UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM N-CSR

CERTIFIED SHAREHOLDER REPORT OF REGISTERED MANAGEMENT

INVESTMENT COMPANIES

Investment Company Act file number 811-22920

The Advisors’ Inner Circle Fund III

(Exact name of registrant as specified in charter)

SEI Investments

One Freedom Valley Drive

Oaks, PA 19456

(Address of principal executive offices) (Zip code)

SEI Investments

One Freedom Valley Drive

Oaks, PA 19456

(Name and address of agent for service)

Registrant’s telephone number, including area code: (877) 446-3863

Date of fiscal year end: October 31, 2019

Date of reporting period: October 31, 2019

Item 1. Reports to Stockholders.

A copy of the report transmitted to stockholders pursuant to Rule 30e-1 under the Investment Company Act or 1940, as amended (the “Act”) (17 CFR § 270.30e-1), is attached hereto.

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

TABLE OF CONTENTS

Shareholders’ Letters	1
Schedules of Investments	9
Statements of Assets and Liabilities	17
Statements of Operations	19
Statements of Changes in Net Assets	21
Financial Highlights	25
Notes to Financial Statements	29
Report of Independent Registered Public Accounting Firm	43
Disclosure of Fund Expenses	45
Trustees and Officers of the Advisors’ Inner Circle Fund III	48
Approval of Investment Advisory Agreement	54
Notice to Shareholders	58

The Funds file their complete schedules of investments with the Securities and Exchange Commission (“SEC”) for the first and third quarters of each fiscal year on Form N-Q or as an exhibit to its reports on Form N-PORT within sixty days after period end. The Funds’ Form N-Q and Form N-PORT reports are available on the SEC’s website at http://www.sec.gov, and may be reviewed and copied at the SEC’s Public Reference Room in Washington, DC. Information on the operation of the Public Reference Room may be obtained by calling 1-800-SEC-0330.

A description of the policies and procedures that the Funds use to determine how to vote proxies relating to Fund securities, as well as information relating to how a Fund voted proxies relating to fund securities during the most recent 12-month period ended June 30, is available (i) without charge, upon request, by calling 1-844-IAM-USA1; and (ii) on the SEC’s website at http://www.sec.gov.

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC GLOBAL FRANCHISE FUND OCTOBER 31, 2019 (Unaudited)

Investec Global Franchise Fund - Annual Review - October 31, 2018 to October 31, 2019

Market Background

The last 12 months have been characterized by contrasting periods in global equity markets. The final quarter of 2018 saw the MSCI ACWI record the largest dollar-denominated quarterly drawdown since 2011. This reversed almost completely in the first quarter of 2019. The US Federal Reserve’s (Fed’s) decision to raise interest rates early in January set in train a strongly positive environment for the vast majority of markets over 2019 to end-October. However, the rally has been interspersed with two periods of turbulence, in May and August (through which the portfolio offered good drawdown protection), caused by escalations of the trade spat between the US and China and concerns around slowing global growth.

Of perhaps greater impact on the Fund was the market rotation in September, sparked by central banks’ responses to expectations of slowing growth. The shift towards more cyclical equities was significant, on hopes for a rebound in cyclical growth underpinned by easier monetary policy. This rotation meant high-quality sectors such as IT and consumer staples – held in the portfolio – lost ground to more cyclical sectors such as banks, materials, energy and industrials.

Fund outlook and performance

The Fund aims to achieve long-term outperformance through investing in a concentrated number of high-quality, attractively valued, well-run companies that have strong balance sheets and dominant, hard-to-replicate market positioning. We believe that the companies held in the portfolio will deliver positive long-term returns overall, while also offering some resilience during downturns in global economic cycles.

The Fund outperformed the MSCI ACWI NR Index over the 12 months to the end of October 2019.

Stock picking within financials and an overweight in IT were the main drivers of relative outperformance. Within financials, the key contributors were credit rating agencies Moody’s and S&P Global. The strong recovery in capital markets this year has encouraged large corporates to issue higher levels of debt – to which both agencies assign ratings, which is their primary revenue stream. Within IT, the main outperformers included global payment provider Visa, software company Microsoft, online internet domain registration company Verisign, and lithography

1

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC GLOBAL FRANCHISE FUND OCTOBER 31, 2019 (Unaudited)

equipment manufacturer ASML. Visa benefited from higher revenues and transaction volumes, while Microsoft has continued to scale its cloud offering, Azure. Shares in ASML reacted to positive orders for the company’s new EUV lithography tools, which are in the early stages broad market adoption among semiconductor manufacturers. Verisign has benefited from a steady increase in domain-name registrations resulting in consistently growing revenues.

Not holding companies in capital-intensive sectors such as energy and materials added to returns, as did holding a zero-weighting to banks.

Our exposure to consumer staples was the primary drag on relative returns. While some holdings sold off as part of the rotation, idiosyncratic developments affected certain others. Consumer goods company Reckitt Benckiser reported issues in its US consumer health and Chinese infant formula businesses, while US pharmaceutical company Johnson & Johnson was impacted by the US opioid rulings.

Tobacco companies Imperial Brands and Philip Morris International also detracted due to weaker trading updates. We are aware of the challenges and headwinds in US tobacco, particularly in vaping. However, we still believe that the vape category will grow overall, and that closed systems will win out over open systems. A lot of disruption is taking place in the tobacco industry, which is not only creating challenges and risks to established business models but also opportunities. We continue to monitor the situation and our portfolio positioning closely.

Outlook

The significant equity drawdown in late 2018 and the subsequent strong recovery this year to date (although this has slowed more recently) serve as stark reminders of where we are in the current market cycle. Equity markets are starting to look more vulnerable than they have for some time, especially given that valuations have recovered well year to date. A long list of factors are weighing on investor confidence, including slowing global economic activity, trade tensions between China and the US, and weakened consumer and business confidence in Europe. Against this backdrop, investors have to balance the potential for the global economy to benefit from more patient monetary normalization by the US Federal Reserve and the European Central Bank. Central banks’ more dovish tone has proven a tailwind for capital markets year to date.

2

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC GLOBAL FRANCHISE FUND OCTOBER 31, 2019 (Unaudited)

With an increased likelihood of additional rate cuts in the US this year, yields on 10-year US Treasuries have fallen to lows not seen since mid-2016. Additionally, political risks have increased, while debt levels remain elevated across governments, corporates and households. We believe that in the face of these headwinds and exogenous risks, portfolio resilience is now more important than ever. As we saw in the fourth quarter of 2018, focusing on structural rather than cyclical growth is key to defensive performance. External factors – such as commodity prices, interest rates or the economy – cannot be relied on to sustain growth.

We maintain discipline by investing in high-quality companies at reasonable valuations that continue to compound cash flows at attractive rates over time. Nothing has changed in terms of how quality companies can provide long-term outperformance, and thus we believe the opportunities offered by quality stocks remain attractive.

Clyde Rossouw, Co-Head of Quality and Portfolio Manager

Definition of the Comparative Index

The MSCI All Country World Index (Net) is a market capitalization weighted index designed to provide a broad measure of equity-market performance throughout the world and is calculated with dividends reinvested after deduction of withholding tax.

The information may discuss general market activity or industry trends and is not intended to be relied upon as a forecast, research or investment advice. The economic and market views presented herein reflect Investec Asset Management’s (‘Investec’) judgment as at the date shown and are subject to change without notice. There is no guarantee that views and opinions expressed will be correct, and Investec’s intentions to buy or sell particular securities in the future may change. The investment views, analysis and market opinions expressed may not reflect those of Investec as a whole, and different views may be expressed based on different investment objectives. This communication is based on internal data, public and third party sources. Although we believe the information to be reliable, we have not independently verified it, and we cannot guarantee its accuracy or completeness. Investec’s internal data may not be audited. Holdings are subject to change. Current and future holdings are subject to risk.

3

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC GLOBAL FRANCHISE FUND OCTOBER 31, 2019 (Unaudited)

Comparison of Change in the Value of a $10,000 Investment in the Investec Global Franchise Fund, I Shares, versus the MSCI All Country World Index (Net).

	AVERAGE ANNUAL TOTAL RETURN FOR THE YEAR  ENDED OCTOBER 31, 2019
	1 Year	Inception to Date*
I Shares*	15.45%	9.04%
A Shares (without sales charge)**	15.10%	8.23%
A Shares (with sales charge)**	8.49%	2.48%
MSCI All Country World Index (Net)	12.59%	5.03%

* Fund commenced operations on December 11, 2017. The graph is based on I Shares only; Performance for A Shares would have been lower due to a maximum front-end sales charge of 5.75% and differences in fee structures.

** Commenced operations on September 28, 2018.

The performance data quoted herein represents past performance and the return and value of an investment in the Fund will fluctuate so that, when redeemed, may be worth less than its original cost. Past performance is no guarantee of future performance and should not be considered as a representation of the future results of the Fund. The Fund’s performance assumes the reinvestment of dividends and capital gains. Index returns assume reinvestment of dividends and, unlike a fund’s returns, do not reflect any fees or expenses. If such fees and expenses were included in the index returns, the performance would have been lower.

Please note that one cannot invest directly in an unmanaged index.

There are no assurances that the Fund will meet its stated objectives. The Fund’s holdings and allocations are subject to change because it is actively managed and should not be considered recommendations to buy individual securities.

Returns shown do not reflect the deduction of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares.

See definition of comparative index on page 3.

4

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC EMERGING MARKETS EQUITY FUND OCTOBER 31, 2019 (Unaudited)

Emerging Markets Equity Fund - Annual Review - November 28, 2018 to October 31, 2019

Market Background

A weak final quarter of 2018 rounded off the worst year for the MSCI Emerging Markets Equity Index since 2015, due to growth concerns stemming from a rise in trade tensions globally and excessive monetary tightening. The first quarter of 2019, however, saw a reversal of fortunes. The benchmark made three straight monthly gains, rising 9.9% over the period as central banks eased monetary policy. April onwards was more varied, with an uncertain global growth outlook undermining investor sentiment. Latin America was particularly hard hit, with Argentina’s political situation a significant performance headwind.

More broadly, developments in the US-China trade war have been a strong influence on emerging markets over the period. The dispute has provided alternating headwinds and tailwinds, driven by the progress of talks and the perceived likelihood of a deal. At the sector level, technology, consumer discretionary and energy were the best performers. Health care, materials and communications services underperformed.

Performance

The portfolio has outperformed the MSCI Emerging Markets Equity Index since inception to the end of October 2019.

At the sector level, technology was the largest contributor to relative returns. The leading individual contributor here was Indian IT service provider Tech Mahindra (0.00%)¹, which reported better-than-expected profits in February on improved margins and a rebound in orders from communication services clients. We have since exited the position as the original investment case had played out, as well as the company reporting weaker-than-expected earnings later in the year. Taiwan Semiconductor (6.84%) performed well as earnings upgrades started to come through on Huawei (0.00%) and chip production accelerated, while China stepped up its 5G roll out. There was also a wider re-rating in the sector, driven by increased competition and improved demand in the semiconductor market.

Consumer staples also drove performance, led by Chinese distiller Wuliangye Yibin (1.18%). The recovery in Baijiu demand continued, as did the trend towards premiumisation of its product. Demand remained strong and inventories

5

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC EMERGING MARKETS EQUITY FUND OCTOBER 31, 2019 (Unaudited)

appeared lean. Chinese sports clothing brand Li Ning (0.92%) was a key contributor as it delivered first-half sales and profit figures ahead of its June profit alert.

Most of the worst-performing stocks were in the materials sector, although the sector overall was a contributor to relative performance. Indorama Ventures (0.61%) was the largest detractor from returns, as the company has been exposed to weakness in polyethylene prices, having been one of the companies that invested in a new Gulf Coast cracker project. Another detractor was steelmaker Ternium (0.50%), which reported falling demand in several of its key markets. Investors also factored in the impact of a recent surge in iron ore prices. Mexican cement company Cemex (0.00%) detracted from performance as returns were hindered by Mexico’s presidential handover, where uncertainty about the incoming administration’s policies triggered sell-offs. The portfolio no longer holds Cemex.

South African chemicals company Sasol (0.59%) sold off after delaying the release of its annual financial results to accommodate a more thorough investigation into its delayed ethane cracker project in North America.

Outlook

The wax and wane of US-China trade tensions are a recipe for volatility and risk aversion, and have put pressure on higher risk asset classes such as equities, and in particular emerging market equities. Historically, periods of heightened risk aversion have tended to be short-lived. In addition, the increasing dovishness of central banks globally will provide some underpinning for risk assets. In the short term, distinguishing ‘signal’ from ‘noise’ is going to be exceedingly difficult, but such periods can create opportunities.

We find it interesting that our process is beginning to distinguish some companies that are beneficiaries of existing themes (and where valuations have been forced down to compelling levels) or companies that in our view could benefit from some of the rapid changes in the economic environment. It is also worth noting that emerging market equities have been volatile from quarter to quarter in the past year, but have broadly traded within a relatively narrow range in that time.

Why the resilience when faced with an epic trade war and a major global economic slowdown? Because the asset class is relatively cheap versus history and developed markets. Expectations are generally low (and pessimism high) and emerging market equities are generally lightly owned. We believe this is a recipe for much improved performance when the economic backdrop improves.

6

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC EMERGING MARKETS EQUITY FUND OCTOBER 31, 2019 (Unaudited)

Archie Hart, Portfolio Manager

¹ Percentage of the Fund as of October 31, 2019.

Definition of the Comparative Index

The MSCI Emerging Markets Equity Index (Net) is a free float-adjusted market capitalization index that is designed to measure equity market performance

of emerging markets.

The information may discuss general market activity or industry trends and is not intended to be relied upon as a forecast, research or investment advice. The economic and market views presented herein reflect Investec Asset Management’s (‘Investec’) judgment as at the date shown and are subject to change without notice. There is no guarantee that views and opinions expressed will be correct, and Investec’s intentions to buy or sell particular securities in the future may change. The investment views, analysis and market opinions expressed may not reflect those of Investec as a whole, and different views may be expressed based on different investment objectives. This communication is based on internal data, public and third party sources. Although we believe the information to be reliable, we have not independently verified it, and we cannot guarantee its accuracy or completeness. Investec’s internal data may not be audited. Holdings are subject to change. Current and future holdings are subject to risk.

7

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC EMERGING MARKETS EQUITY FUND OCTOBER 31, 2019 (Unaudited)

Comparison of Change in the Value of a $10,000 Investment in the Investec Emerging Markets Equity Fund, I Shares, versus the MSCI Emerging Markets Equity Index (Net).

	TOTAL RETURN FOR THE PERIOD ENDED OCTOBER 31, 2019
	Cumulative Inception to Date*
I Shares*	7.37%
A Shares (without sales charge)*	7.14%
A Shares (with sales charge)*	0.98%
MSCI Emerging Markets Equity Index (Net)	7.76%

* Fund commenced operations on November 28, 2018. The graph is based on I Shares only; Performance for A Shares would have been lower due to a maximum front-end sales charge of 5.75% and differences in fee structures.

The performance data quoted herein represents past performance and the return and value of an investment in the Fund will fluctuate so that, when redeemed, may be worth less than its original cost. Past performance is no guarantee of future performance and should not be considered as a representation of the future results of the Fund. The Fund’s performance assumes the reinvestment of dividends and capital gains. Index returns assume reinvestment of dividends and, unlike a fund’s returns, do not reflect any fees or expenses. If such fees and expenses were included in the index returns, the performance would have been lower.

Please note that one cannot invest directly in an unmanaged index.

There are no assurances that the Fund will meet its stated objectives. The Fund’s holdings and allocations are subject to change because it is actively managed and should not be considered recommendations to buy individual securities.

Returns shown do not reflect the deduction of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares.

See definition of comparative index on page 7.

8

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC GLOBAL FRANCHISE FUND OCTOBER 31, 2019

Sector Weightings (unaudited) †:

† Percentages are based on total investments.

SCHEDULE OF INVESTMENTS
COMMON STOCK — 90.5%
	Shares		Value
BELGIUM — 1.1%
Anheuser-Busch InBev ADR		8,968	$	724,345
CHINA — 1.4%
NetEase ADR		3,195		913,323
GERMANY — 3.4%
Beiersdorf		18,467		2,186,974
NETHERLANDS — 3.5%
ASML Holding		8,557		2,243,451
SOUTH KOREA — 1.6%
Samsung Electronics GDR		968		1,048,330
SPAIN — 1.6%
Amadeus IT Group		13,528		1,001,236
SWITZERLAND — 8.6%
Nestle		26,025		2,777,758
Roche Holding		9,198		2,766,624
				5,544,382

The accompanying notes are an integral part of the financial statements.

9

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC GLOBAL FRANCHISE FUND OCTOBER 31, 2019

COMMON STOCK — continued
	Shares		Value
UNITED KINGDOM — 9.1%
Imperial Brands		49,535	$	1,084,796
Reckitt Benckiser Group		22,172		1,711,100
St. James’s Place		87,453		1,178,035
Unilever		30,836		1,844,454
				5,818,385
UNITED STATES — 60.2%
Communication Services — 1.3%
Fox		26,770		857,711
Consumer Discretionary — 5.4%
Booking Holdings *(1)		1,699		3,480,860
Consumer Staples — 6.3%
Altria Group		15,782		706,876
Colgate-Palmolive (1)		9,350		641,410
Philip Morris International (1)		32,670		2,660,645
				4,008,931
Financials — 12.9%
Charles Schwab		45,688		1,859,958
FactSet Research Systems		5,128		1,300,051
Moody’s		15,727		3,470,792
S&P Global		6,370		1,643,396
				8,274,197
Health Care — 7.3%
Becton Dickinson		5,803		1,485,568
Johnson & Johnson		17,717		2,339,353
Medtronic		7,748		843,757
				4,668,678
Information Technology — 27.0%
Check Point Software Technologies *		16,764		1,884,441
Intuit		8,402		2,163,515
Microsoft		31,148		4,465,689
VeriSign*		17,770		3,376,656
Visa, Cl A (1)		30,663		5,484,384
				17,374,685
				38,665,062

The accompanying notes are an integral part of the financial statements.

10

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC GLOBAL FRANCHISE FUND OCTOBER 31, 2019

COMMON STOCK — continued
	Value
Total Common Stock (Cost $51,994,156)	$	58,145,488
Total Investments — 90.5% (Cost $51,994,156)	$	58,145,488

Percentages are based on Net Assets of $64,258,515.

* Non-income producing security.

(1) Represents a company categorized as a “non-United States company,” as set forth in the Fund’s Prospectus, because at least 50% of the company’s revenue is generated outside of the United States.

ADR	American Depositary Receipt
Cl	Class
GDR	Global Depositary Receipt

As of October 31, 2019, all of the Fund’s investments were considered Level 1 in accordance with the authoritative guidance of fair value measurements and disclosure under U.S. generally accepted accounting principles.

For the year ended October 31, 2019, there were no transfers in or out of Level 3.

The accompanying notes are an integral part of the financial statements.

11

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC EMERGING MARKETS EQUITY FUND OCTOBER 31, 2019

Sector Weightings (unaudited) †:

† Percentages are based on total investments.

SCHEDULE OF INVESTMENTS
COMMON STOCK — 95.2%
	Shares		Value
AUSTRIA — 1.1%
Erste Group Bank		14,723	$	520,201
BRAZIL — 7.1%
Ambev		11,398		49,290
Ambev ADR		133,346		574,721
Atacadao		89,510		427,884
Banco do Brasil		48,071		574,903
Engie Brasil Energia		37,609		421,584
Petroleo Brasileiro ADR		70,009		1,136,946
				3,185,328
CHINA — 13.0%
58.com ADR *		6,568		346,856
Alibaba Group Holding ADR *		17,045		3,011,340
Anhui Conch Cement, Cl A		77,853		466,538
Haier Smart Home, Cl A		194,622		442,612
Kunlun Energy		294,000		274,205
NetEase ADR		2,753		786,973
Wuliangye Yibin, Cl A		28,433		533,791
				5,862,315

The accompanying notes are an integral part of the financial statements.

12

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC EMERGING MARKETS EQUITY FUND OCTOBER 31, 2019

COMMON STOCK — continued
	Shares		Value
COLOMBIA — 1.1%
Bancolombia ADR		9,567	$	496,336
DENMARK — 1.0%
Carlsberg, Cl B		3,232		454,901
HONG KONG — 21.3%
AIA Group		86,800		868,808
Air China, Cl H		312,000		276,265
China Construction Bank, Cl H		1,130,000		909,744
China Merchants Bank, Cl H		111,500		533,479
China Resources Gas Group		52,000		313,817
China Resources Land		142,000		606,032
China Telecom, Cl H		1,162,000		495,181
CSPC Pharmaceutical Group		252,000		647,869
Galaxy Entertainment Group		57,000		393,808
Kerry Properties		77,500		251,158
Li Ning		121,500		413,128
Ping An Insurance Group of China, Cl H		104,500		1,209,969
Sands China		93,200		460,786
Techtronic Industries		68,000		533,575
Tencent Holdings		19,500		798,142
Want Want China Holdings		496,000		418,939
Weichai Power, Cl H		289,000		456,489
				9,587,189
HUNGARY — 1.2%
MOL Hungarian Oil & Gas		33,572		332,332
Richter Gedeon Nyrt		10,369		192,456
				524,788
INDIA — 3.8%
Bharat Electronics		77,858		129,692
HDFC Bank		20,641		358,045
ITC		127,682		463,807
Shriram Transport Finance		24,584		394,658
State Bank of India		83,807		369,121
				1,715,323

The accompanying notes are an integral part of the financial statements.

13

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC EMERGING MARKETS EQUITY FUND OCTOBER 31, 2019

COMMON STOCK — continued
	Shares		Value
INDONESIA — 3.7%
Astra International		1,028,200	$	509,082
Bank Negara Indonesia Persero		820,500		448,624
Perusahaan Gas Negara		1,960,500		294,696
Telekomunikasi Indonesia Persero		1,450,000		424,557
				1,676,959
LUXEMBOURG — 0.5%
Ternium ADR (1)		11,297		225,827
MALAYSIA — 0.8%
Genting		143,700		199,808
Malayan Banking		69,800		143,659
				343,467
MEXICO — 2.3%
Grupo Mexico		173,447		459,491
Wal-Mart de Mexico		197,374		593,502
				1,052,993
NETHERLANDS — 0.8%
Prosus *		5,319		366,907
POLAND — 0.9%
Powszechna Kasa Oszczednosci Bank Polski		39,652		396,208
RUSSIA — 3.2%
LUKOIL PJSC ADR		9,153		842,625
MMC Norilsk Nickel PJSC ADR		21,102		585,264
				1,427,889
SOUTH AFRICA — 5.0%
Bidcorp		20,673		483,781
Naspers, Cl N		5,509		784,697
Old Mutual		229,480		299,352
RMB Holdings		62,741		331,001
Sasol		14,627		266,322
SPAR Group		4,982		67,149
				2,232,302

The accompanying notes are an integral part of the financial statements.

14

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC EMERGING MARKETS EQUITY FUND OCTOBER 31, 2019

COMMON STOCK — continued
	Shares		Value
SOUTH KOREA — 8.9%
Hana Financial Group		12,991	$	376,292
Hyundai Motor		4,033		422,903
Samsung Electronics		69,300		3,002,037
Samsung Life Insurance		3,210		194,788
				3,996,020
SWITZERLAND — 0.5%
Swatch Group		896		247,893
TAIWAN — 9.5%
Delta Electronics		75,000		330,152
MediaTek		42,000		562,934
Novatek Microelectronics		45,000		289,746
Taiwan Semiconductor Manufacturing		314,000		3,079,089
				4,261,921
THAILAND — 2.4%
Advanced Info Service		56,600		429,256
Bangkok Bank NVDR		39,900		229,925
Bangkok Bank		9,600		55,320
Indorama Ventures		295,600		274,112
Kasikornbank NVDR		11,800		54,320
Kasikornbank		5,900		27,160
				1,070,093
TURKEY — 1.2%
TAV Havalimanlari Holding		60,626		276,781
Yapi ve Kredi Bankasi *		623,609		248,896
				525,677
UNITED ARAB EMIRATES — 1.7%
Abu Dhabi National Oil for Distribution PJSC		178,723		127,492
Aldar Properties PJSC		404,134		258,581
Emaar Properties PJSC		321,841		374,172
				760,245
UNITED KINGDOM — 2.9%
Anglo American (1)		22,720		582,582
Polymetal International (1)		27,603		451,835

The accompanying notes are an integral part of the financial statements.

15

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC EMERGING MARKETS EQUITY FUND OCTOBER 31, 2019

COMMON STOCK — continued
	Shares		Value
UNITED KINGDOM (continued)
X5 Retail Group GDR		8,480	$	283,741
				1,318,158
UNITED STATES — 1.3%
Information Technology — 1.3%
Broadcom (1)		1,973		577,793
Total Common Stock (Cost $40,644,812)				42,826,733
PREFERRED STOCK (A) — 2.4%
BRAZIL — 2.4%
Cia de Transmissao de Energia Eletrica Paulista		33,257		195,098
Itausa - Investimentos Itau		259,260		884,781
Total Preferred Stock (Cost $991,930)				1,079,879
Total Investments — 97.6% (Cost $41,636,742)			$	43,906,612

Percentages are based on Net Assets of $44,984,281.

* Non-income producing security.

(1) Represents a company categorized as a “emerging market company,” as set forth in the Fund’s Prospectus, because it derives 50% or more of its annual revenue or profits from goods produced, sales made or services performed in emerging market countries.

(A) There is currently no rate available.

ADR	American Depositary Receipt
Cl	Class
GDR	Global Depositary Receipt
NVDR	Non-Voting Depositary Receipt
PJSC	Public Joint Stock Company

As of October 31, 2019, all of the Fund’s investments were considered Level 1 in accordance with the authoritative guidance of fair value measurements and disclosure under U.S. generally accepted accounting principles.

For the period ended October 31, 2019, there were no transfers in or out of Level 3.

The accompanying notes are an integral part of the financial statements.

16

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

STATEMENTS OF ASSETS AND LIABILITIES
		Investec Global Franchise Fund		Investec Emerging Markets Equity Fund
Assets:
Investments, at Value (Cost $51,994,156 and $41,636,742)	$	58,145,488	$	43,906,612
Foreign Currency, at Value (Cost $7,605 and $97,039)		7,702		97,242
Cash		5,981,801		902,705
Receivable for Capital Shares Sold		192,887		300
Reclaim Receivable		40,147		5,459
Dividend and Interest Receivable		23,864		21,338
Receivable due from Investment Adviser		8,021		23,244
Receivable for Investments Sold		–		219,438
Deferred Offering Costs (Note 2)		–		6,000
Prepaid Expenses		10,877		3,848
Total Assets		64,410,787		45,186,186
Liabilities:
Payable for Capital Shares Redeemed		81,409		98
Audit Fees Payable		25,260		25,260
Payable due to Administrator		10,192		9,342
Payable due to Trustees		3,567		2,502
Chief Compliance Officer Fees Payable		1,776		1,246
Distribution Fees Payable – A Shares		637		2
Payable for Investment Securities Purchased		–		120,015
Unrealized Loss on Foreign Spot Currency Contracts		–		184
Other Accrued Expenses		29,431		43,256
Total Liabilities		152,272		201,905
Net Assets	$	64,258,515	$	44,984,281
NET ASSETS CONSIST OF:
Paid-in Capital	$	57,598,851	$	42,431,568
Total distributable earnings		6,659,664		2,552,713
Net Assets	$	64,258,515	$	44,984,281

The accompanying notes are an integral part of the financial statements.

17

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

STATEMENTS OF ASSETS AND LIABILITIES (continued)
		Investec Global Franchise Fund		Investec Emerging Markets Equity Fund
I Shares:
Net Assets	$	60,832,082	$	44,973,150
Outstanding Shares of beneficial interest (unlimited authorization - no par value)		5,212,770		4,194,660
Net Asset Value, Offering and Redemption Price Per Share		$ 11.67	$	10.72
A Shares:
Net Assets	$	3,426,433	$	11,131
Outstanding Shares of beneficial interest (unlimited authorization - no par value)		294,253		1,040
Net Asset Value, Offering and Redemption Price Per Share	$	11.64	$	10.70
Maximum Offering Price Per Share ($11.64/94.25%, $10.70/94.25%)	$	12.35	$	11.35

The accompanying notes are an integral part of the financial statements.

18

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS FOR THE PERIOD ENDED OCTOBER 31, 2019

STATEMENTS OF OPERATIONS
		Investec Global Franchise Fund			Investec Emerging   Markets Equity   Fund*
Investment Income:
Dividends	$	808,974		$	1,745,258
Less: Foreign Taxes Withheld		(25,586	)		(119,473	)
Total Investment Income		783,388			1,625,785
Expenses:
Investment Advisory Fees		369,315			292,975
Administration Fees – Note 4		118,905			101,562
Trustees’ Fees		12,438			11,353
Distribution Fees - A Shares		5,042			24
Chief Compliance Officer Fees		3,367			4,354
Transfer Agent Fees		79,819			72,652
Legal Fees		44,040			48,917
Registration and Filing Fees		42,691			7,978
Printing Fees		35,525			14,262
Audit Fees		25,410			25,260
Custodian Fees		3,889			99,241
Offering Costs		–			72,215
Other Expenses		10,555			26,965
Total Expenses		750,996			777,758
Less:
Investment Advisory Fee Waiver		(338,440	)		(292,975	)
Reimbursement from Adviser		–			(152,666	)
Fees Paid Indirectly — Note 4		(46	)		(46	)
Net Expenses		412,510			332,071
Net Investment Income		370,878			1,293,714
Net Realized Gain (Loss) on:
Investments		333,275			(869,759	)
Foreign Currency Transactions		85			(90,006	)
Net Realized Gain (Loss)		333,360			(959,765	)

The accompanying notes are an integral part of the financial statements.

19

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS FOR THE PERIOD ENDED OCTOBER 31, 2019

STATEMENTS OF OPERATIONS (continued)
		Investec Global Franchise Fund		Investec Emerging   Markets Equity   Fund*
Net Change in Unrealized Appreciation (Depreciation) on:
Investments	$	6,010,290	$	2,269,870
Foreign Currency Translation		588		636
Net Change in Unrealized Appreciation (Depreciation)		6,010,878		2,270,506
Net Realized and Unrealized Gain on Investments and Foreign Currency Transactions		6,344,238		1,310,741
Net Increase in Net Assets Resulting from Operations	$	6,715,116	$	2,604,455

* Commenced operations on November 28, 2018.

The accompanying notes are an integral part of the financial statements.

20

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC GLOBAL FRANCHISE FUND

STATEMENTS OF CHANGES IN NET ASSETS
	Year Ended     October 31,     2019			Period Ended     October 31,     2018 *
Operations:
Net Investment Income	$	370,878			$          223,726
Net Realized Gain (Loss) on Investments and Foreign Currency Transactions		333,360			(123,977	)
Net Change in Unrealized Appreciation on Investments and Foreign Currency Translation		6,010,878			140,541
Net Increase in Net Assets Resulting From Operations		6,715,116			240,290
Distributions:
I Shares		(272,758	)		(18,765	)
A Shares		(4,219	)		–
Total Distributions		(276,977	)		(18,765	)
Capital Share Transactions:
I Shares:
Issued		25,833,954			33,769,559
Reinvestment of Distributions		272,764			18,765
Redeemed		(4,926,989	)		(529,246	)
Increase from I Shares Capital Share Transactions		21,179,729			33,259,078
A Shares:
Issued		3,992,641			399,209
Reinvestment of Distributions		4,213			–
Redeemed		(1,234,927	)		(1,092	)
Increase from A Shares Capital Share Transactions		2,761,927			398,117
Net Increase in Net Assets From Capital Share Transactions		23,941,656			33,657,195
Total Increase in Net Assets		30,379,795			33,878,720
Net Assets:
Beginning of Year/Period		33,878,720			–
End of Year/Period	$	64,258,515			$    33,878,720

The accompanying notes are an integral part of the financial statements.

21

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC GLOBAL FRANCHISE FUND

STATEMENTS OF CHANGES IN NET ASSETS (continued)
	Year Ended     October 31,     2019			Period Ended     October 31,     2018 *
Shares Transactions:
I Shares:
Issued		2,336,121			3,333,177
Reinvestment of Distributions		28,443			1,873
Redeemed		(436,588	)		(50,256	)
Increase in Shares Outstanding from I Shares Transactions		1,927,976			3,284,794
A Shares:
Issued		362,817			39,145
Reinvestment of Distributions		439			–
Redeemed		(108,040	)		(108	)
Increase in Shares Outstanding from A Shares Transactions		255,216			39,037
Net Increase in Shares Outstanding From Share Transactions		2,183,192			3,323,831

* I Shares commenced operations on December 11, 2017. A Shares commenced operations on September 28, 2018.

The accompanying notes are an integral part of the financial statements.

22

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC EMERGING MARKETS EQUITY FUND

STATEMENTS OF CHANGES IN NET ASSETS (continued)
	Period Ended     October 31,     2019 *
Operations:
Net Investment Income		$      1,293,714
Net Realized Loss on Investments and Foreign Currency Transactions		(959,765	)
Net Change in Unrealized Appreciation on Investments and Foreign Currency Translation		2,270,506
Net Increase in Net Assets Resulting From Operations		2,604,455
Distributions:
I Shares		(52,053	)
A Shares		(13	)
Total Distributions		(52,066	)
Capital Share Transactions:
I Shares:
Issued		48,106,676
Reinvestment of Distributions		52,053
Redeemed		(5,737,205	)
Increase from I Shares Capital Share Transactions		42,421,524
A Shares:
Issued		13,506
Reinvestment of Distributions		13
Redeemed		(3,151	)
Increase from A Shares Capital Share Transactions		10,368
Net Increase in Net Assets From Capital Share Transactions		42,431,892
Total Increase in Net Assets		44,984,281
Net Assets:
Beginning of Period		–
End of Period		$    44,984,281

The accompanying notes are an integral part of the financial statements.

23

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC EMERGING MARKETS EQUITY FUND

STATEMENTS OF CHANGES IN NET ASSETS (continued)
	Period Ended     October 31,     2019 *
Shares Transactions:
I Shares:
Issued		4,741,041
Reinvestment of Distributions		5,450
Redeemed		(551,831	)
Increase in Shares Outstanding from I Shares Transactions		4,194,660
A Shares:
Issued		1,327
Reinvestment of Distributions		1
Redeemed		(288	)
Increase in Shares Outstanding from A Shares Transactions		1,040
Net Increase in Shares Outstanding From Share Transactions		4,195,700

* Commenced operations on November 28, 2018.

The accompanying notes are an integral part of the financial statements.

24

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC GLOBAL FRANCHISE FUND

FINANCIAL HIGHLIGHTS

Selected Per Share Data & Ratios

For a Share Outstanding

	I Shares
	Year Ended October 31, 2019			Period Ended October 31, 2018(1)
Net Asset Value, Beginning of Year/Period		$10.19			$10.00
Income from Investment Operations:
Net Investment Income*		0.09			0.08
Net Realized and Unrealized Gain		1.47			0.12
Total from Investment Operations		1.56			0.20
Dividends and Distributions:
Net Investment Income		(0.08	)		(0.01	)
Total Dividends and Distributions		(0.08	)		(0.01	)
Net Asset Value, End of Year/Period		$11.67			$10.19
Total Return†		15.45	%		1.98	%
Ratios and Supplemental Data
Net Assets, End of Year/Period (Thousands)	$	60,832		$	33,481
Ratio of Expenses to Average Net Assets		0.85	%		0.85	%††
Ratio of Expenses to Average Net Assets (Excluding Waivers and Reimbursements)		1.56	%		2.10	%††
Ratio of Net Investment Income to Average Net Assets		0.79	%		0.93	%††
Portfolio Turnover Rate		7	%		9	%‡

*	Per share calculations were performed using average shares for the period.
†	Total return is for the period indicated and has not been annualized. Returns shown do not reflect the deductions of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares
††	Annualized
‡	Portfolio turnover is for the period indicated and has not been annualized.
(1)	Commenced operations on December 11, 2017.

The accompanying notes are an integral part of the financial statements.

25

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC GLOBAL FRANCHISE FUND

FINANCIAL HIGHLIGHTS (continued)

Selected Per Share Data & Ratios

For a Share Outstanding

	A Shares
	Year Ended October 31, 2019			Period Ended October 31, 2018(1)
Net Asset Value, Beginning of Year/Period		$10.19			$10.76
Income (Loss) from Investment Operations:
Net Investment Income (Loss)*		0.05			(0.01	)
Net Realized and Unrealized Gain (Loss)		1.47			(0.56	)
Total from Investment Operations		1.52			(0.57	)
Dividends and Distributions:
Net Investment Income		(0.07	)		—
Total Dividends and Distributions		(0.07	)		—
Net Asset Value, End of Year/Period		$11.64			$10.19
Total Return†		15.10	%		(5.30	)%
Ratios and Supplemental Data
Net Assets, End of Year/Period (Thousands)		$3,427			$398
Ratio of Expenses to Average Net Assets		1.10	%		1.15	%††(2)
Ratio of Expenses to Average Net Assets (Excluding Waivers and Reimbursements)		1.78	%		3.35	%††
Ratio of Net Investment Income (Loss) to Average Net Assets		0.48	%		(1.00	)%††
Portfolio Turnover Rate		7	%		9	%‡

*	Per share calculations were performed using average shares for the period.
†	Total return is for the period indicated and has not been annualized. Returns shown do not reflect the deductions of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares
††	Annualized
‡	Portfolio turnover is for the period indicated and has not been annualized.
(1)	Commenced operations on September 28, 2018.
(2)	Ratio reflects the impact of low level of average net assets. Under normal asset levels, ratio would have been 1.10%.
	Amounts designated as “—” are $0.

The accompanying notes are an integral part of the financial statements.

26

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC EMERGING MARKETS EQUITY FUND

FINANCIAL HIGHLIGHTS (continued)

Selected Per Share Data & Ratios

For a Share Outstanding

	I Shares
	Period Ended October 31, 2019(1)
Net Asset Value, Beginning of Period		$10.00
Income from Investment Operations:
Net Investment Income*		0.32
Net Realized and Unrealized Gain		0.42
Total from Investment Operations		0.74
Dividends and Distributions:
Net Investment Income		(0.02	)
Total Dividends and Distributions		(0.02	)
Net Asset Value, End of Period		$10.72
Total Return†		7.37	%
Ratios and Supplemental Data
Net Assets, End of Period (Thousands)	$	44,973
Ratio of Expenses to Average Net Assets		0.85	%††
Ratio of Expenses to Average Net Assets (Excluding Waivers and Reimbursements)		1.99	%††
Ratio of Net Investment Income to Average Net Assets		3.31	%††
Portfolio Turnover Rate		62	%‡

*	Per share calculations were performed using average shares for the period.
†	Total return is for the period indicated and has not been annualized. Returns shown do not reflect the deductions of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares
††	Annualized
‡	Portfolio turnover is for the period indicated and has not been annualized.
(1)	Commenced operations on November 28, 2018.

The accompanying notes are an integral part of the financial statements.

27

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC EMERGING MARKETS EQUITY FUND

FINANCIAL HIGHLIGHTS (continued)

Selected Per Share Data & Ratios

For a Share Outstanding

	A Shares
	Period Ended October 31, 2019(1)
Net Asset Value, Beginning of Period		$10.00
Income from Investment Operations:
Net Investment Income*		0.28
Net Realized and Unrealized Gain		0.43
Total from Investment Operations		0.71
Dividends and Distributions:
Net Investment Income		(0.01	)
Total Dividends and Distributions		(0.01	)
Net Asset Value, End of Period		$10.70
Total Return†		7.14	%
Ratios and Supplemental Data
Net Assets, End of Period (Thousands)		$11
Ratio of Expenses to Average Net Assets		1.10	%††
Ratio of Expenses to Average Net Assets (Excluding Waivers and Reimbursements)		2.24	%††
Ratio of Net Investment Income to Average Net Assets		2.94	%††
Portfolio Turnover Rate		62	%‡

*	Per share calculations were performed using average shares for the period.
†	Total return is for the period indicated and has not been annualized. Returns shown do not reflect the deductions of taxes that a shareholder would pay on Fund distributions or the redemption of Fund shares
††	Annualized
‡	Portfolio turnover is for the period indicated and has not been annualized.
(1)	Commenced operations on November 28, 2018.

The accompanying notes are an integral part of the financial statements.

28

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

NOTES TO FINANCIAL STATEMENTS

1. Organization:

The Advisors’ Inner Circle Fund III (the “Trust”) is organized as a Delaware statutory trust under a Declaration of Trust dated December 4, 2013. The Trust is registered under the Investment Company Act of 1940, as amended, as an open-end management investment company with 30 funds. The financial statements herein are those of the Investec Global Franchise Fund and Investec Emerging Markets Equity Fund (the “Funds”). The investment objectives of the Funds are to seek long-term capital growth. The Funds are classified as a non-diversified investment company. Investec Asset Management North America, Inc. serves as the Funds’ investment adviser (the “Adviser”). The Investec Global Franchise Fund commenced operations on December 11, 2017, and currently offers Class I Shares (effective as of December 11, 2017) and Class A Shares (effective as of September 28, 2018). The Investec Emerging Markets Equity Fund commenced operations November 28, 2018, and currently offers Class I Shares and Class A Shares. The financial statements of the remaining funds of the Trust are presented separately. The assets of each of the funds are segregated, and a shareholder’s interest is limited to the funds in which shares are held.

2. Significant Accounting Policies:

The following is a summary of the significant accounting policies, which are consistently followed in the preparation of the financial statements of the Funds. The Funds are investment companies that apply the accounting and reporting guidance issued in Topic 946 by the U.S. Financial Accounting Standards Board (“FASB”).

Use of Estimates — The preparation of financial statements in conformity with U.S. generally accepted accounting principles (“U.S. GAAP”) requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities as of the date of the financial statements and the reported amounts of increases and decreases in net assets from operations during the reporting period. Actual results could differ from those estimates and such differences could be material.

Security Valuation — Securities listed on a securities exchange, market or automated quotation system for which quotations are readily available (except for securities traded on NASDAQ), including securities traded over the counter, are valued at the last quoted sale price on an exchange or market (foreign or domestic) on which they are traded or, if there is no such reported sale on the valuation date, at the most recent quoted bid price. For

29

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

securities traded on NASDAQ, the NASDAQ official closing price will be used. The prices for foreign securities are reported in local currency and converted to U.S. dollars using currency exchange rates. Prices for most securities held in the Funds are provided daily by recognized independent pricing agents. If a security price cannot be obtained from an independent, third-party pricing agent, the Funds seek to obtain a bid price from at least one independent broker.

Securities for which market prices are not “readily available” are valued in accordance with fair value procedures established by the Funds’ Board of Trustees (the “Board”). The Funds’ fair value procedures are implemented through a fair value pricing committee (the “Committee”) designated by the Board. Some of the more common reasons that may necessitate that a security be valued using fair value procedures include: the security’s trading has been halted or suspended; the security has been de-listed from a national exchange; the security’s primary trading market is temporarily closed at a time when under normal conditions it would be open; the security has not been traded for an extended period of time; the security’s primary pricing source is not able or willing to provide a price; or trading of the security is subject to local government imposed restrictions. When a security is valued in accordance with the fair value procedures, the Committee will determine the value after taking into consideration relevant information reasonably available to the Committee.

For securities that principally trade on a foreign market or exchange, a significant gap in time can exist between the time of a particular security’s last trade and the time at which the Funds calculate their net asset value. The closing prices of such securities may no longer reflect their market value at the time the Funds calculate net asset value if an event that could materially affect the value of those securities (a “Significant Event”) has occurred between the time of the security’s last close and the time that the Funds calculate net asset value. A Significant Event may relate to a single issuer or to an entire market sector. If the Adviser of the Funds become aware of a Significant Event that has occurred with respect to a security or group of securities after the closing of the exchange or market on which the security or securities principally trade, but before the time at which the Funds calculate its net asset value, it may request that a Committee meeting be called.

The Funds use MarkIt Fair Value (“MarkIt”) as a third party fair valuation vendor. MarkIt provides a fair value for foreign securities in the Funds based on certain factors and methodologies (involving, generally, tracking valuation correlations between the U.S. market and each non-U.S. security) applied by MarkIt in the event that there is a movement in the U.S. market that exceeds

30

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

a specific threshold established by the Committee. The Committee establishes a “confidence interval” which is used to determine the level of correlation between the value of a foreign security and movements in the U.S. market before a particular security is fair valued when the threshold is exceeded. In the event that the threshold established by the Committee is exceeded on a specific day, the Funds value non-U.S. securities that exceed the applicable “confidence interval” based upon the fair values provided by MarkIt. In such event, it is not necessary to hold a Committee meeting. In the event that the Adviser believes that the fair values provided by MarkIt are not reliable, the Adviser contacts SEI Investments Global Fund Services (the “Administrator”) and can request that a meeting of the Committee be held.

If a local market in which the Funds own securities is closed for one or more days, the Funds shall value all securities held in that corresponding currency based on the fair value prices provided by MarkIt using the predetermined confidence interval discussed above.

In accordance with U.S. GAAP, the Funds disclose fair value of its investments in a hierarchy that prioritizes the inputs to valuation techniques used to measure the fair value. The objective of a fair value measurement is to determine the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date (an exit price).

Accordingly, the fair value hierarchy gives the highest priority to quoted prices (unadjusted) in active markets for identical assets or liabilities (Level 1) and the lowest priority to unobservable inputs (Level 3). The three levels of the fair value hierarchy are described below:

● Level 1 — Unadjusted quoted prices in active markets for identical, unrestricted assets or liabilities that the Funds has the ability to access at the measurement date;

● Level 2 — Other significant observable inputs (includes quoted prices for similar securities, interest rates, prepayment speeds, credit risk, referenced indices, quoted prices in inactive markets, adjusted quoted prices in active markets, adjusted quoted prices on foreign equity securities that were adjusted in accordance with pricing procedures approved by the Board, etc.); and

● Level 3 — Prices, inputs or exotic modeling techniques which are both significant to the fair value measurement and unobservable (supported by little or no market activity).

Investments are classified within the level of the lowest significant input considered in determining fair value. Investments classified within Level 3

31

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

whose fair value measurement considers several inputs may include Level 1 or Level 2 inputs as components of the overall fair value measurement.

For the period ended October 31, 2019, there have been no significant changes to the Funds’ fair valuation methodology.

Federal Income Taxes — It is the Funds’ intention to qualify as a regulated investment company for Federal income tax purposes by complying with the appropriate provisions of Subchapter M of the Internal Revenue Code of 1986, as amended. Accordingly, no provisions for Federal income taxes have been made in the financial statements.

The Funds evaluate tax positions taken or expected to be taken in the course of preparing the Funds’ tax returns to determine whether it is “more-likely than-not” (i.e., greater than 50-percent) that each tax position will be sustained upon examination by a taxing authority based on the technical merits of the position. Tax positions not deemed to meet the more-likely-than-not threshold are recorded as a tax benefit or expense in the current year. The Funds did not record any tax provision in the current period. However, management’s conclusions regarding tax positions taken may be subject to review and adjustment at a later date based on factors including, but not limited to, examination by tax authorities (i.e., from commencement of operations, as applicable), on-going analysis of and changes to tax laws, regulations and interpretations thereof.

As of and during the period ended October 31, 2019, the Funds did not have a liability for any unrecognized tax benefits. The Funds recognize interest and penalties, if any, related to unrecognized tax benefits as income tax expense in the Statement of Operations. During the period, the Funds did not incur any significant interest or penalties.

Security Transactions and Investment Income — Security transactions are accounted for on trade date. Costs used in determining realized gains and losses on the sale of investment securities are based on the specific identification method. Dividend income and expense are recorded on the ex-dividend date. Interest income is recognized on the accrual basis from settlement date. Certain dividends from foreign securities will be recorded as soon as the Funds are informed of the dividend if such information is obtained subsequent to the ex-dividend date.

Foreign Currency Translation — The books and records of the Funds are maintained in U.S. dollars. Investment securities and other assets and liabilities denominated in a foreign currency are translated into U.S. dollars on the date of valuation. The Funds do not isolate that portion of realized or unrealized gains and losses resulting from changes in the foreign exchange

32

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

rate from fluctuations arising from changes in the market prices of the securities. These gains and losses are included in net realized and unrealized gains and losses on investments on the Statement of Operations. Net realized and unrealized gains and losses on foreign currency transactions represent net foreign exchange gains or losses from foreign currency exchange contracts, disposition of foreign currencies, currency gains or losses realized between trade and settlement dates on securities transactions and the difference between the amount of the investment income and foreign withholding taxes recorded on the Funds’ books and the U.S. dollar equivalent of the amounts actually received or paid.

Expenses — Most expenses of the Trust can be directly attributed to a particular Fund. Expenses which cannot be directly attributed to a particular Fund are apportioned among the funds of the Trust based on the number of funds and/or relative net assets.

Dividends and Distributions to Shareholders — The Funds distribute substantially all of their net investment income annually. Any net realized capital gains are distributed annually. All distributions are recorded on ex-dividend date.

Offering Costs — For the Investec Global Franchise Fund offering costs, including costs of printing the initial prospectus, legal and registration fees, were fully amortized over twelve months from inception of the Fund.

For the Investec Emerging Markets Equity Fund offering costs, including costs of legal, printing and registration fees, are being amortized to expense over twelve months. As of October 31, 2019, the Fund had $6,000 remaining to be amortized.

3. Transactions with Affiliates:

Certain officers of the Trust are also employees of SEI Investments Global Funds Services (the “Administrator”), a wholly owned subsidiary of SEI Investments Company, and/or SEI Investments Distribution Co. (the “Distributor”). Such officers are paid no fees by the Trust, other than the Chief Compliance Officer (“CCO”) as described below, for serving as officers of the Trust.

The services provided by the CCO and his staff are paid for by the Trust as incurred. The services include regulatory oversight of the Trust’s Advisors and service providers as required by SEC regulations. The CCO’s services and fees have been approved by and are reviewed by the Board.

4. Administration, Distribution, Custodian and Transfer Agent Agreements:

The Funds and the Administrator are parties to an Administration Agreement under which the Administrator provides administration services to the Funds. For

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THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

these services, the Administrator is paid an asset based fee, which will vary depending on the number of share classes and the average daily net assets of the Funds. For the period ended October 31, 2019, the Funds paid $118,905 and $101,562 for the Investec Global Franchise Fund and the Investec Emerging Markets Equity Fund, respectively, for these services.

The Trust has adopted a Distribution Plan with respect to A Shares (the “Plan”) in accordance with the provisions of Rule 12b-1 under the 1940 Act, which regulates circumstances under which an investment company may directly or indirectly bear expenses relating to the distribution of its shares. Under the Plan, the Distributor or financial intermediaries may receive up to 0.25% of the average daily net assets of the A Shares as compensation for distribution and shareholder services. For the period ended October 31, 2019, the Funds paid $5,042 and $24 for the Investec Global Franchise Fund and the Investec Emerging Markets Equity Fund, respectively, for these services.

Brown Brothers Harriman & Co. acts as custodian (the “Custodian”) for the Funds. The Custodian plays no role in determining the investment policies of the Funds or which securities are to be purchased or sold by the Funds.

DST Systems, Inc. serves as the transfer agent and dividend disbursing agent for the Funds under a transfer agency agreement with the Trust.

During the period ended October 31, 2019, the Funds earned cash management credits of $46 and $46 for the Investec Global Franchise Fund and the Investec Emerging Markets Equity Fund, respectively, which were used to offset transfer agent expenses. This amount is labeled “Fees Paid Indirectly” on the Statement of Operations.

5. Investment Advisory Agreement:

Under the terms of an investment advisory agreement, the Adviser provides investment advisory services to the Funds at a fee calculated at an annual rate of 0.80% from November 1, 2018 to April 30, 2019 and 0.75% from May 1, 2019 to period end of the Investec Global Franchise Fund’s average daily net assets and 0.75% of the Investec Emerging Markets Equity Fund’s average daily net assets. The Adviser has contractually agreed to reduce fees and reimburse expenses to the extent necessary to keep total annual fund operating expenses after fee reductions and/or expense reimbursements (excluding any class specific expenses, dividend and interest expenses interest, taxes, acquired fund fee expenses and non-routine expenses) from exceeding 0.85% of the average daily net assets of the Funds’ I Shares and A Shares until February 28, 2020 (the “Expense Limitation”). The Adviser may recover all or a portion of its fee reductions or expense reimbursements, up to the expense cap in place at the time the expenses were waived, within a three-year period from the year in which it

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THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

reduced its fee or reimbursed expenses if the Fund’s total annual fund operating expenses are below the Expense Limitation. This agreement may be terminated by the Board for any reason at any time, or by the Adviser, upon ninety (90) days’ prior written notice to the Trust, effective as of the close of business on February 28, 2020. As of October 31, 2019, the fees which were previously waived by the Adviser which may be subject to possible future reimbursement, are as follows:

Fund	Expiring 2021		Expiring 2022		Total
Investec Global Franchise Fund	$	301,042	$	338,440	$	639,482
Investec Emerging Markets Equity Fund		—		445,641		445,641

6. Investment Transactions:

For the period ended October 31, 2019, the Investec Global Franchise Fund made purchases of $24,234,288 and sales of $3,292,398 in investment securities other than long-term U.S. Government and short-term securities. There were no purchases or sales of long-term U.S. Government securities.

For the period ended October 31, 2019, the Investec Emerging Markets Equity Fund made purchases of $67,432,003 and sales of $24,925,642 in investment securities other than long-term U.S. Government and short-term securities. There were no purchases or sales of long-term U.S. Government securities.

7. Federal Tax Information:

The amount and character of income and capital gain distributions to be paid, if any, are determined in accordance with Federal income tax regulations, which may differ from U.S. GAAP. As a result, net investment income (loss) and net realized gain (loss) on investment transactions for a reporting period may differ significantly from distributions during the year. The book/tax differences may be temporary or permanent. To the extent these differences are permanent in nature, they are charged or credited to distributable earnings (loss) or paid-in capital as appropriate, in the period that the difference arises.

Permanent book and tax basis differences are primarily attributable to non-deductible excise tax paid which have been classified to (from) the following for the year ended October 31, 2019:

	Distributable Earnings (Accumulated Loss)		Paid-in Capital
Investec Emerging Markets Equity Fund	$	324	$	(324	)

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THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

These reclassifications have no impact on net assets or net asset value per share.

The tax character of dividends and distributions declared during the last two fiscal periods was as follows:

Investec Global Franchise Fund

	Ordinary Income		Total
2019		$        276,977		$276,977
2018		18,765		18,765

Investec Emerging Markets Equity Fund*

	Ordinary Income	Total
2019	$          52,066	$  52,066

* Commenced operations on November 28, 2018.

As of October 31, 2019, the components of distributable earnings (accumulated losses) on a tax basis were as follows:

Investec Global Franchise Fund

Undistributed Ordinary Income	$	294,696
Undistributed Long-Term Capital Gain		213,549
Unrealized Appreciation		6,151,419
Total Distributable Earnings	$	6,659,664

Investec Emerging Markets Equity Fund

Undistributed Ordinary Income	$	1,152,110
Capital Loss Carryforwards - Short Term		(740,092	)
Unrealized Appreciation		2,140,697
Other Temporary Differences		(2	)
Total Distributable Earnings	$	2,552,713

For Federal income tax purposes, capital losses incurred may be carried forward and applied against future capital gains. Net capital losses earned may be carried forward indefinitely and retain their character as either short-term or long-term capital losses. During the year ended October 31, 2019, the Investec Global Franchise Fund utilized $119,727 of prior short-term capital loss carrryforwards to offset capital gains.

The difference between book-basis and tax-basis unrealized appreciation (depreciation) is due to differences in the timing of recognition of gains and losses on investments for tax and book purposes. The Funds’ net unrealized appreciation difference is attributable primarily to wash sales.

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THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

The Federal tax cost and aggregate gross unrealized appreciation and depreciation for the investments held by the Funds at October 31, 2019, were as follows:

	Federal Tax Cost		Aggregate Gross Unrealized Appreciation		Aggregate Gross Unrealized Depreciation			Net Unrealized Appreciation
Investec Global Franchise Fund	$	51,994,156	$	8,136,150	$	(1,984,731	)	$	6,151,419
Investec Emerging Markets Equity Fund		41,766,551		4,452,245		(2,311,548	)		2,140,697

8. Concentration of Risks:

As with all management investment companies, a shareholder of the Funds is subject to the risk that his or her investment could lose money. The Funds are subject to the principal risks noted below, any of which may adversely affect the Funds’ net asset value (“NAV”) and ability of a Fund to meet that Fund’s investment objective.

Active Management Risk (Emerging Markets Equity Fund & Global Franchise Fund) – Each Fund is subject to the risk that the Adviser’s judgments about the attractiveness, value, or potential appreciation of the Fund’s investments may prove to be incorrect. If the investments selected and strategies employed by the Fund fail to produce the intended results, the Fund could underperform in comparison to its benchmark index or other funds with similar objectives and investment strategies.

Equity Risk (Emerging Markets Equity Fund & Global Franchise Fund) – Since each Fund purchases equity securities, the Fund is subject to the risk that stock prices may fall over short or extended periods of time. Historically, the equity market has moved in cycles, and the value of the Fund’s securities may fluctuate from day to day. Individual companies may report poor results or be negatively affected by industry and/or economic trends and developments. The prices of securities issued by such companies may suffer a decline in response. These factors contribute to price volatility, which is the principal risk of investing in the Fund. Common stock is generally subordinate to preferred stock and debt securities with respect to the payment of dividends and upon the liquidation or bankruptcy of the issuing company.

Preferred Stock Risk (Emerging Markets Equity Fund) – Preferred stocks in which the Fund may invest are sensitive to interest rate changes, and are also subject to equity risk, which is the risk that stock prices will fall over short or

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extended periods of time. The rights of preferred stocks on the distribution of a company’s assets in the event of a liquidation are generally subordinate to the rights associated with a company’s debt securities.

Small- and Mid-Capitalization Company Risk (Emerging Markets Equity Fund) – The small- and mid-capitalization companies in which the Fund may invest may be more vulnerable to adverse business or economic events than larger, more established companies. In particular, investments in these small- and mid-sized companies may pose additional risks, including liquidity risk, because these companies tend to have limited product lines, markets and financial resources, and may depend upon a relatively small management group. Therefore, small- and mid-cap stocks may be more volatile than those of larger companies. These securities may be traded over-the-counter or listed on an exchange.

Large-Capitalization Company Risk (Emerging Markets Equity Fund & Global Franchise Fund) – The large-capitalization companies in which the Funds may invest may lag the performance of smaller capitalization companies because large-capitalization companies may experience slower rates of growth than smaller capitalization companies and may not respond as quickly to market changes and opportunities.

ETF Risk (Emerging Markets Equity Fund) – ETFs are pooled investment vehicles, such as registered investment companies and grantor trusts, whose shares are listed and traded on U.S. and non-U.S. stock exchanges or otherwise traded in the over-the-counter market. To the extent that the Fund invests in ETFs, the Fund will be subject to substantially the same risks as those associated with the direct ownership of the securities comprising the index on which an index ETF is based or the other holdings of an active or index ETF, and the value of the Fund’s investment will fluctuate in response to the performance of the underlying index or holdings. ETFs typically incur fees that are separate from those of the Fund. Accordingly, the Fund’s investments in ETFs will result in the layering of expenses such that shareholders will indirectly bear a proportionate share of the ETFs’ operating expenses, in addition to paying Fund expenses.

Foreign Company Risk (Emerging Markets Equity Fund & Global Franchise Fund) – Investing in foreign companies, including direct investments and investments through Depositary Receipts, poses additional risks since political and economic events unique to a country or region will affect those markets and their issuers. These risks will not necessarily affect the U.S. economy or similar issuers located in the United States. Securities of foreign companies may not be registered with the U.S. Securities and Exchange Commission (the “SEC”) and foreign companies are generally not subject to the same level of regulatory controls imposed on U.S. issuers and, as a consequence, there is generally less publicly available information about foreign securities than is available about

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domestic securities. Income from foreign securities owned by a Fund may be reduced by a withholding tax at the source, which tax would reduce income received from the securities comprising the Fund’s portfolio. Foreign securities may also be more difficult to value than securities of U.S. issuers and foreign markets and securities may be less liquid. While Depositary Receipts provide an alternative to directly purchasing the underlying foreign securities in their respective national markets and currencies, investments in Depositary Receipts continue to be subject to many of the risks associated with investing directly in foreign securities.

Emerging Markets Securities Risk (Emerging Markets Equity Fund) – The Fund’s investments in emerging markets securities are considered speculative and subject to heightened risks in addition to the general risks of investing in foreign securities. Unlike more established markets, emerging markets may have governments that are less stable, markets that are less liquid and economies that are less developed. In addition, the securities markets of emerging market countries may consist of companies with smaller market capitalizations and may suffer periods of relative illiquidity; significant price volatility; restrictions on foreign investment; and possible restrictions on repatriation of investment income and capital. Furthermore, foreign investors may be required to register the proceeds of sales, and future economic or political crises could lead to price controls, forced mergers, expropriation or confiscatory taxation, seizure, nationalization or creation of government monopolies.

Foreign Currency Risk (Emerging Markets Equity Fund & Global Franchise Fund) – Currency risk is the risk that foreign currencies will decline in value relative to the U.S. dollar, in which case the dollar value of a Fund’s investments in securities denominated in, and/or receiving revenues in, foreign currencies, would be adversely affected.

Depositary Receipts Risk (Emerging Markets Equity Fund) – Investments in Depositary Receipts may be less liquid and more volatile than the underlying securities in their primary trading market. If a Depositary Receipt is denominated in a different currency than its underlying securities, the Fund will be subject to the currency risk of both the investment in the Depositary Receipt and the underlying security. Holders of Depositary Receipts may have limited or no rights to take action with respect to the underlying securities or to compel the issuer of the receipts to take action. The prices of Depositary Receipts may differ from the prices of securities upon which they are based.

Geographic Focus Risk (Emerging Markets Equity Fund) – To the extent that it focuses its investments in a particular country or geographic region, the Fund may be more susceptible to economic, political, regulatory or other events or conditions affecting issuers and countries within that country or geographic region.

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As a result, the Fund may be subject to greater price volatility and risk of loss than a fund holding more geographically diverse investments.

Risk of Investing in China (Emerging Markets Equity Fund) – The Chinese economy is generally considered an emerging market and can be significantly affected by economic and political conditions and policy in China and surrounding Asian countries. A relatively small number of Chinese companies represents a large portion of China’s total market and thus may be more sensitive to adverse political or economic circumstances and market movements. The economy of China differs, often unfavorably, from the U.S. economy in such respects as structure, general development, government involvement, wealth distribution, rate of inflation, growth rate, allocation of resources and capital reinvestment, among others. Under China’s political and economic system, the central government has historically exercised substantial control over virtually every sector of the Chinese economy through administrative regulation and/or state ownership. In addition, expropriation, including nationalization, confiscatory taxation, political, economic or social instability or other developments could adversely affect and significantly diminish the values of the Chinese companies in which the Fund invests. The Fund may invest in shares of Chinese companies traded on stock markets in China or Hong Kong. These stock markets have recently experienced high levels of volatility, which may continue in the future. The Hong Kong stock market may behave differently from the China stock markets and there may be little to no correlation between the performance of the Hong Kong stock market and the China stock markets.

Stock Connect Investing Risk (Emerging Markets Equity Fund) – Trading through Stock Connect is subject to a number of restrictions that may affect the Fund’s investments and returns. For example, trading through Stock Connect is subject to daily quotas that limit the maximum daily net purchases on any particular day, which may restrict or preclude the Fund’s ability to invest in China A Shares through Stock Connect. In addition, investments made through Stock Connect are subject to trading, clearance and settlement procedures that are relatively untested, which could pose risks to the Fund. Moreover, China A Shares purchased through Stock Connect generally may not be sold, purchased or otherwise transferred other than through Stock Connect in accordance with applicable rules. A primary feature of Stock Connect is the application of the home market’s laws and rules applicable to investors in China A Shares. Therefore, the Fund’s investments in China A Shares purchased through Stock Connect are generally subject to Chinese securities regulations and listing rules, among other restrictions. While overseas investors currently are exempt from paying capital gains or value added taxes on income and gains from investments in China A Shares purchased through Stock Connect, these tax rules could be changed, which could result in unexpected tax liabilities for the Fund. Stock Connect will

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only operate on days when both the China and Hong Kong markets are open for trading and when banks in both markets are open on the corresponding settlement days. There may be occasions when the Fund may be subject to the risk of price fluctuations of China A Shares during the time when Stock Connect is not trading. Stock Connect is a relatively new program. Further developments are likely and there can be no assurance as to the program’s continued existence or whether future developments regarding the program may restrict or adversely affect the Fund’s investments or returns. In addition, the application and interpretation of the laws and regulations of Hong Kong and China, and the rules, policies or guidelines published or applied by relevant regulators and exchanges in respect of Stock Connect are uncertain, and they may have a detrimental effect on the Fund’s investments and returns.

Liquidity Risk (Emerging Markets Equity Fund) – Certain securities may be difficult or impossible to sell at the time and the price that the Fund would like. The Fund may have to accept a lower price to sell a security, sell other securities to raise cash, or give up an investment opportunity, any of which could have a negative effect on Fund management or performance.

Non-Diversification Risk (Emerging Markets Equity Fund & Global Franchise Fund) – Each Fund is classified as “non-diversified,” which means it may invest a larger percentage of its assets in a smaller number of issuers than a diversified fund. To the extent that a Fund invests its assets in a smaller number of issuers, the Fund will be more susceptible to negative events affecting those issuers than a diversified fund.

New Fund Risk (Emerging Markets Equity Fund) – Because the Fund is new, investors in the Fund bear the risk that the Fund may not be successful in implementing its investment strategy, may not employ a successful investment strategy, or may fail to attract sufficient assets under management to realize economies of scale, any of which could result in the Fund being liquidated at any time without shareholder approval and at a time that may not be favorable for all shareholders. Such liquidation could have negative tax consequences for shareholders and will cause shareholders to incur expenses of liquidation.

9. Other:

At October 31, 2019, 86.02% of I Shares outstanding were held by three record shareholders and 80.97% of A Shares outstanding were held by one record shareholder in the Investec Global Franchise Fund.

At October 31, 2019, 86.95% of I Shares outstanding were held by three record shareholders and 96.25% of A Shares outstanding were held by one record shareholder in the Investec Emerging Markets Equity Fund.

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In the normal course of business, the Funds enter into contracts that provide general indemnifications. The Funds’ maximum exposure under these arrangements is dependent on future claims that may be made against the Funds and, therefore, cannot be established; however, based on experience, the risk of loss from such claim is considered remote.

10. Regulatory Matters:

On August 17, 2018, the SEC adopted amendments to Regulation S-X. These changes are effective for periods after November 5, 2018. The updates to Registered Investment Companies were mainly focused on simplifying the presentation of distributable earnings by eliminating the need to present the components of distributable earnings on a book basis in the Statement of Assets & Liabilities. The update also impacted the presentation of undistributed net investment income and distribution to shareholders on the Statement of Changes in Net Assets. The amounts presented in the current Statement of Changes in Net Assets represent the aggregated total distributions of net investment income and realized capital gains, except for distributions classified as return of capital which are still presented separately.

11. New Accounting Pronouncement:

In August 2018, the FASB issued Accounting Standards Update 2018-13, Fair Value Measurement (Topic 820). The new guidance includes additions, removals and modifications to disclosures requirements for fair value measurements. For public entities, the amendments are effective for financial statements issued for fiscal years beginning after December 15, 2019, and interim periods within those fiscal years. Management elected to early adopt the removal and modifications of certain disclosures and delay the adoption of additional disclosures until the effective date.

12. Subsequent Events:

The Funds have evaluated the need for additional disclosures and/or adjustments resulting from subsequent events through the date the financial statements were issued. Based on this evaluation, no additional disclosures and/or adjustments were required to the financial statements as of October 31, 2019.

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THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM

To the Board of Trustees of The Advisors’ Inner Circle Fund III and Shareholders of

Investec Global Franchise Fund and Investec Emerging Markets Equity Fund

Opinion on the Financial Statements

We have audited the accompanying statements of assets and liabilities, of Investec Global Franchise Fund and Investec Emerging Markets Equity Fund (collectively referred to as the “Funds”) (two of the series constituting The Advisors’ Inner Circle Fund III (the “Trust”)), including the schedules of investments, as of October 31, 2019, and the related statements of operations, changes in net assets and the financial highlights for each of the periods indicated in the table below and the related notes (collectively referred to as the “financial statements”). In our opinion, the financial statements present fairly, in all material respects, the financial position of the Funds (two of the series constituting The Advisors’ Inner Circle Fund III) at October 31, 2019, the results of their operations, the changes in their net assets and the financial highlights for each of the periods indicated in the table below, in conformity with U.S. generally accepted accounting principles.

Individual fund constituting The Advisors’ Inner Circle Fund III	Statements of operations	Statements of changes in net assets	Financial highlights
Investec Global Franchise Fund	For the year ended October 31, 2019	For the year ended October 31, 2019 and the period from December 11, 2017 (commencement of operations) through October 31, 2018	For the year ended October 31, 2019 and the period from December 11, 2017 (commencement of operations) through October 31, 2018
Investec Emerging Markets Equity Fund	For the period from November 28, 2018 (commencement of operations) through October 31, 2019	For the period from November 28, 2018 (commencement of operations) through October 31, 2019	For the period from November 28, 2018 (commencement of operations) through October 31, 2019

Basis for Opinion

These financial statements are the responsibility of the Trust’s management. Our responsibility is to express an opinion on the Funds’ financial statements based

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on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (“PCAOB”) and are required to be independent with respect to the Trust in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements are free of material misstatement, whether due to error or fraud. The Trust is not required to have, nor were we engaged to perform, an audit of the Trust’s internal control over financial reporting. As part of our audits, we are required to obtain an understanding of internal control over financial reporting, but not for the purpose of expressing an opinion on the effectiveness of the Trust’s internal control over financial reporting. Accordingly, we express no such opinion.

Our audits included performing procedures to assess the risks of material misstatement of the financial statements, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements. Our procedures included confirmation of securities owned as of October 31, 2019, by correspondence with the custodian and brokers or by other appropriate auditing procedures where replies from brokers were not received. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements. We believe that our audits provide a reasonable basis for our opinion.

We have served as the auditor of one or more Investec Asset Management North America, Inc. investment companies since 2017.

Philadelphia, Pennsylvania

December 30, 2019

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DISCLOSURE OF FUND EXPENSES (Unaudited)

All mutual funds have operating expenses. As a shareholder of a mutual fund, your investment is affected by these ongoing costs, which include (among others) costs for Fund management, administrative services, and shareholder reports like this one. It is important for you to understand the impact of these costs on your investment returns.

Operating expenses such as these are deducted from the mutual fund’s gross income and directly reduce your final investment return. These expenses are expressed as a percentage of the mutual fund’s average net assets; this percentage is known as the mutual fund’s expense ratio.

The following examples use the expense ratio and are intended to help you understand the ongoing costs (in dollars) of investing in your Fund and to compare these costs with those of other mutual funds. The examples are based on an investment of $1,000 made at the beginning of the period shown and held for the entire period from May 1, 2019 to October 31, 2019.

The table on the next page illustrates your Fund’s costs in two ways:

• Actual Fund Return. This section helps you to estimate the actual expenses after fee waivers that your Fund incurred over the period. The “Expenses Paid During Period” column shows the actual dollar expense cost incurred by a $1,000 investment in the Fund, and the “Ending Account Value” number is derived from deducting that expense cost from the Fund’s gross investment return.

You can use this information, together with the actual amount you invested in the Fund, to estimate the expenses you paid over that period. Simply divide your ending starting account value by $1,000 to arrive at a ratio (for example, an $8,600 account value divided by $1,000 = 8.6), then multiply that ratio by the number shown for your Fund under “Expenses Paid During Period.”

• Hypothetical 5% Return. This section helps you compare your Fund’s costs with those of other mutual funds. It assumes that the Fund had an annual 5% return before expenses during the year, but that the expense ratio (Column 3) for the period is unchanged. This example is useful in making comparisons because the Securities and Exchange Commission requires all mutual funds to make this 5% calculation. You can assess your Fund’s comparative cost by comparing the hypothetical result for your Fund in the “Expenses Paid During Period” column with those that appear in the same charts in the shareholder reports for other mutual funds.

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Note: Because the return is set at 5% for comparison purposes — NOT your Fund’s actual return — the account values shown may not apply to your specific investment.

	Beginning Account Value 5/01/19		Ending Account Value 10/31/19		Annualized Expense Ratios			Expenses Paid During Period*
Investec Global Franchise Fund — I Shares
Actual Fund Return		$1,000.00		$1,029.10		0.85	%		$4.35
Hypothetical 5% Return		1,000.00		1,020.92		0.85			4.33
Investec Global Franchise Fund — A Shares
Actual Fund Return		$1,000.00		$1,027.40		1.10	%		$5.62
Hypothetical 5% Return		1,000.00		1,019.66		1.10			5.60
Investec Emerging Markets Equity Fund — I Shares
Actual Fund Return		$1,000.00		$989.80		0.85	%		$4.26
Hypothetical 5% Return		1,000.00		1,020.92		0.85			4.33
Investec Emerging Markets Equity Fund — A Shares
Actual Fund Return		$1,000.00		$988.90		1.10	%		$5.51
Hypothetical 5% Return		1,000.00		1,019.66		1.10			5.60

* Expenses are equal to the Fund’s annualized expense ratio, multiplied by the average account value over the period, multiplied by 184/365 (to reflect the one-half year period shown).

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 TRUSTEES AND OFFICERS OF THE ADVISORS’ INNER CIRCLE FUND III (Unaudited)

Set forth below are the names, years of birth, positions with the Trust, length of term of office, and the principal occupations for the last five years of each of the persons currently serving as Trustees and Officers of the Trust. Unless otherwise noted, the business address of each Trustee is SEI Investments Company, 1 Freedom Valley Drive, Oaks

Name and Year of Birth	Position with Trust and length of Time Served1	Principal Occupation in the Past Five Years
INTERESTED TRUSTEES2 3
William M. Doran (Born: 1940)	Chairman of Board of Trustees (Since 2014)	Self-Employed Consultant since 2003. Partner at Morgan, Lewis & Bockius LLP (law firm) from 1976 to 2003. Counsel to the Trust, SEI Investments, SIMC, the Administrator and the Distributor. Secretary of SEI Investments since 1978.
INDEPENDENT TRUSTEES3
Jon C. Hunt (Born: 1951)	Trustee and Lead Independent Trustee (since 2014)	Retired since 2013. Consultant to Management, Convergent Capital Management, LLC (“CCM”) from 2012 to 2013. Managing Director and Chief Operating Officer, CCM from 1998 to 2012.
Thomas P. Lemke (Born: 1954)	Trustee (Since 2014)	Retired since 2013. Executive Vice President and General Counsel, Legg Mason, Inc. from 2005 to 2013.

1 Each Trustee shall hold office during the lifetime of this Trust until the election and qualification of his or her successor, or until he or she sooner dies, resigns, or is removed in accordance with the Trust’s Declaration of Trust.

2 Denotes Trustees who may be deemed to be “interested” persons of the Fund as that term is defined in the 1940 Act by virtue of their affiliation with the Distributor and/or its affiliates.

3 Trustees oversee 30 funds in The Advisors’ Inner Circle Fund III.

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Pennsylvania 19456. Trustees who are deemed not to be “interested persons” of the Trust are referred to as “Independent Trustees.” Mr. Doran is a Trustee who may be deemed to be an “interested” person of the Trust as that term is defined in the 1940 Act by virtue of their affiliation with the Trust’s Distributor. The Trust’s Statement of Additional Information (“SAI”) includes additional information about the Trustees and Officers. The SAI may be obtained without charge by calling 1-844-IAM-USA1. The following chart lists Trustees and Officers as of October 31, 2019.

Other Directorships Held in the Past Five Years⁴

Current Directorships: Trustee of Gallery Trust, Schroder Series Trust, Schroder Global Series Trust, SEI Daily Income Trust, SEI Institutional International Trust, SEI Institutional Investments Trust, SEI Institutional Managed Trust, SEI Asset Allocation Trust, SEI Tax Exempt Trust, Adviser Managed Trust, New Covenant Funds, SEI Insurance Products Trust and SEI Catholic Values Trust. Director of SEI Investments, SEI Investments (Europe), Limited, SEI Investments—Global Funds Services, Limited, SEI Investments Global, Limited, SEI Investments (Asia), Limited, SEI Global Nominee Ltd., SEI Investments – Unit Trust Management (UK) Limited and SEI Investments Co. Director of the Distributor.

Former Directorships: Trustee of O’Connor EQUUS (closed-end investment company) to 2016. Trustee of SEI Liquid Asset Trust to 2016. Trustee of Winton Series Trust to 2017. Trustee of The Advisors’ Inner Circle Fund, The Advisors’ Inner Circle Fund II, Bishop Street Funds, The KP Funds and Winton Diversified Opportunities Fund (closed-end investment company) to 2018.

Current Directorships: Trustee of City National Rochdale Funds, Gallery Trust, Schroder Series Trust and Schroder Global Series Trust.

Former Directorships: Trustee of O’Connor EQUUS (closed-end investment company) to 2016. Member of Independent Committee of Nuveen Commodities Asset Management to 2016. Trustee of Winton Series Trust to 2017. Trustee of Winton Diversified Opportunities Fund (closed-end investment company) to 2018.

4 Directorships of Companies required to report to the Securities and Exchange Commission under the Securities Exchange act of 1934 (i.e., “public companies) or other investment companies under the 1940 Act.

49

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

Name and Year of Birth	Position with the Trust and Length of Time Served1	Principal Occupation During the Past Five Years
INDEPENDENT TRUSTEES (continued)2
Jay C. Nadel (Born: 1958)	Trustee (Since 2016)	Self-Employed Consultant since 2004. Executive Vice President, Bank of New York Broker Dealer from 2002 to 2004. Partner/Managing Director, Weiss Peck & Greer/Robeco from 1986 to 2001.
Randall S. Yanker (Born: 1960)	Trustee (Since 2014)	Co-Founder and Senior Partner, Alternative Asset Managers, L.P. since 2004.
OFFICERS
Michael Beattie (Born: 1965)	President (Since 2014)	Director of Client Service, SEI Investments Company, since 2004.
James Bernstein (Born: 1962)	Vice President and Assistant Secretary (since 2017)	Attorney, SEI Investments, since 2017. Prior Positions: Self-employed consultant, 2017. Associate General Counsel & Vice President, Nationwide Funds Group and Nationwide Mutual Insurance Company, from 2002 to 2016. Assistant General Counsel & Vice President, Market Street Funds and Provident Mutual Insurance Company, from 1999 to 2002.
John Bourgeois (Born: 1973)	Assistant Treasurer (since 2017)	Fund Accounting Manager, SEI Investments, since 2000.
Stephen Connors (Born: 1984)	Treasurer, Controller and Chief Financial Officer (Since 2015)	Director, SEI Investments, Fund Accounting, since 2014. Audit Manager, Deloitte & Touche LLP, from 2011 to 2014.

1 Each Trustee shall hold office during the lifetime of this Trust until the election and qualification of his or her successor, or until he or she sooner dies, resigns, or is removed in accordance with the Trust’s Declaration of Trust.

2 Trustees oversee 30 funds in The Advisors’ Inner Circle Fund III.

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THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

Other Directorships

Held in the Past Five Years³

Current Directorships: Trustee of City National Rochdale Funds, Gallery Trust, Schroder Series Trust and Schroder Global Series Trust.

Former Directorships: Trustee of Winton Series Trust to 2017. Director of Lapolla Industries, Inc. to 2017. Trustee of Winton Diversified Opportunities Fund (closed-end investment company) to 2018.

Current Directorships: Trustee of Gallery Trust, Schroder Series Trust and Schroder Global Series Trust. Independent Non-Executive Director of HFA Holdings Limited.

Former Directorships: Trustee of O’Connor EQUUS (closed-end investment company) to 2016. Trustee of Winton Series Trust to 2017. Trustee of Winton Diversified Opportunities Fund (closed-end investment company) to 2018.

None.

None.

None.

None.

3 Directorships of Companies required to report to the Securities and Exchange Commission under the Securities Exchange act of 1934 (i.e., “public companies) or other investment companies under the 1940 Act.

51

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

Name and Year of Birth	Position with Trust and Length of Time Served	Principal Occupation During the Past Five Years
OFFICERS (continued)
Dianne M. Descoteaux (Born: 1977)	Vice President and Secretary (since 2014)	Counsel at SEI Investments since 2010. Associate at Morgan, Lewis & Bockius LLP, from 2006 to 2010.
Russell Emery (Born: 1962)	Chief Compliance Officer (since 2014)	Chief Compliance Officer of SEI Structured Credit Fund, LP since 2007. Chief Compliance Officer of The Advisors’ Inner Circle Fund, The Advisors’ Inner Circle Fund II, Bishop Street Funds, The KP Funds, The Advisors’ Inner Circle Fund III, Gallery Trust, Schroder Series Trust, Schroder Global Series Trust, SEI Institutional Managed Trust, SEI Asset Allocation Trust, SEI Institutional International Trust, SEI Institutional Investments Trust, SEI Daily Income Trust, SEI Tax Exempt Trust, Adviser Managed Trust, New Covenant Funds, SEI Insurance Products Trust and SEI Catholic Values Trust. Chief Compliance Officer of O’Connor EQUUS (closed-end investment company) to 2016. Chief Compliance Officer of SEI Liquid Asset Trust to 2016. Chief Compliance Officer of Winton Series Trust to 2017. Chief Compliance Officer of Winton Diversified Opportunities Fund (closed-end investment company) to 2018.
Matthew M. Maher (Born: 1975)	Vice President and Assistant Secretary (since 2018)	Counsel at SEI Investments since 2018. Attorney, Blank Rome LLP, from 2015 to 2018. Assistant Counsel & Vice President, Bank of New York Mellon, from 2013 to 2014. Attorney, Dilworth Paxson LLP, from 2006 to 2013.
Robert Morrow (Born: 1968)	Vice President (since 2017)	Account Manager, SEI Investments, since 2007.
Bridget E. Sudall (Born: 1980)	Privacy Officer (since 2015) Anti-Money Laundering Officer (since 2015)	Senior Associate and AML Officer, Morgan Stanley Alternative Investment Partners, from 2011 to 2015. Investor Services Team Lead, Morgan Stanley Alternative Investment Partners, from 2007 to 2011.

52

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

Other Directorships

Held in the Past Five Years

None.

None.

None.

None.

None.

53

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

APPROVAL OF INVESTMENT ADVISORY AGREEMENT

Pursuant to Section 15 of the Investment Company Act of 1940 (the “1940 Act”), the Funds’ advisory agreement (the “Agreement”) must be renewed at least annually after its initial two-year term: (i) by the vote of the Board of Trustees (the “Board” or the “Trustees”) of The Advisors’ Inner Circle Fund III (the “Trust”) or by a vote of a majority of the shareholders of the Funds; and (ii) by the vote of a majority of the Trustees who are not parties to the Agreement or “interested persons” of any party thereto, as defined in the 1940 Act (the “Independent Trustees”), cast in person at a meeting called for the purpose of voting on such renewal.

A Board meeting was held on June 27, 2019 to decide whether to renew the Agreement for an additional one-year term. In preparation for the meeting, the Trustees requested that the Adviser furnish information necessary to evaluate the terms of the Agreement. Prior to the meeting, the Independent Trustees of the Funds met to review and discuss the information provided and submitted a request for additional information to the Adviser, and information was provided in response to this request. The Trustees used this information, as well as other information that the Adviser and other service providers of the Funds presented or submitted to the Board at the meeting and other meetings held during the prior year, to help them decide whether to renew the Agreement for an additional year.

Specifically, the Board requested and received written materials from the Adviser and other service providers of the Funds regarding: (i) the nature, extent and quality of the Adviser’s services; (ii) the Adviser’s investment management personnel; (iii) the Adviser’s operations and financial condition; (iv) the Adviser’s brokerage practices (including any soft dollar arrangements) and investment strategies; (v) the Funds’ advisory fees paid to the Adviser and overall fees and operating expenses compared with peer groups of mutual funds; (vi) the level of the Adviser’s profitability from its relationship with the Funds, including both direct and indirect benefits accruing to the Adviser and its affiliates; (vii) the Adviser’s potential economies of scale; (viii) the Adviser’s compliance program, including a description of material compliance matters and material compliance violations; (ix) the Adviser’s policies on and compliance procedures for personal securities transactions; and (x) the Funds’ performance compared with peer groups of mutual funds and the Funds’ benchmark indices.

Representatives from the Adviser, along with other Fund service providers, presented additional information and participated in question and answer sessions at the Board meeting to help the Trustees evaluate the Adviser’s services, fees and other aspects of the Agreement. The Independent Trustees received advice from independent counsel and met in executive sessions outside the presence of Fund management and the Adviser.

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THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

At the Board meeting, the Trustees, including all of the Independent Trustees, based on their evaluation of the information provided by the Adviser and other service providers of the Funds, renewed the Agreement. In considering the renewal of the Agreement, the Board considered various factors that they determined were relevant, including: (i) the nature, extent and quality of the services provided by the Adviser; (ii) the investment performance of the Funds and the Adviser; (iii) the costs of the services provided and profits realized by the Adviser from its relationship with the Funds, including both direct and indirect benefits accruing to the Adviser and its affiliates; (iv) the extent to which economies of scale are being realized by the Adviser; and (v) whether fee levels reflect such economies of scale for the benefit of Fund investors, as discussed in further detail below.

Nature, Extent and Quality of Services Provided by the Adviser

In considering the nature, extent and quality of the services provided by the Adviser, the Board reviewed the portfolio management services provided by the Adviser to the Funds, including the quality and continuity of the Adviser’s portfolio management personnel, the resources of the Adviser, and the Adviser’s compliance history and compliance program. The Trustees reviewed the terms of the Agreement. The Trustees also reviewed the Adviser’s investment and risk management approaches for the Funds. The most recent investment adviser registration form (“Form ADV”) for the Adviser was available to the Board, as was the response of the Adviser to a detailed series of questions which included, among other things, information about the investment advisory services provided by the Adviser to the Funds.

The Trustees also considered other services provided to the Funds by the Adviser such as selecting broker-dealers for executing portfolio transactions, monitoring adherence to the Funds’ investment restrictions, and monitoring compliance with various Fund policies and procedures and with applicable securities laws and regulations. Based on the factors above, as well as those discussed below, the Board concluded, within the context of its full deliberations, that the nature, extent and quality of the services provided to the Funds by the Adviser were sufficient to support renewal of the Agreement.

Investment Performance of the Funds and the Adviser

The Board was provided with regular reports regarding the Funds’ performance over various time periods. The Trustees also reviewed reports prepared by the Funds’ administrator comparing the Funds’ performance to their benchmark indices and peer groups of mutual funds as classified by Lipper, an independent provider of investment company data, over various periods of time.

55

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

Representatives from the Adviser provided information regarding and led discussions of factors impacting the performance of the Funds, outlining current market conditions and explaining their expectations and strategies for the future. The Trustees determined that the Funds’ performance was satisfactory, or, where the Funds’ performance was materially below their benchmarks and/or peer groups, the Trustees were satisfied by the reasons for the underperformance and/or the steps taken by the Adviser in an effort to improve the performance of the Funds. Based on this information, the Board concluded, within the context of its full deliberations, that the investment results that the Adviser had been able to achieve for the Funds were sufficient to support renewal of the Agreement.

Costs of Advisory Services, Profitability and Economies of Scale

In considering the advisory fees payable by the Funds to the Adviser, the Trustees reviewed, among other things, a report of the advisory fees paid to the Adviser. The Trustees also reviewed reports prepared by the Funds’ administrator comparing the Funds’ net and gross expense ratios and advisory fees to those paid by peer groups of mutual funds as classified by Lipper. The Trustees reviewed the management fees charged by the Adviser to other clients with comparable mandates to the Investec Emerging Markets Equity Fund. The Trustees considered any differences in management fees and took into account the respective demands, resources and complexity associated with the Investec Emerging Markets Equity Fund and other client accounts as well as the extensive regulatory, compliance and tax regimes to which the Investec Emerging Markets Equity Fund is subject. The Board concluded, within the context of its full deliberations, that the advisory fees were reasonable in light of the nature and quality of the services rendered by the Adviser.

The Trustees reviewed the costs of services provided by and the profits realized by the Adviser from its relationship with the Funds, including both direct benefits and indirect benefits, such as research and brokerage services received under soft dollar arrangements, accruing to the Adviser and its affiliates. The Trustees considered how the Adviser’s profitability was affected by factors such as its organizational structure and method for allocating expenses. The Trustees concluded that the profit margins of the Adviser with respect to the management of the Funds were not unreasonable. The Board also considered the Adviser’s commitment to managing the Funds and its willingness to continue its expense limitation and fee waiver arrangement with the Funds.

The Trustees considered the Adviser’s views relating to economies of scale in connection with the Funds as Fund assets grow and the extent to which the benefits of any such economies of scale are shared with the Funds and Fund shareholders. The Board considered the existence of any economies of scale and

56

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

whether those were passed along to the Funds’ shareholders through a graduated advisory fee schedule or other means, including fee waivers. The Trustees recognized that economies of scale are difficult to identify and quantify and are rarely identifiable on a fund-by-fund basis. Based on this evaluation, the Board concluded that the advisory fee was reasonable in light of the information that was provided to the Trustees by the Adviser with respect to economies of scale.

Renewal of the Agreement

Based on the Board’s deliberations and its evaluation of the information described above and other factors and information it believed relevant in the exercise of its reasonable business judgment, the Board, including all of the Independent Trustees, with the assistance of Fund counsel and Independent Trustees’ counsel, unanimously concluded that the terms of the Agreement, including the fees payable thereunder, were fair and reasonable and agreed to renew the Agreement for another year. In its deliberations, the Board did not identify any absence of information as material to its decision, or any particular factor (or conclusion with respect thereto) or single piece of information that was all-important, controlling or determinative of its decision, but considered all of the factors together, and each Trustee may have attributed different weights to the various factors (and conclusions with respect thereto) and information.

57

THE ADVISORS’ INNER CIRCLE FUND III INVESTEC FUNDS OCTOBER 31, 2019

NOTICE TO SHAREHOLDERS (Unaudited)

For shareholders that do not have an October 31, 2019 tax year end, this notice is for informational purposes only. For shareholders with an October 31, 2019 tax year end, please consult your tax advisor as to the pertinence of this notice. For the fiscal period ended October 31, 2019, the Funds are designating the following items with regard to distributions paid during the period.

	Long-Term Capital Gain Distributions			Ordinary Income Distributions			Total Distributions			Qualifying for Corporate Dividends Received Deduction (1)			Qualifying Dividend Income (2)
Investec Global Franchise Fund		0.00	%		100.00	%		100.00	%		89.26	%		100.00	%
Investec Emerging Markets Equity Fund		0.00	%		100.00	%		100.00	%		1.24	%		58.79	%
	U.S. Government Interest (3)			Interest Related Dividends (4)			Short-Term Capital Gain Dividends (5)			Qualifying Business Income (6)			Foreign Tax Credit
Investec Global Franchise Fund		0.00	%		0.00	%		0.00	%		0.00	%		0.00	%
Investec Emerging Markets Equity Fund		0.00	%		0.00	%		0.00	%		0.00	%		69.18	% (7)

(1) Qualifying dividends represent dividends which qualify for the corporate dividends received deduction and is reflected as a percentage of ordinary income distributions (the total of short-term capital gain and net investment income distributions).

(2) The percentage in this column represents the amount of “Qualifying Dividend Income” as created by the Jobs and Growth Tax Relief Reconciliation Act of 2003 and is reflected as a percentage of ordinary income distributions (the total of short-term capital gain and net investment income distributions). It is the intention of the Fund to designate the maximum amount permitted by law.

(3) “U.S. Government Interest” represents the amount of interest that was derived from direct U.S. Government obligations and distributed during the fiscal year. This amount is reflected as a percentage of ordinary income. Generally, interest from direct U.S. Government obligations is exempt from state income tax. However, for shareholders of the Fund who are residents of California, Connecticut and New York, the statutory threshold requirements were not satisfied to permit exemption of these amounts from state income.

(4) The percentage in this column represents the amount of “Interest Related Dividends” and is reflected as a percentage of ordinary income distributions. Interest related dividends are exempted from U.S. withholding tax when paid to foreign investors.

(5) The percentage in this column represents the amount of “Short-Term Capital Gain Dividends” and is reflected as a percentage of short-term capital gain distributions that is exempted from U.S. withholding tax when paid to foreign investors.

(6) The percentage in this column represents the amount of ordinary income that qualified for 20% Business Income Deduction.

(7) The percentage in this column represents the amount of “Qualifying Foreign Taxes” as a percentage of ordinary distributions during the fiscal year ended October 31, 2019 amounting to $116,864 are expected to be passed through to the shareholders as foreign tax credits on Form 1099-DIV for the year ending December 31, 2019, which shareholders of the Fund will receive in late January, 2020. In addition, for the fiscal year ended October 31, 2019, gross foreign source income amounted to $1,392,115 for the Fund.

The information reported herein may differ from the information and distributions taxable to the shareholders for the calendar year ending December 31, 2019. Complete information will be computed and reported in conjunction with your 2019 Form 1099-DIV.

58

Investec Global Franchise Fund

P.O. Box 219009

Kansas City, MO 64121-9009

1-844-IAM-USA1

Investment Adviser:

Investec Asset Management North America, Inc.

666 Fifth Avenue, 37th Floor

New York, NY 10103

Administrator:

SEI Investments Global Funds Services

One Freedom Valley Drive

Oaks, PA 19456

Distributor:

SEI Investments Distribution Co.

One Freedom Valley Drive

Oaks, PA 19456

Legal Counsel:

Morgan, Lewis & Bockius LLP

1701 Market Street

Philadelphia, PA 19103

This information must be preceded or accompanied by a current prospectus for the Fund described.

INV-AR-001-0200

Item 2. Code of Ethics.

The Registrant has adopted a code of ethics that applies to the Registrant’s principal executive officer, principal financial officer, controller or principal accounting officer, and any person who performs a similar function. There have been no amendments to or waivers granted to this code of ethics during the period covered by this report.

Item 3. Audit Committee Financial Expert.

(a)(1) The Registrant’s board of trustees has determined that the Registrant has at least one audit committee financial expert serving on the audit committee.

(a)(2) The Registrant’s audit committee financial experts are Thomas P. Lemke and Jay Nadel, and each of Mr. Lemke and Mr. Nadel is “independent” as that term is defined in Form N-CSR Item 3 (a)(2).

Item 4. Principal Accountant Fees and Services.

Fees billed by PricewaterhouseCoopers LLP (“PwC”) relate to The Advisors’ Inner Circle Fund III (the “Trust”).

PwC billed the Trust aggregate fees for services rendered to the Trust for the last two fiscal years as follows:

		2019			2018
		All fees and services to the Trust that were pre- approved	All fees and services to service affiliates that were pre- approved	All other fees and services to service affiliates that did not require pre- approval	All fees and services to the Trust that were pre- approved	All fees and services to service affiliates that were pre- approved	All other fees and services to service affiliates that did not require pre- approval
(a)	Audit Fees(1)	$530,415	None	None	$378,215	None	None
(b)	Audit-Related Fees	None	None	None	None	None	None
(c)	Tax Fees(2)	None	None	$78,700	None	None	$60,000
(d)	All Other Fees	None	None	$11,800	None	None	$10,000

Fees billed by Ernst & Young LLP (“E&Y”) relate to the Trust

E&Y billed the Trust aggregate fees for services rendered to the Trust for the last two fiscal years as follows:

		2019			2018
		All fees and services to the Trust that were pre- approved	All fees and services to service affiliates that were pre- approved	All other fees and services to service affiliates that did not require pre- approval	All fees and services to the Trust that were pre- approved	All fees and services to service affiliates that were pre- approved	All other fees and services to service affiliates that did not require pre- approval
(a)	Audit Fees(1)	$56,231	None	None	$82,560	None	None
(b)	Audit-Related Fees	None	None	None	None	None	None
(c)	Tax Fees	None	None	None	None	None	None
(d)	All Other Fees	None	None	None	None	None	None

Fees billed by Deloitte & Touche LLP (“D&T”) relate to the Trust

D&T billed the Trust aggregate fees for services rendered to the Trust for the last two fiscal years as follows

		2019			2018
		All fees and services to the Trust that were pre- approved	All fees and services to service affiliates that were pre- approved	All other fees and services to service affiliates that did not require pre- approval	All fees and services to the Trust that were pre- approved	All fees and services to service affiliates that were pre- approved	All other fees and services to service affiliates that did not require pre- approval
(a)	Audit Fees(1)	$63,500	None	None	$63,500	None	None
(b)	Audit-Related Fees	None	None	None	None	None	None
(c)	Tax Fees	None	None	None	None	None	None
(d)	All Other Fees	None	None	None	None	None	None

Notes:

(1) Audit fees include amounts related to the audit of the Trust’s annual financial statements and services normally provided by the accountant in connection with statutory and regulatory filings.

(2) Tax return preparation fees for affiliates of the Funds.

(e)(1) The Trust’s Audit Committee has adopted and the Board of Trustees has ratified an Audit and Non-Audit Services Pre-Approval Policy (the “Policy”), which sets forth the procedures and the conditions pursuant to which services proposed to be performed by the independent auditor of the Funds may be pre-approved.

The Policy provides that all requests or applications for proposed services to be provided by the independent auditor must be submitted to the Registrant’s Chief Financial Officer (“CFO”) and must include a detailed description of the services proposed to be rendered. The CFO will determine whether such services:

(1) require specific pre-approval;

(2) are included within the list of services that have received the general pre-approval of the Audit Committee pursuant to the Policy; or

(3) have been previously pre-approved in connection with the independent auditor’s annual engagement letter for the applicable year or otherwise. In any instance where services require pre-approval, the Audit Committee will consider whether such services are consistent with SEC’s rules and whether the provision of such services would impair the auditor’s independence.

Requests or applications to provide services that require specific pre-approval by the Audit Committee will be submitted to the Audit Committee by the CFO. The Audit Committee will be informed by the CFO on a quarterly basis of all services rendered by the independent auditor. The Audit Committee has delegated specific pre-approval authority to either the Audit Committee Chair or financial expert, provided that the estimated fee for any such proposed pre-approved service does not exceed $100,000 and any pre-approval decisions are reported to the Audit Committee at its next regularly-scheduled meeting.

Services that have received the general pre-approval of the Audit Committee are identified and described in the Policy. In addition, the Policy sets forth a maximum fee per engagement with respect to each identified service that has received general pre-approval.

All services to be provided by the independent auditor shall be provided pursuant to a signed written engagement letter with the Registrant, the investment adviser, or applicable control affiliate (except that matters as to which an engagement letter would be impractical because of timing issues or because the matter is small may not be the subject of an engagement letter) that sets forth both the services to be provided by the independent auditor and the total fees to be paid to the independent auditor for those services.

In addition, the Audit Committee has determined to take additional measures on an annual basis to meet the Audit Committee’s responsibility to oversee the work of the independent auditor and to assure the auditor’s independence from the Registrant, such as (a) reviewing a formal written statement from the independent auditor delineating all relationships between the independent auditor and the Registrant, and (b) discussing with the independent auditor the independent auditor’s methods and procedures for ensuring independence.

(e)(2) Percentage of fees billed applicable to non-audit services pursuant to waiver of pre-approval requirement were as follows (PwC):

	2019	2018
Audit-Related Fees	None	None
Tax Fees	None	None
All Other Fees	None	None

(e)(2) Percentage of fees billed applicable to non-audit services pursuant to waiver of pre-approval requirement were as follows (E&Y):

	2019	2018
Audit-Related Fees	None	None
Tax Fees	None	None
All Other Fees	None	None

(e)(2) Percentage of fees billed applicable to non-audit services pursuant to waiver of pre-approval requirement were as follows (D&T):

	2019	2018
Audit-Related Fees	None	None
Tax Fees	None	None
All Other Fees	None	None

(f) Not applicable.

(g) The aggregate non-audit fees and services billed by PwC for services rendered to the Registrant, and rendered to the Registrant’s investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the adviser that provides ongoing services to the Registrant for the last two fiscal-years-ended October 31^st were $90,500 and $70,000 for 2019 and 2018, respectively.

(g) The aggregate non-audit fees and services billed by E&Y for services rendered to the Registrant, and rendered to the Registrant’s investment adviser (not including any sub-adviser whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the adviser that provides ongoing services to the Registrant for the last two fiscal-years-ended October 31^st were $0 and $0 for 2019 and 2018, respectively.

(g) The aggregate non-audit fees and services billed by D&T for services rendered to the Registrant, and rendered to the Registrant’s investment adviser (not including any sub-adviser

whose role is primarily portfolio management and is subcontracted with or overseen by another investment adviser), and any entity controlling, controlled by, or under common control with the adviser that provides ongoing services to the Registrant for the last two fiscal-years-ended October 31^st were $0 and $0 for 2019 and 2018, respectively.

(h) During the past fiscal year, all non-audit services provided by the Registrant’s principal accountant to either the Registrant’s investment adviser or to any entity controlling, controlled by, or under common control with the Registrant’s investment adviser that provides ongoing services to the Registrant were pre-approved by the Audit Committee of Registrant’s Board of Trustees. Included in the Audit Committee’s pre-approval was the review and consideration as to whether the provision of these non-audit services is compatible with maintaining the principal accountant’s independence.

Item 5. Audit Committee of Listed Registrants.

Not applicable to open-end management investment companies.

Item 6. Schedule of Investments.

Schedule of Investments is included as part of the Report to Shareholders filed under Item 1 of this form.

Item 7. Disclosure of Proxy Voting Policies and Procedures for Closed-End Management Investment Companies.

Not applicable to open-end management investment companies.

Item 8. Portfolio Managers of Closed-End Management Investment Companies.

Not applicable to open-end management investment companies. Effective for closed-end management investment companies for fiscal-years-ending on or after December 31, 2005.

Item 9. Purchases of Equity Securities by Closed-End Management Company and Affiliated Purchasers.

Not applicable to open-end management investment companies.

Item 10. Submission of Matters to a Vote of Security Holders.

There have been no changes to the procedures by which shareholders may recommend nominees to the Registrant’s Board of Trustees during the period covered by this report.

Item 11. Controls and Procedures.

(a) The Registrant’s principal executive and principal financial officers, or persons performing similar functions, have concluded that the Registrant’s disclosure controls and procedures, as defined in Rule 30a-3(c) under the Act (17 CFR § 270.30a-3(c)), as of a date within 90 days of the filing date of the report, are effective based on the evaluation of these controls and procedures required by Rule 30a-3(b) under the Act (17 CFR § 270.30a-3(b)) and Rules 13a-15(b) or 15d-15(b) under the Securities Exchange Act, as amended (17 CFR § 270.30a-15(b) or § 240.15d-15(b)).

(b) There has been no change in the Registrant’s internal control over financial reporting (as defined in Rule 30a-3(d) under the Act (17 CFR § 270.3a-3(d)) that occurred during the second fiscal quarter of the period covered by this report that has materially affected, or is reasonably likely to materially affect, the Registrant’s internal control over financial reporting.

Items 12. Disclosure of Securities Lending Activities for Closed-End Management Investment Companies.

Not applicable to open-end management investment companies.

Items 13. Exhibits.

(a)(1) A copy of the Registrant’s Code of Ethics, as required by Item 2 of this Form, accompanies this filing as an exhibit.

(a)(2) A separate certification for the principal executive officer and the principal financial officer of the Registrant, as required by Rule 30a-2(a) under the Act (17 CFR § 270.30a-2(a)), is filed herewith.

(b) Officer certifications, as required by Rule 30a-2(b) under the Act (17 CFR § 270.30a-2(b)), also accompany this filing as an exhibit.

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, the Registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

(Registrant)	The Advisors’ Inner Circle Fund III
By (Signature and Title)*	/s/ Michael Beattie
	Michael Beattie, President

Date: January 8, 2020

Pursuant to the requirements of the Securities Exchange Act of 1934 and the Investment Company Act of 1940, this report has been signed below by the following persons on behalf of the registrant and in the capacities and on the dates indicated.

By (Signature and Title)*	/s/ Michael Beattie
	Michael Beattie, President

Date: January 8, 2020

By (Signature and Title)*	/s/ Stephen Connors
	Stephen Connors,
	Treasurer, Controller, and CFO

Date: January 8, 2020

* Print the name and title of each signing officer under his or her signature.