FORM ADV PART 2A BROCHURE

Robertson Stephens Wealth Management, LLC

455 Market Street Suite 1450 San Francisco, CA 94105-2442 (415) 500-6810

www.rscapital.com

March 31, 2026  

This brochure provides information about the qualifications and business practices of Robertson Stephens Wealth Management, LLC. If you have any questions about the contents of this brochure, contact us at 415-500-6835. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. 

Additional information about Robertson Stephens Wealth Management, LLC is available on the SEC's website at www.adviserinfo.sec.gov. 

Robertson Stephens Wealth Management, LLC is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training.  

Item 2 Summary of Material Changes  

Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. 

Since the filing of our last annual updating amendment, dated March 31, 2025 we have no material changes to report. 

Item 3 Table of Contents  

Item 2 Summary of Material Changes 2 

Item 3 Table of Contents 3 

Item 4 Advisory Business 4 

Item 5 Fees and Compensation 5 

Item 6 Performance-Based Fees and Side-By-Side Management 7 

Item 7 Types of Clients 7 

Item 8 Methods of Analysis, Investment Strategies and Risk of Loss 8 

Item 9 Disciplinary Information 10 

Item 10 Other Financial Industry Activities and Affiliations 10 

Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 11 

Item 12 Brokerage Practices 13 

Item 13 Review of Accounts 16 

Item 14 Client Referrals and Other Compensation 16 

Item 15 Custody 16 

Item 16 Investment Discretion 17 

Item 17 Voting Client Securities 17 

Item 18 Financial Information 17 

  

Item 4 Advisory Business  

Robertson Stephens Wealth Management, LLC ("Robertson Stephens") is a Delaware limited liability company and a wholly-owned subsidiary of Robertson Stephens Holdings, LLC. Robertson Stephens has been in business and registered with the SEC since 2017. 

Robertson Stephens offers investment advisory services including investment management, investment consulting, pension consulting, portfolio asset allocation, and due diligence and performance monitoring of professional money managers. Robertson Stephens provides advice on the management of investments in equities, fixed income, mutual funds, exchange-traded funds, options, and private funds, including hedge funds, fund of funds, private equity funds and other similar investments. Robertson Stephens offers additional advisory services such as financial planning, cash management, tax and estate planning, insurance planning, risk management, retirement planning, financial education, family office services, financial reporting, and administration. Robertson Stephens also offers tax management and compliance services to clients. 

Investment management services are offered on a discretionary and non-discretionary basis as described in the client's investment advisory agreement. 

Robertson Stephens’ investment advisory services are provided to clients through its investment advisor representatives ("Advisors"). Advisors provide individualized investment advice based on the client's investment profile, including, but not limited to, their financial situation, goals and risk tolerance, which in turn are based on financial records provided by clients, responses to questionnaires, and/or client interviews. 

Advisors assess and analyze each client's financial situation and investment objectives and develop an asset allocation plan, investment policy statement, financial plan or other similar statement of work which is reviewed with clients. Advisors implement this plan as agreed to by the client. Clients may impose restrictions on investing in certain securities or types of investments. There is an inherent conflict of interest for Robertson Stephens whenever a financial plan recommends use of professional investment management services or the purchase of insurance products or other financial products or services through Robertson Stephens or its affiliates because Robertson Stephens or certain of its Advisors and affiliates may receive compensation for financial planning as well as for the provision of investment management services, the sale of insurance and/or other products and services. Robertson Stephens does not make any representation that these products and services are offered at the lowest available cost and the client may be able to obtain the same products or services at a lower cost from other providers. However, the client is under no obligation to accept any of the recommendations of Robertson Stephens or use the services of Robertson Stephens. 

Portfolio management strategies may be implemented by third-party professional money managers or sub-advisors. Robertson Stephens performs the necessary due diligence to evaluate the selection, performance and suitability of money managers. These money managers will have full investment discretion and trading authority. Advisors will also provide ongoing advice and monitoring relating to the services of the money manager. 

Robertson Stephens’ portfolio management services may include an investment of a client’s assets in one or more model portfolios developed by Robertson Stephens. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. 

Robertson Stephens may utilize sub-advisors, who are completely independent and unaffiliated with either Robertson Stephens or the Advisor. When managing client portfolios, Advisors and sub-advisors may therefore provide advice on other investment advisors. Robertson Stephens may also offer advice on investing in alternative strategies such as hedge funds, funds of funds, private equity, venture capital funds and other similar investment vehicles. 

Advisors may also provide direct portfolio management services as agreed to by clients. 

Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment to you. 

IRA Rollover Recommendations  

When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: 

• Meet a professional standard of care when making investment recommendations (give prudent advice);  

• Never put our financial interests ahead of yours when making recommendations (give loyal advice);  

• Avoid misleading statements about conflicts of interest, fees, and investments;  

• Follow policies and procedures designed to ensure that we give advice that is in your best interest;  

• Charge no more than is reasonable for our services; and  

• Give you basic information about conflicts of interest.  

  

We benefit financially from the rollover of your assets from a retirement account to an account that we manage or on which we provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. 

Assets Under Management  

As of December 31, 2025, we manage total client assets of $8,763,969,974 as disclosed in Item 5.F.(2)(c) of our Form ADV Part 1. Of these, we manage $6,992,879,444 on a discretionary basis and $1,771,090,530 on a non-discretionary basis. 

Item 5 Fees and Compensation  

Investment advisory fees are typically charged as a percentage of assets under management and based on the value of a client’s assets on the last day of the calendar quarter or on the average daily balance. Client fees are billed and payable quarterly, either in advance or arrears. Fees for investment management services are negotiable but typically range from 0.10% to 2%, based on the size and complexity of the services required to manage the assets and will typically be debited directly from client accounts with the client's written authorization, unless a different method of payment is mutually agreed to. A client’s specific advisory fee and manner of calculation will be disclosed clearly in the client’s investment advisory agreement. 

For the client’s first billing period, fees will typically be billed in arrears based on the aggregate average daily balance of the assets under management during the period. The fees for a partial quarter at the termination of the client’s relationship with Robertson Stephens will be prorated based on the number of days the assets were managed during the quarter. A significant addition or withdrawal of greater than one million dollars of assets under management will typically be subject to a fee adjustment based on the value of the assets and a proration based on the number of days applicable to the addition or withdrawal. Details are disclosed in each client’s individual investment advisory agreement. 

The market value of the assets under management is determined by Robertson Stephens based on (1) the securities pricing information provided by the custodian, (2) the most recent and available pricing information received by Robertson Stephens from third-party managers and/or fund(s) the assets are invested in, if available, and (3) for securities and other assets that are not publicly traded or for which third-party managers and/or funds do not provide regular pricing information, such relevant information that Robertson Stephens deems appropriate based on the Robertson Stephens’ valuation policies and procedures, including, if available, historical cost, comparable asset pricing and other factors. Robertson Stephens reserves the right, in its sole and absolute discretion, in each instance to adjust the market value of the assets under management with respect to current or prior billing periods (and accordingly, its fees) if Robertson Stephens determines, in its reasonable discretion, such adjustment is necessary or advisable in order to provide a more accurate fair market value of the assets or if Robertson Stephens receives adjusted pricing information from third-party sources and determines such adjustment to be material. All assets listed on Robertson Stephens-provided reports but classified by Robertson Stephens as non-billable will not be included in the calculation of the fee for so long as they are classified by the Advisor as non-billable. 

At the clients’ request and subject to negotiation, clients can be charged an annual fixed fee for investment management services. Annual fixed fees are negotiated based on the size and complexity of the relationship and charged based on the frequency stated in the agreement with the client. 

Use of Margin 

To the extent that a client authorizes the use of margin, and margin is thereafter employed by Robertson Stephens in the management of the client's investment portfolio, the market value of the client's account and corresponding fee payable by the client to Robertson Stephens will be increased, which increases the investment advisory fee charged to the client account. Clients are not required to use margin in their investment accounts. 

Financial Planning Services  

Financial planning services may be billed separately or included with investment management and other services under a single advisory fee. Financial planning fees, when charged separately, will be disclosed in the client agreement. Such fees are negotiable depending on the complexity of the plan and nature of the services (e.g., a one-time vs. ongoing engagement) and are typically charged at either (a) an hourly rate of $250 to $500 per hour with or without an up-front non-refundable retainer, (b) as quarterly flat fee installments totaling $500 to $100,000 per year, or (c) as a flat fee of $2,500 to $50,000 per plan and $1,000 to $5,000 per update, or (d) based on the client's marketable net worth. Fees based on the client's marketable net worth will typically include assets owned or in trust, and all U.S. or foreign assets including brokerage, 401(k), IRA, investment, and other assets as well as real estate (net of mortgages) but exclude any assets which cannot or will not be disposed of in a structured and liquid market. Clients may cancel the financial planning services at any time upon written notice. Upon cancellation, the client will be invoiced for work performed to date, which is payable upon receipt. 

Retirement Plan Consulting Services  

Retirement Plan consulting fees are negotiated with the client based on the nature and complexity of the services required and they are stated in the client contract. 

Tax Compliance Services  

Tax compliance services may include the preparation and filing of tax returns, addressing notices, computing estimated taxes, and representation of taxpayers before taxing authorities. Separately charged Tax Compliance fees are negotiable but are generally charged based on the specific returns and form filed and/or time spent. 

Tax Management Services  

Tax Management Services include tax advice and execution of tax strategies as well as Tax Compliance. Separately charged Tax Management fees are negotiable but generally range from $500 to $10,000 per tax year depending upon the level and scope of the service(s) required and are payable (as disclosed in the agreement with the client) either as a one-time fee or quarterly for ongoing services. 

Other Services  

Separately charged fees for other services are negotiable and depend on the nature, complexity, and level of the services and the fees and payment terms will be documented in the relevant agreement with the client. 

Payment of Fees  

Clients can pay their fees by (1) authorizing Robertson Stephens to debit their custodian account for advisory service fees; (2) providing authorization through Bill.com to execute an ACH transaction from the client’s account at a financial institution or charge the client’s credit card, (3) check or (4) by electronic funds transfer directly to Robertson Stephens. 

Additional Fee Information 

In addition to Robertson Stephens’ fees, clients may be separately responsible for management fees charged by money managers, investment managers, sub-advisors, hedge funds, private equity funds, fund of funds and other investments as outlined in the client contracts with those providers. Terms of these management fees may differ from Robertson Stephens terms (i.e., in advance vs. in arrears) and will be disclosed separately. Fees from such managers and sub-advisors will typically be deducted directly from client accounts at the custodian. In addition, clients are separately responsible for applicable transaction fees, commissions, and expenses charged by custodians and broker-dealers and mutual funds. 

Client Review of Custodian Statements 

Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their custodial statements to verify the accuracy of the calculation and consistency with the client’s agreement with Robertson Stephens, among other things. 

Item 6 Performance-Based Fees and Side-By-Side Management  

Robertson Stephens does not accept performance-based fees or participate in side-by-side management. Performance-based fees are fees that are based on a share of capital gains or capital appreciation of a client's account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. Our fees are calculated as described in the Fees and Compensation section above and are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your advisory account.  

Item 7 Types of Clients  

Robertson Stephens primarily provides investment advisory services to individuals, including without limitation high net worth individuals and families, and associated trusts, estates, family and multi-family offices, charitable organizations, retirement and profit sharing plans, and other legal entities. 

Item 8 Methods of Analysis, Investment Strategies and Risk of Loss 

Robertson Stephens develops, recommends, and implements investment strategies for its clients in accordance with each client’s individual investment profile. Robertson Stephens makes asset allocation recommendations along with recommendations for third-party account managers, public and private fund managers, and individual investments designed to achieve the recommended asset allocations. 

The Robertson Stephens Investment Office develops model portfolios that seek to achieve varying levels of risk and return and conducts due diligence on third-party managers and funds. 

The Robertson Stephens Investment Committee oversees, advises on, and approves the Investment Office's capital market assumptions, investment evaluation framework, model solutions and manager and fund offerings. 

Robertson Stephens Advisors review individual client investment profiles and make client-specific recommendations regarding investment strategies, asset allocation, managers, and investments. Investment advice will vary depending upon each client’s specific investment profile, and different advice may be given to different clients regarding the same investments. Advisors review Investment Office output in addition to conducting research and analysis of their own. Advisors are ultimately responsible for determining the suitability of all individual client recommendations.

While the Advisor does not incorporate Environmental, Social, & Governance, “ESG”, factors into its investment approach generally, it may consider ESG integration and/or exclusions for Advisory Clients on a case-by-case basis upon request. There are no universally accepted ESG standards and not all Advisory Clients may agree on the appropriate ESG standards to apply in a particular situation. 

Risks  

Investing in securities is inherently risky. Different types of investments involve varying degrees of risk, and clients should be prepared to bear that risk. Each investment involves risk of loss. Past performance is no guarantee of future performance. There is no guarantee that any investment strategy or recommendation will meet its objectives. The following additional risks may be faced by the client depending on the investment: 

Market & Interest Rate Risks - General economic conditions and changing interest rates may affect securities prices and liquidity which could result in losses. 

Issuer & Credit Risks - Certain risks including failure to meet financial obligations, reinvestment, default, prepayment and duration may affect securities prices and liquidity which could result in losses. 

International Investment Risks - Foreign securities may have additional risks such as trade tariffs, currency controls, exchange rate fluctuations, withholding taxes, political uncertainty and instability which could result in losses. 

Liquidity Risks - Securities actively traded on exchanges may be subject to periods of illiquidity and may not be able to be sold at the desired time which could result in losses. 

Mutual Fund and ETF Risks - Are subject to the risks stemming from the individual issuers of the fund's underlying portfolio securities which could result in losses. 

Alternative Strategies - Investments in companies or securities that are not publicly traded are normally illiquid and run the risk of a majority or complete loss of investment depending on underlying companies. These investments should be considered long term and investors may not see any return for longer periods of time depending on underlying companies. 

ESG Investing Risk - In the course of an advisory relationship, a client may request that Robertson Stephens recommend third-party ESG-related investments or managers. ESG portfolios may underperform a traditional portfolio due to a variety of factors including, but not limited to, changes in legislation or new regulations, advents of new technology, increased costs associated with minimizing environmental impacts, increased costs due to socially responsible programs and similar initiatives and other factors. There may also be increased costs associated with these investments. Robertson Stephens makes no assurances with respect to performance and adherence by a third-party to any ESG factors or sustainability standard. 

Options Contracts – Options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. Risks of options trading include, but are not limited to, the following: 

• Option buyers run the risk of losing their entire investment in a relatively short period of time.  

• Covered call traders forego the right to profit when the underlying stock rises above the strike price of the call options sold and continue to risk a loss due to a decline in the underlying stock.  

• Writers of naked calls risk unlimited losses if the underlying stock rises.  

• Writers of naked puts risk substantial losses due to a decline in the underlying stock.  

Prior to buying or selling an option, investors must read a copy of the Characteristics and Risks of Standardized Options, also known as the options disclosure document (ODD). It explains the characteristics and risks of exchange traded options and may be found at the following location: https://www.theocc.com/Company-Information/Documents-and-Archives/Options-Disclosure- Document.  

Use of Margin - While the use of margin borrowing for investments can substantially improve returns, it may also increase overall portfolio risk and have a significant effect on the profitability and stability of a client's portfolio. Margin transactions are generally effected using capital borrowed from a financial institution (“lender”). Securities purchased on margin are the lender's collateral for the loan to you. If the securities in your account decline in value, so does the value of the collateral supporting your loan, and, as a result, the lender can take action, such as issue a margin call and/or sell securities or other assets in any of your accounts held with the member, in order to maintain the required equity in the account. It is important that you fully understand the risks involved in trading securities on margin. These risks include, but are not limited to, the following: 

• You can lose more funds than you deposit in the margin account.  

• The lender can force the sale of securities or other assets in your account(s).  

• The lender can sell your securities or other assets without contacting you.  

• You are not entitled to choose which securities or other assets in your account(s) are liquidated or sold to meet a margin call.  

• The lender can increase its "house" maintenance margin requirements at any time and is not required to provide you with advance written notice.  

• You are not entitled to an extension of time on a margin call.  

  

Additionally, to the extent that a client authorizes the use of margin, and margin is thereafter employed by Robertson Stephens in the management of the client's investment portfolio, the market value of the client's account and corresponding fee payable by the client to Robertson Stephens will be increased. As a result, in addition to understanding and assuming the additional principal risks associated with the use of margin, clients authorizing margin are advised of the potential conflict of interest whereby the client's decision to employ margin may correspondingly increase the management fee payable to Robertson Stephens. Accordingly, the decision as to whether to employ margin is left to the discretion of the client. 

Item 9 Disciplinary Information  

Robertson Stephens is required to disclose the facts of any legal or disciplinary events that are material to a client's evaluation of its advisory business or the integrity of management. Robertson Stephens and its management have no reportable disciplinary events to disclose. 

Item 10 Other Financial Industry Activities and Affiliations  

Robertson Stephens is a wholly-owned subsidiary of Robertson Stephens Holdings, LLC ("RSH"). RSH is majority- owned by investment funds managed by affiliates of Long Arc Capital LP, a private equity investment firm (together with its affiliates, "Long Arc"), and receives management and strategic advisory services from Long Arc. Robertson Stephens recommends investments in private funds issued, sponsored or managed by Long Arc (“Long Arc Funds”) and for which Long Arc receives compensation or maintains a proprietary interest. This presents a conflict of interest because Robertson Stephens has an incentive to recommend Long Arc Funds over similar investments managed by unaffiliated third-party managers based on compensation received by an affiliate, rather than based solely on clients’ best interests. There is no requirement for Robertson Stephens to recommend Long Arc Funds to clients, clients are not obligated to invest in Long Arc Funds, and Long Arc Funds may only be recommended to clients when the recommendations are in the clients’ best interests. When recommending Long Arc Funds to clients, Robertson Stephens will ensure that all relevant fees and conflicts are disclosed. 

Robertson Stephens offers tax management and compliance services to clients. This practice presents a conflict of interest as Robertson Stephens is incentivized to recommend such services based on compensation rather than client need. No client is under any obligation to utilize tax management and compliance services from Robertson Stephens. 

Some Robertson Stephens employees engage in outside business activities selling insurance products as licensed insurance agents. Insurance products are sold through our affiliated insurance agency, 415 Insurance Solutions, LLC (“415”), as well as through independent, third-party agencies. 415 and these insurance licensed employees receive compensation in the form of commissions for the sale of these products. This practice presents a conflict of interest, in that it provides an incentive for 415 and these employees to recommend insurance products based on compensation received rather than on client need. Any insurance commissions you pay are separate and distinct from the fees you pay to Robertson Stephens for investment advisory services. Clients are under no obligation to purchase insurance products from 415 or any Robertson Stephens employee. 

Some Robertson Stephens Advisors are also Registered Representatives (“RR”s) of the Company’s affiliated broker dealer (“BD”), Robertson Stephens Capital Markets, LLC (“RSCM”), a member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation. RRs of RSCM recommend brokerage products to clients through RSCM brokerage accounts. If you purchase products through RSCM, RRs receive brokerage compensation including commissions, asset-based sales charges, service fees or 12b-1 fees for the sale or holding mutual funds (collectively “commissions”). Additionally, RRs could be eligible to receive incentive awards such as RSCM may offer. This activity presents a conflict of interest because Robertson Stephens Advisors who are RRs of RSCM have an incentive to recommend brokerage products to you in brokerage accounts based on the commissions received, rather than on your investment needs. Any brokerage commissions earned by these BD-licensed Advisors through RSCM are separate and distinct from the fees you pay Robertson Stephens for advisory services, and any transaction made by a Robertson Stephens Advisor in the capacity of RR will take place outside of your advisory account. Neither RSCM nor its RRs will receive commissions on assets held in your advisory account. You are under no obligation, contractually or otherwise, to purchase brokerage products through RSCM or any RSCM RR. 

Robertson Stephens recommends private investments that are issued, sponsored, or managed by clients of Robertson Stephens (“Client-Managed Investments”). When Robertson Stephens clients purchase Client-Managed Investments in Robertson Stephens-managed portfolios, Robertson Stephens charges an advisory fee on those holdings. This presents a conflict of interest because Robertson Stephens has an incentive to recommend the Client-Managed Investments in the hopes of earning or maintaining the advisory business of the clients managing these investments rather than based solely on the best interests of the purchasing clients. There is no requirement for Robertson Stephens to recommend Client-Managed Funds to clients, clients are not obligated to purchase Client-Managed Funds, and Client-Managed Funds may only be recommended to clients when the recommendations are in the best interests of the purchasing clients. When recommending Client-Managed Investments to clients, Robertson Stephens will ensure that all relevant conflicts are disclosed. 

Vikram Chugh, Chief Operating Officer of Robertson Stephens serves on the Schwab Advisor Services Client Experience Panel (the “CX Panel”). The CX Panel consists of representatives of independent investment advisory firms who have been invited by Schwab to participate in meetings and discussion regarding Schwab Advisor Services’ services for independent investment advisory firms and their clients. CX Panel members sign nondisclosure agreements with Schwab under which they agree not to disclose confidential information shared with them. This information generally does not include material nonpublic information about the Charles Schwab Corporation, whose common stock is listed for public trading on the New York Stock Exchange (symbol SCHW). The CX Panel meets in person or virtually approximately twice per year and has periodic conference calls scheduled as needed. CX Panel members are not compensated by Schwab for their participation, but Schwab does pay for or reimburse CX Panel members’ travel, lodging, meals and other incidental expenses incurred in attending meetings. 

Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading  

Robertson Stephens, its principals, Advisors and employees may personally invest in the same investments recommended to clients. Robertson Stephens has adopted a code of ethics that addresses and seeks to avoid conflicts of interest involving personal trades and includes policies and procedures to prevent insider trading and front-running. The code of ethics requires, among other things, that its principals, Advisors and employees (collectively, “Associated Persons”): 

• At all times, all Associated Persons must comply with applicable federal securities laws and must reflect the professional standards expected of those engaged in the investment advisory business, and they shall act within the spirit and the letter of the federal, state, and local laws and regulations pertaining to investment advisers and the general conduct of business. These standards require all personnel to be judicious, accurate, objective, and reasonable in dealing with both clients and other parties so that his or her personal integrity is unquestionable.  

• All Associated Persons are required to report any violation of the Code, by any person, to the Chief Compliance Officer (“CCO”) or other appropriate persons of the Company promptly. Such reports will be held in confidence.  

• Associated Persons must place the interests of clients first. All Associated Persons must scrupulously avoid serving his or her own personal interests ahead of the interests of the Company's clients. In addition, Associated Persons must work diligently to ensure that no client is preferred over any other client.  

• Associated Persons must use good judgment in identifying and responding appropriately to actual or apparent conflicts. Conflicts of interest that involve the Company and/or its Associated Persons on one hand and clients on the other hand will generally be fully disclosed and/or resolved in a way that favors the interests of the clients over the interests of the Company and its Associated Persons. If an Associated Person believes that a conflict of interest has not been identified or appropriately addressed, that Associated Person should promptly bring the issue to the CCO’s attention.  

• All Associated Persons are naturally prohibited from engaging in any practice that defrauds or misleads any client, or from engaging in any manipulative or deceitful practice with respect to clients or securities.  

• No Associated Person may serve on the board of directors of any publicly traded company without prior written permission from the CCO.  

• Associated Persons will not cause or attempt to cause any client to purchase, sell, or hold any security in a manner calculated to create any personal benefit, or on behalf of the Company.  

• Associated Persons must use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, trading, promoting the Company’s services, and engaging in other professional activities.  

• Associated Persons must conduct all personal securities transactions in full compliance with this Code. Doubtful situations should be resolved in favor of clients and in cooperation with the CCO. Technical compliance with the Code's provisions shall not automatically insulate from scrutiny any securities transactions or actions that could indicate a violation of the Company's fiduciary duties.  

• Personal transactions in securities by Access Persons must be transacted to avoid even the appearance of a conflict of interest on the part of such personnel with the interests of the Company's clients. Likewise, Associated Persons must avoid actions or activities that allow (or appear to allow) a person to profit or benefit from his or her position with the Company at the expense of clients, or that otherwise bring into question the person's judgment.  

• Associated Persons are subject to Insider Trading Policies adopted by the Company to detect and prevent the misuse of material nonpublic information.  

• No Associated Person shall communicate information known to be false to others (including but not limited to clients, prospective clients and other Associated Persons) with the intention of manipulating financial markets for personal gain.  

• Associated Persons are prohibited from accepting compensation for services from outside sources without the specific prior written permission of the CCO.  

• When any Associated Person faces a conflict or potential conflict between his or her personal interest and the interests of clients, he or she is required to immediately report the conflict to the CCO for instructions regarding how to proceed.  

• Associated Persons must treat recommendations and actions of the Company as confidential and private matters. Accordingly, we have adopted a Privacy Policy to prohibit the transmission, distribution, or communication of any information regarding securities transactions in client accounts or other nonpublic information, except to broker-dealers, other bona fide service providers, or regulators in the ordinary course of business. In addition, no information obtained during the course of employment regarding particular securities (including internal reports and recommendations) may be transmitted, distributed, or communicated to anyone who is not affiliated with the Company, without the prior written approval of the CCO.  

• No Associated Person shall intentionally sell to or purchase from a client any security or other property without prior written authorization from the CCO.  

• No Associated Person shall provide loans or receive loans from clients.  

  

Robertson Stephens’ Compliance Policy also requires employees to: (1) pre-clear certain personal securities transactions, (2) report personal securities transactions on at least a quarterly basis, and (3) provide Robertson Stephens with a detailed summary of certain holdings (both initially upon commencement of employment and annually thereafter) over which such employees have a direct or indirect beneficial interest. 

A copy of Robertson Stephens’ Code of Ethics shall be provided to any client or prospective client upon request. 

Item 12 Brokerage Practices  

The Custodians and Brokers We Use  

Robertson Stephens does not maintain custody of client assets that we manage or on which we advise, although we may be deemed to have custody of client assets if clients give us authority to withdraw assets from their accounts (see Item 15 Custody, below). Client assets must be maintained in accounts at a “qualified custodian,” generally a broker-dealer or bank. Robertson Stephens recommends that clients establish custodial accounts with certain independent custodians (“Recommended Custodians”) such as National Financial Services LLC and Fidelity Brokerage Services LLC (together with all affiliates, "Fidelity"), Charles Schwab & Co., Inc. ("Schwab") and Pershing Advisors Solutions LLC, each a FINRA-registered broker-dealer and member of SIPC, to maintain custody of their assets and to execute trades for their accounts. Robertson Stephens is independently owned and operated and is not affiliated with any Recommended Custodians. While Robertson Stephens recommends that clients use Recommended Custodians, clients will decide whether to do so and will open their accounts with Recommended Custodians by entering into account agreements directly with them. We do not open accounts for clients, although we may assist them in doing so. Robertson Stephens does not require that clients' custody their assets with Recommended Custodians or any other particular custodian; a client may use other custodians as determined by the client. Conflicts of interest associated with Robertson Stephens’ recommendation of Recommended Custodians are described below as well as in Item 14 (Client referrals and other compensation). You should consider these conflicts of interest when selecting your custodian. 

  

How We Select Custodians  

When recommending custodians, Robertson Stephens considers a wide range of factors, including the following: 

• Combination of transaction execution services along with asset custody services  

• Capability to execute, clear and settle trades (buy and sell securities for the client's account)  

• Capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.)  

• Breadth of investment products made available (stocks, bonds, mutual funds, Exchange traded funds (ETFs), etc.)  

• Availability of investment research and tools that assist Robertson Stephens in making investment decisions  

• Quality of services  

• Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate them  

• Reputation, financial strength and stability of the provider  

• Availability of other products and services that benefit Robertson Stephens and the client  

Client Brokerage and Custody Costs  

Custodians typically charge brokerage commissions and transaction fees for effecting securities transactions in client accounts. Custodians are also compensated for other services such as margin lending and securities lending and on earned interest on uninvested cash in client accounts. Recommended Custodian commission rates are generally considered discounted from customary retail commission rates. However, there is no guarantee that commissions and transaction fees charged by Recommended Custodians will be lower than those charged by other custodians and broker-dealers. Robertson Stephens is not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although Robertson Stephens is not required to execute all trades through Recommended Custodians, Robertson Stephens has determined that having them execute most trades is consistent with its duty to seek “best execution” of client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer clients may pay lower transaction costs. 

Margin Costs 

Clients will incur additional costs when using margin as custodians charge interest on the borrowed funds. Interest rates are set by the custodian of your account. Robertson Stephens does not receive any compensation from your custodian when margin is used. 

Products and Services Available to Robertson Stephens from Recommended Custodians  

Recommended Custodians have businesses serving independent investment advisory firms like Robertson Stephens. They provide Robertson Stephens and its clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to retail customers. However, certain retail investors may be able to get institutional brokerage services without going through Robertson Stephens. Recommended Custodians also make available various support services. Some of those services help Robertson Stephens manage or administer its clients’ accounts, while others help Robertson Stephens manage and grow its business. These support services are generally available at no charge to Robertson Stephens. Following is a more detailed description of these support services: 

Services That Benefit Clients  

The institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products include some to which Robertson Stephens might not otherwise have access or that would require a significantly higher minimum initial investment by clients. The services described in this paragraph generally benefit clients and client accounts. 

Services That Do Not Directly Benefit Clients  

Recommended Custodians also make available to Robertson Stephens other products and services that benefit Robertson Stephens but do not directly benefit clients or client accounts. These products and services assist Robertson Stephens in managing and administering clients’ accounts and operating its business. They include investment research from Recommended Custodians and that of third parties. Robertson Stephens uses this research to service all or a substantial number of its clients’ accounts, including accounts not maintained at Recommended Custodians. In addition to investment research, Recommended Custodians also make available software and other technology that: 

• Provide access to client account data (such as duplicate trade confirmations and account statements)  

• Facilitate trade execution and allocate aggregated trade orders for multiple client accounts  

• Provide pricing and other market data  

• Facilitate payment of advisory fees from clients’ accounts  

• Assist with back-office functions, recordkeeping, and client reporting  

Services That Generally Benefit Only Robertson Stephens  

Recommended Custodians also offer other services intended to help Robertson Stephens manage and further develop its business enterprise. These services include: 

• Educational conferences and events  

• Consulting on technology and business needs  

• Consulting on legal and compliance related needs  

• Publications and conferences on practice management and business succession  

• Access to employee benefits providers, human capital consultants, and insurance providers  

• Marketing consulting and support  

• Recruiting and custodial search consulting  

  

Recommended Custodians provide some of these services themselves. In other cases, they will arrange for third-party vendors to provide the services. Recommended Custodians also discount or waive their fees for some of these services or pay all or a part of a third party’s fees. If clients did not maintain their accounts with Recommended Custodians, Robertson Stephens would be required to pay for those services from its own resources. 

Robertson Stephens’ Interest in Recommended Custodians’ Services  

The availability of these services from Recommended Custodians benefits Robertson Stephens because it does not have to produce or purchase them. Robertson Stephens doesn’t have to pay for these services. Recommended Custodians have also agreed to pay for certain technology, research, marketing, and compliance consulting products and services on behalf of Robertson Stephens once the value of our clients’ assets in accounts at Recommended Custodians reach certain thresholds. The fact that Robertson Stephens receives these benefits from Recommended Custodians is an incentive for Robertson Stephens to recommend them as custodians/brokers rather than making such decisions based exclusively on clients’ interest in receiving the best value in custody services and the most favorable execution of their transactions. This is a conflict of interest. Robertson Stephens believes, however, that taken in the aggregate its recommendation of Recommended Custodians as custodians and brokers is in the best interests of its clients. This recommendation is primarily supported by the scope, quality, and price of Recommended Custodians’ services (see “How we select brokers/ custodians”) and not the services that benefit only Robertson Stephens. 

Order Aggregation and Allocation 

Although each client’s portfolio is managed individually, RSWM will sometimes aggregate purchase or sell orders in the same security for multiple clients. Orders are aggregated to take advantage of volume discounts, improve trade execution quality or realize other potential cost savings. Robertson Stephens will aggregate orders when possible and when appropriate for clients. Trades from aggregated orders will be allocated to participating clients at the same average price per unit as all other transaction costs shared on a pro-rata basis. Robertson Stephens allows de minimis deviations with respect to allocation determinations in order to place round lots in advisory client accounts. No advisory account will be favored over any other account. 

Directed Brokerage 

Robertson Stephens does not allow directed brokerage accounts. 

Item 13 Review of Accounts  

Advisors typically review client accounts on at least an annual basis or as client personal, market or economic events warrant. 

Robertson Stephens reports include account values and performance information in comparison to appropriate benchmarks as well as other customized information based on clients’ needs. These reports are typically sent quarterly, or upon client request. Factors triggering more frequent reviews include, but are not limited to, material changes to clients’ individual circumstances, market, political or economic circumstances, or changes in management of sub-advisers or money managers. 

Clients will be kept fully informed about their investment activity by receiving copies of transaction confirmations and monthly or quarterly statements from brokerage firms, mutual fund companies, custodial broker-dealer, and/or third-party money managers and sub-advisers, as applicable. 

Item 14 Client Referrals and Other Compensation  

Robertson Stephens compensates independent persons or firms ("Promoters"), for introducing clients to Robertson Stephens in compliance with Rule 206(4)-1 under the Investment Advisers Act of 1940, as such rule may be amended or supplemented. The compensation paid to Promoters will not affect the fees clients pay to Robertson Stephens, and the arrangements are fully disclosed to clients in writing. 

Schwab has granted Robertson Stephens funds to be used towards compliance and technology or other services that benefit the firm. These funds, which are limited, are contingent on reaching an asset goal on Schwab's platform. This represents a conflict of interest as we have an incentive to maintain assets at Schwab. Clients may choose to custody their assets at other custodians. 

Fidelity has granted Robertson Stephens funds to be used toward client termination fees as well as other transition expenses. These funds, which are limited, are only available for a certain period of time. This represents a conflict of interest as we have an incentive to maintain assets at Fidelity. Clients may choose to custody their assets at other custodians. 

Robertson Stephens receives an economic benefit from Recommended Custodians in the form of the support products and services they make available to Robertson Stephens and other independent investment advisors whose clients maintain their accounts at Recommended Custodians. In addition, Recommended Custodians have also agreed to pay for certain products and services for which Robertson Stephens would otherwise have to pay once the value of Robertson Stephens’ clients’ assets in accounts at Recommended Custodians reach a certain size. Clients do not pay more for assets maintained at Recommended Custodians as a result of these arrangements. However, Robertson Stephens benefits from the arrangement because the cost of these services would otherwise be borne directly by Robertson Stephens. Clients should consider these conflicts of interest when selecting a custodian. The products and services provided by Recommended Custodians, how they benefit Robertson Stephens, and the related conflicts of interest are described above (see Item 12 Brokerage Practices). 

Item 15 Custody  

Robertson Stephens does not intend to maintain physical possession of client assets or securities in our separately managed accounts. Assets in client accounts will be held in custody by an independent qualified custodian. Clients typically authorize Robertson Stephens to directly charge advisory fees to their custodial accounts. Due to the nature of this "direct debit" billing procedure, as well as permitting clients to issue standing letters of authorization, Robertson Stephens will be considered to have custody of client assets as defined by regulation. 

Standing Letters of Authorization ("SLOAs") - Our firm is deemed to have custody of client funds or securities when clients have SLOAs with their custodians to move money from the clients’ accounts to third parties and, under the SLOAs, we are authorized to designate the amount or timing of the transfers. The SEC has set forth a set of standards intended to protect client assets in such situations, which we follow. We do not have a beneficial interest in any of the accounts of which we are deemed to have Custody because SLOAs are on file. 

At least quarterly, Clients will receive account statements directly from their custodian(s) which will include all account activity and holdings during the statement period. Clients should review the custodian statements promptly and carefully and compare them to the portfolio reports provided by Robertson Stephens. Clients should contact Robertson Stephens or the custodians directly if there are any discrepancies. 

Item 16 Investment Discretion  

Robertson Stephens provides investment advisory services on a discretionary or non-discretionary basis as stated in each client’s investment advisory agreement. Robertson Stephens may accept discretionary authority to make investment decisions for clients, subject to client directions and restrictions. 

Item 17 Voting Client Securities  

Generally, Robertson Stephens does not accept proxy-voting authority from clients. However, with approval from the Chief Compliance Officer, certain Advisors may accept proxy-voting authority from clients assigned to that Advisor, in which case this authority will be documented in those clients’ investment advisory agreements. Separately, certain third-party managers and sub-advisors recommended by Robertson Stephens may accept the authority to vote client proxies, as disclosed in the managers’ or sub-advisors’ Form ADV. Clients will receive their proxies or other solicitation materials directly from their custodian(s) or broker-dealer(s) unless directed to such managers or sub-advisors. Clients should contact their custodian, broker-dealer, manager or sub-advisor rather than Robertson Stephens with questions about a particular proxy solicitation. 

Item 18 Financial Information  

Our firm does not have any financial condition or impairment that would prevent us from meeting our contractual commitments to you. We do not take physical custody of client funds or securities, serve as trustee or signatory for client accounts, or require the prepayment of more than $1,200 in fees six or more months in advance. Therefore, we are not required to include a financial statement with this brochure. 

We have not filed a bankruptcy petition at any time in the past ten years.