Overview
                                    
                                    
                                        
                                            The Adviser 
The Adviser is an investment firm organized as a Delaware limited liability company that has 
its principal place of business located in New York, New York. The Adviser is wholly owned 
by Integral Health Advisors, LP  which is owned primarily  by  Bhagwan Jay Rao (the 
“Principal”)  
The Adviser was formed in 2019 by the Principal. 
Adviser Services 
The Adviser provides discretionary investment advisory and sub-advisory services to sub-
advised accounts (referred to herein as “Managed Accounts”),  and also serves as the 
investment manager to affiliated pooled investment vehicles that are exempt from registration 
under the Investment Company Act of 1940, as amended  (the “1940 Act”), and whose 
securities are not registered under the Securities Act of 1933, as amended (the “Securities 
Act”) (each, a “Fund”, collectively, the “Funds”, and together with the Managed Accounts, the 
“Clients”).  The Funds are organized in a master-feeder structure. The Funds currently advised 
by the Adviser are Integral Health Newton, LP, a Delaware limited partnership (the “Onshore 
Fund”), Integral Health Newton, Ltd., an exempted company incorporated and existing under 
the laws of the Cayman Islands (the “Offshore Fund”), and Integral Health
                                        
                                        
                                             Newton Master 
Fund, LP, an exempted limited partnership existing under the laws of the Cayman Islands (the 
“Master Fund”). The Onshore Fund and the Offshore Fund pursue their objectives by investing 
substantially all of their assets in the Master Fund.  Integral Health GP, LLC, a Delaware 
limited liability company (the “General Partner”) serves as general partner to the Onshore 
Fund and the Master Fund. 
The Adviser may tailor the specific advisory services with respect to each Client based on the 
particular investment objectives and strategies as  described in the applicable  Client’s 
confidential offering memorandum, operating agreement, investment management 
agreement, sub-advisory agreement separate account agreement (as applicable) (referred to 
as, the “Governing Document(s)”).  The Governing Document(s) for a Managed Account 
may be tailored to reflect the specific needs of the Managed Account.  Investments by the 
Funds are restricted by the terms of each Fund’s Governing Documents. 
The Adviser does not participate in wrap fee programs. 
Assets Under Management 
As of December 31, 2023, the Adviser manages $815,150,147  in discretionary regulatory 
assets under management and $0 in non-discretionary regulatory assets under management.