Performance Composite Report Template (GIPS-aligned)

Performance Composite Report: [Composite name]

Annual performance report for one composite (the set of discretionary portfolios that follow the same strategy and are reported together as one track record), prepared by a firm that claims compliance with, or reports in the format of, the GIPS® standards (2020 edition for Firms, the current edition as of 2026-10). It covers the firm definition, the composite and benchmark, the annual return table with risk and dispersion statistics, the fee schedule, the calculation methodology (time-weighted and money-weighted returns), valuation, significant events, verification and a disclosure checklist written in our own words. The worked example is the fictional adviser Kestrel Bay Capital. Replace every [bracketed] value and every row marked Example. This template does not make a firm compliant: compliance is claimed firm-wide, and the required statements and disclosures must be taken from the official GIPS standards. This is a document format, not investment, legal or accounting advice. Obtain the standard or law for the normative text.

Document control

Approvals

Revision history

Contents

1. Firm definition and compliance claim
2. Composite description
3. Benchmark description
4. Annual performance table
5. Fee schedule and net-of-fee method
6. Calculation methodology
7. Valuation and policies
8. Significant events, errors and restatements
9. Verification status
10. Disclosure checklist
11. Production workflow and controls
12. Glossary and references

1. Firm definition and compliance claim

1.1 Firm definition

Example: Kestrel Bay Capital is a fictional investment adviser registered with the SEC. For this report the firm is defined as all discretionary and non-discretionary assets managed by Kestrel Bay Capital in its New York office. Its EU affiliate, Kestrel Bay Capital Europe (a MiFID investment firm), is a separate legal entity presented to clients under its own name and is therefore defined as a separate firm with its own claim. The fictional Kestrel Bay Global Quality Equity Fund, a UCITS managed by Kestrel Bay Capital Europe with the same strategy, is therefore not a member of this composite as shown in Fund Factsheet (finance/fund-factsheet). Total firm assets at 2025-12-31 were USD 2,480 million.

1.2 Compliance claim placeholder

Insert the compliance statement here only when the firm actually claims compliance and every firm-wide requirement has been met. Copy the wording exactly from the current GIPS standards; do not edit it, shorten it or add qualifiers. If the firm is verified, use the version of the statement for verified firms; if it is not, use the version for firms that have not been verified.

[Insert the compliance statement in the exact wording required by the GIPS standards for this firm's situation.]

If the firm does not claim compliance, delete this subsection and do not describe the report as compliant, "in accordance with" or "consistent with" the standards. A report that only borrows the layout is a marketing piece and must say nothing that implies compliance.

1.3 Trademark notice

Place the trademark notice required by the GIPS trademark guidelines at the foot of the report, in the exact wording given there. Use the registered mark on first use and only as an adjective ("GIPS® standards", "GIPS® Composite Report").

[Insert the trademark notice in the exact wording required by the current GIPS trademark guidelines.]

2. Composite description

2.1 Composite profile

Example: The Global Quality Equity Composite (KBC-GQE) contains all fee-paying, discretionary, long-only portfolios that invest in listed developed and emerging market equities of companies with high and stable returns on capital, typically 40 to 60 holdings, unhedged, with no leverage. Derivatives are not used except currency forwards to settle trades. The composite was created on 2016-01-15 and has an inception date of 2016-01-01. The reporting currency is USD. Portfolios below USD 2 million at the start of a month are excluded for that month. New portfolios join at the start of the first full calendar month after they are fully invested; terminated portfolios leave after the last full month before notice. A client contribution or withdrawal of 25% or more of portfolio assets is a significant cash flow: the portfolio leaves the composite for that month and returns at the start of the next month.

2.2 Membership changes since the last annual period

Example: no portfolio joined or left the composite during 2025, so the six portfolios in section 4.3 are the whole composite for that year. The log entries above fall in 2026, after the period covered by section 4, and will be reflected in the 2026 annual figures. The log is kept continuously, not only at year end.

Keep the history of every portfolio that has ever been in the composite. A terminated portfolio's past returns stay in the composite for the periods it was included; never remove them retroactively.

3. Benchmark description

Example: The benchmark is [a broad developed and emerging market equity index], net dividends reinvested, in USD, unhedged. It is the opportunity set from which the strategy selects stocks. The benchmark has not changed since inception. The firm holds a data licence that permits publication of annual benchmark returns in client materials.

Index names and data are usually trademarks and licensed data of the index provider. Use the provider's required attribution line and do not publish index constituent data beyond what the licence allows.

4. Annual performance table

4.1 Annual returns and statistics

All returns are in USD and are total returns including reinvested income. Gross returns are after transaction costs and before management fees. Net returns are after a model management fee (see section 5). Figures for the 3-year annualised standard deviation are calculated from 36 monthly returns held in the calculation workbook.

Notes to the table:

• N/A: the 3-year standard deviation is not shown until 36 monthly returns are available.
• N/M: internal dispersion is not shown as meaningful when too few portfolios were in the composite for the full year. State the threshold the firm applies and check it against the GIPS standards.
• Composite and firm assets are at year end. The percentage column is composite assets divided by firm assets (Example: 151.2 / 2,480 = 6.1% for 2025).
• Example: composite assets moved from USD 135.0 million at the end of 2024 to USD 151.2 million at the end of 2025. The 11.86% gross return accounts for USD 16.0 million (135.0 x 0.1186), and net client contributions for the remaining USD 0.2 million; the six portfolios were the same at both dates (section 4.3).

4.2 Annualised returns for the required periods

Marketing rules in several jurisdictions expect standard periods next to the calendar-year table. For a US registered adviser, the SEC Marketing Rule (17 CFR 275.206(4)-1(d)(2)) requires 1-, 5- and 10-year results (or since inception if shorter) ending no earlier than the most recent calendar year end, with equal prominence. Annualised returns are the geometric mean of the annual returns in the window.

Example: the 5-year gross figure links 2021 to 2025: 1.2012 x 0.8437 x 1.2148 x 1.1427 x 1.1186 = 1.5737, and 1.5737 to the power 1/5, minus 1, gives 9.49% p.a.

4.3 Internal dispersion worked example

Internal dispersion shows how consistently the strategy was applied across portfolios that were in the composite for the whole year. The firm uses the asset-weighted standard deviation of annual portfolio returns around the composite return; state the measure the firm chose. For simplicity this worked example weights by assets at the start of the year; the production calculation aggregates monthly.

Example: the asset-weighted composite return is 11.86% and the asset-weighted dispersion is 0.63%. For comparison, the equal-weighted population standard deviation of the six returns is 0.90% and the high-low range is 2.69 percentage points (12.86 minus 10.17). The six portfolios were in the composite for all of 2025 (membership did not change during 2025), so they are both the dispersion population and the full composite for the year. Their beginning assets (USD 135.0 million) therefore equal the 2024 year-end composite assets in section 4.1.

4.4 Reconciliation

5. Fee schedule and net-of-fee method

5.1 Current fee schedule

Example: a USD 40 million portfolio pays 0.75% on the first 25 million (USD 187,500) and 0.60% on the next 15 million (USD 90,000), total USD 277,500 a year or 0.69% of assets.

5.2 Net-of-fee method

Example: net returns are calculated by deducting one twelfth of the highest tier fee (0.75% a year) from the gross composite return each month, so the annual model fee compounds:

For 2025: 1.1186 x (1 - 0.000625) to the 12th power = 1.1186 x 0.99253 = 1.1102, so the net return is 11.02%.

Record whether actual or model fees are used, why the chosen model fee is at least as high as the fee a prospective client would pay, and the treatment of performance fees and bundled fees. The SEC staff Marketing Compliance FAQ (updated 2025-03-19 and 2026-01-15) addresses net performance (including net figures that use actual fees when future fees will be higher) and extracted performance; check the current FAQ before publication.

6. Calculation methodology

6.1 Portfolio returns: time-weighted return

The firm calculates portfolio returns as time-weighted returns (TWR). The portfolio is valued on the date of each external cash flow of 10% or more of its value (Example firm threshold) and at each month end. Sub-period returns are linked geometrically, so the timing and size of client contributions and withdrawals do not affect the result.

Here the external cash flow $CF_s$ is treated as arriving at the start of sub-period $s$, and $BMV_s$ is the value just before it arrives.

Example (portfolio P-104, July 2026): beginning value USD 10.00 million on 2026-07-01; value USD 10.25 million at the close of 2026-07-15; contribution of USD 2.00 million at the start of 2026-07-16; ending value USD 12.18 million on 2026-07-31.

Linking: 1.025 x (12.18 / 12.25) = 1.025 x 0.994286 = 1.019143, so the TWR for July is 1.914%.

6.2 Approximation for flows without a valuation

Where a cash flow is below the firm's revaluation threshold, the modified Dietz method weights each flow by the fraction of the period it was invested:

where $D$ is the number of days in the period and $d_j$ is the number of days elapsed before flow $j$ arrives. Example: applying it to the same July data, the flow arrives after 15 of 31 days, so $W$ = 16/31 = 0.5161; the gain is 12.18 minus 10.00 minus 2.00 = 0.18; the return is 0.18 / (10.00 + 2.00 x 0.5161) = 0.18 / 11.0323 = 1.632%. The gap to the true TWR (1.914%) shows why large flows require a valuation.

6.3 Money-weighted return

Money-weighted return (MWR, the internal rate of return) reflects the timing of cash flows and is the usual measure for closed-end private market funds where the manager controls flows. If the composite uses MWR, show it since inception, annualised, with the cash flow frequency.

Example: solving this for July gives a monthly MWR of 1.632%, close to the modified Dietz figure, because modified Dietz is a first-order approximation of the same rate. For this open-ended equity strategy the firm reports TWR, which is the appropriate measure when clients, not the manager, decide on contributions and withdrawals.

6.4 Composite returns

7. Valuation and policies

Example: Kestrel Bay Capital values listed equities at the closing price on the primary exchange, converted at the 16:00 London fix. Its valuation committee approves any override and reviews stale prices weekly.

8. Significant events, errors and restatements

8.1 Significant events

8.2 Error correction log

Define materiality in the firm's error correction policy (for example, by size of the change and whether it would alter a reader's view). Keep the disclosure for the period the policy and the standards require.

9. Verification status

Example: Kestrel Bay Capital has been verified for the periods 2016-01-01 to 2025-12-31. The Global Quality Equity Composite has not had a performance examination. The verification report is available on request.

10. Disclosure checklist

Tick each item only after comparing the report with the official source. This list is original to this template and is not the list of GIPS provisions; obtain the standards for the authoritative list.

11. Production workflow and controls

Keep the records that support each figure (portfolio valuations, transactions, membership decisions and calculations) for at least the period required by the firm's record-keeping rules; for a US adviser, check the books and records rule (17 CFR 275.204-2).

12. Glossary and references

12.1 Glossary

12.2 References

Standard and licence note

Structure aligned with the GIPS® standards (2020 edition for Firms), which are referenced by name only; no text, provision wording, sample report or table from the standards is reproduced or paraphrased. GIPS® is a registered trademark of its owner, which has not endorsed or reviewed this template; insert the compliance statement, verification wording and trademark notice from the official sources. The SEC Marketing Rule and record-keeping rule (US federal works) and EU legislation from EUR-Lex are cited by section and article in original wording; the ESMA guidelines are cited by reference and ESMA does not endorse this template. The worked example (Kestrel Bay Capital) and all figures are fictional. The text is original. Check the current official versions before use. This is a document format, not investment, legal or accounting advice. Template licence: MIT.