Item 5: Performance-Based Fees .............................................................................................................. 6 Item 6: Types of Clients.............................................................................................................................. 7 Item 7: Methods of Analysis, Investment Strategies and Risk of Loss ............................................. 8 Item 8: Disciplinary Information ............................................................................................................ 11 Item 9: Other Financial Industry Activities and Affiliations ............................................................. 12 Item 10: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ....................................................................................................................................................................... 13 Item 11: Brokerage Practices ................................................................................................................. 14 Item 12: Review of Accounts ................................................................................................................. 15 Item 13: Client Referrals and Other Compensation ........................................................................ 16 Item 14: Custody ....................................................................................................................................... 17 Item 15: Investment Discretion ............................................................................................................. 17 Item 16: Voting Client Securities ........................................................................................................... 18 Item 17: Financial Information ................................................................................................................ 19 Item 2: Material changes Summary of Material Changes Our company filed its initial disclosure brochure in February 2011. This ADV Part 2A Brochure, dated March 2023, constitutes an annual amendment to our previously-filed brochure dated March 2022. Over the calendar year ending 31 December 2022 Fulcrum launched the following funds that are marked to US investors on a private placement basis:
• FULCRUM FUNDS II SPC - FULCRUM DYNAMIC CONVEXITY FUND SP
• FULCRUM FUNDS II SPC - FULCRUM HORIZON FUND SP
• FULCRUM FUNDS SPC - FULCRUM DISCRETIONARY MACRO FUND SP
• FULCRUM FUNDS SPC FULCRUM ENERGY INFRASTRUCTURE RENEWABLES FUND SP
• FULCRUM INFLATION PROTECTION STRATEGY MASTER FUND Additionally, as at the end of 31st December 2022, There have been no material changes in the partners and employees who make up Fulcrum Asset Management LLP. Item 3: Advisory Business Fulcrum Asset Management LLP (“Fulcrum”, the “Firm”) is an asset management company founded by Gavyn Davies and Andrew D. Stevens in 2004. Mr Davies and Mr Stevens are the Firm’s majority principal owners. Fulcrum has been registered as an investment adviser with the US Securities and Exchange Commission (“SEC”) since March 2011 and has been authorised and regulated by the Financial Conduct Authority (“FCA”) in the United Kingdom since April 2004. Fulcrum has been registered as a Commodity Pool Operator (“CPO”) with the Commodity and Futures Trading Commission (“CFTC”) and is also a member of the National Futures Association since January 2013. The Firm undertakes discretionary investment management services for a variety of clients comprising of funds and managed accounts (“accounts”). Fulcrum employs diverse investment management strategies, which are unified by a central research team and a focus on a global macro

strategy and thematic equity investment. Fulcrum provides on-going discretionary investment management services to 4 clients (of which 3 are Non-US clients). Fulcrum is also the investment adviser to a regulated investment company under the 1940 Investment Company Act Fund. Other funds, not sold in the US, are generally subject to either the European Union Undertakings for Collective Investment in Transferable Securities Directives (UCITS), the UK Alternative Investment Fund Directive (UK AIF), UK non-UCITS retail scheme (NURS), or as a managed scheme by the Australian Securities and Investments Commission. Each fund managed by the Firm may contain a number of different share classes, which differ as to matters such as reporting currency, minimum investment, redemption terms, treatment of income and fees. Individual accounts managed by Fulcrum will typically be invested across various asset classes and geographies. Before determining an appropriate asset allocation, the Firm obtains a thorough understanding of each client’s financial situation, return objectives and risk profile. Should clients wish to impose restrictions on investing in certain types of securities, then the Firm discusses and documents these requirements at the outset of the relationship. As at 31st December 2022, the Firm managed regulatory assets under management of US$ 1,378,973,758 billion across all funds and managed accounts, all of which is managed on a discretionary basis. The information contained in this brochure summarises the details contained within the prospectuses prepared for each of the funds. This brochure does not contain all the information which a prospective investor will require prior to making an investment. If you have any questions about us or our services that we did not answer in this document, please contact us at +44 (0) 20 7016 6450 or email [email protected]. Management Fees Fulcrum generally charges clients a management fee. For these funds, the fees are based on the Net Asset Value (“NAV”) of each class within a fund and are deducted from the portfolio on a monthly basis. The fee schedule for the funds varies from fund to fund and between classes in those funds. Part of the fees received may be rebated to clients. For managed accounts the management fees charged are generally based on a fixed % of assets. This percentage will depend on the client type, the strategy and the size of the mandate. Fees are payable in arrears and are charged only in respect of the period for which the fund or account was managed. Other fees Other fees that may be charged to fund clients are set out below: Administrator fees Fees are charged on a sliding scale depending on the amount of assets managed. The administrator will also be reimbursed any reasonable out-of-pocket expenses or costs necessarily incurred in the performance of its duties. Prime broker and custodian fees Prime broker and custodian fees will not exceed normal commercial rates. They may also levy transaction charges and other charges which can include Value Added Tax. Other fees and expenses Other fees and expenses charged may include the following: (a) charges and expenses of legal advisers, accountants and independent auditors, (b) brokers’ commissions, broker funding costs (c) all taxes or stamp duties and corporate fees payable to governments or agencies, (d) Directors’ fees (if any) and expenses, (e) interest on borrowings if applicable, including borrowings from the Prime Broker and Custodian, (f) communication expenses with respect to investor services and all expenses of meetings of Shareholders and of preparing, printing and distributing financial and other reports, proxy forms, prospectuses and similar documents, (g) the cost of insurance for the benefit of the Directors, (h) litigation and indemnification expenses and extraordinary expenses not incurred in the ordinary course of business, (i) the cost of obtaining and maintaining the listing of shares on a stock exchange (if applicable) and (j) some other organisational and operating expenses. It is to be noted certain expenses to be borne by the Master Fund with respect to itself and its feeders will be capped under the fund terms (please see prospectus under “Expenses”). Please see the section on “Brokerage practices” for a description of other brokerage charges. In the case of our managed account clients only additional custody fees are applicable, which are paid directly to the applicable custodian under the contract signed directly between the client and the custodian.