Investment adviser · CRD 129683

ZEPHYR MANAGEMENT, L.P.

Investment adviser filing (IA)

NEW YORK, NY, United States · Form ADV filed Mar 17, 2026

Regulatory AUM: $256M
Client accounts: 34
Employees: 22
Advisory professionals: 13

Who they report serving

Form ADV · Item 5.D

Client types and their share of reported regulatory assets.

Client type	Clients	Regulatory assets	Share of AUM
Pooled investment vehicles	30	$243,653,567	95.1%
Other clients	Fewer than 5	$11,977,500	4.7%
High-net-worth individuals	Fewer than 5	$673,294	0.3%

Filing source

Form ADV 2056253 · Mar 17, 2026 · Item 5.D

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

Private funds & service providers

32 Private funds

The count excludes feeder funds. Funds in the latest filing appear first, ordered by reported gross assets. Earlier funds retain their last reported values.

ZEPHYR PEACOCK INDIA GROWTH FUNDPrivate Equity Fund · Last reported Mar 17, 2026$77.6MGross asset value

Feeder funds

ZEPHYR PEACOCK INDIA GROWTH FUND LIMITED
ZEPHYR PEACOCK INDIA GROWTH FUND U.S., L.P.

Fund administrator VISTRA ITCL (INDIA) LIMITED MUMBAI, India Investor statements: No (provided to no investors) Related to adviser: No

Auditor S.R. BATLIBOI & ASSOCIATES LLP BANGALORE, India

Custodian AXIS BANK LIMITED MUMBAI, India Related to adviser: No

Custodian ICICI BANK LIMITED BANGALORE, India Related to adviser: No

Provider details

Annual audit: Yes
Prime brokers: No
Custodians: Yes
Administrator other than the adviser: Yes
External marketing: No

S.R. BATLIBOI & ASSOCIATES LLP
PCAOB 1485

Fund details & source

Fund ID: 805-1536268805
Reported beneficial owners: 76
Minimum commitment: $140K

Form ADV 2056253 · Mar 17, 2026 · Schedule D 7.B.(1)

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

ZEPHYR PEACOCK INDIA GROWTH FUND IIPrivate Equity Fund · Last reported Mar 17, 2026$20.2MGross asset value

Feeder funds

ZEPHYR PEACOCK INDIA GROWTH FUND II U.S., L.P.
ZEPHYR PEACOCK INDIA GROWTH FUND LIMITED
ZEPHYR PEACOCK INDIA GROWTH FUND U.S., L.P.

Fund administrator VISTRA ITCL (INDIA) LIMITED MUMBAI, India Investor statements: No (provided to no investors) Related to adviser: No

Auditor S.R. BATLIBOI & ASSOCIATES LLP BANGALORE, India

Custodian AXIS BANK LIMITED MUMBAI, India Related to adviser: No

Custodian ICICI BANK LIMITED BANGALORE, India Related to adviser: No

Marketer ACEANA GROUP LLC KEY BISCAYNE, Florida, United States Related to adviser: No

Provider details

Annual audit: Yes
Prime brokers: No
Custodians: Yes
Administrator other than the adviser: Yes
External marketing: Yes

S.R. BATLIBOI & ASSOCIATES LLP
PCAOB 1485

Fund details & source

Fund ID: 805-9563819585
Reported beneficial owners: 45
Minimum commitment: $100K

Form ADV 2056253 · Mar 17, 2026 · Schedule D 7.B.(1)

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

ZEPHYR MANTRA LLCPrivate Equity Fund · Last reported Mar 17, 2026$19.7MGross asset value

Custodian FIDUCIARY TRUST COMPANY BOSTON, Massachusetts, United States Related to adviser: No

Provider details

Annual audit: No
Prime brokers: No
Custodians: Yes
Administrator other than the adviser: No
External marketing: No

FIDUCIARY TRUST COMPANY
LEI 254900HQ4FOE2DTMJN14

Fund details & source

Fund ID: 805-6727046523
Reported beneficial owners: 1
Minimum commitment: $1M

Form ADV 2056253 · Mar 17, 2026 · Schedule D 7.B.(1)

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

ZW AGGRESSIVE FUNDHedge Fund · Last reported Mar 17, 2026$16.6MGross asset value

Fund administrator SS&C FUND SERVICES (BERMUDA), LTD. HAMILTON, Bermuda Investor statements: Yes (provided to all investors) Related to adviser: No

Auditor GRANT THORNTON IRELAND DUBLIN, Ireland

Custodian JP MORGAN CHASE BANK, N.A. NEW YORK, New York, United States Related to adviser: No

Custodian THE NORTHERN TRUST COMPANY CHICAGO, Illinois, United States Related to adviser: No

Marketer HDFC TRU MUMBAI, India Related to adviser: No

Marketer WATERFIELD ADVISORS PRIVATE LIMITED MUMBAI, India Related to adviser: No

Provider details

Annual audit: Yes
Prime brokers: No
Custodians: Yes
Administrator other than the adviser: Yes
External marketing: Yes

GRANT THORNTON IRELAND
PCAOB 1402

JP MORGAN CHASE BANK, N.A.
LEI 7H6GLXDRUGQFU57RNE97

Fund details & source

Fund ID: 805-5021171758
Reported beneficial owners: 58
Minimum commitment: $25K

Form ADV 2056253 · Mar 17, 2026 · Schedule D 7.B.(1)

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

ZEPHYR PEACOCK INDIA FUND III LIMITEDPrivate Equity Fund · Last reported Mar 17, 2026$16.3MGross asset value

Fund administrator APEX FINANCIAL SERVICES (MAURITIUS) LTD. EBENE, Mauritius Investor statements: No (provided to no investors) Related to adviser: No

Auditor MSK & ASSOCIATES EBENE, Mauritius

Custodian AFRASIA BANK LIMITED PORT LOUIS, Mauritius Related to adviser: No

Custodian KOTAK MAHINDRA BANK LIMITED MUMBAI, India Related to adviser: No

Provider details

Annual audit: Yes
Prime brokers: No
Custodians: Yes
Administrator other than the adviser: Yes
External marketing: No

MSK & ASSOCIATES
PCAOB 7045

Fund details & source

Fund ID: 805-3678057451
Reported beneficial owners: 60
Minimum commitment: $100K
Form D file number: 021-176142

Form ADV 2056253 · Mar 17, 2026 · Schedule D 7.B.(1)

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

ZW CONSERVATIVE FUNDHedge Fund · Last reported Mar 17, 2026$15.1MGross asset value

Fund administrator SS&C FUND SERVICES (BERMUDA), LTD. HAMILTON, Bermuda Investor statements: Yes (provided to all investors) Related to adviser: No

Auditor GRANT THORNTON IRELAND DUBLIN, Ireland

Custodian JP MORGAN CHASE BANK, N.A. NEW YORK, New York, United States Related to adviser: No

Custodian THE NORTHERN TRUST COMPANY CHICAGO, Illinois, United States Related to adviser: No

Marketer HDFC TRU MUMBAI, India Related to adviser: No

Marketer WATERFIELD ADVISORS PRIVATE LIMITED MUMBAI, India Related to adviser: No

Provider details

Annual audit: Yes
Prime brokers: No
Custodians: Yes
Administrator other than the adviser: Yes
External marketing: Yes

GRANT THORNTON IRELAND
PCAOB 1402

JP MORGAN CHASE BANK, N.A.
LEI 7H6GLXDRUGQFU57RNE97

Fund details & source

Fund ID: 805-4882160501
Reported beneficial owners: 83
Minimum commitment: $25K

Form ADV 2056253 · Mar 17, 2026 · Schedule D 7.B.(1)

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

ZW ALL EQUITIES FUNDHedge Fund · Last reported Mar 17, 2026$12.7MGross asset value

Fund administrator SS&C FUND SERVICES (BERMUDA), LTD. HAMILTON, Bermuda Investor statements: Yes (provided to all investors) Related to adviser: No

Auditor GRANT THORNTON IRELAND DUBLIN, Ireland

Custodian JP MORGAN CHASE BANK, N.A. NEW YORK, New York, United States Related to adviser: No

Custodian THE NORTHERN TRUST COMPANY CHICAGO, Illinois, United States Related to adviser: No

Marketer HDFC TRU MUMBAI, India Related to adviser: No

Marketer WATERFIELD ADVISORS PRIVATE LIMITED MUMBAI, India Related to adviser: No

Provider details

Annual audit: Yes
Prime brokers: No
Custodians: Yes
Administrator other than the adviser: Yes
External marketing: Yes

GRANT THORNTON IRELAND
PCAOB 1402

JP MORGAN CHASE BANK, N.A.
LEI 7H6GLXDRUGQFU57RNE97

Fund details & source

Fund ID: 805-4206476164
Reported beneficial owners: 65
Minimum commitment: $25K

Form ADV 2056253 · Mar 17, 2026 · Schedule D 7.B.(1)

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.

Services & filing details

Most recent filing: Mar 17, 2026. View historical filings

Reported services

Individual portfolio management · Pooled investment vehicle management

Compensation

Percentage of assets · Performance-based

Principal office

12 EAST 49TH STREET, 41ST FLOOR
NEW YORK, NY, 10017, United States

CRD 129683

Filing source

Form ADV 2056253 · Mar 17, 2026 · Items 1 & 5

Official IAPD profile (latest public filing). Values are the most recently reported in our imported data; the public profile may show a newer filing.