Important Information & Disclosures

This page sets out important legal and regulatory information governing your access to and use of this website and any materials made available through it. By continuing to use this website, you acknowledge that you have read and understood this information. If you do not agree, you should not use this website.

This page should be read together with the firm's Terms of Service, Privacy Policy, Risk Disclosure, and AML Policy.

1. Nature of Gliese Capital

Gliese Capital LLC ("Gliese Capital," "the firm," "we," "us," or "our") is a private investment management firm pursuing distressed and special-situations strategies across selected emerging and frontier markets. The firm sponsors and/or advises privately offered investment funds and related vehicles (each, a "Fund") whose interests are offered only by private placement to eligible investors.

Gliese Capital is not a registered investment company, mutual fund, or exchange-traded fund; it is not making a public offering of any security; and it is not a FINRA-member broker-dealer. Nothing on this website should be read to imply otherwise. Where the firm uses an introducing or placement intermediary, any such intermediary acts in its own capacity and under its own licences; the firm itself does not act as a broker-dealer.

2. No Offer, No Solicitation, No Advice

The information on this website is provided for general informational purposes only. It does not constitute, and must not be construed or relied upon as:

an offer to sell, or a solicitation of an offer to buy, any security, Fund interest, or other financial instrument;
a recommendation to enter into any transaction or investment strategy; or
investment, legal, tax, accounting, regulatory, or other professional advice.

No fiduciary, advisory, or client relationship is created by accessing or using this website. Any offer or sale of interests in a Fund will be made solely through, and is qualified in its entirety by, that Fund's confidential offering documents — including its Private Placement Memorandum (PPM), limited partnership or operating agreement, and subscription documents (together, the "Offering Documents"). In the event of any inconsistency, the Offering Documents control and supersede anything stated on this website. No interest in any Fund will be issued on the basis of this website.

3. Eligible Investors Only

Interests in the Funds are offered only to investors who meet applicable eligibility criteria in their jurisdiction and who can bear the financial risks of the investment, including the risk of losing their entire investment. Eligibility categories include, without limitation:

United States — "accredited investors" within the meaning of Rule 501 of Regulation D under the U.S. Securities Act of 1933 and, where a Fund relies on the relevant exclusion, "qualified purchasers" within the meaning of the U.S. Investment Company Act of 1940.
United Kingdom — persons to whom financial promotions may lawfully be communicated under the Financial Services and Markets Act 2000 (Financial Promotion) Order, such as professional clients, certified high-net-worth individuals, and certified or self-certified sophisticated investors; the materials are not directed at retail clients.
United Arab Emirates / DIFC — "Professional Clients" as defined under the applicable Dubai Financial Services Authority rules; the materials are not directed at Retail Clients.
Kazakhstan / AIFC — professional or otherwise eligible investors under the rules of the Astana International Financial Centre and the Astana Financial Services Authority, in connection with a private placement.

No interests are offered to any person who is not an eligible investor in a permitted jurisdiction. The Funds, their interests, and the related Offering Documents have not been approved or disapproved by the U.S. Securities and Exchange Commission, the U.K. Financial Conduct Authority, the Astana Financial Services Authority, the Dubai Financial Services Authority, or any other regulatory authority, and no such authority has passed upon the accuracy or adequacy of any offering materials.

4. Jurisdiction-by-Jurisdiction Notices

This website is accessible globally. The following notices apply to recipients in or connected with the jurisdictions indicated. Recipients are responsible for informing themselves about, and observing, any applicable legal or regulatory requirements.

4.1 United States

Interests in the Funds have not been and will not be registered under the U.S. Securities Act of 1933 or the securities laws of any state, and are offered and sold in reliance on the private-placement exemptions thereunder. The Funds are not registered as investment companies under the U.S. Investment Company Act of 1940 in reliance on an available exclusion. Interests may not be resold or transferred except as permitted under the Offering Documents and applicable law.

4.2 United Kingdom

This website and its contents are issued in the United Kingdom only to, and are directed only at, persons to whom they may lawfully be communicated under the financial-promotion regime in section 21 of the Financial Services and Markets Act 2000 and the orders made under it. Any investment activity to which this website relates is available only to such persons and will be engaged in only with such persons. Persons who do not fall within the relevant categories should not act or rely on this website.

4.3 United Arab Emirates / DIFC

To the extent any material is made available in or from the Dubai International Financial Centre, it is directed only at Professional Clients and is not intended for, and should not be relied upon by, Retail Clients. Where relevant, materials are made available on the basis of reverse solicitation — that is, at the recipient's own initiative — and do not constitute active marketing into the jurisdiction.

4.4 Kazakhstan / AIFC

The Astana International Financial Centre operates under an independent, English-common-law-based legal framework, with the Astana Financial Services Authority as financial regulator. Any private placement connected with the AIFC is directed only at professional or otherwise eligible investors and is made by way of a Private Placement Memorandum or Information Memorandum, not a prospectus.

4.5 Other Jurisdictions

This website is not directed at, and the interests described are not available to, any person in any jurisdiction where the distribution of this material, or the offer or solicitation of interests, would be unlawful or would require registration, licensing, or other authorisation that has not been obtained. The availability of any Fund in a given jurisdiction is subject to the relevant Offering Documents and applicable law. It is the responsibility of each recipient to satisfy itself as to the full observance of the laws of any relevant jurisdiction, including obtaining any required governmental or other consent and observing any applicable formalities and exchange-control or other restrictions.

5. Forward-Looking Statements

This website may contain forward-looking statements — including statements about strategy, objectives, pipeline, targeted or projected returns, internal rates of return, exit multiples, entry discounts, and market conditions. Words such as "target," "expect," "intend," "aim," "project," "believe," "estimate," "may," and "anticipate" identify such statements. Forward-looking statements are based on assumptions and are subject to significant risks and uncertainties, many of which are beyond the firm's control. Actual results may differ materially from those expressed or implied. Any targeted or projected figures are objectives, not promises or guarantees, and may not be achieved. Forward-looking statements speak only as of the date on which they are made, and the firm undertakes no obligation to update or revise them.

6. Past Performance and Targeted Returns

Past performance is not indicative of, and is no guarantee of, future results. Any track record reflects particular vehicles, market conditions, team composition, and transactions that may differ materially from those of any current or future Fund. Any hypothetical, model, illustrative, or target figures have inherent limitations, are prepared with the benefit of hindsight, do not reflect actual trading or investment, and no representation is made that any investor will or is likely to achieve comparable results.

7. Risk of Loss

An investment in any Fund involves a high degree of risk, including the possible loss of the entire amount invested. Risks include, among others: the distressed and special-situations nature of the strategy; the heightened political, legal, institutional, currency, expropriation, and sanctions risks of emerging and frontier markets, including Kazakhstan and Central Asia and parts of South America; sector-specific risks across mining and resources, energy and infrastructure, real estate and development, and agriculture and commodities; commodity-price volatility; illiquidity and the absence of any public or secondary market; long holding periods and capital lock-up; the use of leverage; concentration by sector, geography, and individual position; valuation uncertainty for private assets; conflicts of interest; and fees, expenses, and carried interest that reduce net returns. There is no assurance that any Fund will achieve its objectives or that any return, distribution, or income will be paid; distributions, where made, are discretionary and are not guaranteed. Prospective investors should review the full Risk Disclosure and the risk-factor section of the relevant Offering Documents, and should consult their own advisers.

8. Sanctions, Anti-Money-Laundering, and Eligibility Representations

Given the firm's footprint across Central Asia, the UAE, the United Kingdom, and the United States, and its activity in resource and infrastructure sectors, the firm applies a risk-based sanctions and anti-money-laundering program. Prospective investors, their beneficial owners and controllers, and, where relevant, counterparties are screened against applicable sanctions lists, including those administered by the U.S. Office of Foreign Assets Control (OFAC), the U.K. Office of Financial Sanctions Implementation (OFSI), the European Union, the United Nations, and the Astana Financial Services Authority.

The firm will not knowingly accept subscriptions from, or transact with, sanctioned or otherwise restricted persons, and reserves the right to reject, freeze, return, or unwind any subscription on sanctions or financial-crime grounds. In subscribing, investors will be required to represent, among other things, that they are not subject to sanctions, are not acting on behalf of any sanctioned or restricted person, and are not located in an embargoed jurisdiction. Further detail is set out in the firm's AML Policy.

9. No Representation or Warranty; Third-Party Information

Information on this website is provided "as is" and "as available." While the firm believes the information to be reliable as of the date published, it makes no representation or warranty, express or implied, as to its accuracy, completeness, or fitness for any purpose, and accepts no liability for any error or omission, to the maximum extent permitted by law. Certain information may be derived from third-party or market sources that have not been independently verified. Links to third-party websites are provided for convenience only and do not imply endorsement; the firm is not responsible for their content.

10. Intellectual Property

All content on this website — including text, graphics, logos, and the "Gliese Capital" name and marks — is owned by or licensed to Gliese Capital LLC and is protected by applicable intellectual-property laws. No content may be reproduced, distributed, or otherwise used except as permitted by the Terms of Service or with the firm's prior written consent.

11. Updates and Contact

This page may be amended from time to time; the version in effect is the one published on this website. Questions regarding this Important Information & Disclosures page may be directed to Gliese Capital LLC at compliance@gliesecap.com, with general enquiries to info@gliesecap.com. The firm's legal counsel are Cohen & Gresser and Morgan Lewis, and its auditor is EY.