Effective: February 11, 2026
By accessing or using this website (the “Site”) of Lapis Advisers, LP and its affiliates (collectively, “Lapis”), you hereby accept and agree to comply with these Terms and Conditions of Use. You acknowledge your understanding that these Terms and Conditions of Use constitute a binding agreement between you and Lapis (sometimes referred to as “we” or “us”) that governs your access and use of the Site, which includes any images, text, illustrations, designs, icons, photographs, programs, music clips, downloads, systems and methods of trading, video clips, graphics, user interfaces, visual interfaces, information, data, tools, products, written materials, services and other content (together, “Content”), including but not limited to the design, structure, selection, coordination, expression and arrangement of the Content available on or through the Site.
PLEASE READ THESE TERMS AND CONDITIONS OF USE CAREFULLY BEFORE USING THE SITE. EACH TIME YOU USE THE SITE, YOUR USE INDICATES YOUR FULL ACCEPTANCE OF AND AGREEMENT TO ABIDE BY THESE TERMS AND CONDITIONS IN CURRENT FORM. IF YOU DO NOT ACCEPT THE TERMS AND CONDITIONS STATED HEREIN, DO NOT USE THE SITE. IF YOU DO NOT AGREE TO THESE TERMS AND CONDITIONS OF USE, YOU AGREE THAT YOUR SOLE AND EXCLUSIVE REMEDY IS TO DISCONTINUE USING THE SITE.
YOUR COMPLIANCE WITH THESE TERMS AND CONDITIONS OF USE AND ALL OTHER RULES, PROCEDURES, POLICIES, TERMS AND CONDITIONS THAT GOVERN ALL OR ANY PORTION OF THE SITE IS A CONDITION TO YOUR RIGHT TO ACCESS THE SITE. YOUR BREACH OF ANY PROVISION OF THESE TERMS AND CONDITIONS OF USE OR OTHER RULES, PROCEDURES, POLICIES, TERMS AND CONDITIONS THAT GOVERN ALL OR ANY PORTION OF THE SITE WILL AUTOMATICALLY, WITHOUT THE REQUIREMENT OF NOTICE OR OTHER ACTION, REVOKE AND TERMINATE YOUR RIGHT TO ACCESS THE SITE AND YOU WILL BE FULLY LIABLE FOR CONVERSION, MISAPPROPRIATION, TRESPASS TO CHATTELS AND ALL OTHER CLAIMS AND CAUSES, REGARDLESS OF THE IDENTITY OF CLAIMANT OR INJURED PARTY, ARISING FROM OR RELATING TO YOUR CONTINUED USE OF THE SITE AFTER SUCH BREACH.
Lapis grants you a limited right to use the Site. Your right to use the Site is subject to your agreement to abide by these Terms and Conditions of Use in their entirety, as well as any other rules, procedures, policies, terms or conditions that govern all or any portion of the Site. At any time and for any reason Lapis may revoke your right to use all or any portion of the Site.
Lapis reserves the right to make changes to the Site and these Terms and Conditions of Use at any time without prior notice to you and without your consent. For this reason, each time you use the Site, you should visit and review the then-current Terms and Conditions of Use that apply to your use of the Site.
You may not violate or attempt to violate the security of the Site. Tampering with any portion of the Site, providing untruthful or inaccurate information, misrepresenting your identity, or conducting fraudulent activities on the Site, whether or not through the use of agents, are prohibited and constitute a breach of these Terms and Conditions of Use.
You are prohibited from violating or attempting to violate the security of the Site, including, without limitation, (a) accessing data not intended for you or logging onto a server or an account which you are not authorized to access; (b) disabling, removing, defeating, or avoiding any security device or system, including, without limitation, any password and login functionality used to authenticate users; (c) attempting to probe, scan or test the vulnerability of a system or network or to breach security or authentication measures without proper authorization; (d) attempting to interfere with service to any user, host or network, including, without limitation, via means of submitting a virus to the Site, overloading, “flooding,” “spamming,” “mailbombing” or “crashing;” (e) sending unsolicited email, including promotions and/or advertising of products or services; (f) forging any TCP/IP packet header or any part of the header information in any email or posting; (g) using or attempting to use any engine, software, tool, agent or other device or mechanism (including, without limitation, browsers, spiders, robots, avatars or intelligent agents) to navigate or search the Site other than the search engine and search agents available on the Site and other than generally available third party web browsers; (h) reverse engineering, decompiling or disassembling the underlying software; (i) removing any notices, warnings, labels, annotations or instructions from any portion of the Site or any related material, including, without limitation, any patent, trademark, copyright, or other proprietary notices or license provisions; or (j) otherwise invading the privacy of, obtaining the identity of, or obtaining any personal information about any user of the Site.
Any violations of system or network security, including attempts to intentionally access a computer without authorization or exceed your authorized access level, may result in civil and criminal charges, including but not limited to charges under the Computer Fraud and Abuse Act (18 U.S.C. §1030). Lapis may investigate occurrences that might involve such violations and may involve, and cooperate with, law enforcement authorities in prosecuting users who are involved in such violations. We may, without prior notice or warning of any kind, restrict or terminate the access of any and all users to the Site if we reasonably conclude that such restriction or termination is necessary to prevent, or prevent the further spread, of a virus, security breach or system malfunction.
You may download or copy Content only to the extent such download is expressly permitted in writing on the Site. No right, title or interest in any downloaded materials or software is transferred to you as a result of any such downloading or copying. You may not reproduce (except as noted above), publish, transmit, distribute, display, modify, create derivative works from, sell or participate in any sale of or exploit in any way, in whole or in part, any of the Content, the Site or any related software.
Nothing on the Site shall be interpreted as granting any license or right to use any image, trademark, trade dress, logo or service mark on the Site. Anything transmitted to the Site by you becomes Lapis’ property and may be used by us for any lawful purpose. Lapis reserves all rights with respect to copyright and trademark ownership of all material on the Site, and will enforce such rights to the full extent of the law.
Unless otherwise noted, all Contents are copyrights, trademarks, trade dress and/or other intellectual property owned, controlled or licensed by Lapis or by third parties who have licensed their materials to Lapis and are protected by U.S. and international copyright laws. The compilation of all Contents on the Site is the exclusive property of Lapis and is also protected by U.S. and international copyright laws.
We may collect certain aggregate and non-personal information when you visit the Site. We may collect this information through “cookie” technology. Cookies are bits of text that can be placed on your computer’s hard drive when you visit certain web sites. Cookies may enhance your online experience by saving your preferences while you are visiting a particular site. The “help” portion of the toolbar on most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Remember, though, without cookies, you may not be able to take full advantage of all of the Site features.
The information on this website is provided for informational purposes only. No Content or other material on the Site shall be used or considered as an offer to sell or a solicitation of any offer to buy the securities or services of Lapis or any other issuer. Offers can only be made where lawful under, and in compliance with, applicable law.
Lapis makes no representations that transactions, products or services discussed on the Site are available or appropriate for sale or use in all jurisdictions or by all investors. Those who access the Site do so at their own initiative and are responsible for compliance with local laws or regulations.
While Lapis uses reasonable efforts to obtain information from reliable sources, Lapis makes no representations or warranties as to the accuracy, reliability or completeness of any information or document at the Site obtained outside of Lapis. Certain information on the Site may contain forward-looking statements, which reflect our views with respect to, among other things, our operations and financial performance. Such forward-looking statements are subject to various risks and uncertainties and speak only as of the date on which they are made. Accordingly, there are or will be important factors that could cause actual outcomes or results to differ materially from this indicated in these statements. You can identify these forward-looking statements by the use of words such as “outlook,” “indicator,” “believe,” “expect,” “potential,” “continue,” “may,” “should,” “seek,” “approximately,” “predict,” “anticipate,” “optimistic,” “intend,” “plan,” “estimate,” “aim,” “will” or the negative version of these words or similar expressions. Lapis undertakes no obligation to update publicly or revise any information on the Site, whether as a result of new information, future developments or otherwise. Opinions and any other Contents at the Site are subject to change without notice.
Lapis is not utilizing the Site to provide investment or other advice, and no information or material at the Site is to be deemed a recommendation to buy or sell any securities or is to be relied upon for the purpose of making or communicating investment or other decisions. In addition, no information, Content or other materials contained on the Site should be construed or relied upon as investment, legal, accounting, tax or other professional advice or in connection with any offer or sale of securities. Any transactions listed on the Site are included as representative transactions and are not necessarily reflective of overall performance.
Lapis does not advise on the tax consequences of any investment.
Past performance is not indicative of future results; no representation is being made that any investment will or is likely to achieve profits or losses similar to those achieved in the past, or that significant losses will be avoided.
BY USING THE SITE, YOU EXPRESSLY AGREE THAT SUCH USE IS AT YOUR SOLE RISK. THE SITE AND RELATED SERVICES ARE PROVIDED ON AN “AS IS”, “AS AVAILABLE” AND “WITH ALL FAULTS” BASIS. NEITHER LAPIS NOR ANY OF ITS RESPECTIVE OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, THIRD-PARTY CONTENT PROVIDERS, DESIGNERS, CONTRACTORS, DISTRIBUTORS, MERCHANTS, SPONSORS, LICENSORS OR THE LIKE (COLLECTIVELY, “ASSOCIATES”) WARRANT THAT USE OF THE SITE OR RELATED SERVICES WILL BE UNINTERRUPTED OR ERROR-FREE. NEITHER LAPIS NOR ITS AFFILIATES WARRANT THE ACCURACY, INTEGRITY, COMPLETENESS, AVAILABILITY OR TIMELINESS OF THE CONTENT PROVIDED IN THE SITE OR THE MATERIALS OR SERVICES OFFERED IN THE SITE NOW OR IN THE FUTURE. LAPIS AND ITS AFFILIATES SPECIFICALLY DISCLAIM ALL WARRANTIES, WHETHER EXPRESSED OR IMPLIED, INCLUDING BUT NOT LIMITED TO WARRANTIES OF TITLE, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE OR NON-INFRINGEMENT OF THE SITE, INFORMATION ON THE SITE OR THE RESULTS OBTAINED FROM USE OF THE SITE OR RELATED SERVICES.
UNDER NO CIRCUMSTANCES WILL LAPIS OR ITS AFFILIATES BE LIABLE TO YOU OR ANYONE ELSE FOR ANY DIRECT, CONSEQUENTIAL, INCIDENTAL, SPECIAL, EXEMPLARY, PUNITIVE OR OTHER INDIRECT DAMAGES, INCLUDING BUT NOT LIMITED TO LOST PROFITS, TRADING LOSSES, UNAUTHORIZED ACCESS, SYSTEMS FAILURE, COMMUNICATIONS LINE FAILURE, INTERNET FAILURE OR DAMAGES THAT RESULT FROM USE OR LOSS OF USE OF THE SITE, CONTENT, INCONVENIENCE OR DELAY. THIS IS TRUE EVEN IF LAPIS HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES OR LOSSES.
Any Content downloaded or otherwise obtained through the Site is done at your own discretion and risk and you are solely responsible for any damage to your computer or other electronic system or loss of data that results from the download of any such Content. The foregoing limitation of liability will apply in any action, whether in contract, tort or any other claim, even if an authorized representative of Lapis has been advised of or should have knowledge of the possibility of such damages.
References on this Site to any names, marks, products or services of third parties who may or may not be affiliated with Lapis, or hypertext links to third party sites or information or Content provided by third parties, are provided solely as a convenience to you and do not in any way constitute or imply our endorsement, sponsorship or recommendation of the third party, its information, materials or services. We are not responsible for the practices or policies of such third parties, nor the Content of any third party sites, and do not make any representations regarding third party materials or services, or the Content or accuracy of any material on such third party sites. Nor have we independently verified the content of any such third party sites. If you decide to link to any such third party sites, you do so entirely at your own risk. You are advised to review the terms of use and privacy policies of any website that you visit.
The content on Lapis’ social media channels, including X, Instagram, LinkedIn, YouTube and Facebook provided as information only. It does not constitute an offer to sell any securities or the solicitation of an offer to purchase any securities. Lapis is not utilizing any such channels to provide investment or other advice, and no information or material on such channels is to be deemed a recommendation to buy or sell any securities or is to be relied upon for the purpose of making or communicating investment or other decisions. In addition, no information, Content or other materials contained on such channels should be construed or relied upon as investment, legal, accounting, tax or other professional advice or in connection with any offer or sale of securities. Any transactions listed on such channels are included as representative transactions and are not necessarily reflective of overall performance.
Lapis does not warrant the accuracy, completeness or usefulness of the information available on its social media channels. Lapis does not control and is not responsible for any third party content on such channels or on other third party sites that may be linked to by such channels. Such third party content or sites should not be presumed to reflect the view of Lapis or our staff. Lapis is not responsible for the ramifications of your use of such channels or such third party content or sites, or for any third party’s policies or practices regarding security, privacy, use or other matters.
Our name, brands and reputation may be misused by imposters and frauds publishing fake web sites and engaging in “phishing” scams seeking personal or confidential information.
When communicating with Lapis through digital media, please:
If you have any questions about the above, please contact Lapis using our Contact Us page.
These Terms and Conditions of Use are effective unless and until terminated by either you or Lapis. You may terminate these Terms and Conditions of Use at any time, provided that you discontinue any further use of the Site. We also may terminate these Terms and Conditions of Use, in our sole discretion, at any time and may do so immediately without notice, and accordingly deny you access to the Site. Upon any termination of these Terms and Conditions of Use by either you or us, you must promptly destroy all materials downloaded or otherwise obtained from the Site, as well as all copies of such materials, whether made under these Terms and Conditions of Use or otherwise.
As a condition of your use of the Site, you agree to indemnify and hold Lapis and its affiliates harmless from and against any and all claims, losses, liability, costs and expenses (including, but not limited, to attorney’s fees), as incurred, arising from your use of the Site or related services or from your violation of these Terms and Conditions of Use.
You represent and warrant that: (i) you have full authority and all rights necessary to enter into and fully perform all of your obligations pursuant to these Terms and Conditions of Use; (ii) you have not and you will not enter into any agreement or perform any act which might contravene the purposes and/or effects of these Terms and Conditions of Use; and (iii) you will not delete any Content.
Nothing contained in these Terms and Conditions of Use is intended to modify or amend any other written or oral agreement you may have with Lapis (including without limitation any subscription agreement, partnership agreement, separate managed account agreement, investment management agreement) (collectively, “Other Agreements”), if any, that may currently be in effect. In the event of any inconsistency between these Terms and Conditions of Use and any Other Agreement, the Other Agreement will govern. Some pages within the Site contain supplemental terms and conditions and additional disclosure and disclaimers, which are in addition to these Terms and Conditions of Use. In the event of a conflict, such supplemental terms and conditions and additional disclosures and disclaimers will govern for those sections or pages.
Funds and Accounts managed by Lapis Invest in Publicly Traded Securities
Funds and accounts managed by Lapis invests in publicly traded securities issued by or on behalf of companies and governmental agencies. As a result, Lapis does not want to receive material, non-public information about publicly traded companies or governmental agencies or their debt or equity securities. Lapis thus does not wish to receive material, non-public information or otherwise confidential information about a public company or security issuing governmental agency from any source.
Governing Law:
These Terms and Conditions of Use and any dispute, claim, or controversy arising out of or relating to these Terms and Conditions of Use or your use of the Site shall be governed by and construed in accordance with the laws of the State of Delaware, without regard to its conflict of laws principles.
Mandatory Arbitration:
Any dispute, claim, or controversy arising out of or relating to these Terms and Conditions of Use, the Site, or the breach, termination, enforcement, interpretation, or validity thereof, including the determination of the scope or applicability of this agreement to arbitrate, shall be resolved exclusively by final and binding arbitration.
Arbitration shall be administered by the American Arbitration Association under its Commercial Arbitration Rules then in effect. The arbitration shall be conducted before a single arbitrator unless the amount in controversy exceeds $5,000,000, in which case it shall be conducted before a panel of three arbitrators.
The seat and venue of arbitration shall be selected by Lapis, in its sole discretion, and may be located in the State of Delaware, the State of Colorado, or the State of New York. You irrevocably consent to such selection and waive any objection to venue, forum non conveniens, inconvenience, or similar doctrine with respect to the selected location.
Judgment on the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof.
Class Action Waiver:
To the fullest extent permitted by law, arbitration shall be conducted solely on an individual basis and not in a class, consolidated, collective, or representative action.
Equitable Relief:
Notwithstanding the foregoing, Lapis may seek injunctive or other equitable relief in any court of competent jurisdiction to protect its intellectual property, confidential information, or other proprietary rights, without the requirement of posting bond, proving irreparable harm, or satisfying any similar requirement.
Severability; No Waiver:
If any provision of these Terms and Conditions of Use is held to be unenforceable, such provision will be reformed only to the extent necessary to make it enforceable. The failure of Lapis to act with respect to a breach of these Terms and Conditions of Use by you or others does not constitute a waiver and will not limit Lapis’ rights with respect to such breach or any subsequent breaches.
Jurisdictional Issues:
Unless otherwise specified, the materials in or accessible through the Site are directed at residents of the United States, its territories, possessions and protectorates. The Site is controlled and operated by Lapis from its offices within the United States. Lapis makes no representation that materials in or accessible through the Site are appropriate or available for use in other locations or that access to them where their content is located is not illegal and prohibited. Those who choose to access the Site from other locations do so on their own initiative and are responsible for establishing the legality, usability and correctness of any information or materials under any or all jurisdictions and the compliance of that information or material with local laws if and to the extent local laws are applicable. You may not use or export the information or materials in violation of U.S. export laws and regulations. The information provided in or accessible through the Site is not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to law or regulation or which would subject Lapis to any registration or other requirement within such jurisdiction or country. Lapis reserves the right to limit access to the Site to any person, geographic region or jurisdiction. Investors who are not U.S. Residents should note that none of the funds or accounts managed or advised by Lapis are registered (or otherwise authorized for sale) in any jurisdictions other than the United States. Moreover, Lapis has no intention to register (or otherwise authorize) its funds for sale in any jurisdiction other than the United States. In particular, investors based in the European Union or European Economic Area should note that no application has been made (or will be made) pursuant to article 42 of EU Directive 2011/61 (AIFMD) in respect of any Lapis fund or account.
Environmental, Social and Governance (ESG) and Sustainability Disclosures
References on the Site to environmental, social, governance, sustainability, impact, responsible investment, or similar considerations (“ESG”) reflect Lapis’ current views, methodologies, frameworks, and internal policies as of the date indicated. Such views and methodologies are inherently subjective and may change at any time without notice.
ESG-related assessments and conclusions are based on a combination of quantitative and qualitative information, including third-party data, company disclosures, industry reports, and internally developed metrics. Such information may be incomplete, inaccurate, inconsistent, estimated, unaudited, or unavailable. Third-party ESG data providers may employ different standards, criteria, and methodologies, and there is no universal or legally binding definition of ESG or sustainability.
The weight, importance, and application of ESG considerations in any investment decision may vary across strategies, funds, accounts, time periods, and market conditions. The consideration of ESG factors does not necessarily result in improved investment performance, reduced risk, or alignment with any particular investor’s ethical, moral, or sustainability preferences.
Statements regarding ESG objectives, targets, initiatives, commitments, or outcomes may constitute forward-looking statements and are subject to uncertainty, evolving regulatory standards, changing market practices, and data limitations. There can be no assurance that any ESG-related objective will be achieved or that ESG considerations will be applied in any particular manner in any specific investment.
Nothing on the Site should be construed as a representation that any investment, portfolio company, or strategy satisfies any particular environmental, social, governance, sustainability, impact, or regulatory standard under any jurisdiction’s laws or regulatory framework.
Business Continuity Summary Disclosure Statement:
Lapis maintains a Business Continuity Program as a framework to prepare the firm in the event of extended service outages caused by factors beyond its control (e.g., hurricanes, natural disasters, man-made events) and to restore services to the widest extent possible in a minimum time frame. The Program outlines the steps the firm will take in the event of a crisis to:
If you cannot contact Lapis through normal channels, please check Lapis’ web site (www.lapisadvisers.com) for alternative means of communication.
Contact Information:
811 East 17th Avenue
Denver, Colorado 80218
Phone: 415-275-6280
Web Site: www.lapisadvisers.com
Lapis’ Business Continuity Program is subject to change at any time in Lapis’ sole discretion.
You may not use any automated means, including without limitation bots, spiders, scrapers, crawlers, data-mining tools, artificial intelligence systems, machine learning models, large language models, generative AI systems, algorithmic agents, or similar technologies, to access, extract, harvest, copy, monitor, index, frame, reproduce, republish, transmit, store, analyze, or otherwise use any portion of the Site or its content.
Without limiting the foregoing, you may not:
No license, express or implied, is granted to use the Site or its content for artificial intelligence, machine learning, automated decision-making, or data aggregation purposes. Any such use is strictly prohibited.
Lapis reserves the right to pursue all available legal and equitable remedies, including injunctive relief without the requirement of posting bond or proving irreparable harm, in the event of any violation of this provision.