1607 Capital Partners, LLC

1607 Capital Partners, LLC (“1607 Capital”), a Delaware limited liability company is an investment advisory firm founded in 2007. 1607 Capital Partners Limited (the “Relying Adviser” and together with 1607 Capital, “1607” or the “Company”) was incorporated in 2017 in England and Wales and is a wholly owned subsidiary of 1607 Capital Partners, LLC. All persons acting on behalf of the Relying Adviser are subject to the supervision and control of the Company. 1607 Capital is privately held and majority owned by Shannon Fake, Ashley Long, James Mallory, Kirk Tattersall and Rosemont Investment Group, LLC. 1607 offers investment advisory services to high net worth individuals and institutional clients including corporate and public pension funds, and university and foundation endowments. The Company provides these services through commingled private funds (“Funds”) and separately managed accounts (“Managed Accounts”, and together with Funds, “Clients”). 1607 currently offers seven different investment strategies in which a client may participate. Aside from a willingness to abide by a limited set of guidelines imposed by the client, 1607 does not tailor investment advice based on each client's individual needs, but rather according to the parameters for each investment product or strategy the Company manages. 1607 enters into a discretionary investment management agreement with each Client. These agreements establish each Client’s investment strategy and the other terms, limitations and conditions of 1607’s engagement. Client assets are actively managed by investing primarily in closed-end mutual funds that invest in domestic equities, international equities, and fixed income products. “Closed-end mutual funds” means exchange-traded closed-end funds and similar exchange-traded investment funds and investment holding companies (together, “CEFs”) that trade at prices that generally will reflect a discount (or premium) to net asset value. 1607 will also utilize investment instruments that track an index, including exchange-traded funds (“ETFs”), or hold cash, in market environments where 1607 believes the relative value of the available CEFs becomes less attractive or to gain market exposure. On an ongoing basis, 1607 monitors the performance of Client accounts and the investment markets and reallocates Clients’ assets as appropriate. In addition, 1607 Capital acts as the general partner to the Funds which are organized as Delaware limited partnerships. 1607 may from time to time enter into letter agreements or other similar agreements (“side letters”) with one or more investors of a 1607 Fund that provide such investor(s) with additional and/or different rights than investors have pursuant to the general terms of the Fund. Such rights may include providing the investor with shorter notice periods, more frequent and detailed reports, the reduction or waiver of the management or performance fee, investment restrictions, or other rights. As of December 31, 2025, the Company had $3.485 billion of assets under management on a discretionary basis.

Fees charged by 1607 vary based on Client and/or strategy, but generally include a management fee, a performance-based fee, or a combination thereof, which are at rates and terms described in the Client’s investment management agreement and are generally not negotiable. However, some

large or strategic investors may receive more favorable economic terms than other investors. 1607 reserves the right to enter into similar arrangements in the future. Current and certain former employees of 1607 and/or their related person’s investments are not typically subject to the fees described above. Upon termination of 1607’s investment management or investment advisory role, any earned, unpaid fees would be due and payable. The timing of when fees are paid depends on the individual governing documents of the Client. Asset based management fees generally range between 0% and .75% and are charged quarterly in advance or in arrears as stated in each Client’s governing documents, based on a percentage of the client's assets under management at the beginning or end of the calendar quarter, subject to adjustments for contributions to, or withdrawals from, the Client’s account. Performance based fees generally range between 0% and 30% and will generally be based upon a share of the capital gains or capital appreciation of the funds and securities in a Client’s account above those of the stated benchmark for the particular Client. Performance fees will only be charged to qualified clients and in accordance with Rule 205-3 under the Advisers Act. Investment advisory services begin with the effective date of the Investment Management Agreement. If applicable, fees will be adjusted pro rata based upon the number of calendar days in the quarter that the Agreement first becomes effective. Fees are generally deducted from the assets of the Client in accordance with the terms of the investment management agreement or Fund limited partnership agreement. Fund investors do not have the ability to choose to be billed directly for fees incurred. Managed Account fees can either be deducted directly from the client's brokerage account or paid directly by the Client pursuant to a written agreement. 1607’s advisory fees are separate and distinct from fees and expenses charged by the managers of the CEFs or ETFs that are recommended to clients. Additionally, the fees paid to 1607 are exclusive of custodial and transaction costs paid to custodians, brokers, or any other third parties. Investors in Funds also bear their proportional share of the operating expenses particular to the Fund in which they invest, which may include, without limitation, the following: legal fees; accounting fees; custodian fees; fund administration fees; organizational and registration expenses; transactional fees, filing fees, any insurance, indemnity or litigation expense, and certain offering costs. In general, 1607 will allocate expenses that are shared across multiple Clients on a pro-rata basis based on assets under management. However, in certain situations 1607 may assign expenses in a different manner with the goal of allocating expenses in a fair and equitable manner. Clients should carefully review their governing documents to gain a full understanding of all fees and expenses associated with their Managed Account or interest in a Fund prior to investment. 1607 has adopted a Security Valuation Policy to govern the valuation of securities held in Client portfolios. In certain cases, valuation procedures may be memorialized in a Client’s governing documents and generally call for valuations to be determined by a third-party administrator or custody bank. In these cases, advisory fees are based on the security valuations provided by that administrator or custodian. In other cases, the governing documents may not include such provisions, in which case, advisory fees are based on 1607’s security valuations obtained in accordance with the Security Valuation Policy. Although both 1607 and the Client’s custodian utilize well-known, widely used, independent pricing vendors, such security valuations may differ between pricing sources. When such variations exist, which generally only occurs on a small number of securities (typically those in liquidation or certain foreign issues), 1607 seeks to work

with the Client administrator or custodian to determine fair value. Regardless, Client administrators and custodians may not ultimately assign the same value to a particular security. If for any reason a Client wishes to terminate an investment advisory contract, the Client must provide prior written notice in accordance with the terms of their contract. The client is responsible to pay for services rendered until the termination of the agreement. Upon termination, any unearned fees charged for advisory services will be refunded on a pro-rata basis. Investors’ ability to redeem from the 1607 Funds is subject to formal notice requirements and other restrictions. The 1607 Funds’ offering memorandum provides a summary of when investors are permitted to make complete or partial redemptions.

The 1607 investment team generally invests Client’s assets in CEFs that trade on U.S. exchanges and foreign exchanges, depending on the strategy. In addition, 1607 will often purchase ETFs targeting specific exposures or indexes. 1607 begins its investment process with the collection of data on the universe of investable closed-end funds, as determined by 1607. Information such as prices, dividends, manager reported net asset values, and portfolio composition are collected to evaluate the current net asset values of the CEFs. Based on this information, 1607 then ranks the universe of investable CEFs using a proprietary model. Factors that are typically utilized include, but are not limited to, relative and absolute discount levels, net asset value performance, fund size, corporate actions (share repurchases, tender offers, open-ending provisions, etc.), and other additional data. The output of this ranking system provides the starting point for 1607’s investment decisions. 1607 then considers various factors such as fund management, top-down country and regional data, various macro-economic data and forecasts, sector, credit quality, and other inputs, to confirm the bottom-up research and control risks, including country valuations, economic growth, and geopolitical environments, among other factors. The factors considered will vary with the strategy. Specific client guidelines and benchmarks along with diversification considerations are then monitored to further control risks and confirm investment choices. Client portfolios are created from this research and re-evaluated on a daily basis. Risk management occurs at every stage of 1607’s investment process – from the initial and ongoing evaluation of the CEFs in which 1607 makes investments to the construction and ongoing management of the portfolio of CEFs in each strategy. At the fund level, a thorough analysis is conducted of each fund the firm follows, using a proprietary database of historical net asset values, prices, and dividends for each fund. Often a fund’s NAV is modeled upon inclusion into the investable universe, allowing for real-time NAV estimates throughout the trading day. Then, depending on the security, NAV variance reports are generated daily and analyzed by the investment team to identify unusual activity. When necessary, the team may seek to engage the fund’s manager in order to better understand any variances that occur. Further risk management practices exist at the client portfolio level. Typically, the Client’s exposure will be comprised of numerous CEFs often resulting in over 1000 securities on a lookthrough basis, thus, much of the security-specific risk is diversified away. This diversification enables 1607 to focus its risk management efforts on higher-level portfolio characteristics like relative sector or country exposure. Each portfolio’s look through exposure is tracked in real-time in comparison to the appropriate benchmark. The more the portfolio deviates from the benchmark, the more 1607 will adjust its buy or sell targets in response. 1607 will also use ETFs to manage underweight positions as 1607 deems advisable. 1607 continues to evolve and refine its long-standing risk management framework and may incorporate new tools as the 1607 deems appropriate and consistent with Client investment guidelines. Additionally, in composites with multiple clients, 1607 seeks to minimize return dispersion across accounts. The Company’s portfolio management system and its trade allocation platform seek to ensure that trades are allocated appropriately across accounts with the same strategy so that generally individual positions are held at similar percentages.

The description provided above is a brief overview of 1607’s investment strategy and risk management controls. It should not be considered comprehensive and variations exist between different strategies. All investing involves a risk of loss and the Company’s investment strategies could lose money or underperform benchmarks over short or even long periods. Past performance is not indicative of future returns. RISK OF LOSS The following is a summary of the material risks involved with the investment strategies and methods of analysis employed by 1607, as described above. Investing in the Funds that 1607 manages involves a risk of loss that all fund investors should be prepared to bear. Similarly, the discussion of risks that follows below also applies to 1607’s Managed Accounts, which typically engage in the same strategies as the Funds. It is not possible to identify all of the risks associated with investing, and the particular risks applicable to each Client account will depend on the nature of the account, its investment strategy and the types of investments held in the account. A more detailed discussion of the risks of investing is presented in the relevant offering documents. It is critical that Clients and investors refer to their respective Client’s offering documents for a more complete understanding of the significant risks associated with investments (including the risk of total loss). Investment Approach and Strategies Risk is inherent in all investing. No guarantee or representation is made that the Company’s investment approach or strategies will be successful or produce profitable results. The Company’s unique fund of funds investment style may not be successful in realizing the client’s investment objectives. Profitable investing is often dependent on anticipating that the market will change its perception of what appears to be an undervalued security at some point in the future. Markets subject to random price fluctuations, rather than rational decisions, may generate a series of losing investments. There have been periods in the past when the markets have been subject to irrational price movements, and such periods may recur. Any factor that would make it difficult to execute trades, such as reduced liquidity or extreme market developments resulting in limit moves, also could be detrimental to profits. For example, supply and demand for securities and other financial instruments can change rapidly and will be affected by a variety of factors. Such factors include: investment-specific price fluctuations, the macro-economic environment, market and industry-specific conditions, including, but not limited to, national and international economic conditions, domestic and international financial policies and performance, conditions affecting particular investments (such as the results of operations, financial condition, sales and product lines of corporate issuers), national and international politics, governmental events and changes in interest rates and income tax laws. In addition, events such as political instability, terrorism, natural disasters, and regional and global health epidemics may occur. No assurance can be given that the Company’s techniques and strategies will be profitable in the future. Closed – End Funds

1607 intends to invest primarily in CEFs that invest in domestic and international equities, fixed income products, and ETFs (depending on the specific investment product). Risks of investing in shares of a CEF that invest in domestic and international equities, fixed income products, and ETFs are similar to those risks associated with investing in these securities directly. In addition to these risks, the shares of CEFs often trade at a discount to the underlying net asset value of the fund and this discount can increase significantly during various market conditions that do not otherwise affect the value of the fund’s holdings. 1607 clients and investors are also subject to manager risk, which is the risk associated with the CEF management team’s ineffective or underperforming management. While 1607 analyzes the fund management, clients are indirectly subject to the risks associated with the investment decisions of the CEF management. Further, CEFs incur investment advisory, transactional, administrative and other expenses that are in addition to the investment advisory, transactional, administrative and other expenses incurred by the client. Exchange-Traded Funds 1607 will invest in shares of ETFs that invest in equity and fixed income securities. Risks of investing in shares of an ETF that invest in securities are similar to those risks associated with investing in the securities directly. In addition to these risks, an investment in shares of an ETF also expose investors to the risk of errors in matching the ETF’s underlying assets to an index and the risk that because an ETF is generally not actively managed, it cannot sell poorly performing equity securities as long as they are represented in an index. These risks may affect the ability of 1607 to implement its investment strategy effectively and reduce the accounts’ profit potential. Additionally, an ETF’s return may not match the return of the index it is trying to replicate (the “Replicated Index”) for a number of reasons. For example, an ETF incurs a number of operating expenses not applicable to the Replicated Index, and incurs costs in buying and selling securities, especially when rebalancing the ETF’s securities holdings to reflect changes in the composition of the Replicated Index. The ETF may not be fully invested at times, either as a result of cash flows into the ETF or reserves of cash held by the ETF to meet redemptions and expenses. International Investing 1607 invests in CEFs and ETFs that conduct investment activities outside the U.S. Investing in non-U.S. securities that generally are denominated in foreign currencies, involve both opportunities and risks not typically associated with investing in U.S. securities. These include: fluctuations in exchange rates of foreign currencies; possible imposition of exchange control regulation or currency restrictions that would prevent cash from being brought back to the United States; less public information with respect to issuers of securities; less governmental supervision of exchanges, securities brokers and issuers of securities; difficulties in obtaining and enforcing a judgment against a foreign issuer; different accounting, auditing and financial reporting standards; different settlement periods and trading practices; less liquidity and frequently greater price volatility in foreign markets than in the United States; imposition of foreign withholding and other taxes; and sometimes less advantageous legal, operational and financial protections applicable to foreign sub-custodial arrangements. The cost of investing in securities of non-U.S. issuers can be higher than the cost of investing in U.S. securities. Investments in securities denominated in foreign currencies also involve the additional cost of converting currencies upon the purchase and sale of securities.

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1607 provides investment advisory services to Funds and Managed Accounts. The Managed Accounts and Funds are only offered to certain qualified investors such as pension plans, banks, sovereign wealth funds, endowments, other investment advisers, corporations, insurance companies, and high net worth individuals. Admission to the Funds is not open to the general public. An investment in a Fund is generally restricted to investors that qualify as “accredited investors,” as that term is defined under rule 501(a) of Regulation D of the Securities Act of 1933, as amended. These Funds are exempt from registration as investment companies with the SEC pursuant to Section 3(c)(1) or Section 3(c)(7) of the Investment Company Act of 1940. 1607 typically will not act as investment adviser for separately managed accounts with an initial commitment of less than $25 million, and generally require 1607 Fund investors to initially contribute $3 million, with the exception of one fund which has an initial minimum contribution of $250,000. As the general partner of the Funds, 1607 may waive an investor’s minimum capital commitment, and has done so for certain investors.

Performance based fees are fees based on a share of capital gains on, or capital appreciation of, the assets of a client. An adviser charging performance fees to some accounts faces a variety of conflicts because the adviser can potentially receive greater fees from accounts with a performance-based compensation structure than from those accounts it charges a fee unrelated to performance (e.g., an asset-based fee). As a result, the adviser may have an incentive to direct the best investment ideas to, or to allocate or sequence trades in favor of, the account that pays a performance fee. This potential conflict of interest additionally may create an incentive to make investments that are riskier or more speculative than in the absence of such a performance-based fee. To help mitigate these potential conflicts of interest, 1607 has established reasonable policies and procedures regarding trade allocation and aggregation (see Brokerage Practices Section). Only qualified clients are eligible to be assessed a performance fee. Qualified clients generally must i) have at least $1,100,000 in assets under management with 1607, or ii) have a net worth (or joint net worth with a spouse) of at least $2,200,000.

1607 Capital Partners Limited (the “Relying Adviser”) was incorporated in 2017 in England and Wales and is a wholly owned subsidiary of 1607 Capital Partners, LLC. The Relying Adviser has been authorized and regulated by the UK Financial Conduct Authority (“FCA”) in the UK since 20 August 2019. The Relying Adviser was established to undertake research on potential investment opportunities for 1607 Capital and to provide advice to 1607 Capital on investment opportunities in securities that are listed in the UK. Moreover, 1607 Limited is also involved in the execution process whereby it receives orders from 1607 Capital and transmits them to the relevant executing brokers in the UK. Some employees of 1607 Capital are dual hatted to roles at the Relying Adviser. All persons acting on behalf of the Relying Adviser are subject to the supervision and control of 1607 Capital. Rosemont Investment Group, LLC (“Rosemont”), an exempt reporting advisor, is a minority investor in 1607. Rosemont’s investment in 1607 is indirectly controlled by the Markel Corporation, a specialty insurer that trades on the New York Stock Exchange under the symbol “MKL.” Rosemont has investments in other financial industry participants, and will likely make additional such investments in the future. 1607 is independently operated and does not believe Rosemont’s minority investment generates any material conflicts of interest for 1607. Rosemont may refer other financial industry participants in which Rosemont has an ownership stake to 1607. In addition, 1607 serves as general partner and investment manager to several private funds that are exempt from registration as investment companies under the 1940 Act. In fulfilling these roles, 1607 directly manages the assets of several Clients with similar investment objectives. Notwithstanding that the investment objectives of two or more Clients may be similar, 1607 may also give advice or take action with respect to any such Client that differs from the advice given or actions taken with respect to the other such Clients.

Transactions and Personal Trading

1607 has a fiduciary relationship with its Clients that requires that the Company and its employees place the interests of Clients first. As such, 1607 operates under a Code of Ethics (the “Code”) in accordance with Rule 204A-1 under the Advisers Act. The Code covers all employees and sets forth guidelines that promote ethical conduct generally. In addition to the Code’s policies regarding personal securities trading, the Code requires employees to follow policies and procedures relating to the conduct standards of the Code including: conflicts of interest, inside

information, gifts and entertainment, personal political contributions, and disclosure of personal securities transactions and holdings. Under the Code, 1607 employees are permitted to trade for their own accounts on a limited basis, and from time to time may buy or sell securities that the Company trades for clients. This creates a potential conflict of interest. In order to mitigate this potential conflict of interest, the Company maintains a restricted list and employees are required to secure pre-approval from the 1607compliance department prior to trading any security that may be restricted. Additionally, the Code requires, among other things, that its employees: • • • • • • • • • •

Act with integrity, competence, diligence, respect and in an ethical manner with the public, clients, prospective clients, employers, employees, colleagues in the investment profession, and other participants in the global capital markets; Place the integrity of the investment profession, the interests of clients, and the interests of 1607 above one’s own personal interests; Adhere to the fundamental standard that he or she should not take inappropriate advantage of his or her position; Avoid and/or disclose any actual or potential conflict of interest; Conduct all personal securities transactions in a manner consistent with the policy; Use reasonable care and exercise independent professional judgment when conducting investment analyses, making investment recommendations, taking investment actions, and engaging in other professional activities; Practice and encourage others to practice in a professional and ethical manner that will reflect credit on the employee and the profession; Promote the integrity of, and uphold the rules governing, capital markets; Maintain and improve his or her professional competence and strive to maintain and improve the competence of other investment professionals; and Comply with applicable provisions of the federal securities laws.

The Code also requires employees to: (1) pre-clear certain personal securities transactions; (2) report personal securities transactions on at least a quarterly basis; and (3) provide the CCO with a detailed summary of personal securities holdings (both initially upon commencement of employment and annually thereafter), in each case subject to certain exceptions described in the Code of Ethics. A copy of the Code will be provided to any Client or prospective Client upon request.

In the course of providing services, 1607 will execute trades for clients through various brokerdealers. When 1607 has broker discretion, there is no restriction on the brokers that may be selected to execute client transactions. When placing portfolio transactions, 1607 will seek to obtain best execution for the clients, taking into account factors such as, but not limited to, the following: the ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any); the operational efficiency with which transactions are effected, taking into account the size of the order and difficulty of execution; the ease of use, staffing commitment, and responsiveness of the brokers trading desk and back office; the financial

strength, integrity, and stability of the broker; the firm’s risk in positioning a block of securities; the relevance of the broker’s order flow and block trading capabilities; the quality, comprehensiveness and frequency of available research services considered to be of value; and the competitiveness of commission rates in comparison with other brokers satisfying the Company’s other selection criteria. Allocation and Aggregation of Orders When appropriate, 1607 is permitted to, but are not required to, aggregate Client orders to achieve execution that is more efficient or to provide for equitable treatment among accounts. A Client’s participation in aggregated trades will be allocated securities or cash based on the average price achieved for such trades, as well as a proportionate amount of the expenses incurred in the transaction. Depending upon market conditions, the aggregation of orders may result in higher or lower average prices paid or received. Orders that are not aggregated are entered at the market prices prevailing at the time of the transaction. Accordingly, trades that are not aggregated and entered at different times during the same day may result in different pricing. Determinations concerning the investment and trading needs of each Client and the timing of transactions (e.g., security purchases and sales) shall be made throughout the trading day by the responsible Portfolio Manager(s). Each Client will not necessarily participate in every security transaction notwithstanding the fact that such investment opportunity may otherwise be suitable for that Client. In general, 1607 strives to allocate trades on a pro rata basis or a target percentage basis. Allocation determinations may change during the trading day. When determining final allocations, the Portfolio Manager takes into account all relevant factors, including, but not limited to, the amount of shares received, the size of each client’s allocation, clients’ liquidity needs, pending cash flows, the available opportunity set, overall portfolio construction, and previous allocations. In the case of partial fills, accounts with smaller weightings in the security in relation to overall target position goals will generally receive allocation priority. Accounts that are ramping up or ramping down may receive a larger or priority allocation. 1607 will sometimes round allocations to an even lot. In the case of de Minimis fills, 1607 may allocate to as few as a single account and/or may forgo some allocations if the perceived processing expense weighs too heavily on the allocation. Block trading is undertaken with the goals of facilitating best execution, equitably allocating trades among Clients, eliminating differences in prices and execution order that might have resulted had such orders been placed independently, and seeking to ensure that no participating Client is favored over any other Client. The vast majority of the Company’s trades are executed in this manner. However, when significant cash flows occur within a specific account, trades may be executed for that specific account individually (i.e. not blocked with others) in order to align that account with similar accounts participating in the same investment strategy. In relation to a particular order, aggregation may work to disadvantage a particular Client, however the Company believes this method provides the fairest outcome for all Clients over a series of orders. The CCO, or his designee, conducts periodic reviews to ensure that no client or group of clients is being systematically favored or harmed in the selection and allocation of investment opportunities. Cross Trades

Consistent with 1607’s duty to seek to obtain best execution, occasionally 1607 may execute cross transactions between Client accounts. A cross trade occurs when an adviser purchases and sells a particular security between two or more accounts under the adviser’s management by instructing brokers to cross the trade. 1607 generally utilizes cross trades when 1607 believes the practice is deemed advantageous for each participant. For example, a sale in a Client account may be advisable for reasons such as overall portfolio construction, changes in the market value, withdrawals from the account by the Client, or changes in the Client's investment guidelines or asset allocation requirements. At the same time, 1607 may advise another Client account that is under-weighted in the same security, or the security being sold is an ideal investment for a newly formed account. Certain Clients may be restricted from participating in cross trades based on regulatory requirements or Client restrictions. Such restrictions may result in a less advantageous weighting or executed price for a security. In some instances, 1607 may refrain from executing a feasible cross trade if 1607 believes in its discretion that such a trade is unlikely to have a material impact on execution price. In no instance does 1607 receive additional compensation when crossing trades for client accounts. 1607 will seek to ensure that the terms of the transaction, including the consideration to be paid or received, is fair and reasonable, and the transaction is done for the sole benefit of all participating clients. Soft Dollars The term “soft dollars” refers to arrangements where an investment adviser obtains products and services, other than securities execution, from a broker-dealer in return for directing Client securities transactions to the broker-dealer. Section 28(e) of the Securities Exchange Act of 1934, as amended allows an adviser to pay broker-dealers more than the lowest commission available in order to obtain research and brokerage services without breaching its fiduciary duties to clients or imposing a duty upon the adviser to obtain the lowest commission if certain conditions are met and the adviser makes a good faith determination that the commissions paid are reasonable in relation to the value of the brokerage or research services on behalf of its advisory clients. 1607 does not direct Client brokerage commissions to particular brokers in exchange for information the Company receives. 1607 does, however, receive research and commentary from a variety of broker-dealers, including those to whom Clients pay a commission in connection with purchases and sales of securities. The research and commentary can include both proprietary as well as third party materials. While much of the information is unsolicited and not directly relevant to the transactions in which the Company engages, some is specifically related to, and can aid in decision-making regarding, Client transactions. Some European brokers are required to periodically send a statement declaring what portion of commission dollars were “execution” and what portion was “research”, however, an unbundled execution-only commission rate is not available. The Company views this research and commentary as “free” in that it does not agree to pay a higher commission to receive such research and commentary than the Company would otherwise pay for execution of Client transactions. That being said, the provision of such information may create an incentive to select a broker-dealer based on the volume or quality of the information from a particular broker-dealer, rather than on execution price. Any benefits to the Company’s investment analysis gleaned from the information received on an asset underlying a client transaction is for the benefit of all Clients, not just the Clients who participated in trades with the providing broker-dealer.

Individual Clients may, and have, instructed 1607 not to use broker-dealers that provide soft dollar credits when executing their trades. As a result, Clients who provide 1607 with complete discretion in the selection of brokers may incur different commission costs compared to clients who instruct us not to use broker dealers providing soft dollar credits. 1607 may engage in soft dollar arrangements prior to engaging in such arrangements involving a particular Client account. 1607 reserves the right to enter into soft dollar arrangements in the future, where permissible, without prior notice to Clients. 1607 is not affiliated with any broker-dealers.

1607 does not receive economic benefits from non-clients for providing investment advice and other advisory services. The Company does not have any arrangements to compensate third parties for client referrals at this time.

1607 is not aware of any legal or disciplinary events involving the Company or its personnel in the past 10 years that would be material to the Company or its personnel.

Client accounts are monitored continuously and changes and/or alternate investment opportunities are recommended when a Portfolio Manager believes it is appropriate to do so. General conditions in the stock and bond markets are continuously monitored. Factors triggering reviews include, but are not limited to, changed circumstances of the clients; changed portfolio construction parameters, changed general conditions in the stock and bond markets; and changes in closed-end funds owned by Clients. Client accounts are reviewed by the Portfolio Managers. There is no set number of accounts that will be reviewed. Clients receive copies of all transaction confirmations and monthly/quarterly statements from their custodians. All clients and 1607 Fund investors receive monthly reports, which include performance and market commentary. In addition, all investors receive quarterly reports regarding account performance, expanded market commentary, holdings, discounts, and country allocation. Investors in 1607 Funds receive annual audited financial statements prepared by an independent accounting firm, as discussed in the Custody section below.

All client assets are held in custody by unaffiliated broker/dealers or banks, however a registered investment adviser who, directly or through an affiliate, acts as the general partner or managing member to a limited partnership or other comparable pooled investment vehicle is considered to have custody over client assets. In addition, if an adviser can debit accounts to collect fees, then it is considered to have custody. Rule 206(4)-2 imposes a number of requirements on an SECregistered investment adviser that is deemed to have custody of its clients’ funds and securities. To comply with Rule 206(4)-2 and to provide meaningful protection to 1607 Fund investors, each 1607 Fund is subject to an annual financial statement audit by an independent public account registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board. The audited financial statements are prepared in accordance with generally accepted accounting principles, and are distributed to each investor within 120 days of the Fund’s fiscal year end.

In cases where 1607 can access separate account client funds and securities though its ability to debit advisory fees from the custodial account, the account custodians send statements directly to the account owners on at least a quarterly basis. Clients should carefully review these statements, and should compare these statements to any account information provided by 1607.

1607 has full discretionary authority with respect to investment decisions, and its advice with respect to the Clients is given in accordance with the investment objectives and guidelines set forth in the applicable offering documentation or advisory agreement, as the case may be. Except as otherwise may be set forth in such documents, Clients may not impose restrictions on investing in certain securities or types of securities. 1607 determines which investment securities or other assets are to be purchased and/or sold for the Clients. 1607 may be limited as to the securities or other assets that may be purchased by the offering documents, advisory agreement, and other governing documents, as well as applicable securities laws.

1607 understands and appreciates the importance of proxy voting and will generally manage the receipt of incoming proxies, maintain a log of all proxies, and place votes based on established policies, guidelines, and according to the terms established in the Client’s governing documents. 1607 seeks to vote client proxies in the interest of maximizing shareholder value over the anticipated investment horizon of the investment. To that end, 1607 will vote in a way that it believes, consistent with its fiduciary duty, will be more likely to cause the security to increase the most, or decline the least, in value. Consideration will be given to both the short and long-term implications of the proposal to be voted when considering what 1607 believes is the optimal vote (which may include abstaining). 1607 is not aware of any conflicts between its Client’s interests and its own interests within the Company’s proxy voting process. Nevertheless, if 1607 determines that it is facing a material conflict of interest in voting client proxies, the Company’s procedures provide for seeking instruction, where feasible and practicable (e.g., as to time), from the Client, or utilizing the opinion of an independent third party (e.g., proxy voting service). As an added protection, if the Company utilizes an independent third party, the third party’s decision is binding. 1607’s proxy voting policy and procedures are memorialized in writing and are available for Client review. In addition, Clients may request a proxy voting record related to their account. 1607 shall vote, or refrain from voting, all proxies with respect to securities held in the Funds in accordance with its proxy voting policies, guidelines, and procedures in effect from time to time. 1607 shall not vote (or abstain from voting) proxies in a manner that reflects differing policies of investors in proportion to each investor’s economic interest in the Funds. Investors in the Funds may not direct the 1607’s vote on behalf of the Fund in any particular situation. In the event 1607 is not empowered to exercise proxy-voting authority over a particular Client account, then the obligation to vote Client proxies shall at all times rest with the Client. The Client shall in no way be precluded from contacting us for advice or information about a

particular proxy vote. However, 1607 shall not be deemed to have proxy-voting authority solely as a result of providing such advice to Client. Should 1607 inadvertently receive proxy information for a security held in a Client’s account in which 1607 does not maintain proxy-voting authority, 1607 will endeavor to immediately forward such information on to the Client, but will not take any further action with respect to the voting of such proxy. Upon termination of 1607’s Agreement with the Client, 1607 shall make a good faith and reasonable attempt to forward proxy information inadvertently received by 1607 on behalf of the Client to the forwarding address provided by the Client. 1607 will not file Class Action lawsuits on behalf of Managed Account Clients. However, 1607 will help Clients who seek assistance in filing Class Actions. 1607 has retained Northern Trust to file for class action settlements on behalf of the Funds as part of its standard service offering. Any compensation received as the result of participation in a class action settlement shall be paid to the Client that has the holding in its portfolio. For its services, Northern Trust or a third-party vendor will be paid based on a percentage of the proceeds recovered from a class action filing. It should be noted that Clients bear the cost (i.e., receive a reduced amount of the class action proceeds) of any third party used for class action recovery services.

1607 is not aware of any financial condition that impairs its ability to meet contractual commitments to Clients and has never been the subject of a bankruptcy proceeding.