On February 23, 2022, at approximately 3:00 GMT, Russia declared that it would invade Ukraine. Our team’s first thoughts are for the safety and well-being of the people of both Ukraine and Russia who have been harmed by this gross atrocity.

The conflict is obviously of material consequence for both investors generally and shareholders of the Seafarer Funds, and as such Seafarer is monitoring events closely.

Investors should consider not only first-order impacts of the conflict (i.e., companies directly impacted because they are based in either Russia or Ukraine), but also second-order impacts (i.e., companies not based in either country, but which have material business interests in either Russia or Ukraine), and even third-order impacts (i.e., companies that might be impacted because of ensuing security, energy or trade crises in Europe, or that might be otherwise impacted by the conflict as it persists or escalates).

To aid investors’ deliberations, Seafarer has summarized the exposures of the Seafarer Funds to first- and second-order impacts, as follows:

None of the aforementioned holdings are subject to Executive Order 14024.⁵

Seafarer has not disclosed all potential exposures to third-order impacts because the conflict is highly complicated and still unfolding. Seafarer believes that even if the immediate conflict subsides, it will engender a crisis that will have far-reaching and lasting implications for security, energy and trade practices in Europe and beyond.

During highly complicated, fast-moving, large-scale events such as this conflict, Seafarer’s general tendency is to avoid overreaction in the short term (either materially increasing or decreasing exposure). We prefer to gather facts over time and make careful, deliberate assessments before committing (or decommitting) large amounts of capital.

Thank you for placing your trust and capital with the Seafarer Funds.

Seafarer Capital Partners, LLC

The views and information discussed in this commentary are as of the date of publication and are subject to change post publication. The views expressed represent an assessment of market conditions at a specific point in time, are opinions only and should not be relied upon as investment advice regarding a particular investment or markets in general. Such information does not constitute a recommendation to buy or sell specific securities or investment vehicles. It should not be assumed that any investment will be profitable or will equal the performance of the portfolios or any securities or any sectors mentioned herein. The subject matter contained herein has been derived from several sources believed to be reliable and accurate at the time of compilation. The data provided is derived by Seafarer on a best efforts basis from publicly available information in the financial disclosures and regulatory filings of portfolio holdings in the Seafarer Funds. Seafarer does not warrant the data’s accuracy or completeness. Seafarer disclaims any responsibility for the use of this information for investment purposes; the Firm does not accept any liability for losses either direct or consequential caused by the use of this information.

1. View the holdings of the Seafarer Overseas Growth and Income Fund. View the holdings of the Seafarer Overseas Value Fund. Holdings are subject to change.
2. As of December 31, 2021, Global Ports Investments PLC, a Russian holding, comprised 1.1% of the Seafarer Overseas Value Fund’s net assets.
3. As of March 31, 2022, the Seafarer Overseas Value Fund retained its position in Global Ports Investments PLC, a Russian holding that represented 0.0% of the Fund’s net assets. Effective March 3, 2022, trading was halted in Russian securities, including this holding. Security prices subject to fair valuation determinations may be subject to future change in light of subsequent events and newly discovered information. Given the judgment involved in making a fair value determination, there can be no assurance that a fair value assigned to a particular security is accurate or that it reflects the price that could be obtained for such security if the security were to be sold at the time as of which fair value pricing is determined. Regarding the Seafarer Funds’ Fair Valuation Policies and Procedures: The Board of Trustees of the Seafarer Funds has adopted Fair Valuation Policies and Procedures for the fair valuation of portfolio assets held by the Funds in the event that (1) market quotations for the current price of a portfolio security or asset are not readily available or (2) available market quotations that would otherwise be used to value a portfolio security or asset in accordance with the Funds’ Pricing Policies and Procedures appear to be unreliable.  When such an event is identified, the Seafarer Funds’ Fair Valuation Committee makes a good faith determination of the fair value for a security in accordance with the Fair Valuation Policies and Procedures.  As part of this process, the Funds’ investment adviser, Seafarer Capital Partners, may provide information and a fair value recommendation to the Funds’ Fair Valuation Committee.  Before being implemented, a recommendation must be approved by other members of the Fair Valuation Committee via affirmative vote.
4. “Material business interests” is defined here as companies that have publicly disclosed in their most recently published annual report either (a) annual sales to Russia and/or Ukraine in excess of 10%, or (b) assets located in Russia and/or Ukraine in excess of 25%.
5. For information on Executive Order 14024, please see Executive Order on Prohibiting Certain Imports and New Investments With Respect to Continued Russian Federation Efforts to Undermine the Sovereignty and Territorial Integrity of Ukraine – March 8, 2022 and Executive Order 14024 – April 15, 2021.