PartnerFacts
Data last updated: Oct 23, 2026, 5:45 PM ETLatest filing: Oct 22, 2026Now: Oct 24, 2026, 4:56 AM ET

Sponsor Check › Sponsor group

EE

Em Es Sfl

One sponsor team, 2 deal companies · Road Town, Tortola, Virgin Islands, British (as filed: D8)

Grouped because: 3 shared people, 3 shared management entities, same business address (2 issuers) (automatic match from the filings) · not the same sponsor?

2deal companies
$233.2Mreported sold
15investors
26Form D filings
2014–2026active
0new, last 12 mo

Data last updated Oct 23, 2026, 5:45 PM ET · Latest filing in this group Mar 25, 2026 · Courts (RECAP) last checked: Oct 24, 2026, 2:16 AM ET · SEC enforcement last checked: covered by the index scan as of Oct 24, 2026, 2:50 AM ET

The short version

Em Es Sfl is a sponsor group of 2 issuers that PartnerFacts links to one sponsor (shared people, shared management entity, same business address; automatic match from the filings), filing 26 Form D filings between Aug 2014 and Mar 2026.

What this means One team, 2 deal companies, about 12 years of track record in SEC filings. We link the companies because the same people or address appear on their forms — tap "Request a correction" if that is wrong.

Combined reported sold: $233.2M to 15 investors (latest filing per issuer). Industries as reported: Pooled Investment Fund (2). Issuers are based in Virgin Islands, British (as filed: D8) (2).

What this means $233.2M raised across the group, about $15.5M per investor. Amounts come from each company's latest Form D; they are what the sponsor reported, not audited figures.

Principal people: Anthony Steinberg (2 issuers, promoter), David Payne (2 issuers, executive officer and promoter), EM ES Fund Management LLC (2 issuers, executive officer, entity), EM ES Fund Management Ltd (2 issuers, executive officer, entity), EM-ES Fund Management LLP (2 issuers, executive officer and promoter, entity) and 1 more.

What this means The person on the most companies is usually the one running the show; their page lists every deal.

Activity: 0 new offerings in the last 12 months; latest filing Mar 25, 2026.

What this means No new raise filed in the past year.

Adviser registration (Form ADV) on record: EM-ES FUND MANAGEMENT LTD.; EM-ES FUND MANAGEMENT LLP.

Public records searched: federal courts (CourtListener / RECAP), SEC enforcement releases, state securities regulators (AZ, CA, DE, TX, WA), property records (NYC, FL, IL and TX counties) — none found.

What this means Nothing turned up where we looked (4 sources). That does not prove there is nothing — it means none was found in those sources on that date.

We compared 26 public filings for Em Es Sfl and found 11 differences, 2 worth asking the sponsor about: Investor count went down between filings; 10 people are no longer listed on a later amendment; and more below.

What this means These are differences between the sponsor's own SEC filings — both values, dates and sources are listed in Key records, section 4. Most have ordinary explanations; ask the sponsor.

What the community is saying

Community search for Em Es Sfl has not run yet — it is joining a line of 2,037 names; searches run around the clock at the hosts' allowed rate. Searched so far: 27 names.

Community comments are quoted as written by their authors. Sources searched: BiggerPockets forums (via DuckDuckGo, Brave, Bing and BiggerPockets search) and Reddit (search feed + public archive).

Key records

Five things investors ask first. Items still in human review are counted, not shown.

1. Lawsuits

None found in sources searched — federal courts (CourtListener / RECAP), checked Oct 24, 2026

What was searched

Sources searched: CourtListener bulk data (RECAP dockets as of 2026-09-30; recall-first rule 10-24) — federal district + bankruptcy courts State courts: not covered (one-tap state court links under Look further). PACER: not searched. · Last checked Oct 24, 2026, 2:16 AM ET.

State courts: not covered (one-tap state court links under Look further). No state offers a lawful automated statewide source PartnerFacts can use today. Texas (re:SearchTX) terms prohibit storing results in a database open to third parties; New York (WebCivil) and Massachusetts (MassCourts) require a browser check that blocks scripted queries; California has no statewide index (58 county portals; Rule of Court 2.503 grants name-based access case by case); Florida, Utah and Illinois offer paid or partial access whose terms for automated use are unverified. Washington (dw.courts.wa.gov; bulk index reports under a JISC data-dissemination agreement), Delaware (CourtConnect; Court of Chancery not included) and Arizona (apps.azcourts.gov/publicaccess, which has an official channel to request high-volume access) are the candidates; PartnerFacts will request written permission before any automated search. Federal courts are searched through CourtListener / RECAP.

2. Regulatory actions

None found in sources searched — SEC enforcement releases (index scan as of Oct 24, 2026, 2:50 AM ET) · state securities regulators: AZ, CA, DE, TX, WA (crawled Oct 23, 2026)

What was searched

SEC enforcement searched: SEC litigation releases and administrative proceedings — respondent names in the sec.gov index titles (30,205 releases, 1995-09-19 to 2026-10-23); release text is read only to confirm a candidate. Names that appear only in the body of a release are not found. — Searched SEC litigation releases and administrative proceedings (1995→ / 2007→) (30,205 records as of Oct 24, 2026, 2:50 AM ET) — nothing matched Em Es Sfl..

State securities regulators searched: AZ (Corporation Commission Securities Division), CA (DFPI — 16 of 12,159 DFPI respondent pages read so far; sponsor-name matches are read first), DE (DOJ Investor Protection Unit), TX (State Securities Board), WA (DFI) — last crawled Oct 23, 2026, 9:57 PM ET. Other states are not covered.

3. Bankruptcies

None found in sources searched — federal bankruptcy courts (CourtListener / RECAP), checked Oct 24, 2026

What was searched

Sources searched: Federal bankruptcy courts via CourtListener / RECAP archive (federal district courts, federal bankruptcy courts). State courts: not covered (one-tap state court links under Look further). PACER: not searched (RECAP only). · Last checked Oct 24, 2026, 2:16 AM ET.

State courts: not covered (one-tap state court links under Look further). No state offers a lawful automated statewide source PartnerFacts can use today. Texas (re:SearchTX) terms prohibit storing results in a database open to third parties; New York (WebCivil) and Massachusetts (MassCourts) require a browser check that blocks scripted queries; California has no statewide index (58 county portals; Rule of Court 2.503 grants name-based access case by case); Florida, Utah and Illinois offer paid or partial access whose terms for automated use are unverified. Washington (dw.courts.wa.gov; bulk index reports under a JISC data-dissemination agreement), Delaware (CourtConnect; Court of Chancery not included) and Arizona (apps.azcourts.gov/publicaccess, which has an official channel to request high-volume access) are the candidates; PartnerFacts will request written permission before any automated search. Federal courts are searched through CourtListener / RECAP.

4. Differences between public sources

No comparisons published

What is compared

No public statement by this sponsor group has been collected yet, so there is nothing to compare. Sources compared: the sponsor's own website (known from the issuer's own filings — Form C issuer website, EDGAR company profile — an approved profile claim or Form ADV Item 1.I of its matched adviser) · SEC Form D · SEC Form ADV (IAPD) · Internet Archive · No website is on file for this sponsor group yet.

11 differences found between the filings for Em Es Sfl — 2 worth asking about (compared 26 filings on Oct 24, 2026)

Worth asking · Apr 11, 2018 – Apr 11, 2019

Investor count went down between filings — EM ES SFL Hedge Investment SPV LP

The Apr 11, 2018 filing reports 3 investors; the Apr 11, 2019 Form D/A reports 1 investor.

What this means Investor counts normally only grow. A smaller number can mean investors left or were refunded, or a count was corrected. Ask the sponsor what happened.

Sources
Worth asking · Nov 29, 2017 – Mar 22, 2024

10 people are no longer listed on a later amendment

David Payne is no longer listed on the Mar 22, 2024 amendment — EM ES SFL Hedge Investment SPV LP · David Payne is no longer listed on the Nov 30, 2023 amendment — EM-ES Feeder Fund L.P. · EM-ES Fund Management LLP is no longer listed on the Apr 11, 2019 amendment — EM ES SFL Hedge Investment SPV LP · EM ES Fund Management LLC is no longer listed on the Apr 11, 2019 amendment — EM ES SFL Hedge Investment SPV LP · Anthony Steinberg is no longer listed on the Apr 11, 2019 amendment — EM ES SFL Hedge Investment SPV LP · and 5 more

What this means People leave; the issuer lists only current officers, directors and promoters. Ask why and who replaced them.

Sources
Note · Apr 11, 2018 – Apr 11, 2019

David Payne's role changed at EM ES SFL Hedge Investment SPV LP: executive officer → executive officer, promoter

The Apr 11, 2018 filing lists David Payne as executive officer; the Apr 11, 2019 Form D/A lists executive officer, promoter.

What this means Roles on Form D are self-reported by the issuer. A change can mean a real change in who runs the company, or just a different box ticked. Ask who makes decisions today.

Sources
Note · Nov 29, 2017 – Nov 29, 2018

David Payne's role changed at EM-ES Feeder Fund L.P.: executive officer → executive officer, promoter

The Nov 29, 2017 filing lists David Payne as executive officer; the Nov 29, 2018 Form D/A lists executive officer, promoter.

What this means Roles on Form D are self-reported by the issuer. A change can mean a real change in who runs the company, or just a different box ticked. Ask who makes decisions today.

Sources
Note · Aug 12, 2015 – Dec 2, 2015

EM-ES Fund Management LLP's role changed at EM-ES Feeder Fund L.P.: promoter → executive officer

The Aug 12, 2015 filing lists EM-ES Fund Management LLP as promoter; the Dec 2, 2015 Form D/A lists executive officer.

What this means Roles on Form D are self-reported by the issuer. A change can mean a real change in who runs the company, or just a different box ticked. Ask who makes decisions today.

Sources
Note · Apr 11, 2018 – Apr 11, 2019

Address moved from London, United Kingdom (as filed: X0) to Miami, FL — EM ES SFL Hedge Investment SPV LP

The people listed on the Apr 11, 2018 filing give London, United Kingdom (as filed: X0); on the Apr 11, 2019 filing they give Miami, FL.

What this means Businesses move; this just shows the two places and dates. If you were told one city and the forms say another, ask which is current.

Sources
Note · Nov 29, 2017 – Nov 29, 2018

Address moved from London, United Kingdom (as filed: X0) to Miami, FL — EM-ES Feeder Fund L.P.

The people listed on the Nov 29, 2017 filing give London, United Kingdom (as filed: X0); on the Nov 29, 2018 filing they give Miami, FL.

What this means Businesses move; this just shows the two places and dates. If you were told one city and the forms say another, ask which is current.

Sources
Note · Apr 11, 2018 – Apr 11, 2019

Minimum investment changed between filings — EM ES SFL Hedge Investment SPV LP

The Apr 11, 2018 filing lists a minimum of $1,000,000; the Apr 11, 2019 Form D/A lists $250,000.

What this means A different minimum usually means the offering terms changed. Check which terms apply to you.

Sources
Note · Aug 6, 2014 – Aug 12, 2015

Minimum investment changed between filings — EM ES SFL Hedge Investment SPV LP

The Aug 6, 2014 filing lists a minimum of $0; the Aug 12, 2015 Form D/A lists $1,000,000.

What this means A different minimum usually means the offering terms changed. Check which terms apply to you.

Sources
Note · Aug 6, 2014 – Aug 12, 2015

Minimum investment changed between filings — EM-ES Feeder Fund L.P.

The Aug 6, 2014 filing lists a minimum of $0; the Aug 12, 2015 Form D/A lists $1,000,000.

What this means A different minimum usually means the offering terms changed. Check which terms apply to you.

Sources
Note · Aug 6, 2014 – Mar 25, 2026

Issuer used a different name before — EM ES SFL Hedge Investment SPV LP

SEC records list prior names for this filer: RBC (EM ES SFL) Basket Reference Fund I LP. The current name on file is "EM ES SFL Hedge Investment SPV LP".

What this means A name change is normal, but your documents may show the old name. Match the CIK, not just the name.

Sources
What is compared

What is compared: every Form D and D/A we hold for this subject, side by side — filing dates vs. first-sale dates (the 15-day rule), amendment timing on open offerings (the yearly-amendment expectation), amounts sold, investor counts, offering amounts and minimums across amendments, industry and size bands, addresses, how each person's name and role is written, paid sellers' CRD numbers, and (for groups) where the member companies were formed and sit. Everything is as filed by the issuer; the SEC does not check it. Differences are common and usually have ordinary explanations — we show both values, the dates, and the source so you can ask. As of Oct 24, 2026.

5. Money to insiders

None reported on 2 offerings — no sales commissions, finder's fees or proceeds to insiders

Per-offering detail
Offering (latest filing)Sales commissionsFinder's feesTo insidersPaid to sell itSource
Mar 25, 2026 D/A
EM ES SFL Hedge Investment SPV LP
File 021-222426
$0$0$0
Customary management fees will be paid to EM-ES Fund Management Ltd, as disclosed in the Issuer's offering documents.
None listed on this filingEDGAR ↗
Dec 1, 2025 D/A
EM-ES Feeder Fund L.P.
File 021-222423
$0$0$0
Customary management fees will be paid to EM-ES Fund Management Ltd, as disclosed in the Issuer's offering documents.
None listed on this filingEDGAR ↗

Counts come from Form D Items 12–15 on the filings in our index (latest filing per offering; one offering = one SEC file number; an amendment updates its offering rather than adding one). "To insiders" = gross proceeds used for payments to executive officers, directors or promoters. "—" = not reported on that filing. Amounts marked (est.) were reported as estimates. "Paid to sell it" = sales compensation recipients named on that filing (Item 12), each linked to FINRA BrokerCheck when a CRD number is reported.

Counted across all 2 issuers in this group — every filing in our index, latest filing per offering (SEC file number).

Property records 0 documents · 0 ownership records · last checked Oct 23, 2026, 8:59 PM ET · NYC and Cook County lookup still to run

0 recorded documents and 0 ownership records matched to Em Es Sfl in the sources searched.

Not found in sources searched as of Oct 23, 2026, 8:59 PM ET: Hillsborough County FL Clerk of Court Official Records daily index (publicrec.hillsclerk.com D/P/M files), 2 daily files (Oct 14, 2026 to Oct 15, 2026) — loaded Oct 23, 2026, 8:59 PM ET; Florida DOR NAL roll (Hillsborough 39) roll year 2026 — loaded Oct 23, 2026, 8:54 PM ET; Florida DOR NAL roll (Dade 23) roll year 2026 — loaded Oct 23, 2026, 8:58 PM ET; Harris County Appraisal District real_acct.txt roll year 2026 — loaded Oct 23, 2026, 8:58 PM ET; Dallas Central Appraisal District ACCOUNT_INFO.CSV roll year 2026 — loaded Oct 23, 2026, 8:58 PM ET. Still to be looked up for this group: NYC ACRIS via NYC Open Data (Real Property Parties 636b-3b5g, Master bnx9-e6tj, Legals 8h5j-fqxa, Document Control Codes 7isb-wh4c) · NYC PLUTO ownership via NYC Open Data (64uk-42ks) · Cook County IL Assessor via Cook County Open Data (Parcel Sales wvhk-k5uv; Parcel Addresses 3723-97qp). Records in other counties, and recorder indexes we do not yet cover, were not searched.

Property records coverage: New York City (ACRIS recorded documents and PLUTO ownership, looked up per issuer when its page is viewed; re-checked when the page is viewed again more than 30 days after the last check); Hillsborough County FL (recorded documents from Oct 14, 2026 forward; ownership from FL DOR roll 2026); Cook County IL (assessor ownership and deed/sale records, looked up per issuer when its page is viewed); Harris County TX and Dallas County TX (assessor ownership rolls only, 2026 roll; no deed, mortgage or sale records); Miami-Dade County FL (ownership from FL DOR roll only; Clerk recorded documents not covered). Recorder indexes for TX, AZ, IL and WA counties, mortgages and liens outside NYC and FL, lis pendens and foreclosure notices everywhere, Miami-Dade County FL recorded documents, Maricopa County AZ, King County WA, Salt Lake County UT, and all other counties are not covered — not searched. Last refresh by source: Hillsborough County FL Clerk daily index Oct 23, 2026, 8:59 PM ET; Dallas Central Appraisal District ACCOUNT_INFO.CSV Oct 23, 2026, 8:58 PM ET; Harris County Appraisal District real_acct.txt Oct 23, 2026, 8:58 PM ET; Florida DOR NAL roll (Dade 23) Oct 23, 2026, 8:58 PM ET; Florida DOR NAL roll (Hillsborough 39) Oct 23, 2026, 8:54 PM ET. NYC and Cook County are looked up per issuer when its page is viewed; the most recent such lookup on this site finished Oct 24, 2026, 3:30 AM ET. Parties are named as the recorder's index names them (role suffixes as recorded); no address, account number or trust date is shown for an individual, and individual owners of record (home ownership) are not matched or shown. Items still in human review are not shown.

Issuers in this group

Why each issuer is here is stated in the "Linked by" column. Low-confidence links are never shown — they wait for human review.

SourceIssuerLinked byLocationIndustryFilingsSold (max)InvestorsMin. investment (latest filing)Active
EDGAR ↗EE EM-ES Feeder Fund L.P.shared people, shared management entity, same business addressROAD TOWN, TORTOLA, Virgin Islands, British (as filed: D8)Pooled Investment Fund13$105,944,055
offering Indefinite · similar: $155,000–$5,250,000
12
similar: 4–27
$1,000,000
similar: $1,000–$100,000
2014–2025
EDGAR ↗EE EM ES SFL Hedge Investment SPV LPshared people, shared management entity, same business addressROAD TOWN, TORTOLA, Virgin Islands, British (as filed: D8)Pooled Investment Fund13$127,265,217
offering Indefinite · similar: $155,000–$5,250,000
3
similar: 4–27
$250,000
similar: $1,000–$100,000
2014–2026

"Similar" = offerings in the same industry claiming the same exemption, filed in the last 5 years: Pooled Investment Fund / 506(b) (83,801 filings); ranges are the middle half (25th–75th percentile). Computed by PartnerFacts from SEC EDGAR Form D data as of Oct 23, 2026, 5:45 PM ET. Rows without a range: fewer than 30 comparable filings, or not a Rule 506 offering. No ranking or score.

Timeline of offerings

SourceFiledIssuerFormIndustryOfferedSold
EDGAR ↗Mar 25, 2026EM ES SFL Hedge Investment SPV LPD/APooled Investment FundIndefinite$127,265,217
EDGAR ↗Dec 1, 2025EM-ES Feeder Fund L.P.D/APooled Investment FundIndefinite$105,944,055
EDGAR ↗Mar 25, 2025EM ES SFL Hedge Investment SPV LPD/APooled Investment FundIndefinite$125,265,217
EDGAR ↗Nov 29, 2024EM-ES Feeder Fund L.P.D/APooled Investment FundIndefinite$103,344,055
EDGAR ↗Mar 22, 2024EM ES SFL Hedge Investment SPV LPD/APooled Investment FundIndefinite$120,615,217
EDGAR ↗Nov 30, 2023EM-ES Feeder Fund L.P.D/APooled Investment FundIndefinite$87,902,691
EDGAR ↗Mar 22, 2023EM ES SFL Hedge Investment SPV LPD/APooled Investment FundIndefinite$111,553,498
EDGAR ↗Dec 1, 2022EM-ES Feeder Fund L.P.D/APooled Investment FundIndefinite$74,822,972
EDGAR ↗Mar 22, 2022EM ES SFL Hedge Investment SPV LPD/APooled Investment FundIndefinite$99,153,221
EDGAR ↗Nov 30, 2021EM-ES Feeder Fund L.P.D/APooled Investment FundIndefinite$62,808,386
EDGAR ↗Apr 12, 2021EM ES SFL Hedge Investment SPV LPD/APooled Investment FundIndefinite$72,824,107
EDGAR ↗Nov 30, 2020EM-ES Feeder Fund L.P.D/APooled Investment FundIndefinite$56,564,144
EDGAR ↗Apr 13, 2020EM ES SFL Hedge Investment SPV LPD/APooled Investment FundIndefinite$70,824,107
EDGAR ↗Nov 27, 2019EM-ES Feeder Fund L.P.D/APooled Investment FundIndefinite$37,196,732
EDGAR ↗Apr 11, 2019EM ES SFL Hedge Investment SPV LPD/APooled Investment FundIndefinite$31,676,907
EDGAR ↗Nov 29, 2018EM-ES Feeder Fund L.P.D/APooled Investment FundIndefinite$37,196,732
EDGAR ↗Apr 11, 2018EM ES SFL Hedge Investment SPV LPD/APooled Investment FundIndefinite$20,929,465
EDGAR ↗Nov 29, 2017EM-ES Feeder Fund L.P.D/APooled Investment FundIndefinite$20,050,000
EDGAR ↗Apr 14, 2017EM ES SFL Hedge Investment SPV LPD/APooled Investment FundIndefinite$10,229,000
EDGAR ↗Dec 1, 2016EM-ES Feeder Fund L.P.D/APooled Investment FundIndefinite$10,900,000
EDGAR ↗Aug 8, 2016EM ES SFL Hedge Investment SPV LPD/APooled Investment FundIndefinite$8,900,000
EDGAR ↗Dec 2, 2015EM-ES Feeder Fund L.P.D/APooled Investment FundIndefinite$5,600,000
EDGAR ↗Aug 12, 2015EM ES SFL Hedge Investment SPV LPD/APooled Investment FundIndefinite$0
EDGAR ↗Aug 12, 2015EM-ES Feeder Fund L.P.D/APooled Investment FundIndefinite$5,000,000
EDGAR ↗Aug 6, 2014EM ES SFL Hedge Investment SPV LPDPooled Investment FundIndefinite$0
EDGAR ↗Aug 6, 2014EM-ES Feeder Fund L.P.DPooled Investment FundIndefinite$0

Activity: 0 new offerings in the last 12 months across all issuers in this group (new offering = a Form D that is not an amendment, D/A) · most recent filing Mar 25, 2026. Industry history, as reported on each offering's latest filing: All 2 offerings reported: Pooled Investment Fund (2014).

People across the group

NameRolesIssuers hereFirst → last listed
JM Jim MeadExecutive Officer, Promoter2Nov 30, 2023 → Mar 25, 2026
DP David PayneExecutive Officer, Promoter2Aug 6, 2014 → Mar 22, 2023
EE EM-ES Fund Management LLP entityExecutive Officer, Promoter2Aug 6, 2014 → Apr 11, 2018
EE EM ES Fund Management LLC entityExecutive Officer2Aug 6, 2014 → Apr 11, 2018
AS Anthony SteinbergPromoter2Aug 6, 2014 → Apr 11, 2018
EE EM ES Fund Management Ltd entityExecutive Officer2Dec 2, 2015 → Apr 11, 2018

Adviser registration (Form ADV)

EM-ES FUND MANAGEMENT LTD. — Exempt reporting adviser · SEC registration status as reported: “ERA - Active” since Apr 13, 2017 · SEC file 802-110452 · Main office: ROAD TOWN, TORTOLA · IAPD record ↗ · Form ADV filing (PDF) ↗

Regulatory assets under management: Not reported — exempt reporting advisers do not complete Form ADV Item 5.

Websites listed on Form ADV (Item 1.I): www.emesfunds.com ↗

Item 11 disclosure questions as answered on Form ADV filed Mar 26, 2026: 0 of 24 answered “Yes”
  • No — Form ADV Item 11 asks: “Do any of the events below involve you or any of your supervised persons?”
  • No — Form ADV Item 11A(1) asks: “A. In the past ten years, have you or any advisory affiliate: (1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony?”
  • No — Form ADV Item 11A(2) asks: “A. (2) been charged with any felony?”
  • No — Form ADV Item 11B(1) asks: “B. In the past ten years, have you or any advisory affiliate: (1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving: investments or an investment-related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses?”
  • No — Form ADV Item 11B(2) asks: “B. (2) been charged with a misdemeanor listed in Item 11.B(1)?”
  • No — Form ADV Item 11C(1) asks: “C. Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: (1) found you or any advisory affiliate to have made a false statement or omission?”
  • No — Form ADV Item 11C(2) asks: “C. (2) found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?”
  • No — Form ADV Item 11C(3) asks: “C. (3) found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted?”
  • No — Form ADV Item 11C(4) asks: “C. (4) entered an order against you or any advisory affiliate in connection with investment-related activity?”
  • No — Form ADV Item 11C(5) asks: “C. (5) imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?”
  • No — Form ADV Item 11D(1) asks: “D. Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: (1) ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical?”
  • No — Form ADV Item 11D(2) asks: “D. (2) ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?”
  • No — Form ADV Item 11D(3) asks: “D. (3) ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted?”
  • No — Form ADV Item 11D(4) asks: “D. (4) in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?”
  • No — Form ADV Item 11D(5) asks: “D. (5) ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory affiliate, by order, from associating with an investment-related business or restricted your or any advisory affiliate's activity?”
  • No — Form ADV Item 11E(1) asks: “E. Has any self-regulatory organization or commodities exchange ever: (1) found you or any advisory affiliate to have made a false statement or omission?”
  • No — Form ADV Item 11E(2) asks: “E. (2) found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approved by the SEC)?”
  • No — Form ADV Item 11E(3) asks: “E. (3) found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted?”
  • No — Form ADV Item 11E(4) asks: “E. (4) disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you or the advisory affiliate from association with other members, or otherwise restricting your or the advisory affiliate's activities?”
  • No — Form ADV Item 11F asks: “F. Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or suspended?”
  • No — Form ADV Item 11G asks: “G. Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C., 11.D., or 11.E.?”
  • No — Form ADV Item 11H(1)(a) asks: “H. (1) Has any domestic or foreign court: (a) in the past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity?”
  • No — Form ADV Item 11H(1)(b) asks: “H. (1)(b) ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations?”
  • No — Form ADV Item 11H(1)(c) asks: “H. (1)(c) ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a state or foreign financial regulatory authority?”
  • No — Form ADV Item 11H(2) asks: “H. (2) Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H(1)?”

Answers as filed by the adviser on Form ADV Part 1A, Item 11; question text quoted from the form. Details of each “Yes” are in the Disclosure Reporting Pages of the Form ADV (PDF) ↗.

Matched on management entity listed on Form D = adviser name, no state to compare · Form ADV data: SEC Investment Adviser Information Report (exempt reporting advisers), file dated 2026-10-02, loaded Oct 23, 2026, 8:39 PM ET · IAPD record last checked Oct 23, 2026, 8:36 PM ET

EM-ES FUND MANAGEMENT LLP — Exempt reporting adviser · SEC registration status as reported: “ERA - Active” since May 5, 2017 · SEC file 802-110581 · Main office: LONDON, ENGLAND · IAPD record ↗ · Form ADV filing (PDF) ↗

Regulatory assets under management: Not reported — exempt reporting advisers do not complete Form ADV Item 5.

Websites listed on Form ADV (Item 1.I): WWW.EMESFUNDS.COM ↗

Item 11 disclosure questions as answered on Form ADV filed Jun 12, 2026: 0 of 24 answered “Yes”
  • No — Form ADV Item 11 asks: “Do any of the events below involve you or any of your supervised persons?”
  • No — Form ADV Item 11A(1) asks: “A. In the past ten years, have you or any advisory affiliate: (1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony?”
  • No — Form ADV Item 11A(2) asks: “A. (2) been charged with any felony?”
  • No — Form ADV Item 11B(1) asks: “B. In the past ten years, have you or any advisory affiliate: (1) been convicted of or pled guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving: investments or an investment-related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses?”
  • No — Form ADV Item 11B(2) asks: “B. (2) been charged with a misdemeanor listed in Item 11.B(1)?”
  • No — Form ADV Item 11C(1) asks: “C. Has the SEC or the Commodity Futures Trading Commission (CFTC) ever: (1) found you or any advisory affiliate to have made a false statement or omission?”
  • No — Form ADV Item 11C(2) asks: “C. (2) found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes?”
  • No — Form ADV Item 11C(3) asks: “C. (3) found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted?”
  • No — Form ADV Item 11C(4) asks: “C. (4) entered an order against you or any advisory affiliate in connection with investment-related activity?”
  • No — Form ADV Item 11C(5) asks: “C. (5) imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity?”
  • No — Form ADV Item 11D(1) asks: “D. Has any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority: (1) ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical?”
  • No — Form ADV Item 11D(2) asks: “D. (2) ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes?”
  • No — Form ADV Item 11D(3) asks: “D. (3) ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted?”
  • No — Form ADV Item 11D(4) asks: “D. (4) in the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity?”
  • No — Form ADV Item 11D(5) asks: “D. (5) ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory affiliate, by order, from associating with an investment-related business or restricted your or any advisory affiliate's activity?”
  • No — Form ADV Item 11E(1) asks: “E. Has any self-regulatory organization or commodities exchange ever: (1) found you or any advisory affiliate to have made a false statement or omission?”
  • No — Form ADV Item 11E(2) asks: “E. (2) found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approved by the SEC)?”
  • No — Form ADV Item 11E(3) asks: “E. (3) found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted?”
  • No — Form ADV Item 11E(4) asks: “E. (4) disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you or the advisory affiliate from association with other members, or otherwise restricting your or the advisory affiliate's activities?”
  • No — Form ADV Item 11F asks: “F. Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or suspended?”
  • No — Form ADV Item 11G asks: “G. Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C., 11.D., or 11.E.?”
  • No — Form ADV Item 11H(1)(a) asks: “H. (1) Has any domestic or foreign court: (a) in the past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity?”
  • No — Form ADV Item 11H(1)(b) asks: “H. (1)(b) ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations?”
  • No — Form ADV Item 11H(1)(c) asks: “H. (1)(c) ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a state or foreign financial regulatory authority?”
  • No — Form ADV Item 11H(2) asks: “H. (2) Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H(1)?”

Answers as filed by the adviser on Form ADV Part 1A, Item 11; question text quoted from the form. Details of each “Yes” are in the Disclosure Reporting Pages of the Form ADV (PDF) ↗.

Matched on management entity listed on Form D = adviser name, different legal form as filed (LP vs LLC), no state to compare, issuer filed in D8 · Form ADV data: SEC Investment Adviser Information Report (exempt reporting advisers), file dated 2026-10-02, loaded Oct 23, 2026, 8:39 PM ET · IAPD record last checked Oct 23, 2026, 8:36 PM ET

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