UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

 

 

FORM N-CSR

 

 

CERTIFIED SHAREHOLDER REPORT OF REGISTERED

MANAGEMENT INVESTMENT COMPANIES

Investment Company Act file number 811-22920

 

 

The Advisors’ Inner Circle Fund III

(Exact name of registrant as specified in charter)

 

 

SEI Investments

One Freedom Valley Drive

Oaks, PA 19456

(Address of principal executive offices) (Zip code)

 

 

SEI Investments

One Freedom Valley Drive

Oaks, PA 19456

(Name and address of agent for service)

 

 

Registrant’s telephone number, including area code: 1-877-446-3863

Date of fiscal year end: July 31, 2020

Date of reporting period: July 31, 2020

 

 

 


Item 1.

Reports to Stockholders.

A copy of the report transmitted to stockholders pursuant to Rule 30e-1 under the Investment Company Act or 1940, as amended (the “Act”) (17 CFR § 270.30e-1), is attached hereto.


The Advisors’ Inner Circle Fund III

 

LOGO

KBI Global Investors Aquarius Fund

 

ANNUAL REPORT    JULY 31, 2020

 

Beginning on January 1, 2021, as permitted by regulations adopted by the Securities and Exchange Commission, paper copies of the Funds’ shareholder reports will no longer be sent by mail, unless you specifically request paper copies of the reports from the Funds or from your financial intermediary, such as a broker-dealer or bank. Instead, the reports will be made available on a website, and you will be notified by mail each time a report is posted and provided with a website link to access the report.

 

If you already elected to receive shareholder reports electronically, you will not be affected by this change and you need not take any action. You may elect to receive shareholder reports and other communications from the Funds electronically by contacting your financial intermediary, or, if you are a direct investor, by calling 1-833-658-4739.

 

You may elect to receive all future reports in paper free of charge. If you invest through a financial intermediary, you can follow the instructions included with this disclosure, if applicable, or you can contact your financial intermediary to inform it that you wish to continue receiving paper copies of your shareholder reports. If you invest directly with the Funds, you can inform the Funds that you wish to continue receiving paper copies of your shareholder reports by calling 1-833-658-4739. Your election to receive reports in paper will apply to all funds held with your financial intermediary if you invest through a financial intermediary or all KBI Global Investors Funds if you invest directly with the Funds.

 

Investment Adviser:

KBI Global Investors (North America) Ltd.

 


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

TABLE OF CONTENTS

 

 

Letter to Shareholders

    1  

Schedule of Investments

    4  

Statement of Assets and Liabilities

    8  

Statement of Operations

    9  

Statement of Changes in Net Assets

    10  

Financial Highlights

    11  

Notes to Financial Statements

    12  

Report of Independent Registered Public Accounting Firm

    26  

Disclosure of Fund Expenses

    28  

Review of Liquidity Risk Management Program

    30  

Trustees and Officers of The Advisors’ Inner Circle Fund III

    32  

Notice to Shareholders

    38  

The Fund files its complete schedule of investments with the Securities and Exchange Commission (“SEC”) for the first and third quarters of each fiscal year on Form N-Q or as an exhibit to its reports on Form N-PORT within sixty days after period end. The Fund’s Form N-Q and Form N-PORT reports are available on the SEC’s website at http://www.sec.gov, and may be reviewed and copied at the SEC’s Public Reference Room in Washington, DC. Information on the operation of the Public Reference Room may be obtained by calling 1-800-SEC-0330.

A description of the policies and procedures that the Fund uses to determine how to vote proxies relating to Fund securities, as well as information relating to how a Fund voted proxies relating to fund securities during the most recent 12-month period ended June 30, is available (i) without charge, upon request, by calling 1-833-658-4739; and (ii) on the SEC’s website at http://www.sec.gov.

 

 


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020 (Unaudited)  

 

 

 

Dear Shareholders,

We are pleased to provide the 2019/2020 financial report for the KBI Global Investors Aquarius Fund (the “Fund”) for the period year ended to July 31st, 2020.

The period began fuelled by trade-related fears of a global economic slow-down and falling bond yields across the globe. However, we saw more positive returns towards the end of 2019, and early 2020 after a decisive UK election and some respite from trade talks as a partial resolution of the US/China trade dispute was reached. As 2020 began and the threat of Covid 19 materialised globally there was a significant change to investors risk appetite. Its impact on the global economy and world financial markets was unforeseen and unprecedented — both in terms of the speed of its impact and its severity. Equally, the bounce back has been extreme, with a disconnect between the strong market returns and the reality of sharp declines in global economic data and the earnings declines that companies will suffer through 2020.

With regards the Aquarius Fund, we entered the period under review with an optimistic outlook, with the conviction that we were in the early innings of what we term ‘Wave 3’ of government and policy-oriented spending on water infrastructure. While we have seen volatility in valuations in the midst of the market conditions mentioned above, we anticipate minimal intrinsic value destruction for our companies as they emerge on the other side of this event. The Aquarius Fund strategy entered 2020 with a balanced and well diversified portfolio with a bias towards infrastructure spending and utility services, areas expected to be more resilient given the late stage in the economic cycle, and also because of their essential nature. This resilience is expected to play out as the global economy now deals with a pandemic and stands in contrast to the main categories of structural risk like travel, out of home discretionary spending and oil, which the strategy has minimal exposure to. We continue to have conviction around companies with strong backlogs serving infrastructure end markets and manufacturers of various essential water equipment. The balance sheets of our companies are strong, with about 50% of the portfolio under-levered or with net cash. With this in mind, we believe that the earnings in the portfolio should be relatively resilient in any downturn and should provide support to stocks on the other side of the recession. Recently we have begun to see early signs of upturns from the bottom in several very relevant end markets for the Aquarius Fund such as US residential, short cycle industrial and European waste.

Fund performance over the period has been resilient given the volatile market conditions, returning 4.58%, underperforming the MSCI AC World Index (NR) return of 7.76%. During the extreme market conditions in Q1 2020 on the back of the spread of Covid 19 globally the fund saw negative returns and underperformed the broader MSCI AC World Index (NR). Given that Healthcare, Consumer staples and

 

1


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020 (Unaudited)  

 

 

 

IT, areas where the strategy has very little exposure, were in favour over this period, the strategy has proved considerably resilient through this turbulent time.

Much has changed since March but as bottom up focused, fundamental long term investors, we have spent a lot of time recently analysing the portfolio at the stock level across a number of different metrics from balance sheet strength to liquidity requirements to sensitivity analysis on end markets and stress testing earnings based on the tougher environment we see coming down the tracks. We have spoken to the majority of management teams of companies in the portfolio to get a better sense of what they are seeing on the ground, what actions they are taking and their thoughts on their end markets going forward. We have continued to trim or sell completely out of positions where we feel that fundamentals have changed or earnings power has been impaired. We have also taken advantage of the extreme volatility to add some new names to the portfolio, broadening the breadth of our exposures, upgrading the quality and improving on the upside-asymmetry.

We thank you for your investment in the Fund and look forward to helping you achieve your investment goals in the future.

Warm Regards,

Noel O’Halloran

Chief Investment Officer

This commentary represents the manager’s opinion. It should not be regarded as investment advice or recommendation of specific securities.

There are risks involved with investing, including possible loss of principal. Past performance is no guarantee of future results.

Definition of Comparative Index

The MSCI AC World Index is a market capitalization weighted index that is designed to measure the equity market performance of developed and emerging market countries.

 

2


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020 (Unaudited)  

 

 

 

Growth of a $100,000 Investment

 

   AVERAGE ANNUAL RETURN FOR THE YEAR   ENDED JULY 31. 2020
   1 Year Return   Annualized Inception
to Date*

Institutional Shares

   4.58%   4.64%

MSCI AC World Index 

   7.76%   8.88%

LOGO

*      The Fund commenced operations on October 12, 2018.

The performance data quoted herein represents past performance and the return and value of an investment in the Fund will fluctuate so that, when redeemed, may be worth less than its original cost. The performance data quoted represents past performance. Past performance does not guarantee future results. The investment return and principal value of an investment will fluctuate so that an investor’s shares, when redeemed, may be worth more or less than their original cost, and current performance may be higher or lower than the performance quoted. The Fund’s performance assumes the reinvestment of all dividends and all capital gains. Index returns assume reinvestment of dividends but, unlike a fund’s returns, do not reflect the deduction of any fees or expenses. If such fees and expenses were included in the index returns the performance would have been lower. Please note that one cannot invest directly in an unmanaged index.

There are no assurances that the Fund will meet its stated objectives. The Fund’s holdings and allocations may change at any given time; they do not constitute, and should not be considered, recommendations to buy individual securities.

Returns shown do not reflect the deduction of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares.

See definition of the comparative index on page 2.

 

3


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

 SECTOR WEIGHTINGS (Unaudited)

 

 

LOGO

 

 SCHEDULE OF INVESTMENTS

 COMMON STOCK — 97.4%

 

 

            Shares                      Value        

Austria — 1.7%

 

  

ANDRITZ

    59,530      $         1,997,119    
    

 

 

 

Brazil — 0.6%

 

  

Cia de Saneamento de Minas Gerais-COPASA *

    66,100        692,101  
    

 

 

 

Canada — 1.0%

 

  

Stantec

    37,851        1,218,229  
    

 

 

 

Finland — 0.7%

 

  

Uponor

    50,296        842,483  
    

 

 

 

France — 7.5%

 

  

Suez

    237,672        3,131,426  

Veolia Environnement

    261,738        5,953,566  
    

 

 

 

       9,084,992  
    

 

 

 

Germany — 1.4%

 

  

Norma Group

    63,080        1,740,230  
    

 

 

 

Hong Kong — 6.8%

 

  

Beijing Enterprises Water Group

    5,056,000        2,146,270  

China Everbright International

    3,462,000        2,139,657  

China Water Affairs Group

    2,726,580        2,353,563  

Guangdong Investment

    646,000        1,043,562  

SIIC Environment Holdings

    3,681,000        565,190  
    

 

 

 

       8,248,242  
    

 

 

 

 

The accompanying notes are an integral part of the financial statements.

 

4


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

 COMMON STOCK — continued

 

 

            Shares                      Value        

India — 0.4%

 

  

Jain Irrigation Systems

    793,956      $         106,657    

VA Tech Wabag *

    244,871        374,610  
    

 

 

 

       481,267  
    

 

 

 

Japan — 5.0%

 

  

Kurita Water Industries

    226,700        6,058,611  
    

 

 

 

Mexico — 2.1%

 

  

Orbia Advance

    1,602,800        2,541,578  
    

 

 

 

Netherlands — 5.2%

 

  

Aalberts

    84,628        3,009,576  

Arcadis *

    158,979        3,249,132  
    

 

 

 

       6,258,708  
    

 

 

 

Philippines — 0.7%

 

  

Metro Pacific Investments

    13,596,000        869,668  
    

 

 

 

South Korea — 3.5%

 

  

Woongjin Coway

    65,839        4,238,586  
    

 

 

 

Sweden — 0.9%

 

  

Alfa Laval *

    48,491        1,143,752  
    

 

 

 

United Kingdom — 10.6%

 

  

Costain Group

    1,328,468        1,048,598  

Ferguson

    23,380        2,078,657  

Pennon Group

    157,751        2,200,221  

United Utilities Group

    639,118        7,529,469  
    

 

 

 

       12,856,945  
    

 

 

 

United States — 49.3%

 

  

Health Care — 6.3%

    

Agilent Technologies

    37,556        3,617,769  

Danaher

    19,368        3,947,198  
    

 

 

 

       7,564,967  
    

 

 

 

Industrials — 34.2%

 

  

Evoqua Water Technologies *

    33,297        640,301  

Fortune Brands Home & Security

    62,220        4,759,830  

Granite Construction

    67,984        1,153,009  

IDEX

    5,476        902,554  

 

The accompanying notes are an integral part of the financial statements.

 

5


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

 

 COMMON STOCK — continued

 

 

            Shares                      Value        

United States — continued

 

  

Industrials — continued

    

Lindsay

    11,949      $ 1,158,695    

Mueller Water Products, Cl A

    289,190        2,926,603  

Pentair

    145,598        6,238,875  

PICO Holdings *

    239,533        1,945,008  

Rexnord

    81,308        2,355,493  

Roper Technologies

    8,974        3,880,806  

SPX *

    88,311        3,709,062  

Tetra Tech

    10,812        958,484  

Toro

    24,450        1,744,508  

Valmont Industries

    40,947        4,962,776  

Xylem

    55,596        4,057,396  
    

 

 

 

       41,393,400  
    

 

 

 

Information Technology — 2.0%

 

  

Itron *

    34,279        2,384,447  
    

 

 

 

Utilities — 6.8%

 

  

Consolidated Water

    52,134        639,684  

Essential Utilities

    108,635        4,926,597  

Middlesex Water

    12,229        783,390  

SJW Group

    29,880        1,866,305  
    

 

 

 

       8,215,976  
    

 

 

 

       59,558,790  
    

 

 

 

TOTAL COMMON STOCK

    

(Cost $111,657,065)

       117,831,301  
    

 

 

 

TOTAL INVESTMENTS — 97.4%

 

  

(Cost $111,657,065)

     $     117,831,301  
    

 

 

 

Percentages are based on Net Assets of $120,936,858.

 

*

 Non-income producing security.

Cl — Class

 

The accompanying notes are an integral part of the financial statements.

 

6


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

Investments

in Securities

   Level 1      Level 2‡      Level 3      Total  

Common Stock

           

Austria

   $ 1,997,119      $      $             —      $ 1,997,119  

Brazil

     692,101                      692,101  

Canada

     1,218,229                      1,218,229  

Finland

     842,483                      842,483  

France

     9,084,992                          9,084,992  

Germany

     1,740,230                      1,740,230  

Hong Kong

     8,248,242                      8,248,242  

India

     481,267                      481,267  

Japan

     6,058,611                      6,058,611  

Mexico

     2,541,578                      2,541,578  

Netherlands

     6,258,708                      6,258,708  

Philippines

                869,668               869,668  

South Korea

     4,238,586                      4,238,586  

Sweden

     1,143,752                      1,143,752  

United Kingdom

     12,856,945                      12,856,945  

United States

     59,558,790                      59,558,790  
  

 

 

    

 

 

    

 

 

    

 

 

 

Total Common Stock

     116,961,633        869,668               117,831,301  
  

 

 

    

 

 

    

 

 

    

 

 

 

Total Investments in Securities

   $ 116,961,633      $     869,668      $      $ 117,831,301  
  

 

 

    

 

 

    

 

 

    

 

 

 

‡ All Philippines securities were deemed temporarily illiquid due to extended holiday market closure. The total temporarily illiquid securities represent 0.7% of Net Assets. Total value of these securities is $869,668.

For the year ended July 31, 2020, there were no transfers in or out of Level 3.

For more information on valuation inputs, see Note 2 – Significant Accounting Policies in the Notes to Financial Statements.

 

The accompanying notes are an integral part of the financial statements.

 

7


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

STATEMENT OF ASSETS AND LIABILITIES  

Assets:

 

Investments, at Value (Cost $111,657,065)

  $   117,831,301  

Foreign Currency, at Value (Cost $26,562)

    26,562  

Cash

    2,774,559  

Dividends and Interest Receivable

    317,027  

Reclaim Receivable

    62,582  

Receivable for Investment Securities Sold

    45,954  

Unrealized Appreciation on Spot Contracts

    79  

Prepaid Expenses

    15,110  
 

 

 

 

Total Assets

    121,073,174  
 

 

 

 

Liabilities:

 

Payable Due to Adviser

    76,836  

Audit Fees Payable

    23,270  

Due to Administrator

    7,199  

Chief Compliance Officer Fees Payable

    2,166  

Accrued Foreign Capital Gains Tax on Appreciated Securities

    1,120  

Trustees Fees Payable

    125  

Other Accrued Expenses

    25,600  
 

 

 

 

Total Liabilities

    136,316  
 

 

 

 

Net Assets

  $ 120,936,858  
 

 

 

 

Net Assets Consist of:

 

Paid-in Capital

  $ 114,196,700  

Distributable Earnings

    6,740,158  
 

 

 

 

Net Assets

  $ 120,936,858  
 

 

 

 

Net Asset Value, Offering and Redemption Price Per Share:*

 

Institutional Shares ($120,936,858 ÷ 11,468,049 shares)

 

(unlimited authorization — no par value)

  $ 10.55  
 

 

 

 

 

  *

Redemption price may vary depending on length of time that shares are held.

 

The accompanying notes are an integral part of the financial statements.

 

8


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    FOR THE YEAR ENDED JULY 31, 2020  

 

 

 

STATEMENT OF OPERATIONS

 

Investment Income:

 

Dividend Income

  $ 1,340,964  

Interest Income

    12,909  

Less: Foreign Taxes Withheld

    (75,335
 

 

 

 

Total Investment Income

    1,278,538  
 

 

 

 

Expenses:

 

Investment Advisory Fees

    509,075  

Administration Fees

    84,171  

Trustees’ Fees

    13,547  

Chief Compliance Officer Fees

    6,908  

Professional Fees

    74,783  

Registration Fees

    37,706  

Transfer Agent Fees

    26,675  

Custodian Fees

    23,982  

Printing Fees

    13,555  

Other Expenses

    15,487  
 

 

 

 

Total Expenses

    805,889  
 

 

 

 

Less:

 

Waiver of Investment Advisory Fees

    (147,080
 

 

 

 

Net Expenses

    658,809  
 

 

 

 

Net Investment Income

    619,729  
 

 

 

 

Net Realized Gain on Investments

    453,550  

Net Realized Loss on Foreign Currency Transactions

    (65,176

Net Realized Loss on Forward Foreign Currency Contracts

    (17,323

Net Change in Unrealized Appreciation on Investments

    4,838,393  

Net Change in Unrealized Appreciation on Translation of Other Assets and Liabilities Denominated in Foreign Currencies

    20,974  

Net Change in Accrued Foreign Capital Gains Tax on Appreciated Securities

    2,398  
 

 

 

 

Net Realized and Unrealized Gain on Investments, Forward Foreign Currency Contracts, Foreign Currency Transactions and Translation of Other Assets and Liabilities Denominated in Foreign Currencies and Accrued Foreign Capital Gains Tax on Appreciated Securities

    5,232,816  
 

 

 

 

Net Increase in Net Assets Resulting from Operations

  $     5,852,545  
 

 

 

 

 

The accompanying notes are an integral part of the financial statements.

 

9


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
 

 

 

 

STATEMENT OF CHANGES IN NET ASSETS  
         Year Ended  
    July 31, 2020
         Period Ended  
    July 31, 2019*
 

Operations:

   

Net Investment Income

  $ 619,729     $ 387,410  

Net Realized Gain on Investments, Forward Foreign Currency Contracts and Foreign Currency Transactions

    371,051       644,459  

Net Change in Unrealized Appreciation on Investments, Accrued Foreign Capital Gains Tax on Appreciated Securities and Translation of Other Assets and Liabilities Denominated in Foreign Currencies

    4,861,765       1,328,183  
 

 

 

   

 

 

 

Net Increase in Net Assets Resulting from Operations

    5,852,545       2,360,052  
 

 

 

   

 

 

 

Distributions:

   

Institutional Shares

    (1,468,635     (3,870
 

 

 

   

 

 

 

Total Distributions

    (1,468,635     (3,870
 

 

 

   

 

 

 

Capital Share Transactions:(1)

   

Institutional Shares

   

Issued

    68,399,005       44,824,716  

Reinvestment of Distributions

    1,355,372        

Redeemed

    (382,327      
 

 

 

   

 

 

 

Net Institutional Shares Share Transactions

    69,372,050       44,824,716  
 

 

 

   

 

 

 

Net Increase in Net Assets from Share Transactions

    69,372,050       44,824,716  
 

 

 

   

 

 

 

Total Increase in Net Assets

    73,755,960       47,180,898  
 

 

 

   

 

 

 

Net Assets:

   

Beginning of Year/Period

    47,180,898        
 

 

 

   

 

 

 

End of Year/Period

  $       120,936,858     $       47,180,898  
 

 

 

   

 

 

 

 

*

The Fund commenced operations on October 12, 2018.

(1)

For share transactions, see Note 7 in the Notes to Financial Statements.

Amounts designated as “—” are $0 or have been rounded to $0.

 

The accompanying notes are an integral part of the financial statements.

 

10


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
 

 

 

 

FINANCIAL HIGHLIGHTS  
   

Selected Per Share Data & Ratios

For a Share Outstanding

Throughout Each Year/Period

 

Institutional Shares   Year
Ended
July 31, 2020
    Period
Ended
July 31, 2019
 

Net Asset Value, Beginning of Year/Period

  $             10.37       $             10.00    
 

 

 

   

 

 

 

Income (Loss) from Operations:

   

Net Investment Income(1)

    0.11       0.12  

Net Realized and Unrealized Gain

    0.38       0.25  
 

 

 

   

 

 

 

Total from Operations

    0.49       0.37  
 

 

 

   

 

 

 

Dividends and Distributions:

   

Net Investment Income

    (0.11)       (2)  

Net Realized Gain

    (0.20)        
 

 

 

   

 

 

 

Total Dividends and Distributions

    (0.31)        
 

 

 

   

 

 

 

Net Asset Value, End of Year/Period

  $ 10.55     $ 10.37  
 

 

 

   

 

 

 

Total Return†

    4.58%       3.75%  
 

 

 

   

 

 

 

Ratios and Supplemental Data

   

Net Assets, End of Year/Period (Thousands)

  $ 120,937     $ 47,181  

Ratio of Expenses to Average Net Assets

    1.10%       1.10% ** 

Ratio of Expenses to Average Net Assets (Excluding Waivers)

    1.35%       1.82% ** 

Ratio of Net Investment Income to Average Net Assets

    1.04%       1.40% ** 

Portfolio Turnover Rate

    33%       33% *** 

 

(1)

Calculated using average shares.

(2)

Amount is less than $0.005 per share.

*

Commenced operations on October 12, 2018.

**

Annualized

***

Not Annualized

Total Return is for the period indicated and has not been annualized. Total return would have been lower had certain expenses not been waived and assumed by the Adviser during the period. Returns shown do not reflect the deduction of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares.

 

The accompanying notes are an integral part of the financial statements.

 

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THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

NOTES TO FINANCIAL STATEMENTS   

1. Organization:

The Advisors’ Inner Circle Fund III (the “Trust”) is organized as a Delaware statutory trust under a Declaration of Trust dated December 4, 2013. The Trust is registered under the Investment Company Act of 1940, as amended, as an open-end management investment company with 33 funds. The financial statements herein are those of the KBI Global Investors Aquarius Fund (the “Fund”). The investment objective of the Fund is to seek long-term total return, consisting of capital appreciation and income. The Fund is classified as a non-diversified investment company. KBI Global Investors (North America) Ltd. serves as the Fund’s investment adviser (the “Adviser”). The Fund currently offers Institutional Shares. Investor Shares of the Fund are currently not offered. The Fund commenced operations on October 12, 2018. The financial statements of the remaining funds of the Trust are presented separately. The assets of each fund are segregated, and a shareholder’s interest is limited to the fund in which shares are held.

2. Significant Accounting Policies:

The following are significant accounting policies, which are consistently followed in the preparation of the financial statements of the Fund. The Fund is an investment company that applies the accounting and reporting guidance issued in Topic 946 by the U.S. Financial Accounting Standards Board (“FASB”).

Use of Estimates — The preparation of financial statements in conformity with U.S. GAAP (“U.S. GAAP”) requires management to make estimates and assumptions that affect the fair value of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting period. Actual results could differ from those estimates and such differences could be material.

Security Valuation — Securities listed on a securities exchange, market or automated quotation system for which quotations are readily available (except for securities traded on NASDAQ), including securities traded over the counter, are valued at the last quoted sale price on an exchange or market (foreign or domestic) on which they are traded on valuation date (or at approximately 4:00 pm Eastern Standard Time if a security’s primary exchange is normally open at that time), or, if there is no such reported sale on the valuation date, at the most recent quoted bid price. For securities traded on NASDAQ, the NASDAQ Official Closing Price will be used. If available, debt securities are priced based upon valuations provided by independent, third-party pricing agents. Such values generally reflect the last reported sales price if the security is actively traded. The third-party pricing agents may also value debt securities

 

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THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

at an evaluated bid price by employing methodologies that utilize actual market transactions, broker supplied valuations, or other methodologies designed to identify the market value for such securities. Such methodologies generally consider such factors as security prices, yields, maturities, call features, ratings and developments relating to specific securities in arriving at valuations. On the first day a new debt security purchase is recorded, if a price is not available on the automated pricing feeds from our primary and secondary pricing vendors nor is it available from an independent broker, the security may be valued at its purchase price. Each day thereafter, the debt security will be valued according to the Trust’s Fair Value Procedures until an independent source can be secured. Debt obligations with remaining maturities of sixty days or less may be valued at their amortized cost, which approximates market value provided that it is determined the amortized cost continues to approximate fair value. Should existing credit, liquidity or interest rate conditions in the relevant markets and issuer specific circumstances suggest that amortized cost does not approximate fair value, then the amortized cost method may not be used. The prices for foreign securities are reported in local currency and converted to U.S. dollars using currency exchange rates.

Securities for which market prices are not “readily available” are valued in accordance with “Fair Value Procedures” established by the Fund’s Board of Trustees (the “Board”). The Fund’s Fair Value Procedures are implemented through a Fair Value Committee (the “Committee”) designated by the Board. Some of the more common reasons that may necessitate that a security be valued using Fair Value Procedures include: the security’s trading has been halted or suspended; the security has been de-listed from a national exchange; the security’s primary trading market is temporarily closed at a time when under normal conditions it would be open; the security has not been traded for an extended period of time; the security’s primary pricing source is not able or willing to provide a price; or trading of the security is subject to local government imposed restrictions. When a security is valued in accordance with the Fair Value Procedures, the Committee will determine the value after taking into consideration relevant information reasonably available to the Committee. As of July 31, 2020, there were no securities valued in accordance with the Fair Value Procedures.

For securities that principally trade on a foreign market or exchange, a significant gap in time can exist between the time of a particular security’s last trade and the time at which the Fund calculates its net asset value. The closing prices of such securities may no longer reflect their market value at the time the Fund calculates its net asset value if an event that could materially affect the value of those securities (a “Significant Event”) has occurred between the time of the security’s last close and the time that the Fund calculates net asset value.

 

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THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

A Significant Event may relate to a single issuer or to an entire market sector. If the Adviser of the Fund becomes aware of a Significant Event that has occurred with respect to a security or group of securities after the closing of the exchange or market on which the security or securities principally trade, but before the time at which the Fund calculates its net asset value, it may request that a Committee meeting be called.

The Fund uses MarkIt Fair Value (“MarkIt”) as a third party fair valuation vendor. MarkIt provides a fair value for foreign securities in the Fund based on certain factors and methodologies (involving, generally, tracking valuation correlations between the U.S. market and each non-U.S. security) applied by MarkIt in the event that there is a movement in the U.S. market that exceeds a specific threshold established by the Committee. The Committee establishes “confidence interval” which is used to determine the level of correlation between the value of a foreign security and movements in the U.S. market before a particular security is fair valued when the threshold is exceeded. In the event that the threshold established by the Committee is exceeded on a specific day, the Fund values its non-U.S. securities that exceed the applicable “confidence interval” based upon the fair values provided by MarkIt. In such event, it is not necessary to hold a Committee meeting. In the event that the Adviser believes that the fair values provided by MarkIt are not reliable, the Adviser contacts the Administrator and can request that a meeting of the Committee be held.

If a local market in which the Fund owns securities is closed for one or more days, the Fund shall value all securities held in that corresponding currency based on the fair value prices provided by MarkIt using the predetermined confidence interval discussed above.

In accordance with U.S. GAAP, the Fund discloses fair value of its investments in a hierarchy that prioritizes the inputs to valuation techniques used to measure the fair value. The objective of a fair value measurement is to determine the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date (an exit price). Accordingly, the fair value hierarchy gives the highest priority to quoted prices (unadjusted) in active markets for identical assets or liabilities (Level 1) and the lowest priority to unobservable inputs (Level 3). The three levels of the fair value hierarchy are described below:

 

   

Level 1 — Unadjusted quoted prices in active markets for identical, unrestricted assets or liabilities that the Fund has the ability to access at the measurement date

 

   

Level 2 — Other significant observable inputs (includes quoted prices for similar securities, interest rates, prepayment speeds, credit risk, referenced

 

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THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

 

indices, quoted prices in inactive markets, adjusted quoted prices in active markets, adjusted quoted prices on foreign equity securities that were adjusted in accordance with pricing procedures approved by the Board, etc.); and

 

   

Level 3 — Prices, inputs or exotic modeling techniques which are both significant to the fair value measurement and unobservable (supported by little or no market activity).

Investments are classified within the level of the lowest significant input considered in determining fair value. Investments classified within Level 3 whose fair value measurement considers several inputs may include Level 1 or Level 2 inputs as components of the overall fair value measurement.

For the year ended July 31, 2020, there have been no significant changes to the Fund’s fair valuation methodology.

Federal Income Taxes — It is the Fund’s intention to qualify as a regulated investment company for Federal income tax purposes by complying with the appropriate provisions of Subchapter M of the Internal Revenue Code of 1986, as amended. Accordingly, no provisions for Federal income taxes have been made in the financial statements.

The Fund evaluates tax positions taken or expected to be taken in the course of preparing the Fund’s tax returns to determine whether it is “more-likely than-not” (i.e., greater than 50-percent) that each tax position will be sustained upon examination by a taxing authority based on the technical merits of the position. Tax positions not deemed to meet the more-likely-than-not threshold are recorded as a tax benefit or expense in the current year. The Fund did not record any tax provision in the current year. However, management’s conclusions regarding tax positions taken may be subject to review and adjustment at a later date based on factors including, but not limited to, examination by tax authorities (i.e., from commencement of operations, as applicable), on-going analysis of and changes to tax laws, regulations and interpretations thereof.

As of and during the year ended July 31, 2020, the Fund did not have a liability for any unrecognized tax benefits. The Fund recognizes interest and penalties, if any, related to unrecognized tax benefits as income tax expense in the Statement of Operations. During the year ended July 31, 2020, the Fund did not incur any interest or penalties.

Security Transactions and Investment Income — Security transactions are accounted for on the trade date. Costs used in determining realized gains and losses on the sale of investment securities are based on the specific

 

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THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

identification method. Dividend income and expense are recorded on the ex-dividend date. Certain dividends from foreign securities will be recorded as soon as the Fund is informed of the dividend if such information is obtained subsequent to the ex-dividend date.

Foreign Currency Translation — The books and records of the Fund are maintained in U.S. dollars. Investment securities and other assets and liabilities denominated in a foreign currency are translated into U.S. dollars on the date of valuation. The Fund does not isolate that portion of realized or unrealized gains and losses resulting from changes in the foreign exchange rate from fluctuations arising from changes in the market prices of the securities. These gains and losses are included in net realized gain (loss) on investments and net unrealized appreciation (depreciation) on investments on the Statement of Operations. Net realized gain (loss) on foreign currency transactions and net appreciation (depreciation) on translation of other assets and liabilities denominated in foreign currencies represent net foreign exchange gains or losses from foreign currency exchange contracts, disposition of foreign currencies, currency gains or losses realized between trade and settlement dates on securities transactions and the difference between the amount of the investment income and foreign withholding taxes recorded on the Fund’s books and the U.S. dollar equivalent of the amounts actually received or paid.

Forward Foreign Currency Contracts — The Fund may enter into forward foreign currency contracts to protect the value of securities held and related receivables and payables against changes in future foreign exchange rates. A forward currency contract is an agreement between two parties to buy and sell currency at a set price on a future date. The market value of the contract will fluctuate with changes in currency exchange rates. The contract is marked-to-market daily using the current forward rate and the change in market value is recorded by the Fund as unrealized gain or loss. The Fund recognizes realized gains or losses when the contract is closed, equal to the difference between the value of the contract at the time it was opened and the value at the time it was closed. Any realized gain (loss) or unrealized appreciation (depreciation) during the year is presented on the Statement of Operations. Risks may arise from unanticipated movements in the value of a foreign currency relative to the U.S. dollar. Risks may also arise upon entering into these contracts from the potential inability of counterparties to meet the terms of their contracts and are generally limited to the amount of unrealized gain on the contracts at the date of default.

Expenses — Most expenses of the Trust can be directly attributed to a particular fund. Expenses which cannot be directly attributed to a particular fund are

 

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THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

apportioned among the funds of the Trust based on the number of funds and/or relative net assets.

Cash — Idle cash may be swept into various time deposit accounts and is classified as cash on the Statement of Assets and Liabilities. The Fund maintains cash in bank deposit accounts which, at times may exceed United States federally insured limits. Amounts invested are available on the same business day.

Dividends and Distributions to Shareholders — The Fund distributes substantially all of its net investment income annually. Any net realized capital gains are distributed annually. All distributions are recorded on the ex-dividend date.

Redemption Fees — The Fund retains a redemption fee of 2.00% on redemptions of capital shares held for less than 30 days. For the year ended July 31, 2020, the Fund did not retain any fees. Fees collected are retained by the Fund for the benefit of the remaining shareholders and are included in capital shares transactions in the Statement of Changes in Net Assets.

Offering Costs  Offering costs, including costs of printing the initial prospectus, legal and registration fees, are amortized over twelve-months from inception of the Fund. As of July 31, 2020, the Fund had fully amortized the offering costs.

Foreign Taxes — The Fund may be subject to taxes imposed by countries in which it invests. Such taxes are generally based on either income or gains earned or repatriated. The Fund accrues and applies such taxes to net investment income, net realized gains and net unrealized gains as income and/or capital gains are earned. The Fund has accrued foreign tax in the amount of $1,120 presented on the Statement of Assets and Liabilities.

3. Transactions with Affiliates:

Certain officers of the Trust are also employees of SEI Investments Global Funds Services (the “Administrator”), a wholly owned subsidiary of SEI Investments Company, and/or SEI Investments Distribution Co. (the “Distributor”). Such officers are paid no fees by the Trust, other than the Chief Compliance Officer (“CCO”) as described below, for serving as officers of the Trust.

The services provided by the (“CCO”) and his staff are paid for by the Trust, as incurred. The services include regulatory oversight of the Trust’s advisers and service providers as required by SEC regulations. The CCO’s services and fees have been approved by and are reviewed by the Board.

 

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THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

4. Administration, Distribution, Shareholder Servicing, Custodian and Transfer Agent Agreements:

The Fund and the Administrator are parties to an Administration Agreement under which the Administrator provides administration services to the Fund. For these services, the Administrator is paid an asset-based fee, subject to certain minimums, which will vary depending on the number of share classes and the average daily net assets of the Fund. For the year ended July 31, 2020, the Fund paid $84,171 for these services.

The Fund has adopted a shareholder servicing plan (the “Service Plan”) under which a shareholder servicing fee of up to 0.25% of average daily net assets of Investor Shares of the Fund will be paid to other service providers. Under the Service Plan, other service providers may perform, or may compensate other service providers for performing certain shareholder and administrative services. As of July 31, 2020, Investor Shares of the Fund are not available for purchase.

Brown Brothers Harriman & Co. acts as custodian (the “Custodian”) for the Fund. The Custodian plays no role in determining the investment policies of the Fund or which securities are to be purchased or sold by the Fund.

Atlantic Fund Services, LLC, serves as the transfer agent and dividend disbursing agent for the Fund under a transfer agency agreement with the Trust.

5. Investment Advisory Agreement:

Under the terms of an investment advisory agreement, the Adviser provides investment advisory services to the each of the Fund’s share classes at a fee calculated at an annual rate of 0.85% of each of the Fund’s share class’s average daily net assets. The Adviser has contractually agreed to waive fees and reimburse expenses to the extent necessary to keep Total Annual Fund Operating Expenses (excluding interest, taxes, brokerage commissions, research, 12b-1 Fees, acquired fund fees and expenses and non-routine expenses (collectively, “excluded expenses”)) from exceeding 1.10% of the average daily net assets of each of the Fund’s share classes until November 30, 2020 (the “contractual expense limit”). In addition, the Adviser may receive from the Fund the difference between the Total Annual Fund Operating Expenses (not including excluded expenses) and the contractual expense limit to recoup all or a portion of its prior fee waivers or expense reimbursements made during the three-year period preceding the date of the recoupment if at any point Total Annual Fund Operating Expenses (not including excluded expenses) are below the contractual expense limit (i) at the time of the fee waiver and/or expense reimbursement and (ii) at the time of the recoupment. As of July 31, 2020, the fees which were previously waived and reimbursed to the Fund by the Adviser which may be subject to possible future reimbursement to the Adviser were $198,250 expiring in 2022 and $147,080 expiring in 2023.

 

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THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

6. Investment Transactions:

The cost of security purchases and the proceeds from security sales other than long-term U.S. Government and short-term securities, for the year ended July 31, 2020, were as follows:

 

    Purchases    

  

    Sales and Maturities    

$86,238,745

   $19,082,541

There were no purchases or sales of long-term U.S. Government securities.

7. Share Transactions:

 

     Year Ended
    July 31, 2020    
 

Share Transactions:

  

Institutional Shares

  

Issued

     6,843,452  

Reinvested

     119,721  

Redeemed

     (44,851
  

 

 

 

Net Share Transactions

                     6,918,322  
  

 

 

 

8. Federal Tax Information:

The amount and character of income and capital gain distributions to be paid, if any, are determined in accordance with Federal income tax regulations, which may differ from U.S. GAAP. As a result, net investment income (loss) and net realized gain (loss) on investment transactions for a reporting period may differ significantly from distributions during such period. These book/tax differences may be temporary or permanent. To the extent these differences are permanent in nature, they are charged or credited to paid-in capital and distributable gain (loss), as appropriate, in the period that the differences arise.

The permanent differences primarily consist of foreign currency translations. There are no permanent differences that are credited or charged to Paid-in Capital and Distributable Earnings as of July 31, 2020.

The tax character of dividends and distributions declared during the fiscal year was as follows:

 

   

Ordinary

        Income         

   

Long-Term

    Capital Gain    

   

        Total         

 

2020

  $             1,425,163         $                     43,472         $         1,468,635      

2019

    3,870           —           3,870      

 

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THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

As of July 31, 2020, the components of Distributable Earnings on a tax basis were as follows:

 

Undistributed Ordinary Income

   $ 431,764      

Undistributed Long-Term Capital Gains

     373,746      

Unrealized Appreciation

     5,934,646      

Other Temporary Differences

     2      
  

 

 

 

Total Net Distributable Earnings

   $             6,740,158      
  

 

 

 

For Federal income tax purposes the difference between Federal tax cost and book cost primarily relates to wash sales which cannot be used for Federal income tax purposes in the current year and have been deferred for use in future years and passive foreign investment companies. The Federal tax cost and aggregate gross unrealized appreciation and depreciation for the investments held by the Fund at July 31, 2020, were as follows:

 

Federal
        Tax Cost         

 

Aggregate
Gross
Unrealized
    Appreciation     

   

Aggregate
Gross
Unrealized
    Depreciation     

   

Net Unrealized
    Appreciation    

 
$111,912,367   $ 11,092,144     $ (5,157,498   $ 5,934,646  

9. Concentration of Risks:

As with all management investment companies, a shareholder of the Fund is subject to the risk that his or her investment could lose money. The Fund is subject to the principal risks noted below, any of which may adversely affect the Fund’s net asset value (“NAV”) and ability to meet its investment objective.

Equity Market Risk — The risk that stock prices will fall over short or extended periods of time, sometimes rapidly and unpredictably. The value of equity securities will fluctuate in response to factors affecting a particular company, as well as broader market and economic conditions. Broad movements in financial markets may adversely affect the price of the Fund’s investments, regardless of how well the companies in which the Fund invests perform. Moreover, in the event of a company’s bankruptcy, claims of certain creditors, including bondholders, will have priority over claims of common stock holders such as the Fund.

Small and Medium Capitalization Companies Risk — The risk that small and medium capitalization companies in which the Fund may invest may be more vulnerable to adverse business or economic events than larger, more established companies. In particular, small and medium capitalization companies may have limited product lines, markets and financial resources and may depend upon a relatively small management group. Therefore, small capitalization and medium capitalization stocks may be more volatile than those of larger companies. Small capitalization

 

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THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

and medium capitalization stocks may be traded over-the-counter or listed on an exchange.

Sector Emphasis Risk — The securities of companies in the same business sector, if comprising a significant portion of the Fund’s portfolio, may in some circumstances react negatively to market conditions, interest rates and economic, regulatory or financial developments and adversely affect the value of the portfolio to a greater extent than if such securities comprised a lesser portion of the Fund’s portfolio or the Fund’s portfolio was diversified across a greater number of industry sectors.

Water-Related Resource Sector Risk — The Fund’s investments in the water-related resource sector may underperform relative to the general market, returns on investments in other sectors or fixed-income securities. The water-related resource sector can be significantly affected by climactic, environmental and political events which could impact water consumption and conservation. Furthermore, because the Fund will focus its investments in the water-related resource sector, economic downturns and global and domestic events affecting the water-related resource sector will have a greater impact on the Fund than would be the case if the Fund’s investments were more diversified. These events may include governmental regulation and institutional change, inflation, an increase in the cost of raw materials, an increase in interest rates, technological advances, changes in consumer sentiment and spending and changes in government spending.

Industrials Industry Risk — Stock prices for the types of companies included in the industrials industry are affected by supply and demand both for their specific product or service and for industrial industry products in general. Government regulation, world events and economic conditions, technological developments and liabilities for environmental damage and general civil liabilities, among other factors, will likewise affect the performance of these companies.

Utilities Industry Risk — Stock prices for companies in the utilities industry are affected by supply and demand, operating costs, governmental regulation, taxes, environmental factors, liabilities for environmental damage and general civil liabilities, and rate caps or rate changes. Utility companies also are vulnerable to natural disasters, terrorist attacks, government intervention or other factors may render a utility company’s equipment unusable or obsolete and negatively impact profitability. Among the risks that may affect utility companies are the following: risks of increases in fuel and other operating costs; the high cost of borrowing to finance capital construction during inflationary periods; restrictions on operations and increased costs and delays associated with compliance with federal and state safety regulations; and the effects of energy conservation and regulatory changes.

Liquidity Risk — Liquidity risk is the risk that, due to certain investments trading in lower volumes or to market and economic conditions, the Fund may be unable to

 

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THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

find a buyer for its investments when it seeks to sell them or to receive the price it expects based on the Fund’s valuation of the investments. Events that may lead to increased redemptions, such as market disruptions, may also negatively impact the liquidity of the Fund’s investments when it needs to dispose of them. If the Fund is forced to sell its investments at an unfavorable time and/or under adverse conditions in order to meet redemption requests, such sales could negatively affect the Fund. Liquidity issues may also make it difficult to value the Fund’s investments.

Geographic Focus Risk — To the extent that it focuses its investments in a particular country or region, the Fund may be more susceptible to economic, political, regulatory or other events or conditions affecting issuers and countries within that country or region. As a result, the Fund may be subject to greater price volatility and risk of loss than a fund holding more geographically diverse investments.

Non-Diversified Risk — The Fund is non-diversified, which means that it may invest in the securities of relatively few issuers. As a result, the Fund may be more susceptible to a single adverse economic or political occurrence affecting one or more of these issuers and may experience increased volatility due to its investments in those securities. If the securities in which the Fund invests perform poorly, the Fund could incur greater losses than it would have had it invested in a greater number of securities. However, the Fund intends to satisfy the asset diversification requirements for qualification as a regulated investment company (“RIC”) under Subchapter M of the Internal Revenue Code of 1986, as amended (the “Code”).

Foreign Investment/Emerging Markets Risk — The securities of foreign issuers may be less liquid and more volatile than securities of comparable U.S. issuers. The costs associated with securities transactions are often higher in foreign countries than in the U.S. Additionally, investments in foreign securities, even those publicly traded in the United States, may involve risks which are in addition to those inherent in domestic investments. Foreign companies may not be subject to the same regulatory requirements of U.S. companies, and as a consequence, there may be less publicly available information about such companies. Foreign companies may be subject to significantly higher levels of taxation than U.S. companies, including potentially confiscatory levels of taxation, thereby reducing the earnings potential of such foreign companies. Substantial withholding taxes may apply to distributions from foreign companies. Also, foreign companies may not be subject to uniform accounting, auditing, and financial reporting standards and requirements comparable to those applicable to U.S. companies. Foreign governments and foreign economies often are less stable than the U.S. Government and the U.S. economy. The risks associated with international investing will be greater in emerging markets than in more developed foreign markets because, among other things, emerging markets may have less stable political and economic environments.

 

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THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

Depositary Receipts Risk — Depositary receipts, such as ADRs and GDRs, are certificates evidencing ownership of shares of a foreign issuer that are issued by depositary banks and generally trade on an established market. Depositary receipts are subject to many of the risks associated with investing directly in foreign securities, including, among other things, political, social and economic developments abroad, currency movements and different legal, regulatory and tax environments.

Management Risk — The success of the Fund’s strategy is dependent on the Adviser’s ability and its stock selection process to correctly identify the Fund’s investments. The portfolio securities selected by the Adviser may decline in value or not increase in value when the stock market in general is rising, in which case the Fund could experience losses regardless of the overall performance of the U.S. equity market.

Value Style Risk — Value investing focuses on companies with stocks that appear undervalued in light of factors such as the company’s earnings, book value, revenues or cash flow. If the Adviser’s assessment of market conditions, or a company’s value or prospects for exceeding earnings expectations, is wrong, the Fund could suffer losses or produce poor performance relative to other funds.

Growth Style Risk — The Adviser utilizes a “growth style” of investing, meaning that the Fund invests in equity securities of companies that the Adviser believes will have above-average rates of relative earnings growth and which, therefore, may experience above-average increases in stock prices. Over time, a relative growth investing style may go in and out of favor, causing the Fund to sometimes underperform other equity funds that use differing investing styles.

Currency Risk — As a result of the Fund’s investments in securities or other investments denominated in, and/or receiving revenues in, foreign currencies, the Fund will be subject to currency risk. Currency risk is the risk that foreign currencies will decline in value relative to the U.S. dollar or, in the case of hedging positions, that the U.S. dollar will decline in value relative to the currency hedged. In either event, the dollar value of an investment in the Fund would be adversely affected. Currency exchange rates may fluctuate in response to, among other things, changes in interest rates, intervention (or failure to intervene) by U.S. or foreign governments, central banks or supranational entities, or by the imposition of currency controls or other political developments in the United States or abroad.

Large Capitalization Risk — The risk that larger, more established companies may be unable to respond quickly to new competitive challenges such as changes in technology and consumer tastes.

Money Market Instruments Risk — The value of money market instruments may be affected by changing interest rates and by changes in the credit ratings of the

 

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THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

investments. An investment in a money market fund is not a bank deposit and is not insured or guaranteed by any bank, the FDIC or any other government agency. A money market fund’s sponsor has no legal obligation to provide financial support to the fund, and there should be no expectation that the sponsor will provide financial support to the fund at any time. Certain money market funds float their net asset value while others seek to preserve the value of investments at a stable net asset value (typically, $1.00 per share). An investment in a money market fund, even an investment in a fund seeking to maintain a stable net asset value per share, is not guaranteed and it is possible for the Fund to lose money by investing in these and other types of money market funds. If the liquidity of a money market fund’s portfolio deteriorates below certain levels, the money market fund may suspend redemptions (i.e., impose a redemption gate) and thereby prevent the Fund from selling its investment in the money market fund or impose a fee of up to 2% on amounts the Fund redeems from the money market fund (i.e., impose a liquidity fee). These measures may result in an investment loss or prohibit the Fund from redeeming shares when the Adviser would otherwise redeem shares. Money market funds and the securities they invest in are subject to comprehensive regulations. The enactment of new legislation or regulations, as well as changes in interpretation and enforcement of current laws, may affect the manner of operation, performance and/or yield of money market funds.

10. Other:

At July 31, 2020, 90% of Institutional Class Shares outstanding were held by one record shareholder owning 10% or greater of the aggregate total shares outstanding. This shareholder is comprised of an omnibus account that was held on behalf of various individual shareholders.

In the normal course of business, the Fund enters into contracts that provide general indemnifications. The Fund’s maximum exposure under these arrangements is dependent on future claims that may be made against the Fund and, therefore, cannot be established; however, based on experience, the risk of loss from such claims is considered remote.

11. New Accounting Pronouncement:

In August 2018, The FASB issued Accounting Standards Update 2018-13, Fair Value Measurement (Topic 820). The new guidance includes additions, removals and modifications to disclosures requirements for fair value measurements. For public entities, the amendments are effective for financial statements issued for fiscal years beginning after December 15, 2019, and interim periods within those fiscal years. Management elected to early adopt the removal and modifications of certain disclosures and delay the adoption of additional disclosures until the effective date.

 

24


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

12. Subsequent Events:

The Fund has evaluated the need for additional disclosures and/or adjustments resulting from subsequent events through the date the financial statements were issued. Based on this evaluation, no additional disclosures and/or adjustments were required to the financial statements as of July 31, 2020.

 

25


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM  

To the Board of Trustees of The Advisors’ Inner Circle Fund III and

Shareholders of KBI Global Investors Aquarius Fund

Opinion on the Financial Statements

We have audited the accompanying statement of assets and liabilities of KBI Global Investors Aquarius Fund (the “Fund”) (one of the series constituting The Advisors’ Inner Circle Fund III (the “Trust”)), including the schedule of investments, as of July 31, 2020, and the related statement of operations for the year then ended, the statements of changes in net assets and financial highlights for the year ended July 31, 2020 and the period from October 12, 2018 (commencement of operations) through July 31, 2019, and the related notes (collectively referred to as the “financial statements”). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Fund (one of the series constituting The Advisors’ Inner Circle Fund III) at July 31, 2020, the results of its operations for the year then ended, the changes in its net assets and its financial highlights for the year ended July 31, 2020 and the period from October 12, 2018 (commencement of operations) through July 31, 2020, in conformity with U.S. generally accepted accounting principles.

Basis for Opinion

These financial statements are the responsibility of the Trust’s management. Our responsibility is to express an opinion on the Fund’s financial statements based on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (“PCAOB”) and are required to be independent with respect to the Trust in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. The Trust is not required to have, nor were we engaged to perform, an audit of the Trust’s internal control over financial reporting. As part of our audits we are required to obtain an understanding of internal control over financial reporting but not for the purpose of expressing an opinion on the effectiveness of the Trust’s internal control over financial reporting. Accordingly, we express no such opinion.

 

26


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our procedures included confirmation of securities owned as of July 31, 2020, by correspondence with the custodian. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audits provide a reasonable basis for our opinion.

LOGO

We have served as the auditor of one or more KBI Global Investors (North America) Ltd. investment companies since 2019.

Philadelphia, Pennsylvania

September 29, 2020

 

27


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

DISCLOSURE OF FUND EXPENSES (Unaudited)  

All mutual funds have operating expenses. As a shareholder of a mutual fund, your investment is affected by these ongoing costs, which include (among others) costs for Fund management, administrative services, and shareholder reports like this one. It is important for you to understand the impact of these costs on your investment returns.

Operating expenses such as these are deducted from the mutual fund’s gross income and directly reduce your final investment return. These expenses are expressed as a percentage of the mutual fund’s average net assets; this percentage is known as the mutual fund’s expense ratio.

The following examples use the expense ratio and are intended to help you understand the ongoing costs (in dollars) of investing in your Fund and to compare these costs with those of other mutual funds. The examples are based on an investment of $1,000 made at the beginning of the period shown and held for the entire period from February 1, 2020 to July 31, 2020.

The table on the next page illustrates your Fund’s costs in two ways:

Actual Fund Return. This section helps you to estimate the actual expenses after fee waivers that your Fund incurred over the period. The “Expenses Paid During Period” column shows the actual dollar expense cost incurred by a $1,000 investment in the Fund, and the “Ending Account Value” number is derived from deducting that expense cost from the Fund’s gross investment return.

You can use this information, together with the actual amount you invested in the Fund, to estimate the expenses you paid over that period. Simply divide your ending starting account value by $1,000 to arrive at a ratio (for example, an $8,600 account value divided by $1,000 = 8.6), then multiply that ratio by the number shown for your Fund under “Expenses Paid During Period”.

Hypothetical 5% Return. This section helps you compare your Fund’s costs with those of other mutual funds. It assumes that the Fund had an annual 5% return before expenses during the year, but that the expense ratio (Column 3) for the period is unchanged. This example is useful in making comparisons because the Securities and Exchange Commission requires all mutual funds to make this 5% calculation. You can assess your Fund’s comparative cost by comparing the hypothetical result for your Fund in the “Expense Paid During Period” column with those that appear in the same charts in the shareholder reports for other mutual funds.

 

28


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

DISCLOSURE OF FUND EXPENSES (Unaudited) – concluded  

Note: Because the return is set at 5% for comparison purposes — NOT your Fund’s actual return — the account values shown may not apply to your specific investment.

 

      Beginning
Account
Value
2/1/20
     Ending
Account
Value
7/31/20
     Annualized
Expense
Ratios
    Expenses
Paid During
Period*
 

Actual Fund Return

          

Institutional Shares

   $     1,000.00      $     933.60        1.10   $     5.29  

Hypothetical 5% Return

          

Institutional Shares

   $ 1,000.00      $     1,019.39        1.10   $ 5.52  

* Expenses are equal to the Fund’s annualized expense ratio multiplied by the average account value over the period, multiplied by 182/366 (to reflect the one-half year period shown).

 

29


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

REVIEW OF LIQUIDITY RISK MANAGEMENT PROGRAM (Unaudited)  

Pursuant to Rule 22e-4 under the 1940 Act, the Fund’s investment adviser has adopted, and the Board has approved, a liquidity risk management program (the “Program”) to govern the Fund’s approach to managing liquidity risk. The Program is overseen by the Fund’s Liquidity Risk Management Program Administrator (the “Program Administrator”), and the Program’s principal objectives include assessing, managing and periodically reviewing the Fund’s liquidity risk, based on factors specific to the circumstances of the Fund.

At a meeting of the Board held on March 18, 2020, the Trustees received a report from the Program Administrator addressing the operations of the Program and assessing its adequacy and effectiveness of implementation. The Board acknowledged that the report covered the period from June 1, 2019 through December 31, 2019 and thus did not cover the period of then-current market volatility. The Board requested that the Program Administrator provide an update of the operation of the Program during the then-current market volatility at its next meeting. The Program Administrator’s report noted that the Program Administrator had determined that the Program is reasonably designed to assess and manage the Fund’s liquidity risk and has operated adequately and effectively to manage the Fund’s liquidity risk since the Program was implemented on June 1, 2019. The Program Administrator’s report noted that during the period covered by the report, there were no liquidity events that impacted the Funds or their ability to timely meet redemptions without dilution to existing shareholders. The Program Administrator’s report further noted that material changes had been made to the Program since its implementation relating to the assumed percentage of an equity security’s average daily volume that can be traded without a significant market impact to the share price.

There can be no assurance that the Program will achieve its objectives in the future. Please refer to the prospectus for more information regarding the Fund’s exposure to liquidity risk and other principal risks to which an investment in the Fund may be subject.

 

30


 

 

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THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

TRUSTEES AND OFFICIERS OF THE ADVISORS’ INNER CIRCLE FUND III (Unaudited)  

Set forth below are the names, years of birth, positions with the Trust, length of time served, and the principal occupations for the last five years of each of the persons currently serving as Trustees and Officers of the Trust. Unless otherwise noted, the business address of each Trustee is SEI Investments Company, One Freedom Valley Drive, Oaks Pennsylvania 19456. Trustees who are deemed not to be “interested persons” of the Trust are referred to as “Independent Trustees.” Messrs. Nesher and Doran are Trustees who may be

 

Name and
Year of Birth
   Position with
Trust and Length of
Time Served1
 

Principal Occupations

in the Past Five Years

INTERESTED

TRUSTEES2 3

        
WILLIAM M. DORAN (Born: 1940)    Chairman of the Board of Trustees (Since 2014)  

Self-Employed Consultant since 2003. Partner at Morgan, Lewis & Bockius LLP (law firm) from 1976 to 2003. Counsel to the Trust, SEI Investments, SIMC, the Administrator and the Distributor. Secretary of SEI Investments since 1978.

 

INDEPENDENT

TRUSTEES3

        
JON C. HUNT
(Born: 1951)
   Trustee and Lead Independent Trustee (since 2014)  

Retired since 2013. Consultant to Management, Convergent Capital Management, LLC (“CCM”) from 2012 to 2013. Managing Director and Chief Operating Officer, CCM from 1998 to 2012.

 

THOMAS P. LEMKE
(Born: 1954)
   Trustee
(Since 2014)
 

Retired since 2013. Executive Vice President and General Counsel, Legg Mason, Inc. from 2005 to 2013.

 

JAY C. NADEL
(Born: 1958)
   Trustee
(Since 2016)
 

Self-Employed Consultant since 2004. Executive Vice President, Bank of New York Broker Dealer from 2002 to 2004. Partner/Managing Director, Weiss Peck & Greer/Robeco from 1986 to 2001.

 

RANDALL S. YANKER (Born: 1960)    Trustee
(Since 2014)
 

Co-Founder and Senior Partner, Alternative Asset Managers, L.P. since 2004.

 

1. Each Trustee shall hold office during the lifetime of this trust until the election and qualification of his or her successor, or until he or she sooner dies, resigns, or is removed in accordance with the Trust’s Declaration of Trust.

2. Denotes Trustees who may be deemed to be “interested” persons of the Fund as that term is defined in the 1940 Act by virtue of their affiliation with the Distributor and/or its affiliates.

3. Trustees oversee 33 funds in The Advisors’ Inner Circle Fund III.

 

32


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

deemed to be “interested” persons of the Trust as that term is defined in the 1940 Act by virtue of their affiliation with the Trust’s Distributor. The Trust’s Statement of Additional Information (“SAI”) includes additional information about the Trustees and Officers. The SAI may be obtained without charge by calling 1-833-658-4739. The following chart lists Trustees and Officers as of July 31, 2020.

 

Other Directorships

Held in the Past Five Years4

 

Current Directorships: Trustee of Gallery Trust, Schroder Series Trust, Schroder Global Series Trust, SEI Daily Income Trust, SEI Institutional International Trust, SEI Institutional Investments Trust, SEI Institutional Managed Trust, SEI Asset Allocation Trust, SEI Tax Exempt Trust, Adviser Managed Trust, New Covenant Funds, SEI Insurance Products Trust and SEI Catholic Values Trust. Director of SEI Investments, SEI Investments (Europe), Limited, SEI Investments—Global Funds Services, Limited, SEI Investments Global, Limited, SEI Investments (Asia), Limited, SEI Global Nominee Ltd., SEI Investments – Unit Trust Management (UK) Limited and SEI Investments Co. Director of the Distributor.

 

Former Directorships: Trustee of O’Connor EQUUS (closed-end investment company) to 2016. Trustee of SEI Liquid Asset Trust to 2016. Trustee of Winton Series Trust to 2017. Trustee of The Advisors’ Inner Circle Fund, The Advisors’ Inner Circle Fund II, Bishop Street Funds, The KP Funds and Winton Diversified Opportunities Fund (closed-end investment company) to 2018.

 

Current Directorships: Trustee of City National Rochdale Funds, Gallery Trust, Schroder Series Trust and Schroder Global Series Trust.

 

Former Directorships: Trustee of O’Connor EQUUS (closed-end investment company) to 2016. Member of Independent Committee of Nuveen Commodities Asset Management to 2016. Trustee of Winton Series Trust to 2017. Trustee of Winton Diversified Opportunities Fund (closed-end investment company) to 2018.

Current Directorships: Trustee of Gallery Trust, Schroder Series Trust, Schroder Global Series Trust, JP Morgan Active Exchange-Traded Funds (33 Portfolios) and Symmetry Panoramic Trust (8 Portfolios).

 

Former Directorships: Trustee of Munder Funds to 2014. Trustee of Victory Funds to 2015. Trustee of O’Connor EQUUS (closed-end investment company) to 2016. Trustee of Winton Series Trust and AXA Premier VIP Trust to 2017. Trustee of Winton Diversified Opportunities Fund (closed-end investment company) to 2018.

Current Directorships: Trustee of City National Rochdale Funds, Gallery Trust, Schroder Series Trust and Schroder Global Series Trust.

 

Former Directorships: Trustee of Winton Series Trust to 2017. Director of Lapolla Industries, Inc. to 2017. Trustee of Winton Diversified Opportunities Fund (closed-end investment company) to 2018.

Current Directorships: Trustee of Gallery Trust, Schroder Series Trust and Schroder Global Series Trust. Independent Non-Executive Director of HFA Holdings Limited.

 

Former Directorships: Trustee of O’Connor EQUUS (closed-end investment company) to 2016. Trustee of Winton Series Trust to 2017. Trustee of Winton Diversified Opportunities Fund (closed-end investment company) to 2018.

4 Directorships of Companies required to report to the securities and Exchange Commission under the Securities Exchange act of 1934 (i.e., “public companies”) or other investment companies under the 1940 act.

 

33


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

     
Name and
Year of Birth
  

Position with

Trust and
Length of
Time Served

   Principal Occupations
in the Past Five Years

OFFICERS

         

MICHAEL BEATTIE

(Born: 1965)

  

President

(Since 2014)

  

Director of Client Service, SEI Investments Company, since 2004.

 

JAMES BERNSTEIN (Born: 1962)   

Vice President (Since 2017) Secretary

(Since 2020)

 

  

Attorney, SEI Investments, since 2017.

 

Prior Positions: Self-employed consultant, 2017. Associate General Counsel & Vice President, Nationwide Funds Group and Nationwide Mutual Insurance Company, from 2002 to 2016. Assistant General Counsel & Vice President, Market Street Funds and Provident Mutual Insurance Company, from 1999 to 2002.

 

JOHN BOURGEOIS

(Born: 1973)

  

Assistant Treasurer (since 2017)

 

   Fund Accounting Manager, SEI Investments, since 2000.
STEPHEN CONNORS (Born: 1984)   

Treasurer, Controller and Chief Financial Officer

(Since 2015)

 

   Director, SEI Investments, Fund Accounting, since 2014. Audit Manager, Deloitte & Touche LLP, from 2011 to 2014.

RUSSELL EMERY

(Born: 1962)

   Chief Compliance Officer (Since 2014)   

Chief Compliance Officer of SEI Structured Credit Fund, LP since 2007. Chief Compliance Officer of The Advisors’ Inner Circle Fund, The Advisors’ Inner Circle Fund II, Bishop Street Funds, The KP Funds, Frost Family of Funds, The Advisors’ Inner Circle Fund III, Gallery Trust, Schroder Series Trust, Schroder Global Series Trust, SEI Institutional Managed Trust, SEI Asset Allocation Trust, SEI Institutional International Trust, SEI Institutional Investments Trust, SEI Daily Income Trust, SEI Tax Exempt Trust, Adviser Managed Trust, New Covenant Funds, SEI Insurance Products Trust and SEI Catholic Values Trust. Chief Compliance Officer of O’Connor EQUUS (closed-end investment company) to 2016. Chief Compliance Officer of SEI Liquid Asset Trust to 2016. Chief Compliance Officer of Winton Series Trust to 2017. Chief Compliance Officer of Winton Diversified Opportunities Fund (closed-end investment company) to 2018.

 

ERIC C. GRIFFITH

(Born: 1969)

  

Vice President and Assistant Secretary (Since 2020)

 

   Vice President and Assistant Secretary (since 2020)
MATTHEW M. MAHER (Born: 1975)    Vice President and Assistant Secretary (Since 2018)   

Counsel at SEI Investments since 2018. Attorney, Blank Rome LLP, from 2015 to 2018. Assistant Counsel & Vice President, Bank of New York Mellon, from 2013 to 2014. Attorney, Dilworth Paxson LLP, from 2006 to 2013.

 

ROBERT MORROW

(Born: 1968)

  

Vice President (Since 2017)

 

   Account Manager, SEI Investments, since 2007.
ALEXANDER F. SMITH (Born: 1977)    Vice President and Assistant Secretary (Since 2020)   

Counsel at SEI Investments since 2020. Associate Counsel & Manager, Vanguard, 2012 to 2020. Attorney, Stradley Ronon Stevens & Young, LLP, 2008 to 2012.

 

 

34


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

 

Other Directorships

Held in the Past Five Years

 

None.

 

 

None.

 

 

None.

 

 

None.

 

None.

 

None.

 

None.

 

None.

 

None.

 

 

35


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

     

Name and

Year of Birth

  

Position with

Trust and

Length of

Time Served

  

Principal Occupations

in the Past Five Years

OFFICERS

         
BRIDGET E. SUDALL (Born: 1980)   

Privacy Officer

(Since 2015)

 

Anti-Money Laundering Officer

(Since 2015)

   Senior Associate and AML Officer, Morgan Stanley Alternative Investment Partners, from 2011 to 2015. Investor Services Team Lead, Morgan Stanley Alternative Investment Partners, from 2007 to 2011.

 

36


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

 

Other Directorships

Held in the Past Five Years

 

None.

 

 

37


THE ADVISORS’ INNER CIRCLE FUND III     KBI GLOBAL INVESTORS
    AQUARIUS FUND  
    JULY 31, 2020  

 

 

 

 NOTICE TO SHAREHOLDERS (Unaudited)

For shareholders that do not have a July 31, 2020 tax year end, this notice is for informational purposes only. For shareholders with a July 31, 2020 tax year end, please consult your tax advisor as to the pertinence of this notice. For the fiscal year ended July 31, 2020, the Fund is designating the following items with regard to distributions paid during the period:

 

      Long Term
      Capital Gain
      Distribution

  Ordinary
Income
Distributions
  Total
Distributions
  Dividends
Qualifying  for
Corporate
Dividend
Received
Deduction(1)
  Qualifying
Dividend
Income(2)
  U.S.
Government
Interest(3)
  Interest
Related
Dividends(4)
  Qualified
Short-
Term
Capital
Gain(5)

2.96%

  97.04%   100.00%   11.15%   55.72%   0.00%   0.19%   100.00%

(1) Qualifying dividends represent dividends which qualify for the corporate dividends received deduction and are reflected as a percentage of ordinary income distributions (the total of short term capital gain and net investment income distributions).

(2) The percentage in this column represents the amount of “Qualifying Dividend Income” as created by the Jobs and Growth Tax Relief Reconciliation Act of 2003 and is reflected as a percentage of ordinary income distributions (the total of short term capital gain and net investment income distributions). It is the intention of the Fund to designate the maximum amount permitted by law.

(3) “U.S. Government Interest” represents the amount of interest that was derived from direct U.S. Government obligations and distributed during the fiscal year. This amount is reflected as a percentage of ordinary income.

(4) The percentage in this column represents the amount of “Interest Related Dividend” and is reflected as a percentage of ordinary income distributions. Interest related dividends are exempted from U.S. withholding tax when paid to foreign investors.

(5) The percentage of this column represents the amount of “Short-Term Capital Gain Dividends” and is reflected as a percentage of short term capital gain distributions that is exempted from U.S. withholding tax when paid to foreign investors.

 

38


KBI Global Investors Aquarius Fund

P.O. Box 588

Portland, ME 04112

1-833-658-4739

Investment Adviser:

KBI Global Investors (North America) Ltd.

3rd Floor, 2 Harbourmaster Place

IFSC

Dublin 1 Ireland

Administrator:

SEI Investments Global Funds Services

One Freedom Valley Drive

Oaks, PA 19456

Distributor:

SEI Investments Distribution Co.

One Freedom Valley Drive

Oaks, PA 19456

Legal Counsel:

Morgan, Lewis & Bockius LLP

1701 Market Street

Philadelphia, PA 19103

Independent Registered Public Accounting Firm:

Ernst & Young LLP

One Commerce Square

2005 Market Street, Suite 700

Philadelphia, PA 19103

This information must be preceded or accompanied by a current prospectus for the Fund described.


Item 2.

Code of Ethics.

The Registrant has adopted a code of ethics that applies to the Registrant’s principal executive officer, principal financial officer, controller or principal accounting officer, and any person who performs a similar function. There have been no amendments to or waivers granted to this code of ethics during the period covered by this report.

 

Item 3.

Audit Committee Financial Expert.

(a)(1) The Registrant’s board of trustees has determined that the Registrant has at least one audit committee financial expert serving on the audit committee.

(a)(2) The audit committee financial experts are Thomas Lemke and Jay Nadel, and each of Messrs. Lemke and Nadel is considered to be “independent”, as that term is defined in Form N-CSR Item 3(a)(2).

 

Item 4.

Principal Accountant Fees and Services.

Fees billed by PricewaterhouseCoopers LLP (“PwC”) relate to The Advisors’ Inner Circle Fund III (the “Trust”).

PwC billed the Trust aggregate fees for services rendered to the Trust for the last two fiscal years as follows:

 

      FYE July 31, 2020    FYE July 31, 2019
          

All fees and

services to

the Trust

that were

pre-approved

  

All fees and

services to

service

affiliates

that were

pre-approved

  

All other

fees and

services to

service

affiliates

that did not

require

pre-approval

  

All fees and

services to

the Trust

that were

pre-approved

  

All fees and

services to

service

affiliates

that were

pre-approved

  

All other

fees and

services to

service

affiliates

that did not

require

pre-approval

(a)     Audit Fees(1)    $581,815    $0    $607,218    $506,015    $0    $0
(b)     Audit-Related Fees    $0    $0    $0    $0    $0    $0
(c)     Tax Fees    $0    $0    $335,050    $0    $0    $60,100
(d)     All Other Fees    $0    $0    $15,941    $0    $0    $10,000


Fees billed by Ernst & Young LLP (“E&Y”) relate to the Trust

E&Y billed the Trust aggregate fees for services rendered to the Trust for the last two fiscal years as follows:

 

      FYE July 31, 2020    FYE July 31, 2019
          

All fees and

services to

the Trust

that were

pre-approved

  

All fees and

services to

service

affiliates

that were

pre-approved

  

All other

fees and

services to

service

affiliates

that did not

require

pre-approval

  

All fees and

services to

the Trust

that were

pre-approved

  

All fees and

services to

service

affiliates

that were

pre-approved

  

All other

fees and

services to

service

affiliates

that did not

require

pre-approval

(a)     Audit Fees(1)    $23,330    None    None    $23,270    None    None
(b)     Audit-Related Fees    None    None    None    None    None    None
(c)     Tax Fees    None    None    None    None    None    None
(d)     All Other Fees    None    None    None    None    None    None

Notes:

  (1)

Audit fees include amounts related to the audit of the Trust’s annual financial statements and services normally provided by the accountant in connection with statutory and regulatory filings.

(e)(1) The Trust’s Audit Committee has adopted and the Board of Trustees has ratified an Audit and Non-Audit Services Pre-Approval Policy (the “Policy”), which sets forth the procedures and the conditions pursuant to which services proposed to be performed by the independent auditor of the Funds may be pre-approved.

The Policy provides that all requests or applications for proposed services to be provided by the independent auditor must be submitted to the Registrant’s Chief Financial Officer (“CFO”) and must include a detailed description of the services proposed to be rendered. The CFO will determine whether such services:

(1) require specific pre-approval; (2) are included within the list of services that have received the general pre-approval of the Audit Committee pursuant to the Policy; or (3) have been previously pre-approved in connection with the independent auditor’s annual engagement letter for the applicable year or otherwise. In any instance where services require pre-approval, the Audit Committee will consider whether such services are consistent with SEC’s rules and whether the provision of such services would impair the auditor’s independence.

Requests or applications to provide services that require specific pre-approval by the Audit Committee will be submitted to the Audit Committee by the CFO. The Audit Committee will be informed by the CFO on a quarterly basis of all services rendered by the independent auditor. The Audit Committee has delegated specific pre-approval authority to either the Audit Committee


Chair or financial expert, provided that the estimated fee for any such proposed pre-approved service does not exceed $100,000 and any pre-approval decisions are reported to the Audit Committee at its next regularly scheduled meeting.

Services that have received the general pre-approval of the Audit Committee are identified and described in the Policy. In addition, the Policy sets forth a maximum fee per engagement with respect to each identified service that has received general pre-approval.

All services to be provided by the independent auditor shall be provided pursuant to a signed written engagement letter with the Registrant, the investment adviser, or applicable control affiliate (except that matters as to which an engagement letter would be impractical because of timing issues or because the matter is small may not be the subject of an engagement letter) that sets forth both the services to be provided by the independent auditor and the total fees to be paid to the independent auditor for those services.

In addition, the Audit Committee has determined to take additional measures on an annual basis to meet the Audit Committee’s responsibility to oversee the work of the independent auditor and to assure the auditor’s independence from the Registrant, such as reviewing a formal written statement from the independent auditor delineating all relationships between the independent auditor and the Registrant, and discussing with the independent auditor the independent auditor’s methods and procedures for ensuring independence.

(e)(2) Percentage of fees billed applicable to non-audit services pursuant to waiver of pre-approval requirement were as follows (PwC):

 

      2020    2019

Audit-Related Fees

   0%    0%

Tax Fees

   0%    0%

All Other Fees

   0%    0%

(e)(2) Percentage of fees billed applicable to non-audit services pursuant to waiver of pre-approval requirement were as follows (E&Y):

 

      2020    2019

Audit-Related Fees

   None    None

Tax Fees

   None    None

All Other Fees

   None    None

(f) Not applicable.

(g) The aggregate non-audit fees and services billed by PwC for services rendered to the Registrant, and rendered to the Registrant’s investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the adviser that provides ongoing services to the Registrant for the last two fiscal years ended July 31st were $350,991 and $70,100, respectively.


(g) The aggregate non-audit fees and services billed by E&Y for services rendered to the Registrant, and rendered to the Registrant’s investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the adviser that provides ongoing services to the Registrant for the last two fiscal years ended July 31st were $0 and $0, respectively.

(h) During the past fiscal year, all non-audit services provided by Registrant’s principal accountant to either Registrant’s investment adviser or to any entity controlling, controlled by, or under common control with Registrant’s investment adviser that provides ongoing services to Registrant were pre-approved by the Audit Committee of Registrant’s Board of Trustees. Included in the Audit Committee’s pre-approval was the review and consideration as to whether the provision of these non-audit services is compatible with maintaining the principal accountant’s independence.

 

Item 5.

Audit Committee of Listed Registrants.

Not applicable to open-end management investment companies.

 

Item 6.

Schedule of Investments.

Schedule of Investments is included as part of the Report to Shareholders filed under Item 1 of this form.

 

Item 7.

Disclosure of Proxy Voting Policies and Procedures for Closed-End Management Investment Companies.

Not applicable to open-end management investment companies.

 

Item 8.

Portfolio Managers of Closed-End Management Investment Companies.

Not applicable to open-end management investment companies.

 

Item 9.

Purchases of Equity Securities by Closed-End Management Company and Affiliated Purchasers.

Not applicable to open-end management investment companies.

 

Item 10.

Submission of Matters to a Vote of Security Holders.

There have been no changes to the procedures by which shareholders may recommend nominees to the Registrant’s Board of Trustees during the period covered by this report.

 

Item 11.

Controls and Procedures.

(a) The Registrant’s principal executive and principal financial officers, or persons performing similar functions have concluded that the Registrant’s disclosure controls and procedures, as defined in Rule 30a-3(c) under the Act (17 CFR § 270.30a-3(c)) as of a date within 90 days of the filing date of the report, are effective based on the evaluation of these controls and procedures required by Rule 30a-3(b) under the Act (17 CFR § 270.30a-3(b)) and Rule 13a-15(b) or Rule 15d-15(b) under the Exchange Act (17 CFR § 270.30a-15(b) or § 240.15d-15(b)).

(b) There has been no change in the Registrant’s internal control over financial reporting (as defined in Rule 30a-3(d) under the Act (17 CFR § 270.3a-3(d)) that occurred during the period covered by this report that has materially affected, or is reasonably likely to materially affect, the Registrant’s internal control over financial reporting.


Items 12.

Disclosure of Securities Lending Activities for Closed-End Management Investment Companies.

Not applicable to open-end management investment companies.

 

Items 13.

Exhibits.

(a)(1) A copy of the Registrant’s Code of Ethics, as required by Item 2 of this Form, accompanies this filing as an exhibit.

(a)(2) A separate certification for the principal executive officer and the principal financial officer of the Registrant, as required by Rule 30a-2(a) under the Act (17 CFR § 270.30a-2(a)), is filed herewith.

(b) Officer certifications, as required by Rule 30a-2(b) under the Act (17 CFR § 270.30a-2(b)), also accompany this filing as an exhibit.


SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the Registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

 

(Registrant)       The Advisors’ Inner Circle Fund III
By (Signature and Title)      

/s/ Michael Beattie

     

Michael Beattie,

President

Date: October 9, 2020      

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the Registrant and in the capacities and on the dates indicated.

 

By (Signature and Title)      

/s/ Michael Beattie

     

Michael Beattie,

President

Date: October 9, 2020      
By (Signature and Title)      

/s/ Stephen Connors

     

Stephen Connors,

Treasurer, Controller, and CFO

Date: October 9, 2020      

Policy Statement: Sarbanes-Oxley effected sweeping corporate disclosure and financial reporting reform on public companies, including mutual funds, to address corporate malfeasance and assure investors that the companies in which the investors invest are accurately and completely disclosing financial information. Under Sarbanes-Oxley, all public companies (including the Funds) must either have a code of ethics for their senior financial officers, or disclose why the company does not have a code of ethics. Sarbanes-Oxley was intended to foster corporate environments which encourage employees to question and report unethical and potentially illegal business practices.

Each Fund has chosen to adopt a code of ethics (“Code of Ethics for Financial Officers”) to encourage the Fund’s Principal Executive Officer, Principal Financial, and Accounting Officer and Controller (the “Financial Officers”) for the purpose of promoting:

 

   

Honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships.

 

   

Full, fair, accurate, timely, and understandable disclosure in reports and documents that a registrant files with, or submits to, the SEC and in other public communications made by the Funds.

 

   

Compliance with applicable laws and governmental rules and regulations.

 

   

Prompt internal reporting of violations of the Code of Ethics for Financial Officers to an appropriate person or persons identified in the Code of Ethics of Financial Officers.

 

   

Accountability for adherence to the Code of Ethics for Financial Officers.

Procedures: The Funds have adopted the following procedures regarding this matter:

A compliance officer is responsible for monitoring compliance with these procedures.

FINANCIAL OFFICER CODE OF ETHICS

 

I.

Introduction

The reputation and integrity of Series Trusts, (each a “Trust” and, collectively, the “Trusts”) are valuable assets that are vital to the each Trust’s success. The Trusts’ senior financial officers (“SFOs”) are responsible for conducting the Trusts’ business in a manner that demonstrates a commitment to the highest standards of integrity. The Trusts’ SFOs include the principal executive officer, the principal financial officer, comptroller or principal accounting officer, and any person who performs a similar function.

The Sarbanes-Oxley Act of 2002 (the “Act”) effected sweeping corporate disclosure and financial reporting reform on public companies, including mutual funds, to address corporate malfeasance and assure investors that the companies in which the investors invest are accurately and completely disclosing financial information. Under the Act, all public companies (including


the Trusts) must either have a code of ethics for their SFOs, or disclose why the company does not have a code of ethics. The Act was intended to foster corporate environments which encourage employees to question and report unethical and potentially illegal business practices. Each Trust has chosen to adopt this Financial Officer Code of Ethics (the “Code”) to encourage the Trust’s SFOs to act in a manner consistent with the highest principles of ethical conduct.

 

II.

Purposes of the Code

The purposes of this Code are:

 

  1.

To promote honest and ethical conduct by each Trust’s SFOs, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;

 

  2.

To assist each Trust’s SFOs in recognizing and avoiding conflicts of interest, including disclosing to an appropriate person any material transaction or relationship that reasonably could be expected to give rise to such a conflict;

 

  3.

To promote full, fair, accurate, timely, and understandable disclosure in reports and documents that the Trusts file with, or submit to, the SEC and in other public communications made by the Trusts;

 

  4.

To promote compliance with applicable laws, rules, and regulations;

 

  5.

To encourage the prompt internal reporting to an appropriate person of violations of this Code; and

 

  6.

To establish accountability for adherence to this Code.

 

III.

Questions about this Code

Each Trust’s compliance officer designated to oversee compliance with the Trust’s Code of Ethics adopted pursuant to Rule 17j-1 shall serve as Compliance Officer for the implementation and administration of this Code. You should direct your questions about this Code to the Compliance Officer.

 

IV.

Conduct Guidelines

Each Trust has adopted the following guidelines under which the Trust’s SFOs must perform their official duties and conduct the business affairs of the Trust.

 

  1.

Ethical and honest conduct is of paramount importance. Each Trust’s SFOs must act with honesty and integrity and avoid violations of this Code, including the avoidance of actual or apparent conflicts of interest with the Trust in personal and professional relationships.

 

  2.

SFOs must disclose material transactions or relationships. Each Trust’s SFOs must disclose to the Compliance Officer any actual or apparent conflicts of interest the SFO may have with the Trust that reasonably could be expected to give rise to any violations of this Code. Such conflicts of interest may arise as a result of material transactions or business or personal relationships to which the SFO may be a party. If it is not possible to disclose the matter to the Compliance Officer, the matter should be disclosed to the


  Trust’s Chief Financial Officer, Chief Executive Officer, or another appropriate person. In addition to disclosing any actual or apparent conflicts of interest in which an SFO is personally involved, the Trusts’ SFOs have an obligation to report any other actual or apparent conflicts which the SFOs discover or of which the SFOs otherwise become aware. If you are unsure whether a particular fact pattern gives rise to a conflict of interest, or whether a particular transaction or relationship is “material,” you should bring the matter to the attention of the Compliance Officer.

 

  3.

Standards for quality of information shared with service providers of the Trusts. Each Trust’s SFOs must at all times seek to provide information to the Trust’s service providers (adviser, administrator, outside auditor, outside counsel, custodian, etc.) that is accurate, complete, objective, relevant, timely, and understandable.

 

  4.

Standards for quality of information included in periodic reports. Each Trust’s SFOs must at all times endeavor to ensure full, fair, timely, accurate, and understandable disclosure in the Trust’s periodic reports.

 

  5.

Compliance with laws. Each Trust’s SFOs must comply with the federal securities laws and other laws and rules applicable to the Trusts, such as the Internal Revenue Code.

 

  6.

Standard of care. Each Trust’s SFOs must at all times act in good faith and with due care, competence, and diligence, without misrepresenting material facts or allowing your independent judgment to be subordinated. Each Trust’s SFOs must conduct the affairs of the Trust in a responsible manner, consistent with this Code.

 

  7.

Confidentiality of information. Each Trust’s SFOs must respect and protect the confidentiality of information acquired in the course of their professional duties, except when authorized by the Trust to disclose this information or where disclosure is otherwise legally mandated. You may not use confidential information acquired in the course of your work for personal advantage.

 

  8.

Sharing of information and educational standards. Each Trust’s SFOs should share information with relevant parties to keep these parties informed of the business affairs of the Trust, as appropriate, and to maintain skills important and relevant to the Trust’s needs.

 

  9.

Promote ethical conduct. Each Trust’s SFOs at all times should proactively promote ethical behavior among peers in the SFOs work environment.

 

  10.

Standards for recordkeeping. Each Trust’s SFOs at all times must endeavor to ensure that the Trust’s financial books and records are thoroughly and accurately maintained to the best of the SFOs knowledge in a manner consistent with applicable laws and this Code.

 

V.

Waivers of this Code

You may request a waiver of a provision of this Code by submitting your request in writing to the Compliance Officer for appropriate review. For example, if a family member works for a service provider that prepares a Trust’s financial statements, you may have a potential conflict of interest in reviewing those statements and should seek a waiver of this Code to review the work. An executive officer of each Trust, or another appropriate person (such as a designated Board or Audit Committee member), will decide whether to grant a waiver. All waivers of this code must be disclosed to the applicable Trust’s shareholders and the designated Board to the extent required by SEC rules.


VI.

Affirmation of the Code

Upon adoption of the Code, each Trust’s SFOs must affirm in writing that the SFO has received, has read, and understands the Code, and annually thereafter must affirm that they have complied with the requirements of the Code. To the extent necessary, each Trust’s Compliance Officer will provide guidance on the conduct required by this Code and the manner in which violations or suspected violations must be reported and waivers must be requested.

 

VII.

Reporting Violations

In the event that an SFO discovers or, in good faith, suspects a violation of this Code, the SFO must immediately report the violation or suspected violation to the Compliance Officer. The Compliance Officer, in his or her discretion, may consult with another member of the Trust’s senior management or the Board in determining how to address the suspected violation. For example, a Code violation may occur when a periodic report or financial statement of a Trust omits a material fact, or is technically accurate but, in the view of the SFO, is written in a way that obscures the report’s or financial statement’s meaning.

SFOs who report violations or suspected violations in good faith will not be subject to retaliation of any kind. Reported violations will be investigated and addressed promptly and will be treated as confidential to the extent possible.

 

VIII.

Violations of the Code

Dishonest or unethical conduct or conduct that is illegal will constitute a violation of this Code, regardless of whether this Code specifically refers to such particular conduct. A violation of this Code may result in disciplinary action, up to and including removal as an SFO of the Trust. A variety of laws apply to the Trusts and their operations, including the Securities Act of 1933, the Investment Company Act of 1940, state laws relating to duties owed by Trust officers, and criminal laws. The Trusts will report any suspected criminal violations to the appropriate authorities, and will investigate, address, and report, as appropriate, non-criminal violations.

CERTIFICATION

Pursuant to Rule 30a-2(a) under the Investment Company Act of 1940

and Section 302 of the Sarbanes-Oxley Act of 2002

I, Michael Beattie, certify that:

1. I have reviewed this report on Form N-CSR of The Advisors’ Inner Circle Fund III (the “Registrant”);

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3. Based on my knowledge, the financial statements, and other financial information, included in this report fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the Registrant as of, and for, the periods presented in this report;

4. The Registrant’s other certifying officer(s), if any, and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the Registrant and have:

(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the Registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;

(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

(c) Evaluated the effectiveness of the Registrant’s disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report, based on such evaluation; and

(d) Disclosed in this report any change in the Registrant’s internal control over financial reporting that occurred during the period covered by this report that has materially affected, or is reasonably likely to materially affect, the Registrant’s internal control over financial reporting; and

5. The Registrant’s other certifying officer(s) and I have disclosed to the Registrant’s auditors and the audit committee of the Registrant’s board of directors (or persons performing the equivalent functions):

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the Registrant’s ability to record, process, summarize, and report financial information; and

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the Registrant’s internal control over financial reporting.

 

Date: October 9, 2020

/s/ Michael Beattie

Michael Beattie

President


CERTIFICATION

Pursuant to Rule 30a-2(a) under the Investment Company Act of 1940

and Section 302 of the Sarbanes-Oxley Act of 2002

I, Stephen Connors, certify that:

1. I have reviewed this report on Form N-CSR of The Advisors’ Inner Circle Fund III (the “Registrant”);

2. Based on my knowledge, this report does not contain any untrue statement of a material fact or omit to state a material fact necessary to make the statements made, in light of the circumstances under which such statements were made, not misleading with respect to the period covered by this report;

3. Based on my knowledge, the financial statements, and other financial information, included in this report fairly present in all material respects the financial condition, results of operations, changes in net assets, and cash flows (if the financial statements are required to include a statement of cash flows) of the Registrant as of, and for, the periods presented in this report;

4. The Registrant’s other certifying officer(s), if any, and I are responsible for establishing and maintaining disclosure controls and procedures (as defined in Rule 30a-3(c) under the Investment Company Act of 1940) and internal control over financial reporting (as defined in Rule 30a-3(d) under the Investment Company Act of 1940) for the Registrant and have:

(a) Designed such disclosure controls and procedures, or caused such disclosure controls and procedures to be designed under our supervision, to ensure that material information relating to the Registrant, including its consolidated subsidiaries, is made known to us by others within those entities, particularly during the period in which this report is being prepared;

(b) Designed such internal control over financial reporting, or caused such internal control over financial reporting to be designed under our supervision, to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles;

(c) Evaluated the effectiveness of the Registrant’s disclosure controls and procedures and presented in this report our conclusions about the effectiveness of the disclosure controls and procedures, as of a date within 90 days prior to the filing date of this report, based on such evaluation; and

(d) Disclosed in this report any change in the Registrant’s internal control over financial reporting that occurred during the period covered by this report that has materially affected, or is reasonably likely to materially affect, the Registrant’s internal control over financial reporting; and

5. The Registrant’s other certifying officer(s) and I have disclosed to the Registrant’s auditors and the audit committee of the Registrant’s board of directors (or persons performing the equivalent functions):

(a) All significant deficiencies and material weaknesses in the design or operation of internal control over financial reporting which are reasonably likely to adversely affect the Registrant’s ability to record, process, summarize, and report financial information; and

(b) Any fraud, whether or not material, that involves management or other employees who have a significant role in the Registrant’s internal control over financial reporting.

Date: October 9, 2020

 

/s/ Stephen Connors

Stephen Connors

Treasurer, Controller, and CFO

CERTIFICATION

Pursuant to 18 U.S.C. Section 1350,

As Adopted Pursuant to Section 906

of the Sarbanes-Oxley Act of 2002

The undersigned, Michael Beattie, the President of The Advisors’ Inner Circle Fund III (the “Fund”), with respect to the Fund’s Form N-CSR for the period ended July 31, 2020, as filed with the Securities and Exchange Commission, hereby certifies, pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002, that, to the best of my knowledge:

1. such Form N-CSR fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and

2. the information contained in such Form N-CSR fairly presents, in all material respects, the financial condition and results of operations of the Fund.

Dated: October 9, 2020

 

/s/ Michael Beattie

Michael Beattie
President


CERTIFICATION

Pursuant to 18 U.S.C. Section 1350,

As Adopted Pursuant to Section 906

of the Sarbanes-Oxley Act of 2002

The undersigned, Stephen Connors, the Treasurer, Controller, and CFO of The Advisors’ Inner Circle Fund III (the “Fund”), with respect to the Fund’s Form N-CSR for the period ended July 31, 2020, as filed with the Securities and Exchange Commission, hereby certifies, pursuant to 18 U.S.C. Section 1350, as adopted pursuant to Section 906 of the Sarbanes-Oxley Act of 2002, that, to the best of my knowledge:

1. such Form N-CSR fully complies with the requirements of Section 13(a) or 15(d) of the Securities Exchange Act of 1934; and

2. the information contained in such Form N-CSR fairly presents, in all material respects, the financial condition and results of operations of the Fund.

Dated: October 9, 2020

 

/s/ Stephen Connors

Stephen Connors
Treasurer, Controller, and CFO