Gradient Ridge Capital, L.P.

Gradient Ridge Capital, L.P. advises privately offered pooled investment vehicles and separately managed accounts, primarily providing portfolio management for master-feeder fund structures. It intends to pursue a fundamental long/short equity strategy focused on publicly traded U.S. and non-U.S. equity and equity-related securities and, like many investment managers, expects to charge advisory fees tied to assets under management, though fee terms are not yet finalized.

The firm will manage client accounts on a discretionary, actively managed basis with daily portfolio oversight, aggregated trading for execution efficiency, monthly net asset value reporting and independent monthly administration plus audited annual financial statements. Gradient Ridge plans to accept performance-based compensation across its clients and expects to use soft-dollar arrangements for research, practices it notes will be governed by its compliance policies and Section 28(e) procedures.

Gradient Ridge is newly formed and awaiting SEC registration with funds currently in formation, a profile that contrasts with more established managers. The firm maintains a formal Code of Ethics that treats all employees as access persons, restricts personal trading to certain broad-market instruments subject to a 90-day holding period, and requires pre-approvals and trade reporting—measures intended to address potential conflicts arising from employee trading and soft-dollar use.