Otus Capital Management Limited

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.A. or
11.B. of Form ADV.
Criminal
Check item(s) being responded to:
11.A(1)
11.A(2)
11.B(1)
11.B(2)

Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate
cases arising out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may
result in more than one affirmative answer to the items listed above.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
6709625
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
Casoni, roberto, Chiarion
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not
the organization was an investment-related business and your or the advisory affiliate's position, title, or relationship. 
2.
Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country,
Docket/Case number). 
ITALIAN CRIMINAL COURTS. THIS IS A THREE STAGED PROCESS: 1. CORTE PRIMO GRADO; 2. CORTE DI APPELLO; AND 3. CORTE DI CASSAZIONE
3.
Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY): 
09/28/2009
 Exact
 Explanation
If not exact, provide explanation:
IN JANUARY 2006 WHILST WORKING AT CITIGROUP LONDON, MR. CASONI WAS INVESTIGATED BY THE FSA FOR SELECTIVELY DISSEMINATING
RESEARCH TO CLIENTS PRIOR TO PUBLICATION. SUBSEQUENTLY IN SEPT 2008, CONSOB (ITALIAN REGULATOR) INVESTIGATED THE SAME
INCIDENT FOR THE RELEASE OF NON-PUBLIC INFORMATION.
B.
Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor,
(3) plea for each charge, and (4) product type if charge is investment-related). 
MR. CASONI WAS A LONDON BASED RESEARCH ANALYST AT CITIGROUP. HE WAS FINED £52,500 BY THE FINANCIAL SERVICES AUTHORITY "FSA"
FOR A BREACH OF PRINCIPAL 3 "FAILING TO OBSERVE PROPER STANDARDS OF MARKET CONDUCT" IN MARCH 2007. THE FSA REPORT ALSO
ADDED THAT IN REACHING THE DECISION, THE FSA TOOK INTO ACCOUNT THAT MR. CASONI DID NOT HAVE ANY INTENTION OF MANIPULATING
THE COMPANY'S SHARE PRICE IN MAKING THE DISCLOSURES NOR DID HE OBTAIN ANY FINANCIAL GAIN FROM HIS MISCONDUCT. IN SEPTEMBER
2008, CONSOB INVESTIGATED MR. CASONI AND IN AUG 2009 FOUND MR. CASONI GUILTY OF MARKET MISCONDUCT AND ISSUED A FINANCIAL
PENALTY. IN JULY 2011, CRIMINAL PROCEEDINGS RELATING TO THE SAME INCIDENT WERE LAUNCHED AGAINST MR. CASONI BY ITALY'S PUBLIC
PROSECUTOR WITH THE CASE PROCESS TO BE IN 3 PHASES.
C.
Did any of the Charge(s) within the Event involve a felony? 
 Yes
 No
D.
Current status of the Event? 
 Pending
 On Appeal
 Final
E.
Event Status Date (complete unless status is Pending) (MM/DD/YYYY): 

12/20/2011
 Exact
 Explanation
If not exact, provide explanation:
THE FSA RE-APPROVED MR. CASONI IN 2008 AS A CF30 (CUSTOMER FUNCTION) FINDING HIM FIT AND PROPER TO ENABLE MR. CASONI TO
CONDUCT PORTFOLIO MANAGEMENT ACTIVITIES. IN DEC 2011 PHASE 1 OF ITALY'S PUBLICO MINISTERO CRIMINAL PROCEEDINGS FOUND MR.
CASONI TO BE GUILTY OF THE ABUSE OF PRIVILEGED INFORMATION. ON 16TH JAN 2013, PHASE 2 WAS CONCLUDED AND THE PHASE 1 PENALTY
UPHELD. DUE TO AN APPEAL AND OBJECTION, PHASE 3 IS SET TO BE CONCLUDED IN QUARTER 4 2016.
4.
Disposition Disclosure Detail: 
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if
sentence - suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid. 
PRIOR TO JOINING OCM IN MAY 2007, ROBERTO CASONI WAS FINED BY THE FINANCIAL SERVICES AUTHORITY "FSA" FOR A BREACH OF PRINCIPAL 3 -
"FAILING TO OBSERVE PROPER STANDARDS OF MARKET CONDUCT" IN THE FIRST EVER CASE CONCERNING THE SELECTIVE RELEASE OF RESEARCH
PRIOR TO OFFICIAL PUBLICATION. FURTHERMORE, THE ITALIAN REGULATORY AUTHORITY - CONSOB - CARRIED OUT ITS OWN INVESTIGATION OF THE
SAME CASE AND FOUND ROBERTO GUILTY OF MARKET MISCONDUCT IN 2009. AS A DIRECT RESULT OF THIS CONSOB FINDING, CRIMINAL
PROCEEDINGS WERE BROUGHT AGAINST ROBERTO AND THIS CASE FINALLY CONCLUDED - AFTER ALMOST 11 YEARS - WHEN ROBERTO'S GUILTY
VERDICT WAS UPHELD - IN MARCH 2019. CASE NOW CLOSED
5.
Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was
the subject of the charge(s) occurred. (Your response must fit within the space provided.) 
IN MARCH 2007 THE FSA ISSUED A FINAL NOTICE REPORT AGAINST MR. CASONI. THE MISCONDUCT TOOK PLACE IN JANUARY 2006 WHEN MR. CASONI
WAS A LONDON BASED RESEARCH ANALYST AT CITIGROUP. THE FSA CONCLUDED THAT MR. CASONI DISSEMINATED INFORMATION TO CERTAIN
CLIENTS AHEAD OF PUBLICATION ALLOWING THOSE CLIENTS OPPORTUNITY'S TO PRE-EMPT THE CONCLUSIONS OF THE PUBLISHED RESEARCH AND
THEREBY POTENTIALLY INFLUENCING THEIR INVESTMENT DECISIONS AHEAD OF THE MARKET. IN AUGUST 2008 MR. CASONI RECEIVED NOTICE OF THE
INVESTIGATION FROM CONSOB REGARDING THE SAME CASE.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D.,
11.E., 11.F. or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the
same event. If an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item
11.D(4), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any
event listed in Item 11 that occurred more than ten years ago.

This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
SWEDISH REGULATOR - FINANSINSPEKTIONEN
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
FINE
3.
Date Initiated (MM/DD/YYYY): 
12/21/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
SWEDISH SECURITY STRAX
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
ON THE 21 DECEMBER 2018, OCM RECEIVED NOTIFICATION FROM THE SWEDISH REGULATOR - FINANSINSPEKTIONEN - THAT IT WAS ISSUING THE
FIRM WITH A PENALTY NOTICE OF SEK 240,000 (APPROX £20,500) RELATING TO AN ERROR IN A DISCLOSURE NOTIFICATION MADE BY OCM IN THE
SWEDISH SECURITY STRAX AFTER WE WENT ABOVE THE 5% LONG DISCLOSURE THRESHOLD. THIS DISCLOSURE WAS MADE ON TIME (NEXT BUSINESS
DAY) BUT THE NOTIFICATION SUBMITTED CONTAINED A DATE FIELD ERROR. THIS PENALTY NOTICE WAS APPEALED BY OCM BUT THE APPEAL WAS
ULTIMATELY REJECTED BY FÖRVALTNINGSRÄTTEN (THE SWEDISH ADMINISTRATIVE COURT). THIS PENALTY FINE WAS PAID IN SEPTEMBER 2019 AND
WAS BORNE BY OCM AND NOT BY ANY OF ITS CLIENT FUNDS OR MANAGED ACCOUNTS.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Settled
11. Resolution Date (MM/DD/YYYY):
03/19/2019
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 25,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
ON THE 21 DECEMBER 2018, OCM RECEIVED NOTIFICATION FROM THE SWEDISH REGULATOR - FINANSINSPEKTIONEN - THAT IT WAS ISSUING

THE FIRM WITH A PENALTY NOTICE OF SEK 240,000 (PPROX.. £20,500) RELATING TO AN ERROR IN A DISCLOSURE NOTIFICATION MADE BY OCM
IN THE SWEDISH SECURITY STRAX AFTER WE WENT ABOVE THE 5% LONG DISCLOSURE THRESHOLD. THIS DISCLOSURE WAS MADE ON TIME
(NEXT BUSINESS DAY) BUT THE NOTIFICATION SUBMITTED CONTAINED A DATE FIELD ERROR. THIS PENALTY NOTICE WAS APPEALED BY OCM BUT
THE APPEAL WAS ULTIMATELY REJECTED BY FÖRVALTNINGSRÄTTEN (THE SWEDISH ADMINISTRATIVE COURT). THIS PENALTY FINE WAS PAID IN
SEPTEMBER 2019 AND WAS BORNE BY OCM AND NOT BY ANY OF ITS CLIENT FUNDS OR MANAGED ACCOUNTS.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived: 
ISSUING THE FIRM WITH A PENALTY NOTICE OF SEK 240,000 (APPROX £20,500)
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response
must fit within the space provided).
ON THE 21 DECEMBER 2018, OCM RECEIVED NOTIFICATION FROM THE SWEDISH REGULATOR - FINANSINSPEKTIONEN - THAT IT WAS ISSUING THE
FIRM WITH A PENALTY NOTICE OF SEK 240,000 (PPROX.. £20,500) RELATING TO AN ERROR IN A DISCLOSURE NOTIFICATION MADE BY OCM IN THE
SWEDISH SECURITY STRAX AFTER WE WENT ABOVE THE 5% LONG DISCLOSURE THRESHOLD. THIS DISCLOSURE WAS MADE ON TIME (NEXT BUSINESS
DAY) BUT THE NOTIFICATION SUBMITTED CONTAINED A DATE FIELD ERROR. THIS PENALTY NOTICE WAS APPEALED BY OCM BUT THE APPEAL WAS
ULTIMATELY REJECTED BY FÖRVALTNINGSRÄTTEN (THE SWEDISH ADMINISTRATIVE COURT). THIS PENALTY FINE WAS PAID IN SEPTEMBER 2019 AND
WAS BORNE BY OCM AND NOT BY ANY OF ITS CLIENT FUNDS OR MANAGED ACCOUNTS.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Item 11.H. of Part
1A or Item 2.F. of Part 1B of Form ADV.
Civil Judicial
Check Part 1A item(s) being responded to:
11.H(1)(a)
11.H(1)(b)
11.H(1)(c)
11.H(2)
Check Part 1B item(s) being responded to:
2.F(1)
2.F(2)
2.F(3)
2.F(4)
2.F(5)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File
with a completed Execution Page.
One event may result in more than one affirmative answer to Item 11.H. of Part 1A or Item 2.F. of Part 1B. Use only one DRP to report details related to the
same event. Unrelated civil judicial actions must be reported on separate DRPs.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
6709625
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
Casoni, roberto, Chiarion
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is
registered or applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the
adviser's or advisory affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.H.
(1)(a), and only if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any

event listed in Item 11 that occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the
circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to
the IARD or CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Court Action initiated by: (Name of regulator, foreign financial regulatory authority, SRO, commodities exchange, agency, firm, private plaintiff, etc.) 
COMMISSIONE NAZIONALE PER LE SOCIETÀ E LA BORSA (ITALY) AND ITALY'S PUBLIC MINISTERO
2.
Principal Relief Sought:
Civil Penalty(ies)/Fine(s)
Other Relief Sought: 
3.
Filing Date of Court Action (MM/DD/YYYY):
07/07/2011
 Exact
 Explanation
If not exact, provide explanation:
CONSOB - COMMENCED ITS OWN INVESTIGATION IN SEPTEMBER 2008 AND IN AUGUST 2009 CONSOB PUBLISHED ITS FINDINGS AND ISSUED MR.
CASONI A FINANCIAL PENALTY. MR. CASONI LAUNCHED AN APPEAL AGAINST CONSON WHICH WAS REJECTED BY THE COURT DI APPELLO ON 7TH JULY
2011. AT THE SAME TIME OF THE APPEAL BEING HEARD, CRIMINAL PROCEEDINGS RELATING TO THE SAME INCIDENT, WERE LAUNCHED AGAINST MR.
CASONI BY ITALY'S PUBLICO MINISTERO.
4.
Principal Product Type:
Equity Listed (Common & Preferred Stock)
Other Product Types: 
5.
Formal Action was brought in (include name of Federal, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
Number): 
ITALY'S PUBBLICO MINISTERO AND COURT DI CASSAZIONE IN ROME, ITALY
6.
Advisory Affiliate Employing Firm when activity occurred which led to the civil judicial action (if applicable): 
CITIGROUP GLOBAL MARKETS LIMITED
7.
Describe the allegations related to this civil action (your response must fit within the space provided): 
DISCLOSURE OF NON-PUBLIC INFORMATION. DISSEMINATING RESEARCH TO CLIENTS PRIOR TO PUBLICATION.
8.
Current Status? 
 Pending
 On Appeal
 Final
9.
If on appeal, action appealed to (provide name of court) and Date Appeal Filed (MM/DD/YYYY): 
10. If pending, date notice/process was served (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 14 only.
11. How was matter resolved:
Settled
12. Resolution Date (MM/DD/YYYY): 
03/19/2019
 Exact
 Explanation
If not exact, provide explanation:
13. Resolution Detail:
A.  Were any of the following Sanctions Ordered or Relief Granted(check appropriate items)?
Monetary/Fine Amount: $ 111,533.00
Revocation/Expulsion/Denial
Disgorgement/Restitution
Censure
Cease and Desist/Injunction
Bar
Suspension

B.
Other Sanctions:
N/A
C.
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal,
Financial Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to
requalify/retrain, type of exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution,
disgorgement, or monetary compensation, provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion
of penalty was waived:
N/A
14. Provide a brief summary of circumstances related to the action(s), allegation(s), disposition(s) and/or finding(s) disclosed above (your response must
fit within the space provided). 
IN MAY 2007, MR CASONI WAS FINED BY THE FINANCIAL SERVICES AUTHORITY "FSA" FOR A BREACH OF PRINCIPAL 3 "FAILING TO OBSERVE PROPER
STANDARDS OF MARKET CONDUCT". IN AUGUST 2008, MR. CASONI RECEIVED NOTICE FROM CONSOB - THE ITALIAN REGULATOR - WHO CARRIED OUT
ITS OWN INVESTIGATION INTO THE SAME CASE AND ITALY'S PUBLIC PROSECUTOR LAUNCHED CRIMINAL PROCEEDINGS IN SEPTEMBER 2009.