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Disclosures

About Gresham Investment Management

Gresham Investment Management LLC ("Gresham") is a U.S. registered investment adviser with the U.S. Securities and Exchange Commission ("SEC"). Gresham is also registered with the Commodity Futures Trading Commission ("CFTC") as a Commodity Pool Operator ("CPO") and Commodity Trading Advisor ("CTA") and is a member of the National Futures Association ("NFA").

Registration with the SEC as an investment adviser does not imply any particular level of skill, expertise, training, or endorsement by the SEC or any other governmental authority.

The information contained on this website is provided for informational purposes only and is intended for institutional investors, financial professionals, consultants, and other qualified investors where permitted by applicable law. Nothing contained on this website constitutes an offer to sell or a solicitation of an offer to buy any security, commodity interest, investment product, or advisory service.

Any offer or solicitation may be made only through definitive offering documents, subscription agreements, investment management agreements, and related materials, and only in jurisdictions where permitted by law.

Nothing on this website should be construed as investment, legal, accounting, tax, or other professional advice. Prospective investors should consult their own professional advisers before making any investment decision.

Jurisdictional Restrictions

This website is not directed to, and should not be relied upon by, any person in any jurisdiction where the publication or availability of this website would be contrary to local law or regulation. Persons who access this website are responsible for determining whether access to and use of the website is permissible under applicable local laws and regulations.

Information contained on this website may not be intended for retail investors outside the United States. Certain products and services described herein may be available only to professional, institutional, or otherwise eligible investors under applicable local regulations.

Investment Risks

All investments involve risk, including the possible loss of principal. Past performance is not indicative of future results, and there can be no assurance that any investment objective or target return will be achieved.

Investment strategies discussed on this website may be speculative, volatile, illiquid, and subject to a variety of risks. Investors should carefully review all applicable offering documents and risk disclosures before investing.

Any discussion of investment strategy, portfolio construction, risk management, market outlooks, or research views reflects current opinions and is subject to change without notice. Such information should not be relied upon as investment advice or a recommendation regarding any specific investment.

GreshamQuant Disclosures
Quantitative and Systematic Investing Risks

GreshamQuant strategies utilize quantitative, systematic, and model-driven processes. Quantitative models rely upon historical market data, statistical analyses, assumptions, and proprietary methodologies that may not perform as intended under future market conditions.

There can be no assurance that quantitative models will identify profitable investment opportunities or avoid losses. Performance may be adversely affected by changing market environments, inaccurate or incomplete data, technology failures, operational errors, or model limitations.

Trend Following and Alternative Investment Risks

Certain GreshamQuant strategies employ trend-following, quantitative forecasting, relative value, or other systematic investment techniques. These strategies may experience periods of underperformance, including during range-bound markets, rapid market reversals, low-volatility environments, or periods when historical relationships fail to persist.

Derivatives and Leverage Risks

GreshamQuant strategies may invest in futures, forwards, swaps, options, and other derivative instruments. Derivatives may involve leverage, which can magnify both gains and losses. Derivative investments are subject to additional risks, including liquidity risk, counterparty risk, valuation risk, and operational risk.

Technology, Model, and Cybersecurity Risks

Systematic investment strategies are dependent on technology infrastructure, data integrity, data feeds, third-party vendors, and proprietary models. Failures involving software, data feeds, telecommunications systems, cybersecurity events, third-party vendors, or operational processes may adversely affect investment performance.

Although Gresham maintains policies and procedures designed to protect information systems and confidential information, no cybersecurity program can completely eliminate risk. Cybersecurity incidents affecting Gresham, its service providers, counterparties, market infrastructure, or other third parties may adversely affect operations, investment activities, or investor information.

Gresham Commodities Disclosures
Commodity Investing Risks

Gresham Commodities strategies invest in commodity-related instruments, including futures, forwards, swaps, options, and other commodity-linked investments.

Commodity investing involves substantial risk and may be more volatile than traditional equity or fixed income investments. Commodity prices may be affected by numerous factors, including changes in supply and demand, weather conditions, geopolitical developments, government policies, trade restrictions, inflation expectations, currency movements, interest rates, transportation constraints, and broader economic conditions.

Long-Only and Long-Biased Strategy Risks

Certain Gresham Commodities strategies maintain long-only or predominantly long exposure to commodity markets. As a result, these strategies may be particularly affected by sustained declines in commodity prices and may experience significant losses during adverse market environments.

Unlike market-neutral strategies, long-only and long-biased strategies generally seek to benefit from rising commodity prices and may provide limited protection during broad commodity market downturns.

Commodity Index and Benchmark Risks

Certain strategies may seek exposure relative to commodity benchmarks, including the Bloomberg Commodity Index ("BCOM"), Bloomberg Commodity Total Return Index ("BCOMTR"), S&P GSCI, and other commodity indices.

Differences in futures contract selection, roll methodology, implementation timing, transaction costs, portfolio construction, and cash management may cause strategy performance to differ materially from benchmark returns.

Benchmarks are unmanaged and are not available for direct investment.

Bloomberg, Bloomberg Commodity Index, BCOM, BCOMTR, S&P GSCI, and certain other referenced indices are trademarks or service marks of their respective owners. Such index providers are not affiliated with Gresham and do not sponsor, endorse, sell, or promote any Gresham strategy or investment product.

Futures Curve and Roll Risks

Commodity futures investments are subject to risks associated with contract rollovers and changes in futures curve structure, including contango and backwardation. Such conditions can materially impact investment returns and may cause performance to differ significantly from changes in underlying spot commodity prices.

Sector and Single Commodity Concentration Risks

Strategies focused on a particular commodity or commodity sector may be subject to greater volatility and concentration risk than more diversified investment strategies. Events affecting a specific commodity market may have a disproportionate impact on performance.

Performance Information

Any performance information presented on this website is provided for informational purposes only.

Past performance is not indicative of future results. Investment returns will fluctuate and investors may lose some or all of their invested capital. Actual investor performance may differ from reported performance as a result of subscription timing, redemption timing, fee arrangements, expenses, and other factors.

Benchmark comparisons are provided solely for informational purposes. Benchmarks do not reflect fees, expenses, transaction costs, or investment management fees and are not available for direct investment.

Any forecasts, projections, estimates, expected returns, targets, or forward-looking statements are based upon assumptions and expectations that may not prove accurate. Forward-looking statements are inherently uncertain and are subject to numerous assumptions, risks, and uncertainties, many of which are beyond Gresham's control. Actual results may differ materially from those expressed or implied.

Any social media post or other communication that includes performance information, hypothetical performance, rankings, awards, testimonials, endorsements, third-party ratings, or statements about investment results should be reviewed with its accompanying disclosures and is subject to applicable legal, regulatory, and compliance requirements.

Hypothetical Performance

Hypothetical, model, back-tested, simulated, or projected performance results have inherent limitations and do not represent actual trading. Such results are prepared with the benefit of hindsight and are based on assumptions that may not prove valid. Actual results may differ materially from those reflected in hypothetical performance information.

Hypothetical performance information, if presented, should not be relied upon as an indication of actual or future performance and may not reflect the impact of certain market, liquidity, operational, or implementation factors that may have affected actual trading results.

Testimonials, Endorsements, Ratings, and Awards

Any testimonial, endorsement, third-party rating, award, ranking, or similar statement appearing on this website or on any Gresham social media platform may not be representative of the experience of all clients and is not a guarantee of future performance or success.

No testimonial, endorsement, rating, award, ranking, or similar statement should be construed as a recommendation of Gresham or any investment strategy, product, or advisory service except to the extent expressly stated and accompanied by any disclosures required under applicable law.

Investor Eligibility

Many investment products sponsored or managed by Gresham are available only to investors meeting specific eligibility requirements under applicable laws and regulations. Depending on the investment product, investors may be required to qualify as Accredited Investors, Qualified Eligible Persons, Qualified Purchasers, Professional Investors, Institutional Investors, or other classifications as defined under applicable law.

Investment interests may not be offered, sold, or distributed in any jurisdiction except in accordance with applicable securities, commodities, and other laws and regulations.

Persons accessing this website are responsible for compliance with all applicable local laws and regulations.

CFTC Risk Disclosure

Trading commodity interests involves substantial risk of loss and is not suitable for all investors.

The risk of loss in trading commodity futures, options, swaps, foreign exchange transactions, and other derivative instruments can be substantial. Investors should carefully consider whether such trading is appropriate in light of their investment objectives, financial condition, and risk tolerance. In certain circumstances, losses may exceed amounts initially invested or committed.

Regulatory Disclaimer

THE COMMODITY FUTURES TRADING COMMISSION HAS NOT PASSED UPON THE MERITS OF PARTICIPATING IN ANY GRESHAM INVESTMENT PROGRAM NOR HAS THE COMMISSION PASSED ON THE ADEQUACY OR ACCURACY OF INFORMATION CONTAINED ON THIS WEBSITE. THIS WEBSITE IS NOT A CFTC OR NFA DISCLOSURE DOCUMENT AND SHOULD NOT BE RELIED UPON AS SUCH.

ESG, Sustainability, and Climate-Related References

References to environmental, social, governance ("ESG"), sustainability, climate-related, responsible investing, energy transition, carbon markets, or similar factors do not imply that such factors are determinative of investment decisions and should not be interpreted as indicating that any investment strategy pursues ESG objectives unless expressly stated in applicable offering documents.

Any ESG, sustainability, or climate-related statements are subject to evolving data, methodologies, standards, regulatory expectations, and market practices, and may change over time.

Social Media and Third-Party Platforms

Social media posts, including posts on LinkedIn or other third-party platforms, are provided for informational purposes only and should be read together with the disclosures and regulatory information on this website. Social media content does not constitute an offer to sell or a solicitation of an offer to buy any security, commodity interest, investment product, or advisory service, and should not be relied upon as investment advice or a recommendation regarding any investment strategy or product.

Links to this page may be used to provide additional disclosure and regulatory information in connection with Gresham website content or social media posts, as applicable. However, these disclosures are not intended to replace any disclosures required to accompany a specific communication, including any social media post containing performance information, hypothetical performance, testimonials, endorsements, rankings, awards, ratings, or other regulated content.

Third-Party Information

This website may contain information obtained from third-party sources that Gresham believes to be reliable. However, Gresham does not guarantee the accuracy, completeness, or timeliness of such information and assumes no responsibility for errors, omissions, or inaccuracies.

Gresham is not responsible for the terms of use, privacy practices, content presentation, or functionality of third-party platforms, including LinkedIn. Any content viewed through a third-party platform may be subject to that platform's own terms, conditions, and data practices.

References to, links to, reposts of, or interactions with third-party content on social media or other platforms should not be interpreted as an endorsement, recommendation, approval, or adoption of such content by Gresham, unless expressly stated.

Intellectual Property

Unless otherwise noted, all content on this website, including text, graphics, logos, trademarks, service marks, charts, research, and other materials, is owned by Gresham or its licensors and may not be reproduced, distributed, modified, or republished without prior written consent.

All trademarks, service marks, trade names, and logos appearing on this website are the property of their respective owners.

Website Use

Nothing contained on this website shall create an advisory, fiduciary, or client relationship with Gresham. Such relationships may only be established through a written agreement.

All website content is provided "as is" and may be modified or updated without notice.

By accessing this website, you acknowledge that you have read and understood these disclosures and that your use of this website is subject to applicable laws and regulations.

Regulatory Resources and Additional Links

The following resources are provided for convenience and may assist visitors in accessing public regulatory information regarding Gresham.

  • SEC Investment Adviser Public Disclosure (IAPD): Gresham Investment Management LLC - CRD #134392 / SEC #801-64039. Link: SEC Investment Adviser Public Disclosure
  • NFA BASIC Registration Record: Gresham is registered with the CFTC as a CPO and CTA and is an NFA member. Investors can verify Gresham's registration status through NFA BASIC. Link: NFA BASIC Registration Record
  • Form ADV Part 2A: Gresham's current Form ADV Part 2A brochure is available through the SEC Investment Adviser Public Disclosure website. Link: SEC Investment Adviser Public Disclosure
  • Privacy Notice: Gresham's Privacy Notice provides information regarding the collection, use, and protection of personal information, as applicable. Link: Privacy Notice | Gresham