Aquamarine Financial (Cayman) Ltd

Background Aquamarine is registered with the Cayman Islands Monetary Authority (“CIMA”) under Section 5(4) and Schedule 4 of the Securities Investment Business Act (Revised) of the Cayman Islands. Aquamarine provides investment advisory services to separately managed accounts and pooled investment vehicles as described further herein. Interests in pooled investment vehicles are offered only to sophisticated and qualified investors, including but not limited to, high net worth individuals and family offices. The firm’s services include asset management, investment advisory and financial consulting services. Ownership Currently, Aquamarine is 100% owned by The Aquamarine STAR Trust, a statutory trust under Cayman Islands law (the “Star Trust”). Aquamarine PTC (“Aquamarine PTC”) is the sole trustee of the Star Trust. Eduardo D’Angelo P. Silva is the sole director of Aquamarine PTC and David Mungall is the sole supervisor of Aquamarine PTC. The primary purpose of the Star Trust is to hold the shares of Aquamarine so as to maintain the ownership and control of Aquamarine. Since Eduardo D’Angelo P. Silva and David Mungall also serve as the independent directors of Aquamarine as further described below, the present organizational structure of Aquamarine may give rise to certain potential and actual conflicts of interest. For further details regarding these conflicts, please see the Risks Relating to the Organizational Structure of Aquamarine under Item 8. Aquamarine has entered into a director services agreement with Zedra Trust Company (Cayman) Limited (“Zedra”) under which Zedra is providing the directors to Aquamarine. Zedra is not responsible for the day-to-day operations of Aquamarine, the commercial structuring of the business of Aquamarine or for the provision of investment, commercial, accounting, legal, tax or any other advice to Aquamarine. The directors, being independent directors, are not involved in the day-to-day operations of Aquamarine but retain ultimate responsibility for the governance of Aquamarine. If a director ceases to be employed by Zedra or resigns for whatever reason, Zedra shall nominate a suitable individual to replace that director. The directors of Aquamarine are currently David Mungall and Eduardo D'Angelo P. Silva. The directors are registered directors with CIMA. Registered directors are natural persons appointed as directors of fewer than 20 covered entities. In the Cayman Islands, the same directors may serve on several boards for multiple companies, and this does not indicate that the entities themselves are related, nor does it imply shared ownership, control or operational integration. The overlap is solely as a result of the directors’ independent roles and not due to any affiliation among the entities. As such, the directors of Aquamarine serve on boards for multiple companies, but there is no control or ownership link between Aquamarine and any such other company, and Aquamarine is in no way affiliated with any such other company.

Advisory Services Aquamarine offers a wealth of resources to assist and support clients so they can achieve their financial objectives. Aquamarine's investment objective is to provide suitable income returns and capital appreciation through investments in a combination of different fixed income securities, equity assets and real estate, with particular attention to European and Latin American markets. Risk factors will be considered and monitored on an individual basis. See Item 8 below. Aquamarine has experience in identifying undervalued opportunities across a broad range of asset categories and markets, and has developed, and intends to continue to develop, proprietary sourcing and servicing channels across these categories and markets. Separately Managed Accounts Aquamarine currently manages four separately managed accounts on behalf of institutional clients and may manage additional separately managed accounts in the future (each, a “Managed Account” and collectively, the “Managed Accounts”). Aquamarine tailors the advisory services it provides to meet the needs and objectives of its Managed Account clients and seeks to ensure that client portfolios are managed in a manner consistent with their specific investment profiles. Aquamarine consults with clients on an initial and ongoing basis to determine various factors relevant to the management of their portfolios.

Pooled Investment Vehicles Aquamarine currently manages three pooled investment vehicles and may manage additional pooled investment vehicles in the future (each, a “Fund” and collectively, the “Funds”). Each Fund is organized and incorporated in a country other than the United States. Aquamarine Credit Fund Ltd., a Cayman Islands exempted company (the “Credit Fund”), is the only Fund that Aquamarine currently offers to investors domiciled in the United States. The Credit Fund was subsequently registered with CIMA as a Regulated Mutual Fund under the Mutual Funds Act (Revised) of the Cayman Islands on 7 June 2022. Wrap Fee Programs Aquamarine does not participate in wrap fee programs. Assets Under Management As of December 31, 2025, Aquamarine had $5,761,492,014 in assets under management on a discretionary basis. Aquamarine has sole investment discretion and is authorized to make all investment decisions and to direct the execution of all transactions for the client's account (subject to the investment objectives, guidelines and restrictions that a client may impose on an account) without consulting the client in connection with each transaction.

Aquamarine provides advisory services for compensation based on a percentage of assets under management and fees or allocations based on a percentage of the performance of client accounts. Fees for managed account clients are negotiable. The directors of Aquamarine may enter into side letter agreements with investors in the Credit Fund, varying the terms of their investment, including lower fee arrangements. Current and prospective clients should carefully review all fees charged by Aquamarine. Different fees are charged to different clients and fund investors, and fees can be waived, rebated or reduced for certain clients and fund investors. The CCO shall review fee arrangements for compliance. Credit Fund Aquamarine provides discretionary investment management services to the Credit Fund, which is not registered under the Investment Company Act of 1940, as amended (the “1940 Act”), and whose interests are not registered under the Securities Act of 1933, as amended (the “Securities Act”). The Credit Fund’s offering documents include information about the fees and expenses paid by the Credit Fund.

Management Fee: For discretionary investment management services to the Credit Fund, Aquamarine receives, from the Credit Fund’s assets, a fixed advisory fee payable monthly in arrears equal to 0.125% (1.5% on an annualized basis) of the net asset value of each series of shares of the class shares as of the last calendar day of each month before giving effect to any redemptions occurring as of such day. These management fees are negotiable and may vary for different Credit Fund investors. The management fee structures described herein may be modified from time to time and may vary by each class of shares of the Credit Fund. Fees may differ among investors in the Credit Fund. Performance Fee: Aquamarine also receives a performance fee from the Credit Fund as discussed in Item 6. Aquamarine, in its sole discretion, may waive or reduce all or any portion of the management fee and/or the performance fee for any reason. The management fee and/or the performance fee may also be shared by Aquamarine with any other person in the sole discretion of Aquamarine. Other Expenses: The Credit Fund bears all of the expenses incident to its operations and business, including, without limitation, (i) investment-related expenses (e.g., brokerage commissions, expenses relating to short sales, clearing and settlement charges, custodial fees, bank service fees, loan closing costs, and interest expenses) and other trading-related expenses; (ii) operating expenses (e.g., trade clearance and settlement, corporate action processing, trade confirmation, pricing services, portfolio management reporting software and reconciliation); (iii) directors’ and officers’ fees and expenses and related insurance costs; (iv) interest on balances due and any other fees and charges of prime brokers, financial counterparties, banks. and custodians; (v) any income taxes, withholding taxes, transfer taxes, and other governmental charges and duties imposed on or payable by the Credit Fund; (vi) the Credit Fund’s ongoing legal, accounting, regulatory, compliance and consultants fees and disbursements; (vii) fees and out-of-pocket expenses of the administrator and any custodian; (viii) any fees and expenses associated with the organization and conduct of the Board of Directors’ (as defined below) and shareholders’ meetings and the preparation and distribution of all of its shareholders’ reports and other communications with shareholders; (ix) any fees and expenses associated with maintaining the Credit Fund’s registered office in the Cayman Islands; (x) litigation and indemnification expenses and other extraordinary expenses not incurred in the ordinary course of the Credit Fund’s business; and (xi) management and performance fees payable to the Investment Manager and other expenses described in the investment management agreement. Expenses are allocated pro rata among each class of shares. A fixed organizational charge for the Credit Fund was amortized over a period of sixty (60) months from the date that the Credit Fund commenced operations.

Further details on organizational expenses and operating expenses are included in the Credit Fund’s offering documents, including the Amended and Restated Confidential Memorandum of the Credit Fund. Managed Accounts Management Fees: For discretionary investment management services to Managed Accounts, Aquamarine typically charges management fees generally ranging from 0.25% to 0.5%, which are typically based on the Managed Account’s net asset value of assets under management. These management fees are negotiable, accrue monthly in arrears, and are billed quarterly. Profits Allocation: Aquamarine also receives a profits allocation from certain Managed Accounts as discussed in Item 6. Different fees may be charged for Managed Accounts and Aquamarine may receive a different profit allocation for Managed Accounts, in each case, depending on the investment advisory services being provided by Aquamarine. Other Expenses: To the extent set forth and agreed to in an agreement, certain Managed Accounts will bear certain operating and other expenses associated with their Managed Account.

Risks Relating to the Organizational Structure of Aquamarine Conflicts of Interest in Roles. Eduardo D’Angelo P. Silva, as the sole director of Aquamarine PTC, and David Mungall, as the sole supervisor of Aquamarine PTC, control Aquamarine PTC, which is the sole trustee of the Star Trust. However, Messrs. Silva and Mungall are also independent directors of Aquamarine, the company for which the Star Trust is the sole shareholder. If Aquamarine PTC takes or fails to take an action that affects Aquamarine, Messrs. Silva and Mungall must evaluate that action through their roles at Aquamarine PTC and as directors of Aquamarine. For example, if Aquamarine PTC caused the Star Trust to exercise its shareholder rights in a manner adverse to Aquamarine's business interests, Messrs. Silva and Mungall would face a direct conflict between their duties at Aquamarine PTC and their board-level duties at Aquamarine. While the Star Trust, Aquamarine PTC, and Aquamarine are legally separate entities, there may be actual or potential conflicts of interest if Aquamarine PTC’s trustee decisions benefit the Star Trust or Aquamarine PTC at the expense of Aquamarine. These entities, including Aquamarine, believe that they have proper governance and clear separation of roles, which are designed to mitigate these risks. Trust Purpose vs. Aquamarine Interest. The Star Trust's primary purpose is to maintain ownership and control of Aquamarine. This mandate can conflict with business decisions that would benefit Aquamarine but require changes to the trust's ownership position. If Aquamarine needs to raise capital or otherwise dilute the Star Trust's 100% stake, or if a strategic merger would transfer control to another party, the directors of Aquamarine might favor the transaction on business grounds while Aquamarine PTC might not favor such a transaction for the Star Trust. Messrs. Silva and Mungall would be making decisions on behalf of Aquamarine PTC and as directors of Aquamarine, and there is no independent party positioned to weigh the Star Trust's interests separately from Aquamarine's interests. Risk in Director Replacement. Zedra provides the independent directors to Aquamarine and can nominate replacements. However, since Messrs. Silva and Mungall also hold positions at Aquamarine PTC, which is the trustee of the Star Trust, the sole shareholder of Aquamarine, Messrs. Silva and Mungall may influence who Zedra nominates as directors of Aquamarine. As such, Messrs. Silva and Mungall may have influence over their own replacement or continuation, which may create certain significant conflicts of interest. Zedra’s Limited Role. The director services agreement with Zedra provides a mechanism for providing directors and nominating replacement directors, if necessary. However, Zedra is expressly not responsible for operational management, commercial structuring, or advisory functions. Its role is limited to providing directors and nominating replacements, if necessary. Zedra does not in any way serve as an independent governance check on the substance of decisions made by Messrs. Silva and Mungall.

Use of Cayman Islands Independent Directors. Aquamarine utilizes the services of independent professional directors in the Cayman Islands. It is customary practice in the Cayman Islands for the same independent directors to serve simultaneously on the boards of directors (or equivalent governing bodies) of multiple unaffiliated entities. The fact that a director of Aquamarine also serves as a director of one or more other entities does not, in and of itself, indicate that Aquamarine is related to, affiliated with, or under common ownership or control with any such other entity. The overlap in directorships is solely a function of the directors’ independent professional roles and does not reflect any organizational, economic, or operational integration among the entities on whose boards such directors serve. The use of shared independent directors gives rise to potential and actual conflicts of interest. A director who serves on multiple boards may owe fiduciary or analogous duties to each entity on whose board that director sits, and situations may arise in which the interests of one entity conflict with or diverge from the interests of another entity sharing the same director. While Cayman Islands regulatory requirements and customary governance practice require disclosure, recusal, and management of such conflicts, there can be no assurance that all conflicts will be identified or satisfactorily resolved in every instance, or that the resolution of a conflict will be in the best interest of Aquamarine. Independent directors who serve on numerous boards may have limited time and attention to devote to the affairs of any single entity. Although Cayman Islands regulatory standards applicable to regulated entities require directors to devote sufficient time to their roles and to maintain adequate knowledge of each entity's business, the breadth of a director's commitments may, as a practical matter, limit the depth of oversight and engagement the director can provide to Aquamarine. Investors should be aware that the directors of Aquamarine are not exclusively dedicated to its affairs. Independent directors are not employees of Aquamarine and may resign or be removed at any time. The loss of one or more directors, or the inability to replace a director in a timely manner, could disrupt governance, or delay decision-making at Aquamarine. Methods of Analysis and Investment Strategies Aquamarine seeks to provide high income returns and capital appreciation to the Credit Fund and Managed Accounts through investments in a combination of different fixed income securities and equities, with particular attention to Latin American and European markets, although investment may also be made in or relation to other related markets, taking into account factors such as the credit quality of issuers, changes in and levels of interest rates, projected economic growth rates, volatility, capital flows, debt levels, liquidity, trends in inflation, anticipated movements in foreign currency and governmental initiatives. Aquamarine seeks to achieve the Credit Fund’s investment objective primarily through (a) purchases of corporate, sovereign and quasi sovereign debt securities; (b) investments in loans; and (c) assetbased investments, including portfolios of consumer and commercial receivables and assetbacked financial instruments of undervalued or financially troubled companies. Aquamarine may hold such positions directly or may indirectly hold such positions by entering into one or

more swaps, options, forward contracts or similar derivative transactions, including, among others, credit default swaps. Investment targets may include: (i) out-of-favor sectors where the Credit Fund or a Managed Account can acquire investments at a significant discount to the fundamental value of their underlying cash flow or assets; (ii) companies undergoing, or considered likely to undergo, reorganizations under local bankruptcy laws; (iii) companies initiating debt restructuring, reorganization and/or liquidation outside of bankruptcy; and (iv) companies facing a broad range of liquidity issues. Aquamarine has substantial experience in identifying undervalued situations across a broad range of asset categories and markets, and has developed, and intends to continue to develop, proprietary sourcing and servicing channels across these categories and markets. Risk of Loss AQUAMARINE’S INVESTMENT STRATEGIES INVOLVE A HIGH DEGREE OF BUSINESS AND FINANCIAL RISK THAT CAN RESULT IN SUBSTANTIAL LOSSES AND ARE SUITABLE ONLY FOR INVESTORS PREPARED TO BEAR SUCH RISK. THE RISKS FACTORS BELOW ARE NOT INTENDED TO BE EXHAUSTIVE FOR THE CREDIT FUND OR ANY SEPARATELY MANAGED ACCOUNT. PROSPECTIVE CLIENTS SHOULD ALSO CAREFULLY REVIEW THE RISKS DESCRIBED IN THE APPLICABLE CLIENT’S GOVERNING DOCUMENTS: There can be no assurance that the investment objective of the Credit Fund will be achieved or that the investment strategies of the Credit Fund or any Managed Account will be successful, and certain investment practices can, in some circumstances, potentially increase the adverse impact on the Credit Fund’s or a Managed Account’s investment portfolio. The nature of the Credit Fund’s or a Managed Account’s investments involves certain risks and the Credit Fund or a Managed Account will utilize investment techniques (such as leverage, short selling and the use of derivatives) that carry additional risks. An investment in the Credit Fund or a Managed Account’s investments carries substantial risk and is suitable only for persons that can assume the risk of losing their entire investment. The risk factors below for the Credit Fund may also be applicable to a Managed Account client and should be carefully considered by any Managed Account client before entering into a separately managed account with Aquamarine. The particular risks applicable to a Managed Account will depend on the nature of the account, its investment strategy or strategies and the types of securities the account holds. Any Managed Account client is responsible for appropriately diversifying its assets to help guard against the risk of loss. Note that diversification does not assure a profit or protect against loss in a declining market. Operating History. Any prior performance of the principals of the Investment Manager is not necessarily indicative of results that may be achieved with respect to the Credit Fund. As such,

there can be no assurances that the Credit Fund will be able to implement its investment strategy or achieve its investment objective. Dependence on the Investment Manager. The success of the Credit Fund is significantly dependent upon the ability of the Investment Manager to develop and effectively implement the Credit Fund’s investment objective. Investors will be relying entirely on the Investment Manager to conduct and manage the affairs of the Credit Fund. Subjective decisions made by the Investment Manager may cause the Credit Fund to incur losses or to miss profit opportunities on which it would otherwise have capitalized. Because specific investments of the Credit Fund have not yet been identified, the shareholders must rely on the ability of the Investment Manager to make appropriate investments and investment decisions for the Credit Fund. Limited Liquidity. An investment in the Credit Fund is suitable only for sophisticated investors who do not need liquidity with respect to their investment. An investment in the Credit Fund provides limited liquidity. Shares of the Credit Fund are not freely transferable, and a shareholder generally may only redeem its shares in accordance with the limitations described in the governing documents of the Credit Fund. Further, the Board of Directors, after consultation with the Investment Manager, may declare a suspension (generally or in respect of a specific class or classes of shares) of the determination of net asset value of the Credit Fund and/or the subscription and/or the redemption of shares and/or the payment of redemption proceeds in certain circumstances as set out in the governing documents of the Credit Fund. There is currently no market for shares of the Credit Fund, and it is not contemplated that one will develop. The Credit Fund’s shares offered have not been registered under the securities laws of any jurisdiction and, therefore, cannot be resold unless they are subsequently registered under applicable securities laws or an exemption from registration is available. It is not contemplated that registration of the Credit Fund’s shares under any jurisdiction’s securities laws will ever be effected. In-Kind Distributions. The Credit Fund expects to distribute cash to a shareholder upon a redemption. However, there can be no assurance that the Credit Fund will have sufficient cash to satisfy redemption requests, or that the Credit Fund will be able to liquidate investments at the time of such redemption requests at favorable prices. Under the foregoing circumstances, and in consultation with the Investment Manager, and under other circumstances deemed appropriate by the Credit Fund, a shareholder may receive inkind distributions from the Credit Fund. A Class or Series of Shares is not a Separate Legal Entity. As among the shareholders, the appreciation and depreciation attributable to a class or series of shares will be allocated only to such class or series. Similarly, expenses attributable solely to a particular class or series of Shares will be allocated solely to that class or series. However, a creditor of the Credit Fund will generally not be bound to satisfy its claims from a particular class or series of shares. Rather, such creditor generally may seek to satisfy its claims from the assets of the Credit Fund as a whole. Thus, if a creditor’s claims relating to a particular class or series of

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Aquamarine provides investment advisory services to Managed Accounts and Funds. Interests in the Funds are offered only to sophisticated and qualified investors, including but not limited to, high-net-worth individuals and family offices. The minimum initial subscription amount in the Credit Fund is $1,000,000; provided that the Board of Directors, in its sole discretion, may accept subscriptions of a lesser amount provided that the lesser amount is not less than $100,000 or such other amount as may be required by law or regulation applicable to the Credit Fund or Aquamarine from time to time. As of the date of this brochure, Aquamarine does not have a set minimum dollar value of assets or other conditions for starting or maintaining an account.

As noted above, the Credit Fund will also pay Aquamarine a performance fee, on an annual basis following the end of each fiscal year, equal to 15.0% of the net realized and unrealized appreciation in the net asset value of each series of shares of the Credit Fund; provided, however, that a performance fee generally will only be paid with respect to the net realized and unrealized appreciation in the net asset value of a series of shares in excess of the Prior High NAV (as defined below) of such series of shares of the Credit Fund; provided, further, that a performance fee generally will only be paid with respect to the net realized and unrealized appreciation in the net asset value of a series of shares in excess of the average annualized CME Term SOFR 3-Month Index (the “3-Month SOFR”) on a risk-adjusted basis plus 250 basis points for the financial year in respect of which the performance fee is being calculated (source: CME Group website or another recognized source – it being noted that (a) CME Term SOFR Reference Rates provide an indication of the forward-looking measurement of overnight SOFR, based on market expectations implied from derivatives markets; and (b) the Secured Overnight Financing Rate (SOFR) is a broad measure of the cost of borrowing cash overnight collateralized by Treasury securities) (the “Benchmark”). If the 3-Month SOFR is no longer published or no longer deemed a representative cash index, Aquamarine, in consultation with the board of directors of the Credit Fund (the “Board of Directors”), shall use its best endeavours to determine, in

good faith, an alternative index against which to measure the Benchmark. If a shareholder of the Credit Fund redeems all or a part of its shares prior to the last calendar day of the fiscal year, the performance fee is calculated and then paid to Aquamarine at the time of such redemption with respect to shares that are redeemed. The “Prior High NAV” of a series of shares of the Credit Fund is the net asset value of that series immediately following the date as of which the last year-end performance fee was determined with respect to such series (or, if no performance fee has yet been determined with respect to such series, the net asset value of that series immediately following its initial offering). The Prior High NAV of a series of shares will be adjusted for redemptions from such series. The Credit Fund’s offering documents include information about the performance fee. In addition, as noted above, Aquamarine receives a profits allocation from certain Managed Accounts, generally up to 15% of realized and/or unrealized gains. Such performance-based fees and profit allocations may create potential conflicts of interest because Aquamarine manages, or may manage in the future, clients with such fee arrangements side-by-side with clients that Aquamarine charges a fixed fee only based on assets under management, including that Aquamarine (and its supervised persons) have an incentive to favor accounts where Aquamarine receives a performance-based fee. Please see Item 10, “Other Financial Industry Activities and Affiliations” and Item 11, “Code of Ethics, Participation or Interest in Client Transactions and Personal Trading” for a discussion of the conflicts and risks associated with side-by-side management and how Aquamarine addresses these matters.

Neither Aquamarine nor its employees are registered, or have an application pending to register as a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor or an associated person (or registered representative) of the foregoing entities. Neither Aquamarine nor any of its employees has any relationships or arrangements that are material to its advisory business or to Aquamarine’s clients with any related persons to disclose.

Trading Code of Ethics Aquamarine has implemented policies and procedures relating to, among other things, portfolio management and trading practices, personal investment transactions and insider trading that are designed to prevent or address conflicts of interest. Aquamarine’s policies and procedures, including the Code of Ethics (the “Code”), apply to all Aquamarine supervised persons and are intended to help appropriately mitigate conflicts of interest with respect to clients if they occur. The Code is available to any client or prospective client upon request. The Code is designed to assist Aquamarine in detecting and addressing potential conflicts of interest. The Code sets out standards of conduct and covers personal investment transactions of all supervised persons and their immediate family members, which includes most persons sharing the same household as the employee. Although the Code permits supervised persons to trade in securities for their own accounts, the Code contains preclearance procedures, reporting requirements and other provisions that restrict trading by supervised persons. Supervised persons are required to disclose their personal securities accounts upon commencing employment at Aquamarine and must submit duplicate securities account statements and confirmations. Supervised persons may buy or sell for their own accounts securities that are also held by clients. Conversely, supervised persons may buy and sell securities for client accounts which they themselves own. Such transactions are permitted as long as in compliance with the Code. Reports of personal transactions in securities are reviewed by Aquamarine’s Chief Compliance Officer at least quarterly. Any supervised person who violates the Code may be subject to remedial actions including, but not limited to, censure, demotion, suspension or dismissal. Supervised persons are also required to promptly report any violation of the Code of which they become aware and complete a certification regarding their compliance with the Code at least annually. Potential Conflicts Relating to Advisory Activities Aquamarine provides investment management to the Funds and Managed Accounts. Any Managed Account or Fund may have investment objectives, programs, strategies and positions that are similar or dissimilar to or may conflict with those of any other Managed Account or Fund, as applicable. Also, a Fund or Managed Account may invest in businesses that compete with, have interests adverse to, or are affiliated with the issuers of securities held by any other Fund or Managed Account, which could adversely affect the performance of that Fund or Managed Account. In addition, the fees payable to Aquamarine and the terms of any Managed Account or Fund may differ from those of any other Managed Account or Fund. There is no assurance that a Managed Account or Fund with investment objectives, programs or strategies similar to those of any other Managed Account or Fund will hold the same positions or perform

in a substantially similar manner as that Managed Account or Fund. Aquamarine may give advice or take action with respect to the investments of a Fund or Managed Account, which may differ from the advice given or the timing or nature of any action taken with respect to investments of any other Fund or Managed Account. As a result of such advice or actions, the prices and availability of securities and other financial instruments in which a Fund or Managed Account invests or may seek to invest, and the performance of a Fund or Managed Account may be adversely affected. A Fund or Managed Account may acquire securities or other financial instruments of an issuer that are senior or junior to securities or financial instruments of the same issuer that are held by another Fund or Managed Account (e.g., a Managed Account may acquire senior debt while a Fund may acquire subordinated debt). Aquamarine recognizes that conflicts may arise under such circumstances and will endeavor to treat the Funds and the Managed Accounts fairly and equitably. Aquamarine may have ongoing relationships with companies whose securities are held by or are being or may be considered for a Fund or a Managed Account. Further, Aquamarine’s supervised persons may from time to time invest their own assets in securities or instruments in which Aquamarine may invest a Fund’s or a Managed Account’s assets. Aquamarine or its supervised persons may buy, sell or hold securities or other instruments for their own accounts while making different investment decisions, where applicable for a Fund or a Managed Account. In addition, Aquamarine may invest in certain eligible investment funds managed by Aquamarine of their choosing and are not required to invest in any such funds. It is expected that, if such investments are made, the size and the nature of these investments will change over time. Furthermore, other clients of the Investment Manager or its advisory affiliates may invest directly in the Credit Fund (for instance pursuant to the terms of discretionary mandates between such other clients and the Investment Manager). The Investment Manager or its advisory affiliates, or key principals or employees of any of them, may invest directly in the Credit Fund. Transactions described in this paragraph are permissible as long as in compliance with the Code. It is the policy of Aquamarine to allocate investment opportunities to the Funds and Managed Accounts fairly and equitably, to the extent practicable, over a period. Aquamarine will have no obligation to purchase, sell or exchange any security or financial instrument for a Fund or Managed Account which Aquamarine may purchase, sell or exchange for any other Fund or Managed Account if Aquamarine believes in good faith at the time the investment decision is made that such transaction or investment would be unsuitable, impractical or undesirable for that Fund or Managed Account. Due to the nature of the fixed income markets, as well as specific a Fund’s and a Managed Account’s guidelines and objectives, pro rata allocation of investment opportunities will not always be feasible. Accordingly, Aquamarine will not prescribe one specific manner in which the securities or financial instruments will be allocated among the Funds and Managed Accounts, and Aquamarine may use pro rata, rotational, percentage or other reasonable allocation methods. An allocated transaction may be modified if strict adherence to an anticipated

allocation may lead to impractical or undesirable results such as odd lots or de minimis allocations. The factors that Aquamarine may consider in allocating investments among clients include, but are not limited to, each client’s investment guidelines or restrictions and investment strategies, concentrations and diversification within a client, tax and regulatory issues, the nature and size of existing portfolio holdings and cash positions, risk/return objectives, anticipated redemptions and subscriptions (liquidity). In certain circumstances Aquamarine may give special consideration to certain Funds or Managed Accounts such as a new Fund or Managed Account (including those in which the Aquamarine may have an interest) with a substantial amount of available cash. With respect to initial public offerings of equity securities (“new issues”), Aquamarine will determine which Funds or Managed Accounts are suitable and eligible to receive such issues, taking into consideration the factors described above. Whenever practicable, new issues will be allocated pro rata among all suitable and eligible Funds or Managed Accounts in proportion to their relative capital balances, as determined by Aquamarine in its sole discretion. If Aquamarine determines that the purchase or sale of the same security is in the best interest of more than one Fund or Managed Account, Aquamarine may, but is not obligated to, aggregate orders placed simultaneously to obtain best execution and reduce transaction costs to the extent permitted by applicable law. When an aggregated order is filled through multiple trades at different prices on the same day, each participating Fund or Managed Account will receive the average price with transaction costs allocated pro rata based on the size of each Fund’s or Managed Account's participation in the order (or allocation in the event of a partial fill) as determined by Aquamarine. In the event of a partial fill, allocations may be modified on a basis that Aquamarine deems to be appropriate, including, for example, to avoid odd lots or de minimis allocations. Aquamarine may elect not to aggregate trades, and, in such cases, trades are processed in the order they are placed with the broker or counterparty selected by Aquamarine. As a result, certain trades in the same security or instrument for one Fund or Managed Account (including a Fund or Managed Account in which the Aquamarine and it personnel may have a direct or indirect interest) may receive more or less favorable prices or terms than another Fund or Managed Account and orders placed later may not be filled entirely or at all, based upon the prevailing market prices at the time of the order or trade. In addition, some opportunities for reduced transaction costs and economies of scale may not be achieved. Aquamarine and its personnel may not trade for the Funds, Managed Accounts, or for their own benefit or recommend trading in securities of a company while they are in possession of material, non-public information (“Inside Information”) concerning such company, or disclose such Inside Information to any person not entitled to receive it. Aquamarine may gain access to Inside Information, and accordingly, there may be certain cases where Aquamarine may be restricted from effecting purchases and/or sales of assets on behalf of the Funds or Managed Accounts. Aquamarine seeks to minimize those cases whenever practicable, consistent with applicable law and its policies, and in consultation with Aquamarine’s Chief Compliance Officer and its outside legal counsel, but there can be no assurance that it will not receive Inside

Information and that such restrictions will not occur. At times, Aquamarine, in an effort to avoid restriction for the Funds or Managed Accounts, may elect not to receive Inside Information that other market participants are eligible to receive or have received. Cross Trades Aquamarine may effect cross transactions between client accounts when Aquamarine determines that such transactions are appropriate and in the best interests of both participating clients. A cross transaction occurs when Aquamarine causes a transaction to be effected between two client accounts advised by Aquamarine. Cross trades may be used to facilitate portfolio rebalancing, manage liquidity, or transition positions between client accounts without incurring brokerage commissions that might otherwise be associated with executing transactions in the open market. Cross transactions create a conflict of interest because Aquamarine represents both the buying and selling accounts and therefore has an incentive to complete the transaction in a manner that may benefit one client over another. To address this conflict, Aquamarine has adopted policies and procedures designed to ensure that cross transactions are effected in a manner consistent with its fiduciary obligations. Such procedures generally require that (i) the transaction be effected at an independently determined market price consistent with applicable regulatory requirements; (ii) the transaction be executed in a manner that is fair and equitable to both participating client accounts; and (iii) Aquamarine maintain records of cross transactions in accordance with applicable regulatory requirements. Where required, Aquamarine will comply with the applicable provisions of the Advisers Act, including Section 206(3), and obtain appropriate client consent prior to effecting such transactions. Aquamarine does not currently expect cross trades to occur frequently but retains the ability to engage in such transactions when appropriate. Soft Dollar Arrangements The Adviser may receive research products and services from broker-dealers that execute securities transactions on behalf of clients, including the private funds advised by the Adviser. These research products and services may include, among other things, economic and market analyses, industry and company research, financial publications, portfolio valuation services, market data, pricing services, and other information or services that assist the Adviser in the investment decision-making process. Such research products and services may be provided by broker-dealers without a separate fee, but in consideration for the Adviser directing client brokerage transactions to those brokerdealers. These arrangements are commonly referred to as “soft dollar” arrangements. The Adviser may rely on the safe harbor provided by Section 28(e) of the Securities Exchange Act of 1934 (as amended and the rules and regulations promulgated thereunder, the “Exchange Act”), which permits an investment adviser to cause a client to pay a broker-dealer a commission for effecting a securities transaction in excess of the amount another broker-dealer

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Although Aquamarine has no formal soft dollar arrangements or directed brokerage arrangements at this time, Aquamarine’s approved custodians provide Aquamarine with certain brokerage and research products and services that qualify as “brokerage or research services” under Section 28(e) of the Exchange Act. Aquamarine’s fundamental policy it to seek for its clients what, in its judgment, will be the best overall execution of purchase or sale orders and favorable net prices in securities transactions consistent with its judgment as to the business qualifications of the various broker/dealer firms with which Aquamarine does business. Aquamarine’s decisions with respect to the market in which the transaction is to be competed, the form of transaction, and the allocation of orders among broker/dealers are made in accordance with this policy. With respect to any brokerage commissions charged by executing broker/dealers, Aquamarine will regularly review such charges and such comparative standards that it regards as pertinent for purposes of evaluating the reasonableness of such commissions. It is Aquamarine’s policy to seek to obtain best execution on client transactions and to execute client trades on the most advantageous terms reasonably available under the circumstances. Best execution is not limited solely to the consideration of the lowest available price or commission rate. For example, complicated high-volume transactions in securities, derivatives, or other investments require a broker-dealer with a higher level of competence and infrastructure to help ensure client transactions are executed without error, delay or needless expense. As a result, in seeking to obtain best execution, Aquamarine takes into account a number of factors and criteria, based on information available at the time, including but not limited to price of the security; any markup or mark-down on the security; and any commission paid to the broker-dealer. As permitted by law, Aquamarine can cause its clients to pay broker/dealers an amount of commission for executing a portfolio transaction order on behalf of its clients which is in excess of commissions other broker/dealers would have charged for effecting such a transaction. In order to do so, Aquamarine must determine in good faith that the higher commission is reasonable in relationship to the value of the services provided by the executing broker/dealer viewed in terms of either a particular transaction or Aquamarine’s overall responsibilities to the clients.

Aquamarine does not receive any economic benefit, including sales awards or prizes, from any third party for providing advisory services to Clients. On occasion, Aquamarine can enter into an agreement with an unaffiliated third-party promoter in order to pay cash compensation to the promoter for referring advisory clients. To the extent Aquamarine enters into such an arrangement, Aquamarine will comply with the applicable requirements under Rule 206(4)-1 of the Advisers Act pertaining to compensated “endorsements.” Clients that are referred to Aquamarine through such arrangements will be provided a disclosure document describing the terms and conditions of the arrangement, including the compensation paid to the promoter. Clients will not be charged any additional fees or expenses resulting from the referral and any compensation to a promoter will be borne entirely by Aquamarine.

There are no legal or disciplinary events that are material to a client’s or prospective’ clients evaluation of Aquamarine’s advisory business or the integrity of its management.

Aquamarine performs regular, periodic reviews which include monitoring the performance of investments in a Fund or Managed Account, a comparison of a Fund’s or Managed Account’s portfolio to the diversification and asset allocation of that Fund or Managed Account as compared with that Fund’s or Managed Account’s investment objectives, and an evaluation of the investment strategy in light of any change in circumstances. Aquamarine’s reports include

details of client holdings, asset allocation, and other transaction information. Comparisons to market indices and account performance will be used to evaluate performance. Aquamarine will provide written reports regarding a Fund’s or Managed Account’s portfolio and investment performance.

Aquamarine does not maintain physical custody of client assets. Aquamarine may recommend a qualified custodian for custody and other related services as set forth above under Item 12. The qualified custodian provides account statements directly to clients at their address of record on at least a quarterly basis. Clients need to carefully review the statements sent by a custodian. Since Aquamarine is an offshore adviser, Aquamarine is not subject to rule 206(4)-2 of the Advisers Act (the “custody rule”) with respect to the offshore funds that it advises.

Aquamarine provides discretionary investment management services to a client only if the client or its agent and Aquamarine have signed a written investment management agreement or other document showing the client’s grant of discretion or other authority for its portfolio. Aquamarine generally receives discretionary authority from clients to select, and to determine the quantity of securities or financial instruments to be bought or sold for the client’s portfolio. In exercising its discretionary authority to make investment decisions for a Client’s portfolio, Aquamarine adheres to the investment policies, strategies, limitations and restrictions of the portfolio.

Aquamarine will vote proxies for any securities in the Funds and Managed Accounts under Aquamarine’s proxy voting policies and procedures (the “Proxy Policy”). Aquamarine will

supervise and periodically review its proxy voting activities and the implementation of the Proxy Policy. It is Aquamarine’s policy to exercise any voting or consent rights with respect to securities held in accounts over which Aquamarine has discretionary voting authority consistent with Aquamarine’s fiduciary obligations and applicable law. Each proxy is voted on a case-by-case basis, taking into account relevant facts and circumstances in the best interest of the client. When considering client proxies, Aquamarine may determine not to vote a proxy in certain circumstances in accordance with its fiduciary duties or its agreement with a client. The Proxy Policy requires that Aquamarine identify and address conflicts of interest. If a material conflict of interest is identified, Aquamarine will determine whether voting in accordance with the guidelines set forth in the procedures is in the best interests of its client or whether taking some other action may be more appropriate. If a conflict is identified, Aquamarine will then make a determination (which may be in consultation with outside legal counsel or compliance consultants) as to whether or not the conflict is material. If a conflict is material, Aquamarine will determine what course of action is in the best interests of the client (which may include utilizing an independent third party to vote such proxies).

Aquamarine does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance and therefore is not required to provide, and has not provided, a balance sheet. Furthermore, Aquamarine does not have any financial commitments that may impair its ability to meet contractual and/or fiduciary obligations to clients. Finally, Aquamarine has not been the subject of a bankruptcy proceeding.