Overview
                                    
                                    
                                        
                                            Advisory Firm 
Blue Swell Asset Management Private Limited (“Blue Swell” or the “Firm”) is an exempt 
private company limited by shares, incorporated in Singapore on January 02, 2018. The Firm 
is wholly owned and controlled by Tomofumi Oda (“Mr. Oda”) who serves in the roles of 
Director, Chief Executive Officer and Chief Investment Officer for the Firm. Further, Mr. Oda 
serves as Director of Blue Swell Japan Market Neutral Master Fund (the “Master Fund”) and 
Blue Swell Japan Market Neutral Fund (the “Feeder Fund”) respectively, together with two 
other  independent  directors.  Both  the  Master  Fund  and  Feeder  Fund  (collectively,  the 
“Fund”) are exempted companies with limited liability, incorporated under the laws of the 
Cayman Islands.  
Currently,  the  Firm  acts  as  the  Investment  Manager  of  the  Fund.  Subject  to  control  and 
supervision of the Fund’s Directors, the Firm has full discretion to manage and invest the assets 
of the Fund.  
Further, the Firm acts as the Investment Adviser to certain private pooled investment vehicles 
which  are  managed  by  unaffiliated  SEC  registered  investment  advisers  (“Sub-Advised 
Funds”). 
No  registration  statement  has  been  or  will  be  filed  with  the  U.S.  Securities  and  Exchange 
Commission (the “SEC”) or any state securities authority with respect to any offering of the 
Fund.  The Shares have not been and will not be registered under the United States Securities 
Act of 1933, as amended (the “1933 Act”) or the securities laws of any of the states of the 
United  States.   Furthermore,  the  Fund  has not  been  and  will  not  be  registered  under the 
United States Investment Company Act of 1940, as amended (the “1940 Act”) since Shares 
will only be sold to US Persons who meet the status of “qualified purchasers”, as defined in 
the 1940 Act.  Each subscriber for Shares that is a US Person will be required to certify that 
it  is  an  “accredited  investor”  and  a  “qualified  purchaser”,  in  each  case  as  defined  under 
applicable US federal securities laws, thereby also qualifying as a “qualified eligible person” as 
defined  in  Rule  4.7  under  the  United  States  Commodity  Exchange  Act,  as  amended  (the 
“CEA”). 
 
Types of Services Offered 
The principal activity of the Firm is to provide discretionary investment management services. 
including  investment  advisory  services,  specializing  in  Asia  and  with  predominant  focus  on 
Japan related investments.  
The Firm provides
                                        
                                        
                                             investment management services to the Fund based on specific investment 
objectives and strategies. The Fund’s offering documents (as amended and supplemented from 
time  to  time)  set  forth  the  investment  guidelines  and/or  the  types  of  investments  to  be 
transacted  in  by  the  Firm on  behalf of the  Fund. Together  with  its  affiliates,  the  Firm  also 
provides investment advisory services to the Sub-Advised Funds. Collectively, both the Fund 
and Sub-Advised Funds are referred to as “Clients”. 
Ability to Tailor Services and Impose Restrictions 
The investment objective of the Fund is to achieve absolute returns through emphasis on deep 
fundamental understanding of investment ideas, analysis of companies across all industries and 
sectors from large cap to small cap, predominantly in Japan, in corporate research and investing 
across market cycles. The Firm provides investment management services to the Fund based 
on  the  specific  investment  objectives  and  strategies  of  the  Fund  and  not  individually  to 
investors in the Fund (the “Investors”). Since the Firm does not provide tailored advice to 
the Fund’s Investors, such investors should consider whether the Fund’s investment strategies 
are in line with their risk tolerance. The Firm and/or the Fund may from time to time enter 
into side letter agreements or other similar agreements (“Side Letters”) providing certain 
seed or strategic investors with additional and/or different rights.  
The Firm has entered into Side Letters with certain investors of the Fund. The Side Letters 
with certain investors of the Fund do not provide preferential liquidity or redemption rights 
to the respective investors of the Fund. In addition, there are no material potential conflicts 
to the Fund or its investors as the mentioned arrangements do not in any way serve as a 
detriment  to  the  Fund  or  its  investors.  The  Fund’s  Directors  may  reduce  the  minimum 
subscription amounts to the Fund in consultation with the Firm, subject to requirements under 
applicable laws. 
 
Wrap Fee Programs 
 
The  Firm  does  not  participate,  sponsor  or  act  as  a  portfolio  manager  for  any  wrap  fee 
programs.  
Client Assets 
As of December 31, 2023, the Firm has approximately US$1,187,508,987 regulatory assets 
under management, all of which it manages on a discretionary basis.    
Performances, fees and capital activity (i.e., subscriptions and redemptions) are denominated 
in US dollars (US$).