Albion River Management LLC

Albion is an investment management company which provides investment management and advisory services to its private funds (each a “Fund,” “Partnership,” or “Client” and, collectively, with any related investment vehicles and future pooled investment vehicle for which Albion may serve as an investment adviser, the “Funds,” “Partnerships,” or “Clients”). The principal owner of Albion is Darren Farber (the “Principal”). Albion primarily pursues equity and equity-related investments primarily in global defense companies. Albion retains broad flexibility to invest on behalf of the Funds in accordance with the investment objectives, strategies and guidelines specified in each Fund’s limited partnership agreement, limited liability company operating agreement and/or private placement memoranda, as applicable (collectively, the “Offering Documents”). Albion does not tailor its investment advice to match the needs of any specific investor in any Fund (each such individual an “Investor,” and, collectively, the “Investors”). As of December 31, 2025, Albion manages approximately $2,062,000,000 (calculated based on regulatory assets under management) on a discretionary basis on behalf of the Funds.

Albion (or an affiliate or subsidiary) generally charges each Fund, and consequently the underlying Investors, an annual management fee of between one percent (1.0%) and two percent (2.0%) of the total capital contributions or assets of the Fund during such Fund’s investment period. Management fees are generally payable quarterly in arrears to Albion by each Fund. Investors will generally not be eligible for partial refunds in the case of early withdrawals, but specific details are set forth in each respective Client’s Offering Documents. Albion will generally offset the management fees paid by a Fund in the amount of consulting fees, commitment fees, monitoring fees, director’s fees, break-up fees, success fees or other renumeration (whether in the form of cash, securities or otherwise and net of any reimbursement of transaction or other out-of-pocket expenses) paid to Albion (or its affiliates or subsidiaries (including, without limitation, the Principal, but excluding any persons retained by Albion as operating executives)) for services rendered by such persons in their respective capacities and to the extent related to the investment activities of the Fund. If amounts to be applied to reduce the management fees in any period exceed the management fees payable for such period, such excess will be applied to reduce the management fees payable in the next period and each succeeding period thereafter until the full amount has been applied to offset the management fee. Any such offsets will be conducted in the manner described in the applicable Fund’s Offering Documents. Please refer to Item 6 below for a discussion of potential “performance-based fees” Albion may earn. Generally, fees for advisory services are negotiable. The Adviser may waive or modify the management fees and other “performance-based fees” for Investors that are members, employees or affiliates of the Adviser, relatives of such persons, and for any other Investors, in its sole discretion. Organizational Expenses The Funds will bear, directly or through reimbursement of the Adviser (or its affiliates), all of the costs and all out-of-pocket expenses associated with the organization of the Fund and the syndication of interests therein, including, without limitation, offering, legal, compliance, accounting, travel, consulting and filing expenses.(collectively, “Organizational Expenses”). All Organizational Expenses paid or reimbursed by

any Fund in excess of such Fund’s pro rata share of the cap on Organizational Expenses may result in an offset against the management fee, as further described in the respective Fund’s Offering Documents. Partnership Expenses Each Fund will generally pay all expenses attributable such Fund’s activities and investments (“Partnership Expenses”), including, but not limited to: (i) Organizational Expenses; (ii) legal, accounting, audit, financial administration (including third-party administrators) custodial and other professional fees as well as consulting fees relating to services rendered to such Fund; (iii) banking, brokerage, broken-deal, registration, qualification, finders, depositary and similar fees or commissions; (iv) fees, due diligence costs and other costs, expenses and liabilities incurred in identifying, evaluating, acquiring, holding, valuing, restructuring and disposing of portfolio investments, including all fees and expenses of legal counsel and financial advisers incurred in connection therewith, all fees, costs and expenses for research and subscription services incurred in connection therewith, all travel costs and other transaction-related expenses; (v) transfer, capital and other taxes, duties and costs incurred in acquiring, holding, selling or otherwise disposing of Partnership assets; (vi) the fees and expenses of retaining any third party to manage, service or collect any portion of such Fund’s assets or assets held by the Adviser’s affiliates (including the applicable general partner) for the benefit of the Fund; (vii) insurance premiums, indemnifications, costs of litigation (whether actual, threatened or otherwise anticipated), costs of mediation or other dispute resolution processes and other extraordinary expenses; (viii) costs of financial statements and other reports to the Investors (including, expenses associated with the preparation or distribution of Partnership-related or investment-related financial statements, tax returns, tax estimates, Schedule K-1s, investor information portals or websites through which such reports are distributed) as well as costs of all governmental returns, reports and other filings, including Form PF; (ix) costs of meetings of the Investors (including the reasonable travel and other out-of-pocket costs incurred by the Adviser and its affiliates in attending such meetings); (x) costs of the advisory board (if applicable); (xi) interest expenses; (xii) financing and borrowing costs; (xiii) advertising and public notice costs; (xiv) costs with respect to the dissolution, winding up, or termination of such Fund; (xv) the Management Fee; (xvi) placement agent fees (provided that any placement agent fees will either (A) reduce, on a dollar for dollar basis, the Management Fee otherwise payable to the Adviser or its affiliates, or (B) be paid by the Adviser or its affiliates and not charged as an expense); and (xvii) any other expenses not listed in the preceding clauses (i) through (xvi) that are not normal operating expenses of the Adviser and/or its affiliates. Except as set forth above, the Adviser and its affiliates (including, without limitation, the general partners of the Funds) are responsible for their own day-to-day operating expenses, such as compensation of their staff and the cost of office space, office equipment, communications, utilities and other normal overhead expenses. In all cases, details concerning applicable fees and expenses will be set forth in each respective Client’s Offering Documents.

Albion currently provides investment management services to the Funds. Albion pursues equity and equityrelated investments primarily in global defense companies. There is no assurance that any Fund will achieve its investment objectives. An investment in any Fund is a speculative investment and is not intended as a complete investment program. It is designed for sophisticated investors who fully understand and can bear the risk of an investment in the Fund. No guarantee or representation is made that any Fund will achieve its investment objective or that Investors will receive a return of any of their capital. Prospective Investors should consult their own legal, tax and financial advisors as to all these risks and as to an investment in a Fund generally. Detailed information regarding the investment strategies of the Fund is contained in the applicable Offering Documents. Investors should not consider an investment in any Fund without fully understanding the Fund’s investment strategy. Each Fund’s strategy involves a number of material risks, including, but not limited to: the lack of a liquid public market for investments and therefore a restricted ability to sell positions; the severe restriction on the ability of Investors in the Fund to withdraw their capital; and the ability of Albion and its investment professionals to correctly identify and assess good investment opportunities, particularly given the often early stage of development of the businesses invested in, their frequent need for additional capital and the often rapidly shifting dynamics and intense competition that characterize the industries in which they operate. Additional material risks likely applicable to Albion’s investment strategy (and securities the Funds invest in) include, but are not limited to, the following (capitalized terms not defined herein shall have the meanings ascribed to them in the Fund’s Offering Documents): RISK OF LOSS. An investment in the Fund is speculative and involves significant risk. The profitability of the Fund depends on the Investment Manager correctly assessing the future price movements of the securities, commodities and other financial instruments in which the Fund invests and the movement of interest rates. These price movements may be volatile and are subject to numerous factors which are neither within the control of nor predictable by the Investment Manager. Such factors include, without limitation, a wide range of economic, political, competitive, market, legal, operational and other conditions or events (including, without limitation, natural disasters, acts of terrorism or war) which may affect investments in general or a specific security, commodity or other financial instrument in which the Fund invests. There can be no assurance that the Investment Manager will be successful in accurately predicting price movements. Accordingly, Limited Partners may incur substantial losses on their investments in the Fund, and it is possible that the Fund’s performance will fluctuate substantially from period to period. COMPETITION. The securities industry, the various markets in which the Investment Manager participates and the varied strategies and techniques engaged in by the Investment Manager are extremely competitive and each involves a high degree of risk. The Fund and the Investment Manager compete with firms, including, without limitation, many of the larger securities and investment banking firms, which have substantially greater financial resources and larger research staffs and more traders than the Investment Manager, which may place the Fund at a competitive disadvantage. MARKET VOLATILITY. The profitability of the Fund depends upon the Investment Manager correctly assessing the future price movements of stocks, bonds, options on stocks, other securities, currencies, regulated futures contracts and other commodities and the movements of interest rates. There can be no

assurance that the Investment Manager will be successful in accurately predicting price and interest rate movements. UNCERTAIN ECONOMIC, SOCIAL AND POLITICAL ENVIRONMENT. Consumer, corporate and financial confidence may be adversely affected by current or future tensions around the world, fear of terrorist activity and/or military conflicts, localized or global financial, public health or other crises or other sources of political, social or economic unrest. Such erosion of confidence may lead to or extend a localized or global economic downturn. Further, the outcomes of U.S. elections create uncertainty with respect to legal, tax and regulatory regimes in which the Fund, the General Partner, the Investment Manager and their affiliates may operate. A climate of uncertainty may reduce the availability of potential investment opportunities and increase the difficulty of modeling market conditions, potentially reducing the accuracy of financial projections. Any significant changes in, among other things, economic policy (including with respect to interest rates and foreign trade), the regulation of the asset management industry, tax law, immigration policy and/or government entitlement programs could have a material adverse impact on the Fund and its investments. In addition, limited availability of credit for consumers, homeowners and businesses, including credit used to acquire businesses, in an uncertain environment or economic downturn may have an adverse effect on the economy generally and on the ability of the Fund to execute its strategy. This may slow the rate of future investments by the Fund and result in longer holding periods for investments. For example, Russia’s large-scale invasion of Ukraine on February 24, 2022 has led to various countries, including the United States, imposing economic sanctions on certain Russian individuals and Russian corporate and banking entities. A number of jurisdictions have also instituted broader sanctions on Russia, including banning Russia from global payments systems that facilitate cross-border payments. The sanctions are broad and will likely cause declines in the value and liquidity of Russian securities, downgrades in the credit ratings of Russian securities, devaluation of Russia’s currency, and increased market volatility and disruption in Russia and throughout the world, including in the United States. Sanctions and similar measures, such as banning Russia from financial transaction systems that facilitate international transfers of funds, could limit or prevent the Fund from selling and buying impacted securities both in Russia and in other markets. Such measures will likely cause significant delay in the settlement of impacted securities transactions or prevent settlement altogether. The lack of available market prices for such securities may cause the Fund to use fair value procedures to value certain securities. The consequences of the war and sanctions may negatively impact other regional and global economic markets in which the Fund participates. Additionally, Russia may take counter measures or engage in retaliatory actions—including cyberattacks and espionage—which could further disrupt global markets and supply chains, adversely impacting the Fund’s operations. Companies in other countries that do business with Russia and the global commodities market for oil and natural gas, especially, will likely feel the impact of the sanctions. These sanctions, together with the potential for a wider armed or cyber conflict, could increase financial market volatility globally, including in the United States, and, as a result, negatively impact the Fund’s performance beyond any direct exposure to Russian issuers or securities. GOVERNMENT ECONOMIC INTERVENTIONS. In response to turmoil in the financial markets beginning in 2020 following the COVID-19 pandemic, the U.S. Government, Federal Reserve, U.S. Treasury and other governmental and regulatory bodies have taken a number of actions designed to stabilize the financial markets, including the enactment of the Families First Coronavirus Response Act and the Coronavirus Aid, Relief and Economic Security Act, both of which are sweeping stimulus bills intended to bolster the U.S. economy and provide emergency assistance to qualifying businesses and individuals. There can be no assurance that, in the long term, these actions will improve the efficiency and stability of U.S. financial markets. To the extent the financial markets do not respond favorably to any of these actions or such actions do not function as intended, the Fund’s financial performance may be harmed. In addition, because the programs are designed, in part, to improve the markets for certain of the Fund’s target assets, the establishment of these programs may result in increased competition for attractive opportunities in the Fund’s target assets or, in the case of government-backed refinancing and modification programs, may have

the effect of reducing the revenues associated with certain of the Fund’s target assets. Such policy changes may expose fixed-income and related markets to heightened volatility and may reduce liquidity for certain Fund investments, which could cause the value of the Fund’s investments and net asset value to decline. If the Fund invests in derivatives tied to fixed income markets, it may be more substantially exposed to these risks than a fund that does not invest in derivatives. The U.S. Government, the Federal Reserve, the U.S. Treasury and other governmental and regulatory bodies may take additional actions in the future to address the financial crisis and stimulate the economic recovery. The Investment Manager cannot predict whether or when such actions may occur, and such actions could have an adverse effect on the Fund’s business, results of operations and financial condition. LIQUIDITY. Many of the investments that are made by the Fund will lack liquidity. Accordingly, the Fund’s ability to respond to market movements may be impaired and the Fund may experience adverse price movements upon liquidation of its investments. Furthermore, the Investment Manager may invest in securities, commodity futures or other financial instruments that are thinly traded. This could present a problem in realizing the prices quoted and in effectively trading the position(s). In many situations, the Investment Manager may invest in illiquid investments which could result in significant loss in value should the Investment Manager be forced to sell the illiquid investments as a result of rapidly changing market conditions or as a result of margin calls or other factors. ACCURACY OF PUBLIC INFORMATION. The Investment Manager selects investments for the Fund, in part, on the basis of information and data filed by issuers with various government regulators or made directly available to the Investment Manager by the issuers or through sources other than the issuers. Although the Investment Manager evaluates all such information and data and ordinarily seek independent corroboration when the Investment Manager considers it is appropriate and reasonably available, the Investment Manager is not in a position to confirm the completeness, genuineness or accuracy of such information and data, and in some cases, complete and accurate information is not available. INVESTMENTS IN UNDERVALUED SECURITIES. The Investment Manager may seek to invest in undervalued securities. The identification of investment opportunities in undervalued securities is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. While investments in undervalued securities offer the opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Returns generated from the Fund’s investments may not adequately compensate for the business and financial risks assumed. The Fund will make certain speculative investments in securities which it believes to be undervalued, however, there are no assurances that the securities purchased will in fact be undervalued. In addition, the Fund may be required to hold such securities for a substantial period of time before realizing their anticipated value. During this period, a portion of the Fund’s assets would be committed to the securities purchased, thus possibly preventing the Fund from investing in other opportunities. PREFERRED AND HYBRID SECURITIES RISKS. The Fund may invest in preferred stock and hybrid securities, which may have special risks. Preferred and hybrid securities may include provisions that permit the issuer, at its discretion, to defer distributions for a stated period without any adverse consequences to the issuer. If the Fund owns a preferred or hybrid security that is deferring its distributions, the Fund may be required to report income for tax purposes even though it has not yet received such income. Some preferred and hybrid securities are non-cumulative, meaning that the dividends do not accumulate and need not ever be paid. There is no assurance that dividends or distributions on non-cumulative preferred securities in which the Fund invests will be declared or otherwise made payable or paid. Preferred and hybrid securities are subordinated to bonds and other debt instruments in an issuer’s capital structure in terms of priority to corporate income and liquidation payments and, therefore, will be subject to greater credit risk than more senior debt instruments. Because preferred stock and hybrids are generally junior to debt securities and other obligations of the issuer, deterioration in the credit quality of the issuer will cause

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As described in Item 4, Albion currently provides discretionary investment advisory services to its Funds, which are generally organized as limited partnerships and limited liability companies under the laws of the State of Delaware. Albion may provide investment advisory services to similarly organized Funds in the future. Interests in the Funds are currently limited to highly sophisticated investors who are both “accredited investors” as defined in the Securities Act of 1933, as amended (the “Securities Act”), and “qualified purchasers” as defined in the Investment Company Act of 1940, as amended (the “Company Act”). Accordingly, future Investors may include high net worth individuals and a variety of institutional investors (e.g., trusts, employee benefit plans, endowments, foundations, corporations, and other types of entities, including private funds of funds) meeting the terms of the exceptions and exemptions under which the Funds operate. In addition, employees and other persons associated with Albion and/or its affiliates may be Investors in the Funds. The Adviser and/or its affiliates retain absolute discretion to admit or deny any potential Investor in any of the Funds. Once an Investor has invested in a Fund, it generally will not be able to pledge, assign, sell, exchange, or transfer its interest (or any portion thereof) in the Fund, and no assignee, purchaser or transferee may be admitted as a substitute investor, except with the consent of Albion, which consent may be given or withheld in its sole and absolute discretion. Albion expects each Fund to qualify for exclusion from the definition of “investment company” under the Company Act pursuant to either Section 3(c)(1) or Section 3(c)(7) thereunder, and to offer interests to potential investors pursuant to Regulation D or Regulation S under the Securities Act. This Brochure is designed solely to provide information about Albion and should not be considered to be an offer of interests in any Fund or any future Client. Any such offer may be made only by delivery to the prospective investor of the applicable Offering Documents. Investors considering an

investment in any Fund should consult with their own investment, tax and/or legal consultants prior to investing.

Albion (or an affiliate or subsidiary) charges the Funds “performance-based fees.” Albion anticipates any such “performance-based fees” to be generally no less than fifteen percent (15%) of the net profits attributable to each Investor in the Fund, but this amount is subject to increase or decrease based on whether certain return thresholds are met. Some Funds have “performance-based fees” that increase from fifteen percent (15%) if such Fund hits certain multiple of invested capital thresholds. The Adviser’s receipt of any “performance-based fees” (through its affiliates) is intended to align the Adviser’s interests with those of the Funds and to provide the Adviser with a greater incentive to manage

assets well. The nature of such compensation, however, creates a potential conflict of interest among the Adviser (and its affiliates), its associated persons, and its Clients. Specifically, such performance-based compensation may create an incentive for Albion to cause a Client to make investments that are riskier and more speculative than it would otherwise make. Further, because Albion may at some point have multiple Clients, at times it may need to allocate investment opportunities of limited availability across its Funds. In such situations, some accounts may offer higher management fees and/or performance-based compensation potential than others. In those instances, Albion may have an incentive to favor accounts for which it receives higher performance-based compensation since it will receive a greater profit if the investment generates a positive return. To ensure equitable treatment of all Clients irrespective of such fee considerations, Albion has adopted an investment allocation policy that sets out the criteria for determining allocations, the most important of which are investment objective and strategy, existing portfolio composition and available liquidity. Albion will seek to address any conflicts through careful vetting of investment opportunities by its investment professionals and disclosure of investments to limited partners through capital call notices and periodic reports. Additionally, the Principal and certain investment professionals of Albion will often invest in the Clients, both directly and indirectly (e.g., through general partner commitments or direct investments as limited partners), which is intended to align the interests of Albion and those of the Clients. Albion’s performance-based compensation is charged in compliance with Rule 205-3 under the Advisers Act. Detailed information regarding the carried interest borne by Investors in the Funds will be contained in the applicable Fund’s Offering Documents. Potential investors should not consider an investment in any Fund without fully understanding the Fund’s compensation structure.

Albion is not registered, and does not have an application to register, as a broker-dealer, a registered representative of a broker-dealer, a futures commission merchant (“FCM”), a commodity pool operator (“CPO”), or a commodity trading advisor (“CTA”). Certain of the Adviser’s affiliated entities will serve as general partners/managers to the Funds, and they will be subject to the Advisers Act pursuant to the Adviser’s registration in accordance with SEC guidance. These affiliated entities operate as a single advisory business together with the Adviser, serve as general partners/managers of the Funds, and generally share common owners, officers, partners, employees, consultants, or persons occupying similar positions. As a result of the foregoing, the Adviser, certain affiliated entities serving as general partners to the Funds, the Principal and their respective affiliates (the “Affiliated Parties”) may have conflicts of interests in allocating their time and activity between the Funds and other accounts, in allocating investments among the Funds and other accounts, and in effecting transactions for the Funds and other accounts, including ones in which the Affiliated Parties may have a greater financial interests. The Adviser and its affiliates will strive to act in a manner that it considers fair, reasonable and equitable in allocating its time and investment opportunities among the Funds and the other accounts.

Albion has adopted a code of ethics (the “Code”) and implemented procedures relating to personal securities transactions and insider trading that are designed to detect and prevent (or otherwise mitigate) actual conflicts of interest. The CCO or his designee, among other things, monitor employee trading relative to the Funds’ holdings/trading, companies from which Albion, its partners, or its employees receive material non-public information in an attempt to prevent employees from engaging in improper personal securities transactions and to otherwise detect and prevent potential conflicts of interest. All Albion employees are required to submit annual reports on all covered securities holdings transactions in accounts controlled either directly or indirectly. Submitted reports are reviewed by the CCO or his delegate. Violations of the Code are punishable by sanctions including fines and termination of employment. Albion, its partners, and/or its employees could give advice and take action for their own accounts or the Funds that differs from advice given, and action actually taken on behalf of the Funds. In addition, Albion partners and/or employees could invest in third-party private investment funds that invest in some of the same securities Albion invests in on behalf of the Funds. Further, from time to time, Albion, its affiliates, their employees, and/or their partners could have an investment position or interest in the same securities recommended to or owned by Albion. As such, Albion could purchase or sell for the Funds securities of an issuer in which Albion, its affiliates, their employees, and/or their partners also have an investment position or interest. Albion has established procedures within the Code and a personal trading policy, intended to limit conflicts of interest in cases where Albion, a related person or any employee, buys, sells or otherwise has an interest in securities recommended by Albion to its Funds. Albion, its partners, and/or its employees may come into possession of material non-public or other confidential information which, if disclosed, might affect an investor’s decision to buy, sell, or hold a security. Under applicable law, Albion, its partners, and its employees are prohibited from improperly disclosing or using such information for their personal benefit or for the benefit of any other third party. Accordingly, should Albion, its partners, and/or its employees come into possession of material non-public or other confidential information with respect to any company, they will generally be prohibited from communicating such information to, or using such information for the benefit of, the Clients. Albion has adopted a policy on insider trading in accordance with Section 204A under the Advisers Act, which

establishes procedures to prevent the misuse of material non-public information by Albion, its partners, and its employees. For additional information about the Code or to request a copy, please contact our CCO at (571) 321-5328 or mark.schneiderman@albionriver.com.

With respect to Albion’s private company securities transactions on behalf of its Funds, Albion may retain one or more broker-dealers or investment banks, the costs of which will be borne by the Funds and/or its portfolio companies. In determining to retain such parties, Albion will consider a variety of factors, including: (i) capabilities with respect to the type of transaction being contemplated; (ii) commissions or fees charged; (iii) reputation of the firm being considered; and (iv) responsiveness to requests for information. As a result, although Albion generally will seek reasonable rates for such services, the market for such services involves more subjective evaluations than public securities brokerage transactions, and the Funds may not pay the lowest commission or fee for such services. Albion will seek to obtain best execution for all transactions in public securities. To the extent purchase and sale orders can be aggregated, Albion will try to aggregate such orders as it deems appropriate and in accordance with the applicable Fund’s Offering Documents and in the best interests of such Fund. To the extent applicable, though unlikely, Albion will have the discretion to direct some brokerage business to brokers who refer Investors to its Funds. Because such referrals, if any, are likely to benefit Albion (but will provide an insignificant (if any) benefit to the Client), Albion will have a conflict of interest with its Clients when allocating brokerage business to a broker who has made such referrals. To prevent brokerage commissions from being used to pay referral fees, Albion will not allocate brokerage business to a referring broker unless it has been determined in good faith that the commissions payable to such broker are reasonable in relation to those available from non-referring brokers offering services of substantially equal value to the Client Account. Currently, Albion has no formal soft dollar arrangements in place. Albion may, in its discretion, deem it to be in the best interests of its Funds to reallocate or “cross” securities transactions between Funds. Albion maintains policies and procedures intended to limit the potential conflicts of interest inherent in these transactions. Cross transactions will only be effected if they are deemed to be in the best interests of the particular Clients involved and will be conducted in compliance with such policies and procedures and applicable law.

Albion does not receive an economic benefit from non-Clients in connection with Client transactions and does not compensate any person for Client referrals, nor does Albion anticipate doing either in the future.

The Adviser has no legal or disciplinary events to disclose.

Members of Albion’s investment team anticipate conducting regular reviews of the Funds’ portfolios to determine whether positions should be maintained in view of current market conditions and the rest of the Funds’ portfolio. Albion’s review may consider specific securities held, adherence to investment guidelines, and the Funds’ overall performance. The Investors will receive written reports as described in the Offering Documents. Albion will generally supply monthly or quarterly capital account balance statements and monthly or quarterly letters to Investors that may include investment and market summaries as well as the performance of each Fund (timing of which is dependent on the Fund). Each Investor will also receive a Schedule K-1 for tax purposes. To comply with Rule 206(4)-2 (the “Custody Rule”) of the Advisers Act, Albion will strive to provide annual audit reports to Investors within 120 days following each Fund’s fiscal year end.

Albion (or its affiliates) may offer certain Investors, upon verbal request or through written side letter agreements, additional information and reporting that other Investors may not receive, and such information may affect an Investor’s decision to request a withdrawal, to the extent permitted by the Funds, or transfer of its interests. Albion’s CCO, as relevant, will internally review the information provided to Investors in order to detect and prevent potential concerns with respect to information flow, such as a combination of enhanced transparency and liquidity that could benefit particular Investors to the detriment of other Investors.

Although Albion does not maintain physical custody of the Funds’ assets, under the Advisers Act, Albion will be deemed to have custody of the Funds’ assets because affiliated entities serving as the Funds’ general partners and/or managers will have the authority to access funds and securities (e.g., by deducting advisory fees from a Fund’s account). Therefore, Albion will be required to comply with certain “custody” requirements under the Advisers Act. To comply with these requirements, Albion will ensure that funds and securities of the Funds (except certain privately offered securities) are maintained in custodial accounts with “qualified custodians.” To further comply with custody requirements, Albion will require (1) the appointment of an independent public accounting firm that is registered with the Public Company Accounting Oversight Board to conduct an annual audit of the Funds’ financial statements; (2) distribution of the audited financial statements within 120 days of the fiscal year-end to each Investor in the Funds; and (3) upon liquidation of the Funds, the performance of a liquidation audit and distribution of the related financial statements to Investors promptly upon completion of such audit. Any securities not custodied at a qualified custodian will be held pursuant to the privately offered securities exception of the Custody Rule. Investors should carefully review the audited financial statements of the Funds upon receipt and should compare these statements to any account information provided by Albion. Management personnel will be available to assist in reviewing and understanding any such reports.

Albion provides investment advisory services to its Clients on a discretionary basis. Investment advice is provided directly to the Funds and not the Investors in the Funds. Albion has the authority to determine (i) the securities to be purchased and sold for the Funds, subject to the Funds’ investment restrictions, and (ii) the amount of securities to be purchased or sold for the Funds. The scope of such investment discretion is detailed in the applicable Fund’s Offering Documents. While the general partners and/or managers of the Funds are ultimately be responsible for the management, policies and operation of the Funds, they grant authority to Albion to make investment recommendations and monitor investments, as more fully described in the investment advisory agreements executed between such entities and the Funds at the outset of the advisory relationships. In all cases, however, this discretion is to be exercised in a manner consistent with the investment strategies and objectives of the Funds, as detailed in the applicable Offering Documents. When making investment recommendations, Albion observes the investment policies, limitations and restrictions that are applicable to the Funds.

To the extent Albion is deemed to having voting authority on behalf of the Funds’ securities and Albion actually exercises such authority, Albion will comply with policies and procedures reasonably designed to ensure that in cases where Albion votes proxies with respect to the Funds’ securities, such proxies are voted in the best interests of the Funds (the “Proxy Policy”). The Proxy Policy is designed to (i) identify any material conflicts of interest connected with a particular proxy vote and (ii) ensure that any vote where such conflicts are identified is not improperly influenced by the conflict. Albion understands the importance of proxy voting. For additional information about Albion’s proxy voting policies and procedures and information regarding how Albion voted any specific Fund’s proxies, please contact our CCO at (571) 321-5328 or mark.schneiderman@albionriver.com.

Albion does not (and will not) require or solicit the payment of fees six months or more in advance. Albion is not aware of having any financial condition that is reasonably likely to impair its ability to meet contractual commitments to the Funds. Albion has never been subject to any bankruptcy petition.