11 Capital Partners LP

General Description of Advisory Firm

11 Capital, a Delaware limited partnership formed in March 2019, is an investment adviser to private fund clients and separately managed accounts. 11 Capital has been registered with the SEC as an investment adviser since January 2020. Jason McDougall (the “Chief Investment Officer”) is the principal owner of 11 Capital and has ultimate responsibility for its management and investment decisions. 11 Capital Partners GP LLC, a Delaware limited liability company, serves as the general partner of 11 Capital and is owned by Mr. McDougall and Brian Fieber, the Chief Operating Officer and Chief Compliance Officer (the “Chief Compliance Officer”) and/or entities owned or controlled by them or for the benefit of them and their families. 11 Capital has its principal place of business in Connecticut. 11 Capital Fund GP LLC (the “Fund General Partner”), a Delaware limited liability company, is an affiliate of 11 Capital and serves as the general partner of clients that are organized as U.S. and Cayman Islands exempt limited partnerships. 11 Capital and the Fund General Partner share facilities and personnel. The Fund General Partner is owned by Mr. McDougall and Mr. Fieber and/or entities owned or controlled by them or for the benefit of them and their families. B.

Description of Advisory Services

This Brochure generally includes information about 11 Capital and its relationships with their clients. While much of this Brochure applies to all such clients, certain information included herein applies to specific clients only. 11 Capital provides investment advisory services on a discretionary basis to the following private fund clients (each a “Fund” and collectively, the “Funds”):

11 Capital Onshore Fund LP, a Delaware limited partnership (the “Domestic Fund”);

11 Capital Offshore Fund Ltd, an exempted company incorporated under the laws of the Cayman Islands (the “Offshore Fund”); and

11 Capital Master Fund LP, a Cayman Islands exempted limited partnership (the “Master Fund”), which serves as the master fund into which the Domestic Fund and the Offshore Fund invest substantially all of their assets through a “master feeder” structure.

The Fund General Partner serves as the general partner of the Domestic Fund and the Master Fund. The Offshore Fund is governed by its Board of Directors. 11 Capital also provides advisory services to separately managed accounts (the “Managed Accounts”). The Managed Accounts pursue a substantially similar strategy to the Funds.

References throughout this document to “Clients” refer to the Funds and the Managed Accounts listed above and to any other private investment funds and separately managed accounts 11 Capital may advise in the future. In providing advisory services, 11 Capital pursues a global long/short equity strategy focused on identifying investments that fit into proprietary frameworks and conducting detailed companyspecific research through the use of its internal investment process. Please see “Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss” for a description of 11 Capital’s investment strategies and certain related risks. Notwithstanding the foregoing, subject to any limitations in the governing documents of the Clients, 11 Capital is not limited with respect to the types of investment strategies it may employ or the markets or instruments in which it may invest. The securities of the Funds are offered and sold on a private placement basis under exemptions promulgated under the Securities Act of 1933, as amended, and other exemptions of similar import under U.S. state laws and the laws of other jurisdictions where any offering may be made. Investors in the Funds must meet the qualifications set forth in the applicable offering documents. Persons reviewing this Brochure should not construe this as an offer to sell or solicitation of an offer to buy the securities of any of the Funds described herein. Any such offer or solicitation will be made only by means of a confidential private placement memorandum. C.

Tailored Advisory Services for Client Accounts

11 Capital manages assets in accordance with the stated investment objectives of each Client, as described in any relevant investment management agreement or similar agreement (an “IMA”) or in an offering memorandum or a Client’s organizational documents (together with the IMA and the offering memorandum, the “Offering Documents”). Investment advice is provided directly to Clients and not individually to the limited partners, shareholders, and investors in Clients (the “Investors”). In the case of the Managed Accounts, 11 Capital manages those assets in accordance with the stated investment objectives of such Managed Accounts’ IMA. 11 Capital intends for the Funds and Managed Accounts to hold similar investments, to the extent practical, subject to investment guidelines, tax, regulatory, and other considerations which may cause investments to differ. D.

Wrap Fee Programs

11 Capital does not currently participate in wrap fee programs. E.

Assets Under Management

11 Capital manages, on a discretionary basis, approximately $503,528,000 of Client regulatory assets under management. This figure for regulatory assets under management was determined as of December 31, 2025. 11 Capital does not manage any assets on a non-discretionary basis.

Advisory Services and Fees

11 Capital, either directly or indirectly through the Fund General Partner, receives management and performance-based incentive fees or allocations in connection with the investment advisory services 11 Capital provides to the Clients. 1. Funds The fees applicable to the Funds are set forth in detail in the applicable Offering Documents. A brief summary of such fees is provided below. Management Fee Investors in the Funds (“Fund Investors”) pay 11 Capital a management fee that ranges between 1% and 1.5% per annum (the “Management Fee”), based on the Fund Investor’s class of interest in the Funds. The Management Fee is based upon the Fund Investor’s capital account balance as of the beginning of the fiscal quarter. The Management Fee is generally not negotiable. However, 11 Capital has the right to reduce, waive, assign, grant participation in or otherwise share or modify the Management Fee, without the consent of, or notice to, any Investor. Typically, no Management Fee will be paid by employees of 11 Capital or its affiliates. Incentive Allocation At the end of each fiscal year, the Fund General Partner will be entitled to receive an incentive allocation based on investment performance of the Funds (the “Incentive Allocation”) generally in an amount between 15% and 20% of realized and unrealized gains for the year subject to a traditional “high watermark.” Generally, the Incentive Allocation is not negotiable. However, with respect to any Fund Investor, 11 Capital and/or the Fund General Partner will have the right to reduce, waive, assign, grant participation in or otherwise share or modify the Incentive Allocation, without the consent of, or notice to, any other Investor. Typically, no Incentive Allocation will be paid by employees of 11 Capital or its affiliates. The Funds occasionally enter into side letter arrangements with certain Investors which provide for, different or additional terms than those described above including, without limitation, the fees charged, minimum subscription amounts, redemption rights, key man provisions, “most favored nation” clauses, transfers, reporting, and other rights. The terms of such side letters will be determined by the Domestic Fund’s Fund General Partner and the Offshore Fund’s Board of Directors, where applicable.

2. Managed Accounts The Managed Accounts pay a management fee and incentive fee based on the value and performance of the assets in such account, determined in accordance with each Managed Account’s IMA. B.

Payment of Fees

With respect to the Funds, Management Fees are paid quarterly in advance. With respect to the Managed Accounts, the management fees are paid in arrears. Incentive Allocations and fees are paid in arrears as set forth in the Offering Documents and applicable IMA. With respect to the Funds, the Management Fee and Incentive Allocation are generally deducted from each Investor’s capital balance account by the Funds’ administrator. C.

Additional Expenses

The fees and allocations described above are exclusive of other expenses associated with the provision of investment advisory services that are paid by Clients. Each Client of 11 Capital generally bears all of its own expenses, including but not limited to expenses related to its operations and the investment of its assets. Each Fund shall bear those expenses as set forth in the applicable Offering Documents, as amended from time to time, including but not limited to some or all of the following:

Organizational and offering expenses;

Expenses associated with sourcing, negotiating, investigating, researching, financing and structuring of investments and potential investments, whether or not consummated, including, without limitation, third-party research, data, analytics, modeling, risk, structuring, pricing, execution and other third-party information systems, including, without limitation, installation and maintenance, software and service fees (including, without limitation, the expenses with respect to data, data feeds, subscriptions, expert networks, political intelligence providers and reports);

The costs of research-related computer hardware and software expenses, including, without limitation, Bloomberg terminals and subscriptions;

The costs of 11 Capital’s portfolio management system and any other software used for accounting and/or monitoring of the portfolio, including, without limitation, subscriptions relating to, among other things, trading and order management systems and services;

Expenses associated with holding, financing, monitoring, hedging, maintaining and disposing of all investments of the Funds and all transaction and other costs associated therewith;

Travel and related expenses associated with investments and potential investments;

Professional fees associated with investments and potential investments, including, without limitation, consulting, due diligence, accounting, valuation, financial, legal and other advisory fees and expenses;

Transaction fees, brokerage commissions, custodial fees, clearing and settlement charges and similar fees and expenses associated with the acquisition, disposition and settling of investments and potential investments;

Expenses associated with legal and regulatory filings of the Funds;

Administrative, custodial, appraisal, valuation, legal, regulatory, compliance, consulting, advisory and similar fees and expenses associated with the Funds’ operations, investments and transactions, including, without limitation, fees and expenses of the administrator;

Expenses incurred in connection with responding to requests or inquiries from any U.S. federal, state, local or non-U.S. governmental entity or authority, regulatory body or selfregulatory organization with respect to the Funds;

Broken-deal, failed transaction, break-up and similar fees, costs and expenses (if any);

Costs and expenses of leverage or any other borrowings of the Funds;

Expenses incurred in the collection of monies owed to the Funds, as applicable;

Auditing and accounting expenses of the Funds;

Any entity-level taxes, fees or other governmental charges on the Funds;

Costs and expenses associated with investor communications and reports and the delivery thereof to investors;

The costs of service providers or software to measure or monitor risk metrics, to aggregate positions and/or to provide reporting with respect to risk metrics and/or positions;

Costs and expenses associated with meetings of the Investors;

Insurance expenses, including, without limitation, general partner liability insurance and other policies, if any, as well as the Funds’ share of expenses with respect to directors’ and officers’ liability insurance and errors and omissions insurance;

Costs and expenses associated with the formation, organization and operation of any subsidiary, special purpose vehicle, alternative investment vehicle, holding company or similar entity formed with respect to investments, credit facilities or other transactions entered into for the benefit of the Funds;

Wind-up, liquidation, termination and dissolution expenses;

Costs, fees and expenses related to registration, qualification and/or exemption under any applicable U.S. federal, state, local or non-U.S. laws, rules or regulations;

Costs related to any transfers of interests in the Funds, unless otherwise charged to or borne by the applicable transferor and/or transferee;

Expenses incurred in connection with the preparation of any amendment to the Funds’ Offering Documents, including the preparation or amendment of any side letter;

Expenses incurred in connection with pursuing, defending or participating in any litigation, arbitration, mediation or similar proceeding by the Funds;

Any extraordinary expenses (including, without limitation, all litigation-related and indemnification and contribution expenses, including, without limitation, the amount of any judgment or settlement paid in connection therewith); and

All other fees, costs, charges and expenses associated with the business, affairs and/or operations of the Funds, including, without limitation, any other cost that may otherwise be paid by the Funds with soft dollars pursuant to Section 28(e) of the Exchange Act.

In general, each Fund Investor will bear its proportionate share of the Fund’s expenses on a pro rata basis with respect to the size of its capital account balance. 11 Capital and/or the Fund General Partner may, however, allocate expenses on another basis, including by allocating certain expenses to certain (but not all) Investors in a Fund, if 11 Capital and/or the Fund General Partner determine that such an allocation is more equitable. The expenses borne by the Managed Accounts, to the extent that they are different from the expenses listed above, are detailed in each Managed Account’s IMA. To the extent that expenses to be borne by a Client are paid by 11 Capital, the Client will reimburse 11 Capital for such expenses. To the extent that Client expenses are attributable to multiple Clients, such amounts will be allocated in accordance with 11 Capital’s expense allocation policies, pursuant to which 11 Capital will generally allocate such expenses pro rata based upon the respective net asset values of such applicable 11 Capital Clients, the relative use of a product or service, or such other allocation methodology determined by 11 Capital in its discretion subject to applicable law. However, it is possible not all expenses will be allocated ratably across all Clients. D.

Prepayment of Fees

With respect to the Funds, the Management Fee is paid quarterly in advance. E.

Additional Compensation and Conflicts of Interest

Neither 11 Capital nor its personnel receive a brokerage commission or any other compensation for the sale of securities or other investment products.

Method of Analysis, Investment Strategies and Risk of Loss A.

Methods of Analysis and Investment Strategies

The descriptions set forth in this Brochure of specific advisory services that 11 Capital offers to Clients, and investment strategies pursued and investments made by it on behalf of Clients, should not be understood to limit in any way 11 Capital's investment activities. 11 Capital may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that are considered appropriate, subject to each Client's investment objectives and guidelines. The investment strategies that 11 Capital pursues are speculative and entail substantial risks. Clients and Investors should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any client will be achieved. The investment objective of the Funds is to generate attractive, risk-adjusted returns pursuant to a global long/short equity strategy focused primarily on conducting deep bottoms-up analysis on companies. 11 Capital attempts to identify investments that fit into proprietary frameworks, a unique means of finding alpha generating opportunities, followed by highly detailed companyspecific research through the use of its internal investment process to create an investment edge with a variant perception over a twelve (12) to sixty (60) month timeframe. Generally, the Funds endeavor to avoid popular or consensus investments and focus instead on sourcing differentiated ideas, providing minimal overlap with many other similarly-situated long/short hedge funds. 11 Capital primarily focuses on companies in the consumer, industrials, technology, media and telecom sectors. However, 11 Capital expects to make investments in a wide range of sectors and will seek to develop industry sector themes consistent with its investment objectives of the Funds. 11 Capital seeks to generate long investment opportunities by following a repeatable research process intended to identify high-performing companies when they dislocate, allowing 11 Capital to determine if the cause is permanent or transitory. 11 Capital also searches for special situations that create new opportunities to invest in high-performing companies including exceptional but undermanaged companies that upgrade to a superior management team and high-performing companies spun off from larger but inferior parent companies. Short investment opportunities are expected to be generated through (i) organic research on the long side, where through its research process, 11 Capital discovers competitors, vendors or customers that high performing companies are pressuring, disrupting, or rendering obsolete; (ii) data tracking processes designed to uncover companies exhibiting signs indicative of future problems; and (iii) search inversion where 11 Capital reverses its search algorithms for longs to uncover shorts that have chronic and unsolvable issues that have caused them to consistently underperform and destroy shareholder value. The Managed Accounts pursue the identical or substantially similar strategy as the Funds. B.

Material, Significant or Unusual Risks Relating to Investment Strategies

The investment program that 11 Capital pursues on behalf of its Clients is speculative and involves substantial risks. There can be no assurance that Clients will achieve their investment objectives. As a result of the inherent riskiness and uncertainty of an investment in the Clients, such investment involves the risk of loss of some or all of an Investor’s investment.

Risk Factors These risk factors reflect a summary of those risks 11 Capital believes to be material, significant or unusual and relate to the significant investment strategies or methods of analysis that 11 Capital employs and do not purport to be a complete list or explanation of the risks involved in an investment in a 11 Capital Client. Prospective Investors should carefully consider the risks involved in an investment in a Client, including, but not limited to, those discussed below. For a complete explanation of all relevant investment strategies and their associated risks, prospective Investors should review the applicable Offering Documents and/or IMA, which may contain explanations of additional strategies and corresponding risks not discussed below. Risks Relating to Investment Strategy General Investment and Trading Risks. All securities investments present a risk of loss of capital. Volatile financial markets increase that risk. If 11 Capital’s evaluation of an investment opportunity should prove incorrect, the Clients could experience losses as a result of a decline in the market value of securities in which the Clients holds a long position or an increase in the value of securities in which the Clients holds a short position. The Clients’ investment program includes short sales, which can involve substantial volatility and can, in certain circumstances, substantially increase the adverse impact to which the Clients may be subject. The risk management techniques that may be used by 11 Capital do not provide any assurance that the Clients will not be exposed to a risk of significant investment losses. No guarantee or representation is made that the Clients’ investment program will be successful, that the Clients will achieve their targeted returns or that there will be any return of capital to Investors. In addition, investment results may vary substantially over time. Investment Judgment. The profitability of a significant portion of the Clients’ investment program depends to a great extent upon correctly assessing the future profitability of companies and future price movements of securities and other investments. There can be no assurance that 11 Capital will be able to accurately predict the long-term results of any security or other investment. Availability of Suitable Investments. The success of the Clients’ investment and trading activities depend on the ability of 11 Capital to identify overvalued and undervalued investment opportunities and to manage market risk. Identification and exploitation of the investment strategies to be pursued by the Clients involve a high degree of uncertainty. No assurance can be given that 11 Capital will be able to identify suitable investment opportunities in which to deploy all of the Clients’ capital. A reduction in overall market volatility and liquidity, as well as other market factors, may reduce the pool of profitable investments for the Clients. Certain of the investment strategies employed by the Clients may be based on historical relationships among securities prices, exchange rates, interest rates and bond prices. There can be no assurance that these historical relationships will continue. No representation is made by 11 Capital as to what results the Clients will or is likely to achieve based on these trends and relationships. Available Information. 11 Capital may select investments, in part, on the basis of information and data filed by the issuers of securities with various government regulators or made directly available to 11 Capital by such issuers, or through sources other than the issuers. Although 11 Capital evaluates all such information and data, and seeks independent corroboration when 11

Capital considers it appropriate and when it is reasonably available, 11 Capital is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not readily available. Concentration of Investments; Limited Diversification and Sector Investing. The Clients hold a limited amount of positions (both long and short) at any given time, and the Clients hold relatively large positions in few securities. As a result of the Clients’ possible lack of diversification, a significant loss in any one position may have a material adverse effect on the net asset value of the Clients’ rate of return. Likewise, any fluctuation in the overall value of securities in specific industries or sectors likely will have a material effect on the performance of the Clients. Risk Management. The Clients’ investment program is speculative and entails substantial risks. There can be no assurance that the investment objectives of the Clients will be achieved or that the Clients will be profitable, and results may vary substantially over time.11 Capital will focus on managing risk through the quality of its investment process and monitoring of investments. 11 Capital may not broadly diversify the portfolio, and in such event, the Clients will bear greater risk with respect to each investment than would be the case with respect to a diversified portfolio. There can be no assurance that the investment objectives of the Clients will be achieved. In fact, many of the investment techniques utilized by the Clients may, in certain circumstances, exacerbate the adverse impact of particular transactions or conditions on the investment program of the Clients. Short Sales. Short selling involves borrowing, including from securities brokers or other institutions, and selling securities that are not owned, with an obligation to replace the borrowed securities at a later date, the cost of which may be significant. Short selling allows the investor to profit from a decline in market prices to the extent such decline exceeds the transaction costs and the costs of borrowing the securities. However, since the borrowed securities must be replaced by purchases at market prices to close out the short position, any appreciation in the price of the borrowed securities would result in a loss. A short sale involves the risk of a theoretically unlimited increase in the market price of the security. Purchasing securities to close out the short position can itself cause the price of the securities to rise further, thereby exacerbating the loss. In addition, short sellers are subject to the risk of a “short squeeze.” A short squeeze is a situation in which the short seller is prematurely forced out of a short position. The lender of a security used to cover a short generally has the right to demand the return of the security that has been loaned at any time. If a lender were to demand the return of securities that the Clients had borrowed, the Clients would be required to replace the borrowed securities by borrowing identical securities from another lender. If the Clients were unable to replace the borrowed securities, it would be required to close out the short sale by buying identical securities in the market to make delivery. In such event, the Clients could incur significant losses if the securities sold short had increased in value. The Clients also could be forced to close out a short sale prematurely as a result of an increase in margin requirements, coupled with an inability to provide the required additional margin on short notice. In addition, the cost to borrow securities in connection with short sales may be significant.

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Types of Clients 11 Capital provides investment advice to the Funds and Managed Accounts, as described above. Investors in a Fund generally include, among others, institutions, high net worth individuals, family offices, fund of funds, endowments, foundations, trusts, charitable organizations, pension funds, corporate business entities, and other sophisticated investors. The Funds typically require a minimum initial investment of $5,000,000, although the amount of the minimum capital commitment may be waived or modified by 11 Capital in its sole discretion. Investors generally must be “Accredited Investors” and “Qualified Purchasers” (as defined under federal securities laws). The minimum required for a separately managed account is determined on a case-by-case basis.

Performance-Based Fees and Side-By-Side Management 11 Capital and/or the Fund General Partner receive performance-based fees or allocations from every Client. As a result, 11 Capital and the Fund General Partner do not face certain conflicts of interest that may arise when an investment adviser accepts performance-based fees or allocations from some clients, but not from other clients. The receipt of performance-based fees or allocations can incentivize 11 Capital to make investments that are riskier or more speculative than it would otherwise make. In addition, because the incentive fee or allocation is calculated based on unrealized appreciation of a Client’s net assets, it may be greater than if such compensation were based solely on realized gains. These conflicts are disclosed in the applicable Offering Documents and/or IMA and are believed to be understood by 11 Capital’s Clients. 11 Capital seeks to mitigate such conflicts of interest through the adoption and implementation of its investment allocation policy.

Broker-Dealer Registration

11 Capital and its management persons are not registered as broker-dealers and do not have any application pending to register with the SEC as a broker-dealer or a registered representative of a broker-dealer. B.

Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor Registration

11 Capital and its management persons are not registered as, and do not have any application pending to register as a futures commission merchant, commodity pool operator, a commodity trading advisor, or is an associated person of any of the above. 11 Capital has claimed an exemption from CFTC registration under Rule 4.13(a)(3), which exempts commodity pool operators that (i) trade only a de minimis level of commodity interests, (ii) market to “accredited investors”, and (iii) do not market trading in commodity interests. C.

Material Relationships and Conflicts of Interests with Industry Participants

The Firm’s relationships and arrangements with its Clients and other industry participants are material to its advisory business and may raise actual or potential conflicts of interest. Prospective Investors should carefully consider the risks involved in an investment with us, including, but not limited to, those discussed below. Prospective Investors should consult their own legal, tax and financial advisers as to all of these risks and as to an investment with the Firm generally. Multiple Client Accounts As discussed in Item 4, “Advisory Business” above, 11 Capital provides investment advisory services to multiple Clients. Notwithstanding the foregoing, The Fund General Partner, an affiliate of 11 Capital, serves as the general partner of the Domestic Fund and the Master Fund. 11 Capital, at any time and from time to time, expects to manage assets for other investment vehicles and accounts, either directly through separately managed accounts or indirectly through funds-of-one or other pooled investment vehicles, in the future. These other investment vehicles and accounts may utilize investment strategies that are similar to, or different than, that of the Funds and may be subject to terms, including fees, withdrawal rights, reporting, and disclosure requirements and other terms that are different than the terms applicable to the Funds. As a result of the foregoing, 11 Capital and its affiliates may have conflicts of interest in (i) allocating the time and resources of 11 Capital personnel between and among Clients, (ii) allocating investment opportunities between and among Clients, and (iii) effecting transactions between Clients, including Clients in which 11 Capital or its personnel may have different financial interests.

Research Providers The Chief Investment Officer and Chief Compliance Officer hold minority equity interests in several third-party research providers (collectively, the “Research Firms”), which provide, among other products and services, portfolio and data analytics, research and industry experts. 11 Capital engages such Research Firms to provide research to 11 Capital and the Clients. While 11 Capital believes that the quality and pricing of the Research Firms are as good as, or better than, the Research Firms’ competitors and peers, a conflict of interest arises because the payment of fees by the Clients to the Research Firms may increase the profitability of the Research Firms and, therefore, increase the value of the Chief Investment Officer’s and Chief Compliance Officer’s investments in the Research Firms. Accordingly, 11 Capital currently intends that all fees and expenses charged by the Research Firms will be borne by 11 Capital. Other Registered Investment Advisers The Chief Investment Officer holds a minority, passive, equity interest in an unaffiliated registered investment adviser (the “MA RIA”). 11 Capital advises an account of a private fund primarily advised by the MA RIA (the "MA Client"). Although the Chief Investment Officer has no managerial role or other involvement in the MA RIA's business activities, decisions or operations, his passive economic interest in the MA RIA can give rise to certain risks and conflicts of interest which include the possibility that the Chief Investment Officer would be incentivized to allocate attractive investment opportunities to the MA Client in priority over other Clients. 11 Capital addresses such conflict of interest by allocating investments in accordance with its allocation policy described in Item 11 below. All of 11 Capital’s Clients pursue a substantially similar investment strategy and investments are generally managed pari passu. Subject to limited exception, allocations of investment opportunities will be made to participating Clients, including the MA Client, pro rata based on each such Client’s respective net asset value. How 11 Capital Addresses Potential Conflicts of Interest To address potential conflicts of interests in its material relationships, 11 Capital has adopted certain policies and procedures, including a Code of Ethics. The Chief Compliance Officer is responsible, on a day-to-day basis, for implementing these policies such that they do not pose a material risk to 11 Capital and its Clients. For a more detailed discussion of the Code of Ethics, please see Item 11, “Code of Ethics, Participation or Interest in Client Transactions and Personal Trading,” below. D.

Material Conflicts of Interest Relating to Other Investment Advisers

11 Capital does not recommend or select other investment advisers for our Clients.

Code of Ethics

Pursuant to Rule 204A-1 of the Investment Advisers Act of 1940, as amended (the "Advisers Act"), 11 Capital has adopted a Code of Ethics designed to reinforce and enhance the Firm’s ethical way of doing business. The Code of Ethics is based on the principle that 11 Capital and its employees have a fiduciary duty to its Clients, and must in this fiduciary capacity, place the interest of the Clients before its own. The Code of Ethics is designed to address and avoid conflicts of interests and is applicable to all employees. The Code of Ethics contains detailed rules concerning, among other issues, conflicts of interests, procedures with respect to personal securities transactions, gifts and entertainment, and outside business activities. Furthermore, the Code of Ethics provides for a range of sanctions, as deemed appropriate, including censure, fine, reversal of transactions and disgorgement of profits, suspension or termination of employment. A copy of 11 Capital’s Code of Ethics is available upon request by contacting 11 Capital at the address or telephone number listed on the first page of this document. B.

Participation or Interest in Client Transactions

11 Capital and its employees, directly or indirectly, have investments in the Funds. As a result, 11 Capital and its employees have an interest in the investments that may also be recommended to Clients. Employees may be in possession of information relating to the Funds that is not available to other existing and prospective Investors. Employees are not required to keep any minimum investment in the Funds. It is expected that the size and nature of these Employee investments will change over time without notice to Investors. Investments by the Chief Investment Officer and employees in the Funds could incentivize the Chief Investment Officer and employees to increase or decrease the risk profile of the Funds. 11 Capital does not intend to purchase or sell any securities for its own account and does not otherwise expect to engage in any principal transactions. However, on occasion, and subject to a Client’s applicable investment guidelines and restrictions, 11 Capital may determine that it would be in the best interests of the Clients to transfer a security from one Client to another (each such transfer, a "Cross Trade") for a variety of reasons, including tax purposes, liquidity purposes, to rebalance the portfolios of Clients, or to reduce transaction costs that may arise in an open market transaction. If 11 Capital decides to engage in a Cross Trade, it will determine that the trade is in the best interests of both of Clients involved and take steps to ensure that the transaction is consistent with the duty to obtain best execution for each of those Clients. 11 Capital intends to execute Cross Trades, if at all, with the assistance of a broker-dealer that executes and books the transaction at the close of the market on the day of the transaction. Alternatively, a Cross Trade between two Clients may occur as an "internal cross," where 11 Capital instructs the prime broker for the Clients to book the transaction at a price consistent with the Firm’s Valuation Policy. If 11 Capital effects an internal cross, it will not receive any fee in connection with the completion of the transaction. Cross Trades generally will be made without brokerage commissions being charged. When effecting Cross Trades between Clients, 11 Capital will have potentially conflicting

division of loyalties and responsibilities with respect to each participating Client. To the extent that any such Cross Trade may be viewed as a principal transaction due to the ownership interest in the Client by 11 Capital or its personnel, 11 Capital will comply with all applicable requirements of the Advisers Act. C.

Personal Trading

11 Capital’s Code of Ethics places restrictions on personal trades by its employees and any of their respective spouses, domestic partners or children living in the same household of such employees (each a “Covered Persons”). Except with respect to certain permitted investments, 11 Capital does not typically permit Covered Persons to trade Reportable Securities (as defined in the Code of Ethics, and which include single name equity and debt securities, options or other derivatives on securities, indices and currencies, and interests in private investment funds) in their personal accounts. Permitted investments include mutual funds, U.S. government securities, currencies, ETFs, closed-end funds, unit investment trusts, and other broad index securities. On occasion, and subject to written pre-clearance from the Chief Compliance Officer, Covered Persons may be permitted to trade certain Reportable Securities if such transactions do not pose a conflict of interest. For example, Covered Persons may be permitted to sell securities acquired prior to joining 11 Capital. Such securities may be held in Client portfolios and 11 Capital may intend to cause Clients to continue to hold such securities. Covered Persons may be permitted to purchase certain positions that are not appropriate for 11 Capital’s Clients. Covered Persons must also disclose all personal accounts and holdings initially upon commencement of employment, and annually thereafter. In addition, Covered Persons are required to provide quarterly reports regarding transactions in Reportable Securities and newly opened personal accounts thereafter. D.

Conflicts of Interest Created by Contemporaneous Trading

11 Capital seeks to allocate investment opportunities in a manner that is fair and equitable. The Funds and Managed Account pursue a substantially similar investment strategy and are generally managed pari passu. Allocations of investment opportunities will be made to participating Clients pro rata based on each such Client’s respective net asset value. However, 11 Capital may make non-pro rata allocations among Clients based upon a variety of factors including, among other things, investment program and investment objectives, investment capacity, amount of deployed and undeployed capital, fixed investment periods (if any), available leverage, desired leverage or available cash, tax, legal and regulatory considerations, overall portfolio composition, tolerance for volatility and risk, desired concentration, exposure and diversification targets, liquidity needs, different terms governing Clients, risk profile, investment guidelines and restrictions, to avoid oddlots, when a pro rata allocation would result in a de minimis allocation to one or more Clients and/or such other factors that 11 Capital determines consistent with fair and equitable treatment of all Clients over time. In general, closing transactions (i.e., sales and cover transactions) of investments held by multiple Clients generally will be executed on a pari passu basis. However, investment decisions, including the decision to unwind an existing investment, can be made independently for each Client.

Brokerage Practices Pursuant to the relevant Offering Documents and/or applicable IMA, 11 Capital has discretion to select broker-dealers to effect transactions on behalf of its Clients. Accordingly, portfolio transactions will be allocated to such brokers-dealers based on best execution and in consideration of such broker-dealers’ provision or payment of the costs of research and other services. A.

Selection of Broker-Dealers and Reasonableness of Compensation

11 Capital places trades for execution only with approved brokers-dealers. Purchase and sale transactions for Client accounts are generally allocated to broker-dealers on the basis of best execution. When selecting broker-dealers (including prime brokers) to execute transactions, 11 Capital considers the full range and quality of a broker-dealer’s services (both qualitative and quantitative factors) including, but are not limited to: 

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Quality of execution (including accurate and timely execution, clearance and error/dispute resolution); Reputation, financial strength and stability; Block trading and block positioning capabilities; Willingness to execute difficult transactions; Willingness and ability to commit capital; Access to underwritten offerings and secondary markets; Ongoing reliability; Overall costs of a trade (i.e., net price paid or received) including commissions, mark-ups, mark-downs or spreads in the context of the Firm’s knowledge of negotiated commission rates currently available and other current transaction costs; Nature of the security and the available market makers; Desired timing of the transaction and size of trade; Confidentiality of trading activity; Market intelligence regarding trading activity; The quality, comprehensiveness and accuracy of research services 11 Capital considers of value, whether received directly from a broker or indirectly through a soft dollar or commission sharing arrangement; and Quality of sales trading coverage, including product knowledge, showing of flows etc.

Accordingly, the prices and commission rates charged to Clients by brokers-dealers may be higher than those charged by other brokers-dealers that may not offer such services. In addition, 11 Capital executes a portion of Client securities transactions through an outsourced trading firm, who has the authority to select broker-dealers to execute transactions on behalf of the Clients. As a result, the Clients’ expenses may be higher, as a result of paying such outsourced trading firm than if 11 Capital traded directly with other brokers-dealers.

11 Capital maintains a Brokerage Committee that periodically meets to review the quality of the Firm’s execution and various trading matters. 1. Research and Other Soft Dollar Arrangements 11 Capital uses “soft dollars” to obtain brokerage and research services within the meaning of Section 28(e) of the Exchange Act (“Section 28(e)”). Any soft dollar transactions are expected to fall within the safe harbor provided by Section 28(e). The services furnished by a broker-dealer pursuant to soft dollar transactions for one Client are expected to benefit 11 Capital and its affiliates in rendering investment management services to other Clients. Research products or services within the scope of Section 28(e) typically include research reports, market data, trading software (e.g., an order management system), discussions with research analysts and expert network consultants, meetings with corporate executives, software that provides for analysis of securities and certain publications. Brokerage services generally include activities related to executing securities transactions. In some instances, 11 Capital receives a product or service that may be used only partially for functions covered by Section 28(e) (i.e., a “mixed-use” item). In such instances, 11 Capital will make a good faith effort to determine the relative portion of the product or service used to assist 11 Capital in carrying out its investment decision-making responsibilities with respect to the Clients and the relative portion used for administrative or other purposes not covered by Section 28(e). The portion of the product or service attributable to assisting 11 Capital in carrying out its investment decision-making responsibilities with respect to the Clients, as applicable, will be paid through brokerage commissions generated by transactions on behalf of the Clients, and the portion attributable to administrative or other purposes not covered by Section 28(e) is expected to be paid by 11 Capital from its own resources, and/or the Clients. To the extent that 11 Capital uses “full-service brokers” which provide research and other services to 11 Capital and the commission associated with such services is greater than would otherwise be obtained using available floor brokers or electronic brokers, such commission could be deemed to comprise soft dollar arrangements. 11 Capital has also entered into “commission sharing arrangements” with one or more brokerdealers. Under these arrangements, a portion of the commission is paid to that broker-dealer for execution services and the remainder of the commission is paid to other approved broker-dealers or third-party research providers for research services provided by such broker-dealers or vendors. Transactions executed under these commission sharing arrangements generate a higher commission rate than transactions executed with other broker-dealers. When 11 Capital uses brokerage commissions generated by any Client to obtain research or other products or services, 11 Capital receives a benefit because it does not have to produce or pay for such products or services. While 11 Capital is obligated to seek best execution for each Client, the fact that 11 Capital can obtain or receive such products or services may create an incentive for it to select or recommend a particular broker-dealer more favorable to 11 Capital’s interests, to the exclusion of another broker-dealer that offers business terms which are more favorable to one or more Clients.

On a periodic basis, the Brokerage Committee will evaluate the amount and nature of brokerage and research services provided by brokers under these arrangements to ensure that such services received by 11 Capital are within the safe harbor provided under Section 28(e) and that the allocation of the 11 Capital’s brokerage business is appropriate. 2. Brokerage for Client Referrals Subject to broker-dealer selection factors discussed above, 11 Capital may allocate transactions to broker-dealers on the basis of capital introduction and consulting services provided by such brokerdealers. Even though 11 Capital does not compensate broker-dealers (including prime brokers) for such services and does not commit to allocate a particular amount of brokerage to a broker-dealer and/or prime broker in return for capital introduction services, the use of capital introduction services could create a conflict of interest when deciding which prime brokers to use. 3. Directed Brokerage 11 Capital does not recommend, request, or require that a Client direct 11 Capital to execute transactions through a specified broker-dealer. B.

Aggregating Orders for Client Accounts

Consistent with its duty to seek the best possible execution for Clients, to the extent practicable, 11 Capital will typically seek to aggregate (or “bunch” or “block”) orders that are placed for more than one Client. Aggregated orders include: (i) one order placed on behalf of more than one Client account; and (ii) multiple orders placed on behalf of one or more Client accounts. When an aggregated order is filled in its entirety, each participating Client will participate at the average share price for the bunched order, and transaction costs shall be shared pro rata among each Client participating in the bunched order. If 11 Capital places multiple bunched orders in the same security or other investment, and such orders are executed at multiple prices during the day, the Clients will generally participate at the average price paid. Partially filled orders will generally be allocated pro rata in proportion to the original allocation but may be modified on a basis that 11 Capital deems to be appropriate, including, for example, in order to avoid odd lots or de minimis allocations. Although 11 Capital believes that aggregating orders usually facilitates best execution and reduces transactional costs, it is possible that the average price received for an aggregated order may be worse than the price which a Client could have received had it executed a smaller quantity of shares on its own. There may also be corresponding potential disadvantages when more than one Client simultaneously seeks to dispose of commonly held securities or other investment positions.

Client Referrals and Other Compensation 11 Capital does not receive economic benefits from non-Clients for providing investment advice and other advisory services. Currently, neither 11 Capital nor any of its related persons, directly or indirectly compensate any person who is not a supervised person, including placement agents, for Client referrals. 11 Capital may in the future engage placement agents that solicit or refer potential Clients or Investors on our behalf. Such placement agents will be subject to a conflict of interest because they will be compensated in connection with their solicitation activities. In addition, the use of capital introduction services provided by executing or prime brokers may create a conflict of interest in that it may create an incentive for 11 Capital to direct additional brokerage to such executing brokers or prime brokers.

Disciplinary Information There are no legal or disciplinary events that are material to a Client’s or prospective Investor’s evaluation of the Firm’s advisory business or the integrity of the Firm’s management.

Periodic Review of Client Accounts

The Chief Investment Officer has ultimate responsibility for all investment decisions. The Chief Investment Officer regularly meets with the investment team to discuss new and existing positions held by the Clients. With the assistance of the investment team and the Chief Compliance Office, the Chief Investment Officer continuously monitors Clients’ investments, transactions, performance, and investment strategy to ensure that they conform with the investment objectives set forth in the Offering Documents and the applicable IMA. B.

Additional Review of Client Accounts

A review of a Client’s portfolio may be triggered for a variety of reasons, including unusual activity and changes to certain risk metric controls, such as gross/net exposure, weighted-average betas, long/short exposure, industry weightings, price targets, liquidity metrics and individual stock valuations. C.

Contents and Frequency of Account Reports to Clients

11 Capital provides Fund Investors with annual audited financial statements for the Funds (within 120 days after the end of each fiscal year) and Schedules K-1 with respect to each Investor’s interest in the Fund. In addition, 11 Capital provides Fund Investors with performance and other updates on a periodic basis. In addition to the information provided to all Fund Investors as explained above, 11 Capital provides certain Fund Investors with additional information. This information may provide such Fund Investors with greater insight into the Funds’ activities and possibly affect such Fund Investor's decision to request a redemption from a Fund. 11 Capital also provides the Managed Accounts with various reporting that is more frequent and more detailed than what is provided to Fund Investors.

Custody Pursuant to Rule 206(4)-2 (the “Custody Rule”) under the Advisers Act, 11 Capital is deemed to have custody of the funds and securities held by the Funds. To comply with this Rule, the funds and securities of each Fund must be held by a qualified custodian, with the exception of certain privately offered securities. In addition, 11 Capital meets its custody reporting requirements through the audit method by having the financial statements of each Fund audited annually by an independent, PCAOB-registered accounting firm. 11 Capital subsequently distributes the results of the audited financials to the Investors in each Fund within 120 days after the end of the fiscal year. 11 Capital does not have custody of the funds and securities held in the Managed Accounts.

Investment Discretion 11 Capital has full discretionary investment authority with respect to the Funds and the Managed Accounts, including the authority to determine which securities and investments to buy or sell and the amount of securities and investments to buy or sell, the brokers through which 11 Capital effects trades and the commission rates at which 11 Capital effects trades. Despite this broad authority, 11 Capital is committed to adhering to the investment strategy and program set forth in the applicable Offering Documents and/or applicable IMA.

Voting Client Securities 11 Capital has the authority to cast all proxy votes for its Clients’ securities. As a result, 11 Capital has adopted proxy voting policies and procedures pursuant to and in compliance with the Advisers Act Rule 206(4)-6. 11 Capital’s general policy is to vote proxy proposals, amendments, consents or resolutions (collectively, “Proxies”) in a prudent and diligent manner that will serve the applicable Client’s best interests and is consistent with each Client’s investment objectives. 11 Capital generally expects to vote Proxies in accordance with the recommendations of company management. However, there are many complexities to Proxies, and 11 Capital will vote against a proposal or recommendation of management if it determines that such a vote is in the best interests of its Clients. 11 Capital will process every vote it receives for U.S. and non-U.S. Proxies. Certain types of matters that are the subject of a proxy vote may require a more detailed analysis than the analysis required for some routine or uncontested matters. 11 Capital will abstain from voting or affirmatively decide not to vote if it determines, after considering a variety of factors, that abstaining or not voting is in the best interests of 11 Capital’s Clients. Conflicts of interest may arise between the interests of the Clients and 11 Capital or its affiliates. If 11 Capital determines that it may have, or be perceived to have, a conflict of interest when voting Proxies, 11 Capital will vote in accordance with its Proxy voting policies. Investors and prospective Investors may obtain a copy of 11 Capital’s Proxy voting policies and procedures and information about how 11 Capital voted a Client’s proxies by contacting 11 Capital at the address or telephone number listed on the first page of this document.

Financial Information The Firm is not required to include a balance sheet for its most recent fiscal year, is not aware of any financial condition reasonably likely to impair its ability to meet contractual commitments to Clients and has not been the subject of a bankruptcy petition at any time during the past ten years.