Birchview Capital, LP

Birchview Capital, LP (“Birchview”), a Delaware limited partnership, provides investment management services on a discretionary basis to privately offered investment funds (each, the “Fund” and collectively, the “Funds”). Birchview’s clients also include separately managed accounts, including individual retirement accounts (collectively, the “Separately Managed Accounts” and together with the Funds, the “Clients”). Birchview may decide in the future to sponsor or manage additional privately offered investment funds or separately managed accounts. The Funds include: Birchview Fund LLC, a Delaware limited liability company (the “Birchview Fund”) and Birchview SB-68 Healthcare Fund LLC, a Delaware limited liability company (the “SB-68 Fund”). Birchview Fund The Birchview Fund’s investment objective is to generate capital appreciation by focusing on investing in companies that are underappreciated relative to their growth prospects. In addition to common stocks of public companies or private investments into public companies (or PIPEs), the Clients may participate in private placements. The Birchview Fund’s initial portfolio of investments (the “Initial Portfolio”) comprised assets that, prior to the Birchview Fund’s initial capitalization, were owned directly by Matthew W. Strobeck, Birchview’s owner, founder and Chief Executive Officer (the “Portfolio Manager”). The Birchview Fund acquired the Initial Portfolio at fair market value as an in-kind capital contribution from the Portfolio Manager. Birchview Partners, LLC, an affiliate of Birchview, serves as the sponsor and manager of the Birchview Fund (“Birchview Partners”). SB-68 Fund The SB-68 Fund’s investment objective is to generate attractive risk-adjusted returns through a market-neutral investment program focused on publicly traded companies across the healthcare sector. Birchview SB-68 Healthcare Partners, LLC (“SB-68 Healthcare Partners”, together with the Birchview Partners, “Managers”), an affiliate of Birchview, serves as the manager of the SB-68 Fund. The Funds are offering interests (the “Interest(s)”) to certain qualified investors as described in response to Item 7 below. Investors in the Funds or Separately Managed Accounts, including prospective investors, are referred to herein as “Investors”. Advisory services are tailored to achieve the Clients’ investment objectives. Birchview may give advice and take action with respect to other Clients or for its own accounts that may differ from the advice or the timing or nature of action taken with respect to the Funds. Birchview has no obligation to recommend for purchase or sale for the Funds any asset that Birchview or an affiliate may purchase or sell for its own account or for the account of any of their Clients.

As of December 31, 2025, Birchview had approximately $239.1 million of Client assets under management, all of which is managed on a discretionary basis.

The fees and compensation payable to Birchview are negotiable and vary among its Clients. However, the range of compensation is generally as follows: Management Fee In certain instances, Birchview receives an annual asset-based management fee calculated as a percentage of each Investor’s capital account, payable quarterly in arrears. The management fee generally ranges from 1.25% to 2.0% per year. For Separately Managed Accounts, Birchview may receive management fees comparable to those paid by the Funds; however, fee structures are subject to negotiation and may vary from those paid by the Funds. Incentive Allocation In some instances, Birchview receives an incentive allocation equal to a percentage of the net income allocated to each Investor for the year, but only to the extent net income allocated to that Investor exceeds any cumulative losses that were allocated to that Investor for earlier periods and that have not been recovered (a “high water mark”). This incentive allocation is generally 10% to 20% and is typically made at the end of each calendar year or the date of a withdrawal, distribution or transfer of the Investor’s interests, if applicable. The incentive allocation will only be charged to accounts of those Investors who are “qualified clients” as defined in Rule 205-3 of the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Portfolio Company Fees The Portfolio Manager, Birchview, Birchview Partners or their affiliates or personnel, as applicable, may receive, from time to time, monitoring fees, directors’ fees, transaction fees and other fees from portfolio companies or prospective portfolio companies of a Fund (including any cash received upon exercise, conversion or otherwise of any directors’ stock options or other noncash fees) (“Portfolio Company Fees”). Portfolio Company Fees will be applied as follows: (i) first, to reduce future management fee amounts otherwise payable by the Investors; and (ii) second, to reduce future incentive allocation amounts otherwise allocable from the Investors. Any remaining Portfolio Company Fees will be rebated to the applicable Fund. Portfolio Company Fees will not reduce any management fees or incentive allocations in respect of any prior period. Any out-of-pocket expenses incurred by the Portfolio Manager, Birchview, Birchview Partners or their affiliates or personnel, as applicable, in connection with their portfolio company activities will be reimbursed by the applicable Fund. Transaction Expenses The Funds will be subject to transaction fees and costs in connection with their investments and trading, including spreads, mark-ups on securities, swaps and forwards, brokerage commissions (including options and futures trades), currency and other hedging costs, financing expenses in respect of a Fund’s use of derivatives and other similar costs and expenses, as well as research,

diligence (including travel), software and consulting services expenses, in each case relating to specific investments. Other Types of Fees or Expenses The applicable Client bears, directly or indirectly, the administrative and operational fees and expenses charged to the applicable Client, including (without limitation) management fees (as described above); investment-related expenses, such as exchange commissions and expenses, brokerage commissions, research expenses, data processing costs, bank service fees, interest expenses, borrowing charges, custodial fees, outsourced risk management advisory services and software, investment-related consultants, and research-related travel costs; administrative, legal, accounting, audit, record-keeping, tax preparation, compliance, and consulting costs and expenses; fees, costs, and expenses related to middle office operations, which may include daily reconciliation of cash, cost, positions, and valuations; fees and expenses of the administrator (including investor-related administrative services) and other third-party service providers; regulatory and compliance expenses directly related to the Client as well as filing fees and expenses (including governmental licensing, filing, and exemption fees, such as Blue Sky filing fees, and government and regulatory filings made in respect of the Client, such as Form PF preparation and filing expenses); an allocation of the cost of market research services (such as Bloomberg), databases, data feeds, and data stream subscriptions, and costs and expenses relating to the use of analytical tools and software, artificial intelligence, machine learning and large language model services and tools, and other computational, technical, and telecommunications services; fees, costs, and expenses relating to the development, licensing, maintenance, operation, support, enhancement, and use of SB-68; costs of preparing, printing, and mailing periodic reports and other investor communications; extraordinary expenses in connection with the ongoing offering of interests in the Fund, including the cost of printing and distributing offering and other marketing materials (including travel and other expenses paid to third-party vendors); marketing and syndication expenses; insurance costs and expenses (e.g., for the Client’s assets, directors’ and officers’ liability, and errors and omissions coverage); taxes and other governmental charges (other than taxes allocated to one or more, but not all, investors); organizational expenses; registered office fees and expenses; and other operating expenses. The applicable Client will bear any extraordinary expenses or costs that it may incur, including all judgments, settlements, fines, and expenses (including reasonable attorneys' fees) incurred in connection with any actual, anticipated, or threatened litigation or governmental inquiry, investigation, or proceeding (including any examination, audit, request for information, subpoena, or similar request from the U.S. Internal Revenue Service, the U.S. Securities and Exchange Commission, or any other local, state, federal, or foreign authority), and any indemnification obligations it may owe Birchview Partners, Birchview, or their respective affiliates or other parties. To the extent that an expense is shared among a Fund and other Client accounts of the Managers or Birchview, such expense will be allocated on a fair and equitable basis as determined by the Managers or Birchview, as applicable, in its sole discretion. The Managers and Birchview each bear the costs of providing its services to the Funds, including its own general overhead, salary and office expenses. Investors should refer to a Fund’s offering and governing documents or a Separately Managed Account’s investment management agreement (the “Constituent Documents”) for a full disclosure of costs and expenses that may be borne by the Clients.

Please also see “Item 12—Brokerage Practices” below. Different Economic Terms for Certain Investors From time to time, the Managers may permit certain Fund Investors (including, but not limited to, the Managers or Birchview, as well as the affiliates, principals, partners and employees of the Managers or Birchview and their respective families and any estate planning and/or other vehicles established by or on behalf of any of them) to acquire interests in a Fund on different economic terms than other Investors.

The Clients are focused on investing in companies that are underappreciated relative to their growth prospects and publicly traded companies. The companies of interest to the Clients are focused on improving overall health and the environment. Although the Funds may invest broadly across the healthcare sector, Birchview expects to emphasize those areas in which scientific complexity,

regulatory dynamics, product development milestones, and other company-specific or sectorspecific factors may create differentiated investment opportunities. The investment universe for certain Clients includes, without limitation, biotechnology, pharmaceuticals, life sciences tools and diagnostics, medical technology, healthcare services, healthcare information technology, and other healthcare-related businesses. Certain Clients generally seek to maintain a market-neutral posture, with the objective of limiting directional market exposure while seeking to capture relative value opportunities through long and short positions. In select cases, Birchview professionals may take a more active role with a portfolio company by working with management and the board of directors to increase shareholder value. To catalyze change, Birchview professionals may join the boards of directors of select portfolio companies or otherwise act in an advisory capacity with respect to such companies. The purpose of these activities is to help the company achieve its goals, which may in turn improve the likelihood of a positive return on a Client’s investment. Birchview plans to identify investment opportunities by leveraging industry contacts, analyzing scientific publications, attending industry-related conferences and visiting with management teams at company headquarters. Additionally, Birchview utilizes a proprietary quantitative platform to assist in investment research. The platform employs analytical and quantitative methods to help identify investment opportunities and evaluate potential investments. Because the above strategy can be applied to companies of various sizes, Birchview plans on investing across the entire market capitalization spectrum. The Clients may invest in public and private companies, depending on the applicable Client’s investment objective or investment mandate. Birchview may seek to achieve a Client’s objective by developing and deploying proprietary artificial intelligence (“AI”) systems and autonomous software agents designed to continuously discover, generate, validate, and execute a Client’s trading strategies. The specific algorithms, models, data sources, risk parameters, and portfolio construction techniques employed by the AI systems are proprietary and are expected to evolve over time based on continuous research, development, and adaptation. Birchview also uses Birchview’s proprietary quantitative research and trading platform, known as “SB-68” to seek to achieve a Client’s objective. For Clients pursuing the SB-68 strategy, SB-68 generates investment signals from fundamental, catalystrelated, alternative and technical data. Positions are generally initiated, sized and exited based on these signals, subject to portfolio-level constraints on net exposure, beta, sector and factor exposures, and position concentration, rather than on the price-target discipline described below. Birchview personnel oversee SB-68’s operation and may override, adjust or suspend model outputs. Diligence will be centered on evaluating a host of factors ranging from the underlying asset and intellectual property to the potential commercial opportunity. Research will be translated into a financial forecast, which will drive the valuation analysis and price targets. Birchview will make all investment decisions on behalf of the Clients, including through systems Birchview designs, deploys and supervises. Birchview intends to monitor each Client’s investments closely and seek to dispose of investments according to internal price targets. Generally, if the investment thesis with respect to a particular investment holding changes, Birchview would look to dispose of such investment as soon as practicable. If a position trades down but the investment thesis remains intact, Birchview may add to the position. If a price target is met, Birchview may attempt to dispose of the investment unless the price target is raised following a detailed analysis. Certain Clients have the ability to invest both long and short, and the above investing principles will be applied with respect to both strategies.

Birchview on behalf of the Clients may take an active role with respect to a portfolio company in cases where Birchview determines that doing so might (i) improve corporate governance, (ii) restructure management or the board of directors and/or (iii) further the development or commercialization of a product. In order to determine whether an opportunity for investment exists, Birchview may be required to sign confidentiality agreements with companies of interest, which may limit the Client’s ability to sell or buy securities of certain companies. In addition, service on the board of directors of a portfolio company by a Birchview professional would restrict trading by the Client in such company’s securities to certain windows of time. Generally, these windows are expected to be confirmed by such company’s general counsel or chief executive officer. Investing in underappreciated assets and/or helping to directly improve a company can require a longer investment time horizon. Thus, a Client may hold a security for an extended period of time. The Clients, at times, may be very concentrated. Although a Client expects to own a diverse array of companies, Birchview intends to focus its investment activities in particular sectors. Material Risks of Birchview’s Strategies Investing in securities involves risk of loss that Clients and Investors should be prepared to bear. The following is a summary of some of the material risks associated with the strategies expected to account for a significant portion of the Clients’ investments. This summary does not attempt to describe all of the risks associated with an investment with Birchview. Prospective Investors and Clients should read the entire Brochure as well as the Constituent Documents, other materials that may be provided by Birchview and consult with their own advisors prior to engaging Birchview’s services. Directional Investments. Certain Clients will generally take primarily long positions, but reserve the ability to invest short. In any case, all of the positions that will be taken by the Client will be designed to profit from forecasting absolute price movements in a particular instrument. Predicting future prices is inherently uncertain and the losses incurred, if the market moves against a position, might not be hedged. Accordingly, such losses may be greater than they would have been had they been hedged. The speculative aspect of attempting to predict absolute price movements is generally perceived to exceed that involved in attempting to predict relative price fluctuations. Leverage. The Clients may to a certain extent trade and invest on a leveraged basis through their borrowings and, to the extent that a Client trades derivatives, through the significant degree of leverage typically embedded in any such derivative instruments. Losses incurred on a Client’s leveraged investments will increase in direct proportion to the degree of leverage employed. The use of leverage may result in the forced liquidation of positions (which may otherwise have been profitable) as a result of margin or collateral calls. To the extent the assets of the Client have been leveraged through the borrowing of money, the purchase of securities on margin or otherwise, the interest expense and other costs and premiums incurred in relation thereto may not be recovered. If gains earned by the Client’s portfolio fail to cover such costs, the net asset value of the Client may decrease faster than if there had been no borrowings. Security Selection. If a Client invests only in publicly-traded equity securities, a primary risk of loss relates to Birchview’s security selection process. While Birchview endeavors to minimize such risk through portfolio construction and diversification requirements, there can be no guarantee that such measures will prevent losses.

Concentration of Investments. Birchview will attempt to spread the Client’s capital among a number of investments, if permitted by the Client’s Constituent Documents. However, the Client could hold a relatively small number of securities positions, each representing a relatively large portion of the Client’s capital, and may hold a large percentage of the Client’s capital in cash while awaiting better opportunities. With such concentration and lack of diversification, losses incurred in any such position may have a material adverse effect on the Client’s overall financial condition that might otherwise be mitigated if the Client had a more diversified portfolio. Material Non-Public Information. By reason of their responsibilities in connection with the Clients and other investment activities, including in connection with service as a director or officer of another company or discussions with a company’s management about a particular Client’s investment, Birchview personnel may acquire confidential or material, non-public information that would limit the ability of the Clients to initiate transactions in certain securities or sell certain investments. The Clients’ investment flexibility may be constrained due to Birchview’s inability to use such information for investment purposes. Insider Status. The acquisition by a Client of more than 10% of the equity securities of a public company or the service by any Birchview personnel as an executive officer or director of a company may subject the Client to liability for “short-swing profits” under Section 16(b) of the Securities Exchange Act of 1934 (the “Exchange Act”). If the Client engages in a transaction that results in short-swing profits, the Client may be required to return the amount of such profit to the issuer, which could adversely affect the overall return on investment realized by the Client. Measures to avoid short-swing liability may limit the ability of the Client to buy or sell securities of the portfolio companies. Public Disclosure. The Client is required under the Exchange Act to file disclosure with the SEC when it acquires 5% or more of a publicly traded equity security. If the Client takes an activist strategy or attempts a change of control with respect to such investments, it will be required to file more detailed disclosure in a Schedule 13D. Accordingly, in many instances, details of the Client’s activist strategy will become public. Public knowledge of such activity or the mere fact that the Client has acquired a stake in a company may influence market prices and limit the opportunity of the Client to purchase additional securities at lower prices. In addition, once the Client’s investment intent has changed to changing or influencing control of the issuer, the Client will be restricted for ten days from voting such securities or acquiring additional securities. Control Positions. Birchview personnel may serve as executive officers or directors of certain companies in which a Client invests. The exercise of control or influence over the management and policies of a company through the service of a Birchview officer or employee as an officer or director of such company could expose the assets of the Client to claims by the portfolio company, its security holders and creditors, or could impose additional risks of liability for environmental damage, product defects, failure to supervise management, violation of governmental regulations and other types of liability. Management Opposition. Birchview will seek constructively to work with management of certain of the Clients’ investments. There can be no assurance that the management of any company will agree or acquiesce to Birchview’s involvement in the affairs of the company, or that the strategies that the applicable Client hopes to implement will be effective. Portfolio companies may be hostile to the Client’s activities and may respond to the Client’s proposals by litigation or other defensive measures. Such measures may adversely affect the value of the Client’s investment and may result in high transaction expenses.

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As described in “Item 3 – Advisory Business” above, Birchview provides investment advice to the Funds and to Separately Managed Accounts. Birchview may in the future provide the same or similar services to other privately offered investment funds and/or separately managed accounts. Investment advice is provided directly to the Funds and not individually to the Investors of the Funds. Birchview intends to restrict the number of Investors in the Funds and will offer Interests only through non-public transactions in order to maintain the Funds’ exclusion from “investment company” status under the Investment Company Act of 1940, as amended (the “Investment Company Act”). Prospective investors in the Funds must be “accredited investors” as defined in Regulation D under the Securities Act and “qualified purchasers” as defined in Section 2(a)(51)(A) of the U.S. Investment Company Act of 1940, as amended. The prospective investors are subject to certain withdrawal requirements and limitations. Prospective Investors are encouraged to thoroughly review the applicable Constituent Documents which set forth all of the terms in detail. Though the Clients generally pursue the same strategy, offering terms may differ. Terms for Separately Managed Accounts are generally similar to the Funds, but can be negotiated on a case-by-case basis and may differ from those of the Funds.

As stated in “Item 5 – Fees and Compensation” above, Birchview generally receives an incentive allocation equal to a percentage of the net income allocated to each Investor for the year. Birchview may also receive similar incentive-based compensation with respect to Separately Managed Accounts. If, in the future, Birchview or an affiliate is entitled to performance-based fees from some clients but not others, Birchview may have an incentive to favor the account(s) that pay performancebased fees. Birchview will address this possible conflict of interest through its trade allocation and co-investment policy, in which investment opportunities are allocated among clients according to each client’s investment objectives and other relevant factors and in a fair and equitable manner.

Birchview is exempt from registration with the U.S. Commodity Futures Trading Commission (the “CFTC”) as a commodity trading advisor. Birchview Partners, an affiliate of Birchview, is exempt from registration with the CFTC as a commodity trading advisor and commodity pool operator. SB-68 Healthcare Partners, also an affiliate of Birchview, is exempt from registration with the CFTC as both a commodity trading advisor and commodity pool operator. As noted in Item 4 (Advisory Business) above, Birchview Partners and SB-68 Healthcare Partners, each an affiliate of Birchview serve as managers of certain Funds. Matthew W. Strobeck (previously defined as the Portfolio Manager) is the founder and Chief Executive Officer of Birchview Partners and the Chief Executive Officer of SB-68 Healthcare Partners. The Managers are responsible for the overall management of the applicable Funds’ business and operations, but have delegated investment management duties to Birchview. Any persons acting on behalf of the Managers are subject to the supervision and control of Birchview in connection with any investment advisory activities. In accordance with SEC guidance, Birchview Partners will be registered as an investment adviser in reliance on the Form ADV filed by Birchview. The Managers may also serve as the managers of other funds or accounts that invest in parallel with the Funds or in a master fund. Birchview, the Managers and their affiliates and personnel do not have relationships or arrangements with other financial services companies that pose material conflicts of interest. However, Birchview Partners also serves as the manager of Delta Properties, LLC, an investment vehicle owned by the Portfolio Manager which exclusively invests in real estate. For the avoidance of doubt, in association with its management of Delta Properties, LLC or otherwise, neither Birchview nor the Managers act as a real estate broker, dealer or agent.

Trading Code of Ethics As a fiduciary, Birchview owes an undivided duty of loyalty to its Clients and thus demands the highest standards of ethical conduct and care by all of its principals and employees (referred to herein as “supervised persons”). It is Birchview’s policy that all supervised persons conduct themselves so as to avoid, to the extent possible, not only actual conflicts of interest with Clients but any conduct that could give rise to the appearance of a conflict of interest that might compromise the trust placed in Birchview by its Clients. Birchview has adopted a Code of Ethics that sets forth standards of ethical and business conduct expected of Birchview’s supervised persons and addresses conflicts that may arise from personal trading by Birchview’s supervised persons. The Code of Ethics, among other things, requires compliance with the federal securities laws, reflects Birchview’s fiduciary responsibilities and those of its advisory personnel, prohibits certain personal securities transactions, requires Birchview’s supervised persons to periodically report and/or preclear certain personal securities transactions and addresses prevention of the misuse of material nonpublic information. The Code of Ethics will be provided to any Client or potential Client upon request. Personal Trading Birchview’s supervised persons are permitted to invest in their personal trading accounts, subject to certain restrictions, and may in certain circumstances invest in the same or related securities as Birchview recommends to the Clients, including doing so at or about the same time as a Client’s transaction is effected. In order to reduce certain conflicts of interest that may arise between client accounts and the personal trading activities of Birchview’s supervised persons, Birchview has adopted a personal trading policy (contained in the Code of Ethics). The personal trading policy, among other things, requires preclearance of certain transactions and reporting of all transactions in and holdings of “reportable securities.” The Portfolio Manager made a personal in-kind capital contribution to the Birchview Fund of the Initial Portfolio in connection with the commencement of the Birchview Fund’s operations. However, the Portfolio Manager and/or certain of his affiliates or family members intend to maintain and manage significant personal investment holdings outside of the Birchview Fund that may differ from the type of investments made by the Birchview Fund. In addition, such investments may also overlap with the Birchview Fund’s investments. The Portfolio Manager’s interest in any such investments may give rise to conflicts of interest in his management of the Birchview Fund. Principal Transactions and Cross Trades Birchview and its affiliates may enter into “principal transactions” with the Funds or other Clients within the meaning of Section 206(3) of the Advisers Act. Any principal transactions must meet the client disclosure and consent requirements of Section 206(3). Principal transactions between any Client and Birchview, the Managers or their respective affiliates must be approved by a majority in interest of the Investors. Birchview may also engage a conflicts advisory representative or other investor representative with the consent of a majority in interest of the Investors. Such a

representative will be authorized to consent to any principal transactions and any other conflicts presented to it by Birchview. When advising multiple accounts, Birchview may effect “cross” transactions between Client accounts when appropriate, for example, for purposes of rebalancing transactions, if permitted by applicable law. In a “cross” transaction, one Client account will purchase securities held by another Client account. Birchview will only effect these transactions: (i) when it deems the transaction to be in the best interests of both accounts; and (ii) at a price and under circumstances that it has determined by reference to independent market indicators, or other factors which it believes to constitute “best execution” for both accounts.

Best Execution Birchview has the authority to determine the broker-dealers to be used to effect the Clients’ securities transactions and the commission rates to be paid in connection with the Clients’ securities transactions. Birchview selects broker-dealers in accordance with its obligation to seek best execution. In choosing broker-dealers, Birchview is not required to consider any particular criteria. Birchview generally seeks the best combination of brokerage cost and execution quality. However, Birchview is not required to select the broker-dealer that charges the lowest transaction cost, even if that broker-dealer provides execution quality comparable to other broker-dealers. Birchview takes into account all factors that it considers to be relevant, including, for example, price; the size of the transaction; the nature of the market of the security; the amount of the commission; the timing and impact of the transaction, taking into account market prices and trends; the reputation, experience and financial stability of the broker-dealer; the willingness of the brokerdealer to commit capital; the need for anonymity in the market; the quality of the services rendered by the broker-dealer in other transactions; and the type and quality of the research provided by the broker-dealer. Birchview does not consider, in selecting or recommending broker-dealers, whether it receives investor referrals from a broker-dealer or third party. Soft Dollar Benefits In taking into account all relevant factors in selecting broker-dealers, Birchview may consider the value of research or other products or services other than execution that a broker-dealer may provide to Birchview in connection with securities transactions on behalf of its Clients. Currently, Birchview intends to use soft dollars within the “safe harbor” provided by Section 28(e) of the Exchange Act. The use of brokerage commissions to obtain research services creates a conflict of interest between Birchview and Clients. This may result in Clients paying higher brokerage commissions than might be paid if transactions were effected through brokers that do not provide such services. To the extent that Birchview is able to acquire these products and services without expending its own resources or at reduced prices, Birchview’s use of “soft dollars” would tend to increase their profitability. In addition, the availability of these non-monetary benefits may influence Birchview to select one broker rather than another to perform services for the Clients. All soft dollar arrangements are within the “safe harbor” provided by Section 28(e) of the Exchange Act.

Allocation of Investment Opportunities As a fiduciary, Birchview must allocate investment opportunities among its Clients in a fair and equitable manner. To the extent Birchview provides services for multiple Clients, it will seek to allocate orders and investment opportunities in accordance with its allocation and co-investment procedures. These procedures are designed to help assure that investment opportunities are allocated in a manner that is fair and equitable to each Client and that no Client is improperly favored over any other Client or account. Although such allocations may be pro rata as to the participating entities and Clients, they will not necessarily be so, where Birchview’s allocation policies (e.g., differing objectives or other considerations) dictate a different result. Allocation decisions will be made in consideration of a variety of factors, including, but not limited to, the investment objective, investment guidelines and restrictions, current portfolio holdings, concentration and liquidity considerations, legal restrictions and relative account size applicable to each Client. Birchview also may consider such factors as whether a Client is actively receiving additional investments, is subject to withdrawal requests or is being liquidated, as well as minimum denominations and round lot considerations. Not all factors may be relevant in connection with every investment. In cases where a limited amount of an instrument is available for purchase, the allocation of such instrument among more than one Client may necessarily reduce the amount available for purchase by any one Client. There can be no assurance that a particular order or investment opportunity will be allocated in a particular manner. If conflicts arise in the allocation of investment opportunities, Birchview will seek to resolve such conflicts fairly. The foregoing policy does not require that each opportunity be made available to all accounts, leaving significant discretion to Birchview. For example, accounts may have different objectives, so that the same transaction would not necessarily be made available to all accounts. Trade Aggregation Birchview may, but is not required to, aggregate purchases and sales of the same security for more than one Client if doing so would be in the interest of each participating Client and consistent with Birchview’s duty to seek best execution. The aggregated order must be allocated in a fair and equitable manner across participating accounts, considering the factors discussed above. Each Client that participates in an aggregated order will participate at the average price for all of Birchview’s transactions in that security on a given business day, with transaction costs shared pro rata. Separately Managed Accounts may not always trade in conjunction with the Funds. Trading Errors Policies with respect to Trade and Administrative Errors (as defined below) may vary for different Clients. With respect to the Funds , Birchview is under no obligation to reimburse a Fund for any errors of Birchview with respect to Birchview’s placing or executing trades for a Fund or any other administrative errors made by Birchview, its agents and affiliates (“Trade and Administrative Errors”). Trade and Administrative Errors are considered by Birchview to be a cost

of doing business. However, pursuant to the indemnification provisions set forth in the applicable Constituent Documents, Birchview will be obligated to reimburse the applicable Fund for any Trade and Administrative Errors resulting from Birchview’s willful misconduct or gross negligence. Any correction of a Trade and Administrative Error will only be made to the extent required so that the applicable Fund does not incur a loss related to such Trade and Administrative Error. Birchview, subject to its fiduciary obligations, will determine whether or not any Trade and Administrative Errors are required to be reimbursed in accordance with such indemnification provisions. Birchview has an inherent conflict of interest with respect to the discovery and treatment of Trade and Administrative Errors. Birchview, in its sole discretion, reserves the right to reimburse a Fund for any Trade and Administrative Error. Birchview’s reimbursement of a Fund for any particular Trade and Administrative Error will not constitute a waiver of any policy to cause a Fund to bear the losses from other Trade and Administrative Errors. Any net gain resulting from Trade and Administrative Errors will be for the benefit of the applicable Fund and will not be retained by Birchview.

Birchview and its affiliates may compensate third parties for Client referrals. Placement agents may be compensated with selling commissions (which will be disclosed to the applicable Investor subject to such selling commissions) and/or by Birchview and/or the Managers through sharing of a portion of their management fees and/or incentive allocations, respectively.

Birchview has no legal or disciplinary events to report that would be material to a Client’s or prospective Client’s evaluation of Birchview’s advisory business or the integrity of its management.

Review of Accounts Birchview will review, as pertinent, Client portfolio holdings to determine that the investments held by the Client remain consistent with the pertinent Client documentation and will generally review each Client’s performance on an ongoing basis. Reports to Clients The Funds will generally make available to Investors monthly unaudited account statements and reports via a website, with hard copies available on request. The Funds will generally provide audited annual financial statements prepared in accordance with generally accepted accounting principles (“GAAP”). Birchview, the Managers, the Portfolio Manager and their employees, family members and affiliates, as applicable, may have access to information that is not generally available to other Investors of the Funds and, as a result, may be able to act on such additional information (e.g., request withdrawals) that other Investors do not receive. Other Clients will receive reports as agreed upon in the pertinent investment management or other agreement.

Although Birchview does not physically hold the securities and other assets of the Funds, Birchview is deemed to have custody of the Funds’ assets, since Birchview and/or its related

persons serve as the manager for one or more of the Funds. Investors do not receive account statements from any custodians; rather, the Funds are subject to an annual audit and the audited financial statements are distributed to each Investor. In the event Birchview has custody of the assets of any Client that is not a pooled investment vehicle (e.g., a Separately Managed Account), Birchview will arrange for a qualified custodian to send quarterly account statements directly to the Client and arrange for an annual surprise examination pursuant to Rule 206(4)-2 under the Advisers Act. The Client should carefully review these statements. Any Client that also receives account statements from Birchview should compare those account statements with the account statements received from the qualified custodian.

Birchview provides discretionary investment advisory services to the Clients, subject to the Clients’ investment objectives, strategies and policies. Birchview has full discretion in all investment and trading decisions made on behalf of the Clients. Such discretionary authority is granted to Birchview in the applicable Constituent Documents.

Birchview may have voting authority and responsibility with respect to securities held by the Clients. In voting proxies, Birchview is guided by general fiduciary principles and votes in the manner it believes is consistent with efforts to achieve a Client’s stated investment objectives. Birchview’s general policy is to vote in accordance with the recommendation of an issuer’s management on routine and administrative matters, unless Birchview has a particular reason to vote to the contrary. This general policy is not a predetermination, however, to vote in favor of the issuer’s management, as Birchview will review all Client proxies in accordance with the general fiduciary principles noted above. With respect to non-recurring or extraordinary matters, Birchview will vote on a case-by-case basis in accordance with the goals of achieving a Client’s stated objectives. Birchview retains the discretion to take no action with respect to a proposed vote if it determines that doing so is in the best interests of a Client (for example, where Birchview determines that the cost of voting exceeds the expected benefit to the Client). Birchview follows procedures designed to identify conflicts or potential conflicts that could arise between its own interests and those of its Clients. If it is determined that any such conflict or potential conflict is not material, Birchview may vote proxies notwithstanding the existence of the conflict. If it is determined, however, that a conflict of interest or potential conflict of interest is material, one or more methods may be used to resolve the conflict, including (i) engaging a third party to recommend a vote with respect to the proxy, (ii) disclosing the conflict to the Client and obtaining its consent before voting or (iii) such other method as is deemed appropriate under the circumstances. Clients and Investors may request a copy of Birchview’s proxy voting policy, as well as applicable proxy voting records, by contacting Birchview.

Birchview is not aware of any financial condition reasonably likely to impair its ability to meet contractual commitments to its Clients, and Birchview has not been the subject of a bankruptcy petition.