series
Trust.
FI acts as the investment manager for the UK-based Purisima Investment Funds, an open-ended investment
company (“OEIC”) incorporated in England and Wales under registered number IC 162 and authorized an
Undertaking for Collective Investment in Transferrable Securities (“UCITS”) by the UK Financial Conduct
Authority, which is comprised of three sub-funds: the Purisima Global Total Return Fund, the Purisima UK
Total Return Fund, and the Purisima EAFE Total Return Fund. In addition, FI acts as the investment
manager for the Purisima Investment Fund (CI) Limited, an OEIC established in Jersey, Channel Islands, as
an Expert Fund in accordance with the Jersey Collective Investment Funds Order 1995. FI may recommend
to private clients in the United Kingdom, or use its discretionary authority over clients’ accounts, to invest
client assets in shares of the OEICs. FI will waive its separate account management fee to the extent accounts
indirectly pay a management fee by investing in shares of the OEICs. Clients would pay for all the operating
and other expenses associated with an investment in the OEICs as well as with the separate account. Clients
may also restrict or prohibit investment of their accounts in the OEICs in writing.
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FI acts as the investment manager for the Fisher Investments Institutional Funds plc, an open ended
investment company with variable capital incorporated in Ireland under the Irish Companies Act 1963 to
2009 with registered number 496650 and authorized as a UCITS by the Central Bank of Ireland, which is
currently comprised of twenty-eight sub-funds: the Fisher Investments Institutional Emerging Markets
Equity Fund, the Fisher Investments Institutional Emerging Markets Equity ESG Fund, the Fisher
Investments Institutional Frontier Markets Equity Fund, the Fisher Investments Institutional Asia ex-Japan
Equity Fund, the Fisher Investments Institutional Global Small Cap Equity Fund, the Fisher Investments
Institutional US Small Cap Core Equity ESG Fund, the FIE All-Purpose Fund, the Fisher Investments
Institutional European Equity Fund, the Fisher Investments Institutional Global Equity Fund, the Fisher
Investments Institutional Global Equity Focused Fund, the Fisher Investments Institutional Global Equity
High Yield Fund, the Fisher Investments Institutional Global Developed Equity Fund, the Fisher
Investments Institutional Global Developed Equity ESG Fund, the Fisher Investments Institutional US Small
and Mid-Cap Core Equity Fund, the Fisher Investments Institutional Emerging Markets Equity Fund (Cash
Limit), the Fisher Investments Institutional US Equity ESG Fund, the Fisher Investments Institutional
Emerging Markets Responsible Equity ex Fossil Fuels Fund, the Fisher Investments Institutional Emerging
Markets Concentrated Equity ESG Fund, the Fisher Investments Institutional Global Sustainable Equity
Impact ESG Fund, the Fisher Investments Institutional Quantitative Global Equity ESG Fund, the Fisher
Investments Institutional Emerging Markets Hard Currency Government Bond Fund, the Fisher Investments
Institutional US High Yield Bond Fund, the Fisher Investments Institutional China A-Shares Equity Fund,
the Fisher Investments Institutional US All Cap Equity ESG Fund, the Fisher Investments Institutional
Emerging Markets Sustainable Equity Impact ESG Fund, the Fisher Investments Institutional Global Small
Cap Equity ESG Fund, the Fisher Investments Institutional Global Low Volatility Equity Fund, and the
Fisher Investments Institutional Global ex-US Equity ESG Fund.
FI acts as the investment manager for the Fisher Investments Institutional Funds plc, an open ended
investment company with variable capital incorporated in Ireland under the Irish Companies Act 1963 to
2009 with registered number 496650 and authorized as a UCITS by the Central Bank of Ireland, which is
currently comprised of twenty-four sub-funds: the FI Institutional Emerging Markets Equity Fund, the FI
Institutional Emerging Markets Equity Selection Fund, , the FI Institutional Global Small Cap Equity Fund,
the FI Institutional US Small Cap Core Equity Selection Fund, the FIE All-Purpose Fund, the FI Institutional
European Equity Fund, the FI Institutional Global Equity Selection Fund, the FI Institutional Global Equity
Focused Fund, the FI Institutional Global Equity High Yield Fund, the FI Institutional Global Developed
Concentrated Equity Selection Fund the FI Institutional Global Developed Equity Selection Fund, the FI
Institutional US Small and Mid-Cap Core Equity Fund, the FI Institutional US Equity Selection Fund, the
FI Institutional Emerging Markets Responsible Equity Fund, the FI Institutional Global Sustainable
Equity Impact Fund, the FI Institutional Quantitative Global Equity Selection Fund, the FI
Institutional Emerging Markets Hard Currency Government Bond Fund, the FI Institutional US High
Yield Bond Fund, the FI Institutional China A-Shares Equity Fund, the FI Institutional US All Cap
Equity Selection Fund, the FI Institutional Global Small Cap Equity Selection Fund, the FI
Institutional Global ex-US Equity Selection Fund, the FI Institutional Global Responsible Equity
ESG Fund, and the FI Institutional Global Developed Equity ESG Values Fund.
FI acts as the investment manager for the Fisher Investments Trust, a Delaware statutory trust, which
currently has eight series: FI Institutional Group Emerging Markets Equity Fund, the FI Institutional Group
Foreign Equity Fund, the FI Institutional Group Global Small Cap Equity Fund, the FI Institutional Group
All Foreign Equity Fund, the FI Institutional Group All Foreign Small Cap Equity Fund, the FI Institutional
Group All Foreign Small Cap Equity Quant Fund, the FI Institutional Group Emerging Markets Equity ESG
Fund, and the FI Institutional Group Emerging Markets Equity Opportunities Fund.
FI acts as investment adviser to the following bank-maintained collective funds: the Fisher Investments All
Foreign Equity Collective Fund; the Fisher Investments Emerging Markets Equity Collective Fund; the
Fisher Investments All World Equity Collective Fund; the Fisher Investments U.S. Fixed Income Collective
Fund; the Fisher Investments U.S. Equity Market Collective Fund, and the Fisher Investments U.S. Small
and Mid Cap Core Equity Collective Fund. Each is a Fund established under the Fisher Investments
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Collective Trust. SEI Trust Company is the trustee and manager.
FI acts as investment manager to the following Australian registered funds: the FIA Institutional Global
Equity Focused Fund, the FIA Institutional Global Small Cap Equity Fund, and the FIA Institutional
Emerging Markets Equity ESG Fund. Equity Trustees Limited is the Responsible Entity.
FI acts as investment manager to the following Australian registered funds: the Fisher Investments
Australasia Global Equity Focused Fund, the Fisher Investments Australasia Global Small Cap Equity Fund,
and the Fisher Investments Australasia Emerging Markets Equity ESG Fund. Equity Trustees Limited is the
Responsible Entity.
Where FI manages a separate account and invests those assets in a fund it also advises or manages, FI would
either waive its separate account advisory fee on assets invested in the fund or reduce its fee paid by the
funds to the extent of any other advisory fee charged by FI on those assets. Where the Personalized
Retirement Outcomes service invests participant assets into funds which pay FI a management fee, FI will
reduce the fee rate charged for the Personalized Retirement Outcome service by an amount equal to the
management fee rate it receives from the funds.
FI owns Fisher Investments Europe Limited, doing business as Fisher Investments UK (“FIUK”), an
investment firm in the United Kingdom whose main activities are marketing FI’s and its own investment
management services to prospective private clients in the United Kingdom, including providing investment
and pension transfer recommendations and marketing its own investment management services to and
managing assets for institutional clients in the United Kingdom, Switzerland, and Belgium, which are sub-
managed by FI. FI earns a sub-management fee for the sub-management services it provides to FIUK.
FI owns Fisher Investments Australasia Pty Ltd (“FIA”), a financial services licensee in Australia whose
primary purpose is to manage assets for wholesale clients in Australia and wholesale investors in New
Zealand that are sub-managed by FI. FI earns a sub-management fee for the sub-management services it
provides to FIA.
FI owns Fisher Investments Japan Limited (“FIJ”), a Delaware corporation with a branch in Japan that has a
discretionary investment management and investment advisory and agency licenses in Japan. FIJ’s primary
purpose is to manage assets for professional and general clients in Japan. FI earns a sub-management fee for
the sub-management services it provides to FIJ.
FI has a branch established in the Dubai International Financial Centre, whose primary purpose is to market
FI’s investment management services to prospective institutional clients in the Middle East.
FI owns Fisher Investments GmbH (“FIG”), an investment firm in Germany whose primary purpose is
to manage assets for private clients in Germany, Austria and Switzerland that are sub-managed by FI. FI
earns a sub-management fee for the sub-management services it provides to FIG. FIG owns Fisher
Investments Schweiz GmbH, a representative office of FIG that supervises the activities of tied agents
that introduce residents of Switzerland to FIG.
FI owns Fisher Investments Ireland Limited (“FII”), an investment firm in Ireland whose primary purpose is
to manage assets for private and institutional clients in Europe that are sub-managed by FI. FI earns a sub-
management fee for the sub-management services it provides to FII.
FI owns Fisher Investments Luxembourg, Sàrl (“FIL”), an investment firm in Luxembourg whose primary
purpose is to manage assets for private clients in Europe that are sub-managed by FI. FIL also engages in
insurance brokerage activities in France. FI earns a sub-management fee for the sub-management services it
provides to FIL.
FI owns Fisher Investments Arabia (“FISA”), a capital market institution in the Kingdom of Saudi Arabia
whose primary purpose is to manage assets for private and institutional clients in the Kingdom of Saudi
Arabia. FI earns a fee for investment management support it provides to FISA.
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FI owns Fisher Investments Singapore Pte. Ltd. (“FIS”), which holds a capital markets services license to
conduct fund management activity for accredited and institutional investors in Singapore. FI earns a sub-
management fee for the sub-management services it provides to FIS.
To improve fiduciary literacy and advance brand awareness, the Fisher Investments Institutional Group,
from time to time, may sponsor, either independently or with other managers, consultants, or advisers,
training and educational programs and conferences attended by retirement advisors and plan sponsor
fiduciaries.
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Code of Ethics and Personal Trading
Ethics and integrity are the bedrock on which the rest of our business is built. When FI employees invest for
their own accounts, conflicts of interest may arise between clients and employees. As an investment adviser
and mutual fund adviser, FI is subject to Rule 204A-1 of the Advisers Act and Rule 17j-1 of the Investment
Company Act of 1940, as amended. To comply with these requirements, FI has adopted a Code of Ethics
containing provisions reasonably necessary to prevent its “Access Persons,” as defined in the Code of Ethics,
from engaging in any act, practice or course of business prohibited by the Rules. The Code of Ethics
addresses investments by Access Persons in securities with particular rules for initial public offerings and
limited offerings.
In accordance with FI’s Code of Ethics, all Access Persons are required to have most security transactions
including all common stock, options, corporate bonds, exchange traded funds, and trades in mutual funds
where FI is the sub-adviser to the fund company approved in advance by designated personnel involved in
the trading process. Access Persons and FI Principals have bought, owned, and sold securities in various
publicly traded corporations, including those held and traded in clients’ accounts or in the funds managed or
advised by FI.
Access Persons and Principals may hold securities, which were purchased previous to their employment with
FI, and are now still held. Access Persons and Principals whose accounts are managed by FI may participate
in block transactions placed for clients. Additionally, Access Persons and Principals must submit all
brokerage statements, which reflect transactions for their benefit, to ensure this policy is implemented
according to stated objectives. FI will provide a copy of its Code of Ethics upon request.
FI has adopted policies and procedures designed to address potential conflicts that arise between FI and its
minority owners. These policies and procedures include information barriers designed to prevent the flow of
portfolio holdings and trading information between FI, its personnel and its minority owners; and restrictions
relating to brokerage selection and trading with entities under control of its minority owners. No assurance
can be made that any of FI’s current policies and procedures, or any policies and procedures that are
established by FI in the future will have their desired effect.
In addition to these explicit policies, we also stress ethics in our company vision statement, which states that
“our quest requires delivering unparalleled service, continuous education, and appropriate solutions to our
clients and always considering their interests first.” Likewise, ethics and integrity are a core component of
employee performance reviews, where they are listed as an explicit competency and factor directly into
performance evaluations.
Participation or Interest in Client Transactions
FI imposes restrictions upon itself and all managed accounts that have a relationship with an FI Access
Person or Principal to ensure the clients’ interests are considered before the interests of FI or any person
associated with FI. Such accounts are called proprietary accounts. They will trade in block trades with or
after non-proprietary clients. Exceptions may be made to liquidate certain previously held equity positions in
proprietary accounts that cannot be blocked with non-proprietary clients provided a determination is made
that no non-proprietary client will be disadvantaged. All proprietary clients are aware of such trading
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practices. At no time will transactions be effected in any manner such that FI or the FI Access Person could
benefit at the expense of a non-proprietary client.
Political Contributions
FI personnel may make personal contributions to support political candidates or elected officials,
including candidates who may share the firm's views on issues related to its business interests. Designated
personnel are responsible for ensuring that their political activities comply with applicable laws restricting
political contributions and solicitations, as well as FI's policies and procedures.
Brokerage Practices
Selecting Brokerage Firms
FI generally determines both the brokers to be used to effect transactions for clients and the commissions at
which those transactions are to be effected. Brokers are selected on the basis of the clients’ interests,
requirements and preferences as well as FI’s assessment of the brokers’ execution and other services relative
to the commission charged for each trade. FI evaluates brokers’ fees and commission rates in light of rates
other advisers could readily obtain from brokers in general for similar transactions.
Each client’s investment advisory agreement generally gives FI full authority to determine (without
obtaining client consent or consulting with the client on a transaction-by-transaction basis) the brokers or
dealers through which all transactions for the client’s account will be executed. A client may, however, direct
FI to execute transactions for the client’s account through a specified broker or dealer (the “Specified
Broker”). A client may choose to direct FI in writing to execute transactions through a Specified Broker if,
for example, the client will be receiving investment management consulting services from such Specified
Broker.
FI has delegated a portion of its trading function for certain markets and securities to its affiliate, Fisher
Investments Luxembourg, Sàrl, (“FIL”) subject to the oversight of FI.
Best Execution
Where a client authorizes and the custodian does not restrict FI to select the brokers and/or dealers through
which transactions for the client’s account are executed, FI allocates transactions to brokers and/or dealers
for execution on such markets at such prices and at such commission rates (which may be in excess of the
prices or commission rates that might have been charged for execution on other markets or by other brokers
or dealers) as in the good faith judgment of FI are appropriate. FI considers the selection of brokers and/or
dealers based not only on the available prices and rates of brokerage commissions, but also other relevant
factors which can include:
(a) the execution capabilities of the brokers and/or dealers;
(b) the size of the transaction;
(c) the difficulty of execution;
(d) the operational facilities of the brokers and/or dealers involved;
(e) the risk in positioning a block of securities;
(f) custodian relationship; and
(g) the quality of the overall brokerage services provided by the broker and/or dealer.
FI may cause a client’s account to pay a broker or dealer a higher amount of commission for effecting a
transaction for the client’s account than another broker or dealer would have charged for effecting that same
transaction if FI determines in good faith that the amount of commission is reasonable in relation to the value
of the brokerage and research services provided by the broker or dealer, viewed in terms of either the
particular transaction or FI’s overall responsibilities with respect to the accounts for which FI exercises
investment discretion.
Where a client directs FI to effect transactions for the client’s account through a Specified Broker, FI does
not negotiate brokerage commissions with respect to transactions executed by the Specified Broker for the
client’s account. Rather, the client and the Specified Broker agree on the commission rate that the Specified
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Broker will charge for transactions effected for the account. As a result, the client may pay higher
commissions than those paid by FI’s clients who have not directed FI to execute transactions through a
specified broker or dealer depending upon:
(a) the client’s arrangement with the Specified Broker;
(b) such factors as the number of securities, instruments or obligations being bought or sold for the client,
whether round or odd lots are being acquired for the client and the market for the security, instrument
or obligation;
(c) the fact that the client will be foregoing any benefit from savings on execution costs that FI may
obtain for its clients through negotiating volume commission discounts on batched transactions.
In addition, the client may not receive the lowest available price with respect to certain transactions effected
for the client’s account. Clients that restrict the ability to execute trades for their accounts away from their
custodian through a prime broker services agreement may receive lower commissions for certain trades, but
may also be traded separately in a less advantageous manner than those trades which can be aggregated with
other accounts that allow for prime brokerage. Smaller size and certain other accounts are not eligible for
prime brokerage.
To the extent FIL places trades on behalf of client accounts, FIL will abide by its best execution policy,
which is substantially similar to FI’s best execution policy described above.
Soft Dollars
FI does not have any formal soft dollar arrangements where it uses a portion of commissions generated by
trades by clients’ accounts to pay specific amounts for research products and brokerage services from broker-
dealers or research vendors. However, broker-dealers that custody client assets or effect securities
transactions provide their own research services such as reports, access to website materials, and access to
their analysts. In some cases, FI uses that research if it is believed to be useful and of reasonable value, which
can be considered a soft-dollar benefit for FI even though there is no specific allocated amount of
commissions in order for FI to receive those benefits nor is there believed to be any impact to the transaction
costs for our clients. Additionally, some broker-dealers also provide FI with unsolicited research that FI
considers to have limited value and does not use, which also are technically considered soft dollar benefits
for FI.
Generally speaking, all of FI’s clients benefit from research services provided to FI by the brokers and
dealers who effect transactions for FI’s client accounts. FI periodically considers the value and usefulness of
proprietary research services available through broker-dealers as part of assessing FI’s overall relationship
with a broker-dealer and the quality of services provided, but FI does not make specific trading or
commission allocation decisions based on the research provided. FI’s receipt of research services from
brokers and dealers that effect transactions for FI’s client accounts does not reduce FI’s customary research
activities.
Order Aggregation
FI has adopted the following allocation policy and procedure for aggregating advisory clients’ trade orders.
• Orders will not be aggregated unless aggregation is consistent with our best execution duty and
the applicable advisory agreements.
• No advisory account will be consistently favored over any other account.
• Before entering an aggregated order, an electronic summary of the proposed allocation shall be made
in connection with that order.
FI’s IPC determines the securities to be purchased and sold in client accounts where FI acts with discretion.
FI will aggregate all Private Client group orders directed by the IPC by internal custodian designation
(“custodian code”), trade objective (“PM Order Reason”), and/or strategy group. The custodian code is
determined by, but not limited to, a combination of the Private Client account’s custodian, prime brokerage
eligibility, and order size. Blocks are not aggregated across custodians, and each custodial block would be
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treated as a separate brokerage ticket. Orders across Institutional and Private Clients will not be blocked and
will be executed separately.
FI uses Charles River (“CRD”) as its Order Management System (“OMS”). CRD facilitates the execution
of trades for the Institutional Group and Private Client Group.
• When transactions are aggregated into blocks:
– The actual execution prices applicable to the aggregated transaction will be averaged, and each
client account participating in the aggregated transaction will be deemed to have purchased or
sold its share of the security, instrument, or obligation involved at that average price; and
– All transaction costs incurred in effecting the aggregated transaction shall be shared on a pro
rata basis among all participating accounts, except to the extent certain broker-dealers that also
furnish custody services impose minimum transaction charges applicable to some of the
participating accounts. Client direction and restrictions may result in different costs for a
particular client.
• Where custodian limitations require us to send single orders, orders will not be blocked.
• For Private Clients, if it takes more than one day to complete a transaction for a security or group of
securities, the allocation order of accounts must be subject to a rotation by custodian within a
grouping of strategy models to ensure all accounts are treated equally over time. The IPC has
discretion in determining what grouping of strategy models trade together, including minimum
account sizes to avoid excessive costs to smaller accounts. A custodian rotation and random
allocation (CRD) is applied to each respective grouping. Within each custodian and strategy group,
“baskets” will be created by the Portfolio Implementation team as cash management tools, grouping
the trades within accounts and ensuring accounts are not debited during the random allocation
process. Baskets are randomly generated, and any basket that does not complete in full on a given
day will be allocated by CRD Account ID using the CRIMS Random Allocation Generator. Baskets
will be regenerated and randomized again if a subset of accounts is added to the custodian block
prior to the custodian being completed in full, and baskets are average priced by brokerage ticket
over the course of a trading day. Custodian rotations are tracked and the rotation is progressed with
the next block allocation. To ensure fairness in custodial rotations, a separate custodial rotation is
used for IPC-directed portfolio shifts and non-portfolio trades that affect a smaller subset of clients or
orders, including but not limited to trades resulting from corporate actions and tax optimizations.
• Orders will be allocated on a basis different from the above only if all clients receive fair treatment
and the reason for the different allocation is approved by a member of the IPC member in writing.
Common reasons for deviations include, but are not limited to, cash balance differences and relative
position sizes.
• Blocks executed with multiple brokers on a given day are allocated to the underlying accounts
using the CRIMS Random Allocation Generator.
• Groups of private client orders for a given security determined to be insignificant in size relative
to all existing orders for that security may be traded outside the rotation.
• During an IPC directed portfolio shift, FI traders may be executing given order(s) over multiple days
in a rotation. During this time, trades may have to be placed within client accounts to accommodate
client requests that overlap with the "Rebalance” orders. Where these orders are deemed non-
material/non-impactful to the broader rebalance, the Portfolio Implementation Group may enter
these orders as “Non-Rebalance” to be executed outside of the rotation as a separate custodial block
with a different average price from the “Rebalance” orders.
• Client mandated orders are generally segregated from existing blocks and executed at the market. If
it is deemed that executing the order at the market may have significant market impact, the order will
be executed with discretion.
• Certain private client accounts with special mandates or restrictions will not be included in the
rotation process. In order to satisfy the requirements and restrictions for these accounts, they will
be traded separately. For that reason, these accounts will normally be traded after trades have
been executed in other accounts managed by FI and, therefore these accounts have the potential
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to be executed on different terms, which can be less or more favorable and less promptly
depending on market conditions. Clients with these special accounts are informed of these
limitations.
• European private client custodian blocks may be traded outside the regular rotation if trading
cannot be executed at the appropriate time due to the absence of trading personnel at the
custodian’s local European offices or custodian specific execution restrictions. Rotation
deviations of this nature may cause the clients to receive better or worse execution prices than
would be received if they remained in the regular rotation.
• Private client orders to unwind option positions associated with equity positions will be
segregated from existing blocks. The equity and option orders will generally be executed as
close together as possible.
• Sell short orders will be segregated from sell orders.
• Trades that require shortened settlement will be segregated from existing blocks.
• Trades placed to correct errors in client accounts will be executed at the market separately from
any existing blocks and will not be aggregated with any IPC block trades. If it is deemed that
executing the order at the market may have significant market impact, the order will be executed
with discretion.
• Orders of material size entered in individual accounts as compared to other accounts within an
•
existing block may be segregated and executed separately for the purpose of saving such clients
explicit cost (commission). Additionally, if an order is entered intraday and blocking with
existing orders may significantly change the average price of the block, the order may be
segregated and executed separately at the discretion of the Trading department.
If the custodian/broker receives multiple orders for the same side and symbol at different times
and is unable to average price all executions due to system limitations, it is permissible to book
such trades at their different, respective prices.
• FX trade orders for Private Clients are executed outside of Fisher’s OMS directly in client
accounts with the applicable custodian. Private Client FX trade orders will not normally be
aggregated because of the varied timing and custodians involved for affected clients.
• Books and records will reflect separately for each account the securities held, bought, and sold.
•
Individual investment advice and treatment will be provided to each client’s account.
• FI does not participate in initial public offerings and therefore has no allocation policy with
respect to such offerings.
• No additional compensation or remuneration of any kind will be received by FI as a result of the
procedure referenced above.
Trading Errors
Trading errors sometimes happen for various reasons that may or may not be FI’s responsibility. FI handles
trading errors according to its trade error policy and procedure, including the use of trade error accounts
intended to absorb unfavorable consequences of trade errors (as well as favorable consequences when
deemed not beneficial to the client) to reduce the chance that clients would be affected. FI aggregates the
balances of its error accounts among various broker-dealer and bank custody accounts on a quarterly basis to
determine whether to donate aggregate gains to charity or to contribute to one or more accounts for aggregate
losses. In any event, the client will always be made whole and soft dollars will never be used to correct trade
errors.
Review of Accounts
Periodic Reviews
Account information, including quantities and values of securities held, the amounts of cash and cash
equivalents, and account transaction activity for each client is maintained in FI’s computer systems. This
account information is reconciled against statements or electronic files from appropriate custodial agents
generally daily, but no less than monthly.
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Review Triggers
All existing managed accounts are subject to periodic reviews depending on the criteria being evaluated.
Most reviews utilize computer-generated exception reports from FI’s portfolio management and accounting
systems. Cash balance, position count, position size, asset allocation, country weight, and sector weight
reports are among the measures periodically evaluated. Additionally, ad hoc reports supplement the review
process. FI’s Implementation Manager, under the supervision of the Group Vice President of Research,
oversees the daily operations of the existing account review process.
The IPC consists of five members: the Executive Chairman, a Vice Chairman, an Executive Vice President,
and two Senior Vice Presidents. They collectively determine firm investment policy and are responsible for
managing broad investment strategies. All are actively engaged in securities and capital markets research
contributing to the review process.
Regular Reports
Clients receive a quarterly accounting showing asset value by security, unit cost, total cost, cash balances,
current per share values, etc. Clients are urged to compare the quarterly reports provided by FI with those
provided by their custodian and notify FI of any differences. Additionally, clients regularly receive Quarterly
Reviews, which include the IPC’s general economic outlook and current investment trends. Clients are
encouraged to phone or write FI as often as they deem necessary to receive information regarding the
investment tactics and strategies being followed. Upon specific client request, FI will prepare written
portfolio analysis and reports to satisfy the client’s informational needs.
Client Referrals and Other Compensation
Referrals
From time to time, FI has client referral relationships with outside vendors and will pay a referral fee to these
vendors. There is no increase in fees that clients will pay Fisher as a result of the referral fees that fi pays to
outside vendors. Conflicts of interest exist with respect to these referral relationships, as FI receives certain
economic benefits through its participation in these relationships. FI also has incentives for its personnel to
solicit and refer clients. FI occasionally pays a referral fee to third-party solicitors. No referral fee is paid
unless the referral arrangement and any compensation paid are disclosed. FI’s participation in referral
relationships does not reduce or eliminate FI’s fiduciary duties to put the interests of its clients first and seek
best execution in securities transactions on behalf of its clients.
FI receives compensation to refer prospective clients and clients to non-affiliated investment advisers.
Conflicts of interest exist with these referral relationships. No referral will occur unless consent has been
obtained from the prospective client or client and the referral arrangement and any compensation paid are
disclosed.
Other Compensation
FI has obligations under referral programs with custodians with respect to certain clients, including certain
clients who become clients of FI as part of its merger and acquisition activities. Pursuant to such programs,
FI is obligated to pay the custodian an ongoing fee, usually as a percentage of the fees billed to the account or
a percentage of the assets in the account, with a one-time fee generally payable in the event the account is
transferred away from such custodian. Since the one-time fee is generally higher than the ongoing fee, FI
will have an incentive to maintain the account at the existing custodian.
FI receives very limited income from speaking, writing, and royalties—all related to finance and investing.
Ken Fisher receives royalties from his books. In addition, FI currently receives income for books published
under Fisher Investments Press, an imprint series published by John Wiley & Sons, Inc.
Custody
Account Statements
FI is not a broker-dealer and does not take possession of client assets. FI client assets are housed in nationally
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recognized brokerage firms and banks, otherwise known as custodians. FI has a limited power of attorney to
place trades on the client’s behalf. The custodian will issue trade confirmations and monthly statements
directly to clients, while the client’s account will be managed by FI. Clients are urged to compare the
information in their quarterly FI statements with the statements provided by their custodian.
FI will work with the client and custodian to open and establish a custodian account. It is possible a
prospective client will be assigned to a new custodian even if their existing account is at a custodian FI uses.
Once opened, FI will notify the client of the custodian’s name, address, and the manner in which the funds or
securities are maintained, and promptly thereafter of any changes to this information.
Direct Debit of Fees
FI does have the ability to directly debit fees from clients’ accounts. FI has policies and procedures in place
to ensure fees are calculated correctly and in accordance with clients’ agreed upon rates. Refer to the Fee
Billing under Fees and Compensation section above.
Investment Discretion
Discretionary Authority for Trading and Limited Power of Attorney
FI generally has limited power of attorney to act on a fully discretionary basis on clients’ behalf. When such
limited powers exist between FI and a client, FI chooses the amount and type of securities to be bought and
sold to satisfy account objectives. This is the case with most of FI’s clients. Additionally, FI accepts any
reasonable limitation or restriction to such authority placed by the client. Refer to the Methods of Analysis,
Investment Strategies and Risk of Loss section above. All limitations and restrictions placed on accounts
must be provided to FI in writing.
Voting Client Securities
Proxy Votes
Generally, except to the extent that a client otherwise instructs FI in writing, FI will vote (by proxy or
otherwise) on all matters for which a shareholder vote is solicited by, or with respect to, issuers of securities
beneficially held in client accounts in such manner as FI deems appropriate in accordance with its written
policies and procedures. These policies and procedures set forth guidelines for voting (or abstaining from
voting) many typical proxy proposals. FI regularly reviews these guidelines. In certain instances the IPC will
determine it is in the client’s best interest to vary from the guidelines or the proxy issue will require
individual case-by-case consideration under the guidelines. Where a proxy proposal raises a material conflict
of interest between the interests of FI and its clients, FI will vote in accordance with the guidelines where FI
does not have discretion to vary from the guidelines. Alternatively, FI will obtain voting direction from
Institutional Shareholder Services (“ISS”), an independent third-party proxy service provider, disclose the
conflict of interest to the client and abstain from voting, or obtain client consent prior to voting the securities.
Clients may obtain a copy of FI’s proxy voting policies and procedures and/or information on how FI has
voted the client’s securities by written request to FI. There may also be a variety of corporate actions or other
matters for which shareholder action is required or solicited and with respect to which FI may take action
that it deems appropriate in its best judgment except to the extent otherwise required by agreement with the
client. These actions may include, for example and without limitation, tender offers or exchanges, and
bankruptcy proceedings. Unless FI otherwise agrees in writing, FI will not have any duty or obligation to
advise or take any action on behalf of clients in any legal proceedings, including bankruptcies or class
actions, involving securities held in or formerly held in the client’s account or the issuers of securities. At the
client’s written request, FI will assist when practical with administrative matters regarding any settlement or
judgment.
Financial Information
Financial Condition
FI does not require or solicit prepayment of fees. FI is currently not in, nor has been historically in a
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financially precarious situation, or the subject to a bankruptcy petition.
Additional Information: Fair Valuation
In separate accounts and certain funds FI manages, FI is responsible for determining the fair value of illiquid
securities and other holdings in the unlikely event a price is not readily available or after a significant event
materially affects the value of a security between the time of its last sale on the exchange or market in which
the security trades, and the US market close. FI’s Valuation Committee meets as necessary when a price is
not readily available and will determine if the value of a security should be re-evaluated to reflect a more
current fair market value. Custodians for some clients have alternative valuation procedures that will apply to
accounts managed by FI. Some funds, including the collective funds advised by FI, are subject to the
valuation policies of their trustee or administrator.
Additional Information: Privacy
FI is committed to privacy and will only use information by which individuals can be identified (“Personal
Data”) in accordance with its Joint FIUK and FI privacy and cookie policy for UK-based individuals located
at https://www.fisherinvestments.com/en-gb/privacy. This policy applies to Fisher Investments UK’s
website and all interactions of Fisher Investments UK and/or FI with UK-based individuals.
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