AHL PARTNERS LLP

General Description of Advisory Firm

AHL Partners LLP (the “Investment Manager”) is a limited liability partnership which was incorporated in England and Wales in 2012 with its principal place of business in London, England.1 AHL Partners LLP is authorized and regulated by the Financial Conduct Authority in the United Kingdom, and primarily offers investment advisory or sub advisory services to pooled investment vehicles, commodity pools, registered investment companies, including mutual funds and exchange traded funds, registered under the Investment Company Act of 1940, as amended (“Investment Company Act”) and institutional managed accounts on a discretionary basis. AHL Partners LLP provides discretionary investment advice and/or management services according to the stated investment objectives, restrictions and policies of each client. The managing member of AHL Partners LLP is Man Investments Limited which is ultimately owned by Man Group plc, which is listed on the London Stock Exchange and is a component of the FTSE 250 Index. Man Group plc, through its investment management subsidiaries (collectively, "Man"), is a global alternative investment management business and provides a range of fund products and investment management services for institutional and private investors globally. AHL Partners LLP is part of Man’s Systematic division. As of March 31, 2026, Man had approximately $228.7 billion of assets under management.2 The Firm is doing business as Man Group which represents the marketing name of the Firm. AHL Partners LLP has full discretionary advisory investment management authority with respect to investment decisions for U.S. and non-U.S. pooled investment vehicles, including private funds and commodity pools and managed accounts. AHL Partners LLP also provides and receives sub-advisory services in connection with certain pooled investment vehicles including affiliated private funds (collectively with the private funds and commodity pools, (the “Funds”). AHL Partner LLP’s advice with respect to the Funds is provided in accordance with the investment objectives and guidelines as set forth in the applicable Fund's governing documentation or the managed account's investment management agreement. AHL Partners LLP may manage a Fund’s assets through separately managed portfolios or through investments in other pooled investment vehicles, which may include pooled investment vehicles managed by AHL Partners LLP. An affiliate of AHL Partners LLP may act as general partner or managing member of such Funds. Proprietary assets of AHL Partners LLP or its affiliates may also be directly or indirectly invested in the Funds. “Funds” include one or more funds that AHL Partners LLP, its affiliates or employees3

The business of AHL Partners LLP was founded in 1987.

Man assets under management as stated in the Man Group plc Annual Report include advisory-only assets where Man Group provides model portfolios but does not have decision making or trading authority over the assets and dedicated managed account platform services for which Man provides platform and risk management services but does not provide investment management services. “Employee(s)” for purposes of this Brochure includes personnel, partners, officers, directors (other than nonexecutive directors of Man Group plc) and other persons with similar status or performing similar functions.

have seeded or invested over 25% of the capital of such Funds. Important information regarding each Fund and managed account, which includes investment objectives, risks, strategy, fees and other material information, including applicable conflicts of interest is contained in each Fund’s governing documents and in each managed account's investment management agreement, as the case may be. In addition, AHL Partners LLP provides model portfolio recommendation services through separately managed model portfolio arrangements in accordance with client investment guidelines and restrictions as detailed in such client's investment management agreement. AHL Partners LLP does not have decision making or trading authority for such model portfolio recommendation services. As used herein, the term "client" generally refers to each Fund and each beneficial owner of a managed account. From time to time, certain affiliated advisory firms may be considered “Participating Affiliates” of AHL Partners LLP (as that term is used in relief granted by the staff of the Securities and Exchange Commission (“SEC”)) allowing investment advisers registered with the SEC to use portfolio management, research, operations, and trading resources of advisory affiliates and personnel subject to the supervision of an SEC-registered adviser. Professionals from such Participating Affiliates from time to time render portfolio management, research, trading or other related services to AHL Partners LLP clients and/or AHL Partners LLP as affiliated “associated persons” of AHL Partners LLP and are subject to supervision by AHL Partners LLP. In addition, AHL Partners LLP provides portfolio management, research, trading or other related services to the Participating Affiliates under separate services agreements. Fees are allocated to the parties under these arrangements. AHL Partners LLP complies with applicable U.S. securities regulations only with respect to its U.S. clients. Man provides a number of centralized functions to AHL Partners LLP, which includes trading, financing and cash management, risk management, operations, middle office accounting, finance, proxy voting, class actions, human resources, facilities, tax, legal, compliance, operational risk, business continuity, information, security, information technology, among other such services. AHL Partners LLP utilizes portfolio analysis, investment management, investment models, research, data, client servicing, trading, sales and marketing capabilities of its affiliates in providing services to its clients. In addition, AHL’s affiliates may utilize certain of AHL’s investment management, investment models, research, data and trading services in providing services to their clients. In some cases, certain of AHL Partners LLP’s investment personnel provide investment management services and research to clients of AHL Partners LLP as well as clients of one or more of its affiliates. B.

Description of Advisory Services

Please see Item 8 herein.

This Brochure generally includes information about AHL Partners L L P and its relationships with its clients and affiliates. While much of this Brochure applies to all such clients and affiliates, certain information included herein applies to specific clients or affiliates only. Important information regarding each fund and managed account, which includes investment objectives, risks, strategy, fees and other material information, including applicable conflicts of interest regarding relationships with affiliates, is contained in each fund’s governing documents and in each managed account's investment management agreement, as the case may be. C.

Availability of Customized Services for Individual Clients

AHL Partners LLP’s investment decisions and advice with respect to each Fund are subject to the relevant Fund's investment objectives and guidelines, as set forth in its governing documents. Similarly, AHL Partners LLP’s investment decisions and advice with respect to each managed account are subject to each client's investment objectives and guidelines, as set forth in the client's investment management agreement/trading advisor agreement, as well as any written instructions provided by the client to AHL Partners LLP. Certain Funds issue multiple classes, sub-classes, tranches, sub-tranches and/or series (or subseries) of shares or interests, as applicable, in the future (or enter into "side letter" agreements with certain investor(s) that alter, modify or change the terms of the shares or interests, as applicable, held by the investor(s)), which differ and could be more favourable from the shares or interests, as applicable, currently offered by the Fund in terms of, among other things, performance compensation, management fee, redemption rights (including redemption dates and notice periods), currency denomination, minimum and additional subscription amounts, informational rights and other rights. New classes, sub-classes, tranches, sub-tranches and/or series (or sub-series) of shares or interests, as applicable, may be issued (or "side letter" agreements may be entered into) by a Fund's board of directors and/or managing member, in its sole discretion, on behalf of the Fund, in consultation with AHL Partners LLP, without providing prior notice to, or receiving consent from, existing investors. The terms of such classes, sub- classes, tranches, sub-tranches and/or series (or sub-series) or "side letter" agreements will be determined by the board of directors and/or managing members, in its sole discretion, in consultation with AHL Partners LLP. In general, a Fund will not be required to notify investors upon entering into "side letter" agreements, nor will a Fund be required to offer such additional and/or different rights and/or terms to any or all of the other investors. D.

Wrap Fee Programs

AHL Partners LLP does not participate in wrap fee programs E.

Assets Under Management

AHL Partners LLP manages approximately $68.0 billion in regulatory assets under management on a discretionary basis as of March 31, 2026.

A fee schedule is omitted because this Brochure is being delivered only to qualified purchasers, as defined in section 2(a)(51)(A) of the Investment Company Act. AHL Partners LLP does not maintain a basic fee schedule. The following is a general overview of the types of fees AHL Partners LLP charges its clients: A.

Advisory Fees and Compensation

AHL Partners LLP does not have a standardized fee schedule. For those private funds as disclosed herein AHL Partners LLP generally receives an annual management fee of up to 2% of a Fund's assets under management, payable monthly in arrears. AHL Partners LLP may receive incentive or performance-based compensation generally up to 20% of net profits, realized and unrealized and in some cases subject to a “high water mark”, generally payable annually in arrears. As applicable, AHL Partners LLP performance-based compensation complies with SEC Rule 205-3 under the Investment Advisers Act of 1940 (the “Advisers Act”). Fees charged to the Funds are fully described in the respective Funds’ governing documents. Affiliated exchange traded funds (“ETFs”) pay a unitary advisory fee to AHL’s affiliate which serves as the investment adviser to cover all expenses of the ETF including AHL’s management fee, but excluding interest expenses, acquired fund fees and expenses, taxes, trading fees, brokerage expenses, distribution fees or expenses (if any), litigation expenses and other non-routine or extraordinary expenses, as further described in the ETF’s Prospectus and Statement of Additional Information. Certain UCITS funds pay an administration fee to the non-US based manager of the UCITS funds which is an affiliate of AHL Partners LLP of up to 0.30% per annum of average net asset value payable monthly in arrears. The administration fee is used to pay the services of the administrator and administrative services of the manager as further described in the UCITS funds’ prospectus. Certain Funds also charge their investors a services management fee on a monthly basis which generally ranges from .06% to .15% per annum of the Fund’s assets under management with a minimum charge of USD 20,000 per annum which is paid to an affiliate for their services with regards to the selection and appointment of service providers to the Funds. The Funds have different share classes which may have different fee schedules. Certain non-US share classes of certain Funds may be subject to distribution fees of approximately .50% per annum of the net asset value. AHL Partners LLP reserves the right to charge a discounted management fee or performance-based fee in its sole discretion as well as provide rebates on part or all of its fees to some or all investors or to intermediaries. Schedules of fees and performance-based fees are set forth in the governing documents for each of the Funds, which should be consulted by any prospective investor to determine the applicable level of fees or allocations, when fees are paid, and any conditions on redemptions from the Funds.

AHL Partners LLP’s compensation may be negotiable and AHL Partners LLP may, in its sole discretion, elect to waive or modify any compensation with respect to any investor, without entitling any other investor to a waiver or modification. AHL Partners LLP’s fees and compensation will be shared from time to time with its affiliates. AHL Partners LLP may also invest client or Fund assets in investments that charge additional fees or are subject to additional allocations (including other Funds advised by AHL Partners LLP or its affiliates ("Affiliated Funds")). Clients or investors may therefore indirectly bear (i) advisory fees or an allocation (including management, performance, administrative, or other fees or a performance allocation) to AHL Partners LLP or its affiliates and (ii) fees charged by the underlying investment. Investments that charge additional fees may include, but are not limited to, money market funds, short-term investment vehicles, exchange traded funds, pooled investment vehicles, special purpose investment vehicles and alternative investment vehicles. If a client or Fund invests in any Affiliated Fund, the performance compensation and management fee otherwise payable to AHL Partners LLP or its affiliate at the Affiliated Fund level will generally be waived by such Affiliated Fund. The administrative fee (if any) will generally not be waived. Generally, the investment management agreements with clients may be terminated by either party in accordance with the terms and notice period described in each investment management agreement. AHL Partners LLP’s investment management agreements are generally terminable with prior written notice, without penalty, or upon a breach, and/or also may be automatically renewed. B.

Payment of Fees

Fees and compensation paid to AHL Partners LLP or its affiliates by the Funds are generally paid by the Fund from its assets. With regards to the Funds, the fees are calculated by the Fund’s administrator and are paid directly from the Fund’s assets. Management fees are generally paid on a monthly basis in arrears, services management fees are generally paid on a monthly basis in arrears, and the performance compensation is generally deducted on an annual basis, or at the time of a redemption or withdrawal, as applicable, further described in the Fund’s governing documents or managed account’s investment management agreement. With regards to managed accounts, fees are negotiated and agreed upon with the client directly and may include a management fee or a combination of management fee and performance compensation. Management fees and performance-based compensation may be pro-rated for partial periods. Generally, AHL Partners LLP does not require prepayment of fees unless otherwise permitted under such client documentation. If prepayment were provided for, AHL Partners LLP would rebate a proportionate amount of the prepaid fees to the applicable client, in the event of a termination of its investment management services. AHL Partner LLP’s employees may invest in one or more Funds. AHL Partner LLP’s employees may or may not be subject to a management fee and performance-based compensation by these Funds. In addition, AHL Partner LLP’s employee investments may or may not be subject to the same liquidity terms or fees as those of other investors in such funds.

C.

Additional Fees and Expenses

Not all of AHL Partners LLP’s Fund investors bear all of the expenses set forth below and, in some cases, will bear additional expenses not included herein. In addition to the asset-based and as applicable performance-based compensation described above, each AHL Partners LLP’s Fund investor generally bears the following expenses: operating and other expenses and its pro rata portion of the Fund’s expenses and as applicable master fund expenses, including, but not limited to 1.

2.

3.

4.

all fees and expenses incurred in connection with evaluating, acquiring, holding, managing and/or disposing of investments (whether consummated or not) including, without limitation: brokerage commissions and other transaction charges, clearing and settlement charges, custodial fees and expenses, interest expenses, fees and expenses incurred in any borrowing or lending of securities, any costs of acquiring or maintaining financing for the Fund, any costs of margin lending arrangements and/or implicit in any repurchase or reverse repurchase agreements; currency hedging costs (which may be related to, among other things, one or of both of hedging currency exposures related to investments of the Fund, as well as hedging the various currency exposures of the various share and/or currency classes and/or tranches of the Fund); legal costs relating to the review, negotiation, closing and/or settlement of potential and actual transactions, as applicable, as well as legal research costs and investment-related litigation expenses, consulting, investment banking and any other professional fees or compensation relating to actual or contemplated investments (including, without limitation, such fees and expenses for contemplated investments that the Fund and/or the Investment Manager elect ultimately not to acquire for the Fund); and fees and expenses related to the engagement of any service providers to the Investment Manager and its affiliates or any other trading vehicle incurred in the course of operating assets in which the Fund invests; all research-related expenses (to the extent permitted by applicable law), including expenses associated with obtaining transactional, risk, market, reference, consumer and/or industry data and information, as well as other alternative data (including news and quotation equipment and services), fees due to data, data aggregation and software providers, fees due to exchanges, fees due to other third-party data and information vendors, including those required for access to subscription-based networks that allow investors, such as the Fund, to connect with other experts in the investment fund industry, fees associated with other non-traditional data and information sources, trade ideas and/or alpha capture and fees for academic research data, (all such data and information collectively, “Data”); all fees and expenses paid to the Fund’s service providers including, without limitation, fees and expenses paid to the Services Manager; the Custodian and any brokers; the Funds auditor; fees and expenses relating to third-party valuation services; any fees and expenses of the Partnership Representative, if applicable; any accounting, audit, tax and/or tax-related preparation, tax-related advisory and administrative service fees and expenses; and Directors’ fees and expenses, if applicable; all fees and expenses related to the ongoing operation of the Fund, including, without limitation: those incurred in or connected to: the preparation and distribution of

5.

Shareholder reports; exercising voting rights held by the Fund and participating in any associated class-action or similar litigation, including fees and expenses relating to the engagement of consultants, third-party proxy voting services or other vendors to assist with such proxy voting or the filing of any class-action or similar notices on behalf of the Fund as well as any contingency fees or similar compensation payable to the classaction lawyers, administrator or similar service provider; legal and compliance, including responding to or otherwise addressing any formal or informal inquiries, subpoenas, investigations or other information requests of any type, whether addressed to the Fund or to the Investment Manager in relation to the Fund’s activities or the Investment Manager’s activities on the Fund’s behalf; indemnification obligations; any threatened, pending or anticipated litigation; regulatory filings and/or reporting requirements relating to the Fund and/or its investments; insurance, including, if applicable, a reasonably allocated portion of the premiums for any directors’ and officers’, errors and omissions, cybersecurity or other coverage purchased by the Investment Manager that would offset a portion of the Fund’s indemnity obligations; ERISA bonding, if applicable; the offer and sale of the Shares; preparing, monitoring, analysing and managing the Fund’s tax and administrative reports and other documentation, including but not limited to those relating to the Automatic Exchange of Information, FATCA and tax withholding; taxes and other governmental charges attributable to the Fund, as determined by the Investment Manager; governmental, registration, license and membership fees and expenses, including those payable to regulatory and self-regulatory organizations, as well as for corporate licensing and for maintenance of the Fund’s registered office; the provision of Fund secretarial services; clearing fees, registration fees and other expenses due to regulatory, supervisory or fiscal authorities based outside of the Fund’s home jurisdiction; liquidation costs; promotional and marketing fees and expenses; routine operating fees and expenses, including fees and expenses associated with office maintenance, printing, filing, information technology, risk management systems, software, hardware and general administration; and all other fees, expenses and liabilities incurred in connection with or arising out of the Fund’s business, including those that are extraordinary or non-recurring; reimbursements due to the Investment Manager for all such fees, expenses and liabilities borne by the Investment Manager (and/or its affiliates) on behalf of the Fund or any related entity; and the Fund’s pro rata share of such fees, expenses and liabilities listed in paragraphs 1 to 5 above incurred by any trading vehicle through which the Fund invests.

AHL Partners LLP may, in the absolute discretion of the directors, also bear expenses, the cost of which may vary, incurred with respect to addressing the legal, tax and/or regulatory requirements of a particular class or series of shares or individual shareholders. Allocation of Expenses A Fund or managed account may incur an expense which forms part of a larger aggregate expense relating to a number of entities for which AHL Partners LLP or its affiliates provide services.

Read the rest in the brochure

The descriptions set forth in this Brochure of specific advisory services that AHL Partners LLP offers to clients, and investment strategies pursued and investments made by AHL Partners LLP on behalf of its clients, should not be understood to limit in any way the Investment Manager’s investment activities. AHL Partners LLP may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that AHL Partners LLP considers appropriate, subject to any applicable regulatory restrictions and each client's investment objectives and guidelines. The investment strategies AHL Partners LLP pursues are speculative and entail substantial risks. Clients/investors should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any client will be achieved. AHL Partners LLP manages investment strategies (hereinafter, “AHL Programmes”), each of which employs sophisticated computerized processes to identify trading opportunities across a wide range of markets around the world. AHL Partners LLP clients invest in one or more AHL Programmes. These systematic trading opportunities generally fall into three broad categories: multi-strategy quantitative, momentum, and liquid strategies. AHL Partners LLP primarily uses proprietary quantitative models to implement the AHL Partners LLP Programmes and underlying investment strategies. It should be noted that certain AHL Programmes may have limited capacity. Trading signals are generated and executed via a trading and implementation infrastructure. This process is quantitative, meaning that investment decisions are entirely driven by mathematical models based on quantitative analysis of historical relationships. It is underpinned by rigorous risk control, ongoing research, diversification and the constant quest for efficiency. Trading takes place around the clock and real-time price and non-price information is used to adjust positions across a diverse range of global markets. AHL Programmes may invest in a varied portfolio of financial instruments including, but not limited to, futures, options, forward contracts, swaps, CFDs, cash bonds, cash equities, securitized products and other financial derivatives both on and off exchange. AHL Partners LLP may, where possible, take short positions with respect to any or all investments. AHL Partners LLP may also systematically choose to hold derivative contracts (such as futures) through to cash or physical delivery. Sectors may be accessed directly or indirectly and include, without limitation, stocks, rates, bonds, debt, currencies, credit, energies, cryptocurrencies commodities, volatility and insurance risks. Sectors may also be accessed through direct or indirect investment in registered or unregistered collective investment schemes, funds or other pooled vehicle(s). In line with the principle of diversification, AHL Partners LLP’s approach to portfolio construction and asset allocation is premised on the importance of deploying investment capital across a full range of sectors and markets. Particular attention is paid to the correlation of markets and sectors, expected returns, market access costs and market liquidity. Portfolios are regularly reviewed and, when necessary, adjusted to reflect changes in these, and other, factors. A systematic process for adjusting market risk exposure in real time to reflect changes in the volatility of individual markets

is also in place. Through AHL Partners LLP's ongoing investment in research and technology, the number and diversity of markets and strategies traded directly or indirectly by the AHL Programmes may change over the life of the investment, and may also be subject to specific legal, regulatory or investor specific restrictions. It should also be noted that the implementation of the AHL Programmes for certain AHL managed Funds may differ from the way in which similar AHL Programmes are implemented for other clients or investment products managed by AHL Partners LLP or its affiliates. These differences may include, among other things, differences in the types of financial instruments, markets and asset classes traded which arise out of legal structuring, applicable law and other restrictions and/or considerations with respect to such investment products. AHL Partners LLP is committed to responsible investing, including a focus on understanding how ESG factors may influence performance, generate alpha, and/or mitigate risk in client portfolios, where such factors are consistent with its fiduciary duty to its clients. AHL Partners LLP aims to integrate ESG into its investment process, however, it also recognises that it may not always be possible or appropriate to integrate ESG for certain asset classes or investment strategies that it manages. AHL Partners LLP typically applies an exclusion list of controversial stocks or industries which may be related to arms and munitions, nuclear weapons, tobacco and coal production. Important information regarding each Fund, including investment objectives, strategy, and other material information, are contained in such Fund's governing documentation. B.

Material, Significant or Unusual Risks Relating to Investment Strategies

The investment strategies AHL Partners LLP pursues are speculative and entail investment and market-related risks. There can be no assurance the investment objectives of any client will be achieved. The client's activities could result in substantial losses under certain circumstances. Investing in securities involves risk of loss that clients should be prepared to bear. The following risk factors do not purport to be a complete list or explanation of all risks involved in an investment in a Fund or managed account managed by AHL Partners LLP. A Fund’s governing documentation memorandum may include additional risks not included herein. The following risk factors may not be applicable to all clients. Investments in a Fund are speculative and involve a substantial degree of risk, including the risk that an investor could lose some or all of its investment in a Fund. Prospective investors should carefully consider the risks of investing, which include, without limitation, those set forth below which are more fully described in the applicable Fund's governing documentation. These risk factors include only those risks AHL Partners LLP believes to be material, significant or unusual and relate to particular significant investment strategies or methods of analysis employed by AHL Partners LLP and do not purport to be a complete list or explanation of the risks involved in an investment in a Fund or to clients advised by AHL Partners LLP. Limited Regulatory Oversight AHL Partners LLP is registered with the SEC as an investment adviser under the Advisers Act. AHL Partners LLP is also registered with the CFTC as a CPO and CTA and is a member of NFA.

AHL Partners LLP’s SEC and CFTC registrations and NFA membership do not indicate any level of expertise or qualification, nor has the SEC, CFTC or NFA in any respect approved AHL Partners LLP. Speculative Investment There can be no assurance that the Fund will achieve its investment objective. An investment in a Fund is not guaranteed or subject to principal or capital protection and investors could lose some or all of their investment. Both an investment in the Fund and the investments which the Fund proposes to make are speculative. Furthermore, the Fund's investments may be subject to sudden, unexpected and substantial price movements (which may be influenced by factors such as changes in interest rates, currency exchange rate and economic and political events which are beyond the control of, and not predictable by, the Investment Manager). Unexpected and substantial price movements may lead to substantial fluctuations in the Net Asset Value of the Fund within a short period of time. Accordingly, an investment in the Interests should be made only by those persons who could afford to sustain a loss in such an investment. Regardless of the fact that the Investment Manager intends to manage the Fund diligently in pursuit of the Fund's investment objective, no guarantee or representation can be made that the Fund's investment program will be successful, that the various investment strategies and trading strategies utilized will have low correlation with each other or that the Fund's returns will exhibit low correlation with an investor's traditional investment portfolio. The Fund may utilize a variety of investment techniques, each of which can involve substantial volatility and can, in certain circumstances, substantially increase the adverse impact to which the Fund's investment portfolio may be subject. In order to meet its investment objective, the Fund may invest in financial instruments of all kinds including various, non-standard, complex, thinly-traded and/or novel financial instruments in relation to their structure, operation and underlying exposure. By their very nature, investment in such financial instruments carries a greater risk than that of more common investment products, which may result in a complete or partial loss of investor capital. Investors unable or unwilling to bear such risks should not invest. Performance History There can be no assurance that information on the Investment Manager or the investment strategies set out in a Fund’s governing documentation or elsewhere, including information on past performance, will be indicative of how the Interests will perform (either in terms of profitability or low correlation with other investments) in the future. Dependence on the Investment Manager The success of the Funds is significantly dependent upon the ability of AHL Partners LLP to develop and implement effectively the Fund's investment objective. Except as otherwise discussed herein, investors will be relying entirely on AHL Partners LLP to conduct and manage the affairs of the Fund. Subjective decisions made by the Investment Manager may cause the Funds to incur losses or to miss profit opportunities on which it could otherwise have capitalized.

The performance of the Investment Manager is largely dependent on the talents and efforts of the personnel of AHL Partners LLP. The success of the Funds depends on AHL Partners LLP's ability to identify and willingness to provide acceptable compensation to attract, retain and motivate talented investment professionals and other personnel. There can be no assurance that AHL Partners LLP's investment professionals will continue to be associated with AHL Partners LLP throughout the life of one or more of the Funds and there is no guarantee that the talents of AHL's investment professionals could be replaced. The failure to attract or retain such investment professionals could have a material adverse effect on the Funds. Operational Risk The Funds depend on the Investment Manager to develop appropriate systems and procedures to control operational risk. These systems and procedures may not account for every actual or potential disruption of their operations. The Investment Manager’s respective businesses are dynamic and complex. As a result, certain operational risks are intrinsic to their operations, especially given the volume, diversity and complexity of transactions that the Investment Manager is expected to undertake daily on behalf of its clients. Disruptions in the Investment Manager’s operations may cause the Fund to suffer, among other things, financial loss, the disruption of its businesses, liability to third parties, regulatory intervention or reputational damage. Breaches in Information Technology Security The Investment Manager maintains global information technology systems, consisting of infrastructure, applications and communications networks to support the Fund's as well as its own business activities. These systems could be subject to security breaches such as 'cyber-crime' resulting in theft, a disruption in the Investment Manager's ability to close out positions and the disclosure or corruption of sensitive and confidential information. Security breaches may also result in misappropriation of assets and could create significant financial and/or legal exposure for the Fund. The Investment Manager seeks to mitigate attacks on its own systems and those of the Fund but will not able to control directly the risks to third-party systems to which it may connect. Any breach in security of the Investment Manager's systems could disrupt the Fund's and the Investment Manager's business and may cause the Fund to suffer, among other things, financial loss, the disruption of its business, liability to third parties, regulatory intervention or reputational damage. Performance Fees Performance fees may create an incentive for the Investment Manager to make investments which are riskier than would be the case in the absence of a fee based on performance. In addition, performance fees may be calculated and paid based on unrealized gains which may subsequently not be realized. Substantial Expenses Payable Regardless of Profit The Funds will incur obligations to pay brokerage commissions, option premiums and other transactional costs to the brokers. The Funds will also incur obligations to pay a monthly

Read the rest in the brochure

AHL Partners LLP provides investment advisory services primarily to U.S. or non-U.S. pooled investment vehicles (“Funds”), exchange traded funds, UCITS funds, U.S. or non-U.S. institutional managed accounts which include pension plans and sovereign wealth funds, on a discretionary basis. The securities of these Funds are not registered under the Securities Act of 1933. In addition, the Funds are not registered under the Investment Company Act, and may or may not be continuously offered. In addition, AHL Partners LLP provides sub-advisory services to mutual funds and exchange trade fund registered under the Investment Company Act on a discretionary basis. Redemption rights with respect to each Fund are set forth in the governing documentation for each Fund. Termination rights with respect to each managed account are set forth in the investment management agreement for each managed account. Investments in the Funds may be subject to certain qualifications and a minimum investment requirement which under certain conditions may be waived as set forth in the Fund’s governing documentation. Currently, AHL Partners LLP does not have a predetermined account minimum for managed accounts.

AHL Partners LLP accepts performance-based fees for some, but not all clients to which it provides investment advisory services. AHL Partners LLP may face a conflict of interest by managing accounts that are subject to a performance-based fee or allocation and accounts that are not subject to a performance-based fee or allocation, including that AHL Partners LLP may have an incentive to favour accounts for which it receives performance-based fees or allocations. AHL Partners LLP may also have an incentive to favour accounts from which AHL Partners LLP will receive a performance fee calculated at a higher rate over accounts from which AHL Partners LLP will receive a performance fee or allocation calculated at a lower rate. This includes scenarios where a performance fee may be expected to be at a lower rate given the operation of a fee calculation mechanism such as a high-water mark. Furthermore, performance-based fee compensation may create an incentive for AHL Partners LLP to make riskier or more speculative investments than would be the case in the absence of such performance fees.

Other Conflicts of Interest Associated with Side-by-Side Management of Accounts Other types of side-by-side management of multiple accounts can also create incentives for AHL to favor one account over the other. Long Only/Long-Short Accounts. AHL manages accounts that only allow long positions, as well as accounts that permit short sales. AHL does, on occasion, therefore, sell a security short in some client accounts while holding the same security long in other client accounts. This creates the possibility that AHL is taking inconsistent positions with respect to a particular security in different client accounts. Securities of the Same Kind or Class. AHL does on occasion buy or sell securities of the same kind or class that are purchased or sold for another client, at prices that may be different. AHL may also, at any time, execute trades of securities of the same kind or class in one direction for an account and in the opposite direction for another account or within the same account, due to differences in investment strategy, model signals, or flows. Different strategies effecting trading in the same securities or types of securities may appear as inconsistencies in AHL’s management of multiple accounts side-by-side. Fixed Income and Equity Accounts. AHL manages accounts that invest in equities, as well as accounts that invest in fixed income instruments. AHL may, at times, buy and sell different instruments within an issuer’s capital structure for different clients. Under certain circumstances, this may result in AHL taking action on behalf of one client that disadvantages other clients due to conflicting investment objectives in the accounts. Accounts Managed by AHL and Affiliates. Where a client’s assets are managed by AHL and one or more of its affiliates, AHL and the affiliate may also, at any time, execute trades of

securities of the same kind or class in different directions for the client’s account due to differences in investment strategy or flows. Generally, AHL Partners LLP addresses these conflicts of interest through the adoption of policies and procedures that are designed to mitigate such conflicts of interest and ensure our compliance with applicable law, by way of an investment allocation policy which is designed to ensure all accounts are treated fairly and equitably over time regardless of the types of fees or fee rates paid. Please see Items 11.B.2 and 11.D below.

Broker-Dealer Registration Status

Neither AHL Partners LLP nor any of its management persons is registered as a broker-dealer and AHL Partners LLP does not have any application pending to register with the SEC as a brokerdealer. AHL Partners LLP utilizes the sales team of its affiliate, Man Investments Inc. ("MII") to assist in the marketing of its investment services in the U.S. MII is a limited purpose broker-dealer registered with the SEC and a member of Financial Industry Regulatory Authority, Inc. ("FINRA"). MII acts as solicitor, selling agent and/or investor servicing agent for certain AHL Partners LLP clients and Funds for which it may be compensated as agreed between AHL Partners LLP and MII. B. Futures Commission Merchant, Commodity Pool Operator or Commodity Trading Adviser Registration Status AHL Partners LLP is a commodity pool operator (“CPO”) and commodity trading advisor (“CTA”) registered with the Commodity Futures Trading Commission (“CFTC”) and a member of the National Futures Association (“NFA”). C.

Material Relationships or Arrangements with Industry Participants

AHL Partners LLP through its managing member Man Investments Limited is affiliated and under common control with the following London based entities that are authorized and regulated by the Financial Conduct Authority: Man Fund Management UK Limited; Man Solutions Limited (“MSL”), an investment adviser registered with the SEC and a commodity pool operator registered with the CFTC and a member of the NFA; GLG Partners LP, an investment adviser registered with the SEC and a commodity pool operator registered with the CFTC and a member of the NFA; and Man Global Private Markets (UK) Ltd., an investment adviser registered with the SEC. Furthermore, AHL Partners LLP is affiliated and under common control with the following New York based entities: Man Investments Inc., a limited purpose broker dealer registered with the SEC and member of FINRA which provides placement agent services to certain of AHL Partners LLP Funds as well as marketing and sales services to AHL Partners LLP; Man Solutions LLC (“MS LLC”), an investment adviser registered with the SEC and a commodity pool operator and commodity trading adviser registered with the CFTC and a member of the NFA; Man Capital Management LLC, an investment adviser registered with the SEC; Man Investment Partners (US) LP, an investment adviser registered with the SEC; GLG LLC, an investment adviser registered with the SEC and a commodity pool operator registered with the CFTC and a member of the NFA; Man Global Private Markets (USA) Inc., an investment adviser registered with the SEC; VCC Advisors, LLC an investment adviser registered with the SEC and Varagon Capital Partners, L.P. an investment adviser registered with the SEC with a principal office in New York, NY. In addition, AHL Partners LLP is affiliated and under common control with Numeric Investors LLC, based in Boston, MA with an office in New York, NY which is an investment adviser registered with the SEC, a commodity pool operator registered with the CFTC and a member of the NFA;

and Man Investments (USA) Corp., a corporation incorporated in the State of Delaware, United States, which is the managing member of the AHL Partners LLP Delaware Funds and has responsibility for providing management services to such Delaware Funds. AHL Partners LLP is also affiliated and under common control with Man Asset Management (Ireland) Limited (“MAMIL”), a firm that is registered with the Central Bank of Ireland, Man Asset Management (Cayman) Limited (“MAMCL”), a manager regulated by the Cayman Islands Monetary Authority, and Man Investment Management (Shanghai) Co. Ltd registered with the Asset Management Association of China (AMAC). AHL Partners LLP is also affiliated with Man Investments Australia Limited an investment adviser registered with the SEC and licensed by the Australian Securities and Investments Commission based in Australia. MAMCL and MAMIL may provide certain investment-related services to AHL.

MSL and MS LLC (together, “Man Solutions”) are affiliated investment advisers which provide investment advisory services primarily focused on multi strategies including customized portfolios to their clients across strategies managed by affiliates, including AHL Partners LLP, as well as third party managers. In addition, from time-to-time AHL Partners LLP provides sub-advisory or other investment management services to clients of Man Solutions. AHL Partners LLP, its affiliates and its personnel serve as investment advisers and investment managers to multiple pooled investment vehicles and managed accounts. AHL Partners LLP may manage accounts on behalf of its affiliates alongside its clients. AHL Partners LLP, its affiliates and its personnel may take action or give advice with respect to certain clients and accounts that differs from the advice given to other clients and accounts. Specifically, there may be times whereby the advice given to clients and accounts is opposite of the advice given to other clients and accounts due to differences in investment strategy, redemptions/subscriptions or other factors. AHL Partners LLP manages each client in accordance with its respective investment objectives and guidelines. AHL Partners LLP, its affiliates and its personnel will devote as much time to the activities of each client and account as deemed necessary and appropriate and the amount of time devoted to different clients and accounts varies. Certain affiliates within Man’s Discretionary business are engaged in private credit, direct lending and other private investment activities that may involve the receipt of material non-public information regarding borrowers or issuers. To manage the potential conflicts arising from these activities and to enable the relevant businesses to operate independently, Man maintains an information barrier supported by policies and procedures designed to prevent the inappropriate flow of confidential information. The information barrier may, in certain circumstances, limit the Investment Manager's ability to transact in securities on behalf of its clients, or alternatively may permit the Investment Manager to transact where it might otherwise be restricted absent the barrier. D.

Material Conflicts of Interest Relating to Other Investment Advisers

AHL Partners LLP does not recommend or select other third-party investment advisers for its clients. AHL Partners LLP’s Funds may invest in other AHL Partners LLP Funds.

From time to time, certain affiliates seed funds to which AHL Partners LLP provides investment management services. AHL Partners LLP may provide investment management services to certain funds in which the invested capital is exclusively or predominantly seed capital received from AHL Partners LLP’s affiliates; such arrangements may persist over a long period of time. Certain personnel, including those who are part of certain Man centralized functions and those with specific investment management responsibilities, perform roles for AHL Partners LLP and one or more affiliates of AHL Partners LLP. AHL Partners LLP provides aspects of its systems, know-how, analyses, research and certain models to its affiliates. Use of such information from AHL by its affiliates is at the sole discretion of the affiliates. Potential and actual conflicts of interest arise from the activities described herein. AHL Partners LLP has established policies and procedures to monitor and to the extent possible resolve conflicts of interest and will endeavour to resolve conflicts with respect to investment opportunities in a manner it deems appropriate and equitable to the extent possible under the prevailing facts and circumstances. AHL Partners LLP may be subject to conflicts of interest from time to time in performing its respective duties to Funds and managed accounts. Any such conflict of interest could have a material adverse effect on clients. When a conflict of interest arises AHL Partners LLP will endeavour to ensure that the conflict is resolved or managed appropriately and fairly. Furthermore, AHL Partners LLP has substantial incentives to see the assets of clients appreciate in value and merely because an actual or potential conflict of interest exists does not mean that it will be acted upon to the detriment of clients. AHL Partners LLP is permitted to manage and/or advise other managed accounts and funds, some of which may have objectives similar to those of its existing clients, including without limitation other funds or accounts in which AHL Partners LLP or its affiliates may have an interest.

AHL Partners LLP strives to adhere to the highest industry standards of conduct based on principles of professionalism, integrity, honesty and trust. Accordingly, AHL Partners LLP has adopted a Global Code of Ethics (the “Code”) that is supplemented by additional policies and procedures that are designed to reinforce its institutional integrity, and to set forth procedures and limitations which govern, amongst other matters, the personal securities transactions of its employees. The Code was developed to promote the highest standards of behaviour and to ensure compliance with all applicable regulations. The Code applies to all AHL Partners LLP employees. The Code contains policies and procedures that, among other things: 

Require employees to observe fiduciary duties owed to clients;



Prohibit employees from taking personal advantage of opportunities belonging to clients;



Prohibit trading on the basis of material non-public information;



Require employees to comply with anti-money laundering requirements;



Place limitations on personal trading by employees and impose preclearance and reporting obligations with respect to such with the exception of certain security types;



Impose limitations on the giving or receiving of gifts and entertainment;



Restrict employee outside business activities;



Require employees to disclose family members’ business activities that may present a conflict;



Require pre-clearance on political contributions; and



Prohibit disclosure by employees of confidential information of AHL Partners LLP and its clients.

Employee personal trades in securities covered by the Code are monitored by the Chief Compliance Officer or designee and governed by the procedures set forth in the Code. Employees from time to time will have proprietary investments in which clients advised or sub-advised by AHL Partners LLP also take a position, may trade and invest simultaneously with such clients, and may take investment positions that are different from or opposite to the positions taken by such clients. In general, all personal securities transactions (except for unaffiliated US open- ended mutual funds, US Treasury securities, or other permitted investments listed in the Code) are subject to pre69

clearance by the Chief Compliance Officer, or designee. A copy of AHL Partners LLP’s Code is available to clients and prospective clients upon request by contacting AHLCompliance@man.com. Furthermore, AHL Partners LLP has adopted procedures to prevent and detect misuse of material non-public information. Specifically, AHL Partners LLP’s procedures prohibit any employee from trading securities, either personally or on behalf of others (such as client accounts advised or subadvised by AHL Partners LLP), while in possession of material, non-public information, and prohibit employees from communicating material, non-public information to others in violation of the law. From time to time, as part of its business activities or otherwise, AHL Partners LLP or its affiliates may come into possession of material non-public information concerning specific issuers. Under applicable laws and AHL Partners LLP’s policies and procedures, this may limit AHL Partners LLP’s flexibility to buy or sell securities of such issuers, or other financial instruments linked to such issuers. AHL Partners LLP clients are subject to Man's Global Banned Weapons Policy, which is designed to ensure compliance with a number of conventions and relevant laws that have been implemented globally to ban the manufacture, supply and distribution of anti-personnel landmines, cluster munitions, biological weapons, chemical weapons, blinding laser weapons and nondetectable fragments. This may limit AHL Partners LLP’s flexibility to buy or sell securities of issuers that, among a range of other activities, are involved in banned weapons for its clients. In addition, certain of AHL Partners LLP clients may be subject to the Man Responsible Investment framework which considers responsible investment criteria when making investment decisions. AHL Partners LLP and its affiliates are subject to certain position limits, including commodities. Under applicable laws and internal procedures, this may limit AHL Partners LLP’s flexibility to buy certain futures contracts or derivatives thereon. Furthermore, AHL Partners LLP and its affiliates are subject to other trading restrictions, including in connection with Regulation M Rule 105, which will limit the AHL Partners LLP ability to trade the securities of certain issuers. Related persons and personnel of AHL Partners LLP and its affiliates (the "Advisory Affiliates") may invest in or have a financial interest in the Funds and may not invest in all such Funds. It is expected that the size of these investments or the financial interest will change over time. Potential conflicts may arise due to the fact that the Advisory Affiliates may have investments or financial interests in some Funds but not in others or may have different levels of investments or financial interests in various Funds, and because the Funds may pay different levels of fees. In addition, certain Advisory Affiliates may from time to time make personal investments in securities or financial instruments which may be appropriate for, may be held by, or may fall within client investment guidelines. Such Advisory Affiliates may buy, sell, or hold securities or other financial instruments for their own accounts while entering into different investment decisions for one or more clients. These activities may adversely affect the prices and availability of securities or financial instruments held by or potentially considered for one or more clients.

From time to time, AHL Partners LLP or the Advisory Affiliates may form and manage additional pooled investment vehicles and advise other client accounts with similar or different investment strategies as the Funds or managed accounts currently advised or sub-advised by AHL Partners LLP. It may be appropriate for more than one Fund or managed account advised by AHL Partners LLP to trade in the same securities at the same time. AHL Partners LLP has policies and procedures to manage the conflicts of interest in connection with such trades. B. Securities in which the Investment Adviser or a Related Person Has a Material Financial Interest 1.

Cross Transactions and Principal Transactions

AHL Partners LLP generally does not engage in cross trades. However, should AHL Partners LLP engage in a cross transaction on behalf of the Funds, each cross transaction will be performed in conjunction with AHL Partners LLP’s policies and procedures. To the extent that AHL Partners LLP engages in cross trades and a cross trade is considered a principal transaction, AHL Partners LLP will comply with the requirements of Section 206(3) of the Advisers Act with respect to any U.S. client or fund, including that AHL Partners LLP will notify the applicable client (or an independent representative of the client) in writing of the transaction and obtain the client's consent (or the consent of an independent representative of the client). AHL Partners LLP does not consider transactions b e t we e n c l i e n t s that inadvertently match on an exchange or venue as a result of investment decisions taken by AHL Partners LLP Fund(s) and, where applicable, its affiliates as cross transactions or principal transactions. 2.

Allocation of Investment Opportunities

AHL Partners LLP provides discretionary investment advice and/or management services to multiple client accounts, including Funds seeded by the AHL Partners LLP or its affiliates that may seek to invest in the same or similar investment opportunities given the investment strategies are similar or overlap. This may create potential conflicts particularly where there is limited availability or liquidity for certain investments. AHL Partners LLP has developed policies and procedures that provide that both investment opportunities and trades will be allocated among these client accounts in a manner that is considered to be reasonable and equitable and in a manner that is consistent with each client's investment objectives and guidelines. AHL Partners LLP utilizes proprietary computer-based algorithms to determine allocations of orders and subsequent fills to its client accounts with the goal of allocating trades fairly and equitably across its managed funds. Due to various market conditions, including but not limited to price volatility, variations in liquidity, and differences in order execution, it is impossible for AHL Partners LLP to obtain identical trade execution for all its Funds. In general, orders for any proprietary or testing accounts will be subject to the same allocation procedures as those applicable to client accounts.

AHL Partners LLP may determine that an investment opportunity or particular transaction is appropriate for one or more client accounts, but not for other clients, or are appropriate for or available to certain clients but in different sizes, terms, or timing than is appropriate for others. It is the policy of AHL Partners LLP to allocate investment opportunities among all client accounts fairly, to the extent practical and in accordance with each client account’s applicable investment strategies, over a period of time. AHL Partners LLP will have no obligation to purchase or sell a security for, enter into a transaction on behalf of, or provide an investment opportunity to any client account solely because AHL Partners LLP purchases or sells the same security for, enters into a transaction on behalf of, or provides an opportunity to another client account if, in its reasonable opinion, such security, transaction or investment opportunity does not appear to be suitable, practical or desirable for the client account AHL Partners LLP will make allocations for client accounts of such investments with reference to numerous factors including, without limitation, AHL Partners LLP’s perception of the appropriate risks and rewards for each client account, investment objectives and guidelines of each client account, leverage of each client account, the liquidity of the account at the time of the investment and on a going-forward basis, risk parameters for each client account, regulatory restrictions affecting the client, and such other factors as are relevant in the judgment of AHL Partners LLP. Although allocating orders among client accounts may create potential conflicts of interest because of the interests of AHL Partners LLP or its employees or because AHL Partners LLP may receive greater fees or compensation from one client account over another, AHL Partners LLP will not make allocation decisions based on such interests or greater fees or compensation. Allocation among accounts in any particular circumstance may be more or less advantageous to any one account. In addition, transactions in investments by multiple client accounts may have the effect of diluting or otherwise impairing the values, prices or investment strategies of an individual client, particularly, but not limited to, in small capitalization, or less liquid strategies. Therefore, the amount, timing, structuring, or terms of an investment by some clients may differ from, and performance may be lower than, investments and performance of other clients. 3.

Valuation

The Funds have established valuation policies and procedures that seek to establish a consistent framework and methodology for the determination, validation, approval, regular monitoring and review of pricing all positions of each Fund. The governing bodies of the Fund’s have appointed an Independent Pricing Committee (the “IPC”) to undertake certain services concerning the valuation policies and procedures relating to each Fund. The IPC is an independent body set up to: (1) establish a pricing matrix (a table which lays out a pricing source for certain assets and liabilities) which the governing bodies will decide whether to adopt for the Fund and if so will thereafter be used by the administrator to calculate the value of the assets and liabilities held by the Fund; and (2) establish the prices of any positions held in the Fund that do not have an independently ascertainable value as per the pricing matrix. In addition, the IPC provides general governance and oversight of the valuation process. C. Investing in Securities that the Investment Adviser or a Related Person Recommends to Clients

Read the rest in the brochure

Factors Considered in Selecting or Recommending Broker-Dealers for Client Transactions The Investment Manager will place client orders for the execution of transactions via a centralized trading desk with various brokers, dealers and/or trading venues (as defined by the Markets Financial Instruments Directive) on the basis of best execution (in accordance with the rules of the FCA, SEC and MiFID II) in accordance with its Best Execution Policy based on a number of factors, including, among other things, execution costs inclusive of commission rates, speed and likelihood of execution, impact on market price, availability of price improvement, liquidity of the instrument, the broker's financial strength, ability to commit capital, stability and responsibility, reputation, reliability, overall past performance of services, responsiveness to the Investment Manager as well as means of communication, ability to execute trades based on the characteristics of a particular trade, technology and trading systems, trading activity in a particular security, block trading and block positioning capabilities, net price, depth of available services, bond capability and options operations, the availability of stocks to borrow for short trades, willingness to execute related or unrelated difficult transactions, back office, settlement processing and special execution capabilities and error resolution. The centralized trading desk will take all sufficient steps to execute orders in a manner designed to obtain the best possible results on a consistent basis. However Investment Manager does not need to, nor will it, seek the best result on each and every client order but rather ensures that methodologies employed achieve overall best execution on behalf its Clients. The Investment Manager has established a best execution committee to review execution performance and other execution related decisions taken by Investment Manager on behalf of its Clients. The Investment Manager does not adhere to any rigid formulas in selecting brokers, but weighs a combination of the factors, some of which are referenced above. There is, however, no direct correlation between these factors and the allocations of brokerage for client accounts advised or sub-advised by the Investment Manager. Because of the range of factors considered by the Investment Manager, it is possible that the Investment Manager’s clients may pay brokerage commissions in excess of that which another broker might have charged for effecting the same transaction. The Investment Manager will make a good faith determination that the amount of commission is reasonable in relation to the value of the products and services received, the broker's execution ability, and other factors. Centralized Trading and Financing Desk The Investment Manager has delegated certain of its order handling and execution responsibilities to a centralized trading desk and cash management and related responsibilities to a centralized financing desk. In doing so the Investment Manager ensures that the delegates comply with any client restrictions as well as the Investment Manager’s policies and procedures relating to order handling and execution responsibilities. The Investment Manager believes that such delegation is consistent with its obligations and is in the best interest of its clients.

1.

Research and Other Soft Dollar Benefits

The Investment Manager pays for all investment research as defined by Markets in Financial Instruments Directive II on behalf of the Funds. Data costs are charged separately as expenses to the Funds as further described in Item 5.C.

AHL may share products and/or services procured for its clients with its affiliates to be used in servicing such affiliate’s clients. AHL may also receive products and/or services for use in servicing its clients from its affiliates. 2.

Brokerage for Client Referrals

The Investment Manager does not consider capital introduction and marketing assistance with respect to investors in the Funds in selecting or recommending broker-dealers for the Funds. However, the Investment Manager or its affiliates may be invited to capital introduction events as a result of the relationship the Investment Manager and its affiliates have with certain broker dealers. 3.

Directed Brokerage

AHL Partners LLP does not generally allow for directed brokerage arrangements. B.

Trade Error Policy

In the event that AHL Partners LLP experiences a trade error with respect to order handling and execution on behalf of clients, a formalized process is in place for the resolution of such trade errors. The Investment Manager will correct such trade error in accordance with its policies and procedures. If the Investment Manager, in its sole discretion determines that a client should be reimbursed as a result of a trade error caused by the Investment Manager interest will generally not be paid on such losses. Please refer to Item 8.B under “Trade Error Risk” for additional information and risk disclosures pertaining to trade errors. C.

System Event Policy

The systematic approach to the development and deployment of investment strategies utilised by the Investment Manager harnesses complex econometric and statistical theories, research and modelling which may result in a “System Event” (e.g., errors or omissions regarding trading systems, coding/programing/modelling, etc.). The Investment Manager, to the extent feasible and reasonable, will correct a System Event in accordance with its policies and procedures. The Fund will benefit from any gains and bear any losses unless it is otherwise determined by the Investment Manager. Please refer to Item 8.B under “Model and Data Risk” for additional information and risk disclosures pertaining to system events.

Economic Benefits for Providing Services to Clients

AHL Partners LLP does not receive economic benefits from non-clients for providing investment advice and other advisory services. B.

Compensation to Non-Supervised Persons for Client Referrals

From time to time, AHL Partners LLP and/or its affiliates may from time to time utilize third party placement agents or solicitors that receive compensation, which may be borne either by AHL Partners LLP or its affiliates or by the investor or client, for referring the client to AHL Partners LLP or investors to the Funds. Compensation may be in the form of a percentage of management fees or performance fees, a flat fee or as otherwise agreed. AHL Partners LLP or its affiliates may benefit from the arrangements where clients are referred directly to it and/or investors are referred directly to a Fund, since the management fees are generally based upon a percentage of such client's assets under management. Thus, the more assets the Investment Manager or its affiliates has under management, the higher the management fee income. If applicable, any such arrangement with a third-party solicitor will comply with the Advisers Act. MII, a US based affiliate of the Investment Manager, acts as the selling agent and/or investor servicing agent for certain Funds in the US. MII may receive a percentage of a Fund’s management fee to act as selling agent and or investor servicing agent. In addition, MII has entered into agreements with other broker-dealers and certain financial advisers to solicit interests in Funds and/or to provide ongoing investor services and account maintenance services to investors. Each such broker-dealer and financial adviser generally receives compensation based on the aggregate value of outstanding interests held by investors that receive services from such persons, fixed amounts or other agreed upon compensation. Such compensation generally will be paid by MII from the fees that it receives from a Fund or the Investment Manager. In addition, AHL Partners LLP has entered into an agreement with its affiliate, Man Investments AG (“MIAG”), an entity based in Switzerland that is registered with the Swiss Financial Market Supervisory Authority to market AHL Partners LLP services in jurisdictions outside of the U.S. and Canada. These affiliated entities act as solicitors for managed accounts and the selling agent and/or investor servicing agent for certain Funds outside of the U.S. Certain Funds may also enter into a distribution agreement directly with MIAG to sell Fund interests to non-U.S. persons. MIAG may contract with other affiliates to market AHL Partners LLP services and sell Fund interests in jurisdictions outside of the U.S and Canada.

CNMV: Administrative Proceedings Before Regulatory Authorities

On April 7, 2021, Man Group plc, an advisory affiliate of AHL Partners LLP based in London, England, agreed to pay a fine of €240,000 to the Comision Nacional Del Mercado de Valores (the “CNMV”), pursuant to a settled resolution, in connection with the CNMV’s findings that Man had not complied with European Union (“EU”) regulations requiring the disclosure of an investor’s short positions in the securities of any issuer based in an EU member country, such as Spain. Specifically, the European Securities and Markets Authority (“ESMA”) has issued regulations on short selling and credit default swaps (“SSR”) that require investors to file reports disclosing any short positions above a threshold of 0.2% of an issuer’s outstanding shares, with additional disclosure thresholds at increasing intervals of 0.1%. Thus, an investor must file disclosures calculating its net short position whenever it crosses thresholds (up or down) of 0.2%, 0.3%, 0.4%, 0.5% etc. In the case of Man Group plc, the CNMV determined that, between December 2017 and November 2018, three of Man Group plc’s affiliated managers, including AHL Partners LLP had on five occasions incorrectly disclosed their net short position in four Spanish issuers amounting to between 0.2% and 0.7% of the issuers’ outstanding shares. The SSR regulations impose rules for calculating net short positions at the fund level among affiliated entities, which Man Group plc attempted to apply in good faith. See ESMA 70-145-408, question 8.5, available at https://www.esma.europa.eu/sites/default/files/library/esma70-145-408_qa_on_ssr.pdf. In four cases, the irregularities arose from the incorrect identification of the position holding entity within Man Group plc; (for example, a position held by one Man manager was incorrectly notified as a position held by another Man manager). This misreporting resulted in delayed correcting notifications to the CNMV. In one instance, a position was inadvertently not reported. The order related to Man is set forth in dispatch record no. 2021025805 of the CNMV. The CNMV did not determine that Man Group plc engaged in any misleading or deceptive conduct, nor that it committed any violation in connection with providing investment advisory services to any clients.

In 2019, following the reporting issues noted above, Man implemented a number of measures which included the implementation of a new third party shareholder disclosure system, FundApps, in order to strengthen Man’s systems and controls and reduce the manual component of Man’s reporting processes.

Frequency and Nature of Review of Client Accounts or Financial Plans

The Investment Manager’s portfolio managers are primarily responsible for reviewing accounts of the clients and do so individually or in a group, depending upon account needs and market conditions. The portfolio managers, individually or in various groups, perform daily, weekly, or monthly reviews of all accounts as they deem appropriate or as otherwise required. Reviews may be undertaken because of changes in market conditions; change of security positions; changes in investment objectives or policies; capital inflows/outflows; and other reasons. Various matters may be discussed during such reviews, (e.g., performance of accounts in connection with investment objectives, portfolio construction, risk/reward, security positions, and investment opportunities). In addition to the reviews performed by the portfolio management teams, the Portfolio Risk team reviews portfolios for adherence with client guidelines on a daily basis. B.

Factors Prompting Review of Client Accounts Other than a Periodic Review

A review of a client account may be triggered by changes in market conditions; change of security positions; changes in investment objectives or policies; capital inflows/outflows; and other reasons, including for reasons not yet identified by the portfolio management team. C.

Content and Frequency of Account Reports to Clients

The requirements for frequency and content of reports will be set forth in the documents for each client account. Investors in the Funds generally receive estimated and final monthly statements, as applicable, generally showing account values, changes in account values, account activity, asset allocation, currency exposure and performance. Depending on specific requirements, investors in private funds also generally receive audited financial statements prepared within either 90 or 120 days, depending on regulatory requirements, of the applicable fund's fiscal year end. While all investors generally receive similar information, to the extent an investor receives additional information (that other investors have not received) which is in addition to information provided in a Fund’s regular reports to investors, such information may provide such investor with greater insight into the Fund’s activities. This may enhance such investor's ability to make investment decisions with respect to a Fund and possibly affect such investor’s decision to request a redemption from such Fund. Affiliated investment advisers that invest in AHL Partners LLP Funds will receive information with greater transparency on such Fund that may not otherwise be made available to other investors.

With regards to its U.S. private funds, the Investment Manager is subject to Rule 206(4)-2 under the Advisers Act (the "Custody Rule"). In accordance with the Custody Rule each U.S. private fund complies with the provisions of the "Pooled Vehicle Annual Audit Exception" and is subject to audit at least annually by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, and distributes its audited financial statements to all investors within 120 days of the end of its fiscal year. With respect to certain U.S. managed accounts and, as agreed, AHL Partners LLP may directly debit fees from such clients’ accounts and may be deemed to have custody as a result of such authority. In these cases in order to comply with the Custody Rule, managed accounts will receive statements directly from the managed account’s qualified custodian(s) (as defined in the Custody Rule) on at least a quarterly basis. Managed account clients should carefully review those statements regarding the investment activities and fees for the account.

In general, AHL Partners LLP provides discretionary investment advice and/or management services to its clients. As such, AHL Partners LLP has discretion regarding all investment decisions and is authorized to determine and direct execution of transactions within each client's specified investment objectives, restrictions and policies. However, AHL Partners LLP’s discretion is subject to regulatory constraints as well as limits imposed on the investment manager as described in the applicable governing documentation in the case of the Funds, as applicable, and investment management agreements or other relevant documents with each client advised or sub-advised by AHL Partners LLP. AHL Partners LLP utilizes centralized trading and finance desks to execute orders on behalf of its clients. In recognition of the fact that certain investors may be prevented or constrained from having direct or indirect exposure to certain stocks by virtue of law, statute, rule, regulation or policy, AHL Partners LLP will consider submissions for the exclusion of certain stocks from a relevant AHL Programme where such investor meets a certain threshold of investment. AHL Partners LLP will only exclude such stocks from an AHL Programme in circumstances where it considers, in its absolute discretion, that the exclusion would allow AHL Partners LLP to continue to discharge its duties and obligations as investment manager and that the exclusion will have no material effect on the performance and operation of that AHL Programme.

Proxy Voting

AHL Partners LLP has adopted policies and procedures to ensure that any proxy voted on behalf of clients is voted in a manner which is in the best interests of such clients. Proxy votes that may be voted at AHL Partners LLP’s discretion, or where AHL Partners LLP has been specifically instructed by a client to vote proxies, will be evaluated and AHL Partners LLP will seek to vote in the best interest of the relevant Proxy Client(s). It should be noted that there may be times whereby AHL Partners LLP invests in the same securities/assets while managing different investment strategies and/or clients. Accordingly, it may be appropriate in certain cases that such securities/assets are voted differently across different investment strategies and/or clients, based on their respective investment thesis and other portfolio considerations. It should be noted that AHL Partners LLP will only vote proxies on securities and other portfolio assets currently held by clients or in which clients have an economic interest. Proxies received for securities that are loaned out or are on contract for difference/swap will generally not be voted.4 In addition, from time to time clients may hold equity positions purely for financing purposes. The net result of these holdings is that the client has no economic interest in the issuer and as such AHL Partners LLP will refrain from voting. Furthermore, AHL Partners LLP may refrain from voting a proxy when it is determined that the cost of voting the proxy exceeds the expected benefit to the client. In addition, on an on-going basis AHL Partners LLP will endeavour to identify material conflicts of interest, if any, which may arise between AHL Partners LLP and one or more issuers of clients’ portfolio securities, with respect to votes proposed by and/or affecting such issuer(s), in order to ensure that all votes are voted in the overall best interest of clients. AHL Partners LLP has established Stewardship and Proxy Voting Committees that are responsible for resolving proxy voting issues when deemed necessary; making proxy voting decisions where a material conflict of interest may exist; monitoring compliance with The Global Proxy Voting Policy (the “Policy”); and setting new and/or modifying existing policies. Compliance will undertake monitoring of the Stewardship team’s conflict resolution process (such as the proxy watch list) where potential conflicts of interest may exist. AHL Partners LLP has appointed, and will appoint from time to time, one or more proxy voting service companies, to provide it with proxy voting services for certain Proxy Clients. Where applicable, AHL Partners LLP will generally vote proxies for the relevant Proxy Clients in accordance with AHL Partners LLP’s Proxy Voting Policy guidelines, unless otherwise specifically instructed to vote otherwise by the Portfolio Manager or such Proxy Client. Proxy Clients may

On a case by case basis, stock may be recalled in order to vote.

instruct AHL Partners LLP on proxy voting matters in the manner described in such Proxy Client’s agreement. AHL Partners LLP maintains documentation memorializing the decision to vote a proxy in a manner different from what is stated in the relevant proxy voting guidelines. Documentation is also maintained for all proxies that are not voted for Proxy Clients and the reasons therefore where AHL Partners LLP has been instructed by the Proxy Client to vote. AHL Partners LLP’s Global Proxy Voting Policy uses the Glass Lewis standard policy as the base but applies a number of additional guidelines that target specific areas where we believe higher standards should be promoted. The Glass Lewis standard proxy voting guidelines can be found on Glass Lewis’ website at: https://www.glasslewis.com/voting-policies-current/. AHL Partners LLP’s Global Proxy Voting Policy guidelines are summarised in the table below: Key Areas

Merit, Fairness and Equality5

Human Rights

AHL Partners LLP’s Global Proxy Voting Policy Guidelines US, Canada, UK, Australia, Europe: - At companies included in standard market indices, we will generally vote against the nomination committee chair and/or members when the board of directors is not at least one-third gender diverse, unless the company demonstrates broader board diversity through, for instance, ethnic representation, disclosed plans to achieve diversity objectives, inclusion of diverse profiles in board candidate search process, or gender diversity at the executive level. - At companies listed in other market indices, we will generally vote against the nomination committee chair and/or members when there is not at least one woman on the board of directors. Japan: At companies included in standard market indices, we will generally vote against the nomination committee chair and/or members when the board of directors is not at least 15% gender diverse. We will generally vote against the ESG committee or equivalent when a company is in breach of UN Global Compact (UNGC) compact and/or OECD guidelines. For companies on the Man human rights watchlist6, we will generally vote against the ESG committee or equivalent if the company does not have a human rights policy that is aligned with international standards, such as the Universal Declaration of Human Rights (UDHR), or ILO conventions.

Vote decisions are reviewed on a case-by-case basis based on factors including, but not limited to, local laws, regulations and market standards.

Companies in sub-industries where human rights are material as defined by our ESG service provider.

Climate Change

Executive Compensation

For Man transition laggards7,8, we will generally vote against the ESG committee or equivalent if: - the company lacks board oversight of climate - the company has not set a net zero target - the company does not report their disclosures in line with the Task Force on Climate-Related Financial Disclosures (TCFD) or the Sustainability Accounting Standards Board (SASB) We will generally vote against executive compensation policies if there is insufficient disclosure, significant disconnect between pay and performance, lack of sufficiently stretching targets, excessive discretion, ex gratia, non-contractual payments or guaranteed bonuses, excessive quantum, excessive and unjustified increases in base salary, or lack of structural safeguarding mechanisms such as clawback and malus policies. For Man transition laggards7,8, we will generally vote against executive compensation policies if remuneration awards are not linked to climate indicators.

Board Tenure and Refreshment

Shareholder Proposals

We will generally vote against members of the nomination and/or governance committees wherein the board has an average tenure of greater than 10 years and there have been no new nominees in the last 5 years. We will generally support shareholder proposals that request additional disclosure or promote environmentally or socially positive outcomes where we believe the company is mismanaging the relevant issue or lagging its peers, and where we consider it reasonable to expect the company to take the requested action.

Upon request, clients may receive a copy of AHL Partners LLP’s Global Proxy Voting Policy and/or information regarding the manner in which securities held in their account were voted by contacting their AHL Partners LLP representative at globalproxyvotingclientservices@man.com. B.

Class Actions and Securities Litigation

AHL Partners LLP will only participate in class actions on behalf of clients (as authorized) to the extent possible and practical and where it believes it is in the best interests of clients to do so. There may exist circumstances where a recovery is possible, but AHL Partners LLP does not believe it is in the client’s best interest to so participate. It is currently expected that in substantially all situations where AHL Partners LLP is authorized to file class actions on behalf of clients, AHL Partners LLP will utilize the services of a third-party class actions service provider. Only current clients or Fund investors will receive any proceeds received from class action recoveries. Investors that have fully redeemed will not receive any class action proceeds. AHL Partners LLP may consider a de minimis amount with regards to distributing any proceeds received.

As defined by Man Group’s proprietary transition score.

The climate guidelines mainly apply to executive compensation and director elections; they take into account a company’s size and sector to ensure that shareholders execute votes that make sense from a financial perspective in the context of a company’s operations. Using our internal data capabilities, we have developed a proprietary transition score to identify a list of transition laggards operating in climate material sectors that receive the highest degree of focus.

AHL Partners LLP may from time to time receive notification of and/or determine (as authorized) to engage and/or participate in litigation or other legal proceedings regarding investments held by clients. AHL Partners LLP may participate and/or engage in those lawsuits where AHL Partners LLP has made the determination that the potential benefit to its client(s) outweighs the costs of participation in the litigation. Any monies recovered as a result of any such litigation will be allocated on a pro rata or other appropriate basis to the client(s) which hold/held the investment at issue. AHL Partners LLP will not be responsible for reimbursing any client(s) or investor(s) who may have been invested during the period that is the subject of any litigation but had redeemed or withdrawn such investment prior to such a recovery. AHL Partners LLP may consider a de minimis amount with regards to distributing any proceeds received.

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