Atlas Merchant Capital LLC

Atlas Merchant Capital LLC, a Delaware limited liability company formed in July 2013, is an investment adviser with its principal office located in New York, NY. Atlas Merchant Capital LP is the Managing Member of Atlas Merchant Capital LLC. Robert E. Diamond, Jr. and David I. Schamis (the “Principals”) own the majority of Atlas Merchant Capital LP. Atlas Merchant Capital LLC, collectively with its affiliated investment managers (collectively, “Atlas” or the “Firm”), serves as the investment adviser to several pooled investment vehicles (each, individually, a “Fund” and, collectively, the “Funds”). Certain Funds are closed-ended investment funds pursuing an equity-focused private equity strategy (the “PE Funds”), while other Funds pursue a U.S. regional bank and/or U.S. regional depository company-focused strategy (the “Regional Depository Fund”). Other Funds are co-investment vehicles structured to facilitate investments by third party co-investors alongside the PE Funds (“Co-Investment Vehicles”) and a fund-of-one that invests in special purpose acquisition vehicles (“SPACs”) and their sponsors (the “SPAC Fund”). The SPAC Fund is in the process of winding-down and is no longer accepting subscriptions. The Firm may in the future advise individual investors through funds-of-one or separately managed accounts (collectively with the Funds and the Co-Investment Vehicles, the “Clients” and each a “Client”). The Funds are exempt from registration under the Investment Company Act of 1940, as amended (the “Investment Company Act”), pursuant to Section 3(c)(7) of the Investment Company Act. Interests in the Funds are privately offered to qualified investors. In the future, Atlas may provide discretionary and/or non-discretionary investment advice to other pooled investment vehicles, funds-of-one and/or separately managed accounts. Atlas provides discretionary investment management services to each Client pursuant to separate investment advisory agreements. Investment management services provided to each Client are tailored to such Client’s specific investment strategy, objectives, limitations and restrictions, as set forth in each investment advisory agreement, private placement memorandum, limited partnership agreement and/or other Client constituent document, as applicable (collectively, the “Governing Fund Documents”). Atlas’s investment objective is to generate long-term capital appreciation as further described in the Governing Fund Documents. As of December 31, 2025, Atlas had assets under discretionary management of $593,033,821.

The Governing Fund Documents for each Fund set forth in detail the fee structure relevant to such Fund. As compensation for its services, Atlas generally charges an annual management fee, payable quarterly (the “Management Fee”), as set forth in the Governing Fund Documents for each Fund. The Management Fee of each PE Fund is generally based on a percentage of the Fund’s capital commitments during the investment period, and thereafter based on a percentage of capital invested, and is typically billed quarterly in advance. The Management Fee payable by a PE Fund may be paid out of current income and disposition proceeds of the Fund or from drawdowns which will reduce unfunded capital commitments. As of the date of this Brochure, the maximum Management Fee rate payable by a PE Fund is 2% per year of capital commitments.

The Management Fee charged to the Regional Depository Fund is generally based on the committed capital of the investor and is billed quarterly in advance. As of the date of this Brochure, the maximum Management Fee payable by the Regional Depository Fund is 2% per year of such total committed capital. The Management Fee charged to a Co-Investment Vehicle is generally based on the invested capital of the investor and is typically billed annually in advance. The Management Fee charged to the SPAC Fund is generally based on the net asset value of the capital account of the investor and is billed quarterly in advance. As of the date of this Brochure, the maximum Management Fee rate payable by the SPAC Fund is 0.25% per year of such net asset value. Atlas may elect to reduce, waive or calculate differently the Management Fee with respect to any investor. In the unlikely event Atlas does not provide services for the full period, a portion of the Management Fee is typically required to be returned to investors. In general, the amount of fees returned is calculated based on the number of days remaining in the applicable period. The Management Fee will typically be reduced (but not below zero) by an amount equal to 100% of the investor limited partners’ proportionate share of any other fees allocated to the Fund including but not limited to, transaction fees, break-up fees, director fees, monitoring fees, advisory fees, consulting fees and similar fees or compensation (net of related expenses) (“Transaction Fees”) paid to Atlas related to a Fund investment or potential Fund investment in a portfolio company (to the extent allocated to the Fund’s investment or potential investment in such portfolio company). Transaction Fees do not include: any management, advisory or other fees received by a General Partner (as defined below), Atlas, the Principals or any of their respective affiliates for investments that are not related to portfolio investments of a Fund; and any fees received by a General Partner, Atlas, the Principals or any of their respective affiliates in connection with services, activities or lines of business unrelated to the Funds. The types of fees that do or do not constitute Transaction Fees may vary among the Funds. In accordance with the Fund’s Governing Fund Documents, Transaction Fees paid by or attributable to any Fund’s portfolio company will generally be allocated based on the applicable Fund’s percentage ownership of such portfolio company, in proportion to the capital invested by all investors in the company. If more than one Fund is invested in any portfolio company, then the fees allocated to the Funds will generally be based on the respective Fund’s percentage ownership of such portfolio company. Fees allocated to a Fund will generally be further allocated among all investors in such Fund pro rata, based on each investor’s capital contributions. The general partners of the Funds, which are affiliates of Atlas (the “General Partners”), are generally eligible to receive a performance-based incentive allocation or carried interest, with respect to realized or unrealized investments, which is determined as a percentage of profits derived from the Funds’ investments (after taking into account expenses of the Fund, including Management Fees and, in the case of PE Funds and the Regional Depository Fund, following a preferred return to the Fund’s investors). If the performance-based carried interest of a PE Fund or the Regional Depository Fund results in an over-distribution of the agreed upon amount of carried

interest to the General Partner, the General Partner is subject to an after-tax “claw back” arrangement. As of the date of this Brochure, the maximum carried interest allocable to the General Partner of a PE Fund and of the Regional Depository Fund, respectively, is 20% of the profits derived from the disposition of investments (after taking into account expenses of the Fund, including Management Fees) and the maximum incentive allocation allocable to the General Partner of the SPAC Fund is 10% of the aggregate net capital appreciation attributable to a capital account for a fiscal year. In addition to the Management Fees and performance-based fees described above, each Fund is responsible for its own start-up costs, as set forth in the Governing Fund Documents, including but not limited to, legal, accounting, filing and other out-of-pocket expenses of organizing and raising capital (“Organizational Expenses”) and all placement fees. The fees, costs and expenses that constitute Organizational Expenses will vary from Fund to Fund. Pursuant to the PE Fund Governing Fund Documents and the Regional Depository Fund Governing Fund Documents, excess Organizational Expenses of a PE Fund and the Regional Depository Fund over a threshold amount will typically reduce the Management Fees otherwise payable by such PE Fund or the Regional Depository Fund, as applicable, by an identical amount. All placement fees will reduce the Management Fees otherwise payable by a PE Fund or the Regional Depository Fund, as applicable, by an identical amount. Strategic investors are from time to time entitled to a portion of the carried interest distributions received by the General Partners from certain of the Funds and/or a portion of the profit of the Firm. Each General Partner and each Atlas management entity pays its ordinary administrative and overhead expenses in managing Fund investments, including but not limited to salaries, benefits and rent. Each Fund also bears its own ongoing expenses (“Operating Expenses”) which generally includes, without limitation: expenses incurred in connection with the discovery, evaluation, investigation, development, making, valuation, acquisition, holding, purchase, ownership, supervision, structuring, carrying, monitoring, realization, liquidation, transfer, sale or other disposition of potential or actual investments, including loan fees, expenses relating to short sales, custodial fees, trustee fees, hedging expenses, bank service fees, private placement fees, sales commissions, appraisal fees, taxes, brokerage fees, brokerage commissions (including “soft dollar” arrangements), research fees, due diligence, interest expense, and commitment fees, transfer taxes and premiums, and duties payable in any jurisdiction in connection with any investment, underwriting commissions, clearing and settlement charges and discounts, and related legal, accounting, investment banking, advisory, consulting, information services and professional fees and expenses, and finance, communications (including interest access fees) and other expenses, and any third-party research and market data expenses (including quotation and market data services (e.g., Bloomberg, Reuters, S&P); travel-related expenses (including transportation, meal, entertainment and lodging expenses) related to or arising from the discovery, evaluation, acquisition, holding, monitoring or disposition of investments, including potential investments (which may include travel by way of non-commercial planes at rates not in excess of customary charter rates, where the General Partner determines such travel is necessary due to business

exigencies); expenses incurred in connection with the carrying or management of investments, including, without limitation, custodial, trustee, accounting, recordkeeping and other administration fees (including the fees and expenses of any third-party administrator), as well as portfolio accounting system licenses and fees; expenses incurred in connection with the preparation and distribution of the Fund’s financial statements, tax returns, Schedule K-1s and other communications with partners and the limited partner advisory committee of the Fund, if applicable, including, without limitation, expenses incurred in connection with purchasing, licensing or leasing computer software and hardware for such uses and expenses incurred in connection with providing the Fund’s investors on-line or electronic access to information and reporting relating to the Fund; attorneys’ and accountants’ fees and disbursements; taxes and other governmental charges levied against, or otherwise incurred or payable by, the Fund; insurance premiums or expenses (including directors’ and officers’ insurance and errors and omissions insurance and related brokers’ fees and commissions); any and all expenses to comply with laws and regulations related to the activities of the Fund (including regulatory and compliance-related expenses of the General Partner and Atlas incurred in connection with the operation of the Fund (including, without limitation, expenses related to the preparation and filing of Form PF with the SEC and complying with the Foreign Accounting Tax Compliance Act and the Alternative Investment Fund Managers Directive)); any and all expenses incurred in connection with any litigation or government inquiry, investigation or proceeding involving the Fund or any of its investors, including the amount of any judgment, settlements or fines; fees, costs and expenses associated with maintaining the Fund and any of its subsidiary entities, including fees, costs and expenses incurred in the organization, operation and restructuring of such subsidiary entities; interest on, and fees, costs and expenses arising out of the Fund’s borrowings and indebtedness (including the fees, costs and expenses incurred in obtaining lines of credit, loan commitments and letters of credit for the account of the Fund); expenses incurred in connection with the winding up and dissolution of the Fund or liquidation of the Fund’s assets; expenses relating to defaults by the Fund’s investors in the payment of any capital contributions; out-of-pocket expenses for transactions that are not consummated; expenses incurred in connection with any restructuring or amendments to the constituent documents of the Fund and related entities, including the General Partner of such Fund and Atlas; any and all expenses incurred in connection with distributions to the Fund’s investors; any and all expenses in connection with any meetings with Fund’s investors or any limited partner advisory committee of the Fund; expenses related to the Fund’s indemnification obligations; expenses incurred in connection with the formation of alternative investment vehicles and any intermediate, blocker and other special purpose vehicles formed to facilitate the investment by certain limited partners in a portfolio company, to the extent permitted under the Governing Fund Documents (to be borne solely by investors therein or for whose benefit such vehicle has been established); reasonable out-of-pocket expenses incurred by the members of any limited partner advisory committee of the Fund in connection with the fulfillment of their duties pursuant to the Governing Fund Documents (including meals, entertainment, lodging and other similar expenses and which may include reasonable travel expenses incurred by a committee member travelling to and from such meetings; expenses relating to the offer and sale of interests in the Funds; expenses related to the maintenance of the Fund’s registered office, if applicable; brokerage costs, if applicable; extraordinary expenses; compensation and other similar expenses of consultants (including industry executives, advisors, consultants, operating executives, subject matter experts or other persons acting in a similar capacity) who provide services to the Fund or its portfolio companies (including with respect to potential portfolio investments). The fees, costs

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Atlas’s investment objective is to generate long-term capital appreciation. Atlas pursues a flexible investment strategy and an opportunistic and thematic approach to invest within the broad and diverse financial services industry. PE Funds With respect to the PE Funds, the Firm targets acquisitions of financial services businesses across a range of sectors in developed markets, specifically the United States, Canada, Western Europe and Japan. These sectors include but are not limited to: banks; life insurance; property and casualty insurance and reinsurance; broker-dealers; consumer finance; housing and mortgage finance; and other financial services ancillary businesses. This flexible investment approach provides Atlas with the ability to adapt with the evolving financial services industry and to capitalize on attractive investment opportunities. The development of themes is driven by three core factors: the investment professionals have a deep understanding of the businesses; valuations in the industry are attractive; and Atlas has the relevant expertise to add value and materially improve operations. Atlas focuses on acquiring businesses that are: capitalizing on growth opportunities resulting from evolving market dynamics; undervalued due to a number of factors, including regulatory or market factors, under management, and operational distress; and/or familiar to the Principals and Atlas’s experienced group of senior professionals (collectively, the “Senior Team Members”) due to their deep networks in the global financial services industry. The Senior Team Members’ active and substantial participation in the financial services industry provides Atlas with advantaged deal flow. Given the complexities of the industry, Atlas believes that successful investing requires not only specialized knowledge, but also a deep and extensive relationship network, which the Firm believes to be one of its key competitive advantages. The Senior Team Members bring significant operating and investing expertise across the global financial services industry to the PE Funds. Atlas employs a team-based approach to investing, implementing a collaborative process through the onset of due diligence, investment decision making and disposition. Prior to commencing the due diligence process, Atlas assembles the transaction team based on the relevant expertise of each investment professional and the particular circumstances of each investment opportunity. Every

transaction is overseen by one of the Principals. While all investment professionals are expected to contribute to investment discussions, final investment decisions are made by the Investment Committee, which is comprised of the Principals and Managing Directors (the “Investment Committee”). An investment in a PE Fund involves significant risk and potential conflicts of interest. There can be no assurance that a PE Fund’s investment objectives will be achieved, and actual investment results may vary substantially from the investment objective. Investors should be prepared to bear these risks. The descriptions contained below are a brief overview of different risks related to the PE Funds’ investment strategy; however, it is not intended to serve as an exhaustive list or a comprehensive description of all risks and conflicts that may arise in connection with the management and operations of the PE Funds. Investors should carefully consider all risk factors set forth in a Fund’s Governing Fund Documents. Each prospective investor should carefully review the applicable Governing Fund Documents before deciding to make an investment in a PE Fund. Each prospective investor should consult with his or her own counsel and advisors as to all legal, tax, financial and related matters concerning an investment in the PE Funds. Capital Invested: An investor acquiring interests in the PE Funds must rely upon the ability of the General Partners and Atlas to identify, structure, and implement investments consistent with the PE Funds’ investment objectives and policies. The PE Funds, however, may be unable to find a sufficient number of attractive opportunities to meet their investment objectives. The success of the PE Funds will depend on the ability of the General Partners and Atlas to identify suitable investments, to negotiate and arrange the closing of appropriate transactions and to arrange the timely disposition of such investments. Furthermore, the PE Funds may not be able to invest a significant portion of their capital commitments during their respective investment periods. U.S. Dollar Denomination of Interests: Interests in the PE Funds will be denominated in U.S. dollars. Investors that will subscribe for interests in any country in which U.S. dollars are not the local currency should note that changes in the value of exchange between U.S. dollars and such currency may have an adverse effect on the value, price or income of the investment to such investor. There may be foreign exchange regulations applicable to investments in foreign currencies in certain jurisdictions. General Nature of the PE Funds’ Investments: A substantial portion of the PE Funds’ investments will be in equity or equity-related investments that by their nature involve business, financial, market and legal risks. While such investments offer the opportunity for significant capital gains, they also involve a high degree of risk that may result in substantial losses. There can be no assurance that the PE Funds will correctly evaluate the nature and magnitude of the various factors that could affect the value of such investments. Prices of the investments may be volatile and a variety of other factors that are inherently difficult to predict, such as domestic or international economic and political developments, may significantly affect the results of the PE Funds’ activities. As a result, the PE Funds’ performance over a particular period may not necessarily be indicative of the results that may be expected in future periods.

Although the PE Funds intend to make primarily control-oriented investments, the PE Funds may make minority equity investments in companies where it may have limited or no influence. Such a company may have economic or business interests or goals that are inconsistent with those of the PE Funds, and the PE Funds may not be in a position to limit or otherwise protect the value of its investment in the company. The PE Funds’ control over the policies of these companies may also be limited. The PE Funds may co-invest in a company with financial, strategic or other third-party investors. Such investments will involve additional risks not present in investments where a third party is not involved, including the possibility that the co-investor may have interests or objectives that are inconsistent with those of the PE Funds or may be in a position to take (or block) action in a manner contrary to the PE Funds’ investment objectives. In addition, the PE Funds may, in certain circumstances, be liable for actions of their third-party co-ventures or partners. The PE Funds’ investments may involve the incorporation of new companies. Significant risks are associated with the incorporations of such companies which may require substantial additional capital to support expansion or to achieve or maintain a competitive position. Such companies may face intense competition, including competition from companies with greater financial resources, more extensive development, marketing and service capabilities and a larger number of qualified managerial and technical personnel. The PE Funds’ investments may involve investments in public companies (including strategic public investments) or taking private portfolio companies public. Investments in public companies may subject the PE Funds to risks that differ in type or degree from those involved with investments in privately held companies. Such risks include, without limitation, greater volatility in the valuation of such companies, increased obligations to disclose information regarding such companies, limitations on the ability of the PE Funds to dispose of such securities at certain times (including due to the possession by the PE Funds of material non-public information), increased likelihood of shareholder litigation against such companies’ board members, which may include the Principals, regulatory action by the SEC and increased costs associated with each of the aforementioned risks. The PE Funds’ investments may involve turnaround or underperforming companies or companies identified by Atlas as being in need of additional capital. The financial condition of such companies may be weak or their balance sheets highly leveraged and any investment in them may involve a high degree of risk. The PE Funds generally invest in companies that operate in regulated business lines. Examples include, without limitation, financial services, banks, insurance, payments and broker-dealers. The operations of such companies are subject to compliance with applicable regulations, and such companies may be subject to increased regulations resulting from both new requirements and reregulation of previously de-regulated markets. Prices may be artificially controlled, and regulatory burdens may increase costs of operations. New or increased regulations could adversely affect the performance of the companies in which the PE Funds invest. Financial Services Risk Factors: The PE Funds generally invest primarily in the equity and debt of financial services companies. Financial services companies have asset and liability structures that are essentially monetary in nature and are directly affected by many factors, including

domestic and international economic and political conditions, broad trends in business and finance, legislation and regulation affecting the national and international business and financial communities, monetary and fiscal policies, interest rates, inflation, currency values, market conditions, the availability and cost of short- or long-term funding and capital, the credit capacity or perceived creditworthiness of customers and counterparties, and the level and volatility of trading markets. The profitability of the financial services industry may be adversely affected by a worsening of general economic conditions in domestic and international markets and by monetary, fiscal or other policies that are adopted by various governmental authorities and international bodies. Monetary policies have had, and will continue to have, significant effects on the operations and results of financial services companies. There can be no assurance that a particular financial services company will not experience a material adverse effect on its net interest income in a changing interest rate environment. Factors such as the liquidity of the global financial markets, the level and volatility of prices of financial instruments, investor sentiment, and the availability and cost of credit may significantly affect the activity levels of customers with respect to size, number and timing of transactions. A change in all or any of these factors could lead to a decline in the volume of transactions that financial services companies execute for their customers and thus lead to a decline in revenues from fees, commissions and spreads. The financial services industry is extremely competitive, and it is expected that competitive conditions in the industry will continue to intensify. Merger activity in the financial services industry has resulted in, and may continue to result in, larger institutions with greater financial and other resources that are capable of offering a wider array of financial products and services. The financial services industry has become considerably more concentrated as numerous financial institutions have been acquired by or merged into other institutions. Technological advances and the growth of e-commerce have made it possible for non­financial institutions to offer products and services that have been traditionally offered by financial services institutions. It is expected that cross-industry competition will continue to intensify. The financial services industry is highly dependent on communications and information systems and is exposed to many types of operational risk, including the risk of fraud by employees or other parties, record keeping error, errors resulting from faulty computer or telecommunication systems, computer failures, computer hacking, data breaches and damage to computer and telecommunication systems caused by internal or external events. Financial services companies operate in a highly regulated environment and are subject to extensive legal and regulatory restrictions and limitations and to supervision, examination and enforcement by regulatory authorities. Failure to comply with any of these laws, rules or regulations, some of which are subject to interpretation and may be subject to change, could result in a variety of adverse consequences, including civil penalties, fines, suspension or expulsion, and termination of deposit insurance, which may have material adverse effects. In order to comply with banking laws, rules and regulations, the PE Funds may be required to invest in a manner that may not be as advantageous as the manner of making investments that are not subject to such laws, rules and regulations. Additionally, banks and bank holding companies are subject to various legal and regulatory limitations under federal and state law on the extent to which they can pay dividends or make

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Atlas provides investment advice to the Funds and the Co-Investment Vehicle Clients, which are private investment vehicles that are exempt from registration under the Investment Company Act. Interests in the Funds and Co-Investment Vehicle Clients are typically offered only to “qualified purchasers” as defined in Section 2(a)(51) of the Investment Company Act, and “accredited investors” as defined in Rule 501 of Regulation D of the Securities Act of 1933, as amended (the “Securities Act”). The Funds are marketed exclusively to institutional investors (e.g., trusts, employee benefits plans, endowments, foundations, corporations, and other types of entities,

including private funds of funds) and high net worth individuals. Investment advice is provided directly to the Funds and not individually to the limited partners of a Fund. Prospective investors should refer to the Governing Fund Documents of each respective Fund for information on minimum investment requirements. Typically, Atlas requires a minimum investment of $10,000,000 for its PE funds and for the Regional Depository Fund, although each General Partner, in its sole discretion, may accept lesser amounts and has accepted lower amounts.

As described in the “Fees and Compensation” section above, the General Partners of the PE Funds and the Regional Depository Fund are entitled to receive a performance-based carried interest

distribution, which is based on realized gains from investments above a performance threshold, as specified in each PE Fund’s Governing Fund Documents and the Regional Depository Fund’s Governing Fund Documents, as applicable. In each case, such carried interest is calculated based on a percentage of profits generated from the Fund and is subject to the satisfaction of a preferred rate of return of up to 8%, the return of capital (up to 100%), recoupment of losses, fees, expenses and other criteria set forth in the applicable Governing Fund Documents. The General Partner of a Co-Investment Vehicle is typically entitled to receive a performancebased carried interest distribution, which is usually based on realized gains from its investment above a performance threshold, as specified in each Co-Investment Vehicle Governing Fund Documents. Such carried interest is calculated based on a percentage of profits generated from the Co-Investment Vehicle and is subject to the satisfaction of the return of capital (up to 100%), recoupment of losses, fees, expenses and other criteria set forth in the Governing Fund Documents. The General Partner of the SPAC Fund is also entitled to receive a performance-based carried interest distribution, which is based on realized gains from investments above a performance threshold, as specified in the SPAC Fund’s Governing Fund Documents. Such incentive allocations are calculated based on realized or unrealized net capital appreciation or net capital depreciation attributable to the SPAC Fund’s investments and are allocated among capital accounts in proportion to their respective opening balances for any accounting period. Such carried interest is calculated based on a percentage of profits generated from the Fund and is subject to the satisfaction of a preferred rate of return of up to 4%, the return of capital (up to 100%), recoupment of losses, fees, expenses and other criteria set forth in the Governing Fund Documents. Performance-based fees may create an incentive for Atlas to cause the Funds to make investments that may be riskier or more speculative than those which would be made under a different fee arrangement. However, this incentive is mitigated in part by the financial commitment Atlas’s personnel make to the Funds in an effort to align Atlas’s and the Funds’ interests. Atlas also seeks to address these conflicts through careful vetting of investment opportunities by its investment professionals and disclosure of investments to limited partners by way of capital calls distributed to the limited partners in advance of each investment and quarterly reports to the limited partners. Additionally, Atlas has implemented internal controls to address the potential conflicts associated with performance based fees, as more fully described in each Fund’s Governing Fund Documents. Furthermore, the constituent documents of the PE Funds and the Regional Depository Fund have after-tax “claw back” arrangements as described in the “Fees and Compensation” section above. Although Atlas accepts performance-based carried interest from its PE Funds and the Regional Depository Fund but may not receive such fees from its Co-Investment Vehicle Clients, Atlas does not believe that it faces conflicts of interest in this regard because such Co-Investment Vehicle Clients do not make investments other than investments alongside PE Funds or the Regional Depository Fund that are subject to performance-based carried interest. Allocations of Investments The possibility exists that Atlas will, from time to time, be presented with investment opportunities that fall within the investment objectives of more than one Client. Atlas has established policies

and procedures for allocating investment opportunities among its Clients. When Atlas determines that it would be appropriate for more than one Client to participate in an investment opportunity, Atlas will seek to allocate investments on an equitable basis for all of the participating Clients. There is typically no obligation for a Client to dispose of any investment at the same time as any other Client. In determining initial allocations of investments among the Clients, Atlas and its affiliates will take into account such factors as they deem appropriate, which may include, without limitation: investment objectives; relative amounts of capital available for investments, the timing of capital inflows and outflows and anticipated capital commitments and subscriptions; liquidity needs; applicable concentration limits and other investment restrictions; mandatory minimum investment rights and other contractual obligations applicable to participating Clients and/or to their investors; portfolio diversification; relative exposure to market trends; tax efficiencies and potential adverse tax consequences; regulatory restrictions applicable to participating Clients and their investors that could limit the Client’s ability to participate in a proposed investment; policies and restrictions applicable to participating Clients; the avoidance of odd-lots or a de minimis allocation to one or more participating Clients; the potential dilutive effect of a new position; the overall risk profile of a portfolio; the potential return available from a debt investment as compared to an equity investment; and any other considerations deemed relevant by Atlas and its affiliates. There can be no assurance that any Client’s return from a transaction will be equal to and not less than another Client participating in the same transaction or that it will be as favorable as it would have been had such conflict not existed. When Atlas determines that it would be appropriate for multiple Clients to participate in an investment opportunity, Atlas will seek to aggregate orders for all of the participating Clients, on an equitable basis. The Clients that participate in an aggregated order will generally participate at the average price for all of the transactions in that security with respect to each buy/sell program on a given business day, with transaction costs generally shared pro rata based on the Clients’ participation in the transaction. The effect of such aggregation may operate on some occasions to a Client’s disadvantage. Specifically, if Atlas has determined to invest at the same time for more than one of the Clients, Atlas may place combined orders for all such Clients simultaneously and if any order is not filled at the same price, it may average the prices paid. Similarly, if an order on behalf of more than one Client cannot be fully executed under prevailing market conditions, Atlas may allocate the securities traded among the different Clients on the basis that it considers equitable. In these circumstances, each Client would pay, in connection with the acquisition of securities by more than one Client, the average price per unit acquired, which may be higher than if it had acted alone, and it may otherwise not be able to execute an investment decision as effectively as it could have if it had acted alone. There may be corresponding potential disadvantages when more than one Client simultaneously seeks to dispose of commonly held securities and other investment positions. Though not expected to occur frequently, one or more Clients may invest in portfolio investments or other issuers in which one or more other Clients is invested in a different part of the capital structure. These investments include investments in corporate loans and debt securities, preferred equity securities and common equity securities. The interests of such Clients may not be aligned in all circumstances to the extent they hold more junior or senior debt or equity interests, as the

case may be, which could create actual or potential conflicts of interest or the appearance of such conflicts. In that regard, actions may be taken by a Client that are adverse to another Client. The interests of Clients that are invested in different parts of the capital structure of a portfolio company are particularly likely to conflict in the case of financial distress of the portfolio company (or increased financial stress after the Client invests in the portfolio company). For example, if additional financing is necessary as a result of financial or other difficulties, it may not be in the best interests of the Client holding senior secured debt issued by such portfolio company to provide such additional financing. If a Client holding more junior debt or equity positions were to lose their respective investments as a result of such difficulties, the ability of Atlas to recommend actions that are in the best interests of such Client might be impaired. In addition, it is possible that, in a bankruptcy proceeding, a Client’s interests may be subordinated or otherwise adversely affected by virtue of such other Client’s involvement and actions relating to their investment. There can be no assurance that the term of or the return on a Client’s investment will be equivalent to or better than the term of or the returns obtained by the other Client participating in the transaction. This may result in a loss or substantial dilution of a Client’s investment, while another Client recovers all or part of amounts due to it. Similarly, the General Partner’s ability to implement a Client’s strategies effectively may be limited to the extent that contractual obligations entered into in respect of the activities of the other Clients impose restrictions on a Client engaging in transactions that the General Partner may be interested in otherwise pursuing. Except as required by the Governing Fund Documents of a particular Fund, Atlas is under no obligation to present any particular investment opportunity to any particular Fund. Atlas cannot assure that a Fund will participate in all investment opportunities that may meet its investment objectives. Atlas has established procedures for allocating co-investment opportunities among limited partners in its Funds, which may consider any factors Atlas deems relevant, including, without limitation, the size, sophistication, tenure as an investor, commitment to making co-investment funds available, ability to consummate co-investments within a specified time frame, commitment to invest in future products, interest in pursuing co-investment opportunities or strategic expertise of the prospective co-investor. The structure and terms of any co-investment opportunity to be offered by Atlas to any limited partner of a Fund shall be determined by Atlas, subject to the restrictions, if any, set forth in the Governing Fund Documents of the relevant Fund. When and to the extent that employees and related persons of Atlas and its affiliates make capital investments in or alongside certain Funds, Atlas and its affiliates are subject to conflicting interests in connection with these investments.

Atlas organizes and sponsors the Funds, which are pooled investment vehicles managed by Atlas and controlled by the affiliated General Partners. Atlas or the General Partners are responsible for all decisions regarding portfolio transactions of the Funds and have full discretion over the management of the Funds’ investment activities. While the General Partners are not separately registered as investment advisers with the SEC, all of their investment advisory activities are subject to the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and the rules thereunder. In addition, employees and persons acting on behalf of the General Partners are subject to the supervision and control of Atlas. Thus, the General Partners, all of their employees and the persons acting on their behalf would be “persons associated with” the registered investment adviser so that the SEC could enforce the requirements of the Advisers Act on the General Partners. One SPAC that is incorporated as a Delaware corporation and formed for the purpose of effecting a merger, share exchange, asset acquisition, share repurchase, reorganization or similar business combination with one or more businesses (the “SPAC”) is sponsored by an entity affiliated with Atlas. The SPAC’s sponsors and management include certain of Atlas’s employees who stand to benefit from their direct and/or indirect ownership in the SPAC. The SPAC is currently in the process of closing a business combination with a non financial services company therefore eliminating any potential conflict of interest with the current and any future PE Funds. Rorschach I LLC, a Delaware LLC, was formed for the purpose of effecting a merger and share exchange with an existing publicly traded company. On December 3, 2025, Rorschach I LLC merged with Sonnet BioTherapeutics Holdings, Inc. and was renamed Hyperliquid Strategies Inc. (“Hype”). Hype’s adviser Rorschach Advisers LLC, its Chief Executive Office and Chairman of the Board of Directors include certain of Atlas’s employees who stand to benefit from their roles and direct and/or indirect ownership in Hype. Any compensation received by the Principals or any Atlas employees for serving as directors or officers of Hype are not Transaction Fees. The Principals and Atlas employees may serve as directors and officers of, and provide advice to, publicly traded companies and private companies. Investors should be aware that receipt of material non-public information by such persons regarding these companies could preclude Atlas from effecting transactions in the securities of such companies. Compensation for directorships with portfolio companies of the Funds are Transaction Fees, as discussed under “Fees and Compensation” above. Any compensation received by the Principals or any Atlas employees for serving as directors or officers of the SPAC are not Transaction Fees. Certain of the related persons of Atlas may have personal investments in companies. The Funds are generally not prohibited from acquiring or otherwise engaging in transactions with companies in which affiliates of Atlas have a pre-existing financial interest. It is also possible that Atlas may occasionally utilize the services of entities that have, directly or indirectly, or whose affiliates have, investments in the Funds. Such services will only be used on an arm’s length basis and when they are in the best interest of the Funds. To the extent that conflicts arise, they will be resolved pursuant to Atlas’s policies and procedures and the Governing Fund Documents.

Atlas and its employees will devote such time as shall be necessary to conduct the business affairs of the Clients in an appropriate manner. However, the Firm’s employees may work on other projects, including being employed by other business entities, and therefore, conflicts may arise in the allocation of personnel. Any such conflicts will be managed in accordance with the Clients’ governing documents.

Personal Trading Atlas has adopted a Code of Ethics (the “Code”), which describes the Firm’s fiduciary duties and responsibilities to its Clients, requires that Atlas’s employees act in the best interests of Clients to the exclusion of contrary interests, act in good faith and in an ethical manner, avoid conflicts of interest with Funds to the extent reasonably possible, and identify and manage conflicts of interest to the extent that they arise. Atlas’s employees are also required to comply with applicable provisions of the federal securities laws and make prompt reports to the Firm or other appropriate party of any actual or suspected violations of such laws by Atlas or its employees. In addition, the Code sets forth formal policies and procedures with respect to the personal securities trading activities of Atlas’s employees. The Code prohibits personal securities transactions of issuers who have been placed on the Firm’s restricted list, and requires written pre-approval for all initialpublic offerings, private placements, and transactions in “Reportable Securities”. The Code requires employees to report all securities transactions and provide a summary of securities holdings initially upon hire and on an annual basis thereafter. The Code also addresses outside activities of employees, conflicts of interest, policies and procedures concerning the prevention of insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and the pre-clearance and reporting of political contributions. Atlas will provide a complete copy of the Code to any investor or prospective investor upon request sent to the CCO. Atlas and certain of its affiliated parties and employees will make commitments to the Funds. As such, Atlas and certain of its affiliated parties and employees will have a direct financial interest in the transactions of each of the Funds. While investments by such related parties are intended to align the interests of Atlas and the related parties with those of the Funds, such investments may create conflicts of interest. To address such conflicts, the investment arrangements are described and agreed upon in the Governing Fund Documents of each Fund. Generally, investments and dispositions are made on the same terms for all Fund investors, including Atlas and its related parties, and each investment is made pro rata among the investors of each Fund, including Atlas’s related parties who are investors, so that Atlas and its related parties may not receive more favorable terms or greater exposure to select investments. Allocation of Investment Opportunities: Atlas expects that the universe of potential investments and other activities of Atlas’s business could overlap with the investments and activities of the Funds and, as a result, may create conflicts of interest. Atlas will allocate investment opportunities among its Clients pursuant to its allocation policy and the Governing Fund Documents. With respect to any investment opportunity falling within the investment mandate of both a Fund and a SPAC affiliated with the Firm, such opportunity will be allocated to the Fund first.

Restrictions on Transactions Due to Other Atlas Businesses: From time to time, various potential and actual conflicts of interest may arise from the overall advisory, investment and other activities of Atlas and its personnel. Atlas will endeavor to resolve conflicts of interest with respect to investment opportunities in a manner it deems equitable to the extent possible under the prevailing facts and circumstances. Atlas may invest, on its own behalf, in securities and other instruments that would be appropriate for, held by, or may fall within the investment guidelines of a Client. Atlas may give advice or take action for its own account that may differ from, conflict with, or be adverse to, advice given or action taken for Clients. Potential conflicts of interest also may arise due to the fact that certain of Atlas’s executives may have investments in some Clients but not in others, or may have different levels of investment in the various Clients, and that the Clients may bear different levels of fees and incentive compensation in favor of Atlas. Atlas, together with its Clients, engages in a broad range of business activities and invests in portfolio companies whose operations may be substantially similar to and/or competitive with the portfolio companies in which the Clients have invested. The performance and operation of such competing businesses could conflict with and adversely affect the performance and operation of a Client’s portfolio companies, and may adversely affect the prices and availability of business opportunities or transactions available to such portfolio companies. Atlas will seek to resolve conflicts in a manner that Atlas determines to be fair and equitable and in accordance with its written allocation policy. Atlas may also have ongoing relationships with issuers whose securities have been acquired by, or are being considered for investment by, its Clients. No Client will be prohibited from acquiring, or otherwise engaging in transactions with respect to, securities of an entity in which another Client has a financial interest (whether in the same or a different class of securities) or selling, divesting, making further acquisitions or otherwise engaging in transactions with respect to securities of such entity, including following a coinvestment. The conflicts in any such transaction will be addressed pursuant to the Code and the applicable Governing Fund Documents. Allocation of Expenses: The General Partners, Atlas, the Principals and/or one or more of their respective affiliates may from time to time incur expenses on behalf of the Funds, other affiliated entities and one or more existing or subsequent entities established by the Principals. Although attempts will be made to allocate such expenses on an equitable basis, there can be no assurance that such expenses will in all cases be allocated appropriately. Material Non-Public Information; Information Barriers: Atlas generally operates without ethical screens or information barriers that other investment management firms implement to separate persons who make investment decisions from others who might possess material non-public information that could influence such decisions. In the event that employees of Atlas obtain such material non-public information, Atlas may be restricted in acquiring or disposing of investments on behalf of the Clients, which could impact the returns generated for the Clients. In addition, Atlas’s investment professionals or other employees may acquire, in their capacities as investment professionals or otherwise of one or more Clients (including the Fund), non-public

information regarding investment opportunities, business methodologies, strategies and other proprietary information In such instances, Atlas endeavors to maintain ethical screens and/or information barriers in order to limit use of such information for other portfolio companies or other Clients. Although Atlas will endeavor to ensure that such information sharing and use does not prejudice one or more such other Clients, there can be no assurance that such endeavors will be sufficient or successful. Management Team: Atlas and its personnel may have conflicts of interest in allocating their time and services among Clients. Although the Principals intend to be actively involved in the management of each Client, Atlas’s personnel (including the Principals) will work on other projects, including other Clients and Atlas’s other existing and potential business activities. For example, in addition to providing advisory services to the Funds, Atlas provides non-advisory services to other entities in which certain Atlas Principals have invested. In addition, Atlas’s personnel will concurrently participate in the management of the investment activities of Atlas and the other Clients. Conflicts of interest may arise because Atlas employees will serve as directors of certain of the portfolio companies. In those instances where a Client is not the sole shareholder of the applicable portfolio company, in addition to any fiduciary duties Atlas employees owe to the Client, as directors of portfolio companies, such employees owe fiduciary duties to the shareholders of the portfolio companies. Management Fee / Carried Interest Related Conflicts: The Management Fee payable by each Fund to Atlas and the carried interest that Atlas or its affiliates will receive, each as set forth under the Governing Fund Documents, have not been established on the basis of an arm’s-length negotiation and may affect the determinations of Atlas and its affiliates in various ways. The Management Fee may incentivize Atlas to cause a Fund to continue to hold an investment longer than it may have in the absence of the Management Fee. The existence of the performance-based carried interest with respect to the Funds may create an incentive for Atlas to (i) make riskier or more speculative investments on behalf of the Funds than it might otherwise make in the absence of such performance-based compensation and (ii) dispose of a Fund’s investments at a time and in a sequence that would generate the most carried interest. In addition, the terms of the carried interest distribution in favor of the General Partners could incentivize Atlas, as an affiliate of the General Partners, to make decisions regarding the timing and structure of realization transactions that may not be in the best interests of investors. The right to receive carried interest distributions also creates a potential conflict of interest in the valuation of investments. Atlas has prepared accounting guidelines regarding the recognition of asset impairment and has also adopted written valuation policies and procedures intended to address conflicts of interests that arise in respect of the valuation of the Funds’ assets. In general, following the investment period defined in the applicable Governing Fund Documents, the Management Fee will be based upon the cost basis of portfolio investments that have not been the subject of a disposition, write-off or a permanent write-down, and will be payable in advance, irrespective of any disposition, write-off or write-down during such applicable period. Depending

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Atlas has full discretionary authority to manage the investments of the Clients, including authority to make decisions with respect to which securities are bought and sold, the amount and price of those securities, the brokers or dealers to be used for a particular transaction, and commissions or markups and markdowns paid. Atlas’s authority is limited by its own internal policies and procedures and each Client’s investment guidelines. Atlas does not permit directed brokerage arrangements. Atlas’s PE Funds focus on making investments in private securities and accordingly do not typically trade in public securities. The following discussion applies to the PE Funds and the Regional Depository Fund in the circumstances where Atlas purchases or sells public securities as part of a transaction or has such securities as a result of a portfolio company going public. Factors Considered in Selecting Broker-Dealers Accordingly, the prices and commission rates (or dealer markups and markdowns arising in connection with riskless principal transactions) charged to the Funds by brokers or dealers in the foregoing circumstances may be higher than those charged by other brokers or dealers that may not offer such services. Atlas need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost or spread. Generally, neither Atlas nor the Funds separately compensate any broker or dealer for any of these other services. Best Execution In selecting an appropriate broker-dealer to effect a client trade, Atlas seeks to obtain best execution, taking into consideration the price of a security offered by the broker-dealer, as well as a broker-dealer’s full range and quality of services including, among other things, its facilities,

reliability and financial responsibility, execution capability, commission rates, responsiveness to Atlas, brokerage and research services provided to Atlas (e.g., research ideas, analysis, and investment strategies), special execution and block positioning capabilities, clearance, and settlement and custodial services. If Atlas decides, based on the factors set forth above, to execute transactions on an agency basis through Electronic Communications Networks (“ECNs”), it will also consider the following factors when choosing to use one ECN over another: the ease of use, the flexibility of the ECN compared to other ECNs, and the level of care and attention that will be given to smaller orders. Atlas maintains policies and procedures to review the quality of executions, including periodic reviews by its investment professionals. Research and Other Soft Dollar Benefits From time to time, Atlas receives advice and research reports from broker-dealers who may execute portfolio transactions. This research may be used to service one or more of Atlas’s Clients. Research or brokerage services may include research reports on particular industries and companies, economic surveys and analyses, recommendations as to specific securities or other instruments, online quotations, news and research services, access to an electronic communication network for order entry and account information, participation in broker-dealer sponsored research conferences and other services providing lawful and appropriate assistance to Atlas in the performance of its investment decision-making responsibilities on behalf of its Clients. If a particular broker-dealer’s research contributed to the investment research process, transactions may be directed to such broker-dealer, assuming such broker-dealer meets the aforementioned criteria. Atlas does not formally commit to provide any particular level of commissions (or markups or markdowns) to broker-dealers who provide research services. Atlas understands that the benefits received through its relationship with broker-dealers generally do not depend upon the amount of transactions directed to, or the amount of assets custodied by, such broker-dealers. Receipt of such research or other products or services may create an incentive for Atlas to select or direct more business to particular broker-dealers. However, Atlas will execute trades in accordance with the best execution principles outlined above. Atlas may also pay certain brokerdealers for research services provided, including in connection with compliance with the Markets in Financial Instruments Directive II in Europe. Aggregation of Orders Please see Item 6 for a discussion of Atlas’s practice concerning the aggregation of Client orders. Trade Errors On occasion, trade errors may occur with respect to trades executed, directly or indirectly, on behalf of one or more Clients. The General Partner, Atlas and their respective affiliates and directors, partners, members, shareholders, officers, employees, agents and any other person who serves at the request of the General Partner on behalf of a Client as a director, partner, member, officer, employee, agent or agent of any other entity (in each case, an “Indemnitee”), will typically not be liable to such Client or to its investors for (i) any act taken or omitted to be taken in good faith and in a manner reasonably believed to be in, or not opposed to, the best interests of the Client, any issuer, any subsidiary of an issuer, any alternative investment vehicle or any special

purpose investment vehicle, including any negligent act performed or omission made by it, in the absence of the Indemnitee’s fraud, gross negligence (as interpreted pursuant to the laws of the State of New York) or willful misconduct, or (ii) losses due to the negligence of brokers or other agents of the Client. Even though such exculpation and indemnifications do not constitute a waiver of any non-waivable Advisers Act fiduciary duties of the Indemnitees, subject to the Governing Fund Documents of a Client, this standard of care will result in a Client bearing the costs of any trade errors committed by an Indemnitee, so long as the errors do not evidence fraud, gross negligence or willful misconduct. From time to time, Atlas or its affiliates may voluntarily reimburse a Client for losses suffered as a result of a trade error. However, notwithstanding the previous sentence, investors should not carry the expectation that a reimbursement will ever take place, and in evaluating the Funds, no decisions should be made in reliance on Atlas making any reimbursements to the Funds for losses suffered as a result of such trade errors. Any decision to reimburse is not precedential and should not create the expectation of any reimbursement in the future. Examples of trade errors that may be committed by investment advisers include executing a purchase instead of a sale (or vice versa), marking a short sale as a long sale, purchasing or selling a security or other instrument in the incorrect amount, or purchasing or selling the wrong security or other instrument.

Atlas has engaged unaffiliated third-party financial institutions and other placement agents and solicitors for referrals of Fund investors. See “Fees and Compensation” above for details about compensation for third party placement agents under the PE Funds’ Governing Fund Documents. Any placement fees paid by a Fund to third parties are then generally offset against the Management Fee with respect to such Fund. As noted earlier, Atlas or its affiliates may charge portfolio companies Transaction Fees. The Management Fee will be reduced (but not below zero) by an amount equal to 100% of the investor

limited partners’ proportionate share of any Transaction Fees paid to Atlas related to a Fund investment or potential Fund investment in a portfolio company (to the extent allocated to the Fund’s investment or potential investment in such portfolio company).

There have been no legal or disciplinary events involving either Atlas or any of its management persons that are material to Atlas’s advisory business or the integrity of Atlas’s management.

With respect to the PE Funds and the Regional Depository Fund, investments, in each case, are continuously monitored and reviewed by members of the Firm’s Investment Committee as well as the Firm’s investments professionals. Atlas’s Investment Committee is primarily responsible for portfolio and risk management. The Investment Committee is comprised of senior professionals of the Firm and has the primary responsibility for reviewing all investments and making decisions on whether to acquire investments for the PE Funds and/or the Regional Depository Fund, as applicable. Each Investment Committee member holds a title of Founding Partner or Managing Director. Atlas maintains a strong focus on the ongoing monitoring of industry dynamics and companies across all sectors of the financial services industry, and will develop customized operating metrics for each of its private equity investments. Atlas sends all Fund investors: (i) audited financial statements within 120 days of the end of each fiscal year of the Funds; (ii) where applicable, unaudited financial statements and other information on a quarterly basis; and (iii) tax information related to the Funds necessary for the completion of any applicable federal tax returns.

Atlas is deemed to have custody of the assets of each Client because it or an affiliate serves as the Client’s General Partner. Such General Partner can withdraw a Client’s cash and/or securities held with a custodian upon the General Partner’s instruction to the custodian. Therefore, Atlas is subject to Rule 206(4)-2 promulgated under the Advisers Act (the “Custody Rule”). In accordance with the Custody Rule, the Firm adheres to the applicable requirements of the Custody Rule with respect to the Funds’ public assets. The CCO ensures that all privately offered securities, not held at a custodian, do not violate the “Private Security Exemption” provided in the Custody Rule. Atlas’s CFO is responsible for arranging for annual audits of the Funds by an independent auditor that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board within 120 days of the Funds’ fiscal year end and for obtaining audited financial statements prepared in accordance with GAAP. Atlas will arrange for the delivery of such audited financial statements to investors of the Clients within 120 days of the Funds’ fiscal year end.

Atlas generally has discretionary authority to manage assets and securities on behalf of its Clients. In such instances, Atlas is given such authority pursuant to the investment management agreements with such Clients, subject to the guidelines and/or limitations as described in each Client’s offering memorandum, limited partnership agreement and/or other constituent documents (including any side letters that are executed with investors). Atlas and the General Partners of, and investors in, the Funds are authorized, without the approval of any investor, to enter into side letters or similar written agreements with investors that have the effect of establishing rights under, or altering or supplementing the terms of, the Governing Fund Documents of the applicable Fund with respect to such investor, without entitling any other investor of such Fund to such waiver, modification or new rights. Rights that may be established and terms that may be altered or supplemented include, without limitation, rights and terms relating to greater portfolio transparency, fee waivers or reductions, minimum investment amounts, reports and other information, confidentiality, timing of funding, expenses, distributions, legal or regulatory requirements (e.g., tax and ERISA), advisory committee membership, as applicable, and other more favorable investment terms such as withdrawal rights. To the extent that compliance with any of the provisions of any side letters or similar written agreements would cause Atlas and/or its affiliates to violate their respective fiduciary duties or obligations or to violate any applicable laws, any non-compliance with any such provision will not be deemed to be a breach of such written agreements. Similarly, strategic investors of Atlas may receive certain preferential information and rights not available to other investors in the Funds.

The SEC adopted Rule 206(4)-6 under the Advisers Act, which requires registered investment advisers that exercise voting authority over Client securities to implement proxy-voting policies. In compliance with such rule, Atlas has adopted written proxy voting policies and procedures (the “Proxy Voting Policy”). When agreed upon with a Client, Atlas will be responsible for voting Client proxies relating to equity securities. The Proxy Voting Policy generally provides that Atlas or the applicable General Partner will vote proxy proposals, amendments, consents or resolutions relating to securities, including interests in pooled investment vehicles, if any (collectively, “Proxies”), in a manner that serves the best interests of the Clients, as determined by Atlas in its discretion, taking into account the following factors: (i) the impact on the value of the investments; (ii) the views of management; (iii) the continued or increased availability of portfolio information; and (iv) industry and business practices. In addition, Atlas may not vote Proxies in certain situations where the associated costs outweigh the anticipated benefits to Clients. If a material conflict of interest exists between the interests of Atlas and those of the relevant Client with respect to any issue to be voted on, Atlas will base its voting decision exclusively on Atlas’s judgment of what will best serve the financial interests of the Client that beneficially owns the securities that are the subject of the vote. Investors may obtain a copy of the proxy voting record for a given Client, or a copy of the Proxy Voting Policy, by contacting the Firm’s CCO.

Atlas has not included a balance sheet in this submission because it does not require or solicit prepayment of fees from Clients for periods of six months or more in advance. Atlas has not been the subject of a bankruptcy petition and is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to Clients.