Gam Usa Inc.

GAM USA Inc., established in 1989, is a New York-based investment adviser specializing in providing investment management services to various clients, including pooled investment vehicles, pension plans, trusts, and corporations. As of December 31, 2024, GAM USA managed approximately $1.1 billion in assets on a discretionary basis. The firm offers investment products and services through separately managed accounts and investment fund structures, trading pursuant to strategies of GAM USA and its affiliates. GAM USA's fee structure for institutional separately managed accounts is negotiated based on factors like client type and investment amount, with fees typically deducted directly from client accounts on a monthly or quarterly basis. The firm may also engage in performance-based compensation arrangements, structured to comply with regulatory requirements. Clients of GAM USA have investment discretion, allowing the firm to select securities and execute transactions in alignment with client objectives and restrictions. The firm's brokerage practices prioritize obtaining the most favorable net result for clients, considering factors like research services, execution quality, and market conditions. GAM USA's Code of Ethics ensures high standards of business conduct and fiduciary duties, with employees required to follow guidelines on personal securities trading and potential conflicts of interest. The firm exercises proxy voting authority on behalf of clients, guided by its Proxy Voting Policy and Procedures. GAM USA does not have custody of client assets, which are held by unaffiliated qualified custodians. The firm's financial information indicates a stable financial condition without impairments to meeting client commitments.