Polus Capital Management Limited

• A percentage of assets under your management
• Performance-based fees

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

See the firm's brochure (dated March 31, 2026) for its fees and any account minimum, on the SEC's IAPD site.

$5,319,396,394 as of October 2026, filing dated March 31, 2026.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

• Portfolio management for pooled investment vehicles (other than investment companies)
• Portfolio management for businesses (other than small businesses) or institutional clients
• Other

Registration

SEC-registered investment adviser. Status as filed: Approved.

Registered since

2006 (20 years)

Employees

Total: 85. Performing investment advisory functions: 36.

Wrap fee program participation

No.

States registered or notice-filed

Not reported.

SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

3 Reports 3 disclosure items on Form ADV Item 11. View on IAPD.

Questions answered yes on this filing

Regulatory matters Items 11.C to 11.G

• 11.D(2) Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate was involved in a violation of investment-related regulations or statutes?
• 11.D(4) In the past ten years, has another federal regulator, a state regulator, or a foreign financial regulator entered an order against the firm or an advisory affiliate in connection with investment-related activity?

Civil court matters Item 11.H

• 11.H(1)(b) Has a domestic or foreign court ever found that the firm or an advisory affiliate was involved in a violation of investment-related statutes or regulations?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. What happened, and who was involved, is on the Disclosure Reporting Pages of the IAPD record. Reading a firm's disclosures

Regulatory assets under management: $2,022,527,991 in the October 2021 data and $5,319,396,394 in the October 2026 data, up 163%.

Total employees: 48 in October 2021 and 85 in October 2026.

As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.

1. April 2026
   • Employees performing advisory functions went from 40 to 36.
   • Regulatory assets under management went from $6,045,200,000 to $5,319,396,394 (-12%).
   • Updated its list of owners and control persons (Schedule A).
2. January 2026
   • Updated its list of owners and control persons (Schedule A).

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.