272 Capital LP

272 Capital LP (hereinafter “272”, “we”, “us”, “our”, “Investment Manager”, or the “Firm”), a Delaware limited partnership, was originally formed in 2017. The Firm currently provides investment management services to private pooled investment vehicles and a separate account for an institutional investor. 272 is registered as an investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). PRINCIPAL OWNERS 272 Capital Holdings is the majority owner of the Firm. Wes Cummins is the sole owner of 272 Capital Holdings LLC. TYPES OF ADVISORY SERVICES 272 serves as investment manager to the 272 Capital Fund, LP, a Delaware limited partnership (the “Domestic Fund”), 272 Capital Offshore Fund, Ltd., a Cayman Islands exempted company (the “Offshore Fund” and together with the Domestic Fund, the “Feeder Funds”), and 272 Capital Master Fund, Ltd., a Cayman Islands exempt limited partnership (the “Master Fund” and together with the Feeder Funds, the “272 Fund”). Each of the Feeder Funds invests all or substantially all of its assets in, and conducts its investment activities through, the Master Fund. 272 has full discretionary authority with respect to the investment decisions of the 272 Fund. Our investment advisory services are provided in accordance with the investment objectives and guidelines set forth in Fund offering and governing documents. The information set forth in this Brochure is qualified in its entirety by the Fund offering and governing documents. Interests in the Feeder Funds are privately offered only to eligible investors pursuant to exemptions under the Securities Act of 1933, as amended (the “Securities Act”), and the regulations promulgated thereunder. The Fund is not registered with the SEC as investment companies based on specific exclusions from the definition of investment company under the Investment Company Act of 1940, as amended (the “Company Act”). 272 provides investment advice to the 272 Fund in accordance with the investment objectives, policies and guidelines set forth in the Fund’s offering and governing documents, and not in accordance with the individual needs or objectives of any particular investor in the Fund. In addition to the 272 Fund, as of December 31, 2024, 272 served as adviser to two non-affiliated pooled vehicles and a separately managed account for an institutional investor, each a “Client.” As investment manager, 272 is responsible for investing and re-investing the capital of each Client account in securities, financial instruments and/or other assets in accordance with the investment objectives, policies and guidelines set forth in the 272 Fund’s offering and governing documents as well as the investment management agreements for the sub-advised and separately managed Client accounts. See Item 8: Methods of Analysis, Investment Strategies and Risk of Loss. INVESTMENT RESTRICTIONS Investors generally are not permitted to impose restrictions on investments in certain securities or types of securities or limitations on the management of the Fund. Notwithstanding the foregoing, 272 has entered into, and may in the future enter into, side letter agreements or similar arrangements with certain investors in the Feeder Funds that have the effect of establishing rights under, or altering, modifying, waiving or supplementing the terms of, the governing documents of the Fund in respect of such investors. Among other things, these agreements may entitle an investor in the Fund to lower fees, information or transparency rights, most favored nations status, investment capacity rights, notification rights, rights or terms necessary or advisable in light of particular legal, regulatory or policy considerations of or related to an investor and/or other preferential rights and terms. Advisory services are generally not tailored to each Client, the firm manages a single strategy for all clients in which all clients invest in the same securities at all

times. However, the clients have imposed restrictions, in writing, on investing in certain securities. All Client accounts are managed on a pari passu basis. Each Client account generally buys, sells and holds the same securities. We do not participate in any Wrap Fee Programs. ASSETS UNDER MANAGEMENT As of December 31, 2024, the Firm had approximately $141 million in regulatory assets under management. All of these assets are managed on a discretionary basis.

In consideration of our advisory services, 272 receives a “Management Fee” and an “Incentive/Performance Allocation” with respect to each Client account. While our fees are described in detail in the 272 Fund’s governing and offering documents and in the investment management agreements, a brief summary of our advisory fees is set forth below. Management Fee 272 Fund Management Fee: The Master Fund will pay to the Investment Manager a fee for its services (the “Management Fee”) for each fiscal quarter equal to a quarter of the result of the Management Fee Rate multiplied by the balance of each Capital Account as of the beginning of such fiscal quarter (before taking into account the estimated accrued Incentive Allocation, if any). The Master Fund will calculate and pay the Management Fee in advance but will amortize the Management Fee monthly over the fiscal quarter for which such Management Fee is paid. The portion of the Management Fee applicable to a Capital Account will be charged to its corresponding Master Fund Shares. “Management Fee Rate” means 1.5% per annum. The Master Fund will pay the Management Fee within 10 days of the first day of each fiscal quarter. The Investment Manager may, without the consent of the Limited Partners, cause the Management Fee to be charged to and paid by the Partnership instead of the Master Fund. Incentive Allocation: Generally, at the end of each Fiscal Year, the Master Fund will reallocate from the record of each series of Master Fund Shares corresponding to a Capital Account to the record of the Class M Shares an amount (the “Incentive Allocation”) equal to the result of the applicable Incentive Allocation Rate multiplied by the net realized and unrealized appreciation in the net asset value of such series of Master Fund Shares (taking into account, as applicable, gains and losses realized or deemed realized with respect to Special Investments allocated during such Fiscal Year, and after reducing such amount by the amount of the Management Fee debited to such Limited Partner’s Capital Account during such Fiscal Year), adjusted for (i) any redemption of Master Fund Shares in the series since the last calculation of the Prior High NAV of such series of Master Fund Shares, and (ii) expenses of the Partnership (other than Investor-Related Taxes) corresponding to such series of Master Fund Shares that are not reflected in the net asset value of the Master Fund (the “Adjusted NAV”); provided, however, that an Incentive Allocation will be made only with respect to the excess of the Adjusted NAV of a series of Master Fund Shares over its Prior High NAV. The Incentive Allocation will also be made with respect to net realized and unrealized appreciation attributable to amounts withdrawn, amounts distributed, and amounts transferred (provided that such Transfer results in a change in the beneficial ownership of the Interest transferred) and in connection with the termination of the Partnership or the Master Fund. The Class M Shares will not be subject to the Incentive Allocation. “Incentive Allocation Rate” means 20%. The “Prior High NAV” of each series of Master Fund Shares is the net asset value of that series immediately following the date as of which the last Incentive Allocation allocable with respect to such series was determined (or if no Incentive Allocation has yet been determined with respect to such series, the net asset value of such series immediately following the initial issuance of such series), reduced by any Investor- Related Taxes accrued or paid subsequent to either such date. For purposes of determining allocations, including calculating the Incentive Allocation and the Prior High NAV, any Investor-Related Taxes related to a Partner, or a direct or indirect beneficial owner of the Master Fund will be deemed distributed to such Partner or direct or indirect beneficial owner of the Master Fund and will not be deemed to be expenses that reduce net capital appreciation or increase the Prior High NAV.

“Investor-Related Tax” means any tax withheld from the Partnership or the Master Fund or paid over by the Partnership or the Master Fund, in each case, directly or indirectly, with respect to or on behalf of a Partner or a direct or indirect beneficial owner of the Master Fund, and interest, penalties and/or any additional amounts with respect thereto, including (i) a tax that is determined based on the status, action or inaction (including the failure of a Partner or a direct or indirect beneficial owner of the Master Fund to provide information to eliminate or reduce withholding or other taxes) of a Partner or a direct or indirect beneficial owner of the Master Fund, or (ii) an “imputed underpayment” within the meaning of Section 6225 of the Internal Revenue Code of 1986, as amended (the “Internal Revenue Code”), and any other similar tax, attributable to a Partner or a direct or indirect beneficial owner of the Master Fund, as determined by the General Partner in its sole discretion. If Master Fund Shares of a particular series are redeemed other than at the end of a Fiscal Year as of which an Incentive Allocation is made with respect to such series, the Prior High NAV of such series will be reduced in the same proportion as the reduction in the net asset value of that series caused by such redemption. The Incentive Allocation will be determined separately with respect to each series of Master Fund Shares corresponding to a Capital Account established for a Limited Partner. Accordingly, it is possible that an Incentive Allocation may be made with respect to one series of Master Fund Shares even though another series of Master Fund Shares corresponding to a Capital Account of the same Limited Partner has not appreciated or has depreciated in value during the same period. In the sole discretion of the General Partner, the Incentive Allocation may be waived, reduced or calculated differently with respect to the series of Master Fund Shares corresponding to the Capital Account of any Limited Partner. To facilitate any such waiver, reduction or different calculation, the Master Fund may issue Master Fund Shares of a separate class, series or sub-series. Non-Affiliated Pooled Vehicles and Separately Managed Account Fees: Similarly, for investment services provided to the non-affiliated pooled vehicles and the separately managed account, 272 receives an annual management fee equal to a percentage, generally between 0% and 1.5%. 272 in its discretion, may waive or reduce the management fee as negotiated. Furthermore, under the investment management agreement, 272 will be entitled to receive an Incentive Allocation. The Incentive Allocation is generally equal to a percentage between 15 and 20%. 272, in its discretion, may waive or reduce the Incentive Allocation as to all or any of its Clients. OTHER TYPES OF FEES OR EXPENSES 272 is authorized to incur all expenses, and pay invoices, in the name and on behalf of the 272 Funds which they deem necessary or advisable. The Firm is responsible for and shall pay, or cause to be paid, all of their own ordinary administrative and overhead expenses, including, without limitation, all costs and expenses related to rent, furniture, fixtures, equipment, office supplies, clerical expenses and all salaries, bonuses and benefits paid to, or on behalf of, personnel of the Firm. The Funds bear all other expenses, which include, without limitation, the following expenses incurred by or allocable to the Funds: (a) organizational and offering expenses; (b) expenses associated with all investments and transactions considered, evaluated and/or consummated by the Funds, including, without limitation, those expenses incurred before the initial closing of the Funds, including, without limitation, 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, structuring, pricing, execution and other third-party information systems, software and service fees (including, without limitation, the expenses with respect to data feeds, subscriptions, expert networks, political intelligence providers, and reports); (c) research-related computer hardware and software expenses, including, without limitation, Bloomberg terminals; (d) the Funds’ pro rata share of the Firm’s order management system, portfolio management system and any other software used for accounting and/or monitoring of the portfolio; (e) expenses associated with holding, financing, monitoring, hedging, maintaining and disposing of all investments of the Funds and all transaction and other costs associated therewith; (f) travel and related expenses associated with investments and potential investments; (g) professional fees associated with investments and potential investments, including, without limitation, consulting, due diligence, accounting, valuation, financial, legal, and other advisory fees and expenses; (h) 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; (i) expenses associated with legal and regulatory filings of the Funds (including, without limitation, pursuant to

Section 13 and 16 of the Securities and Exchange Act of 1934, as amended (the “Exchange Act”)) and the Funds’ pro rata portion of the expenses associated with preparation of the Firm’s Form 13F, Form 13H and Form PF, and any other similar filing in any other U.S. or non-U.S. jurisdiction; (j) 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 Funds’ administrator; (k) 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 self-regulatory organization and all extraordinary expenses; (l) broken-deal, failed transaction, break-up and similar fees, costs and expenses, if any; (m) costs and expenses of leverage or any other borrowings of the Funds, including, without limitation, interest charges and fees; (n) expenses incurred in the collection of monies owed to the Funds, as applicable; (o) auditing and accounting expenses of the Funds, including, without limitation, expenses associated with the preparation of

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The descriptions set forth in this Brochure of specific advisory services that we offer to Clients, and investment strategies pursued, and investments made by us on behalf of our Clients, should not be understood to limit in any way our investment activities. We may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that we consider appropriate, subject to each Client’s investment objectives and guidelines as set forth in the Offering Documents. The investment strategies we pursue are speculative and entail substantial risks. Clients 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. Investment Objective 272 seeks to provide equity-like returns with a focus on preservation of capital through a long/short equity strategy that results in low net equity exposure. 272 will invest primarily in individual publicly traded equity securities based mostly in the US through a rigorous bottom-up fundamental research investment process. The bottom-up process will largely drive the gross and net exposures of the portfolio yet will be aided by several portfolio management tools to optimize individual position size and overall risk management. Investments will be weighted towards the Technology, Media and Telecom (“TMT”), Industrial, Consumer, Financial and Healthcare sectors. While no particular sector is off limits, we generally avoid businesses that are directly tied to the price of a commodity. Risk Management While the Master Fund’s gross and net exposures will be driven by 272’s fundamental bottom up investment process, we will utilize multiple tools from a portfolio management perspective to limit risk including: • • •

Position size limitations. Ultimate positions size maximums of 12% for longs and 6% for shorts. A process that identifies market capitalization, liquidity and factor mismatch between the long and short books. While this will not drive our portfolio, we will be vigilant in preventing significant style mismatches on a net exposure basis. A short position sizing model and process that seeks to manage position size around expected stock moving events. While not perfect, this process is designed to help us be nimble on our short book.

Risk of Loss Factors The following risk factors do not purport to be a complete list or explanation of the risks involved in an investment in the clients advised by us. These risk factors include only those risks we believe to be material, significant or unusual and relate to particular significant investment strategies or methods of analysis employed by us. An investment involves significant risks and is suitable only for those persons who can bear the economic risk of the loss of their entire investment, who have limited need for liquidity in their investment, and who have met the conditions set forth in the Offering Documents. There can be no assurances that we will achieve our investment objectives. An investment carries with it the inherent risks associated with investments in publicly-traded stocks and bonds, options, and related instruments, including, without limitation, the risks described below. Each prospective investor should carefully review the Offering Documents and the documents referred to herein before deciding to invest with 272. RISKS RELATING TO PRIVATE INVESTMENT FUNDS GENERALLY Legal and Regulatory Environment for Private Investment Funds and their Managers The legal and regulatory environment worldwide for private investment funds (such as the Fund) and their managers is evolving. Changes in the regulation of private investment funds, their managers, and their trading and investing activities may have a material adverse effect on the ability of the Master Fund to pursue its investment program and the value of investments held by the Master Fund. There has been an increase in scrutiny of the private investment fund industry by governmental agencies and self-regulatory organizations. New laws and regulations or actions taken by regulators that restrict the ability of the Master Fund to pursue its investment program or employ brokers and other counterparties could have a material adverse effect on the Fund and the investors’ investments therein. In

addition, the Investment Manager may, in its sole discretion, cause the Fund or the Master Fund to be subject to certain laws and regulations if it believes that an investment or business activity is in the Master Fund’s interest, even if such laws and regulations may have a detrimental effect on one or more investors. Alternative Investment Fund Managers Directive The Alternative Investment Fund Managers Directive (the “AIFM Directive”) regulates: (i) alternative investment fund managers (each, an “AIFM”) based in the European Economic Area (the “EEA” ) or the United Kingdom; (ii) the management of any alternative investment fund (“AIF”) established in the EEA or the United Kingdom (irrespective of where an AIF’s AIFM is based); and (iii) the marketing of any AIF, such as the Fund, to professional investors in the EEA or the United Kingdom. Under the AIFM Directive, certain conditions must be met to permit the marketing of the Shares to any potential and existing investors in the EEA or the United Kingdom. The ability of the Fund or the Investment Manager to offer the Shares in the EEA or the United Kingdom will depend on the relevant state permitting the marketing of non-EEA or United Kingdom domiciled funds under the national private placement regimes implementing the AIFM Directive and the ability of the Fund and the Investment Manager to comply with such national private placement regimes, where available. Compliance with the requirements of such regimes may increase the costs of the administration of the Fund significantly, including the costs of regulatory reporting services to the Fund and the Master Fund and custody and prime brokerage services provided to the Master Fund. As such, the Fund’s ability to market the Shares to EEA or United Kingdom investors may be limited. Systemic Risk Systemic risk is the risk of broad financial system stress or collapse triggered by the default of one or more financial institutions, which results in a series of defaults by other interdependent financial institutions. Financial intermediaries, such as clearing houses, banks, securities firms and exchanges with which the Master Fund interacts, as well as the Master Fund, are all subject to systemic risk. A systemic failure could have material adverse consequences on the Master Fund and on the markets for the Securities in which the Master Fund seeks to invest. Assumption of Catastrophe Risks The Master Fund may be subject to the risk of loss arising from direct or indirect exposure to various catastrophic events, including the following: hurricanes, earthquakes and other natural disasters; war, terrorism and other armed conflicts; cyberterrorism; major or prolonged power outages or network interruptions; and public health crises, including infectious disease outbreaks, epidemics and pandemics. To the extent that any such event occurs and has a material effect on global financial markets or specific markets or issuers in which the Master Fund invests (or has a material negative impact on the operations of the Investment Manager or the Service Providers), the risks of loss can be substantial and could have a material adverse effect on the Fund and the investors’ investments therein. Furthermore, any such event may also adversely impact one or more individual investors’ financial condition, which could result in substantial redemption requests by such investors as a result of their individual liquidity situations and irrespective of Fund performance. (See “Certain Risk Factors — Risks Relating to the Structure of the Fund — Effect of Substantial Redemptions.”) These potential impacts, while uncertain, could adversely affect the performance of the Fund. No Operating History Each of the Funds, the Master Fund and the Investment Manager are newly formed entities and do not have any operating history upon which prospective investors can evaluate their anticipated performance. Neither the Investment Manager nor its investment professionals have previously operated any investment vehicles similar to the Fund. There can be no assurance that the Funds or the Investment Manager will be successful. Dependence on the Investment Manager The success of the Fund is dependent upon the ability of the Investment Manager to manage the Master Fund and effectively implement the Master Fund’s investment program. The Fund’s governing documents do not permit the investors to participate in the management and affairs of the Fund. If the Investment Manager were to lose the services of the Principal or the Fund or any of the Other Accounts managed by the Investment Manager were to incur substantial losses, the Investment Manager might not be able to provide the same level of service to the Fund as it has in the past or continued operations. (See “Certain Risk Factors — Risks Relating to Management —

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Our clients are described in Item 4 above. The 272 Fund is generally open to, among others, high net-worth individuals, financially sophisticated individuals, and other sophisticated investors. In addition, we have clients that are institutional investors.

As noted in Item 5. Fees and Compensation, we and our affiliates are entitled to performance-based compensation. As a result, we and our affiliates do not face certain conflicts of interest that may arise when an investment adviser accepts performance-based fees from some clients, but not from other clients. Performance-based allocation arrangements could motivate us to recommend investments which may be riskier or more speculative than would be the case if these arrangements were not in effect. Our individual employees and affiliates who are compensated to some extent based upon trading profits for which they are responsible face the same potential conflict. Because the performance-based allocation is calculated on a basis that includes unrealized appreciation in the Fund’s portfolio based upon values assigned by us, 272 faces a conflict of interest in valuing the Fund’s portfolio. 272 addresses these conflicts through full and fair disclosure in the Fund’s offering and/or governing documents and/or this Brochure. SIDE-BY-SIDE MANAGEMENT 272 does not manage client accounts that are not subject to a performance-based allocation; there are currently no conflicts related to side-by-side management.

272 and its employees will devote such time to the Firm’s affairs as is consistent with achieving Client’s investment objectives. However, except as otherwise provided in the investment management agreements or governing documents, 272 and any of our affiliates may engage in other business activities subject to pre-clearance by the Chief Compliance Officer. Wes Cummins is the founder and CEO of public company, Applied Digital Corporation (APLD). Other 272 employees also serve as officers or employees of APLD. Mr. Cummins also serves on the board of public company, Sequans Communications (SQNS). Clients have invested in both APLD and SQNS. AFFILIATED GENERAL PARTNER 272 Advisors LLC serves as the General Partner to the Domestic Fund and Master Fund. OTHER REGISTRATIONS Neither 272, nor any of our management persons are registered, or have an application pending to register, as a brokerdealer or a registered representative of a broker-dealer, futures commission merchant, commodity pool operator

Pursuant to Advisers Act Rule 204A-1, 272 has adopted and implemented a Code of Ethics (the “Code”), which sets forth high standards of business conduct for our employees. Our Code is primarily designed to educate employees about our philosophy regarding ethics and professionalism, emphasize our fiduciary duties to clients, encourage employees to comply with applicable laws, prevent the misuse of material non-public information, the circulation of rumors and other forms of market abuse and address conflicts of interest that arise from personal trading by employees. Among other things, 272 imposes restrictions on employees relating to the purchase or sale of securities for accounts with respect to which they have beneficial ownership and the accounts of certain affiliated persons. Such individuals are required to disclose, and in certain instances, seek pre-approval for their personal securities transactions and personal securities holdings. 272 also maintains certain policies and procedures designed to prevent employees from misusing material non-public information and to address certain actual and potential conflicts of interest that may arise when supervised persons engage in outside business activities; make political contributions; or accept, provide, offer or give gifts or entertainment events. A copy of our Code is available to investors and prospective investors upon request. Our employees are required to certify their adherence to the terms set forth in the Code upon commencement of employment and annually thereafter. Employees also are required to provide quarterly certifications of compliance with certain Code of Ethics provisions. The foundation of our Code is based upon the following underlying fiduciary principles: • • •

Employees must at all times place the interests of the Firm’s Clients first; Employees must ensure that all personal securities transactions are conducted consistent with the Code of Ethics’ Employee Personal Trading Policy (described below); and Employees should not take inappropriate advantage of their position at the Firm.

PERSONAL TRADING ACTIVITIES Employees and their respective affiliates may under limited circumstances purchase or sell for their own account financial instruments that are recommended to, or purchased or sold on behalf of, our Clients. Allowing employees to purchase these securities may motivate those persons to engage in “front running,” which is the practice of executing orders for an employee’s personal account while taking advantage of advance knowledge of pending orders from its Clients. To prevent this practice, 272 limits trading in individual stocks in personal accounts and requires pre-clearance of all personal investments made by our employees and strictly prohibits “front running.” However, 272 does not provide disclosure to our Clients when employees or their respective affiliates purchase or sell for their own account financial instruments that are recommended to, or purchased or sold on behalf of, our Clients. In addition, employees are prohibited from personally, or on behalf of a Client, purchasing or selling securities that appear on the Firm’s Restricted List. Employees are also required to seek preclearance approval by the Chief Compliance Officer prior to participating in an Initial Public Offering (“IPO”) and private investments. We will provide a copy of our Code of Ethics to our Clients, or any prospective investor, upon request. TRANSACTIONS INVOLVING CONFLICTS OF INTEREST 272 may enter into transactions and arrangements involving actual or potential conflicts of interest. 272 will review any transactions involving material conflicts of interest and take such actions as 272 deem necessary or appropriate in an attempt to ensure that the terms of such transactions are fair and reasonable under the circumstances (including, without limitation, obtaining consent with respect to such transactions). 272 employees may, on occasion, accept gifts or invitations to entertainment but must always act in the best interest of 272, and its Clients and avoid any activity that might create an actual or perceived conflict of interest or impropriety in the course of the firm’s business relationships. 272’s gift and entertainment policy implements internal controls to

monitor such activity, which include reporting or seeking pre-approval before giving or accepting gifts and entertainment of significant value and prohibiting or limiting the provision or receipt of cash gifts or entertainment to government employees, foreign officials and certain other categories of recipients. 272 employees may from time-to-time make political or charitable contributions. Employees are required to report political contributions made to any political official, candidate for political office, political party or political action committee (“PAC”). Political contributions are generally permitted except where such contributions may raise issues under the pay-to-play rule.

272 is authorized to determine the broker-dealer to be used for executing securities transaction for Clients. In selecting broker-dealers to execute transactions, we do not need to solicit competitive bids and do not have an obligation to seek the lowest available commission cost. It is not our practice to negotiate “execution only” commission rates; therefore, our Clients may be deemed to be paying for research, brokerage or other services provided by the broker which are included in the commission rate. Our choice of broker is based on quality and value of the service(s) provided. 272 recognizes its duty to best execution. 272 is not obligated to effect a particular volume of transactions through a particular broker and 272 will ascertain that the brokerage commissions charged in connection with transactions are reasonable in relation to the value of the brokerage, research and other services provided by the broker. We shall also have the authority to select and appoint custodians of the assets of our Client accounts. The Firm’s authority is limited by its own internal policies and procedures and each Client’s investment guidelines. BEST EXECUTION In selecting an appropriate broker-dealer to affect a client trade, we seek to obtain “Best Execution,” meaning generally the execution of a securities transaction for a client in such a manner that a client’s total costs or proceeds in the transaction are most favorable under the circumstances. Accordingly, in seeking Best Execution, we will take into consideration the price of a security offered by the broker-dealer, as well as a broker-dealers’ full range and quality of their services including, among other things, their facilities, reliability and financial responsibility, execution capability, commission rates, responsiveness to us, brokerage and research services provided to us (for example, research ideas, analysis, and investment strategies),special execution and block positioning capabilities, clearance, and settlement and custodial services. SOFT DOLLAR PRACTICES

The Firm uses “Soft Dollars” generated by. In such cases, Soft Dollar credits generated by the Firm’s trading activities are used to purchase brokerage and research services. We keep any such arrangements within the parameters of the safe harbor of Section 28(e) of the Exchange Act. However, subject to best execution, we may consider, among other things, capital introduction and marketing assistance with respect to Investors in the 272 Fund in selecting or recommending broker-dealers for our Clients. BROKERAGE FOR INVESTOR REFERRALS From time to time, our third-party brokers may provide opportunities for us to be introduced to potential investors. Our prime brokers or their affiliates may provide capital introduction or other placement services to the 272 Fund and 272 (with or without separate charges for such other services). Such “capital introduction” opportunities may influence our decision to use (or continue to use) the services of these brokers, rather than selecting brokers solely based on the Fund’s interest in receiving the most favorable execution. However, 272 does not compensate brokers for capital introductions and such introductions are not material factors in 272’s best execution evaluations. The provision by a broker of research and other services and property to us creates an incentive for us to select such broker since we would not have to pay for such research and other services and property as opposed to solely seeking the most favorable execution for a client. Any research, services or property provided by a broker may benefit any Client and such benefits may not be proportionate to commission dollars related to the provision of such research, services, or property. DIRECTED BROKERAGE 272 does not recommend, request or require Clients to direct us to execute transactions through a specified brokerdealer. 272 also does not permit Clients to direct brokerage for order execution purposes.

ORDER AGGREGATION AND ALLOCATION OF INVESTMENT OPPORTUNITIES When possible, 272 aggregates transactions for its Clients and allocates trades per the Firm’s pro rata trade allocation policy. TRADE ERRORS 272 has adopted policies and procedures regarding the handling and resolution of trade errors in our compliance manual. Consistent with our fiduciary duties, our policy is to use the utmost care in making and implementing investment decisions with respect to Client accounts. To the extent trading errors occur, 272 seeks to ensure that the Client’s best interests are served. Consistent with provisions, Clients generally will be responsible for trade errors (except for errors caused by the bad faith, willful misconduct or gross negligence of 272, any of our employees, or any of our affiliates).

We do not have referral agreements in place for the 272 Fund or for referrals of separately managed account clients. We do not receive compensation from third parties for investor/client referrals.

272 is not involved in any legal or disciplinary events that are material to an investor’s or prospective investor’s evaluation of our advisory business or the integrity of our management. Mr. Cummins, in his role as an officer of Applied Digital Corporation (APLD), has been named as a defendant, along with APLD, in a securities law class action lawsuit related to operations and management of APLD. The litigation does not relate directly to 272 Capital. Mr. Cummins believes the lawsuit is without merit and intends to vigorously defend against this action.

Our Portfolio Manager and investment professionals continuously monitor and analyze the transactions, positions, and investment levels of the Fund to ensure that they conform with the investment objectives and guidelines that are stated in Client investment management agreements and Fund governing documents. In these reviews, the Firm pays particular attention to any changes in the investment’s fundamentals, overall risk management and changes in the markets that may affect price levels. We perform various periodic reviews of each Client’s portfolio. REPORTS TO CLIENTS/INVESTORS We will distribute an audited financial report with respect to the previous fiscal year to all 272 Fund investors within 120 days of fiscal year end. We may also distribute quarterly unaudited net asset value statements, quarter-end performance reports, and a quarterly letter to all investors.

We are deemed to have custody of Client funds and securities because we have the authority to obtain Client funds or securities, for example, by deducting advisory fees from a Client’s account or otherwise withdrawing funds from a Client’s account. Account statements related to the Clients are sent by qualified custodians to 272. We will comply with Rule 206(4)-2 of the Advisers Act (i.e., the “custody rule”) by meeting the conditions of the pooled vehicle annual audit approach. Upon completion of the relevant Fund’s annual audit by an independent auditor that is registered with, and subject to inspection by, the Public Company Accounting Oversight Board (PCAOB), we will distribute the Fund’s audited financials to Investors within 120 days of such Fund’s fiscal year end.

272 has discretionary power and authority over the types of financial instruments to be bought or sold, as well as the amount to be bought or sold on behalf of Clients. 272 has the authority to determine the broker-dealer or other counterparty to be used for Client transactions and the negotiation of commission rates and other consideration to be paid by the Client. LIMITED POWER OF ATTORNEY 272 also has the authority to conduct authorized trading and perform other acts on behalf of our Clients.

In compliance with Rule 206(4)-6 of the Advisers Act (i.e., the “proxy voting rule”), we have adopted proxy voting policies and procedures. The 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 in line with the Client’s investment objectives. We take into account all relevant factors, as determined by using our discretion, including, without limitation: • • •

the impact on the value of the securities or instruments owned by the relevant client and the returns on those securities; the anticipated associated costs and benefits; the continued or increased availability of portfolio information; and • industry and business practices.

Generally, clients may not direct our vote in a particular solicitation. Clients may obtain a copy of our Proxy voting policies and our Proxy voting record upon request.

272 does not require prepayment of fees six months or more in advance. 272 does not have any financial condition that impairs our ability to meet contractual commitments to our clients, and 272 has not been the subject of any bankruptcy proceeding.