ABSOLUTE INVESTMENT ADVISERS, LLC

Absolute Investment Advisers, LLC ("Absolute", “we” or “us”) is an SEC-registered investment adviser with its principal place of business located in Rosemary Beach, Florida. Absolute is a limited liability company that began conducting business in 2004. Absolute’s principal owner (i.e., those individuals and/or entities controlling 25% or more of the partnership) is James P. Compson. Mutual Fund Portfolio Management Absolute is the investment adviser for the Absolute Convertible Arbitrage Fund, Absolute Flexible Fund, Absolute Capital Opportunities Fund, Absolute CEF Opportunities Fund and the Absolute Select Value ETF (together, the “Funds”, “Mutual Funds” or the “Absolute Funds”) each a registered investment company under the Investment Company Act of 1940 (the “1940 Act”). Absolute serves as the investment adviser to the Funds and continuously manages the Absolute Fund assets based on the investment goals and objectives as outlined in each Absolute Fund's prospectus. Interested investors should refer to each Absolute Fund's Prospectus and Statement of Additional Information ("SAI") for important information regarding objectives, investments, time horizon, risks, fees, expenses, and additional disclosures. These documents are available on-line at www.absoluteadvisers.com. Private Fund Portfolio Management Absolute provides investment management services to a collective investment fund that is not registered as an investment company (the "Private Fund"). The Private Fund (that is managed by Absolute includes: Absolute Finn Investment Partners, L.P. AIA Finn Associates GP, LLC (“General Partner”) is the General Partner to the Absolute Finn Investment Partners L.P. (the “Partners Fund” or “Partnership”), a privately offered pooled investment vehicle. The General Partner has appointed Absolute to serve as the Partners Fund’s investment adviser. The General Partner is a relying adviser of Absolute and is under common control and collectively conducts a single advisory business. Absolute is the manager of the Partners Fund's assets, and the General Partner has no employees or other persons acting on its behalf other than officers, directors, partners or employees of Absolute. Separate Account Portfolio Management Absolute provides continuous investment advisory services to separately managed account clients (“SMA Clients”). Through discussions in which goals and objectives based on the SMA Clients’ particular circumstances are established, Absolute develops the SMA Clients’ investment

guidelines and portfolio parameters and subsequently creates and manages a portfolio based on those guidelines. Absolute manages SMA Clients on a discretionary basis. Account supervision is guided by each respective SMA Client's stated objectives and portfolio parameters (e.g., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. SMA Clients can impose reasonable restrictions on investing in certain securities, types of securities, industry sectors, or such other investment restrictions as may be agreed between a SMA Client and Absolute, but in general management of an account is discretionary on the part of Absolute. Absolute provides continuous separately managed account asset management of portfolios (“SMA Clients”, together with the Private Fund and the Absolute Funds, “Client Accounts”) based on the applicable governing documents of each Client Account. Amount of Managed Assets All of Absolute’s accounts are managed on a discretionary basis. As of December 31, 2025, Absolute was managing approximately $2,233,935,045 of Client Account assets.

Private Fund(s) The Private Fund pays Absolute a fixed quarterly management fee as of the beginning of each fiscal quarter equal to 0.25% (1.00% annualized) of the Private Fund’s opening net asset value for that quarter. Such fixed management fees payable by the Private Fund are generally not negotiable, although in certain circumstances management fees may be waived or reduced. In addition, the Private Fund also typically pays a performance-based fee or profit allocation of 20% of the net realized and unrealized capital appreciation in the Private Fund. This performance-based compensation is subject to waiver by Absolute, in its sole discretion, and is waived for certain Limited Partners in the Private Fund. Absolute has waived the performance-based compensation for certain affiliates of Absolute (the General Partner of the Private Fund), family members of the Principals of the General Partner of the Private Fund, and other entities created for a family member's benefit.) The performance-based compensation is charged only on profits in excess of the Private Fund’s previous "high water mark." Mutual Funds Absolute charges an asset-based fee for investment management services to the Absolute Funds. The fee arrangement, termination, and refund policies are described in each Absolute Fund's prospectus and Statement of Additional Information ("SAI"). For these services, Absolute typically charges annual management fees that range from 0.85% to 1.40% of the average daily net assets of an Absolute Fund, depending on the type of assets being managed. Fees charged with respect to Absolute Funds are subject to annual review and approval

by the Board of Trustees of each Absolute Fund. These fees and expenses are described in each Absolute Fund's prospectus, and clients should review the fees charged by the Absolute Funds and the fees charged by Absolute to fully understand the total amount of fees to be paid by the client. Separately Managed Accounts For SMA Clients, management fees are normally charged based on a percentage of assets under management. Absolute may be paid a management fee in advance at the beginning of each calendar quarter based on an agreed percentage of the market value of the holdings in the SMA Client account as of the beginning of the quarter, or the SMA Client may pay the management fee based on an agreed percentage of the market value of the holdings in the SMA Client account quarterly in arrears based on the average of the net asset value as of the last day of each month during such calendar quarter. Management fees are generally billed to the client, not deducted from the client’s account. Absolute is also entitled to be paid a performance-based fee as mutually agreed between an SMA Client and Absolute (so long as the client is a "qualified client" under the applicable securities regulations). The performance-based fee is based on an agreed percentage of net realized and unrealized capital appreciation on an annual basis and may be subject to a hurdle or target performance amount that must be reached before the performance-based fee will be paid. In addition, the performance-based fee will be subject to a “high-water” mark such that if the account suffers a net capital loss, no performance-based fee will be charged until the account has recovered that loss. If an SMA Client invests a portion of its assets in the Private Fund, then no separate account management fee is paid on the portion of assets in the Private Fund, but rather, only the management and performance-based fees of the Private Fund are charged on those assets. Fees charged to SMA Clients are subject to negotiation and are included in a written contract between the client and Absolute. A minimum of $25 million of assets under management is required for separately managed accounts, subject to Absolute’s discretion to accept more or less. This account size may be negotiable under certain circumstances. An SMA Client agreement generally may be canceled at any time, by either party, for any reason upon receipt of written notice. The Investment Management Agreement between the SMA Client and Absolute will give the specific notice period required, which is generally 30 days. As disclosed above, certain fees are paid in advance of the services provided. Upon termination of any separately managed account that pays management fees in advance, any prepaid, unearned fees will be promptly refunded. In calculating a SMA Client’s reimbursement of fees, Absolute will pro rate the reimbursement according to the number of days remaining in the billing period. Other Fees and Expenses In addition to our advisory fees, Client Accounts are also responsible for the fees and expenses charged by custodians and imposed by broker-dealers, including, but not limited to, any transaction charges imposed by a broker-dealer that effects such transactions. Client Accounts will generally also bear all other costs and expenses related to their investments and operations, including, without limitation, brokerage commissions and other transaction costs, clearing and settlement charges, interest and commitment fees on debit balances or borrowings,

borrowing charges on securities sold short, stock borrowing fees, proxy solicitation expenses, costs of liability insurance obtained on behalf of a Client Account, initial and variation margin, custodial fees, costs of any litigation or investigation involving Client Account activities, indemnification expenses, consulting expenses, the fees and expenses of professionals providing services to the Client Accounts, including legal and other professional fees relating to potential and actual investments, audit, accounting, tax and administration, regulatory costs, any issue or transfer taxes chargeable in connection with any securities transactions, any entity level taxes, regulatory filing and license fees, costs of reporting and providing information to investors in such Client Account (if any), and any extraordinary expenses. A portion of certain Client Account’s operating expenses may be shared with other Client Account managed by Absolute on an equitable basis as determined by Absolute, and if permitted pursuant to a client’s applicable governing documents. Not all of Absolute’s Client Accounts will pay all of the types of expenses and costs listed above, and Client Accounts may also pay different expenses not listed above. In each case, reference should be made to each Client Account’s applicable governing documents for further information. More information regarding fees and expenses applicable to the Absolute Funds is also available on the Absolute Funds’ website. See Item 4 for the website for the Absolute Funds.

Absolute Finn Investment Partners, L.P. The investment objective for the Partners Fund and any Separately Managed Account that follows a similar type of investment strategy, whether in whole or in part, is to seek to generate attractive risk-adjusted total return, consisting of both income and capital appreciation, by investing primarily in closed-end funds (“CEFs”). Absolute believes that certain features of CEFs can create significant market inefficiencies and will opportunistically pursue investments created by or otherwise related to those perceived inefficiencies. Many of these investment opportunities are expected to relate to differences between the trading price of the shares of a CEF as compared to the net asset value (“NAV”) of the securities and other assets held by that CEF. This often results from the fact that holders of interests in CEFs do not have the right to redeem their interests on a daily basis at a price based on NAV. As a result, CEF’s shares will often trade at a premium or at a discount to its NAV. Absolute generally expects to seek investment opportunities for the Partners Fund in two main categories. First are longer-term, or “core” opportunities, where Absolute believes that a CEF is mispriced, and that as a result, Partners Fund may pursue attractive long-term returns by investing in that CEF at prices that Absolute believes are undervalued. Second are event-driven opportunities, which tend to be shorter-term in nature. These potential investments are expected to be more dependent on the outcome of particular special situations related to a CEF and may include opportunities related to events such as rights offerings and dividend changes, among others. It should be noted that although Absolute believes that the foregoing types of investments will generally tend to be either longer or shorter duration holdings for the Partners Fund, as described above, there is no minimum period or outside limitation on how long the Partners Fund will be required to hold any of these investments, and holding periods may vary widely even within either of these categories. Additionally, Absolute expects to also invest a portion of Partners Fund assets in exchange-traded funds (“ETFs”, and collectively with CEFs, “Underlying Funds”) and securities of other issuers. Absolute CEF Opportunities Fund Absolute CEF Opportunities Fund is an absolute return fund that seeks to achieve long-term capital appreciation with an emphasis on absolute (positive) returns and low sensitivity to traditional financial market indices such as the S&P 500 Index. Absolute believes that there are important benefits that come from pursuing the Fund’s investment objective by primarily investing, under normal circumstances, at least 80% of its net assets (plus the amount of any borrowings for investment purposes) will be investments in publicly traded closed-end funds (“CEFs”), including buying securities issued by CEFs, or selling short CEF securities. The Adviser believes that certain features of CEFs can create significant market inefficiencies, and the Fund will opportunistically pursue investments created by or otherwise related to those inefficiencies. One such market inefficiency relates to differences between the trading price of the shares of a CEF as compared to the net asset value (“NAV”) of the securities and other assets held by that CEF.

The Adviser focuses on relative value and event driven strategies in any given asset class. A relative value assessment involves identifying securities that the Adviser believes are mispriced relative to their NAV. The Adviser purchases securities that it believes are undervalued and shorts securities that it believes are overvalued. Relative value trades tend to be longer in nature as the Adviser buys long or sells short a CEF when that security is believed to be mispriced. Typically, the Adviser will believe there is a catalyst that will push the price of the security up or down. Some catalysts include dividend changes, activist ownership, interest rate changes, and other market conditions. An event-driven strategy is when the Adviser opportunistically invests in a security when the Adviser believes an upcoming circumstance or situation has the potential to produce positive returns. Event-driven opportunities tend to be shorter-term in nature. These potential investments are expected to be more dependent on the outcome of special situations or corporate actions related to a CEF. Some of these events include tender offers, rights offerings, fund mergers, fund liquidations, or fund conversions into an ETF or an open-end fund, among others. Absolute Select Value ETF (ETF) The ETF is an actively-managed, exchange-traded fund that employs an absolute return mindset to long-only value investing, emphasizing proven business models priced at a substantial discount to the ETF Portfolio Manager’s conservative estimate of fair value. The ETF’s investment methodology stresses absolute returns, blending a combination of fundamental analysis, discipline and patience with the goal of preserving and compounding capital. St. James Investment Company, LLC, the ETF’s investment sub-adviser (the “Subadviser”), seeks to achieve the ETF’s objective by investing primarily in equity securities of U.S. companies that the Subadviser believes are priced at a substantial discount to the Subadviser’s estimate of fair value. However, the ETF may invest in companies of any market capitalization and in any economic sector, including equity securities of foreign companies that trade on U.S. exchanges, either directly or through American Depositary Receipts (“ADRs”). The Subadviser, which actively manages the ETF, uses a five-stage process to identify, purchase, and sell companies that it believes are fundamentally attractive and will yield positive absolute returns, meaning it seeks positive returns in all market conditions, over complete market cycles, net of fees and expenses, and not returns that outperform a specific benchmark. The first stage of the Subadviser’s process is Qualification. The Subadviser begins with a universe of approximately 1700 companies and identifies candidates that the Subadviser believes are strong financially and have near-term operating challenges that depress its price, which the Subadviser believes is a combination that offers the potential for long-term value. The second stage is Quantitative Valuation, in which the Subadviser analyzes the initial set of candidates to estimate the fair value of the company. In the third stage, Fundamental Qualitative Research, the Subadviser conducts research to assess whether a company is likely to move toward the Subadviser’s estimate of fair value. In the fourth stage, Portfolio Construction, the Subadviser selects a relatively small number of companies, typically between 20 and 25, with, at the time of purchase, no more than 8% in any given position and no more than 20% in a particular industry.

The Subadviser expects that, because of its “bottom up” approach to company analysis, from time to time, the ETF could be overweight in certain market sectors. The Subadviser’s strategy is based on company-by-company analysis, not market sector analysis. In the fifth stage, Sell Discipline, the Subadviser employs a process that triggers a sale when a company hits a sell target determined at the time of purchase, or when the Subadviser believes that there has been a significant change in the long-term prospects for the company. The ETF is non-diversified, which means that it may invest a greater percentage of its assets in fewer issuers than a diversified fund. The ETF may also invest all or substantially all of its assets in cash and cash equivalents, including money market funds and other short-term fixed income investments, in seeking to protect principal, or when, in the Subadviser’s opinion, there are not sufficient companies at valuations appropriate for investment. As an alternative to holding cash or cash equivalents, the Subadviser may invest the ETF’s assets in shares of other investment companies, including open-end and closed-end funds and exchange traded funds in order for the Fund to be more fully invested. Absolute Convertible Arbitrage Fund The Absolute Convertible Arbitrage Fund (the “Arbitrage Fund”) seeks to achieve positive absolute returns over the long-term with low volatility when compared to traditional market indices. The Arbitrage Fund invests primarily in a diversified portfolio of convertible securities issued by both U.S. and foreign companies. These convertible securities are typically debt securities or preferred stocks that can be exchanged for, or convert automatically to, common stock. Convertible arbitrage involves purchasing such a portfolio of convertible securities and hedging the equity risk inherent in such securities by selling short the common stock into which the securities may be converted. The Arbitrage Fund’s convertible arbitrage strategy is intended to offer investors the potential for yield and capital appreciation with less risk than traditional equity indices due to the convertible securities being hedged by shorting the underlying common stock. In so doing, the Arbitrage Fund is designed to provide investors with a potential source of alternative income and returns from investments in interest and dividend-paying convertible securities and trading based on the pricing inefficiencies of the options embedded in the convertible securities. Although the Arbitrage Fund may invest in securities of issuers of any market capitalization, the Arbitrage Fund expects to invest primarily in small- and mid-capitalization companies. For these purposes, the Arbitrage Fund considers small capitalization companies to be those with a market capitalization of less than $2 billion at the time of investment and mid-capitalization companies to be those with a market capitalization between $2 billion and $10 billion at the time of investment. The Arbitrage Fund may also invest in below investment grade securities with individual ratings ranging from BB+ to CCC. The weighted average grade of bonds in the Arbitrage Fund’s portfolio is typically below investment grade. Such “junk bonds” typically are rated Bal or below by

Moody’s, BB+ or below by S&P or BBB- or below by Fitch. The Arbitrage Fund may purchase unrated securities if, at the time of purchase, Absolute believes that they are of comparable quality to rated securities that the Arbitrage Fund may purchase. The Arbitrage Fund may invest, long or short, in securities of issuers of any market capitalization in the U.S. or abroad. The securities in which the Arbitrage Fund typically takes a long position include convertible bonds, such as private placement/restricted and Rule 144A securities and contingent convertible securities (“CoCos”), which are fixed-income instruments that are convertible into equity if a pre-specified trigger event occurs. As part of its convertible arbitrage strategy, the Arbitrage Fund typically invests in short equity positions against a long convertible position of the same issuer, which may include shorting the common stock of such issuer, or shorting certain exposures to non-U.S. issuers obtained through investments in American Depositary Receipts (“ADRs”). The Arbitrage Fund may also invest in pooled investment vehicles, including other registered investment companies and ETFs, and may utilize treasury futures to manage interest rate risk. The Arbitrage Fund may focus its investments in securities of a particular sector from time to time, including the Information Technology Sector, Healthcare Sector, Consumer Discretionary Sector, or Industrials Sector. The Arbitrage Fund may engage in active and frequent trading of portfolio securities. Absolute Flexible Fund The Absolute Flexible Fund (the “Flexible Fund”) seeks to achieve positive absolute returns over the long-term with low volatility when compared to traditional market indices. The Flexible Fund invests primarily in a diversified portfolio of convertible securities issued by both U.S. and foreign companies. These convertible securities are typically debt securities or preferred stocks that can be exchanged for, or convert automatically to, common stock. The Flexible Fund’s strategy generally involves purchasing such a portfolio of convertible securities and, at times, hedging all or a portion of the equity risk inherent in such securities by selling short the common stock into which the securities may be converted. The stock short is referred to as an “equity hedge.” The Flexible Fund’s strategy differs from most convertible arbitrage strategies in that the Flexible Fund may own convertible securities outright (unhedged) or with a partial equity hedge (arbitraged), by selling the same company’s underlying common stock short. The degree of hedging with respect to a particular investment, if any, will depend on the equity sensitivity desired by Absolute at that particular time based on market conditions. The Flexible Fund’s strategy is intended to offer investors the potential for yield and capital appreciation if the underlying common stock moves higher, with lower volatility than traditional equity indices. Although the Flexible Fund may invest in securities of issuers of any market capitalization, the Flexible Fund expects to invest primarily in small- and mid-capitalization companies. For these purposes, the Flexible Fund considers small capitalization companies to be those with a market

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Absolute provides advisory services to mutual funds, an exchange-traded fund, a private fund, and separately managed accounts, whose investors may include private foundations, corporations, state pension plans, and high net-worth individuals. Account Opening Requirements: The Private Fund has a minimum investment amount requirement of generally $100,000, with lesser amounts accepted subject to the sole discretion of Absolute, and investors must meet certain regulatory standards, as described in the Private Fund's Private Placement Memorandum. Absolute Funds generally have minimum investment requirements as well, and these are described in each Absolute Fund's prospectus. A minimum of $25 million of assets under management is generally required for separately managed accounts, subject to Absolute’s discretion to accept more or less.

For Client Accounts that are subject to a performance-based fee or allocation, which are currently the Private Fund and separately managed accounts, there is an inherent conflict of interest built into the fee structure since the performance-based compensation may create an incentive for Absolute to recommend investments which may be riskier or more speculative than those which would be recommended under a different compensation structure. Because Absolute manages accounts that pay performance-based compensation and those that do not, there is an incentive to favor the accounts with performance-based compensation. There is also an inherent conflict of interest between Client Accounts that pay performance-based compensation and Client Accounts that do not, since Absolute has the ability to earn higher fees from the performance-based compensation-paying accounts. This could give Absolute an incentive to place higher performing securities in the accounts that pay performance-based compensation. Absolute seeks to mitigate this by requiring the allocation of securities to occur in advance of trade execution so that trades are not allocated after their performance is known. In addition, for initial public offerings (IPOs) and other limited issues including certain limited availability secondary offerings, which historically have seen large initial gains, Absolute generally requires all eligible accounts to have the opportunity to participate in the offering, on a pro rata basis in proportion to the managed assets in such eligible accounts. Conflicts of Interest Common to all Clients Absolute and affiliated entities, including their members, partners, officers and employees (the “Absolute Affiliates”) are subject to several actual and potential conflicts of interests. Absolute provides investment management services to Absolute Funds, the Private Fund, as well as to Separately Managed Accounts and may in the future provide investment management services to other entities and clients, other collective investment vehicles, registered investment companies and accounts held by single investors, which may or may not utilize investment programs

substantially similar to that of the Absolute Funds, the Private Fund, and Separately Managed Accounts. By the terms of partnership agreements and investment management agreements, Absolute and Absolute Affiliates are not restricted from forming additional investment funds, from entering into other investment advisory relationships, or from engaging in other business activities, even though such activities may be in competition with the Private Fund, Absolute Funds, or Separately Managed Accounts, and/or may involve substantial time and resources of Absolute or Absolute Affiliates. It is anticipated that the Separately Managed Accounts will invest in many of the same securities in which the Private Fund invests. Non-Exclusive Activities. Absolute and Absolute Affiliates will devote as much of their time to the activities of the Private Fund, Absolute Funds and Separately Managed Accounts as Absolute and Absolute Affiliates deem necessary and appropriate. These activities could be viewed as creating a conflict of interest in that the time and effort of the members of Absolute and Absolute Affiliates will not be devoted exclusively to the business of the Private Fund, Absolute Funds and Separately Managed Accounts, but will be allocated between the business of the Private Fund, Absolute Funds and Separately Managed Accounts and other business activities of Absolute and Absolute Affiliates. Limited Resources. Absolute portfolio managers may, and often do, manage accounts for more than one Client Account or type of account, and cannot devote their full time and attention to the management of each single account. Accordingly, Absolute portfolio managers may be limited in their ability to identify investment opportunities for each of the accounts that are as attractive as might be the case if Absolute were to devote substantially more attention to the management of a single account. The effects of this potential conflict may be more pronounced where the accounts have different investment strategies. Limited Investment Opportunities. If Absolute identifies a limited investment opportunity that may be appropriate for more than one account, the investment opportunity may be allocated among several accounts. This could limit any single account's ability to take full advantage of an investment opportunity that might not be limited if Absolute did not provide investment advice to other accounts. Liquidity of investments held across more than one account. If Absolute determines that a particular security is appropriate for several accounts but the security is in limited supply or trades with low volume, such holdings may be both difficult to acquire for the several portfolios, as well as difficult to sell, effecting the ability to move into or out of the position at a desired price level or time frame, or for a particular holding period, and such limitations might not be present if only one or only a couple of accounts had invested in that security. Different Investment Strategies. Client Accounts managed by Absolute can have differing investment strategies. Absolute may give advice or take action with respect to any of the other accounts (including those that have investment objectives and/or investment strategies similar to the Private Fund, Absolute Fund or Separately Managed Account) which may be the same as or differ from the advice given or the timing or nature of any action taken with respect to investments of such Private Fund, Absolute Fund or Separately Managed Account. If Absolute determines that an investment opportunity may be appropriate for only some of the accounts or decides that certain of the accounts should take different positions with respect to a particular security, Absolute may

effect transactions for one or more accounts which may affect the market price of the security or the execution of the transaction, or both, to the detriment or benefit of one or more other accounts. Securities considered as investments for the Private Fund, Absolute Funds or Separately Managed Accounts may also be appropriate for other funds and Client Accounts managed by Absolute, including initial public offerings and other new issues. It is anticipated that the Private Fund, Absolute Fund or Separately Managed Account and certain other funds and accounts managed by Absolute will invest in some or a substantial portion of the same underlying securities. Absolute maintains policies and procedures to seek to ensure that the Private Fund, Absolute Fund or Separately Managed Account will be treated fairly over time with respect to such securities. There is no assurance that the Private Fund, Absolute Fund or Separately Managed Account will purchase securities or sell securities at the same time or in the same proportions. Variation in Compensation. A conflict of interest may arise where Absolute is compensated differently by different accounts. If certain accounts pay higher management fees or performancebased fees, Absolute might be motivated to prefer certain accounts over others. Absolute might also be motivated to favor accounts in which they have a greater ownership interest or accounts that are more likely to enhance Absolute's performance record or to otherwise benefit Absolute. Selection of Brokers. Absolute selects the brokers that execute securities transactions for the Client Accounts that it manages. In addition to executing trades, some brokers provide Absolute with research and other services which generally require the payment of higher brokerage fees than might otherwise be available. Absolute's decision as to the selection of brokers could yield disproportionate costs and benefits among the accounts that they manage, since the research and other services provided by brokers may be more beneficial to some accounts than to others. Shorting of Securities: In a shorting transaction, a Client Account must borrow the shares to be shorted in order to effectuate the short and pay a borrow rate, which can vary based on a number of factors, including whether the custodian has access to the particular security to be shorted from other accounts under its supervision. Securities that are in demand or thinly traded can require a higher borrow rate. The borrow typically is done with the custodian, but if the Client Account has a different custodian, than other Client Accounts, the cost of the borrow can vary between custodians based on each Client Account custodian’s particular access to the security. As a result, Client Accounts can end up paying borrow rates for the same security to be sold short. Use of Soft Dollars. The use of brokerage commissions to obtain research services may create a conflict of interest between Absolute and the Private Fund, Absolute Fund, or Separately Managed Account. This may result in the Private Fund, Absolute Fund, or Separately Managed Account paying higher brokerage commissions than might be paid if transactions were affected through brokers that do not provide such services. To the extent that Absolute can acquire these products and services without expending its own resources or at reduced prices, Absolute’s use of “softdollars” would tend to increase its profitability. In addition, the availability of these non-monetary benefits may influence Absolute to select one broker rather than another to perform services for the Private Fund, Absolute Fund or Separately Managed Account. In general, the use of soft dollars to pay for research products or services will fall within the safe harbor created by Section 28(e) of the Securities and Exchange Act of 1934, as amended (see Use of Soft Dollars under Item 12).

Service on Boards of Directors. Representatives of Absolute and/or an Absolute Affiliate may serve on the board of directors of one or more private or publicly traded companies, including, but not limited to, companies in which a Private Fund, Absolute Fund or Separately Managed Account may invest. In addition, representatives of Absolute and/or an Absolute affiliate, as a result of an investment in a private transaction, may be awarded board of directors’ observer rights on behalf of Absolute for securities in which Client Accounts may invest. As a result, the Private Fund, Absolute Fund or Separately Managed Account may be restricted from transacting in securities of such issuers. Cross Transactions. If permitted under applicable law, Absolute may, on behalf of the Private Fund, Absolute Fund or Separately Managed Account, for liquidity, portfolio rebalancing, trade allocation or other reasons, purchase investments from, sell investments to or enter into agreements with other accounts managed by Absolute and its affiliates (i.e., “cross transactions”). The terms of any such cross transactions will be commercially reasonable and will not be materially less favorable to the Private Fund, Absolute Fund or Separately Managed Account than those available in the market. Absolute will receive no special fees or other compensation in connection with cross transactions. Expenses incurred in a cross transaction will be allocated equitably in the sole discretion of Absolute between the Private Fund, Absolute Fund or Separately Managed Account, and the other accounts that are parties to the cross transaction. Similarly, if a transaction is cancelled, any costs incurred will be allocated equitably in the sole discretion of Absolute between the Private Fund, Absolute Fund or Separately Managed Account and the other accounts that are parties to the cross transaction. Personal Securities Trading. Absolute and Absolute Affiliates may trade in certain securities for their own accounts, including securities that are held by, or may be traded by, Client Accounts, subject to restrictions and reporting requirements as may be required by law or as determined by Absolute, and further provided that no transactions may be entered into that would violate federal securities laws. Absolute has adopted a Code of Ethics and Professional Conduct (the “Code of Ethics”) to govern the personal securities trading of all partners and employees. See Item 11.

Absolute has entered into Promoter arrangements, as defined in Rule 206(4)-1, with unaffiliated advisers and private fund managers in which a portion of a management or incentive fee is paid to Absolute as outlined in the corresponding agreement. These arrangements can create a conflict of interest as Absolute has an incentive to recommend such products for compensation. These arrangements do not impact the fees incurred by an advisory or private fund investor. Brian Hlidek, Managing Principal, Chris Ward, Principal, Chris O’Grady, Director and Janielle Lucas, Vice President of the Sales and Marketing Team at Absolute are registered representatives of Foreside Fund Services LLC, an unaffiliated registered broker-dealer and FINRA member. Absolute CEF Opportunities Fund, Absolute Capital Opportunities Fund, Absolute Convertible Arbitrage Fund and Absolute Flexible Fund Absolute serves as the investment manager to the Absolute CEF Opportunities Fund, Absolute Capital Opportunities Fund, Absolute Convertible Arbitrage Fund, and the Absolute Flexible Fund. The Absolute Capital Opportunities Fund, Absolute Convertible Arbitrage Fund, Absolute Flexible Fund, and Absolute CEF Opportunities Fund (each a “Fund,” and collectively “the Funds”), are a separate series of the Unified Series Trust (the “Trust”). Ultimus Fund Solutions, LLC, acts as the Funds’ transfer agent, fund accountant, and administrator. Ultimus is the parent company of the Distributor. Ultimus Fund Distributors, LLC, is the exclusive agent for distribution of shares of the Absolute Funds. Absolute Select Value ETF (ABEQ) The ETF was organized as a non-diversified series of Unified Series Trust (the “Trust”). The Trust is an open-end investment company established under the laws of Ohio by an Agreement and Declaration of Trust, as amended. Ultimus Fund Solutions, LLC, acts as the ETF’s administrator. Northern Lights Distributors, LLC, is the Distributor. Absolute Finn Investment Partners, L.P. Absolute serves as the investment manager of the Absolute Finn Investment Partners, L.P., a Delaware limited partnership. This arrangement is material to its advisory business. AIA Finn Associates GP, LLC is the general partner of Absolute Finn Investment Partners, L.P. and is under common control with Absolute.

Code of Ethics: Absolute has adopted a Code of Ethics which sets forth the standards of business conduct that Absolute requires of our employees, including compliance with applicable federal securities laws.

Absolute and our personnel owe a duty of loyalty, fairness and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code of Ethics. Our Code of Ethics includes policies and procedures for the pre-clearance of certain employee personal security transactions, the review of quarterly securities transactions reports, as well as initial and annual securities holdings reports that must be submitted to and reviewed by our CCO. Our Code of Ethics also provides for oversight, enforcement and recordkeeping provisions. Absolute's Code of Ethics further includes a policy prohibiting the use of material non-public information. All employees are reminded that, to the extent they come into possession of material non-public information, such information may not be used in a personal or professional capacity, and they must report this to the CCO so that the security can be added to the Restricted List as necessary. A copy of the Code of Ethics may be obtained by sending an email to info@absoluteadvisers.com or by phoning us at 781.740.1904. Absolute and employees and certain related individuals are prohibited from engaging in principal transactions (buying or selling of securities to or from clients from our own accounts). Our Code of Ethics is designed to seek to ensure that the personal securities transactions, activities and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts.

Selection of Broker-Dealers for Client Transactions Absolute is provided with written authority to determine the brokers to use for Client Account transactions and the commission costs that will be charged to our clients for these transactions. In selecting a broker-dealer for a particular transaction for a Client Account, Absolute will seek the most advantageous terms reasonably available under the circumstances for an account’s transactions (i.e. best execution). Price alone is not the determinative factor, but is considered along with the broker’s execution capabilities, financial responsibility, responsiveness, and market information and research services provided. Absolute will consider certain factors which may include the ability of the brokers to effect the transactions, the brokers’ facilities, reliability and financial responsibility and the provision or payment of the costs of brokerage or research products or services. Absolute need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Accordingly, if Absolute determines in good faith that the commissions charged by a broker are reasonable in relation to the value of the brokerage and research products or services provided by such broker to the Client Account or Absolute, the Client Account will generally pay commissions to such broker in an amount greater than the amount another broker might charge.

Use of Soft Dollars Research products or services provided to Absolute include general economic, political, business and market information, industry and company reviews, evaluations of securities and portfolio strategies and transactions, proxy voting data and analysis, technical analysis of various aspects of the securities markets, recommendations as to the purchase and sale of securities and other portfolio transactions, financial, industry, and trade publications, news and information services, pricing and quotation services, and other research services. Any particular research services obtained through a broker-dealer may be used by Absolute in connection with Client Accounts other than those accounts that pay commission to such broker-dealer. Any such research services may be broadly useful and of value to Absolute in rendering investment advisory services to all or a significant portion of its clients, or may be relevant and useful for the management of only one client’s account or a few clients’ accounts, or may be useful for the management of merely a segment of certain clients’ accounts, regardless of whether any such account or accounts paid commissions to the broker-dealer through which such research services was obtained. Advisory fees are not reduced because Absolute receives such services. Absolute evaluates the nature and quality of the various research services obtained through broker-dealer firms and attempts to allocate sufficient portfolio security transactions to such firms to ensure the continued receipt of research services which Absolute believes are useful or of value to it in rendering investment advisory services to its clients. The use of commissions or “soft dollars” to pay for research products or services will fall within the safe harbor created by Section 28(e) of the Securities Exchange Act of 1934, as amended. Under Section 28(e), research obtained with soft dollars generated by a Client Account may be used by Absolute to service accounts other than such Client Account. Where a product or service obtained with soft dollars provides both research and non-research assistance to Absolute, Absolute will make a reasonable allocation of the cost which may be paid for with soft dollars. Non-permitted uses based on this allocation will be paid for by Absolute with hard dollars. It is anticipated that any use by Absolute of soft dollars to pay for research products or services will fall within the safe harbor created by Section 28(e) of the Exchange Act. A Client Account’s securities transactions can be expected to generate brokerage commissions and other compensation, all of which such Client Account, not Absolute, will be obligated to pay. Absolute will have complete discretion in deciding what brokers and dealers a Client Account will use and in negotiating the rates of compensation the Client Account will pay. In addition to using brokers as “agents” and paying commissions, a Client Account may buy or sell securities directly from or to dealers acting as principals at prices that include markups or markdowns and may buy securities from underwriters or dealers in public offerings at prices that include compensation to the underwriters and dealers. In some situations, payment for the provision of research or trade ideas by a broker-dealer is included in the overall commission rate charged by the broker-dealer. This "bundled" commission rate is an informal soft dollar arrangement and Absolute makes no attempt to separate the cost of the research and the cost of trade execution but rather considers the range of the broker's services as described above to determine if best execution has been achieved. Absolute does, however, attempt to ensure that the services received in these informal arrangements are eligible for soft dollar treatment and that the values of such services are comparable to the commission dollars

expended upon them. In other situations, however, a more formal understanding is made and a specific per share rate for trade execution and for soft dollar provision is assigned. These agreements, in which a broker provides products or services in exchange for executing brokerage transactions through that broker, are referred to as a soft dollar arrangement. Clients should consider that these arrangements may create a potential conflict of interest between Absolute and its clients. This conflict of interest may exist because Absolute's decision to use a particular broker may be based in part on that broker's ability and/or willingness to provide certain products or services to Absolute. Products and services acquired with Client Account brokerage commissions within the last fiscal year included the following: research newsletters; credit research; access to on-line research/information portals; access to meetings with company senior managements; invitations to meetings with industry analysts; attendance at industry conventions, webinars, and other information sessions; research analysis of short sales opportunities; financial data & other security fundamentals; research services concerning regulatory filings; market industry/trends information; bankruptcy/reorganization research; quantitative-based research; daily technical research letters; online news & reports; macroeconomic research & forecasting; proprietary brokerage research; access to software platforms to conduct our own research; securities pricing services related to trading of securities; trade order management software and trading capabilities; electronic utilities to communicate trade and order fill details. Brokers sometimes suggest a level of business they would like to receive in return for the various services they provide. Actual brokerage business received by any broker may be less than these suggested allocations but can (and often does) exceed the suggestions, because total brokerage is allocated on the basis of the considerations described above. A broker is not excluded from receiving business merely because it has not been identified as providing research services. Aggregation of Client Trades To the extent possible, investment themes identified as attractive, and the specific security selections within those themes, are considered for all eligible accounts in the same investment strategy and these trades will generally be done pro rata among such eligible accounts. Closed end fund investments generally trade pro rata to total asset size, although from time-to-time certain funds or accounts may be given a different allocation due to cash availability issues, strategy differences, or to compensate for other structural factors. At times, securities considered as investments for Client Accounts in the same investment strategy may also be appropriate for Client Accounts in a different investment strategy managed by Absolute, but the portfolio weightings and specific holdings periods for a particular security may not necessarily be the same across accounts in the various investment strategies because of various considerations outlined above, or for other reasons. The portfolio managers, exercising investment discretion and judgment, will be responsible for the determination as to the amount of a particular security to be allocated across a group of accounts in different investment strategies. This allocation must be done in advance of execution. When the same security is traded on the same day for accounts having different investment strategies, whenever possible the order should be combined and the weighted average execution price per broker for that day will be used for all accounts that participate. Trades of the same security for accounts in different investment strategies, however, might not be combined if there is a different trading execution strategy being employed. For example, one portfolio manager

may want to trade in the market without regard to a specific price, whereas a second portfolio manager may want to trade at a certain limit price or at VWAP (volume weighted average price) over the course of the day. In those instances, a different average price may result. If two or more brokers or trading facilities are used to trade the same security on the same day, the allocation percentage amongst the various accounts participating will be approximately the same, unless a valid exception applies and is documented. Investment decisions that are made at the same time for more than one Client Account, by the same Portfolio Manager for substantially similar reasons, the Adviser may, but will be under no obligation to aggregate, to the extent permitted by applicable law and regulations, the securities to be purchased or sold in order to seek more favorable prices, lower brokerage commissions or more efficient execution. In these situations, the Adviser is expected to adjust the order of which Client Account is trading in the same security to seek to ensure that one of these Client Accounts is not systematically disadvantaged or advantaged when the Adviser does not elect to aggregate trades. In cases where trades are aggregated on behalf of the Absolute Convertible Arbitrage Fund and the Absolute Flexible Fund, the Adviser will place an aggregate order with the broker, if possible, on behalf of all participating accounts in order to ensure fairness for all accounts; provided, however, that trading will be reviewed periodically to the extent deemed necessary by the CCO to ensure that accounts are not systematically disadvantaged by this Policy. The Adviser will determine the appropriate number of shares to place with brokers and will select the appropriate brokers based upon his or her determination of who will likely provide best execution. The allocation process for a block trade is no different than that of a regular trade; allocations are made as described above. In general, orders will be placed pari-passu on behalf of the Absolute CEF Opportunities Fund, Partners Fund and SMA Clients except when complying with certain restrictions imposed on behalf of each client. Trade orders will be executed contemporaneously without preferring one order over the other, even if orders are delivered at different times. In executing aggregated transactions that are placed at the same time and at the same price with the same broker, trades will generally be allocated on the basis of the relative asset size of each respective Client Account. Notwithstanding the prior sentence, it should be noted that allocations may also be made based upon relative cash balances or in some other manner that the Adviser determines is fair and equitable under the circumstances to each respective Client Account. Trade Error Policy Absolute’s policy concerning trade errors is that errors affecting a client’s account must be resolved promptly and fairly, and in accordance with legal & regulatory restrictions and guidelines. Errors include: (i) an incorrect order upon entry; (ii) the purchase or sale of the wrong quantity of securities or the wrong security or type or class of security; (iii) the misallocation or wrong settlement of a securities transaction that is attributable to Absolute or a third party (typically the executing broker-dealer), regardless of whether a profit or loss results from the error; and (iv) any transaction that violates or conflicts with an account’s investment guidelines and restrictions, Absolute’s policies or procedures (including securities on Absolute’s restricted list) or applicable law, regardless of whether the error is due to a mistake, systems failure, miscommunication or

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Absolute may compensate financial institutions for providing marketing or Client Account support services, including third party marketing support services, program service payments, finders fees, business planning assistance, advertising, education, providing placement on the financial institution’s list of offered funds, counseling on the preparation of sales material and presentations and arranging access to sales meetings, and to sales representatives and management representatives of the Financial Institutions. These payments are generally based on one or more of the following factors: average net assets of the Funds shares, gross or net sales of Fund shares, reimbursement of ticket charges (including fees that a dealer firm charges its representatives for effecting transactions in Fund shares and payments for processing transactions via National Securities Clearing Corporations (“NSCC”)) or a negotiated lump sum payment for services rendered. In addition, program servicing payments may be paid in some instances to third parties in connection with investments in the Funds by retirement plans and other investment programs. Absolute may make on-time or annual payments to select financial institutions receiving program servicing payments in reimbursement of printing costs for literature for participants, account maintenance fees or fees for establishment of Absolute’s mutual funds on the financial institution’s system. Absolute, at its expense, may provide additional compensation to financial institutions which sell or arrange for the sale of shares of the Funds to the extent not prohibited by laws or FINRA rules. Such compensation provided by Absolute may include financial assistance to financial institutions that enable Absolute to participate in and/or present at conferences or seminars, sales or training programs for invited registered representatives and other dealer employees, dealer entertainment, and other dealersponsored events, and travel expenses, including lodging incurred by registered representatives and other employees in connection with prospecting retention and due diligence trips. Absolute may, at its own expense, compensate the financial institutions in connection with the sale or expected sale of Fund shares and it may sponsor various promotional activities held by the financial institutions to promote sales of the Funds. Certain financial institutions may provide administrative services (such as sub-transfer agency, record-keeping or shareholder communications services) to investors purchasing shares of the Funds through retirement plans and other investment programs. A financial institution may perform program services itself or may arrange with a third party to perform program services. In addition to participant recordkeeping, reporting, or transaction processing, program services may include services rendered in connection with Fund/investment selection and monitoring, employee enrollment and education, plan balance rollover or separation, or other similar services. Absolute or the Funds (if approved by the Trustees) may pay fees to these financial institutions for their services. Absolute may compensate financial institutions differently depending upon, among other factors, the level and/or type of

marketing support provided by the institution. Such payments will create an incentive for the financial institutions to recommend that investors purchase Fund shares.

There are no legal or disciplinary events to report that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management.

Private Fund Reviews: Absolute periodically reviews and monitors the Private Fund's holdings in accordance with the investment objectives as detailed in its Private Placement Memorandum or other governing documents. In addition, the Private Fund is reviewed on at least a quarterly basis by the Absolute Investment Committee for industry sector allocations, cross-holdings, and other issues relating to trade allocations, exposures, and performance. Reports: The Limited Partners will receive audited financial statements and K-1 statements, if applicable, within 120 days of the Private Fund's year end. These statements are audited by the Private Fund's auditors, Cohen & Co. Investors in the Private Fund also receive unaudited performance reports on a monthly basis during the year. These statements are generated by the Private Fund's administrator, Ultimus LeverPoint Private Fund Solutions. Mutual Fund Portfolio Management Reviews: Absolute periodically reviews and monitors each Absolute Fund's holdings in accordance with the investment objectives as detailed in a Fund Prospectus. In addition, Absolute reports on a variety of matters to the Absolute Funds’ Board of Trustees and the Absolute Funds’ independent CCO. Reports: Clients should refer to the Fund Prospectus for information regarding regular reports to the Absolute Funds by Absolute, which are generally available on each Absolute Fund's website. See Item 4 for the website for the Absolute Funds. Separately Managed Portfolios Reviews: While the underlying securities within separately managed accounts are periodically monitored, SMA Clients are reviewed at least quarterly by the Absolute Investment Committee.

Accounts are reviewed in the context of each SMA Client's stated investment objectives and portfolio parameters. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. Reports: In addition to the monthly statements and confirmations of transactions that SMA Clients receive from their custodians, Absolute provides periodic reports summarizing account performance, balances and holdings.

Absolute does not have custody of the assets of Client Accounts. SMA Clients should carefully review the account statements received from their custodians for errors and contact Absolute with any questions. For the Private Fund, Absolute will seek to ensure compliance with the Advisers Act and the Custody Rule by ensuring that their cash and securities are held with qualified independent custodians. Monthly statements are produced and delivered by the Private Fund’s Administrator, Ultimus LeverPoint Private Fund Solutions, and an annual audit using generally accepted accounting principles (GAAP) is conducted by the Funds’ auditors Cohen & Co, and the audited financial statements are provided to investors in the Private Fund within 120 days of the Fund’s fiscal year end.

Clients generally hire us to provide discretionary asset management services. In general, Absolute is given full investment discretion over Client Account portfolios in the investment management agreement including the Private Fund and Absolute Funds, without obtaining any prior approval from the client. Clients give us discretionary authority when they sign the investment management agreement with Absolute, and any limitations or restrictions are listed in the investment guidelines attached as part of the investment management agreement. Clients may change/amend such limitations by once again providing us with written instructions.

Absolute will vote proxies for all Client Accounts if given this authority in the investment management agreement. Absolute has adopted policies and procedures pursuant to SEC rule 206(4)-6 with respect to voting proxies on behalf of the Private Fund, Absolute Funds, and SMA Clients. Generally, Absolute will vote proxies in the best interests of its clients and in accordance with our established policies and procedures. Absolute will retain all proxy voting books and records for the requisite period of time. Absolute will use reasonable efforts to determine whether a potential conflict may exist, and a potential conflict shall be deemed to exist only if the Adviser actually knew or should have known of the conflict. All employees are obligated to disclose any potential conflict to the CCO and the Portfolio Manager. Materiality determinations will be based on an assessment of the particular facts and circumstances and consultation with outside counsel, as necessary. The CCO shall document the method used to resolve conflicts of interest and maintain supporting documentation in accordance with regulatory requirements. The Firm shall maintain proxy voting records in accordance with regulatory requirements.

A copy of our Proxy Voting Policy and Procedures for the Absolute Funds, SMA Clients and the Private Fund, as well as information related to how proxies were voted may be obtained by sending an email to info@absoluteadvisers.com or by phoning us at 781.740.1904.

Registered investment advisers are required in this item to provide you with certain financial information or disclosures about Absolute’s financial condition. Absolute has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding.