Alterna Capital Partners LLC

Structure; History and Ownership Alterna Capital Partners LLC is a private equity firm with its principal place of business in Orlando, FL (formerly Amherst NH, Bedford, NH and Wilton, CT). Alterna Capital Partners LLC will be referred to in this Brochure as “Alterna” or “the Firm”. The Firm is organized as a Delaware limited liability company. The Firm commenced business in 2007 and registered with the Securities and Exchange Commission under the Investment Advisors Act of 1940 on March 30, 2012. The Firm is currently owned equally by two members: Eric Press and Roger Miller (the “Members”). The Firm is governed by the Members and Earle Goldin (collectively, the “Managing Partners”). One of the original members, James Furnivall, left the Firm in September 2016. One of the original members, Harry Toll, left the Firm in November 2019. In addition to the Managing Partners, as of this filing Alterna has one full-time employee. Alterna was the advisor to Alterna Core Capital Assets Fund, L.P. (“Fund I”). Fund I had its first closing in February 2009 and its final closing in November 2009 with total commitments of $428,282,828. Alterna General Partner LLC (the “Fund I General Partner”) was the general partner of Fund I. In February 2020, Fund I commenced the dissolution of Fund I. In December 2024 Fund I issued a final distribution to its investors and in January 2025 issued and distributed to its investors its final audited financial statements. Fund I was legally dissolved in March 2025. Alterna is also the advisor to Alterna Core Capital Assets Fund II, L.P. (“Fund II,” and together with Fund I, the “Discretionary Funds”). Fund II had its first closing in December 2012 and its final closing in March 2014 with total commitments of $722,424,242. Alterna General Partner II LLC (the “Fund II General Partner”) is the general partner of Fund II. Fund II is closed to additional investment. In December 2022, Fund II commenced its dissolution, which is ongoing. Alterna is also the advisor to Alterna/Lavaca Co-Investment Fund, L.P. (“Lavaca”), a nondiscretionary co-investment fund that follows the same investment strategy as the Discretionary Funds. Lavaca was formed on June 5, 2013, and has a total commitment of $100,000,000. Alterna/Lavaca General Partner LLC (the “Lavaca General Partner”) is the general partner of Lavaca. Lavaca is closed to additional investment. The Lavaca General Partner has commenced the winding up and liquidation of Lavaca. The liquidation is expected to be completed in 2026, and soon thereafter Lavaca will be legally dissolved. Alterna is also the advisor to Tarawa Co-Investment Fund, L.P. (“Tarawa” and, collectively with Fund I, Fund II and Lavaca, the “Funds” and, each individually, a “Fund”), a nondiscretionary co-investment fund that follows the same investment strategy as the Discretionary Funds. Tarawa was formed on October 28, 2015, and has a total commitment of $126,262,626. Alterna Tarawa GP LLC (the “Tarawa General Partner” and, together with the Fund I General Partner, the Fund II General Partner, and the Lavaca General Partner, the “General Partners”) is the general partner of Tarawa. Tarawa is closed to additional investment. The General Partners conduct a single advisory business with Alterna. Collectively, Alterna and the General Partners are referred to in this Brochure as “we” or “us.” Types of Advisory Services The Firm advises the Funds with respect to investments in Core Capital Assets (sometimes referred to in this Brochure as “CCAs”) and in companies with significant involvement in the ownership, operation or

financing of CCAs, primarily in North America, Europe and in countries in other Organization for Economic Co-operation and Development (“OECD”) regions. CCAs are the long-lived, physical assets or resources that are essential to logistics, operations and production in the following sectors:

Transportation–aviation, shipping and rail assets, and transportation facilities;

Industrial–facilities and major equipment for manufacturing, processing, handling and storage; and

Energy–power generation and transmission, conventional and alternative fuel sources and facilities.

All Funds share similar investment strategies and objectives and related risk factors. A more in-depth description of the Discretionary Funds’ investment strategy and objectives and related risk factors may be found in the respective private placement memoranda of the Discretionary Funds. Assets Under Management As of December 31, 2025, we managed $288,038,742 of client assets on a discretionary basis, all of which is invested by or committed to the Discretionary Funds. In addition, we manage $11,311,749 of client assets on a non-discretionary basis invested by or committed to Lavaca and $37,200,922 of client assets on a non-discretionary basis invested by or committed to Tarawa.

Fees Detailed information regarding fees is included in the Funds’ offering documents and the Funds’ governing documents. Because this Brochure will only be delivered to “qualified purchasers” as defined in section 2(a)(51) of the Investment Company Act of 1940, a complete description of our compensation arrangements is not required to be included in this Brochure. Expenses The Funds pay or reimburse us for their own fees and expenses, including but not limited to:

organizational expenses;

accounting and auditing fees and expenses;

legal fees and expenses;

fund administration expenses

custodial expenses;

tax returns preparation;

expenses incurred by the Funds’ Advisory Committee;

Fund annual meetings;

evaluating, making, managing or disposing of portfolio investments;

costs and expenses incurred in connection with the formation of any alternative investment vehicle;

third party expenses incurred in connection with any prospective portfolio investment that is not consummated (subject to certain limitations that are described in the Discretionary Funds’ offering documents);

interest on, and fees and expenses relating to or arising from, Fund or portfolio indebtedness;

other extraordinary, nonrecurring expenses of the Funds;

any action, proceeding or investigation with respect to the Funds or investment vehicle in which the Funds become involved by reason of their investment programs or by reason of the ownership of interests in the Funds by any partner, and the amount of any judgment, arbitration or similar award, settlement, fine or penalty paid in connection with any such action, proceeding or investigation;

certain insurance and bonding costs;

fees (including legal fees) or assessments in connection with any regulatory registrations, qualifications or approvals of the Funds, the Firm or the General Partners that we deem appropriate in connection with the activities of the Funds;

the cost of preparation and distribution of reports and statements to investors;

all transaction costs, including but not limited to legal fees, advisory fees, and costs associated with asset inspection and appraisal;

such research and portfolio management expenses as we deem appropriate, which may include, but are not limited to, costs of software programs related to investment modeling and screening, expenses incurred in traveling to and attending research conferences and otherwise conducting research activities, costs of research reports, data feeds and databases, news wires and quotation services, periodical subscription fees, and fees of outside consultants and experts;

management fees payable to the Firm; and

management fees payable to Alterna employees. This arrangement is only for the investment managed by Tarawa General Partner, whereby Mr. Goldin, Mr. Schaffer and Mr. Samir Patel (the “Tarawa Managers”) are due management fees, calculated at 25bps per annum on outstanding loans. Any compensation received for their services is offset by a reduction in their annual compensation paid by the Firm. Total compensation earned by the Tarawa Managers was $71,031 in 2025. This arrangement ended on December 31, 2025 so the Firm and the Tarawa Managers will no longer receive any fees from Tarawa. A separate independent firm was employed by Alterna Tarawa General Partner starting January 1, 2026 to manage the liquidation of the remaining assets in Tarawa.

Alterna maintains a non-employee network of seasoned professionals (collectively the “Alterna Network”, individually an “Operating Partner”). These individuals provide advice and services to Alterna and in some cases entities in which a Fund is invested on matters such as deal sourcing, interim management, exit strategy, technical consulting, operational improvement initiatives, human capital management, industry networking, and other similar projects. Members of the Alterna Network will work with either Alterna or an entity in which a Fund is invested and will be compensated directly by either Alterna or the investment entity for which such Operating Partner is providing advice. On occasion when the Operating Partner is contracted by Alterna and not an investment entity, the applicable investment entity may be charged by the General Partner and/or its

affiliates for such services in an amount not to exceed what an unaffiliated third party would charge for comparable services, without any reduction to the applicable Fund’s management fee.

Methods of Analysis and Investment Strategies We advise the Funds with respect to investments in CCAs and in companies with significant involvement in the ownership, operation or financing of CCAs, primarily in North America, Europe and OECD countries in other regions. CCAs are the long-lived, physical assets or resources that are essential to logistics, operations and production in the following sectors:

Transportation–aviation, shipping and rail assets and transportation facilities;

Industrial–facilities and major equipment for manufacturing, processing, handling and storage; and

Energy–power generation and transmission, conventional and alternative fuel sources and facilities.

We target CCA investment opportunities where the Managing Partners have proven investment track records and seek to leverage their industry experience and relationships, specialized asset knowledge and financial skills. As of December 31, 2025, Fund II has a diversified portfolio of nine active CCA investments with the fair value of its total investments and remaining capital commitments totaling $281,088,843. As of December 31, 2025, Lavaca has $11,171,521 in fair value of its investment and

remaining capital commitment. As of December 31, 2025, Tarawa has $37,092,072 in fair value of its investment and remaining capital commitments. We believe that the Funds’ portfolios of CCA investments affords investors attractive risk-adjusted returns from: (a) current cash yield; (b) capital preservation through ownership of strategically targeted long-lived assets; (c) active portfolio and asset management; (d) cash flows with enhanced credit characteristics; (e) financial performance characteristics which are differentiated from the broad equity and debt markets; and (f) multiple exit opportunities. We anticipate that the Funds’ investment returns will be generated by three phases of value creation: ▪

Phase One–Acquisition and Structuring. The Funds seek to create value by acquiring investments at attractive valuations, and employing structures that lock in cash flows, mitigate risks and monetize some components of value (for example, various types of tax credits or operating rights).

▪

Phase Two–Investment Management and Optimization. Transaction and portfolio returns may be further improved through a variety of management and optimization activities. These may include restructuring of usage agreements, enhancing asset operating efficiencies, upgrading/rebuilding assets, identifying revenue enhancement opportunities (e.g., extending current use agreements and/or placing assets with new users) and restructuring financings.

▪

Phase Three–Exit. Sales of investments to strategic or financial buyers, and initial public offerings of portfolio investments, represent some of the mechanisms for maximizing exit value. In addition, the ability to disaggregate and separately sell the elements of value inherent in CCAs provides flexibility in control over the timing and structure of realizations.

Our investment approach combines both a “top-down” analysis, which consists of identifying trends, categorizing assets, capitalizing on cyclicality and portfolio diversification, and a “ bottom-up” process, which consists of proactively sourcing and creating deal flow, creating value through financial structuring, partnering with “best-in-class” operators, active portfolio monitoring and management, and optimizing realizations. This approach is illustrated below:

Top-down Analysis / Portfolio Framework Identify Trends

Create / Source Deals

Knowledge of Assets

Structure & Due Diligence

Capitalize on Cyclicality

“Best-in-Class” Operators

Manage & Monitor

Diversification of Portfolio

Realize Investments

Bottom-up Process / Execution of Strategy

Risks Associated with Our Investment Strategy Our investment strategy involves significant risks and is suitable only for investors who are able to independently evaluate the risks and merits of an investment in the Funds. There can be no assurance that any of the Funds’ objectives will be achieved, or that an investor will receive a return of capital. General Investment Considerations Risk of Loss. An investment in any of the Funds entails a high degree of risk with no certainty as to the

magnitude or timing of the returns, if any, on a limited partner’s investment. Accordingly, an investment in a Fund is suitable only for investors who are able to bear the risk of loss of all capital invested. No guarantee or representation is made that the Funds will be able to implement their investment strategy or achieve their targeted returns, or that the overall investment program of the Funds will be successful. Long-term Nature of Investment; Illiquidity of the Funds’ Investments. An investment in any of the

Funds requires a long-term commitment of capital. There may be a significant period of time before the Funds complete their investment programs. The process of searching for and selecting investments and their management and disposition is likely to take several years from the date of each Fund’s initial closing. The return of capital and the realization of gains, if any, from investments may not occur until a number of years after such investments are made, if at all. In addition, investments made by the Funds are likely to be illiquid. Illiquidity may result from the absence of an established market for such investments or the underlying CCAs, as well as from legal, contractual or other restrictions on their resale by the Funds. This illiquidity may interfere with the Funds’ abilities to dispose of investments or the underlying CCAs in a timely manner or adversely affect the terms of such dispositions. Moreover, distributions to the limited partners may be made in kind, including in illiquid securities, and losses on unsuccessful investments may be realized before any gains on successful investments are realized. Risks Upon Disposition of Investments. In connection with the disposition of a portfolio investment,

the Funds may be required to make representations about the business and financial condition of such portfolio investment or may be responsible for the contents of disclosure documents under applicable securities laws. The Funds may also be required to indemnify the purchasers of such portfolio investment or underwriters to the extent that any such representations or disclosure documents turn out to be incorrect, inaccurate or misleading. These arrangements may result in contingent liabilities, which may ultimately have to be funded by the limited partners. Risks Arising from Exercise of Control Rights. The Funds will generally seek to acquire a controlling

interest in each of their investments, either on a stand-alone basis or as part of a group with other investors. Any measures contemplated by a Fund in connection with an exercise of its control rights could expose the assets of the Fund to claims by portfolio companies, their owners (if any) and creditors. These measures also could result in certain liabilities being attributed to the Fund in the event of the bankruptcy or reorganization of a portfolio company. While we intend to manage the Funds in a way that will minimize the Funds’ exposure to such risks, the possibility of successful claims cannot be precluded. Risk of Litigation. The Funds may be a party to litigation matters and claims from time to time in the

ordinary course of their operations, including litigation matters and claims involving Alterna, the General Partners and portfolio companies. Risks Related to an Investment in a Fund Limited Operating History. Fund I, the Fund I General Partner and Alterna commenced operations in

2009. Fund II and the Fund II General Partner were formed in 2012. Lavaca and the Lavaca General Partner were formed in 2013. Tarawa and the Tarawa General Partner were formed in 2015. Accordingly, there is only limited operating history upon which investors can evaluate the possible

performance of the Funds. Additionally, the Firm’s Managing Partners had not operated a private equity fund together prior to the commencement of Fund I’s operations. Dependence on Key Personnel. The success of the Funds depends in substantial part upon the skill and

expertise of the Managing Partners and the other individuals employed by us to assist them. However, there can be no assurance that the Managing Partners will continue to be associated with the General Partners and/or Alterna throughout the life of the Funds, and the loss of one or more Managing Partners, the Chief Financial Officer/Chief Compliance Officer or other key personnel could have a material adverse effect upon the Funds. Competitive Nature of the Funds’ Business. The business of the Funds is highly competitive. The

Funds will be competing for investment opportunities against other investors, including other private equity funds and hedge funds, large and well-capitalized industrial companies and commercial, investment and merchant banks. Some of these competitors could have financial and strategic resources significantly in excess of those of the Funds, may be willing to provide financing and operational assistance on more favorable terms than the Funds and may make competing offers for investment opportunities that are targeted by the Funds. It is possible that competition for investment opportunities may increase, thus reducing the number of opportunities available to the Funds and adversely affecting the terms upon which investments can be made. Consequently, there is no assurance that the Funds will be able to consummate investments which will enable them to invest all of their committed capital, to diversify their investments to the extent anticipated or satisfy their return objectives. General Economic Conditions

The Funds’ activities and results may be affected by a number of general economic factors which are outside the control of the Funds, Alterna or the General Partners. These factors include, but are not limited to, interest rates, inflation, general levels of economic activity, the price of securities and participation by other investors in the financial markets. There is no assurance that the financial markets will continue to provide current valuation levels to Core Capital Assets. Instability in the securities, currency, commodity and other markets may also increase the risks inherent in the Funds’ investments. Economic Cycles. Core Capital Assets are vulnerable to local, national and worldwide economic cycles. These cycles could affect the cash flow from investments, as well as the prices at which the Funds purchase or sell their investments or the underlying CCAs. Interest Rates. Investments in Core Capital Assets may be highly leveraged. As such, movements in the level of interest rates may affect the returns from CCA investments more significantly than investments in assets that are not so leveraged. A material increase in interest rates and/or risk margins during the terms of the Funds could materially and adversely affect the Funds’ abilities to dispose of their investments on favorable terms. Price Levels. Inflation may adversely affect the Funds’ investments. During periods of rising inflation, interest and other expenses incurred by the Funds’ portfolio companies could increase, which would likely reduce returns to the Funds’ limited partners. In addition, certain CCA investments made by the Funds may have fixed income streams, and, accordingly, the value of such investments may decline in periods of rising inflation. Conversely, during periods of deflation, the market value of Core Capital Assets may decline, reducing the Funds’ abilities to achieve targeted returns upon realization of investments. Follow-on Investments. The Funds may be called upon to provide follow-on funding for existing

portfolio companies or have the opportunity to increase their investments in such portfolio companies. There can be no assurance that the Funds will make such follow-on investments or that they will have sufficient funds to do so. Any decision by the Funds not to make follow-on investments or their inability to make them may have a substantial negative impact on portfolio companies in need of such an investment or may diminish the Funds’ ability to influence the portfolio company’s future development.

Distributions in Kind. Although under normal circumstances the Funds intend to make distributions in

cash or in marketable securities, it is possible that under certain circumstances (including the liquidation of the Funds), in-kind distributions could be made and could consist of securities for which there is not a readily available public market. Consequences of Limited Partner Default. In the event that a limited partner fails to fund any portion

of its capital commitment when due, or otherwise fails to comply with certain provisions of the applicable Fund’s limited partnership agreement, such limited partner may be subject to various remedies as provided in the Fund’s limited partnership agreement, including forfeiture of a portion of its interest in the Fund. Furthermore, if a limited partner fails to pay any portion of its capital commitment to a Fund when due, and the contributions made by non-defaulting limited partners and borrowings by the Fund are inadequate to cover the defaulted capital commitment, the Fund may be unable to pay its obligations when due, and its ability to execute its investment strategy or to otherwise continue operations may be impaired. As a result, a Fund may be subjected to significant penalties that could materially and adversely affect the returns to its limited partners (including non-defaulting limited partners). A default by a substantial number of limited partners would limit opportunities for investment diversification and would be likely to have a material adverse effect on the Fund’s economic results. Indemnification. The Funds will be required to indemnify the Firm, the General Partners, and their

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We provide investment advice to the Funds and not individually to the Funds’ limited partners. All four Funds are closed to new investors, and no further commitments will be accepted. Fund I’s limited partners were: three US state-level public pension funds, one US state investment fund, one UK public pension scheme and one private pooled investment fund. Fund II’s limited partners are: six US state-level pension funds, one US state investment fund, three US county-level pension funds, five US educational endowment funds, one private endowment and two US private pension trusts (one of which invests through three different legal entities). In addition, the original members of Fund II’s General Partner have individually committed directly to Fund II; in the aggregate, their commitments are less than one percent of Fund II’s total commitments. Lavaca has one limited partner, a US state-level public pension fund that committed $100,000,000 to Lavaca on a non-discretionary basis (i.e., all investments made by Lavaca must be approved by such limited partner). Tarawa has three limited partners, each affiliated with a US private pension trust, that together committed an aggregate of $125,000,000 to Tarawa on a non-discretionary basis (i.e., all investments made by Tarawa must be approved by such limited partners).

The General Partners may be entitled to be paid a carried interest out of the proceeds of realized investments of the Funds, depending on Fund performance. We do not advise any clients that do not pay performance-based compensation.

Material Financial Industry Affiliations A. Neither Alterna nor anyone with the power to exercise, directly or indirectly, a controlling influence over our management or policies, or to determine the general investment advice given to the Funds (referred to herein as “management persons”) is registered or has an application pending to register as a broker-dealer. B. Neither Alterna nor any of our management persons is registered or has an application pending to register as a futures commission merchant, commodity pool operator, commodity trading advisor or an associated person with any of the foregoing entities. C. Neither Alterna nor any of our management persons has any relationships with related persons that create or could create a material conflict of interest with clients or investors.

D.

Alterna does not select other investment advisors for its clients or investors.

Conflicts of Interest The types of conflicts of interest that Alterna might encounter are described below: General. There may be situations where Alterna, the General Partners, the Managing Partners, other key

personnel and/or their respective affiliates may encounter actual or potential conflicts of interest in connection with the Funds. On any issue involving conflicts of interest, we will be guided by our good faith judgment in determining what courses of action are in the Funds’ best interests. In the event that any matter arises that we determine in our good faith judgment constitutes an actual conflict of interest, we may take such actions as may be necessary or appropriate to ameliorate such conflict of interest, and upon taking such actions we expect to be relieved of any and all responsibilities or liabilities for such conflict of interest. Diverse Membership. The Funds’ limited partners include U.S. taxable and tax-exempt entities, and for

Fund I, an institution from a jurisdiction outside of the United States. Such limited partners may have conflicting investment, tax and other interests with respect to their investments in the Funds. The conflicting interests of individual limited partners may relate to or arise from, among other things, the nature of investments made by the Funds, the structuring of the acquisition of investments and the timing of the disposition of investments. As a consequence, conflicts of interest may arise in connection with our decisions, including with respect to the nature, structuring or timing of investments and dispositions, that may be more beneficial for certain limited partners than for other limited partners, especially with respect to limited partners’ individual tax situations. In selecting and structuring investments for the Funds, we will consider the investment and tax objectives of the Funds and their partners as a whole, rather than the investment, tax or other objectives of any limited partner individually. Management Fee Payable Regardless of Fund Performance; Management Fees Payable on Invested Capital After Close of Investment Period. A management fee or equivalent is required to be

paid to Alterna, even if the Fund experiences net losses in a particular year or over the term of the Fund. After the close of the investment period, Alterna may be incented to retain investments longer than it otherwise would have in order to continue receiving management fees on the invested capital. Carried Interest. The fact that the General Partners’ carried interests are based on the performance of the

Funds may create an incentive for the General Partners and Alterna, which is affiliated with the General Partners, to make investments on behalf of the Funds that are more speculative than would be the case in the absence of performance-based compensation. Fees Earned by Alterna and Affiliates. Alterna and its affiliates may be entitled to receive investment

banking, break-up, monitoring, consulting, directors’ and other similar fees in connection with portfolio investments or from unconsummated transactions. Limited partners will receive only a portion of the total benefit of such fees. Other Investment Activities. Subject to the limitations contained in the Funds’ limited partnership

agreements, Alterna and its affiliates may continue to engage actively in other activities, including investment-related activities. In that regard, our personnel responsible for day-to-day operations of the Funds will devote such time as is reasonably required to conduct the business affairs of the Funds in an appropriate manner. However, these same personnel may also work on other projects; consequently, conflicts may arise in the allocation of management resources. Multiple Funds. Alterna has raised four Funds and may in the future sponsor one or more additional follow-on funds following the same or similar investment strategies as the Funds. We may also provide investors in the Funds with the opportunity to co-invest in or provide debt financing for specific investments. The existence of multiple funds that generally all invest in the same investments and/or securities can create a material conflict of interest with respect to the allocation of investment

opportunities among funds. To the extent that we establish additional funds, we will allocate investment opportunities among the funds by applying such considerations as we deem appropriate, including relative size of such investment vehicles, amount of available capital, size of existing positions in the same or similar securities, impact of leverage, investment objective and strategy considerations, including, without limitation, concentration parameters and tax considerations and other factors. As a result of such considerations, allocations among such funds may not necessarily be pro rata. In cases where a limited amount of a security or other instrument is available for investment, the allocation of such instrument among such funds may necessarily reduce the amount thereof available for purchase by the other funds. Because of differences in timing and the availability of investment opportunities, the net performance of one fund may vary materially from that of other funds for the reasons described above, as well as differing expenses, tax considerations, the impact of leverage and other factors. Conflicts Regarding Valuations and Other Matters. The respective General Partner determines the fair

value of the investments held by the Funds. Currently most of the Funds’ investments are Level 3 investments, as pricing inputs are unobservable for the investments, meaning they reflect the reporting entity’s own assumptions about how market participants would price the asset or liability. Level 3 includes private portfolio investments that are supported by little or no market activity. As such, the respective General Partner for each Fund is responsible for valuing Fund investments each quarter, using its discretion and judgment in determining the appropriate means of valuation. Because of the pricing discretion available to Alterna, it may be incented to report higher values than it otherwise would in order to enhance its ability to market new funds. Our fair value methodology for the Funds’ Level 3 investments includes the examination and consideration of many factors. Valuation of investments in Core Capital Assets may take into account 1) any underlying financing contract employed for the Core Capital Asset (including an analysis of the creditworthiness of the underlying obligor), 2) market analysis, including current and projected market conditions and secondary market transactions for similar equipment, 3) the operating condition of the equipment, including replacement value, 4) financial analysis, including multiples of EBITDA (earnings before interest, taxes, depreciation and amortization), EBITDA with certain adjustments and/or revenue for comparable public companies, and 5) discounted cash flow projections. If there is a subsequent financing or other material shareholder event (including a merger, joint venture or other valuation event) involving a third-party investor at a different valuation, the value of the Funds’ investments may be marked up or marked down in the quarter in which the transaction is completed. Further modifications may be made for the financial condition of any portfolio company investment, and specific market or company events that impact valuation. Furthermore, in the event we are provided with, or otherwise come into possession of, information which leads us to determine that one or more valuations of account assets for a prior period are inaccurate, where we are responsible for valuation, we may adjust or amend such prior valuations as we deem appropriate and adjust or amend any reports or statements of the account (whether or not previously issued) with respect to such prior periods. The Members have each contributed $250,000 in equity for an approximate 10% interest each in First Harvest Navigation Inc., an unrelated business activity which is owned by the wife of one of the Firm’s service providers. On June 30th, 2025 the Managing Partners acquired an 18.5% interest in Sokana Shipping & Trading Ltd. An affiliate of Sokana Shipping & Trading Ltd. (“Sokana”) is the sole commercial manager for three vessels that were in Fund I (sold in 2023) and six vessels in Fund II (previously ten vessels, four vessels were sold in 2023/2024). Sokana manages approximately thirty vessels in total. For the vessels in Fund I and Fund II, Sokana earns/earned a commission of two percent on the gross freight earned on each voyage, as well as a daily management fee of $250/vessel, which is a market-based rate. Fund II continues to own the remaining six vessels.

A material conflict of interest could arise from the acquisition by the Managing Partners of this interest as such interest could potentially influence decisions made by the Managing Partners with respect to the operation, maintenance and disposition of the remaining vessels owned by Fund II. Proper procedures have been established to address such conflicts, and such procedures will be reviewed and updated as needed.

Code of Ethics The Firm has established a Code of Ethics (“Code”) pursuant to Rule 204A-1 under the Investment Advisers Act of 1940, as amended. The purpose of the Code is to identify the ethical and legal framework in which we and our personnel are required to operate and to highlight some of the guiding principles and mechanisms for upholding our standard of business conduct. The Code is designed to ensure that all applicable personnel are aware of and adhere to our policies and procedures. The description below is a summary only. A complete copy of the Code will be provided to clients and prospective clients upon request. Standard of Business Conduct. As a fiduciary, we owe our clients the highest duty of loyalty and rely

on our personnel to avoid conduct that is or may be inconsistent with that duty. Basic Principles. The Code is based on a few basic principles: (i) the interests of our clients come

before our interests and those of our personnel; (ii) the professional activities and personal investment activities of our personnel must be consistent with the Code and avoid any actual or potential conflict between the interests of clients and those of the Firm, the General Partner or our personnel; (iii) the activities of our personnel must be conducted in a way that avoids any abuse of any such person’s position of trust with and responsibility to us and our clients; and (iv) personnel may not engage in any act, practice or course of conduct that would violate the provisions of Rule 204A-1. Conflicts of Interest. As a fiduciary, we have an affirmative duty of care, loyalty, honesty and good

faith to act in the best interests of our clients. We make every effort to avoid conflicts of interest and fully disclose all material facts concerning any conflict of interest that may arise with respect to any client. We take a conservative approach and impose a high standard on our personnel by stressing that individuals subject to this Code must try to avoid situations that have even the appearance of conflict or impropriety. Insider Trading. Our personnel may not trade, either personally or on behalf of another, on material non-

public information or communicate material non-public information to another person in violation of the law. This policy applies to all our personnel and extends to their activities both within and outside their duties at the Firm. We have also implemented policies and procedures designed to detect and prevent insider trading. Personal Securities Transactions. All personnel must comply with our Personal Account Trading

Policy, which provides that investments in initial public offerings or private placements must be preapproved by our Chief Compliance Officer (“CCO”). Service as a Director. None of our personnel may serve as a director of a publicly held company

without prior approval by the CCO based upon a determination that service as a director would not be averse to the interest of any of our clients. We may not trade in any securities issued by any company of which any of our covered persons is a director.

Reporting of Violations. Our personnel are required to report any violation, apparent violation or

potential violation of the Code to the CCO. Review and Enforcement. The CCO is responsible for ensuring adequate supervision over the activities

of all persons who act on our behalf in order to prevent and detect violations of the Code by such persons. In addition, please note the following: Neither Alterna nor any related person recommends, buys or sells investments for client accounts in which any of them has a material financial interest. Neither Alterna nor any related party invests in investments that are recommended to clients. Neither Alterna nor any related party buys or sells any investment for its or their own account(s) at or about the same time that such investments are recommended, bought or sold for client accounts.

Because of the nature of the Funds’ investment programs, we generally do not recommend broker-dealers for client transactions and our brokerage fees are de minimis.

None.

None

Alterna’s Managing Partners review the status of the Funds’ investments on a continuous basis. Each Fund’s audited financial statements are prepared annually and distributed to the respective investors. In addition, annually each limited partner receives their audited Statement of Partner’s Capital. Unaudited financial statements and Statement of Partner’s Capital are prepared quarterly and distributed to each Fund’s investors.

Alterna has custody of client funds by virtue of its relationship to the Funds, which are, in accordance with rule 206(4)-2, audited at least annually by a PCAOB registered firm.

The respective General Partner has broad investment discretion over the Discretionary Funds’ assets within the strategy described in Item 8. However, for each Discretionary Fund, the respective General Partner requires approval from its Advisory Committee in connection with investments in certain types of securities, investments that involve a conflict of interest and/or investments that exceed certain parameters established in the Funds’ limited partnership agreements. In addition, Alterna recommends investments to Lavaca’s limited partner who has full investment discretion and to Tarawa’s limited partners who have full investment discretion.

We have adopted a Proxy Voting Policy designed to ensure that we comply with the requirements of Rule 206(4)-6 and Rule 204-2 promulgated pursuant to the Investment Advisers Act of 1940, as amended, and fulfill our obligation thereunder with respect to proxy voting, disclosure and recordkeeping. Because of the nature of our investment advisory activities, we will not frequently be in a position to vote proxies on behalf of any of our clients. In the event that we are in a position to do so, our objective is to ensure that our proxy voting activities on behalf of our clients are conducted in a manner consistent, under all circumstances, with the best interest of the clients. If we determine that we have, or may be perceived to have, a conflict of interest when voting a proxy, we will address matters involving such conflicts of interest on a case-by-case basis. Investors may obtain a copy of our Proxy Voting Policies and Procedures, and information regarding how we voted particular proxies on behalf of the accounts, on request.

We do not require or solicit prepayment of more than $1,200 in fees from the funds, six months or more in advance, and therefore are not required to include a balance sheet for our most recent fiscal year.