Strategy Capital LLC

Strategy Capital LLC is a registered investment adviser with the SEC, founded in 2002 and owned by Hamilton Helmer and John Rutherford. The firm manages investment funds structured as limited partnerships and provides advisory services for an investment company registered under the Investment Company Act of 1940. Strategy Capital's investment objective varies among its partnerships, focusing on achieving long-term capital appreciation through investments in individual publicly traded equity securities or venture capital investments in private companies. The firm exercises investment discretion, tailoring services to meet clients' objectives. As of December 31, 2024, Strategy Capital had regulatory assets under management of $1,255,969,000. The firm's fee structure includes negotiable management fees based on the type of partnership, with performance-based allocations varying among clients. Strategy Capital has a Code of Ethics in place to prevent conflicts of interest and ensure fair treatment of clients. The firm does not engage in soft dollar relationships and does not conduct cross transactions between clients. Strategy Capital's proxy voting policies aim to vote in the best interests of clients. The firm has no financial commitments that could impair its ability to meet contractual obligations.