Bracebridge Capital, LLC

Bracebridge Capital, LLC (“Bracebridge” or the “Investment Manager”) is an investment adviser organized as a Delaware limited liability company. Nancy Zimmerman and Gabriel Sunshine founded the business in 1994 (under a former adviser entity that was replaced by Bracebridge in 1996) as a manager of absolute return investment funds. Nancy Zimmerman and Gabriel Sunshine control Bracebridge Capital II, L.P. and SVZ, L.P., the principal owners of Bracebridge. Bracebridge provides investment advisory services to pooled investment vehicles that are exempt from registration under the Investment Company Act of 1940, as amended (the “1940 Act”), and whose securities are not registered under the Securities Act of 1933, as amended (the “Securities Act”) (each, a “Fund” and collectively, the “Funds”). As the investment adviser of the Funds, Bracebridge’s services consist of identifying opportunities for acquisition and disposition of investments for the Funds. Investment advice is provided directly to the Funds and not individually to the limited partners or shareholders of the Funds. Bracebridge manages each Fund consistent with the stated investment strategy of such Fund as described in such Fund’s offering documents. Bracebridge provides services to the Funds in accordance with the investment management agreements with the Funds and/or governing documents of the applicable Fund. Bracebridge has discussions with investors from time to time at their request regarding their investment activities, but the firm does not provide specifically tailored investment services to investors. From time to time, consistent with relevant offering memoranda, Bracebridge pursues specialized investment strategies on behalf of one or more funds or classes of interests. As of December 31, 2025, Bracebridge’s regulatory assets under management were approximately $100,349,501,374, all of which are managed on a discretionary basis.

Compensation and Fee Schedules As the investment manager and/or general partner to the Funds, Bracebridge typically charges a management fee (“Management Fee”) and a performance fee or allocation (“Incentive Fees”), as described in the relevant governing documents and/or investment management agreements of the Funds. The fees and other compensation payable to Bracebridge by a Fund may vary from Fund to Fund, as well as among investors in the same Fund, and in certain circumstances, the fees payable to Bracebridge may be negotiated and set forth in subscription documentation in respect of a particular Fund investor and/or waived in whole or in part. Bracebridge generally waives the Management Fee and Incentive Fee for investments by Bracebridge, employees of Bracebridge, its principals, or their related persons, including estate planning vehicles of such persons and certain other persons or entities associated with such persons. All investors should review the governing documents of the relevant Fund in conjunction with this brochure for complete information on the fees and compensation payable with respect to that particular Fund. All Fund investors of Bracebridge are “qualified purchasers” as defined in Section 2(a)(51) of the 1940 Act and therefore specific fee information is not disclosed in this brochure. Deduction of Fees; Timing of Payments; Termination Bracebridge is authorized under the governing documents and investment management agreements of the Funds to charge and deduct Management Fees and Incentive Fees from the assets of the Funds for its services. Generally, the Funds pay Management Fees in advance. If the investment management agreement is terminated (or an investor withdraws all or a portion of its investment) before the end of the billing period, Bracebridge refunds a pro rata portion of the pre-paid Management Fee to the Funds’ (or the investor’s) accounts. The Incentive Fees will be deducted and paid as of the close of each fiscal quarter or fiscal year (and as of each other date on which Bracebridge determines it is appropriate or necessary to make a

determination of the Incentive Fee with respect to an investor, i.e., a date on which an investor withdraws all or a portion of its investment). Other Expenses In addition to the fees disclosed above, an investor also bears its allocable share of a Fund’s investment expenses (e.g., expenses which, in Bracebridge’s determination, are related to investments or prospective investments (whether or not consummated) of the Fund, including without limitation, brokerage commissions; interest expense; expenses related to clearing transactions and other transaction costs, transfer taxes and stamp duty; expenses related to sourcing, structuring or pooling investments, including expenses related to investment vehicles established for such structured or pooled investments and any operations and employees of such vehicles, investment due diligence or to the ongoing maintenance of investments; translation expenses; travel expenses incurred in connection with investments or prospective investments of the Fund, including, without limitation, to attend board meetings of investment vehicles, and expenses related to investments in other pooled investment vehicles, including, without limitation, asset-based and/or performance-based fees payable to the managers of such pooled investment vehicles); expenses of industry experts or other consultants retained for investment research or to provide specialized advice regarding investments or prospective investments; legal expenses (including, but not limited to, expenses associated with compliance with applicable laws and regulations, any and all filings made by the Fund, and expenses related to investments or prospective investments of a Fund), auditing and tax preparation expenses, tax reporting and compliance expenses, domiciliation fees, expenses relating to the offer and sale of a Fund’s interests, fees and expenses of an administrator and/or relating to administration of a Fund, fees and expenses of other service providers including but not limited to custodian fees, director’s fees, fees and expenses of third-party valuation, pricing and appraisal services and extraordinary expenses. A Fund will also bear its allocable share of any such expenses incurred by a subsidiary of the Funds that is formed to make or hold investments or prospective investments. From time to time, brokerage, investment banking and other investment firms may present Bracebridge with potential investment opportunities for which, if consummated, a Fund may pay a commission, consulting or similar "finder's fee." A Fund will be responsible, or will reimburse Bracebridge, for the Fund’s reasonable portion, as determined by Bracebridge in its sole discretion, of any costs and expenses (including, but not limited to, periodic insurance premiums) incurred by Bracebridge in connection with one or more insurance policies pursuant to which the Fund is a beneficiary including, but not limited to, directors and officers liability, errors and omissions liability and other risk insurance. Any expenses of a Fund that are paid for by Bracebridge will be reimbursed by the Fund. Please refer to Item 12 below for additional information regarding Bracebridge’s brokerage practices. Bracebridge and its supervised persons do not accept compensation or commissions for the sale of securities or other investment products.

Methods of Analysis and Investment Strategies The investment objective of most of the Funds managed by Bracebridge is to achieve absolute returns primarily by seeking investment opportunities arising from inefficiencies in financial markets throughout the world. Bracebridge may employ a variety of strategies in pursuit of the Funds’ objectives. There is no assurance that this investment objective will be achieved, and investment results may vary substantially on a monthly, quarterly and annual basis. Investing in securities involves a risk of loss that investors should be prepared to bear. The Funds invest and trade primarily in fixed income securities throughout the world and in the derivatives relating to those securities, but the Funds also seek opportunities in other financial and currency markets. The Funds use instruments, including options, futures, forward contracts, swaps and other derivatives, and equities, in its investment program. The Funds invest in securities and derivatives directly or through other pooled investment vehicles, including other Funds managed by Bracebridge or its affiliates. The Funds generally seek to engage in hedging transactions against macroeconomic risks, including those related to interest rates, foreign exchange and credit. However, the decision as to when and to what extent the Funds will engage in hedging transactions will depend upon a number of factors. Accordingly, there can be no assurance that the Funds will engage in hedging transactions at any given time or from time to time, or that such transactions, if available, will be effective. Unless otherwise noted, all references herein to the portfolios, investments, investment transactions, investment program, brokerage practices and similar matters, including associated risks, of the Funds should be understood to include both direct and indirect investments and/or other transactions, including, without limitation, investments and/or transactions held or taken directly by the Funds, by a master fund into which certain of the Funds invest (each, a “Master Fund” and collectively, the “Master Funds”) or by any other pooled vehicle in which a Fund directly or indirectly invests. Much inefficiency in the financial markets can be attributed to the investment approaches of, or constraints on, diverse market participants. For example, some market participants have institutional or regulatory constraints that force them to use what Bracebridge views as economically suboptimal hedges to protect portfolios of bonds, mortgages, and other interest rate sensitive positions. Other market participants use derivatives as a leveraged means to make a purely directional investment involving the underlying instrument. This provides an opportunity to capitalize on market anomalies. Bracebridge’s strategy is based on identifying such anomalies within or across global financial markets and their derivative products. From time to time, consistent with relevant offering memoranda, Bracebridge pursues specialized investment strategies on behalf of one or more funds or classes of interests.

Investment Risks Investment and Trading Risks in General. All investments made by a Fund risk the loss of capital. The Investment Manager uses such investment techniques as margin transactions, short sales, option transactions and forward and futures contracts, which practices can, in certain circumstances, maximize the adverse impact to which the Funds may be subject. No guarantee or representation is made that the Funds' programs will be successful, and investment results may vary substantially over time. The Funds have been given very broad investment parameters and maintain flexible investment programs. Therefore, the Funds may make investments in the future that may be subject to risks in addition to those described herein. Additional risks associated with an investment in a Fund are disclosed in the offering documents of that Fund. Hedging Transactions. The Funds engage in transactions intended to hedge particular portfolio positions against overall exposure to certain risks including, but not limited to, exposure to interest rate, equity and exchange rate movements. The success of any Fund’s hedging strategy is subject to the Investment Manager’s ability to assess the degree of correlation between the performance of the instruments used in the hedging strategy and the performance of the investments in the portfolios being hedged and the Investment Manager’s ability to readjust and execute hedges in an efficient and timely manner. The decision as to when and to what extent a Fund will engage in hedging transactions will depend upon a number of factors, including, but not limited to, prevailing market conditions, the composition of such Fund’s portfolio and the availability of suitable transactions. For a variety of reasons, the Investment Manager may not seek to establish a precise correlation between the hedging instruments and the portfolio holdings being hedged. Such an imprecise correlation may prevent the Funds from achieving the intended hedge or expose the Funds to risk of loss. Additionally, the Investment Manager may not hedge against a particular risk, if it does not regard the probability of the risk occurring to be sufficiently high as to justify the cost of the hedge, or because it does not foresee the occurrence of the risk. Accordingly, there can be no assurance that a Fund will engage in hedging transactions at any given time or from time to time. Additionally, there is significant judgment in determining which risks to hedge, how to effectively hedge such risks and how much to hedge such risks. Failure to effectively hedge significant risks in a Fund’s portfolio could have a significant adverse impact on the Fund. Leveraged Trading. The Funds employ a leveraged trading strategy. Accordingly, the Funds trade securities on margin, sell securities short, enter into repurchase or reverse repurchase agreements with respect to securities, and/or borrow, pledge, lend or hypothecate securities, cash or other assets. Such practices may increase the volatility of a Fund’s returns. Trading securities on a leveraged basis generally results in interest charges to a Fund and, depending on the amount of trading activity, such charges could be substantial. Similarly, the low margin deposits normally required in options, futures and forward trading permit a high degree of leverage; accordingly, a relatively small price movement in an option, futures or forward contract may result in immediate and substantial losses to a Fund. Other types of derivatives also may entail a high degree of leverage. Irrespective of the risk control objectives of the Investment Manager, such a degree of leverage necessarily entails a high degree of risk. A Fund’s use of leverage may magnify many of the risks discussed herein. Any use of short-term margin borrowings would result in certain additional risks to the Funds. For example, when the securities pledged to brokers to secure a Fund’s margin accounts decline in value, a Fund will be subject to a margin call, pursuant to which a Fund must either deposit additional funds or securities with the broker, or suffer mandatory liquidation of the pledged securities to compensate for the decline in value. In the event of a sudden drop in the value of a Fund’s assets, it might not be able to generate sufficient funds quickly enough to satisfy its margin requirements or may be forced to forego investment opportunities in order to raise cash to satisfy these collateral requirements. Arbitrage Trading. As part of the Funds’ investment strategy, they engage in a significant amount of arbitrage trading. In such trading, a Fund generally attempts to take advantage of price differences of identical or similar securities or financial instruments on different markets or in different forms. Arbitrage

transactions involve the risk that transactions will fail to be executed as intended or agreed upon, the risk that the other party to a transaction will fail to pay or otherwise perform as agreed, and credit risk (i.e., that the other party does not post collateral, etc., as required). Arbitrage investing also involves the risk that the value of a Fund’s long positions potentially decrease while the value of its corresponding short positions increase over the same period. Often arbitrage opportunities disappear rapidly once the opportunity becomes well-known and many investors act on it. Arbitrage trading can also involve greater transaction costs because of the need to simultaneously buy and sell many different securities. There is no assurance that an arbitrage transaction will perform in the manner expected by the Investment Manager and the exposure of a Fund to a movement in the market or other factors could be significantly increased. Transaction Execution and Costs. Purchases and sales of investments in the Funds may be frequent and may result in higher transaction costs than in a fund that engages in limited trading activity. In addition, relatively narrow spreads may exist between the prices at which a Fund purchases and sells particular positions and related hedging transactions. The successful application of a Fund’s investment strategy will therefore depend, in part, upon the quality of execution of transactions, such as the ability of broker-dealers to execute orders on a timely and efficient basis and the ability to execute related orders in different markets. Illiquid Securities. Many of the Funds’ investments are not regulated or traded on exchanges, and may not be readily marketable or may be only thinly traded, including, without limitation, those which are designated as special situation investments. In addition, the Funds invest in private placements of securities that are not registered under applicable securities laws, have little or no trading market, or contain restrictions or outright prohibitions on transfer. The Funds also invest in recapitalizations, spinoffs, corporate and financial restructurings, acquiring or otherwise taking control of a pooled investment vehicle or its assets, and litigation or other catalyst-orientated situations. Such investments are often difficult to analyze. In any such investment opportunity, there exists the risk that the relevant transaction either will be unsuccessful, will take considerable time or will result in a distribution of cash or a new security the value of which will be less than the purchase price to a Fund of the security or other financial instrument in respect of which such distribution is received. A Fund may not be able to readily dispose of such investments, and, in some cases, may be contractually prohibited from disposing of such securities for a specified period. These limitations on liquidity of a Fund’s investments could prevent a successful sale thereof, result in delay of any sale, reduce the amount of proceeds that might otherwise be realized, result in the designation of certain investments as special situation investments (which would reduce the value of Fund interests available to be redeemed), or result in distribution of securities in-kind upon liquidation of a Fund. When market conditions change, investments may become illiquid. For example, the credit markets experienced a significant lack of liquidity at the end of 2008 and the beginning of 2009, and investments that were historically quite liquid became much less liquid, or illiquid. There have also been periods during which certain participants in the forward or other markets have refused to quote prices for certain financial instruments or assets or have quoted prices with an unusually wide spread between the price at which they were prepared to buy and that at which they were prepared to sell. There can be no assurance that a market will be liquid. It is also possible that illiquidity in a market could cause prices to decline, which may have the result of forcing a Fund to sell assets to satisfy requirements under its borrowing arrangements or to meet margin calls, which could, in turn, create further downward price pressure. If there is a substantial decline in the fair value of a Fund’s portfolio of investments, investments may need to be liquidated quickly, and perhaps not at a value that Bracebridge believes reflects the true value of such investments. Risks of Derivatives. The Funds invest in derivatives, which are financial contracts whose value depends on, or is derived from, the value of an underlying financial instrument, asset, reference rate or index. A Fund uses derivatives both as part of a strategy designed to reduce exposure to other risks, such as credit, interest rate or currency risk (at times, on a macroeconomic level, and, at times, on an investment, or portfolio-, specific level) and also when Bracebridge believes derivatives are inefficiently priced in relation to other investments and a Fund can take advantage of such inefficiencies. A Fund also may use derivatives for leverage, which increases opportunities for gain but also involves greater risk of loss due to leveraging risk. The Funds may use derivatives to gain exposure to a market or region that may not be

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Bracebridge provides investment advisory services solely to the Funds. Investment advice is provided directly to the Funds and not individually to the investors in the Funds. In addition, certain Funds managed

by Bracebridge pursue specialized investment strategies on behalf of one or more classes of interests. Further information about each of these Funds, their classes of interests, and their applicable strategies is provided in the offering documents of the applicable Fund. Bracebridge may also in the future provide advisory services to other funds or to separately managed accounts. Interests in the Funds are offered pursuant to applicable exemptions from registration under the 1940 Act and the Securities Act. Investors in the Funds may include high net worth individuals, trusts, estates, charitable organizations, pension plans, foundations, endowments, sovereign wealth funds, corporations, limited partnerships, limited liability companies and similar entities. Bracebridge also allows certain qualified employees to invest in the Funds. The Funds impose minimum initial investment requirements which may be waived at the discretion of the respective board of directors or general partner (subject to the requirements of applicable law).

As disclosed above under Item 5 “Fees and Compensation,” Bracebridge generally receives an Incentive Fee that is based on performance of the Funds. Incentive Fee arrangements may create an incentive for Bracebridge to make investments that are riskier or more speculative than would be the case if such arrangements were not in effect. In addition, because the Incentive Fee is calculated on a basis which includes, without limitation, unrealized appreciation of a Fund’s assets, such Incentive Fee may be greater than if such compensation were based solely on realized gains.

Related Futures Commission Merchant/Commodity Pool Operator/Commodity Trading Advisor Bracebridge is a commodity pool operator and a commodity trading adviser registered with the Commodities Futures Trading Commission. The following management persons are associated persons of Bracebridge: Nancy Zimmerman, Gabriel Sunshine, John Spinney and Erika Faires.

Code of Ethics Bracebridge has adopted a Code of Ethics (the “Code”) that states that employees and certain other persons covered by the Code (as used in this Item 11, “employees”) may not engage in any investment transaction under circumstances in which the employee benefits from or interferes with or otherwise disadvantages the purchase or sale of investments on behalf of a Fund. The policies and procedures set forth in the Code recognize that as an investment adviser, Bracebridge is a fiduciary to the Funds and has a duty to place the interests of the Funds before the interests of Bracebridge and its employees unless otherwise disclosed. This

duty generally includes an obligation to address and mitigate conflicts of interest. The Code requires all employees to comply with applicable U.S. federal securities laws at all times. The Code outlines written policies regarding personal trading in brokerage or securities accounts in which an employee, or certain members of such employee’s immediate family, has any direct or indirect beneficial ownership. Generally, employees are required to seek advance clearance of any proposed purchase or sale of a security, with the exception of certain securities or security types such as municipal securities, mutual funds and certain exchange-traded funds. All personal trade requests are reviewed for potential conflicts. While employees may hold investments that are the same as, or in a different class or type than investments held by a Fund, employees may not use information concerning the investments or investment intentions of Bracebridge on behalf of a Fund, or their ability to influence such investment intentions, in a manner detrimental to the interests of any Fund. The Code prohibits employees from engaging in certain short-term trading and purchases of securities in underwritten public offerings. In addition, the Code requires employees to disclose applicable personal securities holdings upon employment and annually thereafter, and report personal securities transactions at least quarterly. Bracebridge’s compliance department has responsibility for the day-to-day administration of the Code. Employees are required to immediately report any violation of the Code to the Chief Compliance Officer (the “CCO”) or another member of the compliance department. This summary is qualified in its entirety by the Code, which is available to any investor or potential investor upon request. Conflicts of Interest The material reportable conflicts of interest encountered by a Fund include those discussed below, although the discussion below does not necessarily describe all of the conflicts that may be faced by a Fund. Other conflicts may be disclosed throughout this brochure and in the offering documents of each Fund and these materials should be read in their entirety. Bracebridge has adopted policies and procedures to address and mitigate conflicts of interest, including those described below. Bracebridge may give advice and recommend securities to, or buy securities for a Fund, which advice or securities may differ from advice given to, or securities recommended or bought for another Fund, whether their investment objectives are substantially the same or different. In addition, Bracebridge and/or its Manager Related Persons may engage in transactions or make investments for their own accounts which differ from or are identical to the transactions engaged in or investments made by Bracebridge for a Fund (and such transactions or investments may be made through one or more pooled vehicles, including, without limitation, those established for the benefit of Manager Related Persons). There may also be circumstances in which a Fund makes investments that may be potentially suitable for one or more other Funds but in which the other Funds for any number of reasons does not invest. Investments by Manager Related Persons in Funds or pooled vehicles that pursue similar or different investment strategies from a particular Fund may also present conflicts of interest, including with respect to allocating management time or other functions relating to such Fund and other Funds or investment activities. Other conflicts may arise, for example, when one or more of the Funds, (i) invest in different parts of the same issuer’s capital structure, whereby one or more Bracebridge Funds own senior debt obligations of such issuer and other such Funds own junior debt or equity of the same issuer, (ii) own public securities and other Funds own private securities of the same issuer, or (iii) invest in different tranches of the same structured investment. In such cases, Bracebridge will carefully consider and resolve any conflicts of interest consistent with its fiduciary duties in its best judgment but in its sole discretion. Bracebridge strives to allocate investment opportunities among Funds in a fair and equitable manner over time and consistent with Bracebridge’s trade allocation procedures. When Bracebridge determines that the

same investment opportunity may be appropriate for multiple Funds, Bracebridge will allocate such opportunity among such Funds in its sole discretion, taking into account various factors, including, but not limited to, the relative amounts of capital available to each such Fund (considering both cash and available borrowings) for new investments, the relative net asset values of each such Fund, the existing kinds and levels of investments of such Fund in light of such Fund’s investment strategy, such Fund’s limitations on participation in special situation investments or any other side pocket mechanisms, if any, such Fund’s leverage and risk appetite, the investment programs and portfolio positions of each such Fund (including, without limitation, whether or not such opportunity is intended as a hedge of positions held in such Fund’s accounts, whether or not such opportunity is part of a spread trade or other multi-legged trading strategy particular to such Fund, and whether or not such opportunity relates to the readjustment of a historical trade), whether or not an allocation of such opportunity will result in such Fund holding odd lots or a de minimis amount, and applicable tax and regulatory considerations. It is expected that multiple Bracebridge-managed Funds, including a Master Fund, will invest in many of the same assets. When the purchase and sale of securities is considered to be in the best interests of multiple Funds, the securities to be purchased or sold may be aggregated in order to obtain superior execution and/or lower brokerage expenses. Where an aggregated order is executed at more than one price over the course of a day, the executed transactions will generally be allocated so that each Fund receives the average unit price over the course of the day and bears its pro rata share of the aggregated transaction costs, to the extent reasonably practicable. In such events, allocation of prices, as well as expenses incurred in the transaction, shall be made in a manner Bracebridge considers to be equally as favorable to a Fund as to any other Fund. Despite similar investment strategies among certain Funds, the Funds might have different performance results as a result of the manner in which investments are allocated. See Item 12 “Aggregation of Orders” below for more information regarding Bracebridge’s policy on aggregating orders. Bracebridge may engage in cross trades with respect to the Funds to the extent permitted in the Funds’ organizational documents and in a manner consistent with securities regulations that allow such trades. Certain of the Funds are part of a master-feeder structure and, accordingly, Bracebridge advises certain feeder funds to invest in certain Master Funds routinely. The use of a master-feeder structure may create a conflict of interest in that different tax considerations for different Funds within a single master-feeder structure may cause a Master Fund to structure or dispose of an investment in a manner that may have disparate tax effects across the feeder funds within such structure, which may be more advantageous to one or more, but not all, such feeder funds. Bracebridge has certain responsibilities in connection with valuation of securities. A conflict may arise with respect to valuing certain securities given that the Management Fee and Incentive Fee earned by Bracebridge are determined based on the value of such securities. The Funds’ organizational documents do not prohibit Bracebridge or its employees, members and/or principals from buying or selling securities or commodity interests for their own account. The records of any such trades by Bracebridge, its employees, members and/or principals will not be open to inspection by the Funds’ investors. Bracebridge maintains compliance policies and procedures, including personal trading policies, which are designed to reduce potential conflicts of interest (see “Code of Ethics” above). Bracebridge, its affiliates and their respective members, partners, officers, employees or related persons (and any such person’s investment vehicles, estate planning vehicles, donor advised funds and charitable foundations) (collectively, “Manager Related Persons”) have significant capital invested in the Funds. This provides alignment of financial interests with the interests of Fund investors, but may present conflicts of interest in that Manager Related Persons have a larger interest in certain Funds than others. In addition, investments in the Funds by such persons may also present conflicts of interest since such persons are generally permitted to make redemptions without being subject to any minimum lock-up period,

anniversary redemption dates, notice periods or other restrictions on redemptions.

Broker/Dealer Selection Process Bracebridge’s objective is to act in the best interests of the Funds in its selection of brokers/dealers to effect transactions for the Funds. In making such selections, Bracebridge seeks to obtain the best execution for each such transaction. In any specific transaction, Bracebridge assesses best overall execution for the Funds in light of all relevant prevailing circumstances. Bracebridge considers the following factors (to which, in any given transaction, more or less weight may be given) in selecting brokers/dealers: the creditworthiness and financial stability of the particular broker/dealer, the expertise, skills and trade ideas with respect to the specific securities traded for the relevant Fund, the ability to execute and clear trades in an orderly and satisfactory manner, the adequacy of trading infrastructure, technology and capital, and the trading terms, among other factors. Best price (including commissions), or lowest possible transaction cost, is a significant consideration, however, “best execution” does not require Bracebridge to obtain the lowest possible price for any particular transaction, for any group of transactions, or for any particular Fund or all Funds in the aggregate. Bracebridge’s Business Risk Committee reviews the quality and cost of execution being provided by Bracebridge’s broker/dealers. Research and Other Soft Dollar Benefits Section 28(e) of the Exchange Act is a “safe harbor” that permits an investment adviser to use commissions or “soft dollars” to obtain certain research and brokerage services in connection with the investment decision-making process. Bracebridge does not have any soft dollar arrangements. Bracebridge from time to time participates in certain “capital introduction” programs organized or sponsored by certain prime brokers or counterparties to the Funds or affiliates of such prime brokers or counterparties, which programs may include prime brokers, counterparties or their affiliates introducing Bracebridge to potential investors with which the prime brokers, counterparties or their affiliates have a pre-existing relationship. Neither Bracebridge nor the Funds compensate prime brokers, counterparties or their affiliates for organizing such programs or making such introductions or for any investments made by such prospective investors. Such programs and introductions could be construed as an influence on Bracebridge’s broker/dealer selection in connection with brokerage financing and other activities of the Funds. Directed Brokerage Bracebridge does not have client directed brokerage arrangements. Aggregation of Orders Where an investment is appropriate for multiple Funds, Bracebridge may group all such Funds together and submit one aggregated order for the participating Funds. Bracebridge will generally be required to designate the amount of investments to be purchased or sold for each Fund participating in any aggregated order either prior to the execution of the order or promptly thereafter. Such allocation will be based upon the parameters described in Item 11 (“Conflicts of Interest”) above and upon factors that include, without limitation, the available capital of each Fund and whether allocation to a Fund will result in the Fund holding odd lots or a de minimus amount of an investment. If an aggregated order is not completely filled, it will typically be allocated pro rata to all Funds participating in the order promptly following execution subject

to the parameters described in Item 11 (“Conflicts of Interest”) above. Where an aggregated order is executed at more than one price over the course of a day, the executed transactions will be allocated so that each Fund receives the average unit price over the course of the day and bears its pro rata share of the aggregate transaction costs, to the extent reasonably practicable and subject to the parameters described in Item 11 (“Conflicts of Interest”) above. Where it is not practicable, Bracebridge endeavors to ensure the Funds are treated in a fair and equitable manner. To the extent any orders remain unfilled following such allocation, the unfilled amount will be combined with subsequent orders in that investment, if any, for allocation of subsequent transactions. To the extent that a trade allocation is not made pre-trade, Bracebridge’s policy is that such allocation must be made promptly after trade execution and in all cases by the end of the trading day. If circumstances exist that make it impossible or impractical to allocate a trade before the end of the relevant trading day, the relevant trader should so inform the compliance department. See Item 11 (“Conflicts of Interest”) above for more information regarding conflicts of interest related to aggregating orders.

Bracebridge does not compensate any person for Fund investor referrals. ITEM 15. CUSTODY

disciplinary events.

Oversight and Monitoring Bracebridge provides continuous advisory services for the Funds. The investments in each Fund are routinely reviewed by a team of investment professionals, including Bracebridge principals. The Business Risk Committee (i) oversees the risk management framework for the Firm’s investment management activities and monitors those risks (including, without limitation, market, liquidity, leverage, counterparty credit, trading, operational and legal/compliance) that may impact Bracebridge-managed funds and (ii) oversees the Firm’s trading-related policies and procedures (including, without limitation, best execution, trade allocation and aggregation, and trading errors). Reporting Bracebridge provides written reports to Fund investors in accordance with the applicable Fund’s organizational and offering documents and as may be agreed with particular investors. Bracebridge has engaged an independent public accounting firm to audit the Funds’ financial statements within 120 days of the end of each fiscal year (or such shorter period as may be set forth in a Fund’s governing documents) or as soon as reasonably practicable thereafter.

statements directly to Bracebridge’s clients under the custody rule.

Bracebridge provides investment advice directly to the Funds pursuant to a written investment management agreement with each Fund and not directly to the investors in the Funds. Investors generally may not impose restrictions on a Fund investing in certain securities or types of securities.

Bracebridge makes all decisions relating to the voting of proxies and exercise of consent rights (collectively, “Votes” or similar construction, as appropriate) on behalf of the Funds. Bracebridge will vote in accordance with Bracebridge’s Proxy Policy. Bracebridge will endeavor to identify and resolve any conflicts between its own interest or the interest of its employees, on the one hand, and the interests of the Funds for which Bracebridge exercises voting discretion, on the other hand. Bracebridge will also endeavor to identify and resolve any conflicts of interest between different Funds for which Bracebridge exercises voting discretion. Where actual, potential or apparent conflicts are identified regarding any material individual voting matter, Bracebridge may, at the option of the CCO, submit the matter to an independent third party for resolution. This summary of Bracebridge’s voting policies and procedures is qualified in its entirety by Bracebridge’s Proxy Policy that is available to investors upon request. Any requests for information about how Bracebridge has voted with respect to securities held by the respective Fund should be directed to the CCO or another member of the compliance department. ITEM 18. FINANCIAL INFORMATION Item 18.A is not applicable to Bracebridge, as it does not require or solicit prepayment of fees six months or more in advance. In response to Item 18.B, there is no financial condition that Bracebridge believes is reasonably likely to impair its ability to meet its contractual commitments to the Funds.

past ten years. ITEM 19. REQUIREMENTS FOR STATE-REGISTERED ADVISERS