N-CSR 1 d291484dncsr.htm GREATER INDIA PORTFOLIO Greater India Portfolio

 

 

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: 811-08340

 

 

Greater India Portfolio

(Exact Name of Registrant as Specified in Charter)

 

 

Two International Place, Boston, Massachusetts 02110

(Address of Principal Executive Offices)

 

 

Deidre E. Walsh

Two International Place, Boston, Massachusetts 02110

(Name and Address of Agent for Services)

 

 

(617) 482-8260

(Registrant’s Telephone Number)

December 31

Date of Fiscal Year End

December 31, 2021

Date of Reporting Period

 

 

 


Item 1. Reports to Stockholders


Greater India Portfolio

December 31, 2021

 

Portfolio of Investments

 

 

Common Stocks — 104.2%

 

Security   Shares     Value  
India — 104.2%  
Auto Components — 2.6%  

Sona BLW Precision Forgings, Ltd.(1)(2)

    415,081     $ 4,102,068  

Sundram Fasteners, Ltd.

    131,433       1,599,376  

Tube Investments of India, Ltd.

    77,320       1,812,713  
      $ 7,514,157  
Automobiles — 4.2%  

Maruti Suzuki India, Ltd.

    62,212     $ 6,188,318  

Tata Motors, Ltd.(1)

    894,315       5,769,753  
      $ 11,958,071  
Banks — 19.8%  

Axis Bank, Ltd.(1)

    1,444,036     $ 13,147,471  

Federal Bank, Ltd.

    1,650,418       1,836,587  

ICICI Bank, Ltd.

    2,774,975       27,610,123  

Kotak Mahindra Bank, Ltd.

    260,217       6,269,564  

State Bank of India

    1,175,326       7,248,211  
      $ 56,111,956  
Beverages — 1.6%  

United Spirits, Ltd.(1)

    379,718     $ 4,578,148  
      $ 4,578,148  
Building Products — 0.5%  

Kajaria Ceramics, Ltd.

    85,334     $ 1,472,966  
      $ 1,472,966  
Chemicals — 1.4%  

Atul, Ltd.

    11,387     $ 1,382,409  

Navin Fluorine International, Ltd.

    46,183       2,590,000  
      $ 3,972,409  
Construction & Engineering — 1.4%  

Voltas, Ltd.

    241,374     $ 3,954,460  
      $ 3,954,460  
Construction Materials — 3.2%  

JK Cement, Ltd.

    32,085     $ 1,450,710  

UltraTech Cement, Ltd.

    76,049       7,758,499  
      $ 9,209,209  
Security   Shares     Value  
Consumer Finance — 1.0%  

Mahindra & Mahindra Financial Services, Ltd.

    594,130     $ 1,187,886  

SBI Cards & Payment Services, Ltd.(1)

    139,222       1,735,098  
      $ 2,922,984  
Diversified Financial Services — 2.3%  

Bajaj Finserv, Ltd.

    29,338     $ 6,467,048  
      $ 6,467,048  
Diversified Telecommunication Services — 1.0%  

Tata Communications, Ltd.

    144,613     $ 2,841,877  
      $ 2,841,877  
Electric Utilities — 1.2%  

Tata Power Co., Ltd. (The)

    1,143,921     $ 3,387,893  
      $ 3,387,893  
Electronic Equipment, Instruments & Components — 0.6%  

Honeywell Automation India, Ltd.

    3,034     $ 1,709,922  
      $ 1,709,922  
Food & Staples Retailing — 3.1%  

Avenue Supermarts, Ltd.(1)(2)

    114,303     $ 7,160,117  

Medplus Health Services, Ltd.(1)

    109,235       1,516,360  
      $ 8,676,477  
Food Products — 1.6%  

Tata Consumer Products, Ltd.

    467,358     $ 4,663,400  
      $ 4,663,400  
Gas Utilities — 0.7%  

Gujarat Gas, Ltd.

    225,147     $ 1,917,049  
      $ 1,917,049  
Health Care Providers & Services — 1.3%  

Apollo Hospitals Enterprise, Ltd.

    56,116     $ 3,786,037  
      $ 3,786,037  
Hotels, Restaurants & Leisure — 1.9%  

Devyani International, Ltd.(1)

    578,588     $ 1,277,847  

Jubilant FoodWorks, Ltd.

    88,553       4,260,265  
      $ 5,538,112  
 

 

  21   See Notes to Financial Statements.


Greater India Portfolio

December 31, 2021

 

Portfolio of Investments — continued

 

 

Security   Shares     Value  
Household Durables — 2.0%  

Crompton Greaves Consumer Electricals, Ltd.

    641,357     $ 3,759,376  

Dixon Technologies India, Ltd.

    26,438       1,954,800  
      $ 5,714,176  
Insurance — 3.3%  

ICICI Lombard General Insurance Co., Ltd.(2)

    165,875     $ 3,117,268  

SBI Life Insurance Co., Ltd.(2)

    394,005       6,312,612  
      $ 9,429,880  
Interactive Media & Services — 2.2%  

Info Edge India, Ltd.

    84,034     $ 6,273,757  
      $ 6,273,757  
Internet & Direct Marketing Retail — 2.9%  

FSN E-Commerce Ventures, Ltd.(1)

    69,630     $ 1,973,621  

PB Fintech, Ltd.(1)

    114,698       1,473,386  

Zomato, Ltd.(1)

    2,661,297       4,889,161  
      $ 8,336,168  
IT Services — 21.8%  

Coforge, Ltd.

    53,741     $ 4,230,925  

HCL Technologies, Ltd.

    509,908       9,022,620  

Infosys, Ltd.

    1,461,059       37,105,281  

Persistent Systems, Ltd.

    62,010       4,070,596  

Wipro, Ltd.

    775,628       7,431,822  
      $ 61,861,244  
Machinery — 0.8%  

Grindwell Norton, Ltd.

    86,000     $ 2,193,797  
      $ 2,193,797  
Metals & Mining — 3.3%  

APL Apollo Tubes, Ltd.(1)

    156,608     $ 2,095,060  

Hindalco Industries, Ltd.

    792,877       5,033,470  

Jindal Steel & Power, Ltd.(1)

    455,205       2,298,566  
      $ 9,427,096  
Multiline Retail — 0.6%  

Trent, Ltd.

    113,576     $ 1,620,002  
      $ 1,620,002  
Oil, Gas & Consumable Fuels — 5.0%  

Reliance Industries, Ltd.

    445,629     $ 14,158,199  
      $ 14,158,199  
Security   Shares     Value  
Personal Products — 2.1%  

Emami, Ltd.

    308,764     $ 2,150,263  

Marico, Ltd.

    538,582       3,714,297  
      $ 5,864,560  
Pharmaceuticals — 5.2%  

Gland Pharma, Ltd.(1)(2)

    50,542     $ 2,612,514  

Ipca Laboratories, Ltd.

    71,998       2,095,523  

Lupin, Ltd.

    197,697       2,520,504  

Sun Pharmaceutical Industries, Ltd.

    430,716       4,889,763  

Torrent Pharmaceuticals, Ltd.

    58,307       2,571,556  
      $ 14,689,860  
Professional Services — 1.8%  

L&T Technology Services, Ltd.(2)

    40,740     $ 3,060,628  

Quess Corp, Ltd.(2)

    182,207       2,081,226  
      $ 5,141,854  
Real Estate Management & Development — 1.9%  

Godrej Properties, Ltd.(1)

    117,693     $ 2,957,375  

Oberoi Realty, Ltd.(1)

    214,170       2,470,363  
      $ 5,427,738  
Software — 1.0%  

Zensar Technologies, Ltd.

    395,433     $ 2,774,876  
      $ 2,774,876  
Thrifts & Mortgage Finance — 0.9%  

Housing Development Finance Corp., Ltd.

    71,657     $ 2,479,793  
      $ 2,479,793  

Total India
(identified cost $180,401,041)

 

  $ 296,075,175  

Total Common Stocks
(identified cost $180,401,041)

 

  $ 296,075,175  

Total Investments — 104.2%
(identified cost $180,401,041)

 

  $ 296,075,175  

Other Assets, Less Liabilities — (4.2)%

 

  $ (11,922,086

Net Assets — 100.0%

 

  $ 284,153,089  

The percentage shown for each investment category in the Portfolio of Investments is based on net assets.

 

 

  22   See Notes to Financial Statements.


Greater India Portfolio

December 31, 2021

 

Portfolio of Investments — continued

 

 

(1) 

Non-income producing security.

 

(2) 

Security exempt from registration under Rule 144A of the Securities Act of 1933, as amended. These securities may be sold in certain transactions in reliance on an exemption from registration (normally to qualified institutional buyers). At December 31, 2021, the aggregate value of these securities is $28,446,433 or 10.0% of the Portfolio’s net assets.

 

 

Futures Contracts                                  
Description    Number of
Contracts
     Position      Expiration
Date
     Notional
Amount
   

Value/Unrealized
Appreciation

(Depreciation)

 

Equity Futures

             
SGX CNX Nifty Index      47        Long        1/27/22      $ 1,639,313     $ 13,640  
                                        $ 13,640  

 

  23   See Notes to Financial Statements.


Greater India Portfolio

December 31, 2021

 

Statement of Assets and Liabilities

 

 

Assets    December 31, 2021  

Unaffiliated investments, at value (identified cost, $180,401,041)

   $ 296,075,175  

Cash

     2,730,644  

Deposits for derivatives collateral — financial futures contracts

     77,550  

Receivable for variation margin on open financial futures contracts

     13,631  

Due from affiliate

     82,873  

Receivable for foreign taxes

     39,624  

Total assets

   $ 299,019,497  
Liabilities

 

Payable to affiliates:

  

Investment adviser fee

   $ 214,294  

Trustees’ fees

     3,458  

Accrued foreign capital gains taxes

     14,545,163  

Accrued expenses

     103,493  

Total liabilities

   $ 14,866,408  

Net Assets applicable to investors’ interest in Portfolio

   $ 284,153,089  

 

  24   See Notes to Financial Statements.


Greater India Portfolio

December 31, 2021

 

Statement of Operations

 

 

Investment Income   

Year Ended

December 31, 2021

 

Dividends (net of foreign taxes, $460,171)

   $ 1,545,537  

Total investment income

   $ 1,545,537  
Expenses         

Investment adviser fee

   $ 2,340,522  

Trustees’ fees and expenses

     14,180  

Custodian fee

     155,466  

Legal and accounting services

     86,261  

Miscellaneous

     12,426  

Total expenses

   $ 2,608,855  

Net investment loss

   $ (1,063,318
Realized and Unrealized Gain (Loss)         

Net realized gain (loss) —

  

Investment transactions (net of foreign capital gains taxes of $2,732,928)

   $ 38,902,299  

Financial futures contracts

     2,064,339  

Foreign currency transactions

     (195,920

Net realized gain

   $ 40,770,718  

Change in unrealized appreciation (depreciation) —

  

Investments (including net increase in accrued foreign capital gains taxes of $6,153,223)

   $ 20,392,578  

Financial futures contracts

     7,921  

Foreign currency

     (1,399

Net change in unrealized appreciation (depreciation)

   $ 20,399,100  

Net realized and unrealized gain

   $ 61,169,818  

Net increase in net assets from operations

   $ 60,106,500  

 

  25   See Notes to Financial Statements.


Greater India Portfolio

December 31, 2021

 

Statements of Changes in Net Assets

 

 

     Year Ended December 31,  
Increase (Decrease) in Net Assets    2021      2020
(as restated)
 

From operations —

     

Net investment loss

   $ (1,063,318    $ (231,832

Net realized gain

     40,770,718        6,347,912  

Net change in unrealized appreciation (depreciation)

     20,399,100        20,452,727  

Net increase in net assets from operations

   $ 60,106,500      $ 26,568,807  

Capital transactions —

     

Contributions

   $ 31,649,737      $ 42,906,129  

Withdrawals

     (36,627,830      (57,262,729

Net decrease in net assets from capital transactions

   $ (4,978,093    $ (14,356,600

Net increase in net assets

   $ 55,128,407      $ 12,212,207  
Net Assets

 

At beginning of year

   $ 229,024,682      $ 216,812,475  

At end of year

   $ 284,153,089      $ 229,024,682  

 

  26   See Notes to Financial Statements.


 

 

Greater India Portfolio

December 31, 2021

 

Financial Highlights

 

 

     Year Ended December 31,  
      2021     

2020

(as restated)

     2019      2018     2017  

Ratios (as a percentage of average daily net assets):

             

Expenses

     0.95      0.93      0.98      0.98     0.98

Net investment income (loss)

     (0.39 )%       (0.12 )%       0.07      0.19     0.76

Portfolio Turnover

     33      26      21      29     25

Total Return

     24.76      14.14      11.17      (11.57 )%      45.78

Net assets, end of year (000’s omitted)

   $ 284,153      $ 229,025      $ 216,812      $ 213,186     $ 273,437  

 

  27   See Notes to Financial Statements.


Greater India Portfolio

December 31, 2021

 

Notes to Financial Statements

 

 

1  Significant Accounting Policies

Greater India Portfolio (the Portfolio) is a Massachusetts business trust registered under the Investment Company Act of 1940, as amended (the 1940 Act), as a non-diversified, open-end management investment company. The Portfolio’s investment objective is to seek long-term capital appreciation. The Declaration of Trust permits the Trustees to issue interests in the Portfolio. At December 31, 2021, Eaton Vance Greater India Fund held a 99.9% interest in the Portfolio.

The following is a summary of significant accounting policies of the Portfolio. The policies are in conformity with accounting principles generally accepted in the United States of America (U.S. GAAP). The Portfolio is an investment company and follows accounting and reporting guidance in the Financial Accounting Standards Board (FASB) Accounting Standards Codification Topic 946.

A  Investment Valuation — The following methodologies are used to determine the market value or fair value of investments.

Equity Securities. Equity securities listed on a U.S. securities exchange generally are valued at the last sale or closing price on the day of valuation or, if no sales took place on such date, at the mean between the closing bid and ask prices on the exchange where such securities are principally traded. Equity securities listed on the NASDAQ National Market System are valued at the NASDAQ official closing price. Unlisted or listed securities for which closing sales prices or closing quotations are not available are valued at the mean between the latest available bid and ask prices.

Derivatives. Financial futures contracts are valued at the closing settlement price established by the board of trade or exchange on which they are traded, with adjustments for fair valuation for certain foreign financial futures contracts as described below.

Foreign Securities, Financial Futures Contracts and Currencies. Foreign securities, financial futures contracts and currencies are valued in U.S. dollars, based on foreign currency exchange rate quotations supplied by a third party pricing service. The pricing service uses a proprietary model to determine the exchange rate. Inputs to the model include reported trades and implied bid/ask spreads. The daily valuation of exchange-traded foreign securities and certain exchange-traded foreign financial futures contracts generally is determined as of the close of trading on the principal exchange on which such securities and contracts trade. Foreign ownership of shares of certain Indian companies may be subject to limitations. When foreign ownership of such an Indian company’s shares approaches the limitation, foreign investors may be willing to pay a premium to the local share price to acquire shares from other foreign investors. Such shares are valued at the closing price for foreign investors as provided by the exchange on which they trade. Events occurring after the close of trading on foreign exchanges may result in adjustments to the valuation of foreign securities and certain foreign financial futures contracts to more accurately reflect their fair value as of the close of regular trading on the New York Stock Exchange. When valuing foreign equity securities and foreign financial futures contracts that meet certain criteria, the Portfolio’s Trustees have approved the use of a fair value service that values such securities and foreign financial futures contracts to reflect market trading that occurs after the close of the applicable foreign markets of comparable securities or other instruments that have a strong correlation to the fair-valued securities and foreign financial futures contracts.

Fair Valuation. Investments for which valuations or market quotations are not readily available or are deemed unreliable are valued at fair value using methods determined in good faith by or at the direction of the Trustees of the Portfolio in a manner that most fairly reflects the security’s “fair value”, which is the amount that the Portfolio might reasonably expect to receive for the security upon its current sale in the ordinary course. Each such determination is based on a consideration of relevant factors, which are likely to vary from one pricing context to another. These factors may include, but are not limited to, the type of security, the existence of any contractual restrictions on the security’s disposition, the price and extent of public trading in similar securities of the issuer or of comparable companies or entities, quotations or relevant information obtained from broker/dealers or other market participants, information obtained from the issuer, analysts, and/or the appropriate stock exchange (for exchange-traded securities), an analysis of the company’s or entity’s financial statements, and an evaluation of the forces that influence the issuer and the market(s) in which the security is purchased and sold.

B  Investment Transactions — Investment transactions for financial statement purposes are accounted for on a trade date basis. Realized gains and losses on investments sold are determined on the basis of identified cost.

C  Income — Dividend income is recorded on the ex-dividend date for dividends received in cash and/or securities. However, if the ex-dividend date has passed, certain dividends from foreign securities are recorded as the Portfolio is informed of the ex-dividend date. Non-cash dividends are recorded at the fair value of the securities received. Withholding taxes on foreign dividends and capital gains have been provided for in accordance with the Portfolio’s understanding of the applicable countries’ tax rules and rates.

D  Federal and Other Taxes — The Portfolio has elected to be treated as a partnership for federal tax purposes. No provision is made by the Portfolio for federal or state taxes on any taxable income of the Portfolio because each investor in the Portfolio is ultimately responsible for the payment of any taxes on its share of taxable income. Since at least one of the Portfolio’s investors is a regulated investment company that invests all or substantially all of its assets in the Portfolio, the Portfolio normally must satisfy the applicable source of income and diversification requirements (under the Internal Revenue Code) in order for its investors to satisfy them. The Portfolio will allocate, at least annually among its investors, each investor’s distributive share of the Portfolio’s net investment income, net realized capital gains and losses and any other items of income, gain, loss, deduction or credit.

In addition to the requirements of the Internal Revenue Code, the Portfolio may also be subject to local taxes on the recognition of capital gains in India. In determining the daily net asset value, the Portfolio estimates the accrual for such taxes, if any, based on the unrealized appreciation on certain portfolio securities, historical effective tax rates on securities sold, and the availability of any realized losses in excess of gains that may be carried forward to offset future gains. Taxes attributable to unrealized appreciation are included in the change in unrealized appreciation (depreciation) on investments. Capital

 

  28  


Greater India Portfolio

December 31, 2021

 

Notes to Financial Statements — continued

 

 

gains taxes on certain Indian securities sold at a gain are included in net realized gain (loss) on investments. As of December 31, 2021, the Portfolio for tax reporting in India had no accumulated losses available to be carried forward to offset future realized gains from the sale of Indian securities.

As of December 31, 2021, the Portfolio had no uncertain tax positions that would require financial statement recognition, de-recognition, or disclosure. The Portfolio files a U.S. federal income tax return annually after its fiscal year-end, which is subject to examination by the Internal Revenue Service for a period of three years from the date of filing. The Portfolio also files a tax return in India annually as of March 31st. Such tax returns are subject to examination by the Indian tax authorities for open years as determined by the statute of limitations, which is generally a period of up to 7 years after a tax return is filed.

E  Foreign Currency Translation — Investment valuations, other assets, and liabilities initially expressed in foreign currencies are translated each business day into U.S. dollars based upon current exchange rates. Purchases and sales of foreign investment securities and income and expenses denominated in foreign currencies are translated into U.S. dollars based upon currency exchange rates in effect on the respective dates of such transactions. Recognized gains or losses on investment transactions attributable to changes in foreign currency exchange rates are recorded for financial statement purposes as net realized gains and losses on investments. That portion of unrealized gains and losses on investments that results from fluctuations in foreign currency exchange rates is not separately disclosed.

F  Use of Estimates — The preparation of the financial statements in conformity with U.S. GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities at the date of the financial statements and the reported amounts of income and expense during the reporting period. Actual results could differ from those estimates.

G  Indemnifications — Under the Portfolio’s organizational documents, its officers and Trustees may be indemnified against certain liabilities and expenses arising out of the performance of their duties to the Portfolio. Under Massachusetts law, if certain conditions prevail, interestholders in the Portfolio could be deemed to have personal liability for the obligations of the Portfolio. However, the Portfolio’s Declaration of Trust contains an express disclaimer of liability on the part of Portfolio interestholders. Additionally, in the normal course of business, the Portfolio enters into agreements with service providers that may contain indemnification clauses. The Portfolio’s maximum exposure under these arrangements is unknown as this would involve future claims that may be made against the Portfolio that have not yet occurred.

H  Financial Futures Contracts — Upon entering into a financial futures contract, the Portfolio is required to deposit with the broker, either in cash or securities, an amount equal to a certain percentage of the contract amount (initial margin). Subsequent payments, known as variation margin, are made or received by the Portfolio each business day, depending on the daily fluctuations in the value of the underlying security or index, and are recorded as unrealized gains or losses by the Portfolio. Gains (losses) are realized upon the expiration or closing of the financial futures contracts. Should market conditions change unexpectedly, the Portfolio may not achieve the anticipated benefits of the financial futures contracts and may realize a loss. Futures contracts have minimal counterparty risk as they are exchange traded and the clearinghouse for the exchange is substituted as the counterparty, guaranteeing counterparty performance.

2  Investment Adviser Fee and Other Transactions with Affiliates

The investment adviser fee is earned by Boston Management and Research (BMR) as compensation for investment advisory services rendered to the Portfolio. On March 1, 2021, Morgan Stanley acquired Eaton Vance Corp. (the “Transaction”) and BMR became an indirect, wholly-owned subsidiary of Morgan Stanley. In connection with the Transaction, the Portfolio entered into a new investment advisory agreement (the “New Agreement”) with BMR, which took effect on March 1, 2021. The Portfolio’s prior fee reduction agreement was incorporated into the New Agreement. Pursuant to the New Agreement (and the Portfolio’s investment advisory agreement and related fee reduction agreement with BMR in effect prior to March 1, 2021), the fee is computed at an annual rate as a percentage of average daily net assets as follows and is payable monthly:

 

Average Daily Net Assets    Annual Fee
Rate
 

Up to $500 million

     0.850

$500 million but less than $1 billion

     0.800

$1 billion but less than $2.5 billion

     0.775

$2.5 billion but less than $5 billion

     0.750

$5 billion and over

     0.730

For the year ended December 31, 2021, the investment adviser fee amounted to $2,340,522 or 0.85% of the Portfolio’s average daily net assets. Included in Due from affiliate on the Statement of Assets and Liabilities is $82,873, representing a reimbursement from BMR for the overpayment of advisory fees during the period from June 2, 2020 to December 31, 2021. The overpayment of advisory fees resulted from the overstatement of net assets during the same period because accrued foreign capital gains taxes during the period were misstated. See also Note 9 for further explanation. Pursuant to an investment sub-advisory agreement, BMR has delegated the investment management of the Portfolio to Goldman Sachs Asset Management, L.P. (GSAM). In connection with the Transaction, BMR entered into a new investment sub-advisory agreement with GSAM, which took effect on March 1, 2021. BMR pays GSAM a portion of its investment adviser fee for sub-advisory services provided to the Portfolio.

 

  29  


Greater India Portfolio

December 31, 2021

 

Notes to Financial Statements — continued

 

 

Trustees and officers of the Portfolio who are members of EVM’s or BMR’s organizations receive remuneration for their services to the Portfolio out of the investment adviser fee. Trustees of the Portfolio who are not affiliated with the investment adviser may elect to defer receipt of all or a percentage of their annual fees in accordance with the terms of the Trustees Deferred Compensation Plan. For the year ended December 31, 2021, no significant amounts have been deferred. Certain officers and Trustees of the Portfolio are officers of the above organizations.

3  Purchases and Sales of Investments

Purchases and sales of investments, other than short-term obligations, aggregated $90,034,446 and $92,095,525, respectively, for the year ended December 31, 2021.

4  Federal Income Tax Basis of Investments

The cost and unrealized appreciation (depreciation) of investments, including open derivative contracts, of the Portfolio at December 31, 2021, as determined on a federal income tax basis, were as follows:

 

Aggregate cost

   $ 182,055,476  

Gross unrealized appreciation

   $ 115,447,564  

Gross unrealized depreciation

     (1,414,225

Net unrealized appreciation

   $ 114,033,339  

5  Financial Instruments

The Portfolio may trade in financial instruments with off-balance sheet risk in the normal course of its investing activities. These financial instruments may include financial futures contracts and may involve, to a varying degree, elements of risk in excess of the amounts recognized for financial statement purposes. The notional or contractual amounts of these instruments represent the investment the Portfolio has in particular classes of financial instruments and do not necessarily represent the amounts potentially subject to risk. The measurement of the risks associated with these instruments is meaningful only when all related and offsetting transactions are considered. A summary of obligations under these financial instruments at December 31, 2021 is included in the Portfolio of Investments. At December 31, 2021, the Portfolio had sufficient cash and/or securities to cover commitments under these contracts.

The Portfolio is subject to equity price risk in the normal course of pursuing its investment objective. The Portfolio enters into equity index futures contracts to manage cash flows.

The fair value of open derivative instruments (not considered to be hedging instruments for accounting disclosure purposes) and whose primary underlying risk exposure is equity price risk at December 31, 2021 was as follows:

 

     Fair Value  
Derivative    Asset Derivative(1)      Liability Derivative  

Financial futures contracts

   $ 13,640      $         —  

 

(1) 

Only the current day’s variation margin on open futures contracts is reported within the Statement of Assets and Liabilities as Receivable or Payable for variation margin on open financial futures contracts, as applicable.

The effect of derivative instruments (not considered to be hedging instruments for accounting disclosure purposes) on the Statement of Operations and whose primary underlying risk exposure is equity price risk for the year ended December 31, 2021 was as follows:

 

Derivative    Realized Gain (Loss)
on Derivatives Recognized
in Income
(1)
     Change in Unrealized
Appreciation (Depreciation) on
Derivatives Recognized in Income
(2)
 

Financial futures contracts

   $ 2,064,339      $ 7,921  

 

(1) 

Statement of Operations location: Net realized gain (loss) – Financial futures contracts.

 

  30  


Greater India Portfolio

December 31, 2021

 

Notes to Financial Statements — continued

 

 

(2) 

Statement of Operations location: Change in unrealized appreciation (depreciation) – Financial futures contracts.

The average notional cost of futures contracts (long) outstanding during the year ended December 31, 2021, which is indicative of the volume of this derivative type, was approximately $7,821,000.

6  Line of Credit

The Portfolio participates with other portfolios and funds managed by EVM and its affiliates in an $800 million unsecured line of credit agreement with a group of banks, which is in effect through October 25, 2022. Borrowings are made by the Portfolio solely for temporary purposes related to redemptions and other short-term cash needs. Interest is charged to the Portfolio based on its borrowings at an amount above either the Secured Overnight Financing Rate (SOFR) or Federal Funds rate. In addition, a fee computed at an annual rate of 0.15% on the daily unused portion of the line of credit is allocated among the participating portfolios and funds at the end of each quarter. In connection with the renewal of the agreement in October 2021, an arrangement fee totaling $150,000 was incurred that was allocated to the participating portfolios and funds. Because the line of credit is not available exclusively to the Portfolio, it may be unable to borrow some or all of its requested amounts at any particular time. The Portfolio did not have any significant borrowings or allocated fees during the year ended December 31, 2021.

7  Fair Value Measurements

Under generally accepted accounting principles for fair value measurements, a three-tier hierarchy to prioritize the assumptions, referred to as inputs, is used in valuation techniques to measure fair value. The three-tier hierarchy of inputs is summarized in the three broad levels listed below.

 

 

Level 1 – quoted prices in active markets for identical investments

 

 

Level 2 – other significant observable inputs (including quoted prices for similar investments, interest rates, prepayment speeds, credit risk, etc.)

 

 

Level 3 – significant unobservable inputs (including a fund’s own assumptions in determining the fair value of investments)

In cases where the inputs used to measure fair value fall in different levels of the fair value hierarchy, the level disclosed is determined based on the lowest level input that is significant to the fair value measurement in its entirety. The inputs or methodology used for valuing securities are not necessarily an indication of the risk associated with investing in those securities.

At December 31, 2021, the hierarchy of inputs used in valuing the Portfolio’s investments and open derivative instruments, which are carried at value, were as follows:

 

Asset Description    Level 1      Level 2      Level 3      Total  

Common Stocks

           

Communication Services

   $      $ 9,115,634      $         —      $ 9,115,634  

Consumer Discretionary

     3,447,007        37,233,679               40,680,686  

Consumer Staples

     1,516,360        22,266,225               23,782,585  

Energy

            14,158,199               14,158,199  

Financials

            77,411,661               77,411,661  

Health Care

            18,475,897               18,475,897  

Industrials

            12,763,077               12,763,077  

Information Technology

            66,346,042               66,346,042  

Materials

            22,608,714               22,608,714  

Real Estate

            5,427,738               5,427,738  

Utilities

            5,304,942               5,304,942  

Total Common Stocks

   $ 4,963,367      $ 291,111,808    $      $ 296,075,175  

Total Investments

   $ 4,963,367      $ 291,111,808      $      $ 296,075,175  

Futures Contracts

   $      $ 13,640      $      $ 13,640  

Total

   $ 4,963,367      $ 291,125,448      $      $ 296,088,815  

 

*

Includes foreign equity securities whose values were adjusted to reflect market trading of comparable securities or other correlated instruments that occurred after the close of trading in their applicable foreign markets.

 

  31  


Greater India Portfolio

December 31, 2021

 

Notes to Financial Statements — continued

 

 

8  Risks and Uncertainties

Risks Associated with Foreign Investments

Foreign investments can be adversely affected by political, economic and market developments abroad, including the imposition of economic and other sanctions by the United States or another country. There may be less publicly available information about foreign issuers because they may not be subject to reporting practices, requirements or regulations comparable to those to which United States companies are subject. Foreign markets may be smaller, less liquid and more volatile than the major markets in the United States. Trading in foreign markets typically involves higher expense than trading in the United States. The Fund may have difficulties enforcing its legal or contractual rights in a foreign country. Securities that trade or are denominated in currencies other than the U.S. dollar may be adversely affected by fluctuations in currency exchange rates.

Countries within the Indian sub-continent region are considered emerging market countries. The securities markets within the Indian sub-continent are undergoing a period of growth and change, which may result in trading or price volatility and difficulties in the settlement and recording of transactions, and in interpreting and applying relevant laws and regulations. The securities markets in these countries are comparatively underdeveloped and may be concentrated in certain sectors. In addition, governmental actions can have a significant effect on the economic conditions in the India region, which could adversely affect the value and liquidity of investments.

Pandemic Risk

An outbreak of respiratory disease caused by a novel coronavirus was first detected in China in late 2019 and subsequently spread internationally. This coronavirus has resulted in closing borders, enhanced health screenings, changes to healthcare service preparation and delivery, quarantines, cancellations, disruptions to supply chains and customer activity, as well as general concern and uncertainty. Health crises caused by outbreaks, such as the coronavirus outbreak, may exacerbate other pre-existing political, social and economic risks and disrupt normal market conditions and operations. The impact of this outbreak has negatively affected the worldwide economy, the economies of individual countries, individual companies, and the market in general, and may continue to do so in significant and unforeseen ways, as may other epidemics and pandemics that may arise in the future. Any such impact could adversely affect the Portfolio’s performance, or the performance of the securities in which the Portfolio invests.

9  Restatement

Prior to the issuance of the Portfolio’s December 31, 2021 financial statements, it was determined that the accrual for foreign capital gains taxes had been understated since June 2, 2020.

As a result, the Portfolio has restated its Statement of Assets and Liabilities as of December 31, 2020 and its Statement of Operations, Statement of Changes in Net Assets and Financial Highlights for the year then ended. There was no change to the amounts for cost and value of investments as presented in the Portfolio of Investments as of December 31, 2020, although the percentages therein for each investment category based on net assets would change due to the change in net assets. The adjustment for excess asset-based investment advisory fees for the year ended December 31, 2020 was less than $15,000 and was recorded as an adjustment to expense in the year ended December 31, 2021.

The following table presents previously reported balances and restated balances after the adjustment for accrued foreign capital gains taxes and excludes balances that were not restated.

 

Statement of Assets and Liabilities    As Previously
Reported
     As Restated  

Liabilities:

     

Accrued foreign capital gains taxes

   $      $ 8,391,940  

Total liabilities

     294,636        8,686,576  

Net Assets applicable to investors’ interest in the Portfolio

     237,416,622        229,024,682  
Statement of Operations                

Change in unrealized appreciation (depreciation) —

     

Investments (including net increase in accrued foreign capital gains taxes of $0 and $8,391,940, respectively)

   $ 28,841,106      $ 20,449,166  

Net change in unrealized appreciation (depreciation)

     28,844,667        20,452,727  

Net realized and unrealized gain

     35,192,579        26,800,639  

Net increase in net assets from operations

     34,960,747        26,568,807  

 

  32  


Greater India Portfolio

December 31, 2021

 

Notes to Financial Statements — continued

 

 

Statement of Changes in Net Assets    As Previously
Reported
     As Restated  

Net change in unrealized appreciation (depreciation)

   $ 28,844,667      $ 20,452,727  

Net increase in net assets from operations

     34,960,747        26,568,807  

Net increase in net assets

     20,604,147        12,212,207  

Net Assets at end of year

     237,416,622        229,024,682  
Financial Highlights                

Total Return

     18.38      14.14

Net assets, end of year (000’s omitted)

   $ 237,417      $ 229,025  

 

  33  


Greater India Portfolio

December 31, 2021

 

Report of Independent Registered Public Accounting Firm

 

 

To the Trustees and Investors of Greater India Portfolio:

Opinion on the Financial Statements and Financial Highlights

We have audited the accompanying statement of assets and liabilities of Greater India Portfolio (the “Portfolio”), including the portfolio of investments, as of December 31, 2021, the related statement of operations for the year then ended, the statements of changes in net assets for each of the two years in the period then ended, the financial highlights for each of the five years in the period then ended, and the related notes. In our opinion, the financial statements and financial highlights present fairly, in all material respects, the financial position of the Portfolio as of December 31, 2021, and the results of its operations for the year then ended, the changes in its net assets for each of the two years in the period then ended, and the financial highlights for each of the five years in the period then ended, in conformity with accounting principles generally accepted in the United States of America.

Restatement of the 2020 Financial Statements and Financial Highlights

As discussed in Note 9 to the financial statements, the accompanying 2020 financial statements and financial highlights have been restated to correct a misstatement.

Basis for Opinion

These financial statements and financial highlights are the responsibility of the Portfolio’s management. Our responsibility is to express an opinion on the Portfolio’s financial statements and financial highlights based 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 Portfolio 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 and financial highlights are free of material misstatement, whether due to error or fraud. The Portfolio is not required to have, nor were we engaged to perform, an audit of its 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 Portfolio’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 and financial highlights, 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 and financial highlights. 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 and financial highlights. Our procedures included confirmation of securities owned as of December 31, 2021, by correspondence with the custodian and brokers; when replies were not received from brokers, we performed other auditing procedures. We believe that our audits provide a reasonable basis for our opinion.

/s/ Deloitte & Touche LLP

Boston, Massachusetts

March 10, 2022

We have served as the auditor of one or more Eaton Vance investment companies since 1959.

 

  34  


Eaton Vance

Greater India Fund

December 31, 2021

 

Management and Organization

 

 

Fund Management.  The Trustees of Eaton Vance Special Investment Trust (the Trust) and Greater India Portfolio (the Portfolio) are responsible for the overall management and supervision of the Trust and the Portfolio’s affairs. The Board members and officers of the Trust and the Portfolio are listed below. Except as indicated, each individual has held the office shown or other offices in the same company for the last five years. Board members hold indefinite terms of office. Each Trustee holds office until his or her successor is elected and qualified, subject to a prior death, resignation, retirement, disqualification or removal. Under the terms of the Fund’s and the Portfolio’s current Trustee retirement policy, an Independent Trustee must retire and resign as a Trustee on the earlier of: (i) the first day of July following his or her 74th birthday; or (ii), with limited exception, December 31st of the 20th year in which he or she has served as a Trustee. However, if such retirement and resignation would cause the Fund or Portfolio to be out of compliance with Section 16 of the 1940 Act or any other regulations or guidance of the SEC, then such retirement and resignation will not become effective until such time as action has been taken for the Fund or Portfolio to be in compliance therewith. The “noninterested Trustees” consist of those Trustees who are not “interested persons” of the Trust and the Portfolio, as that term is defined under the 1940 Act. The business address of each Board member and officer is Two International Place, Boston, Massachusetts 02110. As used below, “BMR” refers to Boston Management and Research, “EVC” refers to Eaton Vance Corp., “EV” refers to EV LLC, “EVM” refers to Eaton Vance Management and “EVD” refers to Eaton Vance Distributors, Inc. EV is the trustee of each of EVM and BMR. Effective March 1, 2021, each of EVM, BMR, EVD and EV are indirect, wholly owned subsidiaries of Morgan Stanley. Each officer affiliated with EVM may hold a position with other EVM affiliates that is comparable to his or her position with EVM listed below. Each Trustee oversees 138 funds (with the exception of Messrs. Faust and Wennerholm and Ms. Frost who oversee 137 funds) in the Eaton Vance fund complex (including both funds and portfolios in a hub and spoke structure).

 

Name and Year of Birth    Trust/Portfolio
Position(s)
     Length of Service     

Principal Occupation(s) and Other Directorships

During Past Five Years and Other Relevant Experience

Interested Trustee              

Thomas E. Faust Jr.

1958

   Trustee      Since 2007     

Chairman of Morgan Stanley Investment Management, Inc. (MSIM), member of the Board of Managers and President of EV, Chief Executive Officer of EVM and BMR, and Director of EVD. Formerly, Chairman, Chief Executive Officer and President of EVC. Mr. Faust is an interested person because of his positions with MSIM, BMR, EVM, EVD, and EV, which are affiliates of the Trust and the Portfolio, and his former position with EVC, which was an affiliate of the Trust and the Portfolio prior to March 1, 2021.

Other Directorships. Formerly, Director of EVC (2007-2021) and Hexavest Inc. (investment management firm) (2012-2021).

Noninterested Trustees              

Mark R. Fetting

1954

   Trustee      Since 2016     

Private investor. Formerly held various positions at Legg Mason, Inc. (investment management firm) (2000-2012), including President, Chief Executive Officer, Director and Chairman (2008-2012), Senior Executive Vice President (2004-2008) and Executive Vice President (2001-2004). Formerly, President of Legg Mason family of funds (2001-2008). Formerly, Division President and Senior Officer of Prudential Financial Group, Inc. and related companies (investment management firm) (1991-2000).

Other Directorships. None.

Cynthia E. Frost

1961

   Trustee      Since 2014     

Private investor. Formerly, Chief Investment Officer of Brown University (university endowment) (2000-2012). Formerly, Portfolio Strategist for Duke Management Company (university endowment manager) (1995-2000). Formerly, Managing Director, Cambridge Associates (investment consulting company) (1989-1995). Formerly, Consultant, Bain and Company (management consulting firm) (1987-1989). Formerly, Senior Equity Analyst, BA Investment Management Company (1983-1985).

Other Directorships. None.

George J. Gorman

1952

   Chairperson of the Board and Trustee      Since 2021 (Chairperson) and 2014 (Trustee)     

Principal at George J. Gorman LLC (consulting firm). Formerly, Senior Partner at Ernst & Young LLP (a registered public accounting firm) (1974-2009).

Other Directorships. None.

Valerie A. Mosley

1960

   Trustee      Since 2014     

Chairwoman and Chief Executive Officer of Valmo Ventures (a consulting and investment firm). Founder of Upward Wealth, Inc., dba BrightUP, a fintech platform. Formerly, Partner and Senior Vice President, Portfolio Manager and Investment Strategist at Wellington Management Company, LLP (investment management firm) (1992-2012). Formerly, Chief Investment Officer, PG Corbin Asset Management (1990-1992). Formerly worked in institutional corporate bond sales at Kidder Peabody (1986-1990).

Other Directorships. Director of DraftKings, Inc. (digital sports entertainment and gaming company) (since September 2020). Director of Groupon, Inc. (e-commerce provider) (since April 2020). Director of Envestnet, Inc. (provider of intelligent systems for wealth management and financial wellness) (since 2018). Formerly, Director of Dynex Capital, Inc. (mortgage REIT) (2013-2020).

 

  35  


Eaton Vance

Greater India Fund

December 31, 2021

 

Management and Organization — continued

 

 

Name and Year of Birth    Trust/Portfolio
Position(s)
     Length of Service     

Principal Occupation(s) and Other Directorships

During Past Five Years and Other Relevant Experience

Noninterested Trustees (continued)              

William H. Park

1947

   Trustee      Since 2003     

Private investor. Formerly, Consultant (management and transactional) (2012-2014). Formerly, Chief Financial Officer, Aveon Group L.P. (investment management firm) (2010-2011). Formerly, Vice Chairman, Commercial Industrial Finance Corp. (specialty finance company) (2006-2010). Formerly, President and Chief Executive Officer, Prizm Capital Management, LLC (investment management firm) (2002-2005). Formerly, Executive Vice President and Chief Financial Officer, United Asset Management Corporation (investment management firm) (1982-2001). Formerly, Senior Manager, Price Waterhouse (now PricewaterhouseCoopers) (a registered public accounting firm) (1972-1981).

Other Directorships. None.

Helen Frame Peters

1948

   Trustee      Since 2008     

Professor of Finance, Carroll School of Management, Boston College. Formerly, Dean, Carroll School of Management, Boston College (2000-2002). Formerly, Chief Investment Officer, Fixed Income, Scudder Kemper Investments (investment management firm) (1998-1999). Formerly, Chief Investment Officer, Equity and Fixed Income, Colonial Management Associates (investment management firm) (1991-1998).

Other Directorships. None.

Keith Quinton

1958

   Trustee      Since 2018     

Private investor, researcher and lecturer. Formerly, Independent Investment Committee Member at New Hampshire Retirement System (2017-2021). Formerly, Portfolio Manager and Senior Quantitative Analyst at Fidelity Investments (investment management firm) (2001-2014).

Other Directorships. Formerly, Director (2016-2021) and Chairman (2019-2021) of New Hampshire Municipal Bond Bank.

Marcus L. Smith

1966

   Trustee      Since 2018     

Private investor. Formerly, Portfolio Manager at MFS Investment Management (investment management firm) (1994-2017).

Other Directorships. Director of First Industrial Realty Trust, Inc. (an industrial REIT) (since 2021). Director of MSCI Inc. (global provider of investment decision support tools) (since 2017). Formerly, Director of DCT Industrial Trust Inc. (logistics real estate company) (2017-2018).

Susan J. Sutherland

1957

   Trustee      Since 2015     

Private investor. Director of Ascot Group Limited and certain of its subsidiaries (insurance and reinsurance) (since 2017). Formerly, Director of Hagerty Holding Corp. (insurance) (2015-2018) and Montpelier Re Holdings Ltd. (insurance and reinsurance) (2013-2015). Formerly, Associate, Counsel and Partner at Skadden, Arps, Slate, Meagher & Flom LLP (law firm) (1982-2013).

Other Directorships. Director of Kairos Acquisition Corp. (insurance/InsurTech acquisition company) (since 2021).

Scott E. Wennerholm

1959

   Trustee      Since 2016     

Private investor. Formerly, Trustee at Wheelock College (postsecondary institution) (2012-2018). Formerly, Consultant at GF Parish Group (executive recruiting firm) (2016-2017). Formerly, Chief Operating Officer and Executive Vice President at BNY Mellon Asset Management (investment management firm) (2005-2011). Formerly, Chief Operating Officer and Chief Financial Officer at Natixis Global Asset Management (investment management firm) (1997-2004). Formerly, Vice President at Fidelity Investments Institutional Services (investment management firm) (1994-1997).

Other Directorships. None.

 

Name and Year of Birth    Trust/Portfolio
Position(s)
     Length of Service     

Principal Occupation(s)

During Past Five Years

Principal Officers who are not Trustees

Eric A. Stein

1980

   President of the Trust      Since 2020      Vice President and Chief Investment Officer, Fixed Income of EVM and BMR. Prior to November 1, 2020, Mr. Stein was a co-Director of Eaton Vance’s Global Income Investments. Also Vice President of Calvert Research and Management (“CRM”).

Edward J. Perkin

1972

   President of the Portfolio      Since 2014      Chief Equity Investment Officer and Vice President of EVM and BMR since 2014. Also Vice President of CRM.

 

  36  


Eaton Vance

Greater India Fund

December 31, 2021

 

Management and Organization — continued

 

 

Name and Year of Birth    Trust/Portfolio
Position(s)
     Length of Service     

Principal Occupation(s)

During Past Five Years

Principal Officers who are not Trustees (continued)

Deidre E. Walsh

1971

   Vice President and Chief Legal Officer      Since 2009      Vice President of EVM and BMR. Also Vice President of CRM.

James F. Kirchner

1967

   Treasurer      Since 2007      Vice President of EVM and BMR. Also Vice President of CRM.

Jill R. Damon

1984

   Secretary      Since 2022      Vice President of EVM and BMR since 2017. Formerly, associate at Dechert LLP (2009-2017).

Richard F. Froio

1968

   Chief Compliance Officer      Since 2017      Vice President of EVM and BMR since 2017. Formerly, Deputy Chief Compliance Officer (Adviser/Funds) and Chief Compliance Officer (Distribution) at PIMCO (2012-2017) and Managing Director at BlackRock/Barclays Global Investors (2009-2012).

The SAI for the Fund includes additional information about the Trustees and officers of the Trust and the Portfolio and can be obtained without charge on Eaton Vance’s website at www.eatonvance.com or by calling 1-800-262-1122.

 

  37  


Eaton Vance Funds

 

Privacy Notice    April 2021

 

 

FACTS    WHAT DOES EATON VANCE DO WITH YOUR
PERSONAL INFORMATION?
      
  
Why?    Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
   
      
What?   

The types of personal information we collect and share depend on the product or service you have with us. This information can include:

 

   Social Security number and income

   investment experience and risk tolerance

   checking account number and wire transfer instructions

   
      
How?    All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons Eaton Vance chooses to share; and whether you can limit this sharing.
   
      

 

Reasons we can share your
personal information
   Does Eaton Vance share?    Can you limit this sharing?
For our everyday business purposes — such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus    Yes    No
For our marketing purposes — to offer our products and services to you    Yes    No
For joint marketing with other financial companies    No    We don’t share
For our investment management affiliates’ everyday business purposes — information about your transactions, experiences, and creditworthiness    Yes    Yes
For our affiliates’ everyday business purposes — information about your transactions and experiences    Yes    No
For our affiliates’ everyday business purposes — information about your creditworthiness    No    We don’t share
For our investment management affiliates to market to you    Yes    Yes
For our affiliates to market to you    No    We don’t share
For nonaffiliates to market to you    No    We don’t share

 

To limit our sharing   

Call toll-free 1-800-262-1122 or email: EVPrivacy@eatonvance.com

 

Please note:

 

If you are a new customer, we can begin sharing your information 30 days from the date we sent this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.

   
      
   
Questions?    Call toll-free 1-800-262-1122 or email: EVPrivacy@eatonvance.com
   
      

 

  38  


Eaton Vance Funds

 

Privacy Notice — continued    April 2021

 

 

Page 2     

 

Who we are
Who is providing this notice?   Eaton Vance Management, Eaton Vance Distributors, Inc., Eaton Vance Trust Company, Eaton Vance Management (International) Limited, Eaton Vance Advisers International Ltd., Eaton Vance Global Advisors Limited, Eaton Vance Management’s Real Estate Investment Group, Boston Management and Research, Calvert Research and Management, Eaton Vance and Calvert Fund Families and our investment advisory affiliates (“Eaton Vance”) (see Investment Management Affiliates definition below)
What we do
How does Eaton Vance protect my personal information?   To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. We have policies governing the proper handling of customer information by personnel and requiring third parties that provide support to adhere to appropriate security standards with respect to such information.
How does Eaton Vance collect my personal information?  

We collect your personal information, for example, when you

 

   open an account or make deposits or withdrawals from your account

   buy securities from us or make a wire transfer

   give us your contact information

 

We also collect your personal information from others, such as credit bureaus, affiliates, or other companies.

Why can’t I limit all sharing?  

Federal law gives you the right to limit only

 

   sharing for affiliates’ everyday business purposes — information about your creditworthiness

   affiliates from using your information to market to you

   sharing for nonaffiliates to market to you

 

State laws and individual companies may give you additional rights to limit sharing. See below for more on your rights under state law.

Definitions
Investment Management Affiliates   Eaton Vance Investment Management Affiliates include registered investment advisers, registered broker-dealers, and registered and unregistered funds. Investment Management Affiliates does not include entities associated with Morgan Stanley Wealth Management, such as Morgan Stanley Smith Barney LLC and Morgan Stanley & Co.
Affiliates  

Companies related by common ownership or control. They can be financial and nonfinancial companies.

 

   Our affiliates include companies with a Morgan Stanley name and financial companies such as Morgan Stanley Smith Barney LLC and Morgan Stanley & Co.

Nonaffiliates  

Companies not related by common ownership or control. They can be financial and nonfinancial companies.

 

   Eaton Vance does not share with nonaffiliates so they can market to you.

Joint marketing  

A formal agreement between nonaffiliated financial companies that together market financial products or services to you.

 

   Eaton Vance doesn’t jointly market.

Other important information

Vermont: Except as permitted by law, we will not share personal information we collect about Vermont residents with Nonaffiliates unless you provide us with your written consent to share such information.

 

California: Except as permitted by law, we will not share personal information we collect about California residents with Nonaffiliates and we will limit sharing such personal information with our Affiliates to comply with California privacy laws that apply to us.

 

  39  


Eaton Vance Funds

 

IMPORTANT NOTICES

 

 

Delivery of Shareholder Documents.  The Securities and Exchange Commission (SEC) permits funds to deliver only one copy of shareholder documents, including prospectuses, proxy statements and shareholder reports, to fund investors with multiple accounts at the same residential or post office box address. This practice is often called “householding” and it helps eliminate duplicate mailings to shareholders. Eaton Vance, or your financial intermediary, may household the mailing of your documents indefinitely unless you instruct Eaton Vance, or your financial intermediary, otherwise. If you would prefer that your Eaton Vance documents not be householded, please contact Eaton Vance at 1-800-262-1122, or contact your financial intermediary. Your instructions that householding not apply to delivery of your Eaton Vance documents will typically be effective within 30 days of receipt by Eaton Vance or your financial intermediary.

Portfolio Holdings.  Each Eaton Vance Fund and its underlying Portfolio(s) (if applicable) files a schedule of portfolio holdings on Part F to Form N-PORT with the SEC. Certain information filed on Form N-PORT may be viewed on the Eaton Vance website at www.eatonvance.com, by calling Eaton Vance at 1-800-262-1122 or in the EDGAR database on the SEC’s website at www.sec.gov.

Proxy Voting.  From time to time, funds are required to vote proxies related to the securities held by the funds. The Eaton Vance Funds or their underlying Portfolios (if applicable) vote proxies according to a set of policies and procedures approved by the Funds’ and Portfolios’ Boards. You may obtain a description of these policies and procedures and information on how the Funds or Portfolios voted proxies relating to portfolio securities during the most recent 12-month period ended June 30, without charge, upon request, by calling 1-800-262-1122 and by accessing the SEC’s website at www.sec.gov.

 

  40  


Investment Adviser of Eaton Vance Greater India Fund and Greater India Portfolio

Boston Management and Research

Two International Place

Boston, MA 02110

Investment Sub-Adviser of Eaton Vance Greater India Fund and Greater India Portfolio

Goldman Sachs Asset Management, L.P.

200 West Street

New York, NY 10282

Administrator of Eaton Vance Greater India Fund

Eaton Vance Management

Two International Place

Boston, MA 02110

Principal Underwriter*

Eaton Vance Distributors, Inc.

Two International Place

Boston, MA 02110

(617) 482-8260

Custodian

State Street Bank and Trust Company

State Street Financial Center, One Lincoln Street

Boston, MA 02111

Transfer Agent

BNY Mellon Investment Servicing (US) Inc.

Attn: Eaton Vance Funds

P.O. Box 9653

Providence, RI 02940-9653

(800) 262-1122

Independent Registered Public Accounting Firm

Deloitte & Touche LLP

200 Berkeley Street

Boston, MA 02116-5022

Fund Offices

Two International Place

Boston, MA 02110

 
*

FINRA BrokerCheck.  Investors may check the background of their Investment Professional by contacting the Financial Industry Regulatory Authority (FINRA). FINRA BrokerCheck is a free tool to help investors check the professional background of current and former FINRA-registered securities firms and brokers. FINRA BrokerCheck is available by calling 1-800-289-9999 and at www.FINRA.org. The FINRA BrokerCheck brochure describing this program is available to investors at www.FINRA.org.


 

142    12.31.21


Item 2. Code of Ethics

The registrant (sometimes referred to as the “Fund”) has adopted a code of ethics applicable to its Principal Executive Officer, Principal Financial Officer and Principal Accounting Officer. The registrant undertakes to provide a copy of such code of ethics to any person upon request, without charge, by calling 1-800-262-1122. The registrant has not amended the code of ethics as described in Form N-CSR during the period covered by this report. The registrant has not granted any waiver, including an implicit waiver, from a provision of the code of ethics as described in Form N-CSR during the period covered by this report.

Item 3. Audit Committee Financial Expert

The registrant’s Board of Trustees (the “Board”) has designated George J. Gorman, William H. Park and Scott E. Wennerholm, each an independent trustee, as audit committee financial experts. Mr. Gorman is a certified public accountant who is the Principal at George J. Gorman LLC (a consulting firm). Previously, Mr. Gorman served in various capacities at Ernst & Young LLP (a registered public accounting firm), including as Senior Partner. Mr. Gorman also has experience serving as an independent trustee and audit committee financial expert of other mutual fund complexes. Mr. Park is a certified public accountant who is a private investor. Previously, he served as a consultant, as the Chief Financial Officer of Aveon Group, L.P. (an investment management firm), as the Vice Chairman of Commercial Industrial Finance Corp. (specialty finance company), as President and Chief Executive Officer of Prizm Capital Management, LLC (investment management firm), as Executive Vice President and Chief Financial Officer of United Asset Management Corporation (an institutional investment management firm) and as a Senior Manager at Price Waterhouse (now PricewaterhouseCoopers) (a registered public accounting firm). Mr. Wennerholm is a private investor. Previously, Mr. Wennerholm served as a Trustee at Wheelock College (postsecondary institution), as a Consultant at GF Parish Group (executive recruiting firm), Chief Operating Officer and Executive Vice President at BNY Mellon Asset Management (investment management firm), Chief Operating Officer and Chief Financial Officer at Natixis Global Asset Management (investment management firm), and Vice President at Fidelity Investments Institutional Services (investment management firm).


Item 4. Principal Accountant Fees and Services

(a)-(d)

The following table presents the aggregate fees billed to the registrant for the registrant’s fiscal years ended December 31, 2020 and December 31, 2021 by the registrant’s principal accountant, Deloitte & Touche LLP (“D&T”), for professional services rendered for the audit of the registrant’s annual financial statements and fees billed for other services rendered by D&T during such periods.

 

Fiscal Years Ended

   12/31/20      12/31/21  

Audit Fees

   $ 38,900      $ 38,900  

Audit-Related Fees(1)

   $ 0      $ 0  

Tax Fees(2)

   $ 35,295      $ 34,195  

All Other Fees(3)

   $ 0      $ 0  
  

 

 

    

 

 

 

Total

   $ 74,195      $ 73,095  
  

 

 

    

 

 

 

 

(1) 

Audit-related fees consist of the aggregate fees billed for assurance and related services that are reasonably related to the performance of the audit of the registrant’s financial statements and are not reported under the category of audit fees.

(2) 

Tax fees consist of the aggregate fees billed for professional services rendered by the principal accountant relating to tax compliance, tax advice, and tax planning and specifically include fees for tax return preparation and other tax related compliance/planning matters

(3)

All other fees consist of the aggregate fees billed for products and services provided by the principal accountant other than audit, audit-related, and tax services.

(e)(1) The registrant’s audit committee has adopted policies and procedures relating to the pre-approval of services provided by the registrant’s principal accountant (the “Pre-Approval Policies”). The Pre-Approval Policies establish a framework intended to assist the audit committee in the proper discharge of its pre-approval responsibilities. As a general matter, the Pre-Approval Policies (i) specify certain types of audit, audit-related, tax, and other services determined to be pre-approved by the audit committee; and (ii) delineate specific procedures governing the mechanics of the pre-approval process, including the approval and monitoring of audit and non-audit service fees. Unless a service is specifically pre-approved under the Pre-Approval Policies, it must be separately pre-approved by the audit committee.


The Pre-Approval Policies and the types of audit and non-audit services pre-approved therein must be reviewed and ratified by the registrant’s audit committee at least annually. The registrant’s audit committee maintains full responsibility for the appointment, compensation, and oversight of the work of the registrant’s principal accountant.

(e)(2) No services described in paragraphs (b)-(d) above were approved by the registrant’s audit committee pursuant to the “de minimis exception” set forth in Rule 2-01 (c)(7)(i)(C) of Regulation S-X.

(f) Not applicable

(g) The following table presents (i) the aggregate non-audit fees (i.e., fees for audit-related, tax, and other services) billed to the registrant by D&T for the registrant’s fiscal years ended December 31, 2020 and December 31, 2021; and (ii) the aggregate non-audit fees (i.e., fees for audit-related, tax, and other services) billed to the Eaton Vance organization by D&T for the same time periods.

 

Fiscal Years Ended

   12/31/20      12/31/21  

Registrant

   $ 35,295      $ 34,195  

Eaton Vance(1)

   $ 150,300      $ 51,800  

 

(1) 

Certain subsidiaries of Morgan Stanley provide ongoing services to the registrant.

(h) The registrant’s audit committee has considered whether the provision by the registrant’s principal accountant of non-audit services to the registrant’s investment adviser and any entity controlling, controlled by, or under common control with the adviser that provides ongoing services to the registrant that were not pre-approved pursuant to Rule 2-01(c)(7)(ii) of Regulation S-X is compatible with maintaining the principal accountant’s independence.

Item 5. Audit Committee of Listed Registrants

Not applicable.

Item 6. Schedule of Investments

Please see schedule of investments contained in the Report to Stockholders included under Item 1 of this Form N-CSR.

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

Not applicable.

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

Not applicable.

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

Not applicable.


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

No material changes.

Item 11. Controls and Procedures

(a) The registrant maintains disclosure controls and procedures to provide reasonable assurance that the information required to be disclosed by the registrant has been recorded, processed, summarized and reported within the time period specified in the Commission’s rules and forms and that the information required to be disclosed by the registrant has been accumulated and communicated to the registrant’s principal executive officer and principal financial officer in order to allow timely decisions regarding required disclosure. Within 90 days prior to the filing date of the annual report on Form N-CSR, management carried out an evaluation of the effectiveness of the design and operation of the registrant’s disclosure controls and procedures. Based on such evaluation, the principal executive officer and principal financial officer concluded that the registrant’s disclosure controls and procedures were not effective due to a material weakness. A material weakness exists in the design of controls over the calculation of accrued foreign capital gains taxes for the registrant. The design of controls failed to adequately monitor when the amount of available capital loss carry forwards was insufficient to cover the amount of unrealized gains, which would trigger the recording of a deferred tax liability for foreign capital gains. This material weakness resulted in a material error in the 2020 financial statements of the registrant and a material corrected adjustment to the 2021 financial statements of the registrant.

The registrant is implementing enhancements to its disclosure controls and procedures to remediate the material weakness described above. Management has clarified with the fund administration team the process to be used in the calculation of accrued foreign capital gains taxes and adopted review procedures surrounding the calculation.

(b) Other than the enhancements to controls noted above that were implemented subsequent to December 31, 2021, there have been no changes in the registrant’s internal controls over financial reporting during the period covered by this report and subsequent to the date of their evaluation in connection with the preparation of this Form N-CSR that materially affected, or are reasonably likely to materially affect, the registrant’s internal control over financial reporting.

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

Not applicable.

Item 13. Exhibits

 

(a)(1)   Registrant’s Code of Ethics – Not applicable (please see Item 2).
(a)(2)(i)   Treasurer’s Section 302 certification.
(a)(2)(ii)   President’s Section 302 certification.
(b)   Combined Section 906 certification.


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.

 

Greater India Portfolio

By:

 

/s/ Edward J. Perkin

 

Edward J. Perkin

 

President

Date: March 10, 2022

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:

 

/s/ James F. Kirchner

 

James F. Kirchner

 

Treasurer

Date:

 

March 10, 2022

By:

 

/s/ Edward J. Perkin

 

Edward J. Perkin

 

President

Date:

 

March 10, 2022