SPRUCEGROVE INVESTMENT MANAGEMENT LTD

CRD 106355File 801-45884

APPROVED

Retail clients

Custody

Filing as of Apr 9, 2026

Feed vintage Aug 17, 2026

Regulatory AUM

$11.53B

Top 10% of cohort (national)

Discretionary AUM

$11.53B

Clients

34 accounts

Employees

Identity & registration

ADV Item 1

Organization form: Corporation
Firm type: Registered
SEC region: HQ
Registration date: Mar 15, 1994
Principal office: 181 UNIVERSITY AVENUE, SUITE 1300, TORONTO, ONTARIO, M5H 3M7
Phone: 416-363-5854
Website: HTTPS://WWW.SPRUCEGROVE.COM

Assets & accounts

ADV Item 5F

Total regulatory AUM: $11.53B
Discretionary AUM: $11.53B
Non-discretionary AUM: $0
Discretionary accounts: 34
Non-discretionary accounts: 0
Total accounts: 34
AUM per client: $240.3M

Clients by type

ADV Item 5D

Client type	Clients	AUM
Investment companies	1	$3.75B
Charitable organizations	Fewer than 5	$669.5M
High net worth individuals	12	$30.1M
Pooled investment vehicles	35	$3.21B
Pension and profit sharing plans	Fewer than 5	$104.9M
State or municipal government entities	Fewer than 5	$3.77B

Compensation & activities

ADV Items 5E, 5G

Compensation

Performance-based fees
A percentage of assets under your management

Advisory activities

Portfolio management for businesses
Portfolio management for investment companies
Portfolio management for pooled investment vehicles

Custody

ADV Item 9

Firm Custody Cash: No
Firm Custody Assets: No
Firm Custody Clients: No
Firm Custody Securities: No
Related Person Custody Cash: Yes
Related Person Custody Assets: No
Related Person Custody Clients: No
Related Person Custody Securities: Yes

Disclosure events

ADV Item 11

This firm answered no to every Item 11 disclosure question in this filing.

Filed changes

Date	Field	From	To
Aug 17, 2026	Custody	false	true
Aug 12, 2026	Registration	—	APPROVED

Every value above is reproduced from this firm's Form ADV filing. Fields the firm left blank are shown as “Not reported” rather than filled in from other sources.