ALPINE ASSOCIATES MANAGEMENT INC.

Alpine is a Delaware corporation that was organized in 1984. Mrs. Victoria E. Zoellner is Alpine's sole shareholder and the Chairman of Alpine's Board of Directors. Alpine provides investment advisory services to institutions. Its clients consist primarily of a group of seven domestic limited partnerships, one offshore corporation and one offshore trust (together, the "Alpine Funds") that are managed by Alpine and its related persons. Alpine also acts as general partner for such seven domestic limited partnerships. Alpine's other clients are one UCITS fund and one corporation that gives Alpine trading authority over its individually managed account. One of the three directors of the corporate Alpine Fund is a related person of Alpine. Alpine Associates Services Inc. ("AAS"), an affiliate of Alpine, has approximately 26 employees engaged in various services assisting Alpine in managing Alpine's clients. Mrs. Zoellner is the sole shareholder and director of AAS. Alpine manages the investment portfolios of the Alpine Funds and the accounts of its other clients. Alpine's primary investment strategy is merger arbitrage. Alpine also uses an equity trading strategy that is closely related to merger arbitrage. These investment strategies are described further in Item 8 below under "Methods of Analysis, Investment Strategies and Risk of Loss". Alpine is not limited to these strategies, and there are no material restrictions on the particular types of investing in which Alpine may engage, the strategies it may employ or the securities or instruments in which it may cause its clients to invest. Alpine is the sole investment manager of each of the Alpine Funds and the sole general partner of each of the seven domestic Alpine Funds and therefore has broad investment authority with respect to the management of their accounts. The Alpine Funds and the accounts Alpine manages for its other clients generally trade and maintain their investment portfolios on a substantially parallel basis with each other. Certain clients may not participate in all parts of Alpine's investment strategies. Also, certain clients operate with lower levels of investment exposure in Alpine's strategies than the other clients, and one client operates with long market exposures in its equity trading strategy that are normally expected to be significantly greater than the exposures of the other clients. Since Alpine's clients generally trade and maintain their investment portfolios on a substantially parallel basis with each other, Alpine does not ordinarily tailor its advisory services to the individual needs of its clients or of investors in the Alpine Funds. For a client that is an individually managed account, Alpine may agree in the investment management agreement with the owner of such account to investment restrictions or guidelines with respect to the types or amounts of securities or other financial instruments that may be traded for such account. Alpine's general objective is to produce superior absolute returns with low volatility in all types of market environments. For one Alpine Fund, Alpine's objective is to produce superior absolute returns while experiencing less downside volatility than the stock market.

In general, Alpine seeks to produce stock market-like returns with substantially less risk and volatility over the long run than is historically associated with equity investments. Alpine works to reduce risk by seeking broad diversification, by devoting substantial ongoing efforts to quantifying the risk of its clients' investments, and by applying risk guidelines and prohibitions to both individual investments and portfolios. Investors and prospective investors in each Alpine Fund should refer to the confidential private placement memorandum, limited partnership agreement and/or other governing documents for such Alpine Fund (the "Governing Documents") for additional information on the investment objectives, risks and investment terms with respect to a particular Alpine Fund. The investment terms available to investors in the different Alpine Funds and Alpine's other clients vary in certain respects. There is no assurance that any of the investment objectives of Alpine's clients will be achieved. Alpine may enter into "side letters" or similar agreements with certain investors in the Alpine Funds granting the investor certain specific rights, benefits or privileges that are not made available to investors in the Alpine Funds generally. Alpine does not participate in any wrap fee programs. Alpine manages all client assets on a discretionary basis. As of January 31, 2026, the amount of assets in the Alpine Funds, the UCITS fund and the individually managed account managed by Alpine on a discretionary basis, determined based on their respective net asset values, was $1,189,528,093. As of January 31, 2026, Alpine provided discretionary investment advisory services to nine private investment funds, one UCITS fund and one individually managed account. Alpine may in the future provide advisory services, either on a discretionary or non-discretionary basis, to other funds or accounts.

Compensation and Fee Schedules All investors in the Alpine Funds should review the Governing Documents for each Alpine Fund in conjunction with this brochure for additional information on the fees and compensation payable with respect to a particular Alpine Fund. Alpine charges the Alpine Funds (and, indirectly, the investors in the Alpine Funds) fixed monthly management fees at annual rates based on a percentage of net assets under management, generally payable monthly in arrears. The management fees for the Alpine Funds vary. In addition, the Alpine Funds (and, indirectly, the investors in the Alpine Funds) also pay Alpine an annual performance allocation or fee based on a percentage of the amount by which the net value of each investor's account as of the end of each calendar year exceeds the net value of the account as of the beginning of the year. The performance allocations or fees for the Alpine Funds may vary. The performance allocation or fee for each investor is subject to a high-water mark loss carryforward. For investors in certain of the Alpine Funds, the performance allocation or fee is also subject to the investor having obtained a threshold level of appreciation in its account for current and prior years.

The management fee is usually deducted directly from the assets of each Alpine Fund as such fee becomes payable, which is generally monthly in arrears. The performance allocation or fee is payable annually in arrears, or upon withdrawal of capital from an Alpine Fund. Upon termination of any client account, all management fees accrued as of the date of termination will be payable. Alpine charges its other clients that are not Alpine Funds fixed monthly management fees at annual rates based on a percentage of net assets under management, generally payable monthly in arrears. The management fees for such other clients vary. In addition, such other clients also pay Alpine an annual performance fee based on a percentage of the amount by which the net value of the client's account as of the end of each calendar year exceeds the net value of the account as of the beginning of the year. The performance fees for such other clients vary. The performance fee for each such client is subject to a high-water mark loss carryforward. Such fees are billed to such other clients as they become payable, which is generally monthly in arrears for the management fee and annually in arrears or upon withdrawal of capital for the performance fee. Upon termination of such a client account, all fees accrued as of the date of termination will be payable. In certain circumstances, the advisory fees payable to Alpine by clients (or, indirectly, by the investors in an Alpine Fund) may be negotiable. Investors and prospective investors in each Alpine Fund should refer to the Governing Documents of the applicable Alpine Fund for additional information on the advisory fees charged by Alpine. Deduction of Fees Alpine is authorized under the Governing Documents to charge and deduct advisory fees directly from the assets of the Alpine Funds at the times and in the amounts described above. For clients that are individually managed accounts, Alpine normally bills such clients for its advisory fees at the times and in the amounts described above. Other Fees and Expenses Alpine, and not the private funds or any of the other entities that Alpine acts as investment manager for (referred to as the “Clients”), is responsible for providing all office personnel, office space and office facilities required for the performance of its services to the Clients (including personnel and facilities provided by Alpine Services), and for paying expenses and other costs related thereto (including fees, expenses and other costs of research, data and pricing services). The Clients (and, indirectly, the investors in the Clients) are responsible for all costs and expenses incurred in connection with their investments, including (without limitation) brokerage commissions; clearing and settlement fees, expenses and costs; fees, interest and other costs in connection with margin accounts and other indebtedness; borrowing charges on securities sold short; custodial fees; bank service fees; fees, expenses and other costs of any outside appraisers, accountants, attorneys or other experts or consultants (including, but not limited to, business advisory, compliance or cyber security consultants and managed service solutions) engaged by the Clients or Alpine; any legal fees, expenses and other costs (including settlement costs) arising in connection with portfolio investments; and any other expenses and costs related to the

purchase, sale or holding of the Clients’ investments (including expenses related to transactions that fail to close). The Clients (and, indirectly, their investors) also pay all of their operating costs, including (without limitation) costs of communication with or meetings of partners and other investors; legal, accounting, auditing and administrative fees, expenses and other costs, including costs of portfolio management, accounting, risk management and other investment-related software and third-party platforms that assist back-office functions such as margin management, bank balance and accrual monitoring; fees and expenses relating to information technology hardware, software or other technology (including costs of software licensing, implementation, data management and recovery services and custom development) used to research investments, evaluate and manage risk, facilitate valuations, facilitate accounting functions, facilitate compliance with the rules of any self-regulatory organization or applicable law (including reporting obligations), or otherwise manage the Clients and/or their investments, such as Bloomberg terminals, portfolio management systems, risk management systems, investor relations software and/or order management systems; withholding and transfer taxes; insurance costs; costs of preparing any required regulatory filings (including SEC Form PF and Schedules 13D and G, and AIFMD Annex IV); any legal fees, expenses and other costs (including settlement costs) arising in connection with any litigation by or against, or any regulatory investigation instituted against, the Clients or Alpine in connection with the affairs or operations of the Clients; fees, expenses and other costs of the Administrator; and any other expenses or costs related to operating the Clients. Alpine allocates expenses incurred on behalf of the Clients (including expenses related to investments among participating accounts, including some or all of the Clients), in proportion to their participation in the relevant investment, in proportion to their respective net asset values, or in any other manner determined by Alpine to be appropriate. Item 12 below under "Brokerage Practices" describes the factors Alpine considers in selecting or recommending broker-dealers and determining the reasonableness of their compensation. Timing of Payments Advisory fee payments are generally due monthly in arrears, or annually in arrears with respect to performance allocations or fees. Please refer to the Governing Documents of the Alpine Funds for additional information on the timing of advisory fee payments. Transaction-Based Compensation Neither Alpine nor its supervised persons will receive any compensation with respect to the purchase or sale of securities or other investment products by any client (including the Alpine Funds).

Methods of Analysis and Investment Strategies Alpine uses a variety of methods of analysis, including in particular fundamental and technical analysis. Alpine uses certain proprietary and external analytic methods. Alpine's principal sources of information include financial newspapers and other media, press releases and other public statements and materials distributed by issuers of securities and other parties, public periodic and other filings with the SEC and other government entities, research materials prepared by others or internally, contacts with other participants in relevant financial markets and industries, inquiries directed to issuers of securities and other parties and general industry knowledge. Investment Strategies Alpine's primary investment strategy is merger arbitrage. Alpine also uses an equity trading strategy that is closely related to merger arbitrage. Merger arbitrage is the purchase of securities of target companies in merger and acquisition (M&A) transactions, such as mergers, cash tender offers, exchange offers and other similar combinations. In an M&A transaction, an acquiring company will seek to purchase a target company. To make this purchase, the acquiring company may offer to pay the shareholders of the target company for their shares, either indirectly in a merger or similar transaction in which the shareholders exchange their shares for the payment being offered by the acquiring company, or directly via a tender offer or exchange offer made by the acquiring company to the target company's shareholders. Alpine's clients acquire target company

securities after an M&A transaction has been announced or otherwise becomes known to the public. It normally takes some period of time, ranging from about a month to a year or longer, for an M&A transaction to be completed. When an M&A transaction is successfully completed, the clients exchange or tender their target company securities. In return, the clients receive the payment offered by the acquirer. This may be cash, securities to be issued by the acquirer, or a combination of cash and such securities, depending on the terms of the transaction. When an acquirer offers a security to be issued by it in exchange for a target company security, the clients may simultaneously take offsetting short positions in the offered security that are covered with the newly issued acquirer securities when they are received. This strategy may also involve purchasing or selling options, swaps and other derivative instruments in order to enhance returns or limit risk. In its merger arbitrage strategy, Alpine mainly focuses on publicly announced transactions with definitive merger agreements. Alpine's clients may also invest in other types of merger and acquisition transactions, including hostile takeover bids and proposals, situations involving multiple competing bidders, buyout proposals from a company's management or a major shareholder, companies being pressured to initiate a merger and acquisition transaction by activist investors, and companies engaging in recapitalizations, self-tenders, spin-offs or other restructurings. Alpine's time-tested approach to merger arbitrage has been successfully applied by our experienced team in more than 5,000 M&A transactions over 49 years. Alpine's proprietary database, combined with fundamental and transaction research, and our long experience investing in M&A situations, enables us to manage our clients' merger arbitrage portfolios based on historical experience. Alpine's equity trading strategy mainly involves the creation of positions in connection with Alpine's merger arbitrage strategy. In a stock-for-stock M&A transaction, merger arbitrage investors will normally purchase shares of the company being acquired and sell short the shares of the acquirer stock they expect to receive upon completion of the transaction. Alpine's clients create open market exposures in the acquirers in stock-forstock mergers by purchasing shares of the companies being acquired and refraining from selling short all or a portion of such acquirer shares. In this way, the clients seek to take advantage of market dislocations caused by mergers and other extraordinary M&A transactions and events, using Alpine's proprietary database that has been generated from more than 49 years of M&A investing and relying on its long experience trading M&A situations and technical and fundamental analysis. Another part of the equity trading strategy involves hedging. From time to time Alpine may broadly hedge its total portfolio, one or more sections of its portfolio and/or the market exposure of its main equity trading strategy by using stock index futures, options or other derivative instruments or through short sales of specific stocks or other securities. Alpine does not intend to maintain a strictly market neutral position and may be either net long or net short at any given time.

From time to time, Alpine may also engage in general equity trading, building on its arbitrage research together with technical and fundamental analysis. The equity trading strategy mainly involves the purchase and sale of actively traded common stocks. In this strategy Alpine may also trade in stock index futures and other derivatives, options, preferred stocks, corporate and government bonds, swaps, other securities and financial instruments and currencies, in connection with hedging or other investment techniques. Material Risks Although investments in an Alpine Fund or another client or in an account managed by Alpine may result in significant returns to investors in the Alpine Funds and the other clients of Alpine, they also involve a substantial degree of risk. Alpine generally only accepts clients, and the Alpine Funds and Alpine's other clients generally only accept investors, that are able to bear the financial risk of Alpine's investment strategies for an indefinite period of time and are able to sustain the loss of all or a significant part of their investment. The investment strategies employed by Alpine on behalf of its clients involve significant risks. Prospective clients and investors in the Alpine Funds or Alpine's other clients should carefully review the risk factors described below (and the risks described in the Governing Documents for the relevant Alpine Fund), and should evaluate the merits and risks of an investment in the context of their overall financial circumstances. The risk factors below are not intended to be exhaustive and should be considered carefully by prospective investors together with the full text of the applicable Governing Document. Investment and Trading Risks in General All investments risk the complete loss of the amount invested. No guarantee or representation is made that any investment program will be successful, and investment results may vary substantially over time. The value of a client's portfolio and the income (if any) derived from it can go down as well as up. Alpine's investment program will utilize investment techniques such as futures, options, derivatives, margin transactions and short sales, which practices can, in certain circumstances, maximize the adverse impact to which Alpine's clients may be subject. Merger Arbitrage Alpine's primary investment strategy is merger arbitrage. This strategy may involve substantial risks. The prices of securities of companies involved in merger arbitrage transactions are often volatile, and market movements are difficult to predict. Unforeseeable events may cause sharp market fluctuations against the positions held by Alpine's clients, sometimes causing substantial losses. The principal risk involved in the merger arbitrage strategy is that mergers and other M&A transactions may not be completed. Successful consummation of an arbitrage transaction

may depend on many factors, such as shareholder approval, the outcome of litigation seeking to enjoin it (including, for example, government action on the grounds of alleged violations of antitrust or other federal or state laws), the approval of regulatory or tax authorities, the availability of financing or the absence of material adverse change in the business or financial condition of the companies involved in it. Any such factor may cause a transaction to be significantly delayed, or result in the transaction not being consummated, in which event substantial losses may be incurred. In particular, hostile offers by one company for securities of another company are frequently met by defensive tactics such as protracted litigation to enjoin the offer based on assertions of violations of federal or state securities laws, antitrust violations, and other grounds. Target companies' managements may also seek defensive merger partners or engage in other extraordinary defensive actions. Prices of securities of companies involved in merger arbitrage combinations are often volatile, and market movements are difficult to predict. Unforeseeable events may cause sharp market fluctuations in the positions held by Alpine's clients, sometimes causing substantial losses. Alpine's clients frequently purchase securities at prices only slightly lower than the price being offered for them in an exchange or tender offer or a merger. This purchase price often represents a substantial premium over the market price of the security prior to the announcement of the proposed transaction. As a result, the profit that Alpine's clients would make if an arbitrage deal is consummated is usually small in relation to the amount they stand to lose if such deal is not completed. In a stock-for-stock M&A transaction, Alpine's clients may sell short the shares of acquirer stock they expect to receive in the transaction or refrain from selling short all or a portion of such shares. When clients sell short such shares, such shares may increase in price and the transaction may not be completed, resulting in a loss for the clients. When clients refrain from selling short such shares, risks exist with respect to the open market exposure of the acquirer's stock expected to be received in the transaction. The clients will be exposed to adverse changes in the price of such shares. If such shares increase in price, the clients may not benefit unless the transaction is completed. The terms of certain stock-for-stock combinations may make it difficult for an arbitrage investor to accurately anticipate the amount of securities to be received. Another variable exists in offers that are made partly for cash and partly for securities, either simultaneously or in a multi-step transaction. The value of the securities offered may differ from the cash portion. An investor accepting such an offer may not be able to accurately predict whether it will receive cash or securities or the amount of cash or securities to be received. Also, merger arbitrage investing typically involves investing in long and short positions in common stocks and other equity instruments. See the discussion below in the following three paragraphs.

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Types of Clients Alpine provides advice to the Alpine Funds, which are pooled investment vehicles operated under the exemptions under either Section 3(c)(1) or Section 3(c)(7) of the Investment Company Act of 1940, as amended (the "Investment Company Act"). Investors in the

Alpine Funds may include high net worth individuals, corporations, partnerships, trusts, endowments, foundations, estates, pension and profit sharing plans and other institutions. Alpine also provides investment management services to one UCITS fund and also to corporations and other institutional investors through separately managed accounts. Minimum Investment Requirements Alpine and its related persons require that each investor in each of the Alpine Funds be an "accredited investor" as defined in Regulation D under the Securities Act of 1933, as amended. In addition, each investor in an Alpine Fund operating under Section 3(c)(1) of the Investment Company Act is required to be a "qualified client" as defined in Rule 2053(d)(1) under the Advisers Act, and each investor in an Alpine Fund operating under Section 3(c)(7) of the Investment Company Act is required to be a "qualified purchaser" as defined in Section 2(a)(51) of the Investment Company Act. Minimum investment amounts in the Alpine Funds are determined from time to time by Alpine. Generally, Alpine will not advise an individually managed account unless it has a net asset value of at least $30,000,000.

Performance-Based Fees Alpine ordinarily receives a performance-based special allocation of profits or fee from each of its clients (including the Alpine Funds) as described in Item 5 above under "Fees and Compensation." Different clients may be subject to different performance-based compensation arrangements. Please refer to the Governing Documents of each Alpine Fund for additional information about the performance-based fee arrangements of each Alpine Fund. The performance-based compensation arrangements discussed above comply with Rule 205-3 under the Investment Advisers Act of 1940 (the "Advisers Act"). Performance-based compensation arrangements received by Alpine or by related persons of Alpine may create an incentive for Alpine to recommend investments that may be riskier or more speculative than those that would be recommended under a different fee arrangement. Side-by-Side Management Situations may occur where Alpine is entitled to receive a higher percentage of the net profits of the account of one client or one investor in a client than the percentage that Alpine receives from another client or investor. In such situations, Alpine may have an incentive to favor, or to allocate certain riskier or more speculative investments to, the client that is subject to the higher percentage or that has investors that are subject to the higher percentage. However, as noted in Item 4 above under "Advisory Business", Alpine's clients generally trade and maintain their investment portfolios on a substantially parallel basis. Alpine will, as a policy, allocate all investment opportunities among its clients in a manner that it considers fair and equitable to all clients, and no client will be improperly favored over any other client. In general, transactions will be executed, to the extent reasonably practicable, for all of Alpine's clients at substantially the same times and prices. Alpine may also cause particular clients to execute transactions on a stand alone basis in situations where a client's equity capital has increased or decreased and otherwise in circumstances deemed appropriate by Alpine. Among the factors that may be considered by Alpine in allocating trades among client accounts are: investment policies, guidelines or restrictions applicable to each specific client; tax considerations; cash availability; liquidity requirements for payment of redemptions or other purposes; risk tolerances; restrictions under ERISA or other applicable laws or regulations; available credit lines; counterparty arrangements; account size; and hedging objectives and activity.

Registered Broker-Dealers None of Alpine or any of its management persons are registered with the SEC as brokerdealers. Registered Futures Commission Merchants, Commodity Pool Operators and Commodity Trading Advisors None of Alpine or any of its management persons are registered as a registered futures commission merchant, commodity pool operator or commodity trading advisor. Relationships with Related Persons The principal clients of Alpine at present are the Alpine Funds, each of which is a pooled investment vehicle exempt from registration under the Investment Company Act. Alpine is the investment manager of each of its clients. Alpine also is the general partner of seven of the Alpine Funds.

Mrs. Victoria E. Zoellner is the sole shareholder and the Chairman of the Board of Directors of Alpine and is also the sole shareholder and director of AAS. In addition, three of the four directors of Alpine are Alpine employees and most of the senior officers of Alpine are also senior officers of AAS and of certain of the Alpine Funds. See Items 4 and 5 above under "Advisory Business" and "Fees and Compensation" for additional information about the relationships among Alpine and AAS. Employees of Alpine and its affiliates may serve as officers, advisors or in comparable management functions for portfolio companies in which Alpine's clients invest, or provide other services to portfolio companies, and may receive compensation in connection therewith. Employees of Alpine may also from time to time serve on the board of directors or a creditors committee of a portfolio company, or be given access for other reasons to confidential information relating to companies in which Alpine's clients invest. As a result, Alpine's clients may, under certain circumstances, be prohibited for a period of time from engaging in transactions with respect to the debt or securities of such a portfolio company, which prohibition may have an adverse effect on Alpine's clients. Selection or Recommendation of Other Advisers Alpine does not recommend or select other investment advisers for its clients or receive compensation from such advisers in a manner that would create a material conflict of interest. Alpine does not have other business relationships with other advisers that create a material conflict of interest.

Trading Code of Ethics Alpine has adopted a Code of Ethics under Rule 204A-1 of the Advisers Act expressing Alpine's commitment to ethical conduct. Alpine's Code of Ethics describes its fiduciary duties and responsibilities to its clients, and sets forth Alpine's policies for implementing such duties and responsibilities. Under Alpine's Code of Ethics, all supervised personnel have a duty to act only in the best interests of Alpine's clients. Alpine has appointed a Chief Compliance Officer (the "CCO") who is responsible for maintaining and administering the Code of Ethics. All potential violations of the Code of Ethics must be promptly reported to the CCO. It is the expressed policy of Alpine that no person employed by Alpine shall prefer his or her own interest to that of an advisory client. The Code of Ethics contains policies and procedures with respect to personal securities transactions by employees and related accounts that are designed to prevent front-running, scalping, the misuse of inside information and other improper activities. Employees who are involved in Alpine's investment activities or who have access to non-public information regarding Alpine's clients must arrange for all statements and trade confirmations for their personal brokerage accounts to be directly delivered by their brokers to the CCO (or a designee) and must also report all personal transactions to the CCO (or a designee) on at least a quarterly basis. The CCO (or a designee) monitors all transactions by employees in

order to identify any pattern of conduct that may evidence conflicts or potential conflicts with the principles and objectives of the Code of Ethics, or other inappropriate behavior. Alpine requires that all individuals act in accordance with all applicable federal and state regulations governing investment advisory practices. Alpine's Code of Ethics also includes the firm's policy prohibiting the use of material non-public information. Any individual not in observance of the above may be subject to discipline or termination. Alpine will provide a complete copy of its Code of Ethics to any client or prospective client or any investor or prospective investor in an Alpine Fund upon request. To make such a request, please contact Alpine’s CCO at the address or telephone number listed on the first page of this document. Participation or Interest in Client Transactions; Personal Trading Alpine's sole shareholder and certain of its employees and affiliates are investors in some of the Alpine Funds. In certain situations, related persons of Alpine may purchase interests in portfolio investments held by one or more Alpine clients. All such purchases are subject to compliance with Alpine's Code of Ethics as described above. Moreover, from time to time, Alpine may cause an Alpine Fund to engage in "cross trades" via the purchase of a portfolio investment from or sale of a portfolio investment to another Alpine Fund, provided that the sale or purchase is consistent with Alpine's fiduciary obligations to each Alpine Fund.

Subject to the investment objectives, policies and restrictions of each Alpine Fund as set forth in its Governing Documents, Alpine has discretionary authority to determine the type, amount, and price of securities and investments to be bought and sold on behalf of each Alpine Fund, including the selection of, and commissions paid to, brokers. Research and Other Soft Dollar Benefits Alpine selects brokers and dealers to execute transactions for client accounts based on the expected benefits and costs of their services as compared to others in the marketplace. Alpine attempts at all times to achieve best execution. Alpine may take into account special expertise or capacities of a particular broker as well as research and other services provided to Alpine by brokers. Alpine considers such factors as price, the ability to effect the transactions, the brokers' or dealers' facilities, reliability and financial responsibility, special execution capabilities, block trading and block positioning capabilities, willingness to execute related or unrelated difficult transactions in the future, efficiency of execution and error resolution, quotation services, the availability of stocks to borrow for short trades, custody, recordkeeping and similar services, and any research or related services provided by such brokers or dealers (including providing access to the managements of portfolio companies). Alpine does not necessarily solicit competitive bids and does not have an obligation to seek the lowest available commission cost. In limited circumstances, Alpine

may cause a higher commission to be paid to a broker or dealer that furnishes research or other services than might be charged by another broker or dealer for effecting the same transaction, provided that Alpine determines in good faith that the amount of commissions charged is reasonable in relation to the value of the brokerage and research or other services provided by such broker or dealer. Research services provided to Alpine by brokers may include written information and analyses concerning specific securities, companies or sectors (whether produced by the broker or a third party); market, financial and economic studies and forecasts (whether produced by the broker or a third party); statistics and pricing services; databases; discussions with research personnel; and other news, technical and telecommunications services utilized by Alpine in the investment management and execution process. Alpine does not generally receive any benefits outside the safe harbor under Section 28(e) of the Securities Exchange Act of 1934, as amended, for the use of commissions or "soft dollars" to obtain "research and execution" services. Research services provided by brokers may be used for the benefit of all clients of Alpine. Clients may pay higher commissions than are obtainable from other brokers as a result of the consideration of research services as a factor in selecting brokers in addition to commission cost and best execution. Alpine's use of client brokerage commissions to obtain research services is a benefit to Alpine because Alpine does not have to produce or pay for such research services. This may result in an incentive for Alpine to select or recommend a broker-dealer based, in part, on the interest of Alpine in receiving such research services, rather than exclusively on the interest of Alpine's clients in receiving most favorable execution. Alpine and its affiliates may have other business arrangements with brokers and dealers used to execute transactions for clients. Various brokerage firms used to execute transactions for Alpine's clients and such firms' affiliates and employees have made investments in the Alpine Funds, referred investors to the Alpine Funds or Alpine's other clients, and referred clients to Alpine, and may in the future make such investments and referrals. Certain of such brokerage firms also provide prime broker and financing and other services to such clients. Although such investments, referrals and services may give rise to potential conflicts of interest, Alpine does not consider such investments, referrals or services to be a material factor influencing its selection of executing brokers or prime brokers for its clients. Brokerage firms and their employees may offer gifts to employees of Alpine, and may invite employees of Alpine to entertainment and social events. It is Alpine's policy that factors such as gifts and entertainment that do not benefit client accounts should not be considered when selecting brokers and counterparties to execute transactions for clients. Brokerage for Client Referrals Subject to Alpine's obligation to seek best execution of all transactions for its clients, Alpine may consider referrals of clients to Alpine and its affiliates or investors to the Alpine Funds or Alpine's other clients in determining its selection of broker-dealers. Alpine may have an incentive to select or recommend a broker-dealer based on its interest in receiving

investor referrals, rather than on its clients' interest in receiving the most favorable execution. Directed Brokerage Alpine does not recommend, request or require that a client direct it to execute transactions through a specified broker-dealer. Alpine does not permit its clients to direct brokerage through a specified broker-dealer. Trade Aggregation Alpine has established allocation and aggregation procedures for the allocation of portfolio investment transactions among its clients. The allocation and aggregation procedures are designed to ensure that each client is treated fairly and that transactions are allocated in a manner that is fair and equitable to each client relative to the other clients, taking into account all relevant facts and circumstances. Alpine's clients generally trade and maintain their investment portfolios on a substantially parallel basis with each other. Orders to buy or sell the same security for multiple clients are ordinarily placed on an aggregated basis and typically allocated proportionately to each participating client, taking into consideration the size of the order placed, investment restrictions, if any, and any other relevant factors (including the size of each client and the level of each client's investment exposure for such security). Please see Item 6 above under "Performance-Based Fees and Side-by-Side Management" for additional information about how orders for clients may be placed. Each client that participates in an aggregated order will generally participate at the average of all prices at which the order is filled. In certain situations a client may not be in a position to participate in a joint order with Alpine's other clients, for regulatory or other reasons. In such situations, Alpine will ordinarily complete the order for its other clients first, and then execute a substantially equivalent order for the client that is unable to participate jointly. This may disadvantage the client that is unable to participate jointly with respect to the prices at which its order is executed and the quantities of securities and instruments it may be able to buy and sell. Alpine may place orders for its clients in such order and in such other manner as it deems appropriate.

Economic Benefits Received from Third Parties Alpine does not receive any economic benefit for providing advisory services to its clients from any person that is not a client. Third Party Compensation for Client Referrals Alpine or its affiliates may enter into arrangements with third parties whereby Alpine or its affiliates will pay to third parties who introduce clients to Alpine or its affiliates a portion of the advisory fee received by Alpine or its affiliates from such clients. Such arrangements will be disclosed to Alpine's clients in accordance with, and otherwise comply with, Rule 206(4)-3 under the Advisers Act. Alpine and its affiliates may enter into cash compensation arrangements with unaffiliated placement agents or third parties for introducing investors to an Alpine Fund or Alpine's other clients. An investor in an Alpine Fund or other client will not be charged any additional amount or bear any additional charges as a result of an introduction through a placement agent or other unaffiliated third party. As described in Item 12 above under "Brokerage Practices", Alpine may also consider referrals of clients to Alpine and its affiliates and of investors to the Alpine Funds or other clients in determining its selection of broker-dealers for securities transactions. Alpine endeavors at all times to put the interests of its clients first as part of Alpine's fiduciary duty. Nevertheless, the receipt of compensation by placement agents and the potential receipt of brokerage commissions by broker-dealers creates a potential conflict of interest, and may affect the judgment of placement agents and broker-dealers when making referrals to Alpine, the Alpine Funds or Alpine's other clients. Moreover, a potential conflict of interest may arise between the interests of Alpine's clients in obtaining best price and execution and Alpine's interest in receiving future referrals to the Alpine Funds and its other clients. Alpine will address this conflict of interest by seeking to obtain best execution, as discussed in the section titled "Brokerage Practices".

Alpine and its management persons have not been the subject of any material legal proceeding required to be disclosed in response to this item.

Review of Client Accounts Alpine periodically monitors portfolio investments on behalf of each Alpine client. Generally each client portfolio is reviewed at least weekly. Investments are reviewed in the context of each client's (i) adherence to the investment objectives and guidelines as set forth in the Governing Documents of each Alpine Fund or the investment management agreement of each client that is not an Alpine Fund; and (ii) the client's investment performance.

Each review is conducted by one of Alpine's trading personnel, under the supervision of Alpine's Chief Executive Officer. Reports to Clients Investors in the Alpine Funds receive annual audited financial statements. In addition, monthly unaudited account statements are available to investors by email. Account statements are provided by JPMorgan Chase Bank N.A., the administrator for the Alpine Funds. Clients that are not Alpine Funds receive account statements from the custodians or prime brokers having custody of such accounts at such frequencies as the clients and prime brokers may agree.

Alpine will not have physical custody of any client assets. All assets of the Alpine Funds and other client accounts will be held by a qualified custodian unrelated to Alpine (except for certain non-transferable, uncertificated book entry instruments that are not required to be held by a custodian). Alpine may be deemed to have custody of the assets of the Alpine Funds as a result of its authority as investment manager for the Alpine Funds, and also as general partner of seven of the Alpine Funds. It is Alpine's policy to cause each Alpine Fund with assets over which Alpine is deemed to have "custody" to be audited annually and to distribute audited financial statements, prepared in accordance with U.S. generally accepted accounting principles, to investors no later than 120 days after the end of each fiscal year. Clients that are not Alpine Funds should receive at least quarterly statements from their custodian. Alpine urges clients to carefully review such statements and compare them to any account information provided by Alpine.

Subject to the investment objectives, policies and restrictions of each client as set forth in the Governing Documents of each Alpine Fund and the investment management agreement of each client that is not an Alpine Fund, Alpine has discretionary authority to determine the type, amount and price of securities and investments to be bought and sold on behalf of each client account, including the selection of, and commissions paid to, broker-dealers. Alpine, its affiliates and its personnel will not be liable to any client or investor in such client for: (i) any acts or omissions arising out of, or in connection with, the client, any investment made or held by the client or any governing agreement relating to the client, unless such action or inaction was performed or omitted fraudulently or in bad faith or constituted gross negligence or willful misconduct, or for losses due to such action or inaction, or (ii) the negligence, dishonesty or bad faith of any broker or agent of the client, Alpine or any of their affiliates, provided that such broker or agent was selected, engaged or retained by the client or any of the client's affiliates, or that such broker or agent was selected, engaged or retained by Alpine or any of Alpine's affiliates in good faith. Also, Alpine's clients will generally be required to indemnify Alpine, its affiliates and its personnel against any act or omission related to the clients, absent bad faith, gross negligence or willful misconduct. As a result, any negative or positive results of trading errors (including without limitation, human errors such as keystroke errors that occur when entering trades into an electronic trading system, typographical or drafting errors related to derivatives contracts or other agreements, and other errors in entering or failing to enter orders) generally will be borne by the client, rather than by Alpine or any of its affiliates or personnel, so long as Alpine or such affiliate or person adheres to the foregoing standard of care. Each of Alpine and its affiliates and personnel may consult with counsel and accountants in respect of the client's affairs and be fully protected and justified in any action or inaction that is taken in accordance with the advice or opinion of such counsel and/or accountants, provided that they shall have been selected in good faith. The foregoing provisions will not be construed so as to provide for the exculpation of Alpine or any

affiliate or person for any liability (including liability under Federal securities laws which, under certain circumstances, impose liability even on persons that act in good faith), to the extent (but only to the extent) that such liability may not be waived, modified or limited under applicable law, but will be construed so as to effectuate the foregoing provisions to the fullest extent permitted by law.

Alpine has adopted policies and procedures (the "Proxy Voting Policies and Procedures") that have been designed to comply with the requirements of Rule 206(4)-6 and Rule 2042(c)(2) under the Advisers Act. The Proxy Voting Policies and Procedures are designed to ensure that proxies received with respect to client securities for which Alpine exercises voting authority are voted in a manner consistent with the best interest of the client and that Alpine maintains records of its proxy voting in compliance with the Advisers Act. Alpine will vote all client proxies in a manner consistent with the general voting guidelines contained in the Proxy Voting Policies and Procedures and that Alpine believes reflects the best interests of its clients, after taking into consideration relevant facts and circumstances. As a result, depending on the client's particular circumstances, Alpine may vote one client's securities differently than it votes those of another client, or may vote differently on various proposals, even though the securities or proposals are similar (or identical). In some instances, Alpine may determine that it is in the client's best interest for Alpine to "abstain" from voting. If a conflict of interest arises in connection with exercising its voting authority, Alpine will determine whether or not such conflict is material. If a material conflict exists, Alpine takes steps to ensure that its voting decision is consistent with the best interests of the client and is not affected by the conflict. Alpine may, at its discretion, seek the advice of the client in voting such security. Depending on the particular circumstances involved, the appropriate resolution of one conflict of interest may differ from the resolution of another conflict of interest, even though the general facts underlying both conflicts may be similar (or identical). Alpine will deliver to each client upon written request a complete copy of its Proxy Voting Policies and Procedures and/or information on how it voted proxies for the applicable client. To make such a request, please contact Alpine’s CCO at the address or telephone number listed on the first page of this document. With respect to class actions, it is Alpine's normal practice to participate in recoveries related to securities and similar class actions and to file related claim forms on behalf of its clients.

Alpine is not required to make any disclosure in response to this item.