ADAR1 Capital Management, LLC

ADAR1 Capital Management, LLC (hereinafter “ADAR1”, “we”, “us”, “our” or the “Firm”) is organized as a Texas limited liability company with a principal place of business in Austin, TX. ADAR1 serves as the investment adviser, with discretionary trading authority, to private, pooled investment vehicles. These include: ADAR1 Partners, LP, a Delaware limited partnership (the “Master Fund”), ADAR1 Partners (BVI), Ltd., a British Virgin Islands Business Company limited by shares (the “Offshore Fund”), and ADAR1 SPV I, LP, a Delaware limited partnership (the “SPV Fund”, and together with the Master Fund and the Offshore Fund, the “ADAR1 Funds”). “Limited Partners” and “Shareholders” of the applicable ADAR1 Fund are collectively referred to as the “Investors” where appropriate. ADAR1 Capital Management GP, LLC (the “General Partner”), a Texas limited liability company, serves as the general partner of the Master Fund and the SPV Fund and as an investment adviser to the Offshore Fund. Daniel Schneeberger is the sole owner of the General Partner. ADAR1 also acts as the sub-adviser/trading adviser to five sub-accounts of third-party sponsored pooled investment vehicles: Series ADAR1, a series of Spearhead Insurance Solutions IDF, LLC, a Delaware series limited liability company (the “IDF Fund”), Topwater Stonefly Fund LLC, a Delaware limited liability company which is structured as a first loss fund in which ADAR1 contributed first loss capital (the “First Loss Fund”), and three additional sub-accounts whose identities are subject to confidentiality restrictions under the applicable advisory agreements: one structured as a Cayman Islands exempted limited partnership, and two constituting separate segregated portfolios of a single Cayman Islands segregated portfolio company (the “Confidential Sub-Accounts”, and together with the First Loss Fund, the IDF Fund, and the ADAR1 Funds, the “Funds” or “Clients”). All of ADAR1’s Clients are pooled investment vehicles intended for institutional and other sophisticated investors. In January 2025, Daniel Schneeberger, the Manager of ADAR1, founded Central Therapeutics, LLC (“Central”) and currently holds the position as Manager. Daniel Schneeberger has an ownership stake of 100% of Central Therapeutics, LLC through SchneeCo, LLC, a family LLC which Daniel Schneeberger owns solely. SchneeCo, LLC owns 100% of Central. Central is an operating company (non-investment-related business) currently exploring work on two potential drug candidates, and at present, is incubating two sub-companies: West Immunology, Inc. and North Immunology, Inc. Please refer to Item 11 for more details on Central as it relates to ADAR1’s business. We do not generally tailor our advisory services to the individual needs of any particular investor in such pooled investment vehicles or accept investor-imposed investment restrictions. However, we have entered into agreements with certain Investors and Clients, including the First Loss Fund, the IDF Fund, and the Confidential Sub-Accounts, granting these Investors and Clients specific rights including, but not limited to imposing restrictions on investing in certain securities or certain types of securities. Certain Clients have different investment objectives and investment strategies from other Clients. Our investment decisions and advice with respect to each Client are made according to each Client’s investment objectives and guidelines, as set forth in its respective confidential -4-

offering memorandum and governing documents (collectively, “Offering Documents”) and, for the First Loss Fund, the IDF Fund, and the Confidential Sub-Accounts, the investment advisory agreements with the third-party sponsors of such pooled investment vehicles. With respect to the Confidential Sub-Accounts, ADAR1's discretionary investment authority is exercised subject to the supervision and direction of the applicable third-party sponsor, and pursuant to investment parameters and exposure limitations established by such sponsor in the applicable advisory agreement. This Brochure does not constitute an offer to sell, or solicitation of an offer to buy, any securities. The securities of the Funds are offered and sold on a private placement basis under exemptions promulgated under the Securities Act, and other exemptions of similar import under U.S. state laws and the laws of other jurisdictions where any offering may be made. In order to invest in an ADAR1 Fund and become a Limited Partner/Shareholder, a person must meet certain suitability standards and qualify as an accredited investor, within the meaning of Regulation D promulgated under the Securities Act of 1933, as amended (the “Securities Act”), a qualified client, as defined under Rule 205-3 of the Advisers Act, and a qualified purchaser, within the meaning of Section 2(a)(51) of the Investment Company Act of 1940, as amended (the “Company Act”) or a “knowledgeable employee” within the meaning of Rule 3c-5 under the Company Act. In addition, in order to invest in the Offshore Fund, non-U.S. investors must qualify as non-U.S. persons in accordance with Regulation S of the Securities Act and meet certain other conditions fully set forth in its Offering Documents. The Firm has entered into and may enter into “side letters” or similar agreements with certain investors that may waive or modify the application of, or grant special or more favorable rights with respect to the Offering Documents to the extent permitted by applicable law. We do not currently participate in any Wrap Fee Programs. As of December 31, 2025, ADAR1 manages $1,675,129,109 in regulatory assets under management on a fully discretionary basis. ADAR1 does not manage any of its clients’ assets on a non-discretionary basis.

The fees applicable to each of the Clients are set forth in detail in the corresponding Offering Documents. A brief summary of such fees is provided below. ADAR1 Funds: As a general matter, the Firm or an affiliate is paid an asset-based management fee and receives performance-based compensation (detailed in Item 6 below) with respect to the ADAR1 Funds. Management Fee The Firm is paid a monthly management fee equal to 0.125% (1.5% annually), payable in advance, of the net assets of Investors in the Master Fund and Offshore Fund (the “Management Fee”). The Management Fee is payable in advance based on the value of the assets as of the beginning of such calendar month. The Management Fee may be waived or reduced with respect to certain Investors in the discretion of the Firm. -5-

The SPV Fund is not subject to an asset-based management fee. Expenses Organizational Expenses. All expenses of the Offering and organization of the ADAR1 Funds (including legal and other expenses) (“Organizational Expenses”) will be paid by the ADAR1 Fund and/or reimbursed by the ADAR1 Funds to the extent paid by the Firm or the General Partner. The Organizational Expenses will be amortized and charged to the Investors’ capital accounts on a monthly basis over a period of five (5) years commencing from the launch of the ADAR1 Funds’ investment activities. GAAP requires that organizational costs be treated as an expense when incurred. The Firm believes that the impact on the ADAR1 Funds’ results from this departure from GAAP will result in a fairer apportionment of such expenses among Investors. This departure from GAAP may also result in a qualified audit opinion from the ADAR1 Funds’ auditors. If the ADAR1 Funds are terminated within five (5) years of the commencement of investment activities, any unamortized expenses will be recognized. ADAR1 Funds Expenses. The ADAR1 Funds pay (or reimburse the Firm or the General Partner) for all ordinary and reasonable operating and other expenses necessary for the ADAR1 Funds’ operations, including, but not limited to, investment- related expenses (e.g., exchange and brokerage commissions, exchange deposit and withdrawal fees, clearing and settlement charges, custodial fees, interest expenses, expenses relating to consultants, brokers or other professionals or advisors who provide research, advice or due diligence services with regard to investments, appraisal fees and expenses); research costs and expenses (including fees for news, quotation and similar information and pricing services); legal expenses (including, without limitation, the costs of on-going legal advice and services, blue sky filings and all costs and expenses related to or incurred in connection with the compliance obligations of the Firm or the General Partner under applicable federal and/or state securities and investment adviser laws arising out of its relationship to the ADAR1 Funds, as well as extraordinary legal expenses, such as those related to litigation or regulatory investigations or proceedings); the Management Fee; accounting fees and audit expenses; administrative fees; tax preparation expenses and any applicable tax liabilities (including transfer taxes and withholding taxes); other governmental charges or fees payable by the ADAR1 Funds; costs of printing and mailing reports and notices; and other similar expenses related to the ADAR1 Funds, as the Firm or the General Partner determines in its sole discretion. Firm and General Partner Expenses. ADAR1 and the General Partner will pay for their own administrative and overhead expenses incurred in connection with providing services to the ADAR1 Funds. These expenses include all expenses incurred by the Firm and the General Partner in providing for their normal operating overhead, including, but not limited to, the cost of providing relevant support and administrative services (e.g., employee compensation and benefits, rent, office equipment, insurance, utilities, telephone, secretarial and bookkeeping services, etc.), but not including any ADAR1 Fund operating expenses described above. First Loss Fund: No Asset-Based Management Fee ADAR1 does not charge any asset-based management fee to the First Loss Fund. Expenses

-6-

The First Loss Fund bears its own account trading expenses as set forth in ADAR1’s investment advisory agreement with the First Loss Fund. ADAR1 has sole liability for all expenses incurred by it, including, without limitation, salary, bonus and other payments to its personnel, overhead and any out-of-pocket expenses, in connection with its trading adviser duties under the investment advisory agreement. The First Loss Fund is also subject to a management fee and expense pass through charges payable to the third-party sponsor of the First Loss Fund. The First Loss Fund also bears its own operating expenses set forth in the Offering Documents. IDF Fund: Management Fee The Firm is paid a monthly management fee equal to 0.1667% (2.0% annually), payable in arrears, of the net assets of Investors in the IDF Fund (the “Subadvisor Management Fee”). The Subadvisor Management Fee is payable in arrears based on the value of the assets as of the end of such calendar month. Expenses The IDF Fund bears its own trading and other expenses as set forth in ADAR1’s sub-advisory agreement with the IDF Fund. ADAR1 bears its own ordinary overhead and administrative expenses arising out of its investment advisory duties under the investment advisory agreement. The IDF Fund is subject to a management fee and administration fee payable to the third-party sponsor of the IDF Fund. The IDF Fund also bears its own organizational expenses and operating expenses set forth in the Offering Documents. Confidential Sub-Accounts: Management Fee ADAR1 receives a management fee with respect to each Confidential Sub-Account at an annual rate equal to 1.5% of the applicable notional capital, calculated as of the beginning of each calendar month (the “Sub-Account Management Fee”). The Sub-Account Management Fee is prorated to reflect any mid-month changes to notional capital, other than adjustments resulting from net profits or net losses. Notional capital, for purposes of this fee, refers to the capital amount that ADAR1 is deemed to be managing for the benefit of each Confidential Sub-Account, which may exceed the cash and assets actually funded in the account. Expenses ADAR1 bears all of its own overhead expenses in connection with managing the Confidential Sub-Accounts, including compensation, rent, and other operating costs. Each Confidential Sub-Account bears its own account-level expenses, including brokerage commissions, financing costs associated with the notional funding structure, trading expenses, and other investment-related costs. Each Confidential Sub-Account also reimburses ADAR1 for its proportionate share of research expenses incurred on behalf of the account and other accounts managed by ADAR1 under a substantially similar strategy, allocated based on notional capital, and charged prior to the calculation of any performance-based compensation. Each Confidential Sub-Account is additionally subject to a general and administrative fee payable to the applicable third-party sponsor to offset certain expenses incurred in connection with maintaining the account, which may include administration, legal, audit, and other operational costs.

-7-

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 respective Offering Documents and, with respect to the First Loss Fund and the Confidential Sub-Accounts, the investment advisory agreements with each sponsor. 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. -9-

Unless otherwise noted, the investment objectives, investment strategies, types of investments, and risk factors described in this Item 8 with respect to the ADAR1 Funds and the IDF Fund apply in all material respects to the Confidential Sub-Accounts as well, given that each is managed pursuant to a substantially similar investment strategy on a pari passu basis. Certain descriptions may not apply in their entirety to the Confidential Sub-Accounts given the sub-advised nature of those relationships. ADAR1 Funds and IDF Fund: Investment Objective The primary investment objective of the ADAR1 Funds and the IDF Fund is to provide Investors with superior risk adjusted returns. The ADAR1 Funds (other than the SPV Fund) and the IDF Fund have an open investment mandate and will generally aim to deploy capital towards the most attractive opportunities in a given market environment. The SPV Fund plans to devote approximately twenty-five percent to forty percent (25%-40%) of its assets toward publicly-traded equity securities of a single biotechnology company, with the remaining assets of the SPV Fund devoted to a basket of other public securities in the biotechnology space. ADAR1 believes that the biotechnology space is one of the most attractive sectors for alpha generation, given its high volatility, high dispersion and presence of clinical and regulatory event-driven catalysts. As such, ADAR1 expects to allocate a significant share of investments to long and short opportunities in the healthcare/biotechnology space, albeit (except for the SPV Fund, as noted above) with no specific commitment to any particular gross or net exposure to the sector. Risks Associated with Investment in ADAR1 Funds and IDF Fund ADAR1 Funds and IDF Fund will be making sizeable bets on binary clinical events in the biotechnology sector and other special situations including by short selling, utilizing options and leverage. ADAR1 Funds and IDF Fund will employ a variety of risk management measures, such as diversification into non-correlated investments, hedging and position sizing to maximum expected loss (within an array of assumptions). However, no assurance can be given as to whether those risk management techniques will be effective in preventing a permanent loss of capital and as such, Investors are encouraged to limit their investment to a maximum of 10% of their net worth. Investment Strategy ADAR1 will focus and craft investment strategies in a variety of areas, including but not limited to: 1) long and short positions in domestic and international equities; 2) long and short positions in various indices and exchange-traded funds (ETFs) or futures designed to mirror the performance of a variety of assets, currencies and commodities; 3) long and short positions in investment grade and below investment grade debt; and 4) option strategies to maximize returns and limit risk. Each of these strategies is related but requires skill to analyze, manage, trade, and source. The Firm believes that inherent mispricing in certain securities in each of these areas, coupled with broad expertise and analytical abilities of the Firm, will allow the Firm to find investments with highly convex return profiles. ADAR1 will utilize the manager’s medical training and deep scientific due diligence process. For the ADAR1 Funds and IDF Fund, ADAR1 will aim to identify a set of catalysts (clinical trial readouts and regulatory events) that we can predict with a reasonably high degree of confidence. By doing -10-

so, ADAR1 aims to improve the chances of accurately predicting the price movement of the publicly traded company post-catalyst. ADAR1 Funds and IDF Fund will then try to structure an investment around that catalyst, by entering long or short positions in a company’s equity or debt and by purchasing or writing put or call options. In addition to catalyst-oriented investments, this process will be used to identify investments in the biotechnology space that we believe are being misvalued by market participants and that will re-rate over the medium- to long-term if future catalysts (e.g., interim clinical data readouts), commercialization of later-stage assets, and developments in earlier stage pipelines take place as we are underwriting. Types of Investments Long/Short Equities: ADAR1 Funds and IDF Fund will take long and short positions in publicly-traded equities that are over- or underpriced due to misunderstandings of a company’s fundamentals and business outlook, investor biases, spin offs/forced selling, restructurings/liquidations, stock promotions/manias or other events that caused a company’s valuation to materially deviate from its true fundamental value. Additionally, ADAR1 Funds and IDF Fund will pursue investments in biotechnology companies which are expected to undergo certain events that will catalyze a meaningful price movement, specifically clinical trial readouts. Long/Short ETFs. ADAR1 believes that the proliferation of ETFs allows for exposure to various return streams not generally available to smaller investors. Such return streams may include, but not limited to, volatility, commodities, and foreign indices. The Firm believes that investments in such securities, or pairing such securities with existing investments to reduce volatility as appropriate or managing net exposure to a given sector or market, can be a profitable tactic and risk management tool. Long/Short Credit: In this portion of the portfolio, ADAR1 Funds and IDF Fund will take either a long or short position in the bonds, bank debt, privately placed debt, preferred stock, credit default swaps, or other debt related instruments of a company where the market has fundamentally mispriced such securities. The mispricing is typically caused either by investors focusing on a bad event while disregarding a company’s strengths, or by investors ignoring problems in a company’s business model. Option Strategies: This portion of the ADAR1 Funds and IDF Fund portfolios will involve supplementing the long/short equities strategy by maximizing potential returns while mitigating risk when necessary. The option strategies utilized may include, but are not limited to, protective puts, naked puts, covered calls, naked calls, various spread options and long calls/puts, depending on the time horizon and confidence level in an effort to achieve high risk-adjusted returns. For example, naked put options will be implemented to build a position in a security at prices below the prevailing market price in order to mitigate downside risk while generating modest premiums in the short-term. In the event of a fundamental mispricing of a security, the Firm may utilize long calls or puts to leverage potential returns, especially in the presence of an impending event-driven catalyst. ADAR1 Fund Investments The assets of the ADAR1 Funds and IDF Fund may be invested and traded in a broad variety of securities and other instruments, whether traded on exchanges, over-the counter or negotiated on electronic markets. The Firm has broad and flexible investment authority over the ADAR1 Funds and IDF Fund. Accordingly, the investments of the ADAR1 Funds and IDF Fund may at any time include, without limitation, long and short positions, whether in domestic or emerging markets, equity securities -11-

and options on equities, exchange-traded funds and exchange-traded notes; small- and microcapitalization securities; convertible securities; “new issues”; off-exchange retail foreign currency contracts; privately held debt and equities; financial futures, commodity futures and options thereon and swaps and other derivatives. ADAR1 Funds and IDF Fund may periodically maintain all or a portion of their assets in money market instruments and other cash equivalents and may not be fully invested at all times. Distributions and Reinvestment ADAR1 Funds and IDF Fund do not expect to make any dividend payments or other distributions to Investors out of the Fund’s earnings and profits, but rather expects that such income will be reinvested. Potential Investors should keep this limitation in mind when determining whether or not an investment in the ADAR1 Funds or IDF Fund is suitable for their particular purposes. The Firm and the General Partner reserves the right to change such policy. Plan of Distribution and Use of Proceeds; Cash Equivalents Interests will be offered through private placement to a variety of sophisticated investors. See “Qualification of Investors.” The net proceeds of the private offering contemplated herein will be invested in accordance with the policies set forth under “Investment Objective and Strategy.” The ADAR1 Funds and IDF Fund may hold cash or invest in cash equivalents for short-term investments. Among the cash equivalents in which ADAR1 Funds and IDF Fund may invest are obligations of the U.S. Government, its agencies or instrumentalities (e.g., U.S. Government Securities; U.S. Treasury Bills), commercial paper and repurchase agreements, money market mutual funds, certificates of deposit and bankers’ acceptances issued by domestic branches of U.S. banks that are members of the Federal Deposit Insurance Corporation. In the event the Firm determines that there is not sufficiently good value in any investments suitable for capital of the ADAR1 Funds and IDF Fund, all such capital may be held in cash and cash equivalents. Borrowing and Lending ADAR1 may utilize leverage on behalf of the ADAR1 Funds and IDF Fund including, without limitation, borrowing cash and entering into derivative transactions that have the effect of leveraging the portfolio of the ADAR1 Funds and IDF Fund. The use of leverage may, in certain circumstances, maximize the adverse impact to which the ADAR1 Fund’s and IDF Fund’s investment portfolio may be subject. ADAR1 Funds and IDF Fund may also engage in securities lending transactions. ADAR1 Funds and IDF Fund are permitted to borrow for purposes of providing liquidity to fund withdrawals by Investors and/or for investment purposes, subject to regulatory requirements, and for the payment of fees, expenses and other short-term obligations. Loans with respect to the ADAR1 Funds and IDF Fund generally may be obtained from securities brokers and dealers or from other financial institutions or third-party lenders; such loans will be secured by securities or other capital of the ADAR1 Funds and IDF Fund, as the case may be, pledged to such brokers, financial institutions or third- party lenders. In the event the ADAR1 Funds or IDF Fund obtains a credit facility, ADAR1’s investment discretion may be subject to certain limitations prior to and/or following an event of default. For example, pursuant to the terms of the credit facility, the ADAR1 Funds and IDF Fund may have to abide by certain formulas, or the ADAR1 Funds and IDF Fund may have to obtain the lender’s consent to engage in some or all transactions while the credit facility is outstanding. After the occurrence of an event of default (whether because of nonpayment or otherwise), it is likely that, among other consequences, the lender would assume total control of the ADAR1 Funds and IDF Fund assets and/or trading activities and no distributions could be made or withdrawals effected without the lender’s consent.

-12-

Read the rest in the brochure

Our Clients are the ADAR1 Funds, the IDF Fund, the First Loss Fund, and the Confidential SubAccounts, as described in Item 4 above. The ADAR1 Funds are generally open to, among others, institutions, pension plans, endowments, fund of funds, high net-worth individuals, financially sophisticated individuals, and other sophisticated investors. Interests in the IDF Fund are offered only to Insurance Companies on behalf of certain of their Separate Accounts that fund Variable Contracts under Section 817(d) of the U.S. Internal Revenue Code of 1986, as amended. The First Loss Fund and the Confidential Sub-Accounts are each sponsored by unaffiliated third parties and are offered to investors pursuant to their respective offering documents and governing agreements.

Master Fund and Offshore Fund: An investment in the Master Fund and Offshore Fund is also subject to an annual performance allocation equal to twenty percent (20%) of an investor’s ratable share of the Master Fund’s and Offshore Fund’s net capital appreciation for such calendar year, provided that such profits exceed such investor’s “high water mark” (the “Performance Allocation”). The Performance Allocation is made to 9 Brains, LP, a Delaware limited partnership and an affiliate of the General Partner (the “Special Limited Partner”). Daniel Schneeberger is the sole limited partner of 9 Brains, LP. The Performance Allocation may be waived or reduced with respect to certain Investors in the discretion of the General Partner. Performance-based allocation arrangements may create an incentive for us to recommend investments which may be riskier or more speculative than those which we would recommend under a different arrangement. SPV Fund: Distributions from the SPV are split eighty five percent (85%) to such Limited Partner and fifteen percent (15%) to Blue Blood, LP, a Delaware limited partnership and an affiliate of the General Partner (the “SPV Special Limited Partner”), but only after (i) the return of capital contributions to Limited Partners, (ii) 8% preferred return, and (iii) a 50/50 catchup until the cumulative amount distributed to the Special Limited Partner is equal to fifteen percent (15%) of the aggregate amounts distributed to such Limited Partner pursuant to clauses (ii) and (iii). Daniel Schneeberger is the sole limited partner of Blue Blood, LP. First Loss Fund: ADAR1 contributed 10% of the total capital of the First Loss Fund as “first loss” capital. Under this structure, the first 10% of losses of such First Loss Funds will be specially allocable to ADAR1. In return for this enhanced risk, ADAR1 receives a higher percentage of performancebased compensation than in other Client structures. ADAR1 is paid a monthly performance fee in an amount equal to 50% of the net investment gains for such month, after investment losses of ADAR1’s “first loss” capital and regular investor’s investment losses have been recouped. IDF Fund: ADAR1 is entitled to receive from the IDF Fund a performance fee equal to 30% of an investor’s ratable share of the IDF Fund’s net capital appreciation determined and paid upon certain triggering events (defined below). A triggering event is (i) the withdrawal of the investor in the IDF Fund, (ii) the replacement of Daniel Schneeberger as the Principal of ADAR1, or (iii) the ten (10) year anniversary of the investor’s investment in the IDF Fund. Performance-based fee arrangements may create an incentive for us to recommend investments which may be riskier or more speculative than those which we would recommend under a different arrangement. Confidential Sub-Accounts: ADAR1 is entitled to receive from each Confidential Sub-Account a performance fee equal to 20% of new net profits for each annual performance calculation period (generally, each calendar year ending December 31). New net profits are calculated as the aggregate of net -8-

profits and net losses for each monthly accounting period within the applicable performance calculation period, reduced by any loss carryforward. Side-by-Side Management ADAR1 currently manages multiple client accounts with different fee arrangements. The ADAR1 Funds (other than the SPV Fund), the IDF Fund, and the Confidential Sub-Accounts are generally managed pursuant to a substantially similar investment strategy on a pari passu basis, with each subject to different fee structures. The ADAR1 Funds and IDF Fund are subject to performance allocations calculated on net asset value, while the Confidential Sub-Accounts are subject to a performance fee calculated on notional capital. The SPV Fund and the First Loss Fund are managed pursuant to separate and distinct investment strategies and are not managed on a pari passu basis with the foregoing accounts. These differing fee arrangements could create an incentive for ADAR1 to favor accounts with higher performance-based compensation potential. To mitigate this conflict with respect to the pari passu sleeve, ADAR1 is contractually required under the applicable advisory agreements to manage the Confidential Sub-Accounts proportionally to their respective notional capital relative to the ADAR1 Funds. ADAR1 allocates trades among all client accounts in accordance with its Written Compliance Program, which is designed to ensure equitable treatment across clients. Performance-based fee arrangements may create an incentive for ADAR1 to recommend investments that are riskier or more speculative than those it would recommend under a different fee arrangement.

Neither we nor our management persons are registered as broker-dealers, and neither of us has any application pending to register with the SEC as a broker-dealer or registered representative of a broker-dealer, respectively.

Code of Ethics ADAR1 has adopted a “Code of Ethics” that establishes the high standard of conduct that we expect of our employees and procedures regarding our employees’ personal trading of securities. Our employees are required to certify their adherence to the terms set forth in the Code of Ethics 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 of Ethics is based upon the following underlying fiduciary principles: • • •

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

Employees are generally not permitted to trade in single name stocks / derivatives within the healthcare and biotech sectors, except in limited situations contemplated by the Code of Ethics, subject to review and prior approval by the CCO. Employees are required to obtain approval from CCO prior to participating in Initial Public Offerings (“IPOs”). Employees are prohibited from personally, or on behalf of a Client, purchasing or selling securities that appear on the Firm’s Restricted List. Employees must obtain pre-approval from the CCO before: (i) engaging in any outside business activities; (ii) making any private investments; or (iii) making political contributions. We will provide a copy of our Code of Ethics to our Investors, or any prospective investor, upon request, to be viewed on the premises. Participation or Interest in Client Transactions From time to time, ADAR1 or its related persons may recommend or cause Client accounts to invest in securities in which the Adviser or its affiliates have a financial interest. Such transactions may include “principal transactions,” where ADAR1, its control persons, or

-33-

affiliates act as principal for their own accounts and sell securities to, or purchase securities from, a Client account. In September 2025, certain Clients advised by ADAR1 (including Master Fund and IDF Fund) participated in a principal transaction involving two privately held biotechnology companies, North Immunology, Inc. and West Immunology, Inc. (together, the “Target Companies”). The Target Companies are controlled through entities owned by ADAR1’s principal and affiliates (collectively, the “ADAR1 Affiliates”). Accordingly, these investments constituted transactions in which the ADAR1 and its related persons had a material financial interest. ADAR1 recognized that these transactions presented potential and actual conflicts of interest, including that: • • •

the ADAR1 affiliates and certain ADAR1 personnel held ownership or economic interests in the Target companies through equity or reimbursement arrangements; ADAR1 and its affiliates could receive repayment of expenses and potential royalty or other payments from the Target Companies; and ADAR1, its principal, and related persons had an incentive to recommend participation in the investment

To address these conflicts of interest, ADAR1 implemented a documented review and consent process prior to completing the transaction. Specifically, ADAR1: 1. Reviewed governing documents (including advisory and sub-advisory agreements and side letters) and internal compliance policies to identify any notice or consent requirements. 2. Prepared and distributed a written Notice and Information Memorandum to affected investors describing the structure of the investment, the affiliated relationships between the ADAR1 and the Target Companies, the financial interests of related persons, and the risks associated with the transaction. 3. Provided sufficient information for investors to evaluate the valuation and proposed terms of the transaction, including the anticipated investment size, SAFE financing terms, and allocation mechanics. 4. Delivered an Election Form allowing each investor to (a) participate up to a pro-rata amount, (b) increase participation through an additional capital contribution, or (c) decline participation entirely. Investors who did not return the form were deemed not to participate. 5. Obtained affirmative written consent from each participating investor prior to execution of the transaction. No investor was required to participate, and ADAR1’s affiliated investment was made on substantially the same terms as those offered to participating clients. Participating clients were not charged a performance allocation on any profits attributable to the investment, although the investment remained subject to the applicable management fee based on fair value. ADAR1 maintains policies and procedures designed to identify, disclose, and manage conflicts of interest and to ensure that any transaction involving ADAR1 or its related persons is -34-

effected in compliance with applicable law and consistent with ADAR1’s fiduciary duty to its clients.

ADAR1 is authorized to determine the broker-dealer to be used for executing securities transactions for the 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 most favorable pricing. The Funds’ securities and other assets are held in securities accounts at our prime brokers that are “Qualified Custodians” (as defined in the Advisers Act) or, for certain privately offered securities or assets, in accordance with the Custody Rule under the Advisers Act. Best Execution In selecting an appropriate broker-dealer (including prime brokers) to execute transactions, we seek to obtain “Best Execution,” meaning we will execute transactions in a manner most favorable and beneficial to our Clients under the circumstances. ADAR1 considers many factors in determining whether it obtains Best Execution, only one of which is actual commission rate or price paid or received. Best execution is qualitative, and not quantitative, and ADAR1 will weigh a combination of criteria to determine whether the transaction in question represents the best “qualitative” execution for the Client. The General Partner has discretion to execute trades, select broker-dealers and negotiate commissions. In selecting broker-dealers, the General Partner seeks those brokerdealers who can provide best execution of transactions under the circumstances. The principal factors determining this selection are: (1) a broker’s ability to execute the types of transactions occurring in client accounts; (2) the net prices for such transactions; and, (3) trading ideas generated by brokers. “Best execution” is not synonymous with lowest brokerage commission. Consequently, in a particular transaction the Firm may pay a brokerage commission in excess of that which another broker might have charged for executing the same transaction. With respect to the First Loss Fund and the Confidential Sub-Accounts, ADAR1’s broker selection authority is subject to certain constraints established by the applicable thirdparty sponsor. Prime broker accounts for the First Loss Fund and the Confidential SubAccounts are maintained with prime brokerage firms approved by the applicable thirdparty sponsor and all assets attributable to these Clients are held and settled through such approved prime brokers. While ADAR1 retains discretion to select executing brokers for transaction execution, such executing brokers may not maintain custody of any assets attributable to the Confidential Sub-Accounts. Generally, neither ADAR1 nor any Client separately compensates any broker or dealer for any of these other services. ADAR1’s “Best Execution Policy” requires that all trades are executed through approved broker-dealers and that the Firm reviews the performance of its broker-dealers to evaluate whether the Firm is obtaining Best Execution for its Clients’ trades.

-35-

ADAR1 maintains policies and procedures to review the quality of executions, including periodic reviews by its trading and investment professionals. Soft Dollars The Funds may enter into one or more “soft dollar” arrangements with brokers that execute trades for the Fund’s account. Under these “soft dollar” arrangements, the broker would provide certain products and services (or arrange for and pay third parties to provide such products and services) based upon the volume of commissions generated by the Firm’s trading activities. Subject to the Firm’s duty to obtain best execution, these arrangements may not result in the execution of trades at the lowest available commission rates. As a result of these arrangements, the Firm may pay higher commissions than would be the case in the absence of such arrangements. In the event the Firm generates “soft dollars” with respect to trades, the Firm shall comply with the safe harbor of Section 28(e) of the Securities Exchange Act of 1934, as amended. In all events, the Firm will always seek to obtain best execution for the Firm’s portfolio transactions.

-36-

We do not receive economic benefits from non-clients for providing investment advice and other advisory services. Neither we nor any of our related persons, directly or indirectly, compensate any person who is not a supervised person for client referrals.

-32-

To the best of our knowledge, there are no 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.

Our Principal and investment professionals monitor and analyze the transactions, positions, and investment levels of the Master Fund, the IDF Fund, and the SPV Fund to ensure that they conform with the investment objectives and guidelines that are stated in the Offering 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. Account Reporting We perform various periodic reviews of each Client’s portfolio. Such reviews are conducted by our officers. We will distribute an audited financial report with respect to the previous fiscal year to all investors in ADAR1 Funds within 120 days of fiscal year end. We may also distribute quarterly unaudited net asset value statements, quarter-end performance reports, and a quarterly investor letter to all Investors. The IDF Fund and its investment manager receives such reports as are set forth in ADAR1’s subadvisory agreement with the IDF Fund. The First Loss Fund receives such reports as are set forth in ADAR1’s investment advisory agreement with the First Loss Fund. The applicable third-party sponsor of each Confidential Sub-Account receives such reports as are set forth in ADAR1's portfolio management agreement with such sponsor.

We will be deemed to have custody of the assets of the ADAR1 Funds because we have the authority to obtain funds or securities, for example, by deducting advisory fees from the ADAR1 Funds’ accounts or otherwise withdrawing funds from the account. Account statements related to the Clients are sent by qualified custodians to ADAR1. We will comply with Rule 206(4)-2 of the Investment Advisers Act of 1940, as amended (the “Advisers Act”) (i.e., the “custody rule”) by meeting the conditions of the pooled vehicle annual audit approach. Upon completion of the relevant ADAR1 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 ADAR1 Fund’s audited financials to Investors within 120 days of such ADAR1 Fund’s fiscal year end.

We will have full discretionary investment authority with respect to the ADAR1 Funds and the IDF Fund, including authority to make decisions with respect to which securities to be bought and sold, as well as the amount and price of those securities. The investment strategy, guidelines and positions for the First Loss Fund differ in certain respects from those of the ADAR1 Funds, such as with respect to concentration, market capitalization, permitted jurisdictions, trading volume, net exposure levels and liquidity (including with respect to private investments), as set forth in the investment advisory agreement with the First Loss Fund. With respect to the Confidential Sub-Accounts, ADAR1 exercises discretionary investment authority subject to investment parameters and exposure limitations established by the applicable third-party sponsor in the applicable advisory agreements.

In compliance with the Advisers Act’s Proxy Voting Rule, we have adopted proxy voting policies and procedures. The Firm will comply with the Proxy Voting Rule and will act solely in the best interests of its Clients when exercising its proxy voting authority. The Firm determines whether and how to vote proxies on a case-by-case basis, and will vote proxies that are important to the investment strategies of the Clients overall and in particular with respect to the specific company, follow management's recommendations in other situations or may not vote a proxy when such company is not a material position in the Client's portfolio, and vote in a manner that it believes is consistent with the Client’s stated objectives.

-37-

We are not required to include a balance sheet for our most recent fiscal year, are not aware of any financial condition reasonably likely to impair our ability to meet contractual commitments to Clients, and have not been the subject of a bankruptcy petition at any time during the past ten years.

-38-