Boundary Creek Advisors LP

A. Describe your advisory firm, including how long you have been in business. Identify your principal owner(s). Boundary Creek is organized as a Delaware limited partnership and is an investment adviser registered with the SEC. The firm has been in business since 2019. As of December 31, 2025, Boundary Creek has 4 employees located in New York and London. Peter Greatrex serves as the Chief Executive Officer and Chief Investment Officer of Boundary Creek. Mr. Greatrex is the principal owner of Boundary Creek and controls Boundary Creek Partners LLC, the general partner of Boundary Creek. Boundary Creek has approximately $44,799,299 in regulatory assets under management. 1 Boundary Creek serves as an investment adviser to pooled investment vehicles (“Fund Clients” or “Advisory Clients”) that are primarily domestic and foreign limited partnerships, and foreign companies. Boundary Creek provides investment management and supervisory services to its Advisory Clients on a discretionary basis. Boundary Creek may establish additional Advisory Clients in the future. Investments by Fund Clients typically are made through a master-feeder structure, with an affiliate of Boundary Creek serving as general partner of Fund Clients organized as limited partnerships, and Boundary Creek serving as investment adviser to both the Fund Client that invests through the master fund and the master fund itself. Advisory Clients are generally not registered under the Securities Act of 1933, as amended, nor registered under the Investment Company Act of 1940, as amended. Accordingly, interests in such Advisory Clients are offered exclusively to investors satisfying the applicable eligibility and suitability requirements either in private placement transactions within the United States or in offshore transactions. The descriptions in this Brochure do not constitute an offer to sell interests in these Advisory Clients. Please see Item 7 of this Brochure for more information with respect to Boundary Creek’s clients.

B. Describe the types of advisory services you offer. If you hold yourself out as specializing in a particular type of advisory service, such as financial planning, quantitative analysis, or market timing, explain the nature of that service in greater detail. If you provide investment advice only with respect to limited types of investments, explain the type of investment advice you offer, and disclose that your advice is limited to those types of investments. Boundary Creek generally has broad and flexible investment authority with respect to the investment portfolios that it manages for its Advisory Clients. Boundary Creeks provides investment advisory services to its Advisory Clients with respect to investments in a broad array of instruments, among them bonds of investment and non-investment grade credits, government and municipal bonds, loans (both syndicated and privately traded, including private non-recourse loans supported by publicly traded collateral or project financings), credit derivatives (including credit default swaps and loan total return swaps), public equities (including “new issues” as described, and subject to the limitations set forth, in Rules 5130 and 5131 of the Financial Industry Regulatory Authority), convertible bonds and other assetbacked securities and asset-backed financing arrangements, collateralized debt obligations, collateralized loan obligations, insurance-linked securities, financing trades, margin loans, repurchase agreements, reverse repurchase agreements, private and post-reorganization equities, real estate-related assets, privately negotiated investments, equity derivatives, mortgages, futures, commodities interest rate derivatives (including swaps and swaptions), and spot and forward foreign currency contracts. Credit and equity derivatives relate either to individual reference entities or to baskets or portfolios of reference entities (including levered or de-levered tranches of such portfolios or baskets).

Calculated as of December 31, 2025.

Boundary Creek provides such advisory services on a discretionary basis. C. Explain whether (and, if so, how) you tailor your advisory services to the individual needs of clients. Explain whether clients may impose restrictions on investing in certain securities or types of securities. The advisory services provided by Boundary Creek to its Advisory Clients are tailored to the investment objectives, investment strategy and investment restrictions, if any, as set forth in the governing documents of Advisory Clients and/or the investment management agreement entered into by Boundary Creek with such clients. With respect to Fund Clients, except as noted below, Boundary Creek typically does not tailor its advisory services to the individual needs of investors in the Fund Client; accordingly, it typically does not accept material investment restrictions imposed by such Fund Client investors. Certain agreements with one or more investors (“Side Letters”) permit the excuse and/or exclusion of a particular investor from participating in a particular investment in certain limited circumstances, but Boundary Creek generally does not otherwise accept investment restrictions imposed by Fund Client investors. Advisory Clients have entered into and may in the future enter into, subject to applicable law, rule and regulation, Side Letters with one or more of its investors whereby in consideration for agreeing to invest certain amounts in an Advisory Client and/or other consideration deemed sufficiently material, such investors may be granted favorable rights not afforded other investors in such Advisory Client. Such rights may include one or more of the following: rights to receive reports from the Advisory Client on a more frequent basis or that include information not typically provided to other investors that Boundary Creek believes are not prejudicial to other investors; ability to transfer to affiliates or other parties; reduced rates of performance fees/allocations and/or management fees earned by Boundary Creek, each Advisory Client’s general partner and/or other affiliates; application of a restricted securities list; and such other rights as are negotiated between the Advisory Client, Boundary Creek and such investors. Such agreements may be entered into by the Advisory Client and Boundary Creek without the consent of other investors in such Advisory Client; additionally, except as may be required by “most-favorednations” clauses, such agreements usually need not be disclosed to other investors in such Advisory Client. D. If you participate in wrap fee programs by providing portfolio management services, (1) describe the differences, if any, between how you manage wrap fee accounts and how you manage other accounts, and (2) explain that you receive a portion of the wrap fee for your services. Boundary Creek does not participate in “wrap fee arrangements,” whereby clients select Boundary Creek to manage funds through an investment program presented to the clients by a third-party program sponsor. E. If you manage client assets, disclose the amount of client assets you manage on a discretionary basis and the amount of client assets you manage on a non-discretionary basis. Disclose the date “as of” which you calculated the amounts. As of December 31, 2025, Boundary Creek has approximately $49,799,299 in regulatory assets under management which are managed on a discretionary basis.

A. Describe how you are compensated for your advisory services. Provide your fee schedule. Disclose whether the fees are negotiable. Fund Clients generally pay an asset-based management fee, which ranges from 1.0% to 1.75% per annum of the net assets of the Fund Client. Management fees are typically charged and paid, in advance or arrears, as described in the investment management agreement between such Advisory Client and Boundary Creek, on (i) a monthly basis for open-ended Fund Clients and (ii) a quarterly basis for closedended Fund Clients. Management fees are applied pro rata to each investor’s interests in the respective Fund Client. For those Fund Clients that are part of a master-feeder structure, the management fee is typically paid to Boundary Creek by the respective master fund on behalf of the feeder funds. In addition, Boundary Creek (or affiliates of Boundary Creek acting as special limited partners, general partners or managing members of the Fund Clients) receives performance compensation in the form of incentive allocations or carried interest from Fund Clients. With respect to open-ended Fund Clients, performance compensation generally ranges from 15%-30% of net profits allocated to each investor on an annual basis and is payable at the end of each year or upon a redemption by an investor; provided that with respect to certain Fund Clients, performance compensation is payable only if and to the extent that a certain minimum rate of return (a “hurdle”) is exceeded. In certain cases, performance compensation is reduced by the amount of management fees paid over a specified period. Performance compensation is generally subject to a “high water mark” or loss carry forward provisions. With respect to closed-ended Fund Clients, performance compensation is payable after Fund Clients have made distributions to an investor in the fund that exceed the capital contributed by such investor and a hurdle rate of return on unreturned capital contributions. Boundary Creek (or affiliates of Boundary Creek acting as special limited partners, general partners or managing members of the Fund Clients) generally receive performance compensation equal to 20% of any additional distributions. See Item 6 for further information with respect to performance compensation. Depending on the characteristics of the Advisory Client, fees may be higher or lower and may be subject to various reductions and offsets, in each case, as set forth in each Advisory Client’s offering documents. Boundary Creek, reserves the right to waive, reduce or calculate differently management fees and/or performance compensation payable by certain investors in Advisory Clients, including any employee or affiliate of Boundary Creek, any family member thereof, or trusts, estate planning and other investment accounts and/or vehicles established by or for the benefit of such persons. As explained above in Item 4, Boundary Creek enters into Side Letters with certain investors in Fund Clients, typically those with the largest aggregate investments in Fund Clients, whereby such investors are granted favorable rights not granted to other investors in the Fund Client including, among other things, rights to receive reduced or different rates of management fees and/or performance compensation. Except as described in the preceding paragraph, the management fee and performance compensation for Fund Clients are generally not negotiable. To calculate advisory fees, Boundary Creek generally relies on prices provided by third parties (whether third-party data feeds or dealer quotes) for purposes of valuing portfolio securities held by Advisory Clients. Advisory Clients’ third-party administrator (the “Administrator”) verifies the third-party values that Boundary Creek receives. In the event of a disagreement between Boundary Creek and the Administrator, Boundary Creek works with the Administrator to investigate and resolve any differences. Although it is extremely rare for discrepancies to persist after an investigation by Boundary Creek and the Administrator, in the event that Boundary Creek and the Administrator ultimately disagree on the valuation of a position, the Administrator can withhold approval of the net asset value if it is unsatisfied with the valuation. Boundary Creek maintains policies and procedures relating to the pricing process.

Except to the extent that better performance increases assets under management and thus the amount of the management fee (in cases where the management fee is calculated with respect to assets under management), management fees are payable without regard to the overall success or income earned by Advisory Clients and therefore may create an incentive on the part of Boundary Creek to increase assets under management to a higher level than would be the case if Boundary Creek were receiving a lower or no management fee. Boundary Creek and its affiliates have entered into an agreement with a strategic investor who has made substantial investments in Advisory Clients. The terms of the agreement provide for reduced management fee and performance compensation rates and for the right for the strategic investor to receive special allocations based on a percentage of the management fees and performance compensation allocable to Boundary Creek and its affiliates. Other fees payable by investors in Advisory Clients are described below. Advisory Client investors and prospective investors in Advisory Clients should refer to the offering documents or governing documents of the respective Advisory Client for detailed information with respect to the fees associated with such Advisory Client. The information contained herein is a summary only and is qualified in its entirety by such documents. B. Describe whether you deduct fees from clients’ assets or bill clients for fees incurred. If clients may select either method, disclose this fact. Explain how often you bill clients or deduct your fees. Depending on the Advisory Client and the authority granted to Boundary Creek, Boundary Creek will deduct fees (or direct the payment of fees) from Advisory Clients’ assets. Management fees are generally paid by Advisory Clients to Boundary Creek (or an affiliate), pursuant to a management agreement between the parties. Performance compensation is generally paid by Advisory Clients to Boundary Creek, or an affiliate of Boundary Creek, pursuant to the governing documents of the Advisory Client, or paid directly out of Advisory Client assets to Boundary Creek pursuant to a management agreement between the parties. Management fees are generally paid by Advisory Clients monthly or quarterly in arrears or in advance. Performance compensation is generally payable at the end of each year or other pre-defined period, at the time distributions are made to an investor and/or at the time an investor withdraws or redeems, as the case may be, from an Advisory Client, in each case, as set forth in the governing fund documents of Advisory Clients. Management fees and performance compensation may be (and have been) waived or modified in the sole discretion of Boundary Creek and/or its affiliates, as applicable, including for investors who are affiliated with Boundary Creek. Advisory Client investors and prospective investors in Advisory Clients should refer to the private placement memorandum or other offering documents of the respective Advisory Client for detailed information with respect to how fees are paid with respect to their assets. The information contained herein is a summary only and is qualified in its entirety by such documents. C. Describe any other types of fees or expenses clients may pay in connection with your advisory services, such as custodian fees or mutual fund expenses. Disclose that clients will incur brokerage and other transaction costs, and direct clients to the section(s) of your brochure that discuss brokerage. In addition to paying management fees and performance compensation, Advisory Clients are also subject to other expenses, including, without limitation Advisory Clients’ own organizational (which generally

are amortized over a period of time), operating and other expenses including, without limitation: (a) expenses associated with all investments and transactions considered, evaluated and/or consummated by the Advisory Clients, including, without limitation, those expenses incurred before the initial closing of the Advisory Clients, including, without limitation, expenses associated with sourcing, negotiating, investigating, researching, financing, structuring and restructuring of investments and potential investments, whether or not consummated, including, without limitation, third-party research, data, analytics, modeling, structuring, pricing, execution and other third-party information systems, software and service fees (including, without limitation, the expenses with respect to data feeds, subscriptions, expert networks, political intelligence providers, and reports); (b) research-related computer hardware and software expenses, including, without limitation, Bloomberg terminals; (c) the Advisory Clients’ pro rata share of the Boundary Creek’s order management system, portfolio management system and any other software used for accounting and/or monitoring of the portfolio; (d) expenses associated with holding, financing, monitoring, hedging, maintaining and disposing of all investments of the Advisory Clients and all transaction and other costs associated therewith, including management fees and/or performance compensation payable to third parties in connection with holding certain investments (e.g. ETFs, registered investment companies, CLOs and other securitizations); (e) travel and related expenses associated with investments and potential investments; (f) professional fees associated with investments and potential investments, including, without limitation, consulting, due diligence, accounting, valuation, financial, legal, and other advisory fees and expenses; (g) transaction fees, brokerage commissions, custodial fees, brokerage and bank service fees, clearing and settlement charges, transaction taxes, oddlot differentials, transfer taxes, wire transfer and electronic fund fees, and similar fees and expenses associated with the acquisition, holding, disposition and settling of investments and potential investments; (h) expenses associated with legal and regulatory filings of the Advisory Clients (including, without limitation, pursuant to Section 13 and 16 of the Securities and Exchange Act of 1934, as amended and the Advisory Clients’ pro rata portion of the expenses associated with preparation of the Boundary Creek’s Form 13F, Form 13H and Form PF, Form PQR, Form PR, Form N-PX, Annex IV, MIFID and UK MIFID reporting and any other similar filing in any other U.S. or non-U.S. jurisdiction; (i) administrative, custodial, appraisal, valuation, legal, regulatory, compliance, consulting, advisory and similar fees and expenses associated with the Advisory Clients’ operations, investments and transactions, including, without limitation, fees and expenses of the Advisory Clients’ administrator; (j) expenses incurred in connection with responding to requests or inquiries from any U.S. federal, state, local or nonU.S. governmental entity or authority, regulatory body or self-regulatory organization and all extraordinary expenses; (k) broken-deal, failed transaction, break-up and similar fees, costs and expenses, if any; (l) costs and expenses of leverage or any other borrowings of the Advisory Clients, including, without limitation, prime brokerage financing costs, interest charges and fees; (m) expenses incurred in the collection of monies owed to the Advisory Clients, as applicable; (n) auditing and accounting expenses of the Advisory Clients, including, without limitation, expenses associated with the preparation of financial statements, tax returns and reporting, Schedules K-1 and the fees and expenses of the auditor; (o) any entity-level taxes, fees or other governmental charges on the Advisory Clients, including, without limitation, any withholding taxes not due to the noncompliance of a particular Investor; (p) costs and expenses associated with investor communications and reports and the delivery thereof to investors; (q) the costs of service providers or software to measure or monitor risk metrics, to aggregate positions and/or to provide reporting with respect to risk metrics and/or positions; (q) insurance expenses; including, without limitation, directors’ and officers’ liability insurance, general partner liability insurance, errors and omissions insurance and other policies for the benefit of Fund Clients’ directors and general partners, Boundary Creek and its affiliates; (r) costs and expenses (including, without limitation, entity-level taxes, fees or other governmental charges) associated with the formation, organization and operation of any subsidiary, special purpose vehicle, alternative investment vehicle, holding company, or similar entity formed with respect to investments, credit facilities or other transactions entered into for the benefit of the Advisory Clients; (s) wind-up, liquidation, termination and dissolution expenses; (t) costs, fees and expenses related to registration, qualification and/or exemption under any applicable U.S. federal, state, local or non-U.S. laws, rules or regulations, including, without limitation, blue sky fees, Form D, Form 8.3, Commodity Futures Trading Commission filings and notices and other securities

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Fixed Income Obligations An Advisory Client’s investments in fixed income obligations are subject to the risk of an issuer’s ability to meet principal and interest payments on the obligation (credit risk) and may also be subject to price volatility due to such factors as interest rate sensitivity, market perception of the creditworthiness of the issuer and general market liquidity (market risk). Changes in interest rates may cause a decline in the market value of an investment. With bonds and other fixed income securities, a rise in interest rates

typically causes a fall in values, while a fall in interest rates typically causes a rise in values. Bonds and other fixed income securities generally involve less market risk than stocks. However, the risk of bonds can vary significantly depending upon factors such as the issuer and maturity. For example, the issuer of a security or the counterparty to a contract may default or otherwise become unable to honor a financial obligation. The bonds of some companies may be riskier than the stocks of others. Foreign Securities Advisory Clients invest in securities and other instruments of foreign corporations and foreign countries. Investing in such securities involves certain considerations not usually associated with investing in securities of U.S. companies or the U.S. government, including, among other things: political and economic considerations, such as greater risks of expropriation, nationalization and general social, political and economic instability; the smaller size of the securities markets in such countries and the lower volume of trading, resulting in potential lack of liquidity and in price volatility; fluctuations in the rate of exchange between currencies and costs associated with currency conversion; imposition of withholdings and other taxes; and certain government policies that may restrict the Advisory Client’s investment opportunities. In addition, accounting and financial reporting standards that prevail in many foreign countries are not equivalent to U.S. standards and, consequently, less information may be available to investors in companies located in foreign countries than is available to investors in companies located in the U.S. There is also less regulation, generally, of the securities markets in many foreign countries, even developed countries, than in the U.S. Collateralized Loan Obligations Advisory Clients invest in collateralized loan obligations (“CLO Investments”) through purchases in the primary or the secondary market. The CLO Investments into which Advisory Clients invest are principally collateralized by senior secured assets. CLO Investments are subject to various risks including the following credit, liquidity, interest rate and other risks. Advisory Clients’ investment in CLOs involves significant leverage, which could result in a substantial loss to the investor in the CLO. The value of the CLO Investments owned by Advisory Clients generally will fluctuate with, among other things, the financial condition of the obligors or issuers of the underlying portfolio of assets of the related CLO (“CLO Collateral”), market conditions, general economic conditions, the condition of certain financial markets, political events, developments or trends in any particular industry and changes in prevailing interest rates. Under certain circumstances, cash flows from CLO Collateral that otherwise would have been paid to the holders of its mezzanine CLO debt and the related CLO equity will be used to redeem the related CLO senior tranches. This could result in an elimination, deferral or reduction in the interest payments, principal repayments or other payments made to the holders of such CLO debt, which are the CLO Investments in which Advisory Clients will invest, which could adversely impact the returns to Advisory Clients. An optional redemption by a CLO of its notes could require the collateral or portfolio manager of the related CLO to liquidate positions more rapidly than would otherwise be desirable, which could adversely affect the realized value of the items of CLO Collateral sold (and which in turn could adversely impact the holders of any related CLO equity securities, including Advisory Clients). The prices of the CLO Collateral are highly volatile. Price movements are influenced by, among other things: changing supply and demand relationships; trade, fiscal, monetary and exchange control programs and policies of governments; U.S. and foreign political events and policies; changes in national and/or international interest rates and rates of inflation; currency devaluations and revaluations, and market sentiments. Structured Credit Products Advisory Clients invest in structured credit products, including, collateralized debt obligations, synthetic credit portfolio transactions and asset- and mortgage-backed securities. Interest and principal payments of structured credit products are derived from underlying assets and receivables, and there can be no assurance as to the timing and amount of such payments. Synthetic portfolio transactions may be

structured with two or more classes of tranches that receive different proportions of the interest and principal distributions on a pool of credit assets. The yield to maturity of a tranche may be extremely sensitive to the rate of defaults in the underlying reference portfolio. A rapid change in the rate of defaults may have a material adverse effect on the yield to maturity. It is therefore possible that Advisory Clients may incur losses on its investments in structured products regardless of their ratings by S&P or Moody’s. Additionally, structured credit products are typically subject to legal or contractual restrictions on their resale and there is often a relatively inactive trading market. Securities subject to resale restrictions may sell at a price lower than similar securities that are not subject to such restrictions. The governing documents for structured credit products may establish highly complex structures, with payments allocated according to complicated procedures to various classes of securities and with varying forms of credit enhancement. There is a risk that such governing documents may contain ambiguous terms, which may delay receipt of payments. Certain structured credit products are subject to interest rate mismatches, if liabilities are fixed-rate and receivables bear interest at a floating rate, or vice versa. Further structured credit products are subject to credit risk. Advisory Clients may invest insubordinate classes of structured credit products, which classes will be allocated losses prior to more senior classes and which may allow for the deferral of certain payments. Further, as a result of investing in structured credit products, investors in Advisory Clients may incur a duplication of fees and commissions (such as additional management fees, servicing fees, performance fees and all other custody and transaction fees, central administration fees and audit fees payable by investors in structured credit products). Convertible Securities Advisory Clients invest in convertible securities. Convertible securities provide higher yields than the underlying equity securities, but generally offer lower yields than non-convertible securities of similar quality. The value of convertible securities fluctuates, as do bonds, in relation to changes in interest rates and, in addition, fluctuates in relation to the underlying common stock. Derivatives Advisory Clients invest in derivative financial instruments. Derivative financial instruments include futures, options, interest rate swaps, forward currency contracts and credit derivatives such as credit default swaps. In addition, Advisory Clients from time-to-time utilize both exchange-traded and over-thecounter futures, options and contracts for differences, as part of its investment strategy and for hedging purposes, as well as other derivatives. Regulatory restraints may restrict the instruments that an Advisory Client may trade. Such derivative instruments are highly volatile, involve certain special risks and expose investors to a high risk of loss. The low initial margin deposits normally required to establish a position in such instruments permit a high degree of leverage. As a result, a relatively small movement in the price of a contract may result in a profit or a loss which is high in proportion to the amount of funds actually placed as initial margin and may result in unquantifiable further losses exceeding any margin deposited. Further, when used for hedging purposes there may be an imperfect correlation between these instruments and the investments or market sectors being hedged. The trading of over-the-counter derivatives subjects an Advisory Client to a variety of risks including: (i) counterparty risk, (ii) basis risk, (iii) interest rate risk, (iv) settlement risk, (v) legal risk, and (vi) operational risk. Counterparty risk is the risk that one of an Advisory Client’s counterparties might default on its obligation to pay or perform generally on its obligations. Basis risk is the risk that the normal relationship between two prices might move in opposite directions. Interest rate risk is the general risk associated with movements in interest rates. Settlement risk is the risk that a settlement in a transfer system does not take place as expected. Legal risk is the risk that a transaction proves unenforceable in law or because it has been inadequately documented. Operational risk is the risk of unexpected losses arising from deficiencies in a firm’s management information, support and control systems and procedures. Transactions in over-the-counter derivatives may involve other risks as well, as there is no exchange market on which to close out an open position. It may be impossible to liquidate an existing

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Describe the types of clients to whom you generally provide investment advice, such as individuals, trusts, investment companies, or pension plans. If you have any requirements for opening or maintaining an account, such as a minimum account size, disclose the requirements. Types of Clients Boundary Creek provides investment advisory services to pooled investment vehicles operating as private investment funds. Conditions for Managing Accounts The minimum initial investment amount for investors in Fund Clients is generally at least $5,000,000. These requirements generally can be waived at the discretion of the general partner or the board of directors of the Advisory Client, or their respective delegees, subject to any statutory or regulatory minimum requirements.

Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss A. Describe the methods of analysis and investment strategies you use in formulating investment advice or managing assets. Explain that investing in securities involves risk of loss that clients should be prepared to bear. The investment objective of the Advisory Clients is to seek to generate high, risk-adjusted absolute returns, with limited correlation to traditional fixed income and equity portfolios, by investing in or shorting securities, loans and other obligations. Boundary Creek employs a number of fundamentally- and technically-driven investment strategies to make investment decisions on behalf of Advisory Clients, including fundamental long/short, new issues, cross-currency, basis, curve, capital structure and crossasset strategies. Boundary Creek has complete discretion to select and allocate capital among investment strategies and may cause Advisory Clients to invest in additional investment strategies not listed above in or cease investing in investment strategies its own discretion. Advisory Clients will trade in a broad range of listed and unlisted instruments, whether publicly or privately offered, including, but not limited to, corporate bonds of investment and non-investment grade credits, government and municipal bonds, loans (both publicly and privately traded, including private nonrecourse loans supported by publicly traded collateral or project financings), credit derivatives (including credit default swaps and loan total return swaps), public equities (including “new issues” as described, and subject to the limitations set forth, in Rules 5130 and 5131 of the Financial Industry Regulatory Authority), preferred equities, exchange-traded funds, exchange-traded notes, equity derivatives, options, warrants, futures, convertible bonds and other asset-backed securities and asset-backed financing arrangements, collateralized debt obligations, collateralized loan obligations, insurance-linked securities, financing trades, margin loans, repurchase agreements, reverse repurchase agreements, private and postreorganization equities, REITs, real estate-related assets, privately negotiated investments, mortgages, commodities, futures, interest rate derivatives (including swaps and swaptions), spot and forward foreign currency contracts, other government securities and all other forms of investment, financial and commercial agreements, contracts and undertakings. Credit and equity derivatives relate either to individual reference entities or to baskets or portfolios of reference entities (including levered or delevered tranches of such portfolios or baskets). Except as set forth in the governing documentation of Advisory Clients, there are no limitations on the markets, sectors or instruments in which an Advisory Client may trade, or the trading strategies that an Advisory Client may employ. Boundary Creek’s analysts undertake in-depth financial analysis of individual names and monitor market developments across sectors. They combine a fundamental, cash flow approach with an understanding of a company’s capital structure and specific securities to facilitate absolute and relative value judgments on individual names. Analysts make recommendations on outright long or short positions in particular issuers, capital structure trades and opportunities that arise between names. Analysts provide expertise in particular areas of fundamental research to complement sector and name coverage and use quantitative models that generate fundamental, technical and flow-based signals. Boundary Creek’s portfolio managers analyze trade ideas, monitor the portfolio, perform risk and scenario analyses, and look for investment opportunities within their strategies. The portfolio management team is ultimately responsible for deciding which investment ideas to implement. The team makes these determinations based on the current exposures in the portfolio, the market environment, the relative attractiveness, risk profile, and liquidity of the new position, and the judgment of its members. In evaluating securities, the main sources of information used by Boundary Creek include, but are not limited to: quantitative data provided by third-party vendors; financial newspapers and magazines; research materials prepared by third parties; corporate rating services; annual reports, prospectuses and other filings and disclosures made by issuers. However, Boundary Creek relies on its traders, portfolio managers and research analysts for generating and vetting trade ideas. Boundary Creek typically generates the research that it relies upon to make investment decisions internally.

B. For each significant investment strategy or method of analysis you use, explain the material risks involved. If the method of analysis or strategy involves significant or unusual risks, discuss these risks in detail. If your primary strategy involves frequent trading of securities, explain how frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. All securities investments risk the loss of capital. No guarantee or representation is made that an Advisory Client will achieve its investment objective or that investors will not lose all or substantially all of their investment in the Advisory Client. Purchases of interests in Advisory Clients are suitable only for sophisticated investors of substantial financial means who can make a long-term investment, can bear the risk of loss of their entire investment in the Advisory Client and have no need for liquidity in their investment. Boundary Creek’s strategies have the potential for Advisory Clients’ assets to decline in value. The nature of Advisory Clients’ investments involves certain risks, and the use of investment techniques (such as hedging, leverage and short selling) carries additional risks. Notwithstanding the emphasis intended by references to Boundary Creek below, the following risk factors in this Item 8.B generally apply to the Advisory Clients of Boundary Creek. Some of the specific risks to which Advisory Client assets are susceptible are as follows: Concentration of Investments Boundary Creek generally seeks to maintain a diversified portfolio of investments subject to any limitations imposed by the governing documentation of an Advisory Client. However, Advisory Clients ay concentrate its investments in a few industries, issuers and instruments in a specific geographic area, the negative impact on the value of the assets of an Advisory Client due to adverse movements in a particular economy or industry or in the value of the securities of particular issuer or instrument could be considerably greater than if an Advisory Client were not permitted to concentrate its investments to such a significant extent. If an Advisory Client’s portfolio becomes concentrated in a limited number of investments, such Advisory Client’s performance will not necessarily correlate with the performance of the markets on which instruments held by the Advisory Client are traded. Any loss with respect to a portfolio instrument may have a significant adverse impact on an Advisory Client. Volatility The market value of certain of an Advisory Client’s investments may be volatile, and will generally fluctuate due to a variety of factors that are inherently difficult to predict, including, among other things, the macro business and economic environment, specific developments or trends within a company or in any particular industry, the market’s overall perception of risk, general economic conditions, the condition of certain financial markets, domestic and international economic or political events, prevailing credit spreads, changes in prevailing interest rates and the financial condition of counterparties. Illiquidity of Investments In some circumstances, investments are relatively illiquid, making it difficult to acquire or dispose of them at the prices quoted on the various exchanges. Accordingly, Boundary Creek’s ability to respond to market movements may be impaired, and Advisory Clients may experience adverse price movements upon liquidation of its investments. In addition, the Advisory Clients may make private investments that are subject to liquidity-related risks, particularly the risk that an Advisory Client will be unable to dispose of such investments by sale or other means at attractive prices or will otherwise be unable to complete any exit strategy. Among others, these risks include changes in the financial condition or prospects of the entity in which the investment is made. It is not generally expected that private securities acquired by an Advisory Client will eventually be

registered and listed on a securities exchange. Absent registration, such Advisory Client will not be able to sell such securities unless an exemption from such registration requirements is available. In addition, in some cases an Advisory Client may be prohibited by contract or regulatory restrictions from selling such securities for a period of time. To the extent that there is no liquid trading market for an investment, an Advisory Client may be unable to liquidate that investment or may be unable to do so at a profit. Moreover, there can be no assurances that private purchasers for an Advisory Client’s investments will be found. Financial Model Risk Most, if not all, of Advisory Clients’ investments and investment strategies require the use of quantitative and qualitative valuation models developed by Boundary Creek and third parties. As market dynamics shift (for example, due to changed market conditions and participants) over time, a previously highly successful model may become outdated or inaccurate, perhaps without Boundary Creek recognizing the change before significant losses are incurred. An Advisory Client’s model risk extends to the valuation of its investments, most of which will be made on the basis of internal Boundary Creek models in the absence of any readily determinable market value. The valuations so determined may differ materially from values that are actually realized. Quantitative Analysis Use of Systems. Boundary Creek relies on the use of computer systems, hardware, software, and telecommunications equipment. Boundary Creek makes use of its own equipment as well as equipment, systems and services (including so-called “cloud” based storage and other services) provided by third parties. Accordingly, the Advisory Clients are exposed to the risk that computer hardware, software, electronic equipment and other services used by Boundary Creek may cease to be available, for example, due to the insolvency of the provider, the discontinuation of services or software updates, or the interruption of communication access. In such circumstances, Boundary Creek would seek to obtain equivalent hardware, software and services from an alternative supplier, which could take time to accomplish and which could be costly. Risk of Programming Implementation Error or Logical Error. Given the reliance of Boundary Creek upon the operation of its models and other software trading and analysis systems, the Advisory Clients are therefore at risk of errors of implementation (known as “bugs”) and errors of design that may exist or arise in the software or models, and which may cause inappropriate or aberrant behavior under certain market conditions. While reasonable steps have been taken to ensure that the software is adequate in design and free from bugs, formal proof of bug-free code has not been undertaken, nor can the underlying logical and/or mathematical models be certified as free from error; investors should expect that – at any given time – Boundary Creek’s code will contain errors of design and bugs. As with any software, upgrades, “bug fixes” and various other improvements may be introduced over time and the risk therefore exists that such changes may detrimentally affect the performance of the Advisory Clients, rather than improve it. Furthermore, without limitation, while the software has been tested, no guarantee can be given that a combination of input conditions experienced when running the system “live” will not cause the system to fail, perform aberrantly, or take positions that were not anticipated. These failures may occur in a complex, interdependent environment where different elements of code are all functioning correctly, but their interaction gives rise to unanticipated or unintended errors. Given the fact that Boundary Creek will be utilizing proprietary and third-party code (some of which may be opensource or without any warranties), it is possible or likely that errors will arise from such interactions, and that such errors and any related losses would not constitute reimbursable Trade Errors. Risks Inherent in Computer-Driven and Intellectual Property Based Systems. Boundary Creek relies to a

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If you or any of your supervised persons accepts performance-based fees – that is, fees based on a share of capital gains on or capital appreciation of the assets of a client (such as a client that is a hedge fund or other pooled investment vehicle) – disclose this fact. If you or any of your supervised persons manage both accounts that are charged a performance-based fee and accounts that are charged another type of fee, such as an hourly or flat fee or an asset-based fee, disclose this fact. Explain the conflicts of interest that you or your supervised persons face by managing these accounts at the same time, including that you or your supervised persons have an incentive to favor accounts for which you or your supervised persons receive a performance-based fee, and describe generally how you address these conflicts. As described in Item 5, Boundary Creek or its affiliates receive performance-based compensation for investment management services provided to Advisory Clients. Performance-based compensation represents an asset manager’s compensation for managing an account which is based upon a percentage of the net profits of the account being managed. Boundary Creek’s performance-based compensation arrangements are typically a percentage of net profits allocated to an investor in an Advisory Client on an annual basis or based on an internal rate of return calculation by reference to distributions made to investors and, in certain cases, is subject to a hurdle or a reduction based on the amount of management fees paid. Performance-based compensation creates certain inherent conflicts of interest with respect to the management of assets by Boundary Creek. Specifically, Boundary Creek’s entitlement to performance-based compensation may create an incentive for Boundary Creek to make investments that are riskier or more speculative than would be the case in the absence of such performance-based compensation. Boundary Creek currently manages an Advisory Client that is charged only asset-based fees (i.e., fees based solely on the amount of assets under management in an account). As a general matter, since performance-based compensation rewards an adviser for strong performance, there may be a perceived incentive for Boundary Creek to allocate more favorable investment opportunities to those Advisory Clients that pay performance-based compensation rather than Advisory Clients do not. To maintain fair and equitable treatment of all of its Advisory Clients’ accounts, Boundary Creek has implemented controls to further its efforts to treat all accounts fairly, regardless of their corresponding fee-structure. Boundary Creek maintains and adheres to written guidelines on the allocation of investment opportunities that apply to the Advisory Clients. Such allocation guidelines are part of the compliance program that governs the conduct of Boundary Creek and its employees. As explained below, Boundary Creek believes that its allocation guidelines, along with other existing controls, provide an environment that fosters the fair and equitable treatment of all accounts managed by Boundary Creek, regardless of fee structure. Side-by-Side Management Boundary Creek’s investment professionals simultaneously manage portfolios for Fund Clients that implement comparable investment strategies (i.e., side-by-side management). The simultaneous management of these different investment products creates certain potential conflicts of interest and the possibility of favorable or preferential treatment of a portfolio or a group of portfolios, as the fees for the management of certain types of products are higher than others. Because side-by-side management raises such issues, and because Boundary Creek has an affirmative duty to treat its Advisory Clients fairly and equitably over time, it has instituted policies and procedures, including its allocation guidelines, in an effort to ensure that it fulfills this duty. Boundary Creek’s allocation guidelines are written guidelines intended to ensure that investment

opportunities are allocated on a fair and equitable basis among Advisory Clients. The allocation guidelines set forth (i) methods of investment opportunity purchase and sale allocations which are based on (a) the investment strategies pursued by each Advisory Client and (b) the relative target percentages of each Advisory Client for an investment opportunity and (ii) allocation methods which determine how partially-filled orders are divided among Advisory Clients. When allocating investments among Advisory Clients and, in particular, when determining whether to allocate to an investment to an Advisory Client, Boundary Creek will consider a number of factors, including: • • • • • • • • • • • • • •

The size, nature and type of investment opportunity Relative actual or potential exposure of an Advisory Client to the type of investment opportunity in terms of its existing investment portfolio Similar or different investment opportunities identified for future consideration Investment guidelines, target returns, sector or regional exposure, diversification guidelines, and investment limitations otherwise applicable Legal, tax and regulatory requirements or implications Available capital, including recycling provisions applicable to previous investments Cash availability, including cash that becomes available through permitted leverage and available financing for the investment opportunity (including, without limitation, taking into account the levels/rates that would be required to obtain appropriate return) Likelihood of current income Liquidity and duration of the investment opportunity in relation to the remaining investment period of the applicable Advisory Client Seniority of the instrument and other capital structure criteria Applicable transfer or assignment provisions Supply or demand for an investment opportunity at a given price level An Advisory Client’s risk or investment concentration parameters (including, without limitation, parameters such as geography, industry, issuer/sponsor, off-taker or other counterparty, volatility, leverage or other similar risk metrics) Whether the investment opportunity is a follow-on investment or connected in some other manner to a prior investment

Boundary Creek periodically performs a series of tests in an effort to ensure that investment opportunities are allocated in conformity with these guidelines. Although Boundary Creek has a duty to treat all portfolios employing an investment strategy fairly and equitably over time, such portfolios will not necessarily be managed the same at all times. Specifically, there is no requirement that Boundary Creek uses the same investment practices consistently across all portfolios. In general, investment decisions for each Advisory Client will be made independently from those of other Advisory Clients and will be made with specific reference to the individual needs and objectives of each Advisory Client. In fact, different Advisory Client guidelines and/or differences within particular investment strategies may lead to the use of different investment practices for portfolios employing a similar investment strategy. In addition, Boundary Creek will not necessarily purchase or sell the same securities at the same time or in the same proportionate amounts for all eligible portfolios, particularly if different portfolios have materially different amounts of capital under management by Boundary Creek, different idiosyncratic risk concentration limits or different amounts of investable cash available. As a result, although Boundary Creek manages multiple portfolios with comparable investment objectives, or manages accounts with different objectives that trade in the same securities, the portfolio decisions relating to these accounts, and the performance resulting from such decisions, differ from portfolio to portfolio. Boundary Creek has complete discretion to select and allocate capital among investment strategies and may cause Advisory Clients to invest in additional investment strategies not listed above or cease investing in investment strategies. Further, Boundary Creek has discretion to change target percentages for Advisory Clients.

Boundary Creek may, from time-to-time, offer certain investors in Advisory Clients and other third parties (“Co-Investors”) the right or opportunity to co-invest with other investors and/or Advisory Clients in certain portfolio investments, whether as a direct investment by the Co-Investor or as an indirect investment via a special purpose vehicle or other co-investment vehicle established by Boundary Creek or such investor to hold such co-investment (in each case, a “Co-Investment Opportunity”). Any such Co-Investment Opportunity would only be offered following a determination by Boundary Creek that all Advisory Clients have received the full amount of their respective desired allocations of a particular investment in accordance with Boundary Creek’s allocation guidelines. Boundary Creek is not generally obligated to arrange Co-Investment Opportunities for all investors in an Advisory Client, and investors and Advisory Clients generally will not be entitled or have any right to participate in such an opportunity solely by reason of being an Advisory Client or an investor in an Advisory Client. Boundary Creek’s decision to offer (or not to offer) Co-Investment Opportunities to any investor generally will be made in its sole discretion, with due consideration for, among other factors, (i) special rights previously offered to particular large or strategic investors (including “most-favorednations” rights), (ii) the size of the Co-Investment Opportunity, (iii) whether the prospective Co-Investor has expressed interest in Co-Investment Opportunities and such Co-Investor’s capacity to make the investment, (iv) the extent to which previous Co-Investment Opportunities were offered to the prospective Co-Investor (and whether such prospective Co-Investor participated in such previous Co-Investment Opportunities); (v) whether the prospective Co- Investor will represent a good syndicate partner in connection with the Advisory Client’s investment; (vi) how quickly a prospective Co-Investor will be able to consummate its co-investment (including completion of due diligence and obtaining all required internal approvals); (vii) Boundary Creek’s evaluation of whether the Co-Investment Opportunity would subject the potential Co-Investor to legal, regulatory, reporting, public relations, media, or other burdens that make it less likely that the prospective Co-Investor would act upon the Co-Investment Opportunity, if offered; (viii) the ability of such prospective Co-Investor to generate future investment opportunities or provide other benefits to Advisory Clients; (ix) the ability of such prospective Co-Investor to provide analytical and market advice or other expertise that may be valuable to Advisory Clients; and (x) tax, legal, regulatory or confidentiality considerations. Co-Investment Opportunities are typically structured to entitle Boundary Creek to receive performance-based compensation and/or management fees.

A. If you or any of your management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer, disclose this fact. Neither Boundary Creek nor any of its management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. B. If you or any of your management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities, disclose this fact. Neither Boundary Creek nor any of its management persons are registered, or have an application pending to register as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities,. C. Describe any relationship or arrangement that is material to your advisory business or to your clients that you or any of your management persons have with any related person listed below. Identify the related person and if the relationship or arrangement creates a material conflict of interest with clients, describe the nature of the conflict and how you address it. 1. broker-dealer, municipal securities dealer, or government securities dealer or broker 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund) 3. other investment adviser or financial planner 4. futures commission merchant, commodity pool operator, or commodity trading advisor 5. banking or thrift institution 6. accountant or accounting firm 7. lawyer or law firm 8. insurance company or agency 9. pension consultant 10. real estate broker or dealer 11. sponsor or syndicator of limited partnerships. The general partner of Boundary Creek (or its affiliate) also serves as the general partner of Fund Clients organized as limited partnerships. Additionally, Boundary Creek personnel serve on the board of directors of Fund Clients organized as companies and the governance boards of the general partners of Fund Clients organized as limited partnerships. Boundary Creek’s affiliates, principals, partners and employees from time-to-time purchase interests in certain Fund Clients, and investments by such parties generally are not subject to the management fees or performance-based compensation described in Item 5, above. The offering memorandum of each Fund Client that is provided to each potential investor discloses this fact. Boundary Creek is led by Peter Greatrex in his capacity as Chief Executive Officer and Chief Investment Officer of Boundary Creek. D. If you recommend or select other investment advisers for your clients and you receive compensation directly or indirectly from those advisers that creates a material conflict of interest, or if you have other business relationships with those advisers that create a material conflict of interest, describe these practices and discuss the material conflicts of interest these practices create and how you address them. Not applicable.

A. If you are an SEC-registered adviser, briefly describe your code of ethics adopted pursuant to SEC rule 204A-1 or similar state rules. Explain that you will provide a copy of your code of ethics to any client or prospective client upon request. Boundary Creek has established a variety of restrictions, procedures and disclosures designed to address potential conflicts of interest arising between and among Advisory Clients as well as between Advisory Clients and Boundary Creek and its personnel. Boundary Creek strives to adhere to the highest industry standards of integrity, professionalism and trust. To this end, Boundary Creek has adopted a Code of Ethics (the “Code”) that generally requires Boundary Creek employees to comply with all applicable federal securities laws, place the interests of Advisory Clients first, avoid conflicts of interest, not take inappropriate advantage of the employee’s position, adhere to certain restrictions with respect to the receipt and giving of gifts and safeguard confidential information. Each employee is required to report to Boundary Creek’s Chief Compliance Officer any known or suspected violations of the Code or law. Each newly hired employee receives a copy of the Code and is required to certify that they have read and understand it. Training is provided for employees with respect to the Code and their duties under it. On an annual basis, each Boundary Creek employee must certify that they have read and understand the Code, has complied with its provisions and has disclosed, pre-cleared and arranged for the reporting of all transactions in securities consistent with the requirements of the Code. The Code governs the conduct of Boundary Creek and its personnel; therefore, notwithstanding the fact that this description of the Code (as well as the description of the compliance program generally) references Boundary Creek, the Code applies to all of such persons in a similar fashion. Personal Trading The Code places restrictions on the personal trading of employees, including the requirement that employees arrange to have duplicates of certain brokerage statements or a quarterly holdings report provided to Boundary Creek. Boundary Creek’s Chief Compliance Officer (or his designee) reviews and compares all reported personal securities transactions against transactions indicated on the employee’s brokerage statements or holdings reports in an effort to ensure that personal trading by employees is being conducted in a manner consistent with the Code. Except with respect to certain exempted transactions, no Boundary Creek employee may purchase or sell any security without first obtaining pre-clearance pursuant to the approval process set forth in the Code. Certain pre-clearance requests meeting the standards set forth in the Code will generally be approved on the day of such request or the business day following such request. Each employee may submit no more than twenty pre-clearance requests per calendar month; once an employee has submitted the maximum number of pre-clearance requests, typically no further requests will be accepted from that individual until the following calendar month. Any approved request is subject to certain restrictions on the timing of execution. In addition, Boundary Creek enforces a 30-day minimum holding period for personal securities transactions that are subject to the pre-clearance requirement. The Code governs the conduct of Boundary Creek and its personnel. We will provide a copy of our Code to our investors, or any prospective investor, upon request. Insider Trading/Material Non-Public Information; Privacy Boundary Creek maintains an Insider Trading Policy that includes policies and procedures regarding the receipt and dissemination of material non-public information that are designed to prevent the misuse of material non-public information by Boundary Creek and its officers, partners and employees. In accordance with these policies, to prevent trading of public securities based on material non-public information, Boundary Creek maintains, regularly updates and makes available via email and via its order management system a “restricted” securities list of companies about which non-compliance employees

have, or are expected to have, material non-public information. Boundary Creek has a separate information security policy designed to protect the security, confidentiality, and integrity of non-public, personal information of its clients and investors in such clients. Political Contributions Boundary Creek has policies in effect which place limitations on political contributions and related activities by its employees. In order to ensure compliance with applicable SEC rules and other applicable legal and regulatory requirements, all Boundary Creek employees must obtain pre-clearance from the Chief Compliance Officer before any employee makes a contribution to a political candidate, government official, political party or political action committee. Boundary Creek will provide a complete copy of the Code to any investor in or prospective investor in an Advisory Client upon request. Such requests may be addressed to Peter Greatrex, Chief Compliance Officer, at 212-503-6251 and/or pgreatrex@boundarycreek.com. B. If you or a related person recommends to clients, or buys or sells for client accounts, securities in which you or a related person has a material financial interest, describe your practice and discuss the conflicts of interest it presents. Describe generally how you address conflicts that arise. Examples: (1) You or a related person, as principal, buys securities from (or sells securities to) your clients; (2) you or a related person acts as general partner in a partnership in which you solicit client investments; or (3) you or a related person acts as an investment adviser to an investment company that you recommend to clients. As described above in Item 10, Boundary Creek serves as the investment manager to its Advisory Clients, and its related person serves, directly or through a wholly owned subsidiary, as general partner of Advisory Clients organized as limited partnerships. With respect to each Advisory Client organized as a company, Boundary Creek personnel typically serve on the board of directors of such company. Boundary Creek may from time-to-time recommend that certain of its Advisory Clients invest a portion of their investable assets in other Advisory Clients, typically in connection with a master-feeder (or minimaster) fund structure. Such arrangements are described in the offering memoranda or other governing documents of Advisory Clients. Boundary Creek and its related persons also recommend interests in Advisory Clients to prospective investors. From time-to-time, Boundary Creek causes an Advisory Client to buy or sell securities directly from or to another Advisory Client. With respect to any such transaction (i) the transaction must be effected at a price that is fair to Advisory Clients on both sides of the trade, (ii) neither Boundary Creek nor any of its affiliates may receive any compensation for effecting the trade and (iii) the trade must be in the best interests of both Advisory Clients. Boundary Creek’s principals, employees or other related persons from time-to-time purchase interests in one or more Fund Clients and such investments generally are not subject to the management fees or performance-based compensation described above in Item 5. The offering memorandum of the applicable Fund Client provided to each potential investor discloses this fact. Boundary Creek generally does not engage in principal transactions (i.e., transactions where an adviser, acting as principal for its own account or the account of an affiliate deemed proprietary to Boundary Creek, buys from or sells any security to a client’s account). However, under certain circumstances, a cross trade with a fund in which Boundary Creek and/or its controlling persons hold in excess of 25% of the interests may be deemed to be a principal transaction under Section 206(3) of the Advisers Act. The Chief Compliance Officer (or his designee) may approve such deemed principal transactions provided

that any such transaction is effected in compliance with Section 206(3) of the Advisers Act. With respect to any such transaction, prior to its completion, Boundary Creek must disclose to the client in writing the capacity in which Boundary Creek is acting (and any other requisite disclosures pursuant to Section 206(3) of the Advisers Act) and obtain the client’s consent to the transaction. In cases where the client is an Advisory Client, such disclosure may be made to, and consent to the transaction may be obtained from, (i) the board of directors or board of managers of the Advisory Client (or general partner of the Fund Client), as applicable, provided that (a) the applicable board includes one or more members who are independent of Boundary Creek, and (b) the consent of the board includes the unanimous consent of all such independent members; or (ii) if the Advisory Client does not have a board of directors or board of managers, an independent third-party and/or advisory committee made up of certain investors in such Advisory Client (or the representatives of such investors). It is Boundary Creek’s policy that it will not effect any agency cross transactions for client accounts. The fact that Boundary Creek’s related persons, in their capacities as general partners of certain Advisory Clients, and Boundary Creek’s principals, employees and other related persons have financial ownership interests in Advisory Clients creates a potential conflict in that it could cause Boundary Creek to make different investment decisions than it would if such parties did not have such financial ownership interests. Boundary Creek may have an incentive to favor accounts in which such persons have an interest with respect to trading opportunities, trade allocation and allocation of investment opportunities. Subject to the personal securities transaction pre-clearance and reporting requirements generally described in described in Item 11.A, Boundary Creek personnel and access persons (as defined in the Advisers Act) may make or hold investments in some of the same investments that are held or traded by Advisory Clients. In addition, certain personnel may trade in individual securities and instruments that they or that other personnel trade on behalf of Advisory Clients. Consequently, there is a possibility that such persons (i) might benefit from market activity by the Advisory Clients in respect of positions they both hold and (ii) may hold positions in their personal accounts potentially in conflict with positions held by Advisory Clients. Boundary Creek has adopted policies and procedures (including personal trading policies described below) that are guided by the principle that Boundary Creek has fiduciary duties and obligations to its Advisory Clients and aims to effect this principle by establishing a process by which access persons can trade for their personal accounts in a manner that is not inconsistent with Boundary Creek’s fiduciary duties to its clients. Additional conflicts are present in connection with the receipt by Boundary Creek or an affiliate of management fees and performance-based compensation. Except inasmuch as performance affects asset size and thus the amount of the management fee, management fees are payable without regard to the overall success or income earned by Advisory Clients and therefore may create an incentive on the part of Boundary Creek to raise or otherwise increase assets under management to a higher level than would be the case if Boundary Creek were receiving a lower or no management fee. Performance-based compensation also creates certain inherent conflicts of interest with respect to Boundary Creek’s management of assets. Specifically, Boundary Creek’s entitlement to performance-based compensation in managing one or more accounts may create an incentive for it to make investments that are riskier or more speculative than would be the case in the absence of such performance-based compensation. C. If you or a related person invests in the same securities (or related securities, e.g., warrants, options or futures) that you or a related person recommends to clients, describe your practice and discuss the conflicts of interest this presents and generally how you address the conflicts that arise in connection with personal trading. Please refer to Items 11.A and 11.B. D. If you or a related person recommends securities to clients, or buys or sells securities for client accounts, at or about the same time that you or a related person buys or sells the same securities for your own (or the related person’s own) account, describe your practice and discuss the conflicts of

interest it presents. Describe generally how you address conflicts that arise. Please refer to Items 11.A and 11.B.

A. Describe the factors that you consider in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). 1. Research and Other Soft Dollar Benefits. If you receive research or other products or services other than execution from a broker-dealer or a third party in connection with client securities transactions (“soft dollar benefits”), disclose your practices and discuss the conflicts of interest they create. a. Explain that when you use client brokerage commissions (or markups or markdowns) to obtain research or other products or services, you receive a benefit because you do not have to produce or pay for the research, products or services. b. Disclose that you may have an incentive to select or recommend a broker-dealer based on your interest in receiving the research or other products or services, rather than on your clients’ interest in receiving most favorable execution. c. If you may cause clients to pay commissions (or markups or markdowns) higher than those charged by other broker-dealers in return for soft dollar benefits (known as paying-up), disclose this fact. d. Disclose whether you use soft dollar benefits to service all of your clients’ accounts or only those that paid for the benefits. Disclose whether you seek to allocate soft dollar benefits to client accounts proportionately to the soft dollar credits the accounts generate. e. Describe the types of products and services you or any of your related persons acquired with client brokerage commissions (or markups or markdowns) within your last fiscal year. f. Explain the procedures you used during your last fiscal year to direct client transactions to a particular broker-dealer in return for soft dollar benefits you received. Boundary Creek has authority for selecting the broker-dealer used in each transaction for Advisory Clients and for negotiating the fees to be paid to the broker-dealer in connection with such transactions. In choosing brokers and dealers, Boundary Creek is not required to consider any particular criteria. Generally, Boundary Creek seeks the best combination of brokerage expenses and execution quality but, as discussed below, Boundary Creek is not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. In evaluating “execution quality,” historical net prices (after markups, markdowns or other transactionrelated compensation) on other transactions are a principal factor, but other factors are also relevant, including: the execution, clearance, and settlement and error correction capabilities of the broker or dealer generally and in connection with securities of the type and in the amounts to be bought or sold; the broker’s or dealer’s willingness to commit capital; reliability, responsiveness and financial stability of the broker-dealer; the size of the transaction; availability of securities to borrow for short sales; and the market for the security. In addition to execution quality, Boundary Creek may consider whether a broker or dealer may provide access to management of companies in which Boundary Creek has invested or is considering investing on behalf of its clients, though such considerations are not typically a part of Boundary Creek’s selection process. Advisory Clients may pay commissions to such firms in an amount greater than the amount another firm might charge. In addition to execution quality and access to management, Boundary Creek may consider the value of various research products or services, beyond execution, that a broker-dealer provides to Advisory Clients or Boundary Creek. Selecting a broker-dealer in recognition of such other services or products is known as paying for those services or products with “soft dollars.” Because such research products or services

could benefit Boundary Creek or its affiliates, Boundary Creek may have a conflict of interest in allocating Advisory Client brokerage business. Boundary Creek currently maintains no formalized “soft dollar” arrangements with broker-dealers but may do so in the future. With respect to any research products or services Boundary Creek may receive from broker-dealers, and in the event that Boundary Creek enters into any formalized “soft dollar” arrangements, Boundary Creek intends to keep the use of “soft dollars” within the parameters of Section 28(e) of the Securities Exchange Act of 1934. Research that is received by Boundary Creek or one of its affiliates may be used by personnel of Boundary Creek or its affiliates, regardless of the investment strategy to which the research was initially intended to be applicable. On a quarterly basis, Boundary Creek’s Chief Compliance Officer (or his designee) reviews the quality of Boundary Creek’s execution and the effectiveness of its order execution arrangements and execution policy. 2. Brokerage for Client Referrals. If you consider, in selecting or recommending broker-dealers, whether you or a related person receives client referrals from a broker-dealer or third party, disclose this practice and discuss the conflicts of interest it creates. a. Disclose that you may have an incentive to select or recommend a broker-dealer based on your interest in receiving client referrals, rather than on your clients’ interest in receiving most favorable execution. b. Explain the procedures you used during your last fiscal year to direct client transactions to a particular broker-dealer in return for client referrals. In selecting broker-dealers and negotiating the fees to be paid to them, Boundary Creek takes into consideration the factors described in Item 12.A.1 above. Boundary Creek does not consider, in selecting or recommending broker-dealers, whether Boundary Creek or its related persons receive client referrals from a broker-dealer or third party. From time to time, Boundary Creek participates in capital introduction programs arranged by brokerdealers, including firms that serve as prime brokers to an Advisory Client managed by Boundary Creek or recommend investments in Boundary Creek’s Advisory Clients as investments to the clients of the broker-dealer. Boundary Creek executes Advisory Client’s transactions with broker-dealers who have provided capital introduction opportunities if Boundary Creek determines that it is otherwise consistent with seeking best execution. Boundary Creek will not select a broker-dealer as a means of remunerating the broker-dealer for recommending Boundary Creek or its Advisory Clients. Boundary Creek receives asset-based fees and accordingly would receive a financial benefit from the increase in assets under management that results from capital introduction services and investor referrals. Similarly, Boundary Creek receives performance-based compensation and accordingly could receive larger performance-based compensation in any given profit period as a result of an increase in assets under management that results from capital introduction services and investor referrals. The potential for higher fees presents a potential conflict in that Boundary Creek has an incentive to favor broker-dealers that provide services that have a direct impact on fees even if those broker-dealers rate unfavorably in other categories that are part of Boundary Creek’s broker selection analysis. Boundary Creek addresses this potential conflict through quarterly reviews of the quality of Boundary Creek’s execution and the effectiveness of its order execution arrangements and execution policy. 3. Directed Brokerage. a. If you routinely recommend, request or require that a client direct you to execute transactions through a specified broker-dealer, describe your practice or policy. Explain that not all advisers require their clients to direct brokerage. If you and the broker-dealer are affiliates or have another

economic relationship that creates a material conflict of interest, describe the relationship and discuss the conflicts of interest it presents. Explain that by directing brokerage you may be unable to achieve most favorable execution of client transactions, and that this practice may cost clients more money. b. If you permit a client to direct brokerage, describe your practice. If applicable, explain that you may be unable to achieve most favorable execution of client transactions. Explain that directing brokerage may cost clients more money. For example, in a directed brokerage account, the client may pay higher brokerage commissions because you may not be able to aggregate orders to reduce transaction costs, or the client may receive less favorable prices. Boundary Creek does not have any directed brokerage arrangements. B. Discuss whether and under what conditions you aggregate the purchase or sale of securities for various client accounts. If you do not aggregate orders when you have the opportunity to do so, explain your practice and describe the costs to clients of not aggregating. From time-to-time, Boundary Creek combines, but is under no obligation to combine, orders on behalf of Advisory Clients with orders for other accounts for which it or its affiliates have trading authority, or in which it or its affiliates have an economic interest. In such cases, Boundary Creek allocates the securities or proceeds arising out of those transactions (and the related transaction expenses) in accordance with its allocation guidelines. Such allocation guidelines are intended to ensure fair and equitable treatment of all Advisory Clients. Boundary Creek will not aggregate transactions unless it believes that aggregation is consistent with its duty to seek best execution and is consistent with the terms of the investment guidelines and restrictions for each Advisory Client for which trades are being aggregated. Boundary Creek will not receive any additional compensation or remuneration of any kind as a result of the proposed aggregation. While Boundary Creek believes combining orders in this way is, over time, advantageous to all participants, in particular cases the average price could be less advantageous to one Advisory Client than if such Advisory Client had been the only account effecting the transaction or had completed its transaction before the other participants. Please see Item 6 for additional information regarding Boundary Creek’s policy with respect to allocation of investment opportunities.

A. If someone who is not a client provides an economic benefit to you for providing investment advice or other advisory services to your clients, generally describe the arrangement, explain the conflicts of interest, and describe how you address the conflicts of interest. For purposes of this Item, economic benefits include any sales awards or other prizes. Boundary Creek does not receive any monetary compensation or any other economic benefit from a non-client in connection with the provision of investment advisory services. B. If you or a related person directly or indirectly compensates any person who is not your supervised person for client referrals, describe the arrangement and the compensation. Boundary Creek does not currently engage solicitors or placement agents to market Fund Clients but may do so in the future. Boundary Creek effects securities transactions through a number of broker-dealers. By virtue of its conducting business with broker-dealers, Boundary Creek may receive certain economic benefits from such broker-dealers which would not be received if it did not transact through the broker-dealers. These benefits may include, but are not limited to: access to management of companies in which Boundary Creek has invested or is considering investing on behalf of its clients, receipt of proprietary research, participation in broker-dealer sponsored capital introduction services and receipt of consulting services. Boundary Creek understands that the benefits received through its relationship with the broker-dealers (including its prime brokers) generally do not depend upon the amount of transactions directed to, or amount of assets custodied by, the broker-dealers.

If there are legal or disciplinary events that are material to a client’s or prospective client’s evaluation of your advisory business or the integrity of your management, disclose all material facts regarding those events. Neither Boundary Creek nor any of its officers, directors, or employees or other management persons have been involved in any legal or disciplinary events that would require disclosure in response to this item.

A. Indicate whether you periodically review client accounts or financial plans. If you do, describe the frequency and nature of the review, and the titles of the supervised persons who conduct the review. A portfolio manager of Boundary Creek generally reviews the portfolios of each Advisory Client on a regular and ongoing basis to determine if they are consistent with applicable investment objectives and restrictions. The portfolio managers will also consider whether the portfolio should change investments based on various factors, including, but not limited to, changes in securities prices, company fundamentals and performance, industry prospects, general market conditions, advisers, key industry personnel, analysts, news and press releases, and assessment of the financial consequences of world events derived from general information or such other material as is appropriate under the particular circumstances. B. If you review client accounts on other than a periodic basis, describe the factors that trigger a review. Please see Item 13.A. C. Describe the content and indicate the frequency of regular reports you provide to clients regarding their accounts. State whether these reports are written. Investors in Fund Clients generally receive unaudited monthly or quarterly written reports describing the performance of such Fund Clients and annual reports containing audited financial statements and other indicia of performance. Advisory Client investors and prospective investors in Advisory Clients should refer to the private placement memorandum or other offering documents of the respective Advisory Client for detailed information with respect to the reports they will receive in connection with an investment in such Advisory Client. The information contained herein is a summary only and is qualified in its entirety by such documents.

If you have custody of client funds or securities and a qualified custodian sends quarterly, or more frequent, account statements directly to your clients, explain that clients will receive account statements from the broker-dealer, bank or other qualified custodian and that clients should carefully review those statements. If your clients also receive account statements from you, your explanation must include a statement urging clients to compare the account statements they receive from the qualified custodian with those they receive from you. Boundary Creek’s Fund Clients are structured so that Boundary Creek is deemed to have custody of the assets of such Fund Clients under federal securities laws. In those situations, Boundary Creek does not have actual physical custody of such Advisory Clients’ assets; rather, all such assets are held in the name of such Advisory Client by an independent qualified custodian. Each such Fund Client is audited annually, and investors in such Advisory Client receive annual financial statements. Clients should carefully review these statements and are urged to compare them with reporting provided by Boundary Creek.

If you accept discretionary authority to manage securities accounts on behalf of clients, disclose this fact and describe any limitations clients may (or customarily do) place on this authority. Describe the procedures you follow before you assume this authority (e.g., execution of a power of attorney). Boundary Creek generally provides investment management and supervisory services on a discretionary basis on behalf of its Advisory Clients. As described in Item 4.C, the advisory services provided by Boundary Creek are tailored to the investment objectives, investment strategy and investment restrictions, if any, as set forth in the governing documents of Advisory Clients and/or the investment management agreement entered into by Boundary Creek with such clients. With respect to Fund Clients, Boundary Creek does not tailor its advisory services to the individual needs of investors in the Fund Client and, except as specifically provided in a Side Letter, as described in Item 4.C, does not accept investment restrictions imposed by such Fund Client investors. Certain Side Letters permit the excuse and/or exclusion of a particular investor from participating in a particular investment or category of investments in certain limited circumstances, but Boundary Creek generally does not otherwise accept investment restrictions imposed by investors. Advisory Client investors typically execute a subscription agreement and/or the governing documents of the Advisory Client in connection with their investment in the Fund Client, as applicable, that each contain a power of attorney that generally grants an affiliate of Boundary Creek certain powers related to the orderly administration of the affairs of the Fund Client. Please see Item 4 for additional information regarding Boundary Creek’s advisory services.

A. If you have, or will accept, authority to vote client securities, briefly describe your voting policies and procedures, including those adopted pursuant to SEC rule 206(4)-6. Describe whether (and, if so, how) your clients can direct your vote in a particular solicitation. Describe how you address conflicts of interest between you and your clients with respect to voting their securities. Describe how clients may obtain information from you about how you voted their securities. Explain to clients that they may obtain a copy of your proxy voting policies and procedures upon request. Boundary Creek has adopted policies and procedures for voting proxies received by Advisory Clients. As a general rule, Advisory Clients delegate the power to vote such proxies to Boundary Creek or their general partner (as applicable). Investors in Fund Clients do not have the ability to direct proxy votes. Unless the power to vote proxies for an Advisory Client is reserved to that client, Boundary Creek’s Chief Investment Officer (or his designee) is responsible for voting proxies. Proxy votes generally will be cast in favor of proposals that maintain or strengthen the shared interests of shareholders and management and increase shareholder value. These goals are typically met by voting in favor of management proposals. In some cases, Boundary Creek may abstain from voting or may affirmatively decide not to vote if it determines that abstaining or not voting is in the best interests of the Advisory Clients. If the Chief Investment Officer (or his designee) determines that a material conflict may exist between (i) an Advisory Client’s interests and the interests of Boundary Creek or (ii) two or more Advisory Clients’ interests, the Chief Investment Officer (or his designee) is required to inform the Chief Compliance Officer of such material conflict, and the Chief Compliance Officer will determine the appropriate course of action. Information regarding how Advisory Clients’ proxies have been voted in the past and a copy of Boundary Creek’s Proxy Voting Policies and Procedures will be provided by Boundary Creek to its clients upon request. Boundary Creek’s Chief Compliance Officer may be contacted at pgreatrex@boundarycreek.com. B. If you do not have authority to vote client securities, disclose this fact. Explain whether clients will receive their proxies or other solicitations directly from their custodian or a transfer agent or from you, and discuss whether (and, if so, how) clients can contact you with questions about a particular solicitation. As a general rule, Advisory Clients delegate the power to vote such proxies to Boundary Creek or their general partner (as applicable).

A. If you require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, include a balance sheet for your most recent fiscal year. 1. The balance sheet must be prepared in accordance with generally accepted accounting principles, audited by an independent public accountant, and accompanied by a note stating the principles used to prepare it, the basis of securities included, and any other explanations required for clarity. 2. Show parenthetically the market or fair value of securities included at cost. 3. Qualifications of the independent public accountant and any accompanying independent public accountant’s report must conform to Article 2 of SEC Regulation S-X. Not applicable. B. If you have discretionary authority or custody of client funds or securities, or you require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, disclose any financial condition that is reasonably likely to impair your ability to meet contractual commitments to clients. Boundary Creek is not currently aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to its Advisory Clients. C. If you have been the subject of a bankruptcy petition at any time during the past ten years, disclose this fact, the date the petition was first brought, and the current status. Boundary Creek has not been the subject of a bankruptcy petition at any time during the past ten years (or at any time since inception).