Atreides Management, LP

Firm Background Atreides Management, LP (hereinafter “Atreides”, “we”, “us”, “our”, the “Investment Manager”, or the “Firm”) is organized as a Delaware partnership with a principal place of business in Boston, Massachusetts. Atreides is controlled by its general partner, Atreides Management, LLC, a Delaware limited liability company. Gavin Baker (the “Portfolio Manager”) is the managing member of Atreides Management, LLC. Our registration on Form ADV also covers Atreides Foundation Fund GP, LLC (the “Foundation Fund GP”), Atreides Ventures GP, LLC (the “Private Opportunities Fund GP”),Atreides Special Circumstances, LLC (the “Co-Investment Managing Member”), each of which is a Delaware limited liability company, and Atreides AI Associates I L.P. (“VAAI Fund Atreides GP”), which is a Delaware limited partnership. The Foundation Fund GP, Private Opportunities Fund GP and the Co-Investment Managing Member are affiliates of Atreides and serve as the general partner or managing member of the pooled investment vehicles currently managed by Atreides. The VAAI Fund Atreides GP is an affiliate of Atreides and serves as the co-general partner to the pooled investment vehicles co-managed by Atreides and Valor Management LLC. The facilities and personnel of the Foundation Fund GP, Private Opportunities Fund GP, the Co-Investment Managing Member, and the VAAI Fund Atreides GP are provided by Atreides. Types of Advisory Services Pooled Investment Vehicles. We serve as the investment adviser, with discretionary trading authority, to private, pooled investment vehicles, the securities of which are offered through a private placement memorandum to accredited investors, as defined under the Securities Act of 1933, as amended (the “Securities Act”), and qualified purchasers, as defined under the Investment Company Act of 1940, as amended. As of December 31, 2025, our clients included the following private, pooled investment vehicles: • • • • •

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Atreides Foundation Fund, Ltd., a Cayman Islands exempted company (the “Foundation Offshore Fund”); Atreides Foundation Fund, LP, a Delaware limited partnership (the “Foundation Onshore Fund” and, together with the Foundation Offshore Fund, the “Foundation Feeder Funds”); Atreides Foundation Master Fund LP, a Cayman Islands exempted limited partnership (the “Foundation Master Fund” and together with the Foundation Feeder Funds, the “Foundation Funds” and each individually, a “Foundation Fund”); Atreides Private Opportunities Fund, LP, a Delaware limited partnership (the “Private Opportunities Onshore Fund”); Atreides Private Opportunities Offshore Fund, LP, a Cayman Islands exempted limited partnership (the “Private Opportunities Offshore Fund” and together with Private Opportunities Onshore Fund, the “Private Opportunities Feeder Funds” and, together with the Foundation Feeder Funds, the “Feeder Funds”); Atreides Private Opportunities Master Fund I, LP, a Cayman Islands exempted limited partnership (the “Private Opportunities Master Fund” and together with the Private Opportunities Feeder Funds, the “Private Opportunities Funds” and each individually, a “Private Opportunities Fund”); and Valor Atreides AI I L.P., a Delaware limited partnership (together with its parallel fund, Valor

Atreides AI I-B L.P., a Delaware limited partnership, the “VAAI Funds”). The Investment Manager serves as a co-investment manager of the VAAI Funds with Valor Management LLC, a Delaware limited liability company (“Valor”). In January 2026, Atreides 150/50 Technology Master Fund LP, a Cayman Islands exempted limited partnership (the “150/50 Technology Master Fund” and, collectively with its feeder funds, Atreides 150/50 Technology Fund, LP (the “150/50 Technology Onshore Fund”), a Delaware limited -4-

partnership, and Atreides 150/50 Technology Fund, Ltd. (the “150/50 Technology Offshore Fund”), a Cayman Islands exempted company, the “150/50 Technology Funds”) held its first closing and became a client of Atreides. The general partner of the Foundation Onshore Fund and the Foundation Master Fund is the Foundation Fund GP. The general partner of each of the Private Opportunities Funds is the Private Opportunities Fund GP. The VAAI Funds have co-general partners: VAAI Fund Atreides GP, an affiliate of the Firm, and Valor AI Associates I L.P, a Delaware limited partnership (“VAAI Fund Valor GP” and together with VAAI Fund Atreides GP, the “VAAI Fund GPs”), an affiliate of Valor. The general partner of the 150/50 Technology Onshore Fund and the 150/50 Technology Master Fund is Atreides 150/50 Technology Fund GP, LLC (“150/50 Technology Fund GP”). The Foundation Fund GP, the Private Opportunities Fund GP, the VAAI Fund Atreides GP, and the 150/50 Technology Fund GP are together referred to herein as the “General Partners” and each is referred to individually as a “General Partner” as context requires. The Foundation Master Fund, the Private Opportunities Master Fund, and the 150/50 Technology Master Fund are herein together referred to as the “Master Funds” and each individually, a “Master Fund”. The Feeder Funds invest substantially all of their assets in the relevant Master Fund. Investment and trading activity are conducted at the Master Fund level. References herein to the investment objectives, strategies, investments and transactions of each Fund include the Feeder Funds’ investment objectives, strategies, investments and transactions as implemented through the relevant Master Fund. As of December 31, 2025, our clients also include the following private, pooled investment vehicles organized to facilitate specific co-investment opportunities alongside one or both of the Master Funds on a discretionary basis: Co-Investment Master Fund (each a separate series (“Series”) of Atreides Special Circumstances Fund, LLC, a Delaware series limited liability company) Series B DIs Series C DIs Series D DIs Series E DIs Series F DIs Series G DIs Series H DIs Series I DIs Series K DIs Series L DIs Series M DIs Series N DIs Series O DIs Series P DIs Series Q DIs Series R DIs Series S DIs Series T DIs Series U DIs Series V DIs

Co-Investment Offshore Feeder Fund (each a segregated portfolio (“Segregated Portfolio”) of Atreides Special Circumstances Offshore Fund SPC, a Cayman Islands segregated portfolio company) ----Series D DIs SP Series E DIs SP Series F DIs SP Series G DIs SP Series H DIs SP Series I DIs SP Series K DIs SP Series L DIs SP Series M DIs SP Series N DIs SP Series O DIs SP Series P DIs SP Series Q DIs SP Series R DIs SP Series S DIs SP --Series U DIs SP Series V DIs SP

In January 2026, the Co-Investment Master Fund established Series W DIs and the Co-Investment Offshore Feeder Fund established Series W DIs SP. In March 2026, the Co-Investment Master Fund established Series X DIs and the Co-Investment Offshore Feeder Fund established Series X DIs SP. Each Co-Investment Offshore Feeder Fund invests substantially all of its assets in the relevant Co-Investment Master Fund. The Co-Investment Master Funds and Co-Investment Offshore Feeder Funds are collectively referred to as the -5-

“Co-Investment Funds.” The managing member of the Co-Investment Master Fund is the Co-Investment Fund Managing Member. The Master Funds, the Feeder Funds and the Co-Investment Funds are collectively referred to herein as the “Atreides Funds” and each is referred to individually as an “Atreides Fund.” The Atreides Funds and the VAAI Funds are each referred to individually as a “Fund” and are collectively referred to herein as the “Funds.” From time to time, the Funds designate a director affiliated with Atreides to serve on the board of directors of certain portfolio companies as to which the Funds obtain such rights. The Foundation Onshore Fund’s, the 150/50 Technology Onshore Fund’s, the Private Opportunities Feeder Funds’ and the VAAI Funds’ “Limited Partners”, the Foundation Offshore Fund’s and the 150/50 Technology Offshore Fund’s “Shareholders” and the Co-Investment Funds’ “Members” and “Shareholders” (as applicable) are hereafter collectively referred to as the “Investors” where appropriate. Atreides may, from time to time, provide investment advisory services for additional funds or products, including, without limitation, other co-investment vehicles or funds. Separate Accounts. Atreides provides discretionary investment advisory services through separately managed account arrangements pursuant to advisory agreements, which incorporate certain investment guidelines and restrictions. Advisory agreements are typically negotiated to meet the specific needs of the particular client. The Funds, collectively with separate account clients, are referred to as “Clients.” Tailoring of Advisory Services We do not tailor our advisory services to the individual needs of any particular investor in the Funds. Our investment decisions and advice with respect to the Funds are subject to each Fund’s investment objectives and guidelines, as set forth in its respective “Offering Documents.” Investors in the Funds participate in the overall investment program for the applicable Fund, but may be excused from a particular investment due to legal, regulatory or other applicable constraints or for other agreed upon reasons. Each Fund and/or Atreides may enter into side letters or other similar agreements with certain investors that have the effect of establishing rights under, or altering or supplementing the terms (including economic or other terms) of, the relevant Offering Documents. In our sole discretion, we will agree to tailor our advisory services to the individual needs of our separate account clients, who may request certain reasonable restrictions on the securities or types of securities purchased on their behalf for a separate account. We do not currently participate in any wrap fee Programs. Client Assets Under Management As of December 31, 2025, Atreides had approximately $6,488,269,311 in net assets under management on a discretionary basis.

The fees applicable to each of the Funds are set forth in detail in the corresponding Offering Documents. A brief summary of such fees is provided below. Management Fee With respect to the Foundation Funds, Atreides is paid, in advance, an investment management fee (“Foundation Management Fee”) for management services for each fiscal quarter. The Foundation Management Fee will generally range between 1.25% and 1.75% (annualized) of the net asset value of each series of interests of the Foundation Master Fund corresponding to each Investor’s interest or shares in the Foundation Feeder Funds as of the beginning of such fiscal quarter (before taking into account the estimated -6-

accrued incentive allocation). With respect to the 150/50 Technology Funds, Atreides is paid, in advance, an investment management fee (“150/50 Technology Management Fee”) for management services for each fiscal quarter. The 150/50 Technology Management Fee is generally 1.0% (annualized) of the net asset value of each series of interests of the 150/50 Technology Master Fund corresponding to each Investor’s interest or shares in the 150/50 Technology Feeder Funds as of the beginning of such fiscal quarter (before taking into account the estimated accrued incentive allocation). With respect to the Private Opportunities Funds, Atreides is paid, in advance, an investment management fee (“Private Opportunities Management Fee”) for management services for each fiscal quarter. The Private Opportunities Management Fee will generally range between 1.75% and 2.0% (annualized) of the Private Opportunities Master Fund’s capital commitments during the Private Opportunities Funds’ investment period, and thereafter, between 1.25% and 1.5% (annualized) of the Private Opportunities Master Fund’s aggregate invested capital by each Investor in the Private Opportunities Funds less, in the case of any such investment that has been permanently written off, the amount of such write-off. With respect to the VAAI Funds, the Firm and Valor, in their capacities as co-investment managers of the VAAI Funds, are paid, in advance, an investment management fee (“VAAI Management Fee”) for each fiscal quarter. The VAAI Management Fee is generally 2.0% (annualized) of the VAAI Funds’ aggregate capital commitments. Commencing with the first VAAI Management Fee due date after the expiration of the VAAI Funds’ investment period or earlier upon the occurrence of certain events as set forth in the VAAI Funds’ partnership agreements, the VAAI Management Fee will equal 2% of: (i) the aggregate Capital Contributions for portfolio investments (including for bridge financings), less (ii) the aggregate amount of capital contributions in respect of each portfolio investment that has been disposed of or permanently written down, as of the first day of the period in respect of which the VAAI Management Fee is then being paid. In addition, the VAAI Management Fee will be reduced by an amount equal to 100% of the limited partners’ (other than affiliates of the VAAI Fund GP) share of the VAAI Funds’ share of certain fees paid by portfolio companies. The Foundation Management Fee, the 150/50 Technology Management Fee, the Private Opportunities Management Fee and the VAAI Management Fee are collectively referred to herein as the “Management Fees” and each is referred to individually as the “Management Fee.” Investors in the Co-Investment Funds generally do not pay a management fee to Atreides. Atreides, in its sole discretion, may elect to waive, reduce or rebate the Management Fee with respect to certain Investors, including affiliates of Atreides and/or the Firm and their respective members, managers, partners, directors, officers and employees, any “friends and family” members thereof and members of the management advisory committee (the “Committee”, as defined in the Offering Documents) (and the family members and estate planning vehicles of the foregoing persons); provided, however, that no such waiver, reduction or rebate will adversely impact any other Investor or cause them to bear a higher portion of the Management Fee than they would bear absent such waiver, reduction or rebate. Separately managed account clients pay Atreides an asset-based management fee that is calculated monthly or quarterly, in accordance with the terms of each client’s agreement, and payable quarterly in arrears. Other Types of Fees or Expenses Foundation Funds Subject to variations in each Foundation Fund’s Offering Documents (and as further described therein), a Fund will pay, whether directly or through reimbursement of the Investment Manager or one of its affiliates, all costs and expenses related to its investments and its operations, including, without limitation, brokerage and other transaction costs, data fees, clearing and settlement charges, outsourced trading service expenses, trade break fees, research (including research-related travel expenses incurred with respect to specific potential or existing investments) and brokerage products, fees paid to consultants providing services in respect of such systems, that fall within Section 28(e) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), costs of independent appraisals, broken-deal and/or unconsummated expenses associated with an -7-

investment (including, for purposes of clarity, any portion of such expenses that could have been borne by a co-investment vehicle managed by Atreides, which will be allocated to the capital accounts of the A-3 or F-3 Investors (as defined in the Offering Documents) in proportion to their respective participating percentage interests therein unless such co-investors agree otherwise to bear such expenses), the portion of any costs and/or expenses associated with any shared investment of the Fund and the VAAI Funds allocated to the Fund as determined by the general partner (which may include certain internal costs charged to portfolio companies (costs and expenses relating to services provided by Valor to portfolio companies in which the Fund, the VAAI Funds and other funds and accounts invest are expected to be charged to such portfolio companies)); legal fees and other expenses in connection with conducting due diligence and negotiating the terms of investments (including investment-related travel expenses incurred with respect to specific potential or existing investments), regardless of whether such investments are consummated, costs of news services, fees and expenses relating to information technology hardware, software or other technology such as Bloomberg terminals; custodial fees, administrator fees and expenses, directors’ and officers’ fees and expenses (including for individual regulatory filings referable to a Fund), third party valuation services, expenses and costs of expert networks, expenses and costs of obtaining surveys, analysis or other data sets from third parties related to prospective investments or sectors in which the Fund may invest, initial and variation margin, interest and commitment fees on debit balances or borrowings, stock borrowing fees and proxy solicitation expenses, legal expenses (including expenses relating to regulatory or similar investigations, inquiries and “sweeps”), audit and tax preparation expenses, accounting fees, consulting fees and expenses (including any fees and expenses charged by consultants relating to assisting with reviewing and negotiating contracts, research agreements or other documents relating to the Fund), expenses associated with special purpose vehicles, insurance expenses including costs of any liability insurance obtained on behalf of the Fund or officers’ and directors’ insurance, indemnification expenses, expenses of terminating, winding up and dissolving the Fund and liquidating the assets of a Fund, reverse breakup, termination and other similar fees, filing, title, transfer, registration and other similar fees and expenses, printing and communications, any activities with respect to protecting the confidential or non-public nature of any information or data, unreimbursed costs and expenses incurred in connection with any transfer or proposed transfer, the Foundation Management Fee, government and regulatory costs and expenses (including filing and license fees and preparation and submission of filings and licenses, including without limitation, Section 13 filings, Form PF preparation and filing fees, blue sky and corporate filing fees and expenses and anti-money laundering compliance and reporting expenses) in connection with specific investments or offering interests in the Fund, any issue or transfer taxes chargeable in connection with any securities transactions, any entity level taxes and fees, costs of reporting and providing information to Investors (including updates to the Offering Documents), expenses relating to any amendment to the Fund’s agreements and the solicitation of any Investor consents, expenses relating to annual investor meetings, expenses relating to anti-money laundering, client identification and verification and tax information exchange obligations, and costs of litigation or investigation involving Fund activities, and any extraordinary expenses. Expenses are generally shared by all of the Investors, while expenses related to one or more particular series or sub-series or classes or sub-classes of Interests will be allocated accordingly by the Foundation Fund GP. Any investment or other expense relating specifically to a Designated Investment Account (as defined in the Offering Documents) shall be charged against the capital accounts of the A-3 or F-3 Investors participating in such Designated Investment Account in proportion to their respective participating percentage interests therein. Organizational costs of the Foundation Feeder Funds have been fully amortized for financial statement purposes. Other Funds The 150/50 Technology Funds, the Private Opportunities Funds, the Co-Investment Funds and the VAAI Funds will typically bear fees, costs and expenses related to their formation, operations and investments that are similar in nature to the fees costs and expenses described above for the Foundation Funds. Such Funds are also expected to incur certain fees, costs and expenses that are not described above, which may include, for example, expenses relating to the establishment of alternative investment vehicles and expenses charged to portfolio companies in which one or more of the Funds invest may include certain internal costs and certain internal expenses incurred by Valor relating to services that it provides to such portfolio companies that are not borne by the portfolio companies. As the Private Opportunities Funds, the Co-Investment Funds and the VAAI Funds are generally expected to invest in private securities, the expenses described above for the -8-

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The descriptions set forth in this Brochure of specific advisory services that we offer to Clients, and investment strategies pursued and investments made by us on behalf of our Clients, should not be understood to limit in any way our investment activities. We may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that we consider appropriate, subject to each Client’s investment objectives and guidelines as set forth in the Offering Documents. The investment strategies we pursue are speculative and entail substantial risks. Clients should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any Client will be achieved. Methods of Analysis and Investment Strategies Foundation Funds The investment objective of the Foundation Funds is to generate attractive absolute returns for investors over a rolling five-to-seven year time horizon. The Foundation Funds’ investment mandate is technology (including those sectors and industries that the Investment Manager considers to be significantly impacted by technological advancement or to be otherwise technology-adjacent, including for example and without limitation, energy, utilities/infrastructure, data centers and venture capital financing), media and telecommunications and consumer and is expected to be focused on the disruptive forces driving the most

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significant political, social and economic changes seen since the Industrial Revolution. Atreides pursues a longbiased, long/short equity strategy to construct a portfolio primarily consisting of publicly listed equities, although Atreides will invest opportunistically in privately held companies. Atreides will seek to achieve the investment strategy by taking a private equity approach to the public markets generally characterized by a long-duration time horizon, investing in a relatively small number of positions, and pursuing an investment process driven by intensive fundamental research and rigorous portfolio construction. Atreides will seek to own a concentrated portfolio of high-quality businesses with sustainable – and preferably – expanding competitive advantages run by shareholder friendly management teams operating in industries that are taking share of global gross domestic product. Atreides will also seek to be opportunistically short companies whose long-term prospects are impaired either by disruptive trends and/or declining competitive advantages, especially when the aforementioned realities are not reflected in valuations. 150/50 Technology Funds The investment objective of the 150/50 Technology Funds is to generate attractive absolute returns for investors over a long-term time horizon. The 150/50 Technology Funds’ investment mandate is technology (including those sectors and industries that the Investment Manager considers to be significantly impacted by technological advancement or to be otherwise technology-adjacent, including for example and without limitation, energy, utilities/infrastructure, data centers and financial services), media and telecommunications and is expected to be focused on the disruptive forces driving the most significant political, social and economic changes since the Industrial Revolution, most notably, Artificial Intelligence. It is anticipated that the 150/50 Technology Funds will typically invest (both long and short) in the same publicly traded securities issued by technology focused companies as the Foundation Funds. The 150/50 Technology Funds will typically invest in these securities on a pari passu basis with the Foundation Funds (subject to the 150/50 Technology Funds’ exposure targets), provided that the 150/50 Technology Funds might not invest in certain securities and trading strategies (e.g., options) that the Foundation Funds invest in or use, subject to Atreides’ trade allocation policy. The Foundation Funds’ investment mandate is broader than the 150/50 Technology Funds’ investment mandate, as the Foundation Funds also invest in the securities of consumerfocused companies. Atreides will determine, in its sole discretion, whether the companies in which the Foundation Funds invest are focused on technology for purposes of determining whether the 150/50 Technology Funds will also invest in such companies. The 150/50 Technology Funds will construct and maintain a portfolio of securities using a “150/50” approach, meaning that the 150/50 Technology Funds will target a long gross exposure of one hundred and fifty percent (150%) of its Net Asset Value and a short gross exposure of fifty percent (50%) of its Net Asset Value. The 150/50 Technology Funds’ portfolio may, from time to time, be more or less than one hundred and fifty percent (150%) long and fifty percent (50%) short based on numerous factors, including, but not limited to, the Investment Manager’s assessment of market conditions, the availability of securities (to purchase or borrow) at any given time and the cash flow needs of the 150/50 Technology Funds. Atreides will seek to rebalance the 150/50 Technology Funds’ portfolio periodically to achieve its targeted long/short exposure. Private Opportunities Funds The investment objective of the Private Opportunities Funds is to generate attractive absolute returns for investors by a combination of investing in the securities of private venture and growth companies (including companies offering securities in “down rounds” and recapitalizations) and in take-private transactions and structured equity over a period of time. The Private Opportunities Funds’ investment mandate is technology, media and telecommunications and consumer-centric and is expected to be focused on private investments in companies capitalizing on the disruptive forces driving the most significant political, social and economic changes seen since the Industrial Revolution. Atreides has the flexibility to opportunistically invest across public and private companies at various stages through various types of transactions, including but not limited to venture, growth equity, “down rounds,” structured equity and take-privates. Co-Investment Funds The objective of the Co-Investment Funds is to make co-investments (individually, a “Co-Investment” and, collectively, the “Co-Investments”) alongside the Foundation Funds and the Private Opportunities Funds in circumstances where the Investment Manager determines (i) that the Foundation Funds’ and the Private Opportunities Funds’ investment in a particular issuer or other asset should be less than the total investment required for such issuer or other asset for reasons such as the size or specific characteristics related to the -12-

applicable investment or for other strategic reasons and (ii) such investment is appropriate, in terms of size and other characteristics, for co-investment through a Series (for example, that the size and other characteristics of the potential co-investment justify the costs associated with the establishment of a Series). Each Series of the Co-Investment Funds is expected to participate in only a single investment. VAAI Funds The VAAI Funds focus principally on privately-negotiated investments in, or related to, venture stage companies, primarily in the U.S. and Canada, that provide or are planning to provide, directly or indirectly, products, services and/or technologies (i) that incorporate or are expected to incorporate artificial intelligence as a differentiating factor in the application provided and/or (ii) that support other companies or organizations with respect to their products, services and/or technologies that incorporate artificial intelligence. The VAAI Funds’ investments will generally be made in unregistered securities. Atreides invests the Funds’ assets in privately placed unregistered securities that do not have a readily ascertainable market value or other illiquid securities which may be valued but are not freely transferable. There can be no assurance that a Fund’s investment objective will be achieved, and certain trading practices (e.g., the use of leverage, short sales, the concentration of investments, and use of commodities) may, in some circumstances, increase any adverse impact to which Atreides’ investment portfolio may be subject. Risk of Loss The following risk factors do not purport to be a complete list or explanation of the risks involved in an investment in the Funds advised by us. These risk factors include only those risks we believe to be material, significant or unusual and relate to particularly significant investment strategies or methods of analysis employed by us. Certain of the risks described below may be applicable to only certain of the Funds. An investment in the Funds involve significant risks, and is suitable only for those persons who can bear the economic risk of the loss of their entire investment, who have limited need for liquidity in their investment, and who have met the conditions set forth in the Offering Documents. There can be no assurances that we will achieve our investment objectives. An investment carries with it the inherent risks associated with investments in publicly-traded stocks and bonds, options, and related instruments, including, without limitation, the risks described below. Each prospective investor should carefully review the Offering Documents and the documents referred to herein before deciding to invest with Atreides. Investment and Trading Risks. An investment in the Funds involves a high degree of risk, including the risk that the entire amount invested may be lost. No guarantee or representation is made that the Funds’ investment program will be successful or that the Funds will achieve their objective. The Investment Manager will invest substantially all of the Funds’ assets in securities, some of which may be particularly sensitive to economic, market, industry and other variable conditions. The markets in which the Funds expect to invest may experience significant volatility and losses. No assurance can be given as to when or whether adverse events might occur that could cause immediate and significant losses to the Funds. Equity Securities Generally. The Funds invest in equity securities and equity-related securities of public and private companies in the U.S. and other countries. The value of these financial instruments generally will vary with the performance of the issuer and movements in the equity markets. As a result, the Funds may suffer losses if they invest in equity instruments of issuers whose performance diverges from the Investment Manager’s expectations or if equity markets generally move in a single direction and the Funds have not hedged against such a general move. The Funds also may be exposed to risks that issuers will not fulfill contractual obligations such as, in the case of convertible securities or private placements, delivering marketable common stock upon conversions of convertible securities and registering or otherwise qualifying restricted securities for public resale. No Assurance of Investment Return. The Investment Manager cannot provide assurances that it will be -13-

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Our clients are the Funds and separately managed account clients, as described in Item 4 above. With respect to the Foundation Feeder Funds and the 150/50 Technology Feeder Funds, Investors must make initial commitments of no less than $3,000,000, unless such minimum is waived in accordance with the relevant Fund’s Offering Documents. With respect to the Private Opportunities Feeder Funds, Investors must make initial commitments of no less than $1,000,000, unless such minimum is waived in accordance with the Private Opportunities Funds’ Offering Documents. With respect to the Co-Investment Funds, the minimum commitment is dependent upon the specific coinvestment opportunity, unless such minimum is waived in accordance with the Co-Investment Funds’ Offering Documents. With respect to the VAAI Funds, Investors must make initial commitments of no less than $5,000,000, unless such minimum is waived in accordance with the VAAI Funds’ Offering Documents.

We and our affiliates receive performance-based compensation from every Client. We and our affiliates may have a conflict of interest in rendering advice to a Client because the financial benefit from managing one or more separately managed accounts may be lower (e.g., such separately managed accounts generate lower fees or allocations tied to either lower percentages earned or smaller amounts of capital investment by us or our affiliates), which may provide an incentive to favor a particular Client over a separately managed account. With respect to the Foundation Funds, the Foundation Fund GP is generally entitled to receive an annual performance allocation equal to between 12.5% and 19%, depending on the series of interest or sub-class of shares of each Investor, of the net realized and unrealized profits, if any, attributable to each Investor’s series of interest or sub-class of shares at the end of each fiscal year and subject to a hurdle. The performance allocations are described in more detail in the Foundation Funds’ Offering Documents. With respect to the 150/50 Technology Funds, the 150/50 Technology Fund GP is generally entitled to receive an annual performance allocation equal to 20%, provided that such percentage will increase for investors in the 150/50 Technology Funds’ standard series/classes for performance in excess of a certain amount. With respect to the Private Opportunities Funds, the Co-Investment Funds and the VAAI Funds, each of the Private Opportunities Fund GP, the Co-Investment Managing Member and the VAAI Fund Atreides GP, respectively, is generally entitled to receive carried interest distributions (“Carried Interest”). Private Opportunities Funds: Following an Investor’s receipt of distributions from the Private Opportunities Fund in an amount equal to its aggregate capital contributions to the Private Opportunities Fund, generally 20% of subsequent distributions will be made to the Private Opportunities Fund GP as Carried Interest distributions. Co-Investment Funds: Carried Interest for the Co-Investment Funds is separately determined for each Series of the Fund. Following an Investor’s receipt of distributions from a Series of a Co-Investment Fund in an amount equal to its aggregate capital contributions to such Series, generally 8% or 12% (depending on the class of interests an Investor holds in the Foundation Fund) of subsequent distributions will be made to the Co-Investment Managing Member as Carried Interest distributions. VAAI Funds: Following an Investor’s receipt of distributions from the VAAI Fund in an amount equal to its aggregate capital contributions attributable to realized investments and unrealized investments to the extent they are permanently written down as of that time, expenses related thereto and a preferred return on such amounts, subsequent distributions will (i) first be made to the VAAI Fund GPs to provide them with an amount equal to 20% of an amount equal to the preferred return plus distributions made to the VAAI Fund GPs pursuant to this clause (i), and (ii) thereafter be made to the VAAI Fund GPs in an amount equal to 20% of such distributions, provided that such percentage will increase for certain investors (based on the size of -10-

their capital commitments), for distributions in excess of a certain amount. The governing documents for the Private Opportunities Funds and the VAAI Funds require the general partner to return excess amounts of carried interest as “clawbacks”. These clawback obligations create an incentive for a general partner to defer disposition of one or more investments or delay the liquidation of a Fund if the disposition and/or liquidation would result in a realized loss to the fund or would otherwise result in a clawback situation for the general partner. In addition, the manner in which a general partner’s entitlement to carried interest is determined is expected to subject the general partners, from time to time, to potential conflicts between its interests and the interests of Fund investors with respect to the sequence and timing of disposals of investments. However, the Firm believes this incentive is mitigated by the fact that any losses will reduce such Fund’s performance and thus a general partner’s carried interest distributions. The Private Opportunities Fund GP, the Co-Investment Managing Member, or the VAAI Fund GPs, as applicable, in its or their sole discretion, may waive or modify the Carried Interest for any Investor (including, e.g., our employees).

As part of its investment research process, Atreides communicates with a variety of third parties about investment ideas and analyses. Such third parties may include other investors in the securities markets and the information discussed may include references to specific securities in which a Client has invested or may in the future invest and other proprietary information of the Firm. We share such information when the Firm believes that doing so will benefit the Clients through the mutual exchange of information and the resultant idea generation and exposure to different perspectives on relevant issuers and/or industries. It is possible that in any particular instance the sharing of particular proprietary information could be viewed in isolation as harmful to the Clients, though we believe that, in aggregate, the mutual exchange of information is beneficial to the Clients. As mentioned in Item 4, Atreides is affiliated with the Foundation Fund GP, the 150/50 Technology Fund GP, the Private Opportunities Fund GP and the Co-Investment Managing Member, each of which is a limited liability company organized under the laws of the state of Delaware, and the VAAI Fund Atreides GP, which is a Delaware limited partnership. The Foundation Fund GP, the 150/50 Technology Fund GP, the Private Opportunities Fund GP and the Co-Investment Managing Member are affiliates of Atreides and serve or may serve as the general partner or managing member of pooled investment vehicles managed by Atreides. The VAAI Fund Atreides GP is an affiliate of Atreides and serves as the co-general partner to the VAAI Funds. The facilities and personnel of the Foundation Fund GP, the 150/50 Technology Fund GP, the Private Opportunities Fund GP, the Co-Investment Managing Member, and the VAAI Fund Atreides GP are provided by Atreides. The Firm, Valor and each of the VAAI Fund GPs have entered into an agreement governing the arrangements as between them, which includes, among other things, the sharing or governance and authority and the responsibilities of each party thereto with respect to the VAAI Funds and the investment opportunity allocation provisions described below in Item 12. Gavin Baker, the Founder, Managing Partner and Chief Investment Officer of Atreides, serves as a strategic advisor to a private equity fund affiliated with Valor. Antonio Gracias, the Founder, Chief Executive Officer and Chief Investment Officer of Valor, serves as a strategic advisor to Atreides with respect to private investments. The Atreides Funds may invest in privately held companies in which funds managed by Valor and/or the VAAI Funds also invest when such investments are in line with the applicable Atreides Fund’s investment objectives and Atreides believes doing so would be in the Atreides Fund’s best interests. From time to time, Gavin Baker and certain other employees of Atreides also serve on the board of directors of certain private companies invested in by a Fund. Neither we nor our management persons are registered as broker-dealers, and neither of us has any application pending to register with the SEC as a broker-dealer or registered representative of a broker-dealer, respectively. We and our management persons are not registered as, and do not have any application to register as, futures commission merchants, commodity pool operators, commodity trading advisors or associated persons of the foregoing entities. We do not recommend or select other investment advisers for our Clients.

Code of Ethics Atreides has adopted a “Code of Ethics” that establishes the high standard of conduct that we expect of our -40-

employees and procedures regarding our employees’ personal trading of securities. Our employees are required to certify their adherence to the terms set forth in the Code of Ethics upon commencement of employment and annually thereafter. Employees also are required to provide quarterly certifications of compliance with certain Code of Ethics provisions. The foundation of our Code of Ethics is based upon the following underlying fiduciary principles: • • •

Employees must at all times place the interests of the Funds and Investors first; Employees must ensure that all personal securities transactions are conducted consistent with the Code of Ethics’ Employee Personal Investment Policy (described below); and Employees should not take inappropriate advantage of their position at the Firm.

Employees are generally discouraged from maintaining personal brokerage accounts for the purpose of trading “Reportable Securities” (as defined in the Code of Ethics, and which includes a wide variety of investments such as stocks, bonds, fixed income, options, warrants, futures, and derivatives). Employees and Covered Accounts must obtain pre-approval from the CCO or the CCO’s designee (together, “Compliance”) for all trades in Reportable Securities in any Covered Account(s). Employees are prohibited from participating in Initial Public Offerings (“IPOs”), absent pre-clearance from Compliance. Employees are also prohibited from personally, or on behalf of a Fund or other Client, purchasing or selling securities that appear on the Firm’s Restricted List. Employees are not required, however, to obtain pre-clearance for personal investments in certain other asset classes and goods, including certain investments in residential real estate and mutual funds, whether or not our Clients have invested in the same or similar assets. Employees must obtain pre-approval from Compliance before: (i) engaging in any outside business activities; or (ii) making any private investments. We will provide a copy of our Code of Ethics to our Investors, or any prospective investor, upon request. Investors may make such a request by contacting us at the address or telephone number listed on the first page of this document. Securities in which Atreides or a Related Person Has a Material Financial Interest Cross Transactions Investment advisers that manage accounts for multiple clients also have a number of obligations and limitations regarding their ability to effect transfers of securities from one client to another (each such transfer, a “Cross Trade”). To the extent that we determine that it would be in the best interests of certain clients to engage in a Cross Trade (which can happen for a variety of reasons, including tax purposes, liquidity purposes, to rebalance client portfolios, or to reduce transaction costs that may arise in an open market transaction),the terms thereof will be commercially reasonable and will not be materially less favorable to any Client than those available in the market. We will not receive any special fees or other compensation in connection with cross transactions. Expenses incurred in a cross transaction will be allocated equitably in the discretion of the Investment Manager between the Clients that are parties to the Cross Trade. Similarly, if a transaction is cancelled, any costs incurred will be allocated equitably in the discretion of the Investment Manager between such parties. Principal Transactions To the extent that Cross Trades may be viewed as principal transactions (as such term is used under the Advisers Act) due to the ownership interest in a Fund by the Foundation Fund GP, 150/50 Technology Fund GP, the Private Opportunities Fund GP or the Co-Investment Managing Member, and any of their affiliates, as applicable, or otherwise, Atreides or its personnel, for the avoidance of doubt, will comply with the requirements of Section 206(3) of the Advisers Act for any principal transactions. To the extent that we engage in any such transactions, we will obtain approval from each impacted Client, which may include the approval by an advisory board or an independent client representative or independent directors of the Foundation Offshore -41-

Fund or the 150/50 Technology Offshore Fund) to the extent permitted under the Client’s governing document and consistent with the requirements of applicable law. In no event will any principal transaction, Cross Trade, related-party transaction or other transaction or relationship involving actual conflicts of interest, be entered into if it does not comply with applicable law. Investing in Securities that Atreides or a Related Person Recommends to Clients To the extent that we, or any of our affiliates or employees transact in or hold securities that are also held by Clients, Atreides, its affiliates and its employees may give advice or take action for their own accounts that may differ from, conflict with or be adverse to advice given or action taken for our clients. These activities may adversely affect the prices and availability of other securities held by or potentially considered for purchase by our Clients. We may determine from time to time to trade a limited amount of proprietary capital in order to incubate or develop new investment strategies in which Clients will not participate until such time (if ever) as we determine such strategies are appropriate for a Client. From time to time, we may identify opportunities deemed to be attractive to acquire interests in companies exceeding the amount we believe is appropriate for the Master Funds to acquire. Additionally, we may identify situations where we believe the position of the applicable Master Funds and VAAI Funds in an intended investee company would be enhanced were their positions to be accompanied by that of one or more co-investors receiving advice from or managed by us. In such circumstances, one or more co-investment vehicles managed by us, including the Co-Investment Funds, may be utilized to acquire such investments. Certain holders of sub-series of interests or sub-class of shares in the Feeder Funds may be offered (but we are not obligated to offer) an opportunity to invest in such co-investment vehicles based on a prescribed formula. We will typically utilize such co-investment vehicles when we believe their use may be in the interests of the Master Funds and/or the VAAI Funds. The allocation of an investment opportunity between the Master Funds and the VAAI Funds, on the one hand, and the co-investment vehicles, on the other hand, will be determined in our sole discretion in accordance with market practice and as may in our opinion be deemed fair, reasonable and equitable. Such considerations may result in allocations of certain investments on other than a pari passu basis and, in some cases, the Master Funds and the VAAI Funds may not participate fully in a particular co-investment opportunity In furtherance of the foregoing, co-investment opportunities may instead be offered to other Clients or to third parties. In addition, one or more investors (which may include an investor in a Feeder Fund, us or our affiliates or other parties) may provide capital for a co-investment opportunity in the event that subscriptions from investors are not sufficient or if one or more investors do not fund their commitments. If we determine that an investment opportunity is too large for the Master Funds and, where applicable, the VAAI Funds, we and our affiliates may, but will not be obligated to, make proprietary investments therein. We and our affiliates may receive fees and/or allocations from co-investors, which may differ as among co-investors and also may differ from the fees and/or allocations borne by the Master Funds and the VAAI Funds. Other terms and rights applicable to such co-investors (including without limitation, withdrawal rights, information rights and the terms related to the particular structure of any co-investment vehicle) may also differ from the terms and rights applicable to investors in the Feeder Funds and the VAAI funds as well as among co-investors. The determination with respect to making co-investment opportunities available with respect to investments made by the VAAI Funds must be made by both of the VAAI Fund GPs. In exercising its discretion to allocate co-investment opportunities with respect to a particular investment among the Master Funds, the Co-Investment Funds, the VAAI Funds and other Clients, we may consider some or all of a wide range of factors, which may include, but are not limited to, the evaluation of the size and financial resources of the potential co-investment opportunity; any confidentiality concerns that may arise in connection with providing the other account or person with specific information relating to the coinvestment in order to permit such potential co-investment party to evaluate the co-investment opportunity; the potential co-investment amount; our perceptions of past experiences and relationships with the potential co-investment party, such as the willingness or ability of the potential co-investment party to respond promptly and/or affirmatively to potential co-investment opportunities previously offered, and the expected amount of negotiations required in connection with a potential co-investment party’s commitment; and other -42-

tax, legal, regulatory or other considerations. Our exercise of our discretion in allocating co-investment opportunities with respect to a particular investment among various Clients may not, and often will not, result in proportional allocations among such Clients and such allocations may be more or less advantageous to some Clients relative to other Clients. Conflicts of Interest Created by Contemporaneous Trading To the extent Atreides invests in the same securities on behalf of multiple Clients, we will allocate investment opportunities to those Clients on a fair and equitable basis, based upon such factors as we may determine from time to time, which may include the investment objectives, any applicable investment or risk restrictions or limitations, investment portfolio, tax considerations and available of capital of the applicable Clients. Under certain circumstances, Atreides may take different positions in the same security for different Clients on a particular trading day or may purchase securities for one account on the same day as it is selling such securities for another account. This can happen as a result of (i) account rebalancing in connection with achieving a Client’s targeted long/short exposure, (ii) capital flows activity (e.g., in connection with a contribution or withdrawal or the commencement or termination of an account), or (iii) different investment strategies implemented for different Clients. Atreides has implemented alerts in its order management system in an effort to ensure that conflicting orders are intentional and not the result of an error.

Atreides is authorized to determine the broker-dealer to be used for executing securities transaction for Clients. In selecting broker-dealers to execute transactions, we do not need to solicit competitive bids and do not have an obligation to seek the lowest available commission cost. It is not our practice to negotiate “execution only” commission rates; therefore, Clients may be deemed to be paying for research, brokerage or other services provided by the broker which are included in the commission rate. Best Execution In selecting an appropriate broker-dealer to effect a trade, we seek to obtain “Best Execution,” meaning generally the execution of a securities transaction for a Client in such a manner that a Client’s total costs or proceeds in the transaction are most favorable under the circumstances. Accordingly, in seeking Best Execution, we will take into consideration relevant factors, including, but not limited to, price quotes; the size of the transaction; the nature of the market for the security; the timing of the transaction; the difficulty of execution; the broker or dealer’s expertise in the relevant market or sector; the extent to which the broker or dealer makes a market in the security or has access to such market; the broker or dealer’s skill in positioning the relevant market; the broker or dealer’s facilities, reliability, promptness and financial stability; the broker or dealer’s reputation for diligence and integrity (including in correcting errors); confidentiality considerations; the quality and usefulness of research products and services and investment ideas presented by the broker or dealer; and other factors deemed appropriate by the Firm. We may also consider the quality, comprehensiveness and frequency of available research (including discussions with research personnel and research related services) and other products and services considered to be of value. The products and services furnished by broker-dealers may include, among other things, written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; statistics and pricing or appraisal services; discussion with research personnel; special execution capabilities; order of call and the availability of stocks to borrow for short trades. The Investment Manager may, in its discretion, determine to use one or more third party service providers to perform certain trading functions for the Master Funds, and in connection therewith the Master Funds may pay higher brokerage commissions than might be paid if the Investment Manager performed this function, particularly in the case of trades that the Investment Manager directs to be executed with a broker other than the third party service provider. Such service provider may be subject to certain restrictions and conflicts that may limit its ability to perform such trading services. The provision by a broker of research and other services and property to us creates an incentive for us to -43-

select such broker since we would not have to pay for such research and other services and property as opposed to solely seeking the most favorable execution for a Fund. Any research, services or property provided by a broker may benefit any client and such benefits may not be proportionate to commission dollars related to the provision of such research, services or property. Soft Dollars Atreides may pay higher commission prices for the purchase or sale of securities to receive research or other products or services other than execution from a broker-dealer and/or a third-party in connection with Client securities transactions. This is known as a “soft dollar” relationship. In such cases, soft dollar credits, generated by a Client’s trading activities, are used to purchase brokerage and research services or products and, therefore, reduce expenses that Atreides would otherwise bear. We intend to limit our use of soft dollars to services that constitute research and brokerage within the parameters of the safe harbor of Section 28(e) of the Securities and Exchange Act of 1934, as amended (“Section 28(e)”). During the Firm’s last fiscal year, services and products acquired with soft dollar commissions included, among other services and products, (i) equity research reports and information on companies, industries and securities; (ii) software providing analysis of securities portfolios; (iii) economic, financial and market data; (iv) certain financial newsletters and trade journals; and (v) discussions with research analysts. Atreides participates in certain “commission sharing arrangements” pursuant to which Atreides may execute transactions through a broker-dealer and request that the broker-dealer allocate a portion of the commissions or commission credits to another firm that provides research and other products to Atreides. Atreides excludes from use under these arrangements those products and services that are not eligible under Section 28(e) and applicable regulatory interpretations. The provision by a broker of research and other services to us creates an incentive for us to select such broker since we would not have to pay for such research and other services as opposed to solely seeking the most favorable execution for a Client. Any research or services provided by a broker may benefit any Client and such benefits may not be proportionate to commission dollars related to the provision of such research or services. Atreides also reserves the right to purchase (and from time to time purchases) research and brokerage related services with “hard dollars.” Brokerage for Client Referrals Subject to best execution, Atreides may consider, among other things, capital introduction and marketing assistance with respect to Investors in the Funds in selecting or recommending broker-dealers for the Master Funds. Directed Brokerage We do not recommend, request or require that a Client direct us to execute transactions through a specified broker-dealer. Allocation and Aggregation When the purchase and sale of securities and other instruments is considered to be in the best interest of multiple Clients, the securities or other instruments to be purchased or sold will generally be aggregated in order to obtain superior execution and/or lower brokerage expenses. Execution prices for identical securities purchased or sold on behalf of multiple accounts in any one day will typically be (but are not required to be) averaged. In such instances, allocation of prices, as well as expenses incurred in the transaction, will be made in a manner that Atreides considers to be equally as favorable to the participating accounts. Atreides has established policies and procedures for the aggregation and allocation of trades for Clients.

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As a general principle, Atreides seeks to allocate trading and investment opportunities among all accounts in a manner it deems fair and equitable. However, there can be no assurance that any separate account client or Fund will participate in any particular trade or investment opportunity on an equal or pro rata basis with other Clients. Allocation of IPOs. The availability of IPO shares is generally limited. In certain circumstances and as consistent with applicable law and our best execution obligations, Atreides may decide to convey an indication of interest in the IPO shares to the underwriters for our Clients’ accounts on an aggregated basis. In the event Atreides participates in any new issues, Atreides’ policy and practice is to allocate new issue shares fairly and equitably among our Clients according to a specific and consistent basis so as not to favor or disfavor any Client, or group of Clients, over any other. Where Client account guidelines permit participation in IPOs, shares are generally allocated to such Client accounts on a pro rata basis. None of the Special Circumstances Funds, the Private Opportunities Fund or the VAAI Funds are expected to participate in IPOs. Allocation of Private Investments. Investments in private securities are often subject to limited availability. Atreides maintains allocation policies and procedures which generally provide that allocation of private investment opportunities among the Funds will be made in Atreides’ judgment based upon such factors as it may determine, which may include, but are not limited to, investment objectives, any applicable investment or risk restrictions or limitations, investment portfolio, tax considerations and capital available to make the investment. However, it is anticipated that the investments in private securities by the Funds will typically be allocated based on the available capital that each Fund has to invest in private investments. Pursuant to the VAAI Funds’ Offering Documents, investment opportunities meeting the VAAI Funds’ investment criteria will be initially apportioned 50% to the VAAI Funds. Trade Errors Although Atreides exercises due care in making and implementing investment decisions, employees may from time to time make errors with respect to trades made on behalf of one or more Clients. In the event any error occurs in the placement, execution or settlement of any Client transaction, Atreides’ policy is to seek to identify and correct any errors as promptly as possible without disadvantaging the impacted Client or benefiting Atreides in any way. As disclosed in each Fund’s governing documents, in the absence of fraud, willful misconduct or gross negligence, losses related to trade errors will be absorbed by the Fund(s). If a trade error results in a gain to the Fund, the Fund shall retain such gain.

We do not receive economic benefits from non-clients for providing investment advice and other advisory services. We have entered into written agreements with broker-dealers as placement agents (each, a “Placement Agent”) to introduce certain Funds to prospective investors and may enter into additional similar agreements in the future. Pursuant to these agreements, we pay a percentage of the management fees and/or performance-based compensation collected from the investors introduced to us by the applicable Placement Agent to the Placement Agent. With respect to the VAAI Funds, Placement Agents are engaged by both Atreides and Valor.

To the best of our knowledge, there are no legal or disciplinary events that are material to an Investor’s or prospective investor’s evaluation of our advisory business or the integrity of our management.

Our Portfolio Manager and investment professionals regularly monitor and analyze the transactions, positions, and investment levels of the Master Funds and the separate accounts to ensure that they conform with the applicable investment objectives and guidelines. In these reviews, the Firm pays particular attention to any changes in the investments’ fundamentals, overall risk management and changes in the markets that may affect price levels. The VAAI Fund GPs have established an Investment Committee that includes one representative from each of the Firm (Gavin Baker) and Valor (Antonio Gracias). The members of the Investment Committee and certain additional representatives from each of the Firm and Valor monitor and conduct quarterly reviews of the VAAI Funds’ portfolio companies and maintain ongoing oversight. In addition, such individuals review portfolio company information more frequently when a portfolio company needs subsequent financing, in anticipation of a potential acquisition or liquidity event, or if there is a serious performance issue at or other concern about a portfolio company. Account Reporting An audited financial report with respect to each Fund’s previous fiscal year will be distributed to all Investors within 120 days of fiscal year end. We will also distribute unaudited net asset value statements (monthly for the Foundation Funds and 150/50 Technology Funds and quarterly for the Co-Investment and Private -45-

Opportunities Funds), unaudited performance reports (monthly for the Foundation Funds and 150/50 Technology Funds and quarterly for the Private Opportunities Funds), and periodic investor letters to all Investors in each applicable Fund. Investors in the VAAI Funds will be provided with unaudited financial statements for the first three quarters of each fiscal year and unaudited valuation information for each portfolio company annually. In addition to the information typically provided to all prospective and existing Investors in the applicable Funds, the Firm does, in certain circumstances (e.g., in connection with diligence, a co-investment opportunity, or Side Letter rights) provide certain prospective and existing Investors with more frequent or detailed information with respect to a Fund or existing or prospective investments and other Investors will not necessarily receive such information.

As a result of having the authority to obtain the funds and securities of the Funds, we will be deemed to have custody, for example, by deducting advisory fees or otherwise withdrawing funds from a Fund’s account. Account statements related to the Funds are sent by qualified custodians to Atreides. We will comply with Rule 206(4)-2 of the Advisers Act (i.e., the “custody rule”) by meeting the conditions of the pooled vehicle annual audit approach. Upon completion of the relevant Fund’s annual audit by an independent auditor that is registered with, and subject to inspection by, the Public Company Accounting Oversight Board (PCAOB), we will ensure that the Fund’s audited financials are distributed to Investors within 120 days of such Fund’s fiscal year end. Atreides does not have custody of the assets held by separate accounts. To the extent Atreides is deemed to have custody of a separate account’s assets, Atreides will comply with the custody rule.

We have full discretionary investment authority with respect to the Atreides Funds, including authority to make decisions with respect to which securities to be bought and sold, as well as the amount and price of those securities. With respect to the VAAI Funds, we serve as the co-investment manager with Valor. Investment decisions for the VAAI Funds, including purchases and sales of portfolio companies, are required to be made by both members of the Investment Committee (see Item 13 above). Our investment decisions and advice with respect to each Fund are subject to each Fund’s investment objectives and guidelines, as set forth in its Offering Documents. We, or one of our affiliates, have entered into an investment management agreement, or similar agreement, with each Fund, pursuant to which we (or any applicable affiliate) have been granted discretionary trading authority (subject to the joint decision-making requirements described above). Atreides receives discretionary authority from each separate account client at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold. Our investment decisions and advice with respect to each separate account are subject to the stated investment objectives for the separate account, as well as any investment guidelines and/or restrictions.

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In compliance with Rule 206(4)-6 of the Advisers Act (i.e., the “proxy voting rule”), we have adopted proxy voting policies and procedures. The general policy is to vote all proxy proposals, amendments, consents or resolutions (each, a “Proxy” and collectively, “Proxies”) in a prudent and diligent manner that will serve the applicable Fund’s best interests and is in line with the Fund’s investment objectives. We may take into account all relevant factors, as determined by us in our discretion, including, without limitation: • • • •

the impact on the value of the securities or instruments owned by the relevant Fund and the returns on those securities; the anticipated associated costs and benefits; the continued or increased availability of portfolio information; and industry and business practices.

Generally, Clients may not direct our vote in a particular solicitation. With respect to securities held by multiple Clients, we intend to vote in a consistent manner for all Clients. However, as material proxy voting decisions for the private securities held by the VAAI Funds will be made by representatives of the Firm and Valor, it is possible that the vote with respect to an issuer of a security may be different between the VAAI Funds and our other Clients that hold such security. We have appointed Institutional Shareholder Services Inc. (“ISS”) to provide us with proxy voting services with respect to the publicly traded securities held by our Clients. We will vote proxies in accordance with ISS’s proxy voting guidelines and socially responsible investing (“SRI”) principles, unless we have a particular reason to vote to the contrary. The Firm’s Proxy Voting Policy with respect to the publicly traded securities held by our Clients is based on ISS’s Benchmark Proxy Voting Guidelines and the following additional SRI-oriented principles: Key Issue Board Independence Board Diversity Executive Compensation

Independent Auditor Shareholder Proposals

Atreides Proxy Voting Policy Vote against or withhold votes from all director nominees when independent directors make up less than a majority of the directors. Vote against or withhold votes from incumbent nominating committee members if the board does not meet certain diversity criteria. Vote on a case-by-case basis on management proposals seeking advisory votes on executive compensation with closer scrutiny on pay magnitude and performance alignment, internal pay disparity, performance-based equity, and problematic change-in-control and/or severance provisions. Vote for shareholder proposals to rotate company’s auditor every five years or more. Generally vote for shareholder social, workforce, and environmental proposals that promote good corporate citizens while enhancing longterm shareholder and stakeholder value. Generally support proxy voting proposals that call for actions beyond disclosure reporting of corporate environmental policies or resolutions seeking greater transparency around social policies and practices – including support for proposals seeking adoption of policies on topics such as human/labor rights, workplace safety or discrimination, access to pharmaceutical drugs, incorporation of sustainability-related performance metrics into executive compensation setting, hydraulic fracturing and climate change and greenhouse gas or toxic emissions, to name a few.

ISS’s Benchmark Proxy Voting Guidelines can be found on ISS’s website at: https://www.issgovernance.com/policy-gateway/voting-policies/. -47-

With respect to our Clients’ investments in privately held securities, we generally votes in accordance with the recommendations of any board member(s) we appointed unless we determine that voting in such a manner is in conflict with the best interests of the Fund(s). In other cases with respect to privately held securities, we will evaluate and vote the proxies on a case-by-case basis. Nevertheless, in voting proxies, we will consider what is in the overall best interest of our Clients and is in line with each Client’s investment objectives. We will maintain documentation memorializing the decision to vote a proxy in a manner different from what is stated in the relevant proxy voting guidelines. Conflicts of interest may arise between the interests of our Clients and us or our affiliates. If we determine that we may have, or be perceived to have, a conflict of interest when voting Proxies, we will vote in accordance with our Proxy voting policies and procedures. Clients may obtain a copy of our Proxy voting policies and our Proxy voting record upon request by contacting our General Counsel & CCO, Laura Malone, at compliance@atreidesmgmt.com. Atreides utilizes Securities Class Action Services, LLC (“SCAS”) to provide class action litigation monitoring and securities claim filing services on behalf of the Funds (with our oversight). Any compensation received as the result of participation in a class action settlement is paid to the Funds pro-rata based on the percentage of the relevant holding in each portfolio. For its services SCAS is paid based on a percentage of the proceeds recovered from a class action filing. It should be noted that the Funds bear the cost (i.e., receive a reduced amount of the class action proceeds) of any third party used for class action recovery services. We credit any class action settlements received for a Fund to current investors in that particular Fund.

We are not required to include a balance sheet for our most recent fiscal year, are not aware of any financial condition reasonably likely to impair our ability to meet contractual commitments to Clients and have not been the subject of a bankruptcy petition at any time during the past ten years.

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