ARGENTEM CREEK PARTNERS LP

Argentem Creek is a registered investment adviser organized as a limited partnership under the laws of the State of Delaware. Argentem Creek was formed in connection with the spinout of certain private investment funds from Black River Asset Management LLC (“Black River”) in December 2015. As Black River wound down, the members of its Emerging Market Credit Opportunity Team joined Argentem Creek as it launched. Today, Argentem Creek continues to pursue its primary strategy of sourcing, trading and investing in high yield, structured, stressed and distressed corporate debt in emerging markets. Daniel Chapman, Managing Partner, Chief Executive Officer and Co-Chief Investment Officer is the principal owner of Argentem Creek through Argentem Creek Holdings LLC. Mr. Chapman, together with other investment professionals, executes Argentem Creek’s investment strategy. Argentem Creek serves as the investment adviser to a number of private investment vehicles (“Private Funds”), and in such capacity, provides portfolio management and investment advisory services to the Private Funds. Through the Private Funds, Argentem Creek primarily focuses on investing in special situations and structured capital solutions, including high yield, stressed and distressed debt, bankruptcy situations, out-of-court restructurings and workouts involving companies located or doing business in emerging and lesser developed countries. Argentem Creek’s investment advice is limited to such investments that are permissible in accordance with each Private Fund’s offering documents and operating documents, including investment management agreements or sub-advisory agreements (collectively, “Fund Documents”). Additional information regarding the type of investments made by the Private Funds is provided in Item 8. Argentem Creek currently does not provide investment advisory services to an institutional managed account client, but it may provide services to additional managed accounts in the future (“Managed Accounts”). In this Brochure Argentem Creek refers to Private Funds and Managed Accounts as “Clients”. As of December 31, 2025, Argentem Creek managed approximately $550,574,134 Regulatory Assets Under Management (as defined in Form ADV Part 1) on a discretionary basis. In addition, pursuant to the agreements governing two of the managed Funds, (which are closed-end Funds, that do not solicit investors), Argentem Creek is now required to obtain pre-approval from the limited partners in these Funds prior to purchase or sales of any investment except as otherwise specified in the Fund’s governing documents. The total AUM of these non-discretionary Funds is: $77,801,686

Advisory Fees paid by the Private Funds to Argentem Creek are described in the respective Fund Documents. Argentem Creek is generally paid a management fee by each Private Fund monthly or quarterly, as the case may be, in advance or otherwise in accordance with the relevant Fund Documents. Argentem Creek is generally authorized under the relevant Fund Documents to charge management fees but may waive its right for management fees in certain unique circumstances. Argentem Creek is authorized to deduct management fees directly from the assets of the Private Funds. Currently, Argentem Creek charges management fees that range between 0% to 1.75%. Please note, that Argentem Creek has agreed to cease charging management fees for certain Funds it manages. These

certain Funds for which Argentem agreed to cease charging management fees, are closed-end Funds which do not solicit new investors. Please refer to the Fund Documents of each applicable Private Fund for complete information on the fees and compensation payable with respect to such Private Fund. Argentem Creek or its affiliates may also receive incentive compensation or income based on net appreciation or realized return. Argentem Creek may agree to charge higher or lower fees, different fee structures, or different expense payment arrangements depending on a number of factors, including but not limited to, whether investor accounts are employee or affiliate-related, if an increase in assets is expected, if assets under-perform, if investment period is longer than expected, and the length of an investor relationship. In addition, pursuant to the agreements governing one of the managed Funds, (which is a single-investor closed-end Fund, that does not solicit investors), Argentem Creek is receiving certain fixed fees for managing certain investments in lieu of management fees. The Managed Accounts, to the extent Argentem Creek enters into such an arrangement, pay management fees and/or incentive or performance fees based on separately negotiated private contracts (“Private Contracts”). Private Funds Expenses: The Private Funds pay for all expenses attributable to the Private Funds’ activities and investments as described in the relevant Fund Documents. Additionally, Argentem Creek has adopted Expense Policies and Procedures to address how expenses are charged to the Private Funds. For the avoidance of doubt, any inconsistency between a Private Fund’s Fund Documents and the Expense Policies and Procedures will be resolved in favor of the Private Fund’s Fund Documents. Generally, the following expenses are to be charged to the Private Funds pursuant to the Expense Policies and Procedures: (i) management fees; (ii) organizational expenses;

all operating expenses of the Funds, including administrator, legal, auditing, consulting, research, quotation services, valuation services, Bloomberg fees and costs, custodial, financing and securities registration fees, all fees and disbursements of the independent attorneys, accountants and consultants of the Funds, the General Partner and its Affiliates on behalf of the Funds, insurance premiums for directors’ and officers’ liability insurance, errors and omissions insurance, or other insurance, in each case covering the Investment Manager Parties or others (a portion of which, prior to the date hereof, was borne by the Investment Manager), any tax imposed on the Funds in any jurisdiction including transfer and withholding taxes, communications expenses, including any software or online data portal used in connection with reporting or communications to Limited Partners and any costs and expenses incurred in connection with webcasts, video conferencing or similar technology services, all expenses and costs associated with meetings of the Limited Partners (including accommodation, meal, event and other similar expenses and costs related thereto), all expenses and costs associated with the preparation and circulation of reports to the Partners (including bespoke reporting and services

(including translation services) for certain Limited Partners, except to the extent such cost has been agreed to be allocable solely to or paid solely by the applicable Limited Partners), expenses related to administration of any most-favored-nation process, expenses related to ESG compliance, data protection, anti-bribery and corruption, anti-money laundering and “know your customer” compliance, expenses in connection with the attendance at or sponsorship of any industry conferences and meetings related to Investments or related to the evaluation of potential Investments or specific sectors, geographies, or industries solely to the extent that such conferences and meetings are in furtherance of the Fund’s business, expenses related to governmental or regulatory charges payable by the Fund, including fees, costs and other expenses relating to compliance with tax, regulatory or other legal requirements applicable to the Fund and those incurred in connection with any tax filing, tax audit, investigation, settlement, or review of the Fund, except, in each case, to the extent such amounts are, in each such case, (A) allocable to or indemnifiable by one or more Limited Partners and (B) actually borne or paid by such Limited Partner, expenses incurred by the Partnership Representative and Designated Individual for the Fund, all fees, expenses, and costs incurred in connection with government and regulatory filings (but excluding Form ADV), all interest, fees, costs, expenses and obligations (including repayment obligations) incurred in connection with any indebtedness, or other credit arrangement (including a credit facility, any line of credit, loan commitment, or letter of credit for the Fund or related to any Investment (or any underlying asset)) made by the Fund or any subsidiary thereof or any Alternative Investment Vehicle or similar alternative structure, including all expenses incurred in negotiating, entering into, effecting, maintaining, varying, refinancing, and terminating any such indebtedness, or credit arrangement and all legal, accounting, audit, consulting, appraisal, and other expenses (to the extent not subject to reimbursement) incurred therewith, expenses relating to fairness opinions, independent thirdparty appraisals, and pricing services beyond ordinary valuation services, relations, meetings and expenses associated with preparing the Funds’ financial statements and tax returns and related costs, as well as other administrative expenses of the Funds, including the annual registration and registered offices fees payable to the Cayman Islands Register of Exempted Limited Partnerships and the Funds’ registered office providers in the Cayman Islands, and the Funds’ allocable share of the costs, fees and expenses relating to external information technology systems (e.g., Bloomberg), legal functions, accounting and tax preparation functions and expenses attributable to the wind-up and termination of the Funds; all ongoing offering expenses of the Funds, including the costs of updating this Memorandum and revisions of the Partnership Agreement, Supplementary Agreements, or other Fund-related legal documents, as well as legal advice related to offering the Argentem Funds; all out-of-pocket investment-related expenses, which include any expenses incurred in connection with the investigation, sourcing, making, holding, financing, management, sale or proposed sale of any Fund investment, including any such expenses associated with proposed transactions that are ultimately not consummated by the Fund, to the extent not reimbursed by a third party (including broken-deal, reverse termination fees, bid expenses, or similar costs and those that would have been allocable to co-investors had such proposed transaction or investment been consummated, if the amount allocable to such co-investors is not paid by such parties), investment-related travel and entertainment (in accordance with the expense policy of the Investment Manager), any costs or fees, including legal fees, relating to the formation, management, or administration of any special purpose investment vehicles, and any costs associated with entering into currency or other hedging, protective, or enhancing transactions with respect to such investments;

all costs charged or specifically attributed or allocated by the General Partner or the Investment Manager to the Fund in connection with in-house legal, technical, tax, analytics, capital markets, financial, administrative and accounting services to the Funds, including, without limitation, compensation, expenses (including travel), benefit and other overhead allocable to employees of the Investment Manager providing such services up to the costs of obtaining the same or similar services at standard rates charged by third-party service providers, in each instance as determined by the General Partner in its reasonable discretion (the “Allocated Overhead Costs”); and

any out-of-pocket costs and other expenses incurred by the Investment Manager, the Fund, or any of their Affiliates in connection with the administration or winding up of ACP Fund I and its related entities, which are currently being maintained in order to finalize the transfer of assets to the Fund, to the extent such costs and expenses are accrued for or incurred following the final distribution date of ACP Fund I LP, a Cayman Islands exempted limited partnership, and all extraordinary expenses, including litigation-related, indemnification and other extraordinary expenses of the Fund.

All Fund Expenses generally will be allocated among the Limited Partners pro rata in accordance with their Capital Account balances for the calendar month in which they are approved or paid. Certain expenses also may be allocated to fewer than all Limited Partners (e.g., expenses related specifically to the Limited Partners’ non-compliance with tax information reporting regimes or other regulation or taxes resulting from audit adjustments). To the extent certain expenses are shared among Argentem Funds the Investment Manager expects that any shared expenses will be allocated among the Funds on an equitable basis.

Please note that the Manager has engaged a third-party administrator to provide fund administrative, back-office, middle-office and related services to the Funds. The costs of the administrative services provided to the Funds are substantial.

With respect to service providers to the Funds or operating partners, the Funds will bear the costs of engaging such service providers. These costs are in addition to management fees and carried interest. All Fund expenses will be allocated among the investors, pro rata in accordance with the net asset value as of the end of the calendar month in which such fee is processed and paid. For the avoidance of doubt, any tax imposed on a Private Fund in any jurisdiction including transfer and withholding taxes is charged to that Private Fund.

Disclosure Regarding Allocation of Third-Party Service Provider Expenses Effective for the calendar year 2024 and going forward, Argentem Creek has adopted a policy to allocate certain expenses associated with services provided by certain third parties to the Private Funds it manages. These services include, but are not limited to, outsourced Chief Financial Officer (CFO) services, accounting, and other operational or administrative support necessary for the Private Funds' operations (together with CFO and GC, “Third Parties Costs”).

Description of Allocated Expenses Argentem Creek has determined that these third-party services directly benefit the Private Funds and are integral to their management and operations. Therefore, Argentem Creek has allocated the actual costs of these services, as incurred, to the Private Funds. Such allocated expenses include:

Cost associated with accounts payable allocation, review and posting Cost associated with audit preparation, support and review Cost associated with regulatory filing preparation and review Cost associated with tax work and review Cost associated with board meeting preparation and review Cost associated with collateral/cash management Cost associated with trade-related tasks Cost associated with corporate action work Cost associated with EOD pricing and reconciliation Cost associated with Fund accounting and quality control Cost associated with external reporting Cost associated with Reporting and Trade Order systems Costs associated with fund formation and structuring Costs associated with fund governance and oversight Costs associated with regulatory filings and reporting obligations Costs associated with investor agreements and subscription documents Costs associated with dispute resolution or litigation Costs associated with contractual reviews and negotiation Costs associated with tax analyses of investment structures and strategies Retroactive Allocation for 2024 In addition to implementing this policy on a prospective basis, Argentem Creek has determined to retroactively allocate applicable Third Parties Costs for the calendar year 2024 to the Private Funds. These retroactive allocations are calculated based on actual costs incurred and where appropriate, based on AUM during 2024, and will be included in the Private Funds' financial reporting. Allocation for 2025 Due to an oversight, certain technology application expenses that should have been allocated to the Funds were not charged during part of the year. This issue was identified and rectified toward the end of the year, after which the applicable expenses were charged consistent with the Adviser’s expense allocation procedures and the Funds’ governing documents. These allocations were calculated based on AUM during 2025, and will be included in the Private Funds' financial reporting.

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Argentem Creek’s investment strategy primarily focuses on investing in special situations and structured capital solutions, including high yield, stressed and distressed debt, bankruptcy situations, out-of-court restructurings and workouts involving companies located or doing business in emerging and lesser developed countries. Through the Private Funds and Managed Accounts it manages, Argentem Creek may invest across the capital structure in debt or equity securities, and other related investments, in public and private companies that Argentem Creek believes are undervalued or otherwise likely to result in strong returns. In an effort to meet its investment objectives, Argentem Creek’s investment approach seeks to emphasize fundamental credit analysis, due diligence and a focus on the industries and market position of each of the companies in which its Clients will invest. The Fund may also, from time to time, make opportunistic investments in such assets in developed markets. The material risks presented by the strategies and financial assets pursued by Argentem Creek are set forth below and will apply to its Clients to the extent such Clients use the strategies or financial assets described. Additional information is contained in the Fund Documents of each Client. This Brochure does not purport to contain complete disclosure of all risks that may be relevant to a prospective investor in a Private Fund or a prospective Client. The list below of certain risk factors is illustrative only and does not purport to be complete. Nor does it purport to explain rather than simply identify certain of the principal risks of an investment in the Funds. Prospective investors should read the entirety of Fund governing documents and consult with their own legal, financial, tax and other advisors before deciding to make an investment in the Funds managed by Argentem Creek. Investing involves risk of loss that an investor should be prepared to bear. Investments by Argentem Creek involve significant risks. There can be no assurance that Argentem Creek will achieve the investment objectives of any particular strategy or Client, avoid substantial, or complete, loss, or otherwise be able to carry out its investment strategy successfully.

Market Risks in General Risk of Loss; Risk of Ruin. An investment in the Funds involves a high degree of risk, including the risk of substantial or even total losses. “Alternative investment strategies,” such as those implemented for the Funds, are subject to a “risk of ruin” (sudden and material losses) of which no indication is given in their past performance. Argentem Creek’s strategy is subject to market risk: for example, directional price movements, deviations from historical pricing relationships, changes in the regulatory environment, changes in market volatility, “flights to quality” and “credit squeezes.” Certain strategies employed by Argentem Creek as well as investments in emerging markets generally have from time to time incurred sudden and dramatic losses as a result of such market events.

The particular or general types of market conditions in which Argentem Creek’s Clients may incur losses or experience unexpected performance volatility cannot be predicted, and Clients may materially underperform other investment funds with substantially similar investment objectives and approaches. Emerging market economies are more likely to react drastically to changes of economic conditions as compared to the more developed markets. No Material Restrictions. Subject to the Funds focusing their investment activities primarily in the types discussed in the respective governing documents and the investment policies specifically set forth in the investment policies, there are no material restrictions on the instruments, markets or countries in which the Funds may invest or on the strategies which may be employed by the Investment Manager on behalf of the Funds. Compliance with the Investment Policies. As a result of complying with the respective investment policies, the Funds may not be able to make certain investments when the Investment Manager would otherwise recommend doing so. As a result, compliance with the respective investment policies may in certain circumstances result in the Funds’ foregoing potential investment opportunities and/or incurring losses. Potential for Insufficient Investment Opportunities. Argentem Creek may not be able to secure a sufficient number of investment opportunities to utilize the full amount of the capital contributions made to the Funds. The activity of identifying, completing and realizing attractive investments is competitive and involves a high degree of uncertainty. The availability of investment opportunities also will be subject to market conditions as well as to the prevailing regulatory and political climate. Projections. Investment decisions will be made based on a variety of factors, including projections developed by the investment team. Projections are inherently uncertain and subject to factors beyond the control of either the investment team or the investment in question. The inaccuracy of certain assumptions, the failure to satisfy certain financial requirements and the occurrence of unforeseen events could impair or eliminate the ability of an investment to realize projected values and/or cash flow. Investing in Emerging Markets Generally Argentem Creek concentrates its investment activities on behalf of its Clients primarily in emerging markets. While the potential investment returns in emerging markets can be higher than those available in more developed economies, the risks of such investments may also be correspondingly greater. Emerging markets can be inefficient and potentially illiquid markets in which the risk of market disruption is exacerbated. Consequently, Clients are subject to the volatile economic conditions in these markets, which can be materially affected by governmental intervention, illiquidity, and other factors. The general risks of emerging markets investing (in addition to issuer-specific risks) include, but are not limited to, the following: Emerging market securities and derivatives may be less liquid and more volatile than comparable instruments in developed countries. Political or economic disruptions in a country in which Argentem

Creek invests on behalf of its Clients may lead to a material, or complete, loss of such Private Fund’s investment in that economy. Argentem Creek has no means of predicting where political or economic unrest will develop. Emerging markets securities have a much greater risk of default. In fact, it is quite possible that the issuers or guarantors of emerging markets securities will not, in fact, have the capacity and/or willingness to pay interest or principal as due in the event of adverse business, financial or economic conditions. A Client may suffer from major defaults in the countries in which it is invested, while at the same time the emerging markets sector in general might be profitable for other investors. Emerging market securities and derivatives may be more difficult to value than comparable instruments in developed countries. Investments in emerging market securities and derivatives in certain markets may be restricted or controlled by certain governmental authorities, limiting, or precluding a Client from investing in such instruments, or materially increasing the costs of making such investments. In emerging markets, a number of the most profitable trading opportunities are not available to all market participants. The Private Funds, in particular, as foreign investors, may not have the same access to, or may be excluded from, a number of transactions. In addition, once committed to a transaction, a Client may not have the same opportunity to liquidate its positions (either to recognize profits or to limit losses) as other market participants. The transaction costs incurred in emerging markets are materially higher than those in the more developed, efficient markets. Certain emerging markets may have relatively underdeveloped markets and banking and telecommunications systems, which create risks related to settlement, clearing and registration of title. Furthermore, due to the relative unreliability of certain local postal and banking systems, a Client may not realize all entitlements attached to its investments, for example, timely receipt of dividends and other payments. Governments may impose currency controls or otherwise act to impede capital flows which could make it difficult or even impossible for Clients to repatriate invested capital and/or any gains on such investments. Accurate information regarding securities and derivatives and their related issuers may be more difficult to obtain and may be less reliable and such issuers may be subject to different accounting standards than are typical in more developed markets. In addition, in many emerging markets the equivalent of “inside information” is often available to a limited group of insiders who trade on it to their advantage, free of the restrictions on such practices imposed by the developed markets. Furthermore, emerging markets are generally significantly less regulated than comparatively more developed markets, including in respect of such matters as “full and fair disclosure” to all market participants. Argentem Creek may be denied access to material information, which is made available to others, particularly in light of the Private Funds’ status as a speculative pool of foreign capital.

Trading on Exchanges in Emerging Markets Argentem Creek may invest on behalf of its Clients through exchanges located in emerging markets, where the protections provided by U.S. regulations do not apply. Some exchanges in emerging markets, in contrast to U.S. exchanges, are “principals’ markets” in which performance with respect to a contract is the responsibility only of the individual member with whom a Client has entered into the contract and not of the exchange or its clearinghouse, if any. In such cases, a Client will be subject to the risk of the inability of or refusal by its counterparties to perform with respect to their contracts with the Client. Trading on exchanges in emerging markets involves the additional risks of expropriation, burdensome or confiscatory taxation, moratoriums, exchange or investment controls and political or diplomatic disruptions, each of which might materially adversely affect Clients’ trading activities. Risk of Concerted Defaults throughout Emerging Markets The economies of different emerging markets vary widely and are often highly volatile. Argentem Creek recognizes that economic disruptions in a country in which a Client is invested may lead to a material, or complete, loss on a Client’s investment in that economy. It is possible that, as a result of concerted political/economic activities across nations in a particular economic region, “domino effect” defaults could occur. This has occurred from time to time in the past. Argentem Creek has no means of predicting where political or economic unrest will develop, and its Clients may suffer from major defaults in the countries in which it is invested, while at the same time other emerging market sectors in general might be profitable for other investors. Positive Correlation among Emerging Markets Issuers in Market Crises It appears to be generally true that in times of market crisis emerging markets instruments as a whole incur major declines in values. Not only do the same market events tend to have a similar effect on the economies of numerous different developing countries, but also as emerging markets debt is generally perceived as being “high risk,” any “flight to quality,” such as to U.S. Treasuries, typically devalues a wide range of emerging markets debt issues. Furthermore, a broad market decline in emerging markets asset values could not only reduce the value of a Client’s emerging markets securities but itself provoke a wave of defaults on such Client’s emerging markets debt holdings. Lack of Access to Legal Remedies in Emerging Markets Laws in certain emerging markets countries regulating ownership and corporate governance of domestic companies (for example, requiring the disclosure of a significant stock purchase or a majority shareholder to make a general offer to shareholders) may not exist or may confer little protection for minority shareholders or creditors. Disclosure and reporting requirements in general, from annual and quarterly reports to prospectus contents and delivery reporting requirements in general, range from minimal to non-existent. Anti-fraud and insider trading legislation is generally rudimentary and enforcement is often lax. There may be no prohibitions or restrictions under local laws on the ability of management to terminate existing business operations, sell or otherwise dispose of their company’s assets, or otherwise to materially affect the value of the company without the consent of its shareholders

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Argentem Creek provides investment advisory services to private funds. Underlying investors in the funds may include, but are not limited to, institutional investors such as trusts, endowments, foundations, corporates, sovereign wealth funds, pension and profit-sharing plans, as well as to highnet-worth investors. All investors, among other requirements, must be: (i) accredited investors as defined in Rule 501(a) of Regulation D under the Securities Act of 1933; and (ii) either qualified purchasers as defined in Section 2(a)(51) of the Investment Company Act of 1940, as amended (the “Investment Company Act”), or knowledgeable employees as defined in Rule 3c-5 under the Investment Company Act. A minimum initial capital contribution is disclosed in the respective Fund’s Confidential Private Placement Memorandum. However, Argentem Creek or the respective Fund’s general partner may reduce or waive the minimum new investment requirements for the Fund’s investors and intends to waive such requirements for Argentem Creek and its affiliates, employees or owners, as well as their family members.

In certain instances, Argentem Creek receives either incentive income or charges the Clients a performance-based fee. The assessment of performance-based fees and any allocations based on performance will be done in accordance with all requirements for such compensation arrangements as specified under Rule 205-3 of the Advisers Act and rules promulgated thereunder, including the requirement that such fees may be charged only to “qualified clients” as that term is defined in Rule 205-3(d). Performance-based fee and allocation arrangements theoretically create an incentive for Argentem Creek to make more speculative investments in the assets purchased for a Client than it might otherwise make to increase the likelihood that Argentem Creek would be paid incentive fees or receive incentive allocations. In addition, such fee arrangements also create an incentive to favor higher paying fee accounts over other accounts that use the same investment strategy but charge only an asset-based management fee. Although Argentem Creek does not currently provide services to any Clients that it charges only an asset- based management fee, it may do so in the future. As a general matter, this conflict is mitigated by provisions restricting the distribution of any incentive compensation relating to the Private Funds – other than for taxes - until certain performance hurdles are met. Please note that some other arrangement may apply for certain Funds as negotiated with the respective investors of these

certain Funds. Argentem Creek has also adopted policies regarding the allocation of investment opportunities that are designed and implemented to seek to treat Clients that are similarly situated fairly and equitably over time. Performance-based fee arrangements create potential and actual conflicts of interest for Argentem Creek. These conflicts of interest and how Argentem Creek addresses them are further described in Item 10 below.

Argentem Creek serves as the investment adviser to the following Private Funds complexes: 1. 2. 3. 4. 5.

Argentem Opportunities Fund LP (previously known as ACP Fund II LP) Argentem Creek Latin American Special Situation Opportunity Fund LP; Conover Investments LP; Pathfinder Strategic Credit II LP; Centurion Opportunity Fund LP.

Argentem Creek’s various affiliates serve as General Partner of the Private Funds and receive any related incentive compensation or income from the Private Funds. Certain conflicts relating to the Private Funds and Argentem Creek are set forth below. Argentem Creek wholly owns an affiliated United Kingdom subsidiary, Argentem Creek Partners (UK) Limited which is the controlling corporate member of Argentem Creek UK LLP, a United Kingdom Limited Liability Partnership. Argentem Creek UK LLP consults with Argentem Creek on investment matters from its offices in London, England. Argentem Creek wholly owns an affiliated United Arab Emirates subsidiary, Argentem Creek Middle East Ltd. Argentem Creek Middle East Ltd provides a local presence for the business development activities of the firm in Middle East and Asia. Argentem Creek also owns Argentem Trade Services (“Argentem TS”) and Argentem Middle East. Argentem TS is a trade finance and services provider created to facilitate international trading of metals and critical minerals, with a focus on energy transition materials. Please refer to Conflicts of Interest section for further discussion regarding Argentem TS and Argentem Middle East.

Conflicts of Interest The discussion of conflicts of interest in this Brochure is not intended to be a complete description of all potential conflicts that may arise in connection with an investment in the Funds managed by Argentem Creek; investors and potential investors should carefully review the applicable governing documents (including the Fund’s offering materials) for additional information regarding conflicts of interest. Argentem Creek may have financial incentives to favor one Private Fund over the other, or to favor the Private Funds or the Managed Accounts over one another. Even if Argentem Creek does not have such incentives, Argentem Creek will be required to allocate its limited resources among the Private Funds and the Managed Accounts. Argentem Creek currently advises multiple Clients which implement similar investment strategies. The investment period and portfolio of any Client may overlap with another Client. In addition, some Clients may be subject to certain investment restrictions, operational controls and fee refund terms that are not applicable to another Client, and other differences (such as disparities in Argentem Creek’s overall relationship with the investor in a single investor fund or any other Client or with the investors in a

comingled fund) could from time to time raise conflicts of interests for Argentem Creek. Additionally, a Private Fund may be subject to the fiduciary duty provisions of ERISA because the underlying assets of the Private Fund are plan assets under ERISA. Irrespective of any conflicts of interest, the management decisions made for a Private Fund (based on individual circumstances) could under certain circumstances adversely affect another Private Fund. Argentem Creek may also manage other Clients with investment objectives and portfolios that are substantially similar to, or significantly overlap with, that of another Client. To the extent of any such overlap, the management decisions made for one Client, (for example, due to different investment periods of the Private Funds, or compliance with investment restrictions applicable to a particular Private Fund) could have a material adverse effect on another Client. One or a subset of Clients or Argentem Creek may invest in assets that are eligible for purchase by the other Clients, which raises potential conflicts. Conflicts may also arise if a Client makes an investment in which another Client has already invested, including conflicts related to investing in different or overlapping levels of an entity’s capital structure. For example, if a Private Fund is investing in debt securities, it may have an interest in restructuring these securities in a manner that another Client, as an existing equity owner, may not find desirable. In addition, questions may arise as to whether payment obligations and covenants should be enforced, modified or waived, or whether debt should be refinanced. Decisions about what actions should be taken in a troubled situation, including whether or not to enforce claims, whether or not to advocate or initiate a restructuring or liquidation inside or outside of bankruptcy, and the terms of any work-out or restructuring raise conflicts of interest. A Private Fund may also participate in restructuring or recapitalization transactions (including those requiring additional investments of capital) involving companies in which other Clients have invested or may invest. These transactions may present conflicts of interest, including determinations of whether existing investors are being cashed out at a price that is higher or lower than market value and whether new investors are paying too high or low a price for the company or purchasing investments with terms that are more or less favorable than prevailing market terms. There can be no assurance that the return on one Client’s investments will not be less than the returns obtained by other Clients participating in the same overall capital structure. Specifically, investors should be aware of the inherent conflicts of interest that arise if a Client is required or desires to liquidate an investment that is also held by one or more other Clients. Especially with regard to illiquid investments, the Client might not be able to liquidate such investment at the time it is required or would like to do so. Alternatively, if the Client is able to sell its portion of the illiquid investment, such sale might impact the value of the investment held by the other Clients and may be at a price and/or on other terms that are more or less favorable than the price and/or other terms received by such other Clients when liquidating such investments. Certain of the Clients may also make investments in entities or assets in which they have already invested (e.g., an additional investment) or that are held by other Clients. The purchase, holding or sale of these investments may enhance profitability of such investments to the related Clients and therefore present conflicts of interests with respect to the investing Client. As noted above, Argentem Creek’s affiliates (in their capacity as general partner) may invest in Private Funds from time to time and qualified employees of Argentem Creek are also permitted to and have

invested in certain of the Private Funds. Additional conflicting interests can arise in connection with these investments. Conflicts of interest may arise because Argentem Creek personnel may serve as directors of certain companies or other legal entities in which the Clients have invested. In those instances, where the Clients are not the sole owners of the applicable company or other legal entity, in addition to any fiduciary duties the Argentem Creek personnel owe to the Clients, as directors of companies or other legal entities, such personnel may owe certain duties to the owners of the companies or other legal entities and to persons other than the Clients. In general, such director positions are often important to the Client’s investment strategy and may have the effect of enhancing the ability of Argentem Creek personnel to manage investments. However, such positions may place Argentem Creek personnel in a position where a decision must be made that is either not in the best interests of the Clients or not in the best interests of the owners of the company or other legal entity. Should such Argentem Creek personnel make a decision that is not in the best interest of the owners of a company, such decision may subject Argentem Creek and the Clients to claims that they would not otherwise be subject to as an investor, including claims of breach of the duty of loyalty, securities claims and other director-related claims. In addition, because of the potential conflicting duties, Argentem Creek may be restricted in choosing investments for the Client, which could negatively impact returns achieved by them. Argentem Creek, in connection with investments by the Client, may represent creditors or debtors in proceedings under Chapter 11 of the U.S. Bankruptcy Code (or similar provisions in applicable emerging market jurisdictions) or prior to such filings. From time- to-time, Argentem Creek may serve as advisor to, or a member of, creditor or equity committees. This involvement may limit or preclude the flexibility that the Client may otherwise have to participate in restructurings, or the Clients may be required to liquidate or refrain from selling any existing positions of the applicable issuer. In similarity to the potential conflicts that can arise from serving on the board of directors of a company, Argentem Creek personnel that serve as members of a bankruptcy committee may owe fiduciary or other legal duties to other stakeholders in the bankruptcy. While Argentem Creek endeavors at all times to act in the best interests of its Clients, investors should be aware that the types of transactions described above create potential conflicts of interest with respect to Argentem Creek, and the Clients. Argentem Creek will seek to resolve the conflicts of interest discussed above using its best judgment and in a manner that it believes to be fair and reasonable to its Clients in accordance with its duties as an investment adviser. Argentem Creek is the principal owner and controls and may in the future own and control other business interests. Currently, Argentem Creek faces certain conflicts of interest in managing the Private Funds while also operating the Trade Services Company. While the Trae Services Company has been dormant during 2025, and Argentem Creek may unwind its operation during 2026, if Argentem Creek was to determine to continue the Trade Services Company’s operations, it could face conflicts of interest. For example, Argentem Creek will have an incentive to encourage issuers in which its Clients are invested to engage, and pay, the Trade Services Company for commodity trade finance services, and may similarly be incented to invest in issuers already using the Trade Services Company’s services. Argentem Creek may face other unanticipated conflicts of interest in operating the Trade Services Company, the

Private Funds, and the Trade Services Company will compete for the time and attention of Argentem Creek’s personnel. Side Letters Argentem Creek, without any further act, approval or vote of any partner in any of its Funds or accounts, may enter into side letters or other written agreements (“Side Letters”) with certain limited partners and investors which have the effect of amending, modifying or supplementing the terms of a Private Fund’s Fund Documents, with respect to such limited partner or investor. The terms of any Side Letter with a limited partner or investor will govern with respect to such limited partner or investor notwithstanding the provisions of the Fund Documents and may include terms relating to fees, expenses, additional or modified investment restrictions, regulatory matters and reporting, among other terms. Although Argentem Creek does not agree to Side Letter terms it believes will have a material adverse impact on any Private Fund, there can be no assurance that under certain circumstances this would not be the case. Managed Accounts Argentem Creek may manage Managed Accounts for institutional investors. The Managed Accounts may pursue strategies similar to the Private Funds. The investors of Managed Accounts, through negotiated Private Contracts, may have the ability to assume control over the accounts and liquidate positions in the accounts. In the case of a large Managed Account, such liquidation could have an adverse effect on the Private Funds. The beneficial owners of the Managed Accounts generally receive more information (including portfolio information) and have more favorable account termination rights than the Private Funds and their investors. The ability to open a Managed Account is only permitted at the discretion of Argentem Creek and is not available to all clients or investors. Although Argentem Creek does not currently provide advisory services to a Managed Account, it may intend to in the future. It would not be prohibited from managing additional Managed Accounts or single investor funds in the future. General Partners The General Partner (where applicable) of each Private Fund is under common control with Argentem Creek and was formed for the specific purpose of serving as general partner. Consequently, although each General Partner is subject to the duties and responsibilities set forth in the relevant Fund Documents and under applicable law, the General Partners cannot realistically be expected to provide completely objective or independent oversight over Argentem Creek’s management of the Private Funds. Operational and Trading Errors Trading errors are an intrinsic factor in any complex investment process, and can be expected to occur, notwithstanding the execution of due care and special procedures designed to prevent such errors. Argentem Creek’s policy is that any trading errors which do occur will be for the account of the Client, unless they are the result of conduct inconsistent with the standard of care set forth in Argentem Creek’s Compliance Policy and the applicable Fund Documents or Private Contracts including, if applicable, ERISA. Efficient execution of trades in emerging markets can at times be particularly difficult.

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Argentem Creek has adopted, maintains and enforces a Code of Ethics (the “Code of Ethics”), which is intended to satisfy the requirements of Rule 204A-1 under the Advisers Act. The Code of Ethics sets forth the standards of conduct expected of all personnel and requires compliance with the federal securities laws and Argentem Creek’s fiduciary duties, including the duties to always put client interests first and to maintain the confidentiality of client information. The Code of Ethics addresses the personal securities trading activities of all personnel in an effort to detect and prevent illegal or improper personal securities transactions. The Code of Ethics generally prohibits personal securities transactions in any issuer held by or under active consideration for the Private Funds. Argentem Creek personnel must also obtain prior approval from the Chief Compliance Officer, or their delegate, before participating in any initial public offering or limited offering (i.e., private placement). Employees are also required to provide quarterly reports regarding transactions and holdings in Reportable Securities and newly opened Personal Accounts. Employees must disclose all Personal Accounts initially upon commencement of employment, and annually thereafter. Argentem Creek endeavors to maintain current and accurate records of all Personal Accounts of its Employees in an effort to monitor all such activity. To further mitigate the potential for conflicts of interest, the Code of Ethics contains a number of restrictions related to the activities of personnel regarding the provision and receipt of gifts, political contributions and outside employment. The Code of Ethics also requires personnel to report violations of law, rules or the Code of Ethics to the Chief Compliance Officer or their delegate. All personnel must

certify their compliance on an ongoing basis. The Chief Compliance Officer is responsible for administering and enforcing the Code of Ethics and maintaining all records required by the Code of Ethics. A copy of the Code of Ethics is available to advisory clients and prospective advisory clients upon request. A copy of the Code of Ethics is also available to Private Fund investors and prospective investors upon request.

Argentem Creek is authorized to designate the banks, custodians, brokers, dealers and other counterparties (collectively, “brokers”), to be used for all transaction types by Clients. In certain instances, Argentem Creek will permit a Managed Account to direct it as to which broker to use for its own account. Any such direction must be in writing and accepted by Argentem Creek. In such instances, Clients should be aware that Argentem Creek may be unable to achieve the most favorable execution of transactions on behalf of the Managed Account and such direction may cost Clients more money than had they not directed brokerage. The primary selection criterion employed by Argentem Creek in connection with selecting brokers is the brokers’ ability to provide best execution. In assessing best execution, and its overall broker relationships, Argentem Creek considers a variety of factors including trading cost, performance, trade settlement efficiency, availability of product and electronic communication proficiency. Argentem Creek generally gives primary consideration to obtaining the most favorable price and efficient execution. Argentem Creek may, however, pay a higher commission than would otherwise be necessary for a particular transaction when, in Argentem Creek’s opinion, to do so would further the goal of obtaining the best available execution on an aggregate basis for the related investment. Commissions are negotiated with the broker based on the quality and quantity of execution services that the broker provides, in light of generally prevailing commission rates with respect to any securities transactions involving a commission payment. In negotiating commission rates on behalf of the Private Funds, Argentem Creek may take into account the financial stability and reputation of the broker and the quality of the investment research, investment strategies, special execution capabilities, clearance, settlement, custody, recordkeeping and other services provided by such broker, even though the Private Fund may or may not in any particular instance be the direct or indirect beneficiary of the products or services provided. Often times, more than one broker-dealer may be capable of providing the best qualitative execution with respect to a particular order. In such circumstances, a trader may consider research or brokerage services provided by the broker-dealer, consistent with the safe harbor provisions of Section 28(e) of the Exchange Act and related interpretative guidance (“Soft Dollar Arrangement”). As of this date Argentem Creek does not have any Soft Dollar Arrangement. Argentem Creek may or may not solicit competitive bids from brokers and has no obligation to seek the lowest available commission cost. In certain emerging markets, there may be only a very limited number of available brokers or dealers to choose from, and their pricing structures may be materially different, making it difficult to negotiate a competitive price for certain Private Fund transactions. In addition, the

nature of the comparatively lesser developed emerging markets in which the Private Funds invest may result in such Private Fund paying substantially more in commissions than the actual costs of execution. While some Private Fund assets held by brokers may be segregated from the broker’s own property, most other Private Fund assets held as collateral or margin are not, and, accordingly, may not be recoverable in the event of a broker’s insolvency.

Argentem Creek currently has no arrangements regarding Client referrals.

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to an evaluation of Argentem Creek or the integrity of Argentem Creek’s management. Argentem Creek has no such legal or disciplinary events to disclose.

Argentem Creek’s investment and business professionals are responsible for ongoing diligence and reviews of the investments entered on behalf of Clients. These professionals review investments on a periodic basis, and in some cases as frequently as daily. Key items reviewed include investment positions and account and cash activity.

In most cases, Argentem Creek is deemed by applicable regulatory rules to have constructive custody of the assets of comingled investment vehicles that are Private Funds and complies with the applicable requirements. All such Private Funds seek to utilize independent, third-party qualified custodians and seek to provide an annual audit prepared in accordance with U.S. generally accepted accounting principles by an independent public accountant registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board. Such Private Fund investors receive audited financial statements on an annual basis.

Argentem Creek typically manages client accounts on a discretionary basis. With respect to collective investment vehicles that are Private Funds, such discretion is established in the governing documents. With respect to other accounts, clients authorize this discretion in their investment management agreements with Argentem Creek. This discretion may be limited to the extent Argentem Creek agrees to investment guidelines or policies as part of the investment management agreement. Such guidelines or policies generally describe permitted and prohibited investments, strategies and techniques and may contain limitations or restrictions regarding the nature or amount of certain investments.

In accordance with its fiduciary duty to clients and Rule 206(4)-6 of the Advisers Act, Argentem Creek has adopted and implemented written policies and procedures governing the voting of client securities. Argentem Creek does not typically invest in a meaningful fashion in equity securities that solicit proxy votes. It does, however, invest in securities and other instruments involved in various debt restructuring and insolvency proceedings in jurisdictions around the world pursuant to which bond trustees and liquidators do seek proxies instructing them on how to vote on a given proposal. The following policies

and procedures apply in either case. Argentem Creek will generally seek to vote proxies in a way that maximizes its Clients’ assets value. Unless otherwise specified in a written agreement between Argentem Creek and a Client, or otherwise set out in an official offering document pertaining to a Private Fund, the primary factors to be considered in voting proxies are those that would affect the value of the Client’s assets. Argentem Creek will vote proxies on a case-by-case basis when it believes the outcome of the vote may have a material impact on the value of the Client’s position. Argentem Creek may abstain from voting if (i) it deems that abstaining will not have a material adverse impact on a Client, (ii) it is not materially beneficial to the Client or (iii) the potential benefit of voting is outweighed by the cost to the Client. For example, Argentem Creek may be unable to vote securities that have been lent by the custodian or subject to repurchase or reverse repurchase agreements. Proposals which are controversial or non-routine in nature will be reviewed on a case-by-case basis by Argentem Creek. Argentem Creek may be exposed to potential material conflicts of interest in voting proxies and will monitor the potential for such conflicts. As noted previously, Argentem Creek will vote its Clients’ proxies in the best interests of its Clients and not subordinate the Clients’ interests to its own. In voting for such proxies, Argentem Creek shall endeavor to avoid material conflicts of interest between the interests of Argentem Creek, on the one hand, and the interests of Clients, on the other. If a material conflict of interest is identified regarding U.S listed equity security proxy voting, it will generally be addressed by the Investment Committee by adhering to the public recommendation of a third-party proxy voting advisory service. A copy of Argentem Creek’s written proxy voting policies and procedures, as well as a record of how Argentem Creek has voted in the past, will be maintained and available for review upon written request. Clients may contact Argentem Creek’s Chief Compliance Officer at the number provided at the beginning of this Brochure for this information.

Each registered investment adviser is required to disclose whether it has any financial condition that could impair its ability to meet its contractual commitments to its clients, and whether it has been the subject of a bankruptcy proceeding. Argentem Creek does not have any adverse financial conditions to disclose and has never been the subject of a bankruptcy proceeding.