BREACH INLET CAPITAL MANAGEMENT, LLC

A. Description of the Advisory Firm Breach Inlet Capital Management, LLC (hereinafter “BICM”) is a Limited Liability Company organized in the State of Texas. We provide investment management services with respect to an affiliated private pooled investment vehicle and have full discretionary authority with respect to investment decisions. Our investment advisory services are provided in accordance with the investment objectives and guidelines set forth in the applicable offering and governing documents, and the information in this Brochure is qualified in its entirety by the information set forth in such documents. BICM was formed in November 2015, and its sole owner is Chris Colvin.

B. Types of Advisory Services Portfolio Management Services Partnerships BICM is investment manager with respect to Breach Inlet Capital, LP (the “Partnership”) a private investment fund organized as a Delaware limited partnership. BICM is responsible for investing and reinvesting the capital of the Partnership in securities, financial instruments and/or other assets in accordance with the investment objectives, policies and guidelines set forth in the offering and governing documents of the Partnership. Information about the Partnership is set forth in its offering document. Services Limited to Specific Types of Investments BICM generally limits its investment advice to equities, exchange-traded funds (ETFs) and non-U.S. securities, although BICM primarily recommends domestic equities to its clients. BICM may use other securities as well to help diversify a portfolio when applicable.

C. Client Tailored Services and Client Imposed Restrictions We generally provide investment advice to the Partnership in accordance with the investment objectives, policies and guidelines set forth in the offering and governing documents, and not in accordance with the individual needs or objectives of any particular investor in the Partnership. Investors generally are not permitted to impose restrictions or limitations on the management of the Partnership. The Partnership has created and offers, and will in the future offer, various classes of interests with different terms and conditions, including, without limitation, fees, performance allocations and withdrawal rights. The Partnership had previously created a Founders Class made up of limited partners holding Founders Class Capital Accounts (as defined in the Partnership’s limited partnership agreement). The Founders Class is not being offered. The Partnership had previously created an Anchors Class made up of limited partners holding Anchor Class Capital Accounts (as defined in the Partnership’s limited partnership agreement). The Anchors Class is not being offered. The Partnership had previously created a Class C made up of limited partners holding Class C Capital Accounts (as defined in the Partnership’s limited partnership

agreement). The Class C is not being offered. Class D Interests are issued to current limited partners (in the case of additional subscriptions) and new limited partners. The Partnership and BICM may also enter into side letter agreements and other arrangements with certain investors that alter, modify or change the terms of the interests held by those investors. Among other things, these agreements or arrangements may entitle certain investors to specific reports or notice of specified events, including reports listing positions and related risk statistics at a level of detail or frequency not provided to other investors.

D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. BICM does not participate in any wrap fee programs.

E. Assets Under Management BICM has the following assets under management: Discretionary Amounts: $227,650,975

Non-discretionary Amounts: $0

Date Calculated: December 31, 2025

A. Fee Schedule Portfolio Management Fees For its services to the Partnership, BICM is entitled to a management fee (the “Management Fee”) at an annual rate of 1.00% of each limited partner’s capital account balance. The Partnership’s general partner, Breach Inlet Genpar, LP, is entitled to a performance-based profit allocation (the “Performance Allocation”) at the end of each calendar year (and/or at certain other times) equal, generally, to (i) 5% per annum of the amount by which, generally, the Partnership’s net profits allocated to the limited partner’s Founders Class capital account for the current calendar year exceeds the balance in such limited partner’s loss carry forward account for such Founders Class capital account and (ii) 10% per annum of the amount by which, generally, the Partnership’s net profits allocated to the limited partner’s Anchor Class capital account for the current calendar year exceeds the balance in such limited partner’s loss carry forward account for such Anchor Class capital account and (iii) 20% per annum of the amount by which, generally, the Partnership’s net profits allocated to the limited partner’s Class C and/or Class D capital account for the current calendar year exceeds the balance in such limited partner’s loss carry forward account for such Class C or Class D capital account (explained further within the Partnership’s private placement memorandum). Net profit includes unrealized appreciation or depreciation of both marketable and non-marketable investments. BICM has received capital from an initial strategic investor (the “Initial Strategic Investor”). The Initial Strategic Investor has invested in the Partnership and was subject to an extended lock-up period and, in return, the Initial Strategic Investor is entitled to receive a portion of the Management Fee and any Performance Allocation.

The Partnership’s general partner and its affiliates have made contributions to the Partnership’s investment program through an investment in the Partnership. Such affiliated investors will not bear any Management Fee or Performance Allocation but will share pro rata in all other applicable expenses of the Partnership.

B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the limited partner’s capital accounts in an amount equal to one fourth of 1.00% of the account balance, which amount is calculated and paid in advance on the first business day of each calendar quarter based on the account balance as of such day. Performance-based fees are withdrawn directly from the limited partner’s capital accounts at the end of each calendar year generally equal to 5.00% with respect to Founder Class interests; 10.00% with respect to Anchor Class interests; and 20.00% with respect to Class C and Class D interests, of the increase in value above the high water mark.

C. Client Responsibility for Third Party Fees The Partnership bears the expenses of its organization and offering, as further described in the Partnership’s Limited Partnership Agreement (including legal and accounting fees, printing costs, travel, “blue sky” filing fees and expenses and out-of-pocket expenses). The Partnership bears all (i) costs and expenses related to its investment program, including expenses related to proxies, underwriting and private placements, data feed hardware and software, research, trade publications, brokerage commissions, interest on debit balances or borrowings, custody fees and any withholding or transfer taxes imposed on the Partnership; and (ii) all out-of-pocket costs of the administration of the Partnership, including accounting, audit and legal expenses, costs of any litigation or investigation involving the Partnership’s activities and costs associated with reporting and providing information to existing and prospective limited partners; provided, however, that the amount of fund Expenses (including, for this purpose, the amount of amortized organizational expenses, but not including the Management Fee, the trading expenses, borrowing expenses or direct costs associated with the Partnership’s portfolio) shall not exceed 0.50% of annual average net asset value of the Partnership (applied to each capital account of a limited partner on a pro rata basis for the portion of such year the capital account was in existence). The Partnership does not have its own separate employees or office, and it does not reimburse the general partner or BICM for salaries, office rent and other general overhead costs of the general partner or BICM.

D. Prepayment of Fees Asset-based portfolio management fees are collected in advance. Generally, for asset-based fees paid in advance, the fee refunded is determined on a pro rata basis for the amount of time such withdrawal amount was invested during the calendar quarter.

E. Outside Compensation for the Sale of Securities to Clients Neither BICM nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds.

A. Methods of Analysis and Investment Strategies Methods of Analysis BICM’s methods of analysis include fundamental analysis, cyclical analysis and quantitative analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Quantitative analysis deals with measurable factors (such as the value of assets, the cost of capital, historical projections of sales) as distinguished from qualitative considerations such as the character of management or the state of employee morale. Investment Strategies BICM may use long-term trading, short-term trading, short sales and options trading (including covered options, uncovered options, or spreading strategies). Except as otherwise set forth in investment management agreements (and subject to the terms, conditions, restrictions and limitations set forth therein), BICM will generally also use the methods of analysis and investment strategies described for the Partnership. The Partnership The investment objective of the Partnership is to seek long term capital appreciation and to outperform the Russell 2000 Value Index over the long term by investing in undervalued securities of companies having catalysts to grow intrinsic value. BICM seeks to achieve the Partnership’s objective by creating a portfolio primarily of “small cap transformations”, as discussed below, and generally expects the Partnership to hold positions for at least one year. BICM’s investing principles act as the backbone of the Partnership’s strategy. First, BICM views securities as ownership stakes in businesses, and not merely tradable pieces of paper. Second, BICM believes that market prices are often determined by irrational trading, causing securities to be mispriced and markets to be inefficient in the short-term. BICM plans to identify these mispriced securities through a disciplined process and estimate their fair values with fundamental analysis. Additionally, BICM intends to concentrate the Partnership’s investments in securities that it best understands and that it believes are most severely mispriced. BICM also believes that the chances of higher returns should be improved with multiyear targeted holding periods. Further, to reduce the impact of bear markets and recessions until portfolio

securities approach fair values, BICM intends to apply relatively conservative portfolio management, which may include holding cash and utilizing hedges. BICM believes that the Partnership’s core positions possess several key attributes. First, BICM believes that these portfolio companies have market-leading positions with protective barriers to entry that allow for relatively high returns on invested capital (“ROIC”). Second, these companies generally are led by experienced, properly incentivized management teams with proven track records of allocating capital. BICM believes that companies having high ROIC and managed by proven capital allocators often experience substantial growth in intrinsic value. BICM intends to focus on securities trading at significant discounts relative to peers and historical valuations. These investments also typically have visible catalysts that should ultimately close these discounts in valuation. BICM generally avoids sectors where it has less expertise or is otherwise uncomfortable with estimating potential downsides (e.g., energy, health care, and technology). BICM generally targets “small cap transformations”, which it defines as companies that (1) have less than $5 billion of market capitalization and (2) are experiencing transformative changes with potential to create substantial value. BICM generally favors small cap companies because it views these companies as being subject to less research coverage and as having a smaller pool of potential buyers, creating the potential for an informational edge. While small cap companies may have less market liquidity and greater price volatility, BICM believes that these conditions also allow for the greater potential for mispricing and trading opportunities. Additionally, BICM believes that investments in small cap companies are more likely to open direct access to companies’ senior management. Lastly, BICM believes that small cap companies tend to operate with less complexity, allowing for relevant risks to be more easily quantified. BICM believes that “transformations” often go unrecognized or unappreciated by the general market because it is difficult to quantitatively screen for such events, and that these “transformation” catalysts provide visible paths to grow intrinsic value, often over a period of more than one year. In addition to “small cap transformations”, BICM may opportunistically supplement the Partnership with special situations when it believes these are significantly mispriced. The Partnership’s portfolio generally consists of two components: (1) cash and (2) securities. BICM views cash as a valuable call option on every asset since cash has no expiration date or strike price. At any time, as much as 25% of the Partnership’s net asset value may be comprised of cash if, for example, compelling opportunities are scarce. BICM intends to concentrate the Partnership’s securities in a relatively small number of “small cap transformations” in North America. BICM also shorts securities that it believes are overvalued. BICM generally expects the Partnership’s net exposure to range between 30% and 80%. BICM uses what it believes to be a robust and repeatable process to identify, evaluate and position the Partnership’s investments. Candidates for research may come from a variety of sources, including BICM’s network, periodicals, proprietary screens, watch lists, and recycled past investments. Through fundamental analysis, BICM determines whether the investment opportunity is actionable or should be placed on its watch list. This fundamental analysis includes a careful review of public information followed by discussions with the company’s management, suppliers, customers and competitors, as available, in order to garner a full understanding of the economic drivers, industry dynamics, potential catalysts and risk factors. If the investment’s expected risk-adjusted return is identified as being above BICM’s threshold, the size of the Partnership’s potential investment is then determined based on risk-adjusted return, liquidity, and existing exposures within the Partnership. A position may be sold when, in BICM’s opinion, an exposure limit or price target is reached, the company’s fundamentals change, or sale is otherwise appropriate to allow for an alternative opportunity. BICM generally defines “risk” as the potential for the permanent loss of capital. BICM accepts short-term price volatility and seeks long-term returns. BICM’s principal sources of internal risk management are (1)

security selection, (2) portfolio construction and (3) transparent infrastructure. When selecting securities, BICM seeks to apply conservative assumptions, require substantial margins of safety, hedge undesired risks, regularly reassess its own theses, and diversify across sectors. In order to construct a conservative portfolio, BICM intends to limit industry net exposure to 30%. Additionally, BICM intends to avoid recourse leverage, while often maintaining cash and shorting securities. BICM overlays careful security selection and conservative portfolio management with a transparent infrastructure that includes monthly third-party valuations, quarterly reports to limited partners, and annual audited financials, the latter two which are further described below. The Partnership may employ the investment strategies and methods of analysis listed above, but its strategies and analysis are further described in its Private Placement Memorandum. Investors are encouraged to carefully review that document.

B. Material Risks Involved There can be no assurance that we will achieve our investment objective or that our investment strategies will be successful. Our investment program involves a substantial degree of risk, including risk of complete loss. Nothing in this Brochure is intended to imply, and no one is or will be authorized to represent, that our or the Partnership’s investment program is low risk or risk free. Our investment advisory services are appropriate only for sophisticated persons who fully understand and are capable of bearing the risks of investment, including the risk of complete loss of their investment. The various risks outlined below are not the only risks that may be associated with our investment strategies and processes. Prospective investors and clients are urged to consult with their own independent financial, legal and tax advisors before making an investment decision. With respect to the Partnership, the following risks are qualified in their entirety by the risks set forth in the applicable offering documents. Investing in securities involves a risk of loss that you, as a client or investor, should be prepared to bear. General Risks Related to Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two-fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Position Model Risk: Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. General Risks Related to Investment Strategies Long-term trading is designed to capture market rates of both return and risk. Due to its nature, the longterm investment strategy can expose clients and investors to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited

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We currently provide investment advisory services to an affiliated private pooled investment vehicle (the Partnership). We may in the future provide investment advice to other clients or types of clients. The investors in the Partnership generally consist of the following types of investors:       

High-Net-Worth Individuals Pension and Profit Sharing Plans Charitable Organizations Other Investment Advisers Insurance Companies Pooled Investment Vehicles University Endowments

The initial minimum investment in the Partnership is $1,000,000, subject in each case to the Partnership’s general partner’s discretion to accept initial subscriptions in lesser amounts or to establish additional or different amounts in the future.

Performance-Based Fees As noted under Item 5 above, we (or an affiliate) generally are entitled to receive performance-based compensation with respect to our clients. Performance based-compensation could motivate us to make investment decisions that are riskier or more speculative than would be the case if these arrangements were not in effect. In addition, because performance-based compensation is calculated on the basis that may include unrealized appreciation in the client’s portfolio based upon values assigned by us, we face a conflict of interest in valuing the client’s portfolio. Our supervised persons and affiliates who are compensated to some extent based upon trading profits for which they are responsible face the same potential conflict. We address these conflicts through full and fair disclosure in the applicable governing, offering and/or account documents and this Brochure as well as by having policies and procedures designed to ensure that all clients treated fairly duty in terms of investment allocation, brokerage execution and valuation and in keeping with BICM’s fiduciary duty. Side-By-Side Management The terms of performance-based compensation for the Partnership and other client accounts, including private funds that BICM may manage in the future, may differ. Such differences could incent us to favor a client account over another with respect to investment allocations. These potential conflicts would be mitigated by the fact that such accounts will generally invest and trade pari passu with the Partnership. BICM may in the future also manage accounts that are not assessed performance-based fees. Managing both kinds of accounts at the same time presents a conflict of interest because BICM and/or its supervised persons have an incentive to favor accounts for which BICM receives a performance-based fee. BICM addresses the conflicts by ensuring that clients are not systematically advantaged or disadvantaged due to the presence or absence of performance-based fees. BICM seeks best execution and upholds its fiduciary duty for all clients.

A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither BICM nor its management persons are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer.

B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither BICM nor its management persons are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities.

C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Chris Colvin is the Manager of the Partnership, a hedge fund. Chris Colvin is also the principal of CDC Equity, LLC, the general partner of the Partnership’s general partner, Breach Inlet Genpar, LP. Mr. Colvin also controls the Partnership’s general partner, Breach Inlet Genpar, LP. As a fiduciary, BICM has an obligation to provide investment management services to each Fund or client in accordance with the investment objectives, policies, guidelines, restrictions and limitations set forth in the applicable Fund or client governing, account and/or disclosure documents. However, except as otherwise provided in the Firm’s offering and governing documents, BICM and its Supervised Persons do engage, and may in the future engage, in other business activities.

D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections BICM neither utilizes nor selects third-party investment advisers. All assets are managed by BICM management.

Transactions and Personal Trading A. Code of Ethics We have adopted and implemented a code of ethics, which sets forth standards of business conduct for our supervised persons. Our code of ethics is designed to educate supervised persons about our philosophy regarding ethics and professionalism, emphasize our fiduciary duties to clients, encourage supervised persons to comply with applicable laws, prevent the misuse of material non-public information, the circulation of rumors and other forms of market abuse and address material conflicts of interest that arise from personal trading by access persons. Subject to the terms of the code of ethics, we generally impose restrictions on employees relating to the purchase or sale of securities for their own accounts and the accounts of certain affiliated persons. The Code of Ethics covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. BICM's Code of Ethics is available free upon request to any client or prospective client and any investor or prospective investor in the Partnership. We also maintain certain

policies and procedures designed to prevent supervised persons from misusing material non-public information.

B. Recommendations Involving Material Financial Interests Chris Colvin is the Manager of the Partnership, a hedge fund. Chris Colvin is also the principal of CDC Equity, LLC, the general partner of the Partnership’s general partner, Breach Inlet Genpar, LP. Currently, the Partnership is BICM’s only client. However, should BICM obtain additional clients, BICM will recommend investments in the Partnership to those clients for which investment in the Partnership is suitable. This presents a conflict of interest in that BICM or its related persons may receive more compensation from investment in the Partnership than from other investments. Nevertheless, BICM acts in the best interest of the client consistent with its fiduciary duties. Issuers, or affiliates of issuers, whose securities are holdings of the Partnership’s portfolio can and may be investors in the Partnership. Such issuers or their affiliates who are also investors in the Partnership do not receive favorable treatment relative to other investors, such as additional transparency or terms. In addition, BICM acts in the best interest of the Partnership in making investment decisions with respect to investments in such issuers.

C. Investing Personal Money in the Same Securities as Clients Supervised persons of BICM do not generally buy or sell securities for themselves that they also recommend to clients, although supervised persons do and may invest in the Partnership. BICM will always document any transactions in single name equities and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold.

D. Trading Securities At/Around the Same Time as Clients’ Securities Supervised persons of BICM do not generally buy or sell securities that they also recommend to clients, although supervised persons do and may invest in the Partnership. BICM will never engage in trading that operates to the client’s disadvantage if representatives of BICM buy or sell securities at or around the same time as clients.

A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on BICM’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and BICM may also consider the market expertise and research access provided by the brokerdealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in BICM's research efforts. BICM will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian. We may cause our clients to pay higher commissions to brokers believed to offer superior service under the circumstances, including brokers that provide investment research and analysis to their clients. Accordingly, when we determine in good faith that the amount of commissions charged by a broker is reasonable in relation to the value of the overall services provided to our clients, including internally-developed research and other services provided by such

broker, we may cause our clients to pay commissions to such broker in an amount greater than the amount another broker might charge. BICM will generally recommend clients use and effect transactions through the Partnership’s prime broker. Research and Other Soft-Dollar Benefits BICM has no formal soft dollar program or arrangement. BICM has arrangements with certain brokers where a portion of the commissions paid for execution is allocated for research and other services. BICM may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and BICM does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. BICM benefits by not having to produce or pay for the research, products or services, and BICM will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that BICM’s acceptance of soft dollar benefits may result in higher commissions charged to the client. Brokerage for Client Referrals From time to time, our third-party brokers may provide opportunities for us to be introduced to potential investors. Brokers or their affiliates may provide capital introduction or other placement services to the Partnership and BICM (with or without separate charges for such other services). Such “capital introduction” opportunities may influence our decision to use (or continue to use) the services of these brokers, rather than selecting brokers solely based on the Partnership’s interest in receiving most favorable execution. BICM may select broker-dealers that provide capital introduction opportunities provided BICM is not selecting the broker-dealer in recognition of the opportunity to participate in such capital introduction events or the referral of investors. Clients Directing Which Broker/Dealer/Custodian to Use BICM does not permit its clients to direct it to execute transactions through a specified broker-dealer.

B. Aggregating (Block) Trading for Multiple Client Accounts If BICM buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, BICM would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. BICM would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). The Partnership is currently BICM’s only client. We generally allocate investment opportunities among our clients in a fair and equitable manner based upon, among other things, the investment objectives, guidelines and restrictions, risk profiles, financial conditions and tax status of each client. If each participating client receives less than its full allocation, then each participating client generally receives its pro rata portion of the executed order. Under certain circumstances, we have discretion to utilize alternative allocation procedures, provided that all participating clients are treated fairly and equitably.

A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) BICM may receive, but has not yet received, compensation from third-party advisers to which it directs clients. In the event BICM engages in such referrals, it would disclose the conflicts and policies related to the arrangements and related compensation, as applicable.

B. Compensation to Non – Advisory Personnel for Client Referrals BICM may, but does not currently, retain third parties via written arrangement to act as solicitors for BICM’s investment management services. All compensation with respect to the foregoing will be fully disclosed to each client to the extent required by applicable law. BICM will ensure each solicitor is properly registered in all appropriate jurisdictions.

A. Criminal or Civil Actions There are no criminal or civil actions to report.

B. Administrative Proceedings There are no administrative proceedings to report.

C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report.

A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Client portfolios are reviewed continually by Chris Colvin, Managing Member, with regard to their investment policies and risk tolerance levels. The Partnership’s administrator, Apex Group LTD, provides unaudited monthly capital account balance statements to investors in the Partnership. Also, for the Partnership, BICM provides investors with annual audited financial statements and quarterly letters.

B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events.

C. Content and Frequency of Regular Reports Provided to Clients We generally provide (or cause the administrator or auditor to provide) to investors, as soon as reasonably practicable after the end of each fiscal year, annual reports containing financial statements audited by the Partnership’s independent auditor and any other information that any investor reasonably requests relating thereto. We also provide investors with monthly performance updates, quarterly investor letters, and may provide other periodic notices and reports relating to the performance and activities of the Partnership. All such statements and reports are written.

BICM is deemed to have custody over pooled investment vehicle it manages. BICM is required to maintain the funds and securities (except for securities that meet the privately offered securities exemption in the Custody Rule under the Investment Advisers Act of 1940) over which it has (or may be deemed to have) custody with a “qualified custodian.” Qualified custodians include banks, brokers, futures commission merchants and certain foreign financial institutions. Applicable regulations impose on advisers having custody of clients’ funds or securities certain requirements concerning reports to such clients (including underlying investors) and surprise examinations relating to such clients’ funds or securities. However, an adviser need not comply with such requirements with respect to pooled investment vehicles subject to audit and delivery if each pooled investment vehicle: (i) is audited at least annually by an independent public accountant; and (ii) distributes its audited financial statements prepared in accordance with generally accepted accounting principles to their investors, all limited partners, members or other beneficial owners within 120 days of its fiscal year-end. BICM will ensure that such audits are conducted of the Partnership and that the resulting financial statements are distributed to investors. Investors should carefully review those statements for accuracy.

BICM provides discretionary investment advisory services to clients, including the Partnership. The advisory contract established with the client sets forth the discretionary authority for trading. Where investment discretion has been granted, BICM manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share.

BICM has proxy voting authority with respect to the Partnership. Accordingly, we have adopted proxy voting policies and procedures in our compliance manual. In general, our policy is to vote proxy proposals, amendments, consents or resolutions in a manner that serves the best economic interests of each applicable client, as determined in our discretion, taking into account various factors, and without regard to our interests or the interests of any other client. We may abstain from voting a proxy or a specific proxy item if we conclude that the potential benefit from voting is outweighed by the cost or if we reasonably determine that it is in the best interest of a client not to vote the proxy. Our general policy is to vote regularly recurring matters as recommended by the issuer’s board of directors, but certain circumstances may cause us to vote against such proposals (which we will decide on a case-by-case basis). Investors generally may not direct or otherwise influence our vote with respect to any particular proxy solicitation. BICM generally will promptly review proxy materials to evaluate issues presented including the identification of any material conflicts of interest involving us and the proxy voting process and make all determinations with respect to the proxy voting policy. BICM will analyze and determine whether any conflict of interest is material. A conflict of interest will be considered material to the extent that such conflict has the potential to influence our decision-making in voting a proxy. If a material conflict of interest is identified, we may use one or more methods to resolve or otherwise mitigate such conflict, including: (i) disclosing the conflict to the applicable client and investors and obtaining its consent before voting (ii) suggesting to client that it engage another party to vote the proxy on its behalf, (iii) engaging a third party

to recommend a vote with respect to the proxy based on the application of our proxy voting guidelines, or (iv) such other method as is deemed appropriate under the circumstances, given the nature of the conflict. We will maintain a written record of the method used to resolve or otherwise mitigate any material conflict of interest. Clients may obtain copies of our proxy voting policy, together with information regarding how we have voted past proxies, by contacting us.

A. Balance Sheet BICM neither requires nor solicits prepayment of more than $500 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this Brochure.

B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither BICM nor its management has any financial condition that is likely to reasonably impair BICM’s ability to meet contractual commitments to clients.

C. Bankruptcy Petitions in Previous Ten Years Neither BICM nor its principal have been the subject of a bankruptcy petition in the last ten years.