ASHOKA WHITEOAK CAPITAL PTE. LTD.

White Oak is an investment adviser that provides investment advice and management services to pooled investment vehicles, separately managed accounts, and a registered investment company. For purposes of this brochure, the “Adviser” means White Oak, a private limited company based in Singapore. The Adviser provides investment management and supervisory services to pooled investment vehicles that are exempt from registration under the Investment Company Act of 1940, as amended (the “Investment Company Act”) and whose securities are not registered under the Securities Act of 1933, as amended (the “Securities Act”). All Private Funds (the “Private Funds”) currently managed by White Oak are disclosed on its Form ADV 1A, Section 7.B.1. The Adviser also provides investment supervisory services to separately managed accounts and sub-advisory services to an investment company registered under the Investment Company Act. The Adviser makes investments generally in transferable securities and derivative products thereof for the Private Funds and separately managed accounts. The Adviser’s advisory services consist of investigating, identifying and evaluating investment opportunities, structuring, negotiating and making investments on behalf of the Clients, managing and monitoring the performance of such investments, and disposing of such investments. The Adviser provides investment management and supervisory services to its Clients in accordance with the terms of the respective governing documents, including subscription agreements for its advised Private Funds, or investment advisory agreements for separately managed accounts and the registered investment company (each, an “Advisory Agreement”). Investment advice is provided directly to the Private Funds or to other advisors managing the Private Funds, and not individually to the investors in the Private Funds. Services are provided to the Private Funds in accordance with the Investment Management Agreements with the Private Funds and/or organizational documents of the applicable Private Fund. Investment restrictions for the Private Funds, if any, are generally established in the organizational or offering documents of the applicable Private Fund, Advisory Agreements and/or side letter agreements negotiated with investors in the applicable Private Fund (such documents collectively, a Private Fund’s “Organizational Documents”). The Adviser does not participate in wrap fee programs. As of 31 March 2026 the Adviser’s regulatory assets under management consisted of the following:  

Discretionary: $ 5,378,766,539.21 Non-Discretionary: $ 0

The Adviser generally receives Management Fees, sub-advisory fees equal to a percentage of assets under management of the respective fund. The Adviser also receives Performance Fees based on the performance of certain Separately Managed Accounts. The advisory services provided to each of the Private Funds and its affiliated entities are pursuant to separate investment management, service, or subscription agreement (the “Agreements”). The Agreements for each Private Fund, along with any specific organizational documents of such Private Fund, set forth the specific fees and related mechanisms for each Private Fund. Separately managed accounts and the registered investment company are subject to the fees and related mechanisms as defined in its specific Advisory Agreement. Management Fees As compensation for investment management and supervisory services rendered to the Private Funds, the Adviser receives from each such Private Fund a Management Fee typically at an agreed fixed rate, calculated by the Private Fund’s NAV. Management Fees paid by a Private Fund may also be reduced by other fees or compensation received by the Adviser or its affiliates that relate to such Private Fund’s activities and investments, or by certain organizational or other expenses borne by such Private Fund, as described in more detail below. Management Fees paid by a Private Fund are indirectly borne by investors in such Private Fund. The precise amount and calculation of the Management Fees for each Private Fund are set forth in such Private Fund’s Agreements. Management Fee structures can differ from one Private Fund to another. As compensation for investment management services rendered to separately managed accounts, the Adviser receives a Management Fee and/or Performance Based fees, at an agreed fixed rate, calculated based on the account’s assets under management and/or performance of the account. As compensation for sub-advisory services rendered to the registered investment company, the Adviser receives a Management Fee calculated based on the company’s assets under management.

Expenses Adviser Expenses To the extent provided in the Agreements of the Private Funds, the Adviser will pay out of Management Fees all expenses and costs incurred by the Adviser in the course of providing services to the Private Funds, including compensation of its investment professionals, rent, utilities, office expenses, those travel costs which are not related to Private Funds’ expenses under the Organizational Documents, audit costs, staff recruitment costs, insurance costs, information technology costs, marketing costs, legal expenses, software costs, database costs and printing costs. Management Fees and sub-advisory fees received also contributes to these Adviser expenses.

Private Fund Expenses Each Private Fund is responsible for paying its own organizational, operating and related expenses as described below and in the applicable Organizational Documents. In cases where multiple Private Funds, properties or entities incur or benefit from a specific expenditure, Adviser will allocate the expense by estimating the relative usage and benefit that each such Private Fund, property or entity obtains from the expense, as more fully described below. The Private Funds are responsible for travel expenses related to their respective businesses. Such expenses include the Private Fund’s Directors’ coach or economy class airfare for most domestic travel and, for transcontinental, international destinations or other longer duration flights, business or first class airfare.

Allocation of Expenses From time to time the Adviser will be required to decide whether certain fees, costs and expenses should be allocated between or among Private Funds and/or other parties. Certain expenses may be the obligation of one particular Private Fund and may be borne by such Private Fund or, expenses may be allocated among multiple Private Funds and entities. The Adviser will allocate fees and expenses incurred in connection with the operations and management of a Private Fund between the Adviser and such Private Fund in accordance with the Organizational Documents of such Private Fund or Private Funds. However, while the Adviser intends to use good faith and its best judgment in connection with any such allocation, such

allocations may require inherently subjective determinations and give rise to conflicts of interest due to the inherent biases in the process. The appropriate allocation among the Private Funds of expenses and fees generated in the course of evaluating and making investments often may not always be clear, especially where more than one Private Fund participates. For instance, if multiple Private Funds are considering making an investment that is not consummated, allocation of the expenses generated for the account of such Private Funds (such as expenses of common counsel and other professionals) will be made in good faith. In general, the Adviser intends to resolve all such matters on a pro-rata basis, using its best judgment, considering all factors it deems relevant. With respect to allocating other expenses among Private Fund(s), Adviser, Investors and/or Third Parties, as appropriate, to the extent not addressed in the Organizational Documents of a Private Fund, the Adviser will make any such allocation determination in a fair and reasonable manner using its good faith judgment, notwithstanding its interest (if any) in the allocation. The Adviser will make any corrective allocations and take any mitigating steps if it determines such corrections are necessary or advisable. Notwithstanding the foregoing, the portion of an expense allocated to a Private Fund for a particular service may not reflect the relative benefit derived by such Private Fund from that service in any particular instance.

Compensation and Fee Schedules All investors should review the Governing Documents for each Private Fund in conjunction with this brochure for more complete information on the fees and compensation payable with respect to a particular Private Fund. Investors and prospective investors in the Private Funds should note that similar advisory services may (or may not) be available from other investment advisers for similar or lower fees. Deduction of Fees White Oak is authorized under the Governing Documents to charge and deduct advisory fees directly from the assets of the Private Funds and any separately managed account, at the times and in the amounts described above. Other Fees and Expenses In addition to the fees payable to White Oak, the Private Funds will incur certain charges imposed by third parties, including (but not limited to) any sales or other taxes, fees or government charges that may be assessed against The Private Funds; placement agent fees; the costs and expenses (including travel-related expenses) of holding meetings or conferences with the Private Funds’ investors; all expenses relating to litigation and threatened litigation involving the Private Funds; indemnification obligations and expenses; expenses attributable to normal and extraordinary investment banking, commercial banking, accounting, auditing, appraisal, tax advisory, tax preparation, legal, external consulting, custodial and registration services provided to the Private Funds; and the costs and expenses for tax and audit services to the Private Funds. Timing of Payments Management Fee payments are generally due monthly in arrears. Please refer to the Private Fund’s Governing Documents for more complete information on the timing of management fee payments.

Methods of Analysis The Adviser bases its advice to Private Funds, sub-advised and separately managed accounts on the investment objective and restrictions (if any) set forth in the applicable offering memorandum, Organizational Documents, investment management agreement, sub-advisory agreement and/or subscription agreements. Please refer to the Private Fund’s offering documents for further information regarding methods of analysis, investment strategies, and risk of loss. Material Risks The task of identifying investment opportunities and managing such investments is difficult. There can be no assurance that investments selected by Adviser will be able to generate returns for Clients. In addition, there can be no assurance that any investor in any Private Fund advised by the Adviser will receive any distribution from a White Oak . Investing in the Private Fund involves a risk of loss that investors should be prepared to bear. Investors in the Private Funds should carefully consider, among other factors, the following material risks involved with White Oak’s investment strategies. Investors in the Private Funds are requested to refer to the Governing Documents of the applicable White Oak Private Fund for more complete information on investment strategies employed by the White Oak and the corresponding risks associated with such investment strategies. In the following risk disclosures, “the Private Fund” may refer to any Private Fund advised by White Oak. INVESTMENT RISKS Asset Class Risk The equity market and the prices of various stocks and derivative underlyings may fluctuate widely based on a variety of factors including global, jurisdiction-specific macro-economic conditions, and stock specific factors. The performance of futures could be substantially different from the performance of underlying securities. Counterparty Risk The institutions, including brokerage firms and banks, with which the Adviser does business, or to which securities have been entrusted for custodial purposes, may encounter

financial difficulties that impair the operational capabilities or the capital position of client accounts. There is a risk that any of such counterparties could become insolvent. The insolvency of the Adviser’s counterparties is likely to impair the operational capabilities of the Adviser. No Control Over Portfolio Companies Accounts may acquire significant positions in the securities of particular companies. Nevertheless, the Adviser is unlikely to be represented on the board of directors or share any control over the management of any such company. Opposition of management or existing investors of portfolio companies, especially in the absence of an effective legal framework to protect minority shareholder/ creditor’s rights, could jeopardize Adviser’s strategy. The success of each investment depends on the ability and success of the management of that company in addition to economic and market factors. Smaller Company Risk Adviser may invest in the securities of small or medium-size companies that may be more susceptible to market downturns, and the prices of which may be more volatile than those of larger companies. Smaller companies generally pose greater investment risks because such companies have narrower markets and more limited managerial and financial resources than larger, established companies. Availability and Accuracy of Information The Adviser will select investments on the basis of information and data derived from firsthand research by the Adviser. Although the Adviser intends to evaluate all such information and data and to seek independent corroboration when the Adviser consider it appropriate and when it is reasonably available, the Adviser will not in many cases be in a position to confirm the completeness, genuineness or accuracy of such information and data. Reliance on Service Providers/ Intermediaries The Adviser may engage a variety of service providers, including but not limited to those in the areas of legal, tax, accounting, valuations, custodial services, bankers etc. In the event any such persons have any adverse development which affects their performance of duties with their clients or they breach any of the terms of engagement, the Adviser might be posed with a risk, which might be significant. Systems Risk High volume trading will frequently occur at the market opening and before market close. Such high volumes may also occur at any point in the day. These may cause delays in order execution or confirmation. During periods of volatility, on account of market participants continuously modifying their order quantity or prices or placing fresh orders, there may be

delays in execution of order and its confirmation. Therefore, under certain market conditions, it may be difficult or impossible to liquidate a position in the market at a reasonable price or at all, when there are no outstanding orders either on the buy side or the sell side, or if trading is halted due to any action on account of unusual trading activity or price hitting circuit filters or for any other reason. System/ Network Congestion Trading on the exchange is in electronic mode, based on satellite/ leased line communications, combination of technologies and computer systems to place and route orders. Thus, there exists a possibility of communication failure or system problems or slow or delayed response from system or trading halt, or any such other problem/glitch whereby not being able to establish access to the trading system/network, which may be beyond the control of and may result in delay in processing or not processing buy or sell orders either in part or in full. Performance Risks Client accounts may be invested directly or indirectly in companies in highly competitive markets or product segments dominated by firms with substantially greater financial and technical resources. Companies in which client accounts invests may operate in product segments that face technological changes and/or may be dominated by other firms or organizations. These and other inherent business risks could affect the performance of these companies and affect the value of investments, thereby affecting client accounts as a whole, due to their involvement in these companies. Illiquidity of Portfolio Investments Client accounts may be invested in markets which are smaller and potentially more volatile than securities markets in more developed economies, and these securities markets could experience problems that could affect the market price and liquidity of the securities of portfolio companies. Material Information Regarding Portfolio Companies The Adviser may enter into discussions with professionals and agents to in the process of shortlisting of portfolio companies, and the Adviser often will be required to make decisions without complete information or in reliance upon information provided by third parties that is impossible or impracticable to verify. The marketability and value of each investment will depend upon many factors beyond the control of the Adviser. On the other hand, if the Adviser, its employees or Affiliates come in contact with non-public price sensitive information regarding any portfolio company, such persons may be restricted from initiating transactions in the securities of such portfolio companies. RISKS SPECIFIC TO THE FUNDS Concentration of Investments

Although it will be the policy of the Private Fund to diversify its investment portfolio, the Private Fund may at certain times hold relatively few investments. The Private Fund could be subject to significant losses if it holds a large position in a particular investment that declines in value or is otherwise adversely affected, including default of the issuer. Availability and Ability to Acquire Suitable Investments The Adviser will be competing with other investors having similar investment objectives including many of the larger investment banking firms, financial companies and other venture capital or private equity funds which have substantially greater financial resources than the Adviser, and have substantially greater numbers of research staff and more analysts than the Adviser has. There can be no assurance that the Adviser will succeed in finding investments on similar or more favourable terms in comparison to its competitors. Such competition may have an adverse effect on the ability of the Private Fund to successfully utilize the total commitments as well as on the length of time required for the same. Moreover, these investments are not free from risk and may be subject to the liquidation risk of the issuing entities. Exit Strategy The feasibility and terms of any proposed exit strategy for investments will depend in part on factors that are not within the control of the Adviser, at the time of the proposed disposition, such as the effect of applicable legislation and political and economic conditions. Consequently, the precise timing of the disposition of an investment and the manner of disposition are impossible to predict, and no assurance can be given that such disposition will be achieved on terms favorable to client accounts. Portfolio Risk Client accounts will have investments spread by asset type with varying exit horizons. Poor performance by even a few of these investments could lead to adverse effects on overall returns. Client accounts could be subject to significant losses if it holds a large position in a particular investment that declines in value or is otherwise adversely affected, including default of the issuer. Portfolio Turnover While the Adviser generally intends to employ long-only, opportunistically the investment strategy may result in a short holding period before investments are rolled over into new investments or sold. This will cause the recognition of any investment gains. Some of these gains may not qualify for the holding period needed for long capital gains tax treatment. Therefore, taxable Investors in the Private Fund could have a greater need to pay regular taxes (out of their own resources or by requesting redemptions) than compared to other investment strategies that hold investments longer. The turnover of the Private Fund’s portfolio also may

generate substantial transaction costs, which will be borne by the Private Fund, and indirectly by the Investors, regardless of its profitability. Restrictions on Redemptions and Transfer Terms of redemptions and transfers are set out in the relevant Organizational Documents. No Assurance of Returns The investors are not being offered assured returns or redemption, and there will be no recourse to the Adviser. Accordingly, the ability of the Private Fund to pay returns on/redeem the Shares will depend on the realizations from the Private Fund investments. The funds available for distributions on the Shares, as well as upon termination/liquidation of the Private Fund, will be limited to the monies recovered on the Private Fund’s investments and to the balance funds after meeting all liabilities and obligations. The Private Fund will have no assets other than its monies contributed by the Investors and any distributions on the Shares shall be made only out of such funds. Deployment Risk Owing to the market conditions, the Private Fund may not be able to identify the assets to deploy the contributions received and therefore the same may be a deterrent factor for the Private Fund to achieve the targets laid down by the Adviser. Diverse Investor Group The Investors may have conflicting investment, tax and other interests with respect to their investments in the Private Fund. The conflicting interests of individual investors may relate to or arise from, among other things, the nature of investments made by the Private Fund, the structuring or the acquisition of investments and the timing of disposition of investments. As a consequence, conflicts of interest may arise in connection with decisions made by the Adviser, including with respect to the nature or structuring of investments that may be more beneficial for one investor than for another investor, in particular with respect to investors’ individual tax situations. In selecting and structuring investments appropriate for the Private Fund, the Adviser will consider the investment and tax objectives of the Private Fund and its investors as a whole, not the investment, tax or other objectives of any Investor individually. Foreign Currency Exposure As the portfolio of the Private Fund(s) may consist of securities denominated in non-US dollars (“US$”), the NAV of the Private Fund, when measured in US$, will, to the extent this has not been hedged against, be affected by changes in the value of the securities’ currency relative to US$. The Adviser may, but is not obligated to, hedge the portfolio’s exposure to the non-US$ back to US$. The use of hedges involves special risks, including the possible default by the other party to the transaction, illiquidity and, to the extent the Adviser’s assessment of certain market movements is incorrect; the risk that the use of hedges could result in diminished returns or losses greater than if the hedging had not been used. Hedging arrangements may have the effect

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Types of Clients White Oak provides advice to pooled investment vehicles, including the Private Funds, as well as sub-advise and manage separate accounts for institutional clients, sovereign wealth funds and 40 Act Private Fund. The investors of the Private Funds may include corporations, endowments, foundations, trusts, estates, individuals and pension and profit sharing plans. In the US, the Private Funds are offered exclusively to accredited investors pursuant to Section 3(c)(7) of the Investment Company Act, and are therefore not required to register as investment companies under the Company Act in reliance upon certain exemptions available to White Oak Private Funds whose securities are not publicly offered.

Minimum Investment Requirements White Oak ensures that US investors in each of the Private Funds are “accredited investor” as defined in Regulation D under the Securities Act. In addition, White Oak requires that US investor in each of the Private Funds be a “qualified purchaser” as defined in the Investment Company Act.

Performance-Based Fees Fora separately managed accounts and funds, the Adviser may receive certain allocations calculated and charged based on a share of increase in the Net Asset Value compared to a stated benchmark, past a specified high-water mark or similar mechanism. The performance-based allocation arrangements discussed above comply with Rule 2053 under the Investment Advisers Act of 1940 (the “Advisers Act”). Performance-Based

fees are separate and distinct from the advisory management fees charged by White Oak under the Advisory Agreement. Performance-Based Fees may create an incentive for White Oak to recommend investments that may be riskier or more speculative than those that would be recommended under a different fee arrangement. Please refer to the Organizational Documents of each White Oak Private Fund for more complete information on the “performance-based fee” arrangements of each White Oak Private Fund. Side-by-Side Management White Oak may provide concurrent advisory services to clients that are not charged a performance-based fee by the Adviser. As a result, the potential for the Adviser to receive greater fees or allocations from performance-based accounts creates a conflict of interest with respect to the allocation of investment opportunities, as White Oak may have an incentive to direct the best investment ideas to, or to allocate investments in favor of, the account that pays a performance fee or allocation. To alleviate potential conflicts of interest, the allocation of commitments and investment decisions with respect to each White Oak Private Fund, subadvised and separately managed accounts are made by the Adviser in accordance with White Oak’s investment allocation policy, which takes into account multiple criteria for the Private Funds, sub-advised and separately managed accounts, including: specific objectives of each Private Fund, sub-advised and separately managed accounts, the size and capital available for investment, diversification needs, the size of the investment opportunity, current and anticipated market conditions, specific investment restrictions or guidelines applicable to each White Oak Private Fund, sub-advised and separately managed accounts, and relevant tax or regulatory considerations. In the event investment opportunities are suitable for more than one White Oak Private Fund, sub-advised and separately managed accounts, the Adviser will allocate such investment opportunities in a manner that is fair and equitable to each Private Fund, sub-advised and separately managed account relative to the other Private Funds, sub-advised and separately managed accounts over time, taking into account all relevant facts and circumstances.

Registered Broker-Dealers None of White Oak or its management persons are registered as a broker-dealer or a registered representative of a broker-dealer. In addition, White Oak and its management persons are not affiliated with any broker-dealer, bank or other financial services firm. Registered Futures Commission Merchants, Commodity Pool Operators and Commodity Trading Advisors None of White Oak or any of its management persons are registered as a registered futures commission merchant, commodity pool operator or commodity trading advisor. Relationships with Related Persons As discussed in the section titled “Participation or Interest in Client Transactions; Personal Trading,” the Adviser and its related persons are, directly or indirectly, the directors and/or managing members of each of the Private Funds. White Oak and its related persons may spend substantially all of their business time on one or more of the Private Funds as required pursuant to the terms of each advised Private Fund’s Governing Document.

Additionally, White Oak is a related party to the following investment advisers: Acorn Asset Management Ltd; White Oak Capital Management (Spain), Sociedad Limitada; White Oak Capital Management Consultants LLP; Ashoka Whiteoak Capital Management (GIFT) LLP, and WhiteOak Capital Asset Management Limited. The above advisers are under common control with White Oak, and certain executives of the Adviser serve as executives to these related parties. All investment advisers listed provide non-binding advisory services. Besides the Adviser, none of the investment advisers are registered with the SEC as Registered Investment Advisers. Selection or Recommendation of Other Advisers White Oak does not recommend or select other investment advisers for its clients and receive compensation from such advisers in a manner that would create a material conflict of interest.

Trading Code of Ethics White Oak follows a Code of Ethics under Rule 204A-1 of the Advisers Act expressing White Oak’s commitment to ethical conduct. White Oak’s Code of Ethics describes its fiduciary duties and responsibilities to its clients and sets forth White Oak’s (i) policies on receipt of gifts by employees and campaign contributions and (ii) practice of monitoring the personal securities transactions of supervised persons with access to client investment recommendations. Under White Oak’s Code of Ethics, all supervised personnel have a duty to act only in the best interests of the Private Funds and all potential conflicts and violations of the Code of Ethics must be promptly reported to White Oak’s Compliance department. All supervised personnel must acknowledge the terms of the Code of Ethics annually, or as amended. It is the expressed policy of White Oak that no person employed by White Oak shall prefer his or her own interest to that of an advisory client or make personal investment decisions based on the investment decisions of advisory clients. To supervise compliance with its Code of Ethics, White Oak requires that anyone associated with its advisory practices with access to advisory recommendations provide securities holdings reports and quarterly transaction reports to the firm’s Compliance department . White Oak requires such “access persons” to also receive approval from the Compliance department prior to investing in any initial public offerings or private placements. In an effort to prevent inappropriate securities transactions by White Oak’s personnel, the Compliance department will maintain and make available a list of restricted securities. The restricted securities list will be updated periodically and will include securities: (i) held by a White Oak Private Fund with respect to a portfolio investment; (ii) under active investment consideration by White Oak; (iii) held by a White Oak Private Fund as a result of a distribution from a portfolio investment or which White Oak knows or believes will be so distributed to a White Oak Private Fund; (iv) being issued in an IPO or private placement; and (v) about which any access person is in possession of, or knows, material nonpublic information. Access persons are strictly prohibited from trading on their own behalf in restricted securities without obtaining the prior written approval of the Compliance department. White Oak requires that all individuals act in accordance with all applicable federal and state regulations governing investment advisory practices. White Oak’s Code of Ethics also includes the firm’s policy prohibiting the use of material non-public information. Any individual not in observance of the above may be subject to discipline or termination.

White Oak will provide a complete copy of its Code of Ethics to any person upon request.

White Oak is responsible for the placement of the portfolio transactions of clients and the negotiation of any commissions paid on such transactions. Portfolio securities normally are purchased through brokers on securities exchanges or directly from the issuer or from an underwriter or market maker for the securities. Purchases of portfolio instruments through brokers involve a commission to the broker. Purchases of portfolio securities from dealers serving as market makers include the spread between the bid and the asked price. White Oak may utilize the services of one or more introducing brokers who will execute brokerage transactions through the custodian who will clear the transactions of clients and the Private Funds. Securities transactions will be executed through brokers selected by White Oak in its sole discretion and without the consent of investors. In placing portfolio transactions, White Oak will seek to obtain the best execution for the clients, taking into account the following factors: the ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any); the operational efficiency with which transactions are effected, taking into account the size of order and difficulty of execution; the financial strength, integrity and stability of the broker; the broker’s risk in positioning a block of securities; the quality, comprehensiveness and frequency of available research services considered to be of value; and the competitiveness of commission rates in comparison with other brokers satisfying White Oak's other selection criteria. White Oak is authorized to pay higher commissions to such firms if White Oak determines such prices or commissions are reasonable in relation to the overall services provided. White Oak is not required to weigh any of these factors equally. Information so received is in addition to and not in lieu of services required to be performed by White Oak and White Oak's allocations and fees are not reduced as a consequence of the receipt of such supplemental research information. Research services provided by broker-dealers used by the clients and the Private Funds may be utilized by White Oak or its affiliates (including other investment funds managed by such persons) in connection with their other investment activities. Since commission rates are negotiable, White Oak's selection of brokers on the basis of considerations which are not limited to applicable commission rates may at times result in Clients being charged higher transaction costs than it could otherwise obtain. Soft Dollar Arrangements. The term “soft dollars” refers to a means of paying brokerage firms for products and services through commission revenue, based on the volume of brokerage commission revenues generated from securities transactions executed through brokers by an Adviser on behalf of advisory clients. Section 28(e) of the Securities 22 Exchange Act of 1934, as amended allows White Oak to pay broker-dealers more than the lowest commission available in order to obtain research and brokerage services without breaching its fiduciary duties to clients or imposing a duty upon White Oak to obtain the lowest commission if certain conditions are met and White Oak makes a good faith determination that the commissions paid are reasonable in relation to the value of the brokerage or research services on behalf of its advisory clients. The determination may be

viewed in terms of either the particular transaction involved or the overall responsibilities of White Oak with respect to the accounts over which it exercises investment discretion. In determining if something is research, thus falling within the safe harbor provisions, the controlling principle is whether it provides lawful and appropriate assistance to the money manager in the performance of its investment decision-making responsibilities. Certain brokerage and research products and services utilized by White Oak are categorized as mixed-use items that are partially paid for with soft dollars. Pursuant to the guidance set forth in the July 18th, 2006 SEC Interpretive Release regarding permissible client commission practices, White Oak partially pays for mixed-use items with soft dollars after reasonably allocating between eligible and ineligible uses and making a good faith determination that the commissions being paid are reasonable in light of each of the brokerage and research services that are provided. Information so received is in addition to and not in lieu of services required to be performed by White Oak and the Management Allocation and Performance Fee are not reduced as a consequence of the receipt of such supplemental research information. Because commission rates in the are negotiable, White Oak's selection of broker-dealers on the basis of considerations which are not limited to applicable commission rates may at times result in a client and the Private Funds being charged higher transaction costs than it would otherwise obtain. Nonetheless, White Oak's decision on which broker-dealer to utilize will be fully driven by a concerted effort to seek best execution. Research services received from brokerdealers are supplemental to White Oak’s own research effort and, when utilized, are subject to internal analysis before being incorporated by White Oak into its investment process. As a practical matter, it would not be possible for White Oak to generate all of the information presently provided by broker-dealers. White Oak pays cash for certain research services received from external sources. White Oak also allocates brokerage for research services, which are available for cash. While the receipt of research services from brokerage firms has not reduced White Oak’s normal research activities, the expenses of White Oak could be materially increased if it attempted to generate such additional information through its own staff. To the extent that broker-dealers provide research services of value, White Oak is relieved of expenses, which it may otherwise bear. In addition, White Oak has an incentive to select a broker dealer based on its interest in receiving research or other products or services, rather than client’s interests in receiving lower transaction costs. Certain broker-dealers who provide quality brokerage and execution services also furnish research services to White Oak. In selecting a broker-dealer, White Oak may consider, among other things, the broker-dealer’s best execution capabilities, reputation, and access to the markets for the securities being traded. White Oak will generally seek competitive commissions for transactions for advisory client’s accounts. Consistent with obtaining best execution, transactions for advisory clients may be directed to brokers in return for research services furnished by them to White Oak. Such research generally will be used to service all of White Oak's advisory clients, but brokerage commissions paid may be used to pay for research that is not used in managing a specific account. Therefore, research may not necessarily benefit all accounts paying commissions to such brokers. Accordingly, White Oak cannot readily determine the extent to which commission rates charged by broker-dealers reflect the value of their research services. White Oak generally assesses the reasonableness of commissions in light of the total brokerage and research services provided by each

particular broker-dealer. We use client brokerage commissions to obtain research or other products or services and receive a benefit because we do not have to pay for the research, products, or services. We have a conflict of interest in that regard because of our incentive to select or recommend a broker-dealer based on our interest in receiving the research or other products and services, rather than on our clients’ interest in trading at the most favorable prices. White Oak receives a wide range of services from broker-dealers. These services include: information on the economy, industries, groups of securities, individual companies, statistical analysis, performance analysis, and analysis of corporate responsibility issues. These services provide both domestic and international perspective. Research services are received primarily in the form of written reports, computer generated services, telephone contacts, and personal meetings with security analysts. In addition, such services may be provided in the form of meetings arranged with corporate and industry spokespersons, economists, academics and government representatives. In some cases, research services are generated by third parties but are provided to White Oak by or through broker-dealers. Cross Trades. White Oak may engage in cross-trading in limited circumstances. “Crosstrading” involves the purchase and sale of securities between accounts managed by the Company. White Oak does not intend to engage in cross-trading on a regular basis. However, White Oak may effect cross-trades in the future when it believes it is in the best interest of its clients to do so. Cross trades in which White Oak has engaged, and any cross trades in which White Oak engages in the future, have been and will be effected in accordance with procedures designed to ensure that any cross trades between accounts managed by White Oak are consistent with its obligation to achieve “best execution” for its Private Funds and that no Private Fund is disfavored by cross-trading. White Oak will not receive any fees or compensation in connection with cross-trading. White Oak will not effect cross trades involving any account subject to ERISA unless the cross trade complies with an ERISA exemption.

Third Party Compensation for Client Referrals White Oak and related persons of White Oak may enter into cash compensation arrangements with unaffiliated placement agents or third parties for introducing investors to a White Oak Private Fund. Any sales charge associated therewith will ultimately be payable by White Oak or its related persons, either directly or through an offset of the management fee payable by the relevant White Oak Private Fund to White Oak. An investor will not be charged any additional amount or bear any additional charges as a result of an introduction through a placement agent or other unaffiliated third party. White Oak endeavors at all times to put the interests of the Private Funds first as part of White Oak’s fiduciary duty. Nevertheless, the receipt of compensation by the placement agents creates a potential conflict of interest, and may affect the judgment of placement agents and broker-dealers when making referrals to White Oak and The Private Funds.

White Oak and its principals have not been the subject of any material legal proceeding required to be disclosed in response to this item.

Review of Client Accounts The Adviser’s investment team will monitor portfolio investments on behalf of each client account. These reviews include an assessment of: the valuations of the individual securities within the portfolio, the portfolio weightings of individual positions, the level of available cash and equivalents, and the various industry concentrations. The goal of these reviews is to keep the individual portfolios invested in securities that will create long term value for the client. Reports to Clients Investors of the Adviser’s managed Private Funds or separately managed accounts will receive periodic reports or as and when requested based on their respective terms of the offer. Investors are requested to refer to the Governing Documents of each of White Oak's Private Fund for further information on the reports provided by White Oak to its investors.

All Client assets are held in custody by unaffiliated broker/dealers or banks, however White Oak may have access to client accounts since it or an affiliate serves as the managing member of the Private Funds. Subscribers to the Private Funds will not receive statements from the custodian. Instead, the Private Funds are subject to an annual audit and the audited financial statements are distributed to each subscriber (or member or owner). The audited financial statements will be prepared in accordance with Generally Accepted Accounting Principles (GAAP) or International Financial Reporting Standards (IFRS), as applicable, and distributed within 180 days of the Private Fund’s fiscal year end.

Subject to the investment advisory agreement of each separately managed account and subadvisory arrangement, and the, objectives, policies and restrictions of each Private Fund as set forth in the Governing Documents of such Private Fund, the Adviser may have discretionary authority to determine the type, amount and price of investments to be bought and sold on behalf of each client account. For non-discretionary accounts, the Adviser will provide the Client with suggested investments; the Client is ultimately responsible for deciding whether or not to implement such suggested investments.

The Adviser will be responsible for voting Client proxies. The Adviser has developed a written policy and procedures governing its activities in this area. In general, the policy requires the Adviser to vote client proxies in the interest of maximizing shareholder value. In addition, the Adviser maintains a record of all proxy votes cast on behalf of clients. There may be instances where Adviser’s interests conflict, or appear to conflict, with client interests in the voting of proxies. The Adviser recognizes that any material conflicts of interest must be addressed before voting the proxies. In situations where there is a conflict of interest or appearance of a conflict of interest, the Adviser will cast the proxy votes in a manner consistent with the best interest of the clients and shall place those interests ahead of its own. The Adviser will take necessary steps to ensure that a decision to vote the proxy was based on the Adviser’s determination of the client’s best interest and was not the product of the conflict. Investors may contact the Adviser for a copy of the policy or information with respect to a specific client proxy vote, at no cost. Class Action In addition, if any “Class Action” documents are received by the Adviser on behalf of any advised pooled investment vehicle, the Adviser will ensure that the pooled investment vehicle either participates in, or opts out of, any class action settlements received. Adviser will determine if it is in the best interest of the partnerships to recover monies from a class action. The portfolio manager/analyst covering the company will determine the action to be taken when receiving class action notices. In the event the Adviser opts out of a class action settlement, the Adviser will maintain documentation of any cost/benefit analysis to support its decision.

White Oak does not solicit or require the prepayment of management fees six months or more in advance and, to the best of its knowledge and belief, does not have any financial condition that would be likely to impair its ability to meet its commitments to its Clients.