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, Pennsylvania 19456

(Address of principal executive offices) (Zip code)

SEI Investments

One Freedom Valley Drive

Oaks, Pennsylvania 19456

(Name and address of agent for service)

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

Date of fiscal year end: September 30, 2020

Date of reporting period: September 30, 2020


Item 1.    Reports to Stockholders.

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


The Advisors’ Inner Circle Fund III

 

LOGO

RWC Global Emerging Equity Fund

 

ANNUAL REPORT

   September 30, 2020  

 

Investment Adviser:

RWC Asset Advisors (US) LLC

 

Beginning on January 1, 2021, as permitted by regulations adopted by the Securities and Exchange Commission, paper copies of the Fund’s shareholder reports will no longer be sent by mail, unless you specifically request paper copies of the reports from the Fund 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 Fund electronically by contacting your financial intermediary, or, if you are a direct investor, by calling 1-855-RWC-FUND.

 

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 Fund, you can inform the Fund that you wish to continue receiving paper copies of your shareholder reports by calling 1-855-RWC-FUND. 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 RWC Asset Advisors (US) LLC if you invest directly with the Fund.

 


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

TABLE OF CONTENTS

 

 

 

Shareholder Letter

     1  

Schedule of Investments

     4  

Statement of Assets and Liabilities

     9  

Statement of Operations

     10  

Statements of Changes in Net Assets

     11  

Financial Highlights

     12  

Notes to Financial Statements

     14  

Report of Independent Registered Public Accounting Firm

     29  

Trustees and Officers of The Advisors’ Inner Circle Fund III

     30  

Disclosure of Fund Expenses

     36  

Approval of Investment Advisory Agreement

     38  

Notice to Shareholders

     44  

The Fund files its complete schedule of investments with the Securities and Exchange Commission (the “Commission”) 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 Commission’s website at https://www.sec.gov, and may be reviewed and copied at the Commission’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 1-855-RWC-FUND; and (ii) on the Commission’s website at https://www.sec.gov.


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

 LETTER TO SHAREHOLDERS (Unaudited)

Dear Shareholders:

Emerging markets rose during the year despite significant headwinds such as the effects of Covid-19 and a continuation of trade tensions. The RWC Global Emerging Equity Fund Institutional Class Shares returned +11.29% during the period, versus the MSCI Emerging Markets Net TR Index’s return of +10.54%. Governments and authorities worldwide provided significant levels of stimulus which aided the economic recovery in many emerging markets. Economic activity, capacity utilisation and population mobility improved during the third quarter of 2020 as Covid-19 cases and deaths flatlined in most emerging markets. North Asian markets were responsible for the majority of these gains as China, South Korea and Taiwan rose +33.1%, +18.6% and +35.0% year-on-year respectively. Macroeconomic data remains encouraging. Chinese PMIs (Purchasing Managers Index) maintained levels above 50, industrial profit growth was up +19.5% year-on-year and regional exports have staged a significant recovery. India rose +8.4% as the country’s administration implemented significant fiscal stimulus in response to Covid-19. In the EEMEA (Eastern Europe, Middle East and Africa) region, South Africa fell -10.6% while Russia declined -15.9% as Brent crude oil fell -30.5% to c.$40 per barrel. In Latin America, Brazil fell -32.5% as the Brazilian Real depreciated significantly against the dollar. Accommodative monetary policy, fiscal stimulus and reform will likely aid the country’s recovery.

A key contributor to performance came from our technology disruption thematic. The largest being Mercado Libre, a Latin American e-commerce company. The share price rose +110.8% during the year as the company reported strong results showing strong GMV (Gross Merchandise Value) growth including encouraging trends during lockdown. Net revenues increased +55.8% year-on-year while total payment volumes increased +82% year-on-year. Going forward, Mercado Libre should profit from increased digital, e-commerce and payments penetration throughout Latin America. Delivery Hero, one of the world’s leading online food delivery companies, rose +160.9% as Covid-19 restrictions worldwide led to c.100% growth in order volumes year-on-year. Furthermore, the acquisitions of Glovo’s Latin America business and Woowa in Korea should help the company solidify its leading position. Russia was a significant contributor to performance. Yandex rose +85.6% during the year. The company continues to be a beneficiary of growth in ride hailing penetration, digital advertising and financial technology. The fund’s copper and precious metals exposure was also a contributor to performance as copper and gold rose +18.4% and +27.5% respectively, due to constrained supply, a recovery in global growth and global monetary conditions. First Quantum Minerals, AngloGold and KAZ Minerals rose +6.0%, +39.2% and +29.7% respectively.

India detracted from the fund’s performance. The outlook for the country remains positive and some companies, such as HDFC, should benefit from a recovery in GDP growth and accommodative monetary policy. The company’s recent earnings results showed +18.4% year-on-year growth in earnings and continued investments in technology which should help the company maintain its competitive advantages. Brazil was an absolute detractor for the

 

1


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

fund. However, the outlook for the country remains positive. The economy should remain well-supported due to accommodative monetary policy, a stable current account and a competitive currency. Additionally, the Bolsonaro administration could pass tax and administrative reforms which would help reduce the country’s fiscal deficit. Petrobras should profit from continued asset disposals while Rumo will likely benefit from the integration of the recently acquired Malha Central concession. Tullow Oil, a leading oil and gas exploration and production company, fell sharply over the period due to concerns surrounding production and the -30.4% fall in Brent crude oil. However, the Ugandan authorities have recently approved the sale of Tullow’s Uganda assets to Total. This should provide the company with an improved liquidity profile and pave the way for the company’s return to growth.

Fundamentally, we think the outlook for emerging market equities is encouraging. Most governments and authorities are dealing with Covid-19 effectively and stimulus measures are supporting a global economic recovery. Emerging market current accounts are stabilizing, currencies are competitive and valuations are attractive relative to developed markets. The uncertainty surrounding the upcoming US presidential elections should continue to pressure the dollar leading to increased capital flows into emerging markets. In Asia, China, South Korea and Taiwan continue to recover as business confidence, industrial profits and exports improve. This should lead to increased corporate earnings growth across the region. In EEMEA, the oil price remains well supported as demand recovers amid curtailed supply. Russia should benefit from the central bank’s continued accommodative monetary policy. In Latin America, accommodative monetary policy should also benefit Brazil. Furthermore, the country’s current account is now in positive territory while future administrative and tax reform will likely aid the country’s fiscal dynamics.

Definition of the Comparative Index

MSCI Emerging Markets Index is a free float-adjusted market capitalization index that is designed to measure equity market performance of emerging markets.

The material represents the Adviser’s assessment of the portfolio and market environment at a specific point in time and should not be relied upon by the reader as research or investment advice regarding any stock.

Past performance is not a guarantee of future results. Investing involves risk, including possible loss of principal. International investments may involve risk of capital loss from unfavourable fluctuation in currency values, from differences in generally accepted accounting principles or from economic or political instability in other nations. Emerging markets involve heightened risks related to the same factors as well as increased volatility and lower trading volume.

 

2


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020 (Unaudited)

 

 

Comparison of Change in the Value of a $10,000,000 Investment in the RWC Global Emerging Equity Fund, Institutional Class Shares versus the MSCI Emerging Markets Index.

 

  AVERAGE ANNUAL TOTAL RETURN FOR

THE PERIODS ENDED SEPTEMBER 30, 2020*

  One Year   Three Year   Annualized Inception to Date

Institutional Class Shares

  11.29%   (1.03)%   6.64%

Class I Shares†

  11.24%   (1.14)%   (0.87)%

MSCI Emerging Markets Index

  10.54%   2.42%   8.81%

 

LOGO

* The RWC Global Emerging Equity Fund commenced operations on December 30, 2016.

† The graph is based on Institutional Class Shares only. Returns for Class I Shares are substantially similar to those of the Institutional Class Shares and differ only to the extent that Class I Shares have higher total annual fund operating expenses than Institutional Class Shares.

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 Fund’s performance assumes the reinvestment of dividends and capital gains. Index returns assume reinvestment of dividends and, unlike a fund’s returns, do not reflect 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.

High short-term performance from a limited number of the Fund’s holdings is unusual, and investors should not expect such performance to be continued over the long term.

There are no assurances that the Fund will meet its stated objectives. The Fund’s holdings and allocations are subject to change because it is actively managed 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  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

 SECTOR WEIGHTINGS† (Unaudited):

 

LOGO

 

 SCHEDULE OF INVESTMENTS

    

 COMMON STOCK — 98.6%

    
    Shares      Value  

Argentina — 1.2%

    

MercadoLibre *

    2,089       $ 2,261,301  
    

 

 

 

Brazil — 6.1%

    

Pagseguro Digital, Cl A *

    62,561        2,359,175  

Petrobras Distribuidora

    237,760        857,572  

Petroleo Brasileiro ADR

    524,260        3,732,731  

Rumo *

    845,933        2,863,576  

TIM Participacoes *

    745,800        1,722,772  
    

 

 

 
               11,535,826  
    

 

 

 

Chile — 0.2%

    

Sociedad Quimica y Minera de Chile ADR

    14,671        475,634  
    

 

 

 

China — 30.8%

    

Alibaba Group Holding ADR *

    33,912        9,969,450  

Beijing Sinnet Technology, Cl A

    903,049        2,985,430  

Focus Media Information Technology, Cl A

    4,961,768        5,904,708  

Gree Electric Appliances of Zhuhai, Cl A

    419,500        3,308,702  

Hangzhou Robam Appliances, Cl A

    157,231        758,442  

Huazhu Group ADR

    84,721        3,663,336  

JD.com ADR *

    62,884        4,880,427  

 

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

 

4


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

 COMMON STOCK — continued

 

    Shares      Value  

China — (continued)

    

JOYY ADR

    25,931        $ 2,091,854  

New Oriental Education & Technology Group ADR *

    12,216        1,826,292  

NIO ADR *

    297,865        6,320,695  

Pinduoduo ADR *

    40,188        2,979,940  

Sangfor Technologies, Cl A

    118,056        3,686,835  

Shenzhen Kangtai Biological Products, Cl A

    17,700        475,164  

Shenzhen Sunway Communication, Cl A

    552,791        4,476,922  

Zhejiang Huayou Cobalt, Cl A *

    544,363        2,801,954  

Zhejiang NHU, Cl A

    502,508        2,209,454  
    

 

 

 
               58,339,605  
    

 

 

 

Democratic Republic of Congo — 0.7%

    

Ivanhoe Mines, Cl A *

    359,669        1,303,236  
    

 

 

 

Egypt — 0.4%

    

Commercial International Bank Egypt SAE

    188,471        796,203  
    

 

 

 

Ghana — 0.2%

    

Tullow Oil *

    2,182,807        431,122  
    

 

 

 

Greece — 0.6%

    

Cairo Mezz *

    182,956        15,426  

Eurobank Ergasias Services and Holdings *

    2,343,972        1,036,699  
    

 

 

 
       1,052,125  
    

 

 

 

Hong Kong — 8.3%

    

Galaxy Entertainment Group *

    338,900        2,292,051  

Geely Automobile Holdings

    968,000        1,951,880  

Huazhu Group *

    12,600        559,277  

Meituan Dianping, Cl B *

    78,312        2,471,467  

Tencent Holdings

    125,495        8,461,650  
    

 

 

 
       15,736,325  
    

 

 

 

India — 9.4%

    

Housing Development Finance

    142,019        3,358,567  

ICICI Lombard General Insurance

    126,134        2,227,216  

Reliance Industries

    224,288        6,807,114  

SBI Cards & Payment Services

    128,880        1,485,267  

Tata Consultancy Services

    68,477        2,319,918  

 

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

 

5


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

 COMMON STOCK — continued

 

    Shares      Value  

India — (continued)

    

United Spirits *

    214,461        $ 1,505,812  
    

 

 

 
               17,703,894  
    

 

 

 

Kazakhstan — 1.5%

    

Halyk Savings Bank of Kazakhstan JSC GDR

    47,446        502,420  

Halyk Savings Bank of Kazakhstan JSC GDR

    386        4,124  

KAZ Minerals

    277,767        1,881,120  

NAC Kazatomprom JSC GDR

    24,779        361,773  
    

 

 

 
       2,749,437  
    

 

 

 

Kuwait — 2.4%

    

Delivery Hero *

    38,966        4,481,535  
    

 

 

 

Russia — 5.9%

    

Sberbank of Russia PJSC ADR

    355,407        4,144,405  

Yandex, Cl A *

    106,738        6,964,654  
    

 

 

 
       11,109,059  
    

 

 

 

South Africa — 5.6%

    

AngloGold Ashanti ADR

    117,058        3,087,990  

FirstRand

    1,528,318        3,778,290  

Gold Fields ADR

    145,769        1,791,501  

Sibanye Stillwater

    692,010        1,906,147  
    

 

 

 
       10,563,928  
    

 

 

 

South Korea — 9.1%

    

LG Chemical

    5,679        3,173,477  

NAVER

    12,150        3,081,963  

NCSoft

    2,443        1,684,709  

Samsung Electro-Mechanics

    24,962        2,965,364  

Samsung Electronics

    128,282        6,377,749  
    

 

 

 
       17,283,262  
    

 

 

 

Taiwan — 9.0%

    

Globalwafers

    197,482        2,641,349  

Hiwin Technologies

    64,660        642,247  

MediaTek

    126,660        2,680,584  

Taiwan Semiconductor Manufacturing

    728,304        11,003,006  
    

 

 

 
       16,967,186  
    

 

 

 

 

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

 

6


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

 COMMON STOCK — continued

 

    Shares      Value  

Thailand — 0.7%

    

Minor International NVDR *

    2,129,994        $ 1,354,042  
    

 

 

 

Turkey — 0.8%

    

Turk Hava Yollari AO *

    1,124,603        1,534,834  
    

 

 

 

Vietnam — 1.4%

    

Hoa Phat Group JSC

    1,852,770        2,112,559  

Vincom Retail JSC *

    496,233        590,419  
    

 

 

 
       2,702,978  
    

 

 

 

Zambia — 4.3%

    

First Quantum Minerals

    914,649        8,127,931  
    

 

 

 

TOTAL COMMON STOCK
(Cost $154,717,510)

       186,509,463  
    

 

 

 

 PREFERRED STOCK — 1.6%

 

South Korea — 1.6%

    

Samsung Electronics (A)

    67,742        2,918,564  
    

 

 

 

TOTAL PREFERRED STOCK
(Cost $2,114,342)

       2,918,564  
    

 

 

 

 EQUITY-LINKED WARRANTS — 0.0%

 

Thailand — 0.0%

    

Minor International, Expires 09/30/21 *

    116,907        1,476  

Minor International, Expires 07/31/23 *

    94,572        22,234  
    

 

 

 
       23,710  
    

 

 

 

TOTAL EQUITY-LINKED WARRANTS
(Cost $—)

       23,710  
    

 

 

 

TOTAL INVESTMENTS — 100.2%
(Cost $156,831,852)

     $     189,451,737  
    

 

 

 

Percentages are based on Net Assets of $189,123,233.

 

*

Non-income producing security.

(A)

There is currently no rate available.

 

 

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

 

7


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

ADR    American Depositary Receipt
Cl    Class
GDR    Global Depositary Receipt
JSC    Joint Stock Company
NVDR    Non-Voting Depositary Receipt
PJSC    Public Joint Stock Company
SAE    Eqyptian Joint Stock Company

The following table summarizes the inputs used as of September 30, 2020, in valuing the Fund’s investments carried at value:

 

Investments in Securities   Level 1     Level 2     Level 3     Total  

Common Stock

       

Argentina

  $ 2,261,301     $     $               —     $ 2,261,301  

Brazil

    11,535,826                   11,535,826  

Chile

    475,634                   475,634  

China

    31,731,994       26,607,611             58,339,605  

Democratic Republic of Congo

    1,303,236                   1,303,236  

Egypt

          796,203             796,203  

Ghana

          431,122             431,122  

Greece

    15,426       1,036,699             1,052,125  

Hong Kong

    559,277       15,177,048             15,736,325  

India

          17,703,894             17,703,894  

Kazakhstan

    864,193       1,885,244             2,749,437  

Kuwait

          4,481,535             4,481,535  

Russia

    6,964,654       4,144,405             11,109,059  

South Africa

    4,879,491       5,684,437             10,563,928  

South Korea

          17,283,262             17,283,262  

Taiwan

          16,967,186             16,967,186  

Thailand

          1,354,042             1,354,042  

Turkey

          1,534,834             1,534,834  

Vietnam

          2,702,978             2,702,978  

Zambia

    8,127,931                   8,127,931  
 

 

 

   

 

 

   

 

 

   

 

 

 

Total Common Stock

    68,718,963       117,790,500             186,509,463  
 

 

 

   

 

 

   

 

 

   

 

 

 

Preferred Stock

       

South Korea

          2,918,564             2,918,564  
 

 

 

   

 

 

   

 

 

   

 

 

 

Equity-Linked Warrants

       

Thailand

          23,710             23,710  
 

 

 

   

 

 

   

 

 

   

 

 

 

Total Investments in Securities

  $   68,718,963     $   120,732,774     $     $   189,451,737  
 

 

 

   

 

 

   

 

 

   

 

 

 

For the year ended September 30, 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.

 

8


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

 STATEMENT OF ASSETS AND LIABILITIES

 

Assets:

  

Investments, at Value (Cost $156,831,852)

   $ 189,451,737  

Cash and Cash Equivalent

     2,673,540  

Foreign Currency, at Value (Cost $202,595)

     202,658  

Receivable for Investment Securities Sold

     631,038  

Dividend and Interest Receivable

     140,628  

Receivable for Capital Shares Sold

     98,241  

Unrealized Appreciation on Foreign Spot Currency Contracts

     2,563  

Reclaim Receivable

     2,477  

Other Prepaid Expenses

     219,877  
  

 

 

 

Total Assets

     193,422,759  
  

 

 

 

Liabilities:

  

Payable for Investment Securities Purchased

     2,790,443  

Payable for Capital Shares Redeemed

     804,700  

Accrued Foreign Capital Gains Tax on Appreciated Securities

     262,376  

Payable to Investment Adviser

     119,559  

Payable to Administrator

     18,900  

Shareholder Servicing Fees Payable

     4,063  

Chief Compliance Officer Fees Payable

     1,606  

Payable to Trustees

     157  

Other Accrued Expenses and Other Payables

     297,722  
  

 

 

 

Total Liabilities

     4,299,526  
  

 

 

 

Net Assets

   $ 189,123,233  
  

 

 

 

Net Assets Consist of:

  

Paid-in Capital

   $ 186,230,383  

Total Distributable Earnings

     2,892,850  
  

 

 

 

Net Assets

   $ 189,123,233  
  

 

 

 

Institutional Class Shares:

  

Net Assets

   $ 38,173,762  

Outstanding Shares of beneficial interest (unlimited authorization — no par value)

     3,062,492  

Net Asset Value, Offering and Redemption Price Per Share

   $ 12.46  
  

 

 

 

Class I Shares:

  

Net Assets

   $ 150,949,471  

Outstanding Shares of beneficial interest (unlimited authorization — no par value)

     12,130,859  

Net Asset Value, Offering and Redemption Price Per Share

   $ 12.44  
  

 

 

 

 

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

 

9


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

FOR THE YEAR ENDED

SEPTEMBER 30, 2020

 

 

 STATEMENT OF OPERATIONS

 

Investment Income:

 

Dividends

  $ 1,795,571  

Interest

    10,666  

Less: Foreign Taxes Withheld

    (210,482
 

 

 

 

Total Investment Income

    1,595,755  
 

 

 

 

Expenses:

 

Investment Advisory Fees (Note 5)

    1,530,095  

Administration Fees (Note 4)

    204,013  

Shareholder Serving Fees, Class I Shares (Note 4)

    118,327  

Trustees’ Fees

    17,712  

Chief Compliance Officer Fees (Note 3)

    6,611  

Custodian Fees (Note 4)

    157,405  

Transfer Agent Fees (Note 4)

    81,652  

Professional Fees

    62,271  

Printing Fees

    24,276  

Registration and Filing Fees

    21,488  

Other Expenses

    47,341  
 

 

 

 

Total Expenses

    2,271,191  
 

 

 

 

Less:

 

Waiver of Investment Advisory Fees (Note 5)

    (33,635

Net Recovery of Investment Advisory Fees Previously Waived (Note 5)

    4,622  
 

 

 

 

Net Expenses

    2,242,178  
 

 

 

 

Net Investment Loss

    (646,423
 

 

 

 

Net Realized Gain (Loss) on:

 

Investments

    (8,480,267

Foreign Currency Transactions

    (162,338
 

 

 

 

Net Realized Loss

    (8,642,605
 

 

 

 

Net Change in Unrealized Appreciation (Depreciation) on:

 

Investments

             27,257,812  

Foreign Capital Gains Tax on Appreciated Securities

    5,299  

Foreign Currency Transactions and Translation of Other Assets and Liabilities Denominated in Foreign Currencies

    (1,301
 

 

 

 

Net Change in Unrealized Appreciation

    27,261,810  
 

 

 

 

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

    18,619,205  
 

 

 

 

Net Increase in Net Assets Resulting from Operations

  $ 17,972,782  
 

 

 

 

 

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

 

10


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

 

 

 STATEMENTS OF CHANGES IN NET ASSETS

 

     Year
Ended
September 30,
2020
    Year
Ended
September 30,
2019
 

Operations:

    

Net Investment Income (Loss)

   $ (646,423   $ 770,435  

Net Realized Loss on Investments and Foreign Currency Transactions

     (8,642,605     (16,428,342

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

     27,261,810       9,904,321  
  

 

 

   

 

 

 

Net Increase (Decrease) in Net Assets Resulting From Operations

     17,972,782       (5,753,586
  

 

 

   

 

 

 

Distributions:

    

Institutional Class Shares

     (208,130     (39,354

Class I Shares

     (515,962     (59,762
  

 

 

   

 

 

 

Total Distributions

     (724,092     (99,116
  

 

 

   

 

 

 

Capital Share Transactions:(1)

    

Institutional Class Shares

    

Issued

     3,977,045       8,676,417  

Reinvestment of Distributions

     208,130       39,354  

Redeemed

     (7,427,823     (11,806,216
  

 

 

   

 

 

 

Net Institutional Class Shares Transactions

     (3,242,648     (3,090,445
  

 

 

   

 

 

 

Class I Shares

    

Issued

     109,607,577       44,130,705  

Reinvestment of Distributions

     494,915       57,477  

Redeemed

     (77,659,412     (37,873,670
  

 

 

   

 

 

 

Net Class I Shares Transactions

     32,443,080       6,314,512  
  

 

 

   

 

 

 

Net Increase in Net Assets From Capital Share Transactions

     29,200,432       3,224,067  
  

 

 

   

 

 

 

Total Increase (Decrease) in Net Assets

     46,449,122       (2,628,635
  

 

 

   

 

 

 

Net Assets:

    

Beginning of Year

     142,674,111       145,302,746  
  

 

 

   

 

 

 

End of Year

   $ 189,123,233     $ 142,674,111  
  

 

 

   

 

 

 

 

(1)

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

 

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

 

11


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

 

 

 FINANCIAL HIGHLIGHTS

Selected Per Share Data & Ratios

For a Share Outstanding Throughout the Year/ Period

 

   

Institutional Class Shares

 
  Year
Ended
September 30,
2020
    Year
Ended
September 30,
2019
    Year
Ended
September 30,
2018
    Period
Ended
September 30,
2017(1)
 

Net Asset Value, Beginning of Year/Period

    $ 11.25       $ 11.67     $ 13.13     $ 10.00  
 

 

 

   

 

 

   

 

 

   

 

 

 

Income (Loss) from Investment Operations:

       

Net Investment Income (Loss)*

    (0.03     0.07       0.02       0.04  

Net Realized and Unrealized Gain (Loss)

    1.30       (0.48     (1.28     3.09  
 

 

 

   

 

 

   

 

 

   

 

 

 

Total from Investment Operations

    1.27       (0.41     (1.26     3.13  
 

 

 

   

 

 

   

 

 

   

 

 

 

Dividends and Distributions:

       

Net Investment Income

    (0.06     (0.01     (0.05           —  

Capital Gains

          —             —       (0.15           —  
 

 

 

   

 

 

   

 

 

   

 

 

 

Total Dividends and Distributions

    (0.06     (0.01     (0.20           —  
 

 

 

   

 

 

   

 

 

   

 

 

 

Net Asset Value, End of Year/Period

  $ 12.46     $ 11.25     $ 11.67     $ 13.13  
 

 

 

   

 

 

   

 

 

   

 

 

 

Total Return†

    11.29     (3.46 )%      (9.77 )%      31.30
 

 

 

   

 

 

   

 

 

   

 

 

 

Ratios and Supplemental Data

       

Net Assets, End of Year/Period (Thousands)

    $ 38,174       $37,682       $43,464       $30,621  

Ratio of Expenses to Average Net Assets (Including Waivers and Reimbursements)

    1.25%       1.25%       1.25%       1.23%††(2)  

Ratio of Expenses to Average Net Assets (Excluding Waivers and Reimbursements)

    1.26%       1.29%       1.33%       2.95%††  

Ratio of Net Investment Income (Loss) to Average Net Assets

    (0.30)%       0.58%       0.17%       0.42%††  

Portfolio Turnover Rate

    139%       106%       91%       47%‡  

 

*

Per share calculations were performed using average shares for the period.

Total return is for the period indicated and has not been annualized. Returns shown do not reflect the deductions of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares.

††

Annualized

Portfolio turnover is for the period indicated and has not been annualized.

(1)

The Fund commenced operations on December 30, 2016.

(2)

Ratio reflects the impact of the initial low level of net assets associated with commencement of operations. Under normal asset levels, the ratio would have been 1.25%.

 

 

Amounts designated as “—” are either not applicable, $0 or have been rounded to $0.

 

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

 

12


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

 

 

 FINANCIAL HIGHLIGHTS

Selected Per Share Data & Ratios

For a Share Outstanding Throughout the Year/Period

 

   

Class I Shares^

 
  Year
Ended
September 30,
2020
    Year
Ended
September 30,
2019
    Year Ended
September
30, 2018
    Period
Ended
September 30,
2017(1)
 

Net Asset Value, Beginning of Year/Period

    $ 11.23       $ 11.65     $ 13.13     $ 13.03  
 

 

 

   

 

 

   

 

 

   

 

 

 

Income (Loss) from Investment Operations:

       

Net Investment Income (Loss)*

    (0.05     0.06       0.01       (0.01

Net Realized and Unrealized Gain (Loss)

    1.31       (0.47     (1.29     0.11  
 

 

 

   

 

 

   

 

 

   

 

 

 

Total from Investment Operations

    1.26       (0.41     (1.28     0.10  
 

 

 

   

 

 

   

 

 

   

 

 

 

Dividends and Distributions:

       

Net Investment Income

    (0.05     (0.01     (0.05           —  

Capital Gains

          —             —       (0.15           —  
 

 

 

   

 

 

   

 

 

   

 

 

 

Total Dividends and Distributions

    (0.05     (0.01     (0.20           —  
 

 

 

   

 

 

   

 

 

   

 

 

 

Net Asset Value, End of Year/Period

  $ 12.44     $ 11.23     $ 11.65     $ 13.13  
 

 

 

   

 

 

   

 

 

   

 

 

 

Total Return†

    11.24     (3.54 )%      (9.96 )%      0.77
 

 

 

   

 

 

   

 

 

   

 

 

 

Ratios and Supplemental Data

       

Net Assets, End of Year/Period (Thousands)

    $150,949       $104,992       $101,839       $59,552  

Ratio of Expenses to Average Net Assets (Including Waivers and Reimbursements)

    1.34%       1.34%       1.33%       1.37% ††(2) 

Ratio of Expenses to Average Net Assets (Excluding Waivers and Reimbursements)

    1.36%       1.38%       1.41%       1.88% †† 

Ratio of Net Investment Income (Loss) to Average Net Assets

    (0.40)%       0.57%       0.05%       (0.64)% †† 

Portfolio Turnover Rate

    139%       106%       91%       47% ‡ 

 

*

Per share calculations were performed using average shares for the period.

Total return is for the period indicated and has not been annualized. Returns shown do not reflect the deductions of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares.

††

Annualized

Portfolio turnover is for the period indicated and has not been annualized.

^

Class I Shares commenced operations on September 8, 2017.

(1)

The Fund commenced operations on December 30, 2016.

(2)

Ratio reflects the impact of the initial low level of net assets associated with commencement of operations. Under normal asset levels, the ratio would have been 1.40%.

 

 

Amounts designated as “—” are either not applicable, $0 or have been rounded to $0.

 

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

 

13


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 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 34 funds. The financial statements herein are those of the RWC Global Emerging Equity Fund (the “Fund”). The investment objective of the Fund is to seek long-term capital appreciation. The Fund is classified as a diversified investment company. RWC Asset Advisors (US) LLC serves as the Fund’s investment adviser (the “Adviser”). The Fund currently offers Class N Shares, Class I Shares and Institutional Class Shares. The Fund commenced operations on December 30, 2016. As of September 30, 2020, only Class I and the Institutional Class have outstanding shares. 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. generally accepted accounting principles (“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 increases and decreases in net assets from operations 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 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. The prices for foreign securities are reported in local currency and converted to U.S. dollars using currency exchange rates. Prices for most securities held in the Fund are provided daily by recognized independent pricing agents. If a security price cannot be obtained from an independent, third-party pricing agent, the Fund seeks to obtain a bid price from at least one independent broker.

 

14


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

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.

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. 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 a “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

 

15


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

Adviser contacts SEI Investments Global Fund Services (the “Administrator”) and may request that a meeting of the Committee be held.

If a local market in which the Fund own 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 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 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 September 30, 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.

 

16


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

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 period. 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 September 30, 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, the Fund did not incur any significant interest or penalties.

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 capital gain tax in the amount of $262,376 presented on the Statement of Assets and Liabilities.

Security Transactions and Investment Income — Security transactions are accounted for on trade date. Costs used in determining realized gains and losses on the sale of investment securities are based on the specific identification method. Dividend income and expense are recorded on the ex-dividend date. Interest income is recognized on the accrual basis from settlement 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 and unrealized gains and losses on investments on the Statement of Operations. Net realized and unrealized gains

 

17


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

and losses on foreign currency transactions 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.

Cash — Idle cash may be swept into various time deposit accounts and is classified as cash equivalents 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.

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

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 ex-dividend date.

Equity-Linked Warrants — The Fund may invest in equity-linked and index-linked warrants. Equity-linked warrants provide a way for investors to access markets where entry is difficult or costly. A Fund purchases the equity-linked and index-linked warrants from a broker, who in turn is expected to purchase shares in the local market and issue a call warrant hedged on the underlying holdings. If the Fund exercises its call and closes its position, the shares are expected to be sold and the warrant redeemed with the proceeds. Each warrant typically represents one share of the underlying stock or basket of stocks representing the index. Therefore, the price, performance and liquidity of the warrant are all linked to the underlying stock or index, less transaction costs. Equity-linked warrants are generally valued at the closing price of the underlying securities, then adjusted for stock dividends declared by the underlying securities. In addition to the market risk related to the underlying holdings, the Fund bears additional counterparty risk with respect to the issuing broker. A Fund may also purchase warrants, issued by banks and other financial institutions, whose values are based on the values from time to time of one or more securities indices.

Forward Foreign Currency Contracts — The Fund may enter into forward foreign currency contracts as hedges against either specific transactions, fund positions or anticipated fund positions. The Fund may also engage in currency transactions to enhance the Fund’s returns. All commitments are “marked-to-market” daily at the applicable foreign exchange rate, and any

 

18


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

resulting unrealized gains or losses are recorded currently. The Fund realizes gains and losses at the time forward contracts are extinguished. Unrealized gains or losses on outstanding positions in forward foreign currency contracts held at the close of the period are recognized as ordinary income or loss for Federal income tax purposes. The Fund could be exposed to risk if the counterparties to the contracts are unable to meet the terms of the contract and from unanticipated movements in the value of a foreign currency relative to the U.S. dollar. Finally, the risk exists that losses could exceed amounts disclosed on the Statements of Assets and Liabilities. There were no open forward foreign currency contracts as of September 30, 2020.

Classes — Class specific expenses are borne by that class of shares. Income, realized and unrealized gains (losses), and non-class specific expenses are allocated to the respective class on the basis of relative daily net assets.

3. Transactions with Affiliates:

Certain officers of the Trust are also employees of 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 advisors and service providers as required by SEC regulations. The CCO’s services and fees have been approved by and are reviewed by the Board. For the year ended year the Fund was allocated CCO fees totaling $6,611.

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, which will vary depending on the number of share classes and the average daily net assets of the Fund. For the year ended September 30, 2020, the Fund paid $204,013 for these services.

The Fund has adopted the Distribution Plan (the “Plan”) for the Class N Shares. Under the Plan, the Distributor, or third parties that enter into agreements with the Distributor, may receive up to 0.25% of the Fund’s average daily net assets attributable to Class N Shares. Under the Plan, the Distributor may make payments pursuant to written agreements to financial institutions and intermediaries such as banks, savings and loan associations and insurance companies including, without limit, investment counselors, broker-dealers and the Distributor’s affiliates and subsidiaries (collectively, “Agents”) as compensation for services and reimbursement

 

19


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

of expenses incurred in connection with distribution assistance. The Plan is characterized as a compensation plan since the distribution fee will be paid to the Distributor without regard to the distribution expenses incurred by the Distributor or the amount of payments made to other financial institutions and intermediaries. The Trust intends to operate the Plan in accordance with its terms and with the Financial Industry Regulatory Authority (“FINRA”) rules concerning sales charges. For the year ended September 30, 2020, no such fees were incurred.

The Fund has adopted a shareholder servicing plan (the “Service Plan”) under which a shareholder servicing fee of up to 0.15% of average daily net assets of the Class N Shares and 0.08% of average daily net assets of Class I Shares of the Fund will be paid to other service providers. Certain brokers, dealers, banks, trust companies and other financial representatives receive compensation from the Fund for providing a variety of services, including record keeping and transaction processing. Such fees are based on the assets of the Fund that are serviced by the financial representative. Such fees are paid by the Fund to the extent that the number of accounts serviced by the financial representative multiplied by the account fee charged by the Fund’s transfer agent would not exceed the amount that would have been charged had the accounts serviced by the financial representative been registered directly through the transfer agent. All fees in excess of this calculated amount are paid by the Adviser. For the year ended September 30, 2020, the Fund paid $118,327 for these services.

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. For the year ended September 30, 2020, the Fund paid $157,405 for these services.

DST Systems, Inc., serves as the transfer agent and dividend disbursing agent for the Fund under a transfer agency agreement with the Trust. For the year ended September 30, 2020, the Fund paid $81,652 for these services.

5. Investment Advisory Agreement:

Under the terms of an investment advisory agreement, the Adviser provides investment advisory services to the Fund at a fee computed daily at an annual rate of 0.90% of the Fund’s average daily net assets.

The Adviser has contractually agreed to reduce fees and reimburse expenses to the extent necessary to keep total annual fund operating expenses after fee reductions and/or expense reimbursements (excluding interest, taxes, brokerage commissions and other costs and expenses relating to the securities that are purchased and sold by the Fund, distribution fees, shareholder servicing fees, other expenditures which are capitalized in accordance with generally accepted accounting principles, acquired

 

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fund fee expenses and non-routine expenses) from exceeding 1.25% of the average daily net assets of each of the Fund’s share classes until January 29, 2021 (the “Expense Limitation”). The Adviser may recover all or a portion of its fee reductions or expense reimbursements, up to the expense cap in place at the time the expenses were waived, within a three-year period from the year in which it reduced its fee or reimbursed expenses if the Fund’s total annual fund operating expenses are below the Expense Limitation. This agreement may be terminated by the Board for any reason at any time, or by the Adviser, upon ninety (90) days’ prior written notice to the Trust, effective as of the close of business on January 29, 2021. As of September 30, 2020, the fees which were previously waived and reimbursed to the Fund by the Adviser which may be subject to possible future reimbursement, up to the expense cap in place at the time the expenses were waived and reimbursed to the Fund, to the Adviser were $86,621 $59,287, and $33,635, expiring in 2021, 2022 and 2023, respectively. The amount recovered in 2020 was $4,622.

6. Investment Transactions:

For the year ended September 30, 2020, the Fund made purchases of $261,025,851 and sales of $232,661,109 in investment securities other than long-term U.S. Government and short-term securities. There were no purchases or sales of long-term U.S. Government securities.

7. Capital Share Transactions:

Capital share transactions were as follows:

 

     Year
Ended
September 30,
2020
     Year
Ended
September 30,
2019
 

Institutional Class Shares

     

Issued

     355,278        753,785  

Reinvestment of Distributions

     16,690        3,928  

Redeemed

     (660,208      (1,132,886
  

 

 

    

 

 

 

Total Institutional Class Shares Transactions

     (288,240      (375,173
  

 

 

    

 

 

 

Class I Shares

     

Issued

     9,922,444        3,974,716  

Reinvestment of Distributions

     39,720        5,742  

Redeemed

     (7,181,034      (3,371,851
  

 

 

    

 

 

 

Total Class I Shares Transactions

     2,781,130        608,607  
  

 

 

    

 

 

 

Net Increase in Shares Outstanding From Share Transactions

     2,492,890        233,434  
  

 

 

    

 

 

 

 

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8. Federal Tax Information:

It is the Fund’s intention to continue to qualify as a regulated investment company for Federal income tax purposes and distribute all of its taxable income (including net capital gains). Accordingly, no provision for Federal income taxes is required.

Reclassification of Components of Net Assets — The timing and characterization of certain income and capital gain distributions are determined annually in accordance with Federal tax regulations which may differ from accounting principles generally accepted in the United States. As a result, net investment income (loss) and net realized gain (loss) on investment transactions for the reporting period may differ from distributions during such period. These book/tax differences may be temporary or permanent in nature.

The permanent differences primarily consist of foreign currency translations and investments in PFICs.

The tax character of dividends and distributions paid during the years or periods ended September 30, 2020 and 2019 were as follows:

 

     Ordinary Income      Total  
2020    $ 724,092      $ 724,092  
2019      99,116        99,116  

As of September 30, 2020, the components of Accumulated Losses on a tax basis were as follows:

 

Undistributed Ordinary Income

   $ 314,475  

Capital Loss Carryforwards

     (16,232,139

Unrealized Appreciation

     24,321,855  

Post October losses

     (5,510,110

Other Temporary Differences

     (1,231
  

 

 

 

Total Accumulated Earnings

   $ 2,892,850  
  

 

 

 

Post-October capital losses represent capital losses realized on investment transactions from November 1, 2019 through September 30, 2020, that, in accordance with Federal income tax regulations, the Funds may elect to defer and treat as having arisen in the following fiscal year.

 

Short-Term
Loss

   Long-Term
Loss
     Total  
$(11,746,607)    $ (4,485,532    $ (16,232,139

For Federal income tax purposes the difference between Federal tax cost and book cost primarily relates to wash sales, Mark to Market on open FX Forwards, and PFIC

 

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MTM which cannot be used for Federal income tax purposes in the current year and have been deferred for use in future years. The Federal tax cost and aggregate gross unrealized appreciation and depreciation for the investments held (including foreign currency) by the Fund at September 30, 2020, were as follows:

 

Federal Tax Cost

   Aggregate
Gross
Unrealized
Appreciation
     Aggregate
Gross
Unrealized
Depreciation
     Net
Unrealized
Appreciation
 
$ 165,127,126    $ 40,720,902      $ (16,399,047    $ 24,321,855  

9. Concentration of Shareholders:

At September 30, 2020, the percentage of total shares outstanding, held by shareholders owning 10% or greater of the aggregate total shares outstanding, for each share class, which are comprised of individual shareholders and omnibus accounts that are held on behalf of various individual shareholders was as follows:

 

     No. of
Shareholders
     %
Ownership
 

Institutional Class Shares

     3        93

Class I Shares

     2        63

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 claim is considered remote.

10. 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 Risk – Since it purchases equity securities, the Fund is subject to the risk that stock prices may fall over short or extended periods of time. Historically, the equity market has moved in cycles, and the value of the Fund’s securities may fluctuate from day to day. Individual companies may report poor results or be negatively affected by industry and/or economic trends and developments. The prices of securities issued by such companies may suffer a decline in response. These factors contribute to price volatility, which is the principal risk of investing in the Fund.

 

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In addition, the impact of any epidemic, pandemic or natural disaster, or widespread fear that such events may occur, could negatively affect the global economy, as well as the economies of individual countries, the financial performance of individual companies and sectors, and the markets in general in significant and unforeseen ways. Any such impact could adversely affect the prices and liquidity of the securities and other instruments in which the Fund invests, which in turn could negatively impact the Fund’s performance and cause losses on your investment in the Fund.

Foreign Company Risk – Investing in foreign companies, including direct investments and investments through depositary receipts, poses additional risks since political and economic events unique to a country or region will affect those markets and their issuers. These risks will not necessarily affect the U.S. economy or similar issuers located in the United States. Securities of foreign companies may not be registered with the U.S. Securities and Exchange Commission (the “SEC”) and foreign companies are generally not subject to the regulatory controls imposed on U.S. issuers and, as a consequence, there is generally less publicly available information about foreign securities than is available about domestic securities. Income from foreign securities owned by the Fund may be reduced by a withholding tax at the source, which tax would reduce income received from the securities comprising the portfolio. Foreign securities may also be more difficult to value than securities of U.S. issuers. While depositary receipts provide an alternative to directly purchasing the underlying foreign securities in their respective national markets and currencies, investments in depositary receipts continue to be subject to many of the risks associated with investing directly in foreign securities.

Emerging and Frontier Markets Securities Risk – The Fund’s investments in emerging or frontier markets securities are considered speculative and subject to heightened risks in addition to the general risks of investing in foreign securities. Unlike more established markets, emerging and frontier markets may have governments that are less stable, markets that are less liquid and economies that are less developed. In addition, the securities markets of emerging and frontier market countries may consist of companies with smaller market capitalizations and may suffer periods of relative illiquidity; significant price volatility; restrictions on foreign investment; and possible restrictions on repatriation of investment income and capital. Furthermore, foreign investors may be required to register the proceeds of sales, and future economic or political crises could lead to price controls, forced mergers, expropriation or confiscatory taxation, seizure, nationalization or creation of government monopolies.

Foreign Currency Risk – As a result of the Fund’s investments in securities 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 hedged positions, that the

 

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THE ADVISORS’ INNER CIRCLE FUND III  

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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.

Geographic Focus Risk – To the extent that it focuses its investments in a particular country or geographic region, the Fund may be more susceptible to economic, political, regulatory or other events or conditions affecting issuers and countries within that country or geographic 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.

Risk of Investing in China – The Chinese economy is generally considered an emerging market and can be significantly affected by economic and political conditions and policy in China and surrounding Asian countries. A relatively small number of Chinese companies represents a large portion of China’s total market and thus may be more sensitive to adverse political or economic circumstances and market movements. The economy of China differs, often unfavorably, from the U.S. economy in such respects as structure, general development, government involvement, wealth distribution, rate of inflation, growth rate, allocation of resources and capital reinvestment, among others. Under China’s political and economic system, the central government has historically exercised substantial control over virtually every sector of the Chinese economy through administrative regulation and/or state ownership. In addition, expropriation, including nationalization, confiscatory taxation, political, economic or social instability or other developments could adversely affect and significantly diminish the values of the Chinese companies in which the Fund invests.

Small and Mid-Capitalization Company Risk – The small- and mid-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, investments in these small and medium-sized companies may pose additional risks, including liquidity risk, because these companies may have limited product lines, markets and financial resources, and may depend upon a relatively small management group. Therefore, small- and mid-capitalization stocks may be more volatile than those of larger companies. These securities may be traded over-the-counter or listed on an exchange.

Private Placements Risk – Investment in privately placed securities may be less liquid than investments in publicly traded securities. Although these securities may be resold in privately negotiated transactions, the prices realized from these sales could be less than those originally paid by the Fund or less than what may be considered the fair value of such securities. Further, companies whose securities are not publicly traded may not be subject to the disclosure and other investor protection requirements that might be applicable if their securities were publicly traded.

 

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Rights and Warrants Risk – Investments in rights or warrants involve the risk of loss of the purchase value of a right or warrant if the right to subscribe to additional shares is not exercised prior to the right’s or warrant’s expiration. Also, the purchase of rights and/or warrants involves the risk that the effective price paid for the right and/or warrant added to the subscription price of the underlying security may exceed the market price of the underlying security in instances such as those where there is no movement in the price of the underlying security.

Risks of Investing in Other Investment Companies – To the extent that the Fund invests in other investment companies, such as open-end funds, closed-end funds and ETFs, the Fund will be subject to substantially the same risks as those associated with the direct ownership of the securities held by such other investment companies. As a shareholder of another investment company, the Fund relies on that investment company to achieve its investment objective. If the investment company fails to achieve its objective, the value of the Fund’s investment could decline, which could adversely affect the Fund’s performance. By investing in another investment company, Fund shareholders indirectly bear the Fund’s proportionate share of the fees and expenses of the other investment company, in addition to the fees and expenses that Fund shareholders directly bear in connection with the Fund’s own operations.

Because ETFs and certain closed-end funds are listed on national stock exchanges and are traded like stocks listed on an exchange, their shares potentially may trade at a discount or premium. Investments in ETFs and certain closed-end funds are also subject to brokerage and other trading costs, which could result in greater expenses to the Fund. In addition, because the value of ETF and certain closed-end fund shares depends on the demand in the market, the Adviser may not be able to liquidate the Fund’s holdings at the most optimal time, which could adversely affect Fund performance.

Derivatives Risk – The Fund’s use of equity-linked notes and swaps for all purposes, including speculative purposes, is subject to market risk, correlation risk, credit risk, valuation risk and liquidity risk. Market risk is the risk that the market value of an investment may move up and down, sometimes rapidly and unpredictably. Correlation risk is the risk that changes in the value of the derivative may not correlate perfectly or at all with the underlying asset, rate or index. Credit risk is the risk that the counterparty to a derivative contract will default or otherwise become unable to honor a financial obligation. Valuation risk is the risk that the derivative may be difficult to value. Liquidity risk is described below. The Fund’s use of swaps is also subject to leverage risk. Leverage risk is the risk that the use of leverage may amplify the effects of market volatility on the Fund’s share price and may also cause the Fund to liquidate portfolio positions when it would not be advantageous to do so in order

 

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to satisfy its obligations. Each of these risks could cause the Fund to lose more than the principal amount invested in a derivative instrument.

Liquidity Risk – Certain securities may be difficult or impossible to sell at the time and the price that the Fund would like. The Fund may have to accept a lower price to sell a security, sell other securities to raise cash, or give up an investment opportunity, any of which could have a negative effect on Fund management or performance.

Investment Style Risk – The Fund pursues 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 earnings growth and which, therefore, may experience above-average increases in stock prices. Over time, a growth investing style may go in and out of favor, causing the Fund to sometimes underperform other equity funds that use differing investing styles.

Convertible Securities Risk – The value of a convertible security is influenced by changes in interest rates (with investment value declining as interest rates increase and increasing as interest rates decline) and the credit standing of the issuer. The price of a convertible security will also normally vary in some proportion to changes in the price of the underlying common stock because of the conversion or exercise feature.

LIBOR Replacement Risk – The elimination of the London Inter-Bank Offered Rate (“LIBOR”) may adversely affect the interest rates on, and value of, certain Fund investments for which the value is tied to LIBOR. The U.K. Financial Conduct Authority has announced that it intends to stop compelling or inducing banks to submit LIBOR rates after 2021. However, it remains unclear if LIBOR will continue to exist in its current, or a modified, form. Alternatives to LIBOR are established or in development in most major currencies, including the Secured Overnight Financing Rate (“SOFR”), which is intended to replace U.S. dollar LIBOR. Markets are slowly developing in response to these new rates. Questions around liquidity impacted by these rates, and how to appropriately adjust these rates at the time of transition, remain a concern for the Fund. Accordingly, it is difficult to predict the full impact of the transition away from LIBOR on the Fund until new reference rates and fallbacks for both legacy and new products, instruments and contracts are commercially accepted.

11. New Accounting Pronouncements:

In August 2018, the FASB issued Accounting Standards Update 2018-13, Fair Value Measurement (Topic 820). The new guidance includes additions 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 of certain disclosures and delay the adoption of additional disclosure until the effective date.

 

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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 September 30, 2020.

 

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 REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Board of Trustees of The Advisors’ Inner Circle Fund III and Shareholders of RWC Global Emerging Equity Fund

Opinion on the Financial Statements

We have audited the accompanying statement of assets and liabilities, including the schedule of investments, of RWC Global Emerging Equity Fund (one of the funds constituting The Advisors’ Inner Circle Fund III, referred to hereafter as the “Fund”) as of September 30, 2020, the related statement of operations for the year ended September 30, 2020, the statement of changes in net assets for each of the two years in the period ended September 30, 2020, including the related notes, and the financial highlights for each of the periods indicated therein (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 as of September 30, 2020, the results of its operations for the year then ended, the changes in its net assets for each of the two years in the period ended September 30, 2020 and the financial highlights for each of the periods indicated therein in conformity with accounting principles generally accepted in the United States of America.

Basis for Opinion

These financial statements are the responsibility of the Fund’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 Fund 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 of these financial statements in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audits to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud.

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 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. Our procedures included confirmation of securities owned as of September 30, 2020 by correspondence with the custodian and brokers; when replies were not received from brokers, we performed other auditing procedures. We believe that our audits provide a reasonable basis for our opinion.

 

LOGO

Philadelphia, Pennsylvania

November 25, 2020

We have served as the auditor of one or more investment companies in RWC Asset Advisors (US) LLC since 2016.

 

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

Set forth below are the names, years of birth, positions with the Trust, length of term of office, 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.” Mr. Doran is a Trustee who may be an “interested”

 

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 34 funds in The Advisors’ Inner Circle Fund III.

 

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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 1-855-792-3863. The following chart lists Trustees and Officers as of September 30, 2020.

Other Directorships

Held in the Past Five Years4

    

Current Directorships: Trustee of Delaware Wilshire Private Markets Master Fund, Delaware Wilshire Private Markets Fund, Delaware Wilshire Private Markets Tender Fund, 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 Delaware Wilshire Private Markets Master Fund, Delaware Wilshire Private Markets Fund, Delaware Wilshire Private Markets Tender Fund, Chiron Capital Allocation Fund Ltd., 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 Delaware Wilshire Private Markets Master Fund, Delaware Wilshire Private Markets Fund, Delaware Wilshire Private Markets Tender Fund, Chiron Capital Allocation Fund Ltd., Gallery Trust, Schroder Series Trust, Schroder Global Series Trust, JP Morgan Active Exchange-Traded Funds and Symmetry Panoramic Trust.

 

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 Delaware Wilshire Private Markets Master Fund, Delaware Wilshire Private Markets Fund, Delaware Wilshire Private Markets Tender Fund, Chiron Capital Allocation Fund Ltd., City National Rochdale Funds, Gallery Trust, Schroder Series Trust and Schroder Global Series Trust.

 

Former Directorships: Trustee of Rochdale Investment Trust to 2013. Trustee of Winton Series Trust to 2017. Director of Lapolla Industries, Inc. to 2017. Trustee of Winton Diversified Opportunities Funds (closed-end investment company) to 2018.

Current Directorships: Trustee of Delaware Wilshire Private Markets Master Fund, Delaware Wilshire Private Markets Fund, Delaware Wilshire Private Markets Tender Fund, Chiron Capital Allocation Fund Ltd., 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 Funds (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.

 

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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 and Assistant Secretary (since 2017)  

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 December 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, 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)  

Counsel at SEI Investments since 2019. Vice President and Assistant General Counsel, JPMorgan Chase & Co., from 2012 to 2018.

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.

 

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Other Directorships

Held in the Past Five Years

 

None.

None.

 

None.

None.

None.

None.

None.

None.

 

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Name and
Year of Birth
   Position with
Trust and
Length of
Time Served
   Principal Occupations
in the Past Five Years
OFFICERS (continued)     

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.

BRIDGET E. SUDALL

(Born: 1980)

   Privacy Officer (since 2015) and Anit-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.

 

34


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

Other Directorships

Held in the Past Five Years

    

None.

None.

 

35


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 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 April 1, 2020 to September 30, 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 “Expenses Paid During Period” column with those that appear in the same charts in the shareholder reports for other mutual funds.

 

36


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

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
4/01/20
    Ending
Account Value
9/30/20
    Annualized
Expense Ratios
    Expenses Paid
During Period*
 

Institutional Class Shares

                               

Actual Portfolio Return

  $ 1,000.00     $ 1,389.10       1.25   $ 7.47  

Hypothetical 5% Return

    1,000.00       1,018.75       1.25       6.31  

Class I Shares

                               

Actual Portfolio Return

  $ 1,000.00     $ 1,388.40       1.34   $ 8.00  

Hypothetical 5% Return

    1,000.00       1,018.26       1.34       6.76  

 

*

Expenses are equal to the Fund’s annualized expense ratio, multiplied by the average account value over the period, multiplied by 183/366 (to reflect the one-half year period shown).

 

37


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

APPROVAL OF INVESTMENT ADVISORY AGREEMENT (Unaudited)

Pursuant to Section 15 of the Investment Company Act of 1940 (the “1940 Act”), the Fund’s advisory agreement must be approved: (i) by a vote of a majority of the shareholders of the Fund; and (ii) by the vote of a majority of the members of the Board of Trustees (the “Board” or the “Trustees”) of The Advisors’ Inner Circle Fund III (the “Trust”) who are not parties to the agreement or “interested persons” of any party thereto, as defined in the 1940 Act (the “Independent Trustees”), cast in person at a meeting called for the purpose of voting on such approval.

On October 28, 2019, RWC Partners Limited (“RWC Partners”), the parent company of RWC Asset Advisors (US) LLC (the “Adviser”), entered into an agreement for Schroder International Holdings Limited to sell its 41% equity stake in RWC Partners back to RWC Partners shareholders and to RWC Partners’ new long-term partner, Lincoln Peak Capital Management, LLC (the “Transaction”). The Transaction closed on January 31, 2020. In anticipation that the Transaction could be deemed to result in a change in control of the Adviser under the 1940 Act, and, consequently, in the assignment and automatic termination of the investment advisory agreement between the Trust, on behalf of the Fund, and the Adviser (the “Prior Agreement”), a Board meeting was held on December 12, 2019 (the “December 2019 Board Meeting”) to decide whether to approve an interim investment advisory agreement between the Trust, on behalf of the Fund, and the Adviser for a term of up to 150 days (the “Interim Agreement”) and a new investment advisory agreement between the Trust, on behalf of the Fund, and the Adviser for an initial term of two years (the “New Agreement”).

In preparation for the December 2019 Board Meeting, the Trustees requested that the Adviser furnish information necessary to evaluate the terms of the Interim Agreement and the New Agreement. The Trustees used this information, as well as other information that other service providers of the Fund submitted to the Board in connection with the December 2019 Board Meeting and other meetings held since the most recent renewal of the Prior Agreement, to help them decide whether to approve the Interim Agreement for a term of up to 150 days and the New Agreement for an initial two-year term. In recognition of the fact that the Transaction was in progress and had not been consummated at the time of the December 2019 Board Meeting and that the Board was being asked to approve the Adviser as it was expected to exist after the consummation of the Transaction, the materials provided by the Adviser addressed both the Adviser as it existed at the time of the December 2019 Board Meeting and the Adviser as it was expected to exist after the consummation of the Transaction.

Specifically, the Board requested and received written materials from the Adviser regarding, among other things: (i) the terms, conditions, and expected timing of the Transaction, and the reasons that the Adviser was undergoing the Transaction; (ii) the nature, extent and quality of the services to be provided by the Adviser; (iii) the Adviser’s operations and financial condition; (iv) the proposed advisory fee to be paid to the Adviser under the Interim Agreement and the New Agreement; (v) the Adviser’s compliance program; and (vi) the Adviser’s investment management personnel.

At the December 2019 Board Meeting, the Trustees, including all of the Independent Trustees, based on their evaluation of the information provided by the Adviser and other service

 

38


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

providers of the Fund, approved the Interim Agreement and the New Agreement. As part of their evaluation, the Independent Trustees received advice from independent counsel and met in executive session outside the presence of Fund management and the Adviser. In considering the approval of the Interim Agreement and the New Agreement, the Board considered various factors that they determined were relevant, including: (i) the nature, extent and quality of the services to be provided by the Adviser; (ii) the investment performance of the Fund and the Adviser; and (iii) the fee to be paid to the Adviser under the Interim Agreement and the New Agreement, as discussed in further detail below. In addition, the Board, in considering the Interim Agreement and the New Agreement in the context of the Transaction, relied upon representations from the Adviser that: (i) the Transaction was not expected to result in any material changes to the nature, quality and extent of services provided to the Fund by the Adviser that are discussed below; (ii) the Adviser did not anticipate any material changes to its compliance program or code of ethics in connection with the Transaction; and (iii) the portfolio managers for the Fund were not expected to change in connection with the Transaction.

Nature, Extent and Quality of Services Provided by the Adviser

In considering the nature, extent and quality of the services to be provided by the Adviser, the Board reviewed the portfolio management services to be provided by the Adviser to the Fund, including the quality of the continuing portfolio management personnel, the resources available to the Adviser after the consummation of the Transaction and the Adviser’s compliance history and compliance program. The Trustees reviewed the terms of the proposed Interim Agreement and the proposed New Agreement, and noted that (1) the Interim Agreement has the same advisory fee as, and is substantially the same as, the Prior Agreement, except with respect to certain provisions that are required by law; and (2) the New Agreement has the same advisory fee as, and does not materially differ from, the Prior Agreement. The Trustees also reviewed the Adviser’s investment and risk management approaches for the Fund. The most recent investment adviser registration form (“Form ADV”) for the Adviser also was available to the Board.

The Trustees also considered other services to be provided to the Fund by the Adviser such as monitoring adherence to the Fund’s investment restrictions and monitoring compliance with various Fund policies and procedures and with applicable securities laws and regulations. Based on the factors above, as well as those discussed below, the Board concluded, within the context of its full deliberations, that the nature, extent and quality of the services to be provided to the Fund by the Adviser under the Interim Agreement and the New Agreement would be satisfactory.

Investment Performance of the Adviser

In connection with its most recent approval of the continuation of the Prior Agreement and other meetings held during the course of the trailing 12-month period, the Board was provided with reports regarding the Fund’s performance over various time periods. As part of these meetings, the Adviser and its representatives provided information regarding and, as applicable, led discussions of factors impacting, the Adviser’s performance for the Fund, outlining current market conditions and explaining their expectations and strategies for the future. The Board determined that it was appropriate to take into account its consideration of

 

39


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

the Adviser’s performance at meetings held prior to the December 2019 Board Meeting, at which time the Trustees considered that although the Fund underperformed its benchmark for the one-year trailing period-ended June 30, 2019, the Fund’s more recent performance was favorable both on an absolute basis and relative to the Fund’s benchmark. Based on this information and the Adviser’s representation that the portfolio managers for the Fund were not expected to change in connection with the Transaction, the Board concluded, within the context of its full deliberations, that the investment results that the Adviser had been able to achieve for the Fund were sufficient to support approval of the Interim Agreement and the New Agreement.

Costs of Advisory Services, Profitability and Economies of Scale

With respect to the cost of advisory services, the Board considered that the investment advisory fee payable to the Adviser under the Interim Agreement and the New Agreement is the same as the investment advisory fee payable to the Adviser under the Prior Agreement. The Trustees also reviewed information provided by the Adviser in advance of the December 2019 Board Meeting regarding the management fees charged by the Adviser to other clients with comparable mandates. The Trustees considered any differences in management fees and took into account the Adviser’s description of the respective demands and complexity associated with the Fund and other client accounts as well as the extensive regulatory regimes and reporting requirements to which the Fund is subject. The Board concluded, within the context of its full deliberations, that the advisory fee payable to the Adviser under the Interim Agreement and the New Agreement was reasonable in light of the nature and quality of the services expected to be rendered by the Adviser.

With respect to profitability and economies of scale, the Board considered the Adviser’s profitability and economies of scale from its management of the Fund when it most recently approved the continuation of the Prior Agreement, but determined that such profitability and economies may change as a result of the changes to the Adviser’s ownership structure and operations that will occur after the consummation of the Transaction. Accordingly, the Trustees did not make any conclusions regarding the Adviser’s profitability, or the extent to which economies of scale would be realized by the Adviser as the assets of the Fund grow, but will do so during future considerations of the New Agreement.

Conclusion

While formal Board action was not taken with respect to the conclusions discussed above, those conclusions formed, in part, the basis for the Board’s approval of the Interim Agreement and the New Agreement at the December 2019 Board Meeting. The Board concluded, in the exercise of its reasonable judgment, that the terms of the Interim Agreement and the New Agreement, including the compensation to be paid thereunder, are reasonable in relation to the services expected to be provided by the Adviser to the Fund and that the appointment of the Adviser and the approval of the Interim Agreement and the New Agreement would be in the best interest of the Fund and its shareholders. Based on the Trustees’ deliberations and their evaluation of the information described above and other factors and information they believed relevant, the Board, including all of the Independent Trustees, unanimously (a) approved the appointment of the Adviser as investment adviser to the Fund, (b) approved

 

40


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

the Interim Agreement, (c) approved the New Agreement, and (d) recommended the approval of the New Agreement to the Fund’s shareholders. In reaching its determination regarding the approval of the Interim Agreement and the New Agreement, the Board, including all of the Independent Trustees, considered the factors, conclusions and information they believed relevant in the exercise of their reasonable judgment, including, but not limited to, the factors, conclusions and information discussed above; and in their deliberations, the Board members did not identify any particular factor (or conclusion with respect thereto) or information that was all important or controlling, and each Board member may have attributed different weights to the various factors (and conclusions with respect thereto) and information.

Renewal of the Investment Advisory Agreement

Pursuant to Section 15 of the 1940 Act, the Fund’s advisory agreement (the “Agreement”) must be renewed at least annually after its initial two-year term: (i) by the vote of the Board or by a vote of a majority of the shareholders of the Fund; and (ii) by the vote of a majority of the Independent Trustees, cast in person at a meeting called for the purpose of voting on such renewal.

A Board meeting was held on September 11, 2020 (the “September 2020 Board Meeting”) to decide whether to renew the Agreement for an additional one-year term. In preparation for the September 2020 Board Meeting, the Trustees requested that the Adviser furnish information necessary to evaluate the terms of the Agreement. Prior to the September 2020 Board Meeting, the Independent Trustees of the Fund met to review and discuss the information provided and submitted a request for additional information to the Adviser, and information was provided in response to this request. The Trustees used this information, as well as other information that the Adviser and other service providers of the Fund presented or submitted to the Board at the September 2020 Board Meeting and other meetings held during the prior year, to help them decide whether to renew the Agreement for an additional year.

Specifically, the Board requested and received written materials from the Adviser and other service providers of the Fund regarding: (i) the nature, extent and quality of the Adviser’s services; (ii) the Adviser’s investment management personnel; (iii) the Adviser’s operations and financial condition; (iv) the Adviser’s brokerage practices (including any soft dollar arrangements) and investment strategies; (v) the Fund’s advisory fee paid to the Adviser and overall fees and operating expenses compared with a peer group of mutual funds; (vi) the level of the Adviser’s profitability from its relationship with the Fund, including both direct and indirect benefits accruing to the Adviser and its affiliates; (vii) the Adviser’s potential economies of scale; (viii) the Adviser’s compliance program, including a description of material compliance matters and material compliance violations; (ix) the Adviser’s policies on and compliance procedures for personal securities transactions; and (x) the Fund’s performance compared with a peer group of mutual funds and the Fund’s benchmark index.

Representatives from the Adviser, along with other Fund service providers, presented additional information and participated in question and answer sessions at the September 2020 Board Meeting to help the Trustees evaluate the Adviser’s services, fee and other aspects of the Agreement. The Independent Trustees received advice from independent counsel and met in executive sessions outside the presence of Fund management and the Adviser.

 

41


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

At the September 2020 Board Meeting, the Trustees, including all of the Independent Trustees, based on their evaluation of the information provided by the Adviser and other service providers of the Fund, renewed the Agreement. In considering the renewal of the Agreement, the Board considered various factors that they determined were relevant, including: (i) the nature, extent and quality of the services provided by the Adviser; (ii) the investment performance of the Fund and the Adviser; (iii) the costs of the services provided and profits realized by the Adviser from its relationship with the Fund, including both direct and indirect benefits accruing to the Adviser and its affiliates; (iv) the extent to which economies of scale are being realized by the Adviser; and (v) whether fee levels reflect such economies of scale for the benefit of Fund investors, as discussed in further detail below.

Nature, Extent and Quality of Services Provided by the Adviser

In considering the nature, extent and quality of the services provided by the Adviser, the Board reviewed the portfolio management services provided by the Adviser to the Fund, including the quality and continuity of the Adviser’s portfolio management personnel, the resources of the Adviser, and the Adviser’s compliance history and compliance program. The Trustees reviewed the terms of the Agreement. The Trustees also reviewed the Adviser’s investment and risk management approaches for the Fund. The most recent Form ADV for the Adviser was available to the Board, as was the response of the Adviser to a detailed series of questions which included, among other things, information about the investment advisory services provided by the Adviser to the Fund.

The Trustees also considered other services provided to the Fund by the Adviser such as selecting broker-dealers for executing portfolio transactions, monitoring adherence to the Fund’s investment restrictions, and monitoring compliance with various Fund policies and procedures and with applicable securities laws and regulations. Based on the factors above, as well as those discussed below, the Board concluded, within the context of its full deliberations, that the nature, extent and quality of the services provided to the Fund by the Adviser were sufficient to support renewal of the Agreement.

Investment Performance of the Fund and the Adviser

The Board was provided with regular reports regarding the Fund’s performance over various time periods. The Trustees also reviewed reports prepared by the Fund’s administrator comparing the Fund’s performance to its benchmark index and a peer group of mutual funds as classified by Lipper, an independent provider of investment company data, over various periods of time. Representatives from the Adviser provided information regarding and led discussions of factors impacting the performance of the Fund, outlining current market conditions and explaining their expectations and strategies for the future. The Trustees determined that the Fund’s performance was satisfactory, or, where the Fund’s performance was materially below its benchmark and/or peer group, the Trustees were satisfied by the reasons for the underperformance and/or the steps taken by the Adviser in an effort to improve the performance of the Fund. Based on this information, the Board concluded, within the context of its full deliberations, that the investment results that the Adviser had been able to achieve for the Fund were sufficient to support renewal of the Agreement.

 

42


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

Costs of Advisory Services, Profitability and Economies of Scale

In considering the advisory fee payable by the Fund to the Adviser, the Trustees reviewed, among other things, a report of the advisory fee paid to the Adviser. The Trustees also reviewed reports prepared by the Fund’s administrator comparing the Fund’s net and gross expense ratios and advisory fee to those paid by a peer group of mutual funds as classified by Lipper. The Trustees reviewed the management fees charged by the Adviser to other clients with comparable mandates. The Trustees considered any differences in management fees and took into account the respective demands, resources and complexity associated with the Fund and other client accounts as well as the extensive regulatory, compliance and tax regimes to which the Fund is subject. The Board concluded, within the context of its full deliberations, that the advisory fee was reasonable in light of the nature and quality of the services rendered by the Adviser.

The Trustees reviewed the costs of services provided by and the profits realized by the Adviser from its relationship with the Fund, including both direct benefits and indirect benefits, such as research and brokerage services received under soft dollar arrangements, accruing to the Adviser and its affiliates. The Trustees considered how the Adviser’s profitability was affected by factors such as its organizational structure and method for allocating expenses. The Trustees concluded that the profit margins of the Adviser with respect to the management of the Fund were not unreasonable. The Board also considered the Adviser’s commitment to managing the Fund and its willingness to continue its expense limitation and fee waiver arrangement with the Fund.

The Trustees considered the Adviser’s views relating to economies of scale in connection with the Fund as Fund assets grow and the extent to which the benefits of any such economies of scale are shared with the Fund and Fund shareholders. The Board considered the existence of any economies of scale and whether those were passed along to the Fund’s shareholders through a graduated advisory fee schedule or other means, including fee waivers. The Trustees recognized that economies of scale are difficult to identify and quantify and are rarely identifiable on a fund-by-fund basis. Based on this evaluation, the Board concluded that the advisory fee was reasonable in light of the information that was provided to the Trustees by the Adviser with respect to economies of scale.

Renewal of the Agreement

Based on the Board’s deliberations and its evaluation of the information described above and other factors and information it believed relevant in the exercise of its reasonable business judgment, the Board, including all of the Independent Trustees, with the assistance of Fund counsel and Independent Trustees’ counsel, unanimously concluded that the terms of the Agreement, including the fees payable thereunder, were fair and reasonable and agreed to renew the Agreement for another year. In its deliberations, the Board did not identify any absence of information as material to its decision, or any particular factor (or conclusion with respect thereto) or single piece of information that was all-important, controlling or determinative of its decision, but considered all of the factors together, and each Trustee may have attributed different weights to the various factors (and conclusions with respect thereto) and information.

 

43


THE ADVISORS’ INNER CIRCLE FUND III  

RWC GLOBAL EMERGING

EQUITY FUND

SEPTEMBER 30, 2020

 

 

 NOTICE TO SHAREHOLDERS (Unaudited)

For shareholders that do not have a September 30, 2020 tax year end, this notice is for informational purposes only. For shareholders with a September 30 tax year end, please consult your tax advisor as to the pertinence of this notice. For the fiscal period ended September 30, 2020, the Funds are 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
Receivable
Deduction (1)
  Qualifying
Dividend
Income (2)
  U.S.
Government
Interest (3)
  Qualified
Interest
Income (4)
  Qualified Short
Term Capital
Gain (5)
0.00%   100.00%   100.00%   0.00%   100.00%   0.00%   0.00%   0.00%

(1) Qualifying dividends represent dividends which qualify for the corporate dividends received deduction and is 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 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 each of the aforementioned funds to designate the maximum amount permitted by law.

(3) “U.S. Government Interest represents the amount of interest that was derived from U.S. Government obligations and distributed during the fiscal year. This amount is reflected as a percentage of total ordinary income distributions (the total of short term capital gain and net investment income distributions). However, for shareholders of the RWC Global Emerging Equity Fund who are residents of California, Connecticut and New York, the statutory threshold requirements were not satisfied to permit exemption of these amounts from state income.

(4) The percentage in this column represents the amount of “Qualifying Interest Income” as created by the American Jobs Creation Act of 2004 and is a percentage of ordinary income distributions that are exempt from U.S. withholding tax when paid for foreign investors.

(5) The percentage in this column represents the amount of “Qualifying Short-Term Capital Gain” as created by the American Jobs Creation Act of 2004 and is reflected as a percentage of short-term capital gain distributions that is exempt from U.S. withholding tax when paid to foreign investors.

The Fund intends to pass through a foreign tax credit to shareholders. For fiscal year ended 2020 the total amount of foreign source income is $204,518. The total amount of foreign tax paid is $0. Your allocable share of the foreign tax credit will be reported on Form 1099-DIV.

The information reported herein may differ from the information and distributions taxable to the shareholders for the calendar year ending December 31, 2020. Complete information will be computed and reported in conjunction with your 2020 Form 1099-DIV.

 

44


RWC Global Emerging Equity Fund

P.O. Box 219009

Kansas City, MO 64121-9009

1-855-RWC-FUND

Investment Adviser:

RWC Asset Advisors (US) LLC

2640 South Bayshore Drive, Suite 201

Miami, Florida 33133

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

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

RWC-AR-001-0400


Item 2.    Code of Ethics.

The Registrant (also referred to as the “Trust”) 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 Registrant’s audit committee financial experts are Thomas P. Lemke and Jay Nadel, and each of Mr. Lemke and Mr. Nadel is “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”) related to The Advisors’ Inner Circle Fund III (the aforementioned “Trust”).

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

 

    

2020

 

 

2019

 

          

All fees and
services to
the Registrant 
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   $530,415   $0   $0

(b)

   Audit-Related Fees    $4,000   $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

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 its 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 its methods and procedures for ensuring independence.

 

(e)(2)

Percentage of fees billed by PwC applicable to non-audit services pursuant to the “de minimis” exception of Rule 2-01(c)(7)(i)(C) were as follows:

 

              2020                    2019         

Audit-Related Fees

   N/A    N/A

Tax Fees

   N/A    N/A

All Other Fees

   N/A    N/A

 

(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 were $350,991 and $70,100 for 2020 and 2019, respectively.


(h)          During the past fiscal year, all non-audit services provided by the Registrant’s principal accountant to either the Registrant’s investment adviser or to any entity controlling, controlled by, or under common control with the Registrant’s investment adviser that provides ongoing services to the 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. Effective for closed-end management investment companies for fiscal years ending on or after December 31, 2005

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 Rules 13a-15(b) or 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 (17CFR §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.

Item 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 Investment Company Act of 1940, as amended (17 CFR §270.30a-2(a)), is filed herewith.

(b) Officer certifications as required by Rule 30a-2(b) under the Investment Company Act of 1940, as amended (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: December 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: December 9, 2020

     

By (Signature and Title)

     

/s/ Stephen Connors                            

     

Stephen Connors,

     

Treasurer, Controller, and CFO

Date: December 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: December 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: December 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, the President of the Advisors’ Inner Circle Fund III (the “Fund”), with respect to the Fund’s Form N-CSR for the period ended September 30, 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: December 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, 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 September 30, 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: December 9, 2020

 

/s/ Stephen Connors                            

Stephen Connors

Treasurer, Controller, and CFO