BRIDGER MANAGEMENT, LLC

Bridger Management, LLC (“Bridger”, “we”, “us”, “our” or the “Adviser”) is an investment adviser organized as a Delaware limited liability company on April 25, 2000. Bridger is managed by Roberto Mignone (the “Manager”), and principally owned by the Manager through Bridger Management II LP. Bridger currently serves as the investment adviser, with discretionary trading authority, to private, pooled investment vehicles, the securities of which are offered through a private placement memorandum to accredited investors, as defined under the Securities Act of 1933, as amended (the “Securities Act”), and qualified purchasers, as defined under the Investment Company Act of 1940, as amended (the “1940 Act”). Bridger provides discretionary investment management services to qualified investors through its private funds: •

Swiftcurrent Offshore, Ltd., a Cayman Islands exempted company (the “Swiftcurrent Offshore Fund”);

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Swiftcurrent Offshore Intermediate Fund, Ltd., a Cayman Islands exempted company (the “Swiftcurrent Offshore Intermediate Fund”);

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Swiftcurrent Partners, LP, a Delaware limited partnership (the “Swiftcurrent Onshore Fund”);

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Swiftcurrent Master Fund, Ltd., a Cayman Islands exempted company (the “Master Fund” and collectively with the Swiftcurrent Offshore Fund, the Swiftcurrent Offshore Intermediate Fund and the Swiftcurrent Onshore Fund, the “Swiftcurrent Fund”);

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Auson Holdings, LLC, a Delaware limited liability company (the “Auson Fund”);

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Shearwater Onshore LLC, a Delaware limited liability company (the “Healthcare Onshore Fund”);

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Shearwater Offshore, Ltd., a Cayman Islands exempted company (the “Healthcare Offshore Fund”); and

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Bridger Healthcare, Ltd., a Cayman Islands exempted company (the “Healthcare Master Fund” and, collectively with the Healthcare Onshore Fund and the Healthcare Offshore Fund, the "Healthcare Fund”).

The funds referenced above are collectively referred to as the “Funds”. The Healthcare Fund is in the process of being wound down and is not making new investments. Bridger’s investment decisions and advice with respect to the Funds are subject to each Fund’s investment objectives and guidelines, as set forth in its respective Confidential Memorandum, Operating Agreement, Subscription Agreement or Limited Partnership Agreement, as applicable (the “Offering Documents”). -4-

Bridger may in the future organize investment funds or manage investment funds or separately managed accounts that may follow an investment program similar to or different from the Funds’ program (such future funds and managed accounts, collectively with the Funds, the “Clients”). Bridger does not tailor our advisory services to the individual needs of any particular investor in the Funds. Except as imposed by regulatory requirements or as expressly set forth in the Offering Documents, investors may not impose restrictions on investing in certain securities or certain types of securities. We do not currently participate in any Wrap Fee Programs. As of December 31, 2025, Bridger had $485,241,877 of regulatory assets under management, all managed on a discretionary basis. We do not manage any Client’s assets on a non-discretionary basis.

Asset-Based and Performance-Based Compensation The fees and compensation applicable to each of the Funds are set forth in detail in the corresponding Offering Documents. A brief summary of the fees and compensation applicable to the Funds is provided below. We receive from the Swiftcurrent Fund a quarterly management fee (the “Management Fee”), which ranges from 1.5% to 2.0% per annum of the net asset value of a Fund and is paid from the assets of the Swiftcurrent Fund quarterly in advance, and an allocable portion of the Management Fee is deducted from each relevant investor’s account at the beginning of the relevant accounting period. In the case of an investor admitted to a Fund after the first business day of the relevant calendar quarter, the Management Fee is pro-rated based on the admission date of such investor. Effective as of January 1, 2023, Bridger has waived all future Management Fees for the Healthcare Fund. Management Fees assessed on investments in pooled investment vehicles by Bridger, its affiliates their principals, members of the immediate families of such persons or trusts or other entities for their benefit are reduced or waived entirely. Generally, a Fund will pay the Management Fee in advance. If the investment management agreement is terminated before the end of the billing period, Bridger will refund a pro rata portion of the pre-paid fee to the Fund’s investors. The Auson Fund is not charged any Management Fees. An affiliate of Bridger is entitled to an incentive allocation (the “Incentive Allocation”) from the Swiftcurrent Fund equal to 20% of any net profit allocable to each investor for such fiscal year in excess of any loss recovery with respect to such investor’s account, adjusted for contributions, withdrawals and distributions. The Incentive Allocation will be allocated as of the close of each fiscal year and on any interim redemption or withdrawal of capital by an investor. -5-

Effective as of January 1, 2023, an affiliate of Bridger waived its entitlement to receive any future Incentive Allocation from the Healthcare Fund. Incentive Allocation assessed on investments in pooled investment vehicles by Bridger, its affiliates, their principals, members of the immediate families of such persons or trusts or other entities for their benefit are reduced or waived entirely. The Auson Fund is not subject to any Incentive Allocation. Other Expenses The Funds bear their own costs and expenses, such as administrative expenses, investment expenses (e.g., brokerage commissions and expenses of outsourced trading desks, and interest expense), fees and expenses of their governing bodies, legal expenses, valuation, accounting (including without limitation the fees and expenses of any administrator retained for the Funds and the fees and expenses related to regulatory filings of the Funds, the general partner/managing member and Bridger that relate to the Funds (including by way of illustration, Form PF)), auditing and tax preparation expenses, taxes, expenses relating to the offer and sale of interests in the Funds, expenses relating to the organization of the Funds and extraordinary expenses. To the extent the Funds invest in exchange traded funds and/or private investment funds, the Funds would be subject to additional fees and expenses payable by such funds. Costs and expenses common to one or more Clients are generally paid pro rata by each Client based on net asset value, invested capital, the allocation of related time and services, or such other equitable basis as determined in the discretion of Bridger. If Client account assets are invested in a master-feeder structure, the feeder funds bear a pro rata share of the expenses associated with the related master fund. The expenses incurred in connection with a transaction that is consummated will generally be allocated among Funds and any participating third-party investors pro rata in accordance with their respective actual investments or commitments in such investment opportunity, unless Bridger determines that a different allocation methodology would be more equitable. Any expenses incurred in connection with a transaction that is not consummated will generally be allocated among the expected participants in the investment pro rata in accordance with their respective expected investment or commitment in such unconsummated investment opportunity. The Clients incur brokerage and other transaction costs when brokers are used in connection with their investments. For additional information regarding brokerage practices, please see Item 12 below.

Methods of Analysis and Investment Strategies The Adviser’s principal investment objective is to achieve risk adjusted capital growth primarily through investments in equity securities and equity related instruments. The Adviser primarily focuses the Clients’ investment activities on publicly traded securities. The Adviser’s investment strategy for the Swiftcurrent Fund is a long/short equity strategy. The Auson Fund primarily invests in private investment funds managed by third parties. The Adviser’s investment strategies rely upon in-depth, fundamental research. The Adviser generally judges each investment position on its own ability to generate profits consistent with its risk profile. The Adviser identifies investment opportunities through careful field research, quantitative screens, and its extensive investment network. Ongoing due diligence of portfolio investments includes rigorous competitive, accounting, and valuation analyses. This work is supplemented, if appropriate, by interviews with company management teams, customers, suppliers, and competitors. The Clients’ portfolios typically include both (i) long positions in securities of companies in which the Adviser believes it has identified a fundamental value driver -7-

for capital appreciation and (ii) short positions in securities of companies in which the Adviser believes there is fundamental business deterioration. The Adviser seeks to acquire long positions in companies where it has identified fundamental value drivers that have not been recognized or fully exploited by the broader investment community. Long positions will typically consist of investments in companies whose growth prospects demonstrate significant potential for high incremental returns on investment, with welldefined competitive advantages. Such advantages may include high barriers to entry, large market opportunities, and strong management teams. The Adviser may also seek to acquire long positions in companies whose valuation reflects a disproportionate discount to its private market value or peer group, where the Adviser has identified a catalyst for capital appreciation. These catalysts may include a restructuring, spin-off, or change in management control. The Adviser believes that short positions not only serve as a hedge against volatile market conditions, but also generate profit opportunities for the Clients. Because of the risks inherent in short selling, the Adviser devotes significant effort to generating short ideas through its field research and proprietary screens. The Adviser may seek to acquire a short position when the Adviser determines that the investment community has a fundamental misperception about a company’s business prospects, and the Adviser has identified a timeline and catalyst for a correction in valuation. Such catalysts may include product failures, customer losses, or overestimated market potential. Short positions may also be taken in companies with balance sheets that reflect significant business risk. Such companies may have deteriorating fundamentals, poor cash generation capabilities, and reliance upon debt financing. The Adviser may seek to acquire securities of non-U.S. issuers and a variety of fixed income and equity or equity related instruments, including swaps, options, futures and forward contracts, as well as any other instruments (such as private investment funds managed by third party investment managers) and use leveraging and hedging devices deemed appropriate by the Adviser, in order to seek to maximize returns and minimize risk. The method of analysis and the investment strategies summarized in this Item 8 represent the Adviser’s current intentions. Depending on conditions and trends in securities markets and the economy generally, the Adviser may pursue other objectives or employ other techniques it considers appropriate and in the best interests of the Clients. Investment Risks Investing in securities involves a substantial degree of risk of loss. Bridger’s investment program is speculative and entails investment and market-related risks. The practices of short selling, leverage and other investment techniques which Bridger employs on behalf of the Clients can, in certain circumstances, substantially increase any adverse impact to which the Clients’ investment portfolios may be subject. Accordingly, the Clients could experience substantial losses under certain circumstances. Clients and investors in the Funds must be prepared to bear the risk of a complete loss of their investments.

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Below is a list of certain risks associated with Bridger’s investment strategies and methods of analysis. Additional risks associated with an investment in the Funds are disclosed in the Offering Documents of the applicable Funds. Investment and Trading Risk. While investments in companies in certain industries offer the opportunity for significant capital gains, such investments involve a high degree of business, financial, technological and regulatory risk which can result in substantial losses. Moreover, the Clients’ investment portfolios may include investments particularly subject to increased risk because they are in companies at an early stage of development, which have been or may go into bankruptcy, acquired as leverage buyouts subject to interest rate fluctuations, or engaged in highly competitive industries dominated by companies with substantially greater resources. The stock market has experienced volatility which affected the securities of companies. As a result, the performance of Clients’ accounts may experience substantial volatility and potential for loss. Risks of Investing in the Healthcare Sector. Investments in companies in the healthcare sector involve a high degree of business, financial, technological and regulatory risk which can result in substantial losses. These risks include, but are not limited to, the following: (i) certain of these companies may have limited operating histories; (ii) certain of these companies may not have sufficient management or marketing personnel with appropriate scientific or medical training, which may slow or impede the companies’ growth; (iii) obtaining approval for new products from governmental agencies can often be a lengthy and expensive process, the outcome of which can be uncertain; (iv) certain of these companies may become involved in lawsuits related to their patents or products; (v) products produced by certain of these companies may become obsolete; (vi) government policies and regulations applicable to certain of these companies may change in ways that adversely affect them; (vii) investor sentiments and preferences with regard to healthcare sector investments (some of which are generally perceived as risky) may change, which may have an adverse effect on the price of underlying securities; and (viii) U.S. stock markets may become more volatile, which may affect the prices of healthcare company securities and, in turn, may cause the performance of the Funds or a Client account to experience substantial volatility. Clients may invest in the securities of healthcare companies engaged in the development of products or technologies or that are conducting clinical trials on products. The development of products generally is a costly and time-consuming process. There can be no assurance that the research or product development efforts of such companies will be successfully completed, that specific products can be manufactured in adequate quantities at an acceptable cost and with appropriate quality, or that such products can be successfully marketed or achieve customer acceptance. The research, development, pre-clinical and clinical trials, manufacturing, and marketing of healthcare products are subject to extensive regulation by numerous governmental authorities in the U.S. and other countries. Obtaining product approval often requires the submission of extensive preclinical and clinical data, information about product manufacturing processes, and inspection of facilities and supporting information for each therapeutic indication to establish a product candidate’s safety and efficacy. Varying -9-

interpretations of the data obtained from preclinical and clinical testing could delay, limit or prevent regulatory approval of a product. The process of obtaining and maintaining regulatory approvals may vary and involves substantial regulatory discretion, is expensive and often takes many years, if approval is obtained at all. Many highly promising products ultimately fail to prove safe and effective. There can be no assurance that products under development will ever be approved by the appropriate governmental authorities in the U.S. and other countries. Healthcare companies generally depend heavily upon intellectual property for their competitive position. Intellectual property rights in the fields of medical devices, diagnostics, pharmaceuticals and biotechnology are highly uncertain and may involve complex legal and scientific questions. There can be no assurance that a healthcare company will be able to obtain patents for key inventions. Moreover, healthcare companies may not be able to obtain additional issued patents relating to their products, methods, processes, services or other technologies. Even if issued, patents may be challenged, narrowed, invalidated or circumvented, or others may obtain patents claiming aspects similar to those covered by such patents and patent applications, which factors could limit a company’s ability to stop competitors from marketing similar products or services, limit the length or term of patent protection they may have for their products or services, and expose them to substantial costs and risks in litigation and administrative proceedings and drain resources. Changes in either patent laws or in interpretations of patent laws in the U.S. and other countries may diminish the value of a company’s intellectual property or narrow the scope of its patent protection. The success of many companies in the healthcare industry depends on governmental and third-party reimbursement policies that are under constant review and are subject to change at any time. Any such change could adversely affect a healthcare company’s viability. The testing and marketing of pharmaceutical, medical products and technologies entail an inherent risk of product liability. Accordingly, companies in the healthcare industry may be exposed to potential liability risks inherent in the testing, manufacturing, marketing and sale of healthcare products and/or the provision of healthcare services. A liability claim or the imposition of liability may have an adverse effect on the market prices of a company’s securities. Healthcare is a very litigious industry. Companies in the healthcare industry may be subject to lawsuits, including without limitation lawsuits brought against them by governmental agencies (e.g., HHS, OIG, DOJ and CMS), competitors, customers, suppliers and former employees. Any such lawsuits could adversely affect these companies, which could have an adverse effect on a Client’s portfolio. Financial Market Fluctuations. General fluctuations in the market prices of securities may affect the value of the investments held by the Clients. Instability in the securities markets may also increase the risks inherent in the Clients’ investments. Price movements of the instruments in which the Clients’ assets may be invested may be influenced by, among other things, interest rates, general economic conditions, the condition of the financial markets, developments or trends in any particular industry, the financial condition of the -10-

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Bridger provides investment advisory services to the Clients. Investment advice is provided directly to the Funds, subject to the discretion and control of the general partner/managing member or the board of directors of the applicable Fund, and not individually to the investors in the Funds. 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, endowments, corporations, limited partnerships, limited liability companies, pension funds, and similar entities. With respect to a Client that is a pooled investment vehicle, any initial and additional subscription minimums are disclosed in the Offering Documents for the pooled investment vehicle. Bridger does not have any standard requirements for opening or maintaining a separately managed account and may, in its discretion, require a different minimum for any Client account.

As disclosed in Item 5, “Fees and Compensation,” affiliates of Bridger are entitled to receive Incentive Allocation based on the performance of the Funds. This creates an incentive for Bridger to cause the Funds to make more speculative investments than they would otherwise make in the absence of the Incentive Allocation. Certain Client accounts managed by Bridger hold illiquid investments for which we receive Incentive Allocation only upon their sale or deemed realization. To the extent we are entitled to -6-

Incentive Allocation upon the sale or deemed realization of illiquid investments, we may have an incentive to delay the realization of an illiquid investment. Bridger may also manage or advise other Client accounts in the future that are subject to different fee and compensation arrangements than the Funds. This may create potential conflicts where Bridger is entitled to receive higher fees and performance-based compensation from certain Clients than from other Clients (including the Funds), as Bridger has an incentive to favor Clients that pay higher fees and performance-based compensation. Bridger has implemented policies and procedures intended to address these conflicts of interest. A description of Bridger’s allocation policy is included in Item 11 of this Brochure.

Affiliates of Bridger serve as the general partner of two of the Funds and another affiliate serves as the managing member of another Fund. For a description of material conflicts of interest created by these relationships, as well as a description of how such conflicts are addressed, please see Item 11 below.

Trading Code of Ethics Bridger has adopted a Code of Ethics (the “Code of Ethics”) that generally prohibits persons associated with Bridger from using for their own benefit (or the benefit of anyone other than a client) information about Bridger’s trading or investment recommendations for a client or take advantage of investment opportunities that would otherwise be available for a client. The Code of -23-

Ethics covers each of Bridger’s employees and any other natural person who is subject to Bridger’s supervision and control who (i) has access to nonpublic information regarding a Client’s purchase or sale of securities, (ii) who is involved in making securities recommendations to a Client or (iii) who has access to securities recommendations to a Client that are not public (collectively, the “Covered Persons”). The Code of Ethics requires all Covered Persons to comply at all times with applicable U.S. federal and state securities laws, the rules of any exchange, and the rules of any applicable self-regulatory organization. The Code of Ethics outlines written policies regarding personal trading in any brokerage or trading account in which a Covered Person, or any member of such Covered Person’s immediate family, has any direct or indirect control or beneficial ownership. The personal trading policies adopted by Bridger generally prohibit all personal trading of publicly-traded securities (including trading for accounts in which such Covered Person has any beneficial ownership or control or any accounts of any members of such Covered Person’s family/household) other than registered open-end mutual funds, broad-based exchange-traded funds and exchange-traded funds where the underlying investments are currencies, physical commodities or government obligations, bank certificates of deposit and interests in money market accounts. An employee is required to disclose all of his or her personal account holdings to Bridger upon employment. Covered Persons must provide Bridger with certain quarterly and annual securities holdings reports and, subject to certain exemptions, employees of Bridger must provide Bridger with contemporaneous duplicate copies of all transaction confirmation statements and account statements. The Code of Ethics, and any supplement, amendment or restatement, is distributed to each Covered Person. Each Covered Person is required to read the Code of Ethics and certify that he or she has read the Code of Ethics and understands the materials contained therein. Adherence to the Code of Ethics, both in letter and in spirit, is fundamental and an absolute condition of affiliation with or employment by Bridger. All Covered Persons are required to promptly report all material violations and any apparent material violations of the Code of Ethics to Bridger’s Chief Compliance Officer (“CCO”). Employees who violate the Code of Ethics may be subject to disciplinary actions, including disgorgement of profits, censure, suspension or termination of employment. This summary of the Code of Ethics is qualified in its entirety by the Code of Ethics. Clients and prospective clients may request a copy of Bridger’s Code of Ethics by calling (212) 984-2114 or emailing investorrelations@bridgercapital.com. Conflicts of Interest The material reportable conflicts of interest encountered by the Clients include those discussed below, although the discussion below does not necessarily describe all of the conflicts that may be faced by the Clients. Other conflicts may be disclosed throughout this brochure and in the Offering Documents of the Funds and such materials should be read in their entirety. Bridger has adopted policies and procedures to address and mitigate conflicts of interest, including those described below. Conflicts Relating to Bridger’s Management of the Clients and Other Activities. Bridger, its affiliates and its management persons will sometimes give advice or take action with -24-

respect to a Client that differs from the advice given with respect to another Client. In addition, Bridger and its employees are not obligated to devote their full time to the Clients, but will devote such time as in Bridger’s judgment the conduct of a Client’s business reasonably requires. Conflicts Relating to Investments by the Clients. Bridger advises Clients (including Funds in which Bridger and its personnel have an interest) that have similar investment objectives and will make investments or sell investments on behalf of the Clients in the same securities or other instruments, sectors or strategies. This will create potential conflicts particularly where there is limited availability or limited liquidity for those investments. These potential conflicts of interest are exacerbated where Bridger is entitled to receive higher fees and performance-based compensation from certain Clients than from other Clients, as Bridger has an incentive to favor Clients that pay higher fees and performance-based compensation. When it is determined that it would be appropriate for one of the Clients to participate in an investment opportunity, Bridger will seek to establish positions for all participating Clients on an equitable basis, taking into account such factors as the relative amounts of capital available for new investments and the investment programs and portfolio positions of the clients for which participation is appropriate. Orders for public securities may be combined for all participating Clients, and if any such order is not filled at the same price, they may be allocated on an average price basis. Similarly, if an order for a public security on behalf of more than one Client cannot be fully executed under prevailing market conditions, securities may be allocated among the participating Clients on a basis which Bridger or its affiliates consider equitable. From the standpoint of a Client, simultaneous identical portfolio transactions for such Client and other accounts managed by Bridger may tend to decrease the prices received, and increase the prices required to be paid, by such Client for its portfolio sales and purchases. Bridger will attempt to allocate investment opportunities in a manner which is in the best interests of each Client. Where Bridger believes an investment opportunity is appropriate for the Clients, Bridger will allocate the investment opportunity on a basis that it believes is fair and equitable to each Client. However, there can be no assurance that an investment opportunity which comes to the attention of Bridger will be allocated equally among Clients and any particular Client may be unable to participate in such investment opportunity or participate only on a limited basis. For instance, the investment guidelines of a Fund limit the amount the Fund may invest in illiquid, difficult to value or private investments. There may be circumstances under which Bridger will consider participation by other investors (including the general partner/managing member, Bridger or their respective affiliates and employees) in investment opportunities in which Bridger does not intend to invest, or intends to invest only on a limited basis, on behalf of a particular Client. Conflicts may arise in determining the amount of an investment to be allocated among the Clients, and the portion to be allocated for its own account or those of its affiliates and employees. Bridger and its affiliates evaluate for each Client a variety of factors which may be relevant in determining whether a particular situation or strategy is appropriate and feasible for the Client at a particular time, including the nature of the investment opportunity taken in the context of the other investments at the time, the liquidity of the investment relative to the needs of the particular entity, the investment or regulatory limitations on such Client or particular entity, the tax considerations of the particular entity and its investors, and the -25-

transaction costs involved. These considerations may differ for each Client in the context of any particular investment opportunity. If Bridger determines that an investment opportunity is not appropriate or feasible for a Client, there may be cases where the general partner/managing member, Bridger or their respective affiliates and employees receive an allocation of an investment opportunity when a Client does not. To address these types of conflicts, Bridger has adopted policies and procedures under which it will allocate investment opportunities in a manner that it believes is consistent with its obligations as an investment adviser. Other situations may also occur where a Client could be disadvantaged because of the activities conducted by Bridger for other Clients. Such situations may be based on, among other things: legal restrictions on the combined size of positions which may be taken for all accounts managed by Bridger, thereby limiting the size of a particular Client’s position; the difficulty of liquidating an investment for more than one account where the market cannot absorb the sale of the combined positions; and the determination that a particular investment is warranted only if hedged with an option or other instrument and there is a limited availability of such options or other instruments. Instances may also arise where Bridger determines an investment opportunity to be suitable for all Clients but the market is too illiquid to enable each Client to participate to the extent desired. Affiliated Investments. Bridger, the general partner/managing member and their affiliates (or their principals, members and current or former employees, and members of the immediate families of such persons, or trusts or other entities for their benefit) may invest in certain Funds, and may make decisions with respect to such investment (including to liquidate or sell such investment) that could adversely affect a Fund or other investors. In addition, after any Incentive Allocation is allocated to an affiliate of Bridger or its designee(s), such amounts may remain in a Fund and will participate in the performance of the Fund. Such affiliated investments (together with any Incentive Allocation amounts reinvested in a Fund) currently constitute a substantial portion of certain Funds’ net asset value and may be withdrawn for any reason without notice to investors. Certain affiliated investments may be withdrawn at month-end without notice to investors or Clients. Co-Investment Opportunities. From time to time, Bridger may identify an investment opportunity that it believes is attractive but too large to allocate solely to Client accounts (each, a “Co-Investment Opportunity”). A Co-Investment Opportunity may be made through a special purpose vehicle or other structure (each, a “Co-Investment Vehicle”). Alternatively, Bridger may establish a separate class of interests of a Fund to invest in a Co-Investment Opportunity. Bridger will determine in its sole discretion which investments have excess capacity and may be allocated to such Co-Investment Vehicles. Generally, Bridger has broad discretion in determining to whom and in what relative amounts to allocate Co-Investment Opportunities. In allocating Co-Investment Opportunities, Bridger may give preference to certain investors based on various criteria as determined in Bridger’s sole discretion. Conflicts Relating to Directorships on Boards of Portfolio Companies. Bridger and its affiliates and their principals and employees serve as directors with respect to Portfolio -26-

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Factors Considered in Selecting or Recommending Broker-Dealers for Client Transactions Bridger seeks to obtain best execution for brokerage transactions for the Clients. Bridger considers the following factors in selecting and approving broker-dealers to executed trades for Client accounts: 

Quality of execution, clearance and error/dispute resolution;

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Reputation, financial strength, and stability;

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Block trading and block positioning capabilities;

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Willingness to execute difficult transactions;

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Willingness and ability to commit capital;

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Access to underwritten offerings and secondary markets;

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Ongoing reliability;

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Overall costs of a trade (i.e., net price paid or received) including commissions, markups, mark-downs or spreads in the context of Bridger’s knowledge of negotiated commission rates currently available and other current transaction costs;

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Nature of the investment opportunities and available market makers;

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Desired timing and volume of trading activity size of trade;

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Confidentiality of trading activity;

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Market intelligence about trading activity; and

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The receipt of prime brokerage and related services, including introductions to management and research and industry information.

Bridger has established an operating committee that, among other things, is responsible for reviewing broker-dealers for eligibility to effect transactions and for reviewing broker-dealer trading volumes, prices, commissions, other transaction costs and the overall quality of execution. Research and Other Soft Dollar Benefits -30-

In selecting brokers to effect portfolio transactions in public securities for the Clients, Bridger seeks best execution and considers the factors listed above. Bridger need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Accordingly, if Bridger determines in good faith that the amount of commissions charged by a broker is reasonable in relation to the value of the research and brokerage services provided by such broker, the Clients may pay commissions to such broker in an amount greater than the amount another broker might charge. Section 28(e) of the Securities Exchange Act of 1934, as amended, is a “safe harbor” that permits an adviser to use commissions or “soft dollars” to obtain research and brokerage services that provide lawful and appropriate assistance in the investment decision-making process. Bridger limits the use of “soft dollars” to obtaining research and brokerage services which constitute research and brokerage within the meaning of Section 28(e). Research services within Section 28(e) may include, but are not limited to, research reports (including market research); certain financial newsletters and trade journals; software providing analysis of securities portfolios; corporate governance research and rating services; attendance at certain seminars and conferences; discussions with research analysts; meetings with corporate executives; consultants’ advice on portfolio strategy; data services (including services providing market data, company financial data and economic data); advice from brokers on order execution; and certain proxy services. Brokerage services within Section 28(e) may include, but are not limited to, services related to the execution, clearing and settlement of securities transactions and functions incidental thereto (i.e., connectivity services between Bridger and a broker-dealer and other relevant parties such as custodians); trading software operated by a broker-dealer to route orders; software that provides trade analytics and trading strategies; software used to transmit orders; clearance and settlement in connection with a trade; electronic communication of allocation instructions; routing settlement instructions; post trade matching of trade information; and services required by the SEC or a selfregulatory organization such as comparison services, electronic confirms or trade affirmations. In the last fiscal year, Bridger used soft dollars to pay for research and brokerage services in most of the foregoing categories within Section 28(e). The costs of these services would have been paid for or reimbursed by the Clients directly if soft dollars had not been used to pay for such services. In some instances, Bridger may receive a product or service that may be used only partially for functions within Section 28(e) (e.g., an order management system, trade analytical software or proxy services). In such instances, Bridger will make a good faith effort to determine the relative proportion of the product or service used to assist Bridger in carrying out its investment decisionmaking responsibilities and the relative proportion used for administrative or other purposes outside Section 28(e). The proportion of the product or service attributable to assisting Bridger in carrying out its investment decision-making responsibilities will be paid through brokerage commissions generated by client transactions and the proportion attributable to administrative or other purposes outside Section 28(e) will be paid for by Bridger from its own resources. In order to mitigate the potential conflicts described above, Bridger requires all requests for payment with soft dollars to be reviewed and approved by Bridger’s CCO. In addition to using brokers as “agents” and paying commissions, Bridger may cause the Clients to buy or sell securities directly from or to dealers acting as principals at prices that include markups or markdowns, and may buy securities from underwriters or dealers in public offerings at prices that include compensation to the underwriters and dealers. -31-

Brokers sometimes suggest a level of business they would like to receive in return for the various services they provide. Actual brokerage business received by any broker may be less than the suggested allocations, but can (and often does) exceed the suggestions, because total brokerage is allocated on the basis of all the considerations described above. Bridger will not make any firm commitments to brokers regarding minimum commissions to be generated by the Clients’ trading. Research and brokerage services obtained by the use of commissions arising from Client transactions may be used by Bridger in its other investment activities and thus, a particular Client may not necessarily, in any particular instance, be the direct or indirect beneficiary of the research or brokerage services provided. Although Bridger makes a good faith determination that the amount of commissions paid is reasonable in light of the products or services provided by a broker, commission rates are generally negotiable and thus, selecting brokers on the basis of considerations that are not limited to the applicable commission rates may result in higher transaction costs than would otherwise be obtainable. The receipt of such products or services and the determination of the appropriate allocation in the case of “mixed use” products or services create a potential conflict of interest between Bridger and the Clients. Bridger has engaged soft dollar brokers to aggregate commission credits that arise from Client transactions executed through various brokers. As part of their services, the soft dollar brokers may use soft dollar commissions to pay the entire amount of a “mixed use” product or service and then invoice Bridger for the proportion attributable to administrative or other purposes outside Section 28(e). The soft dollar brokers receive a portion of the commissions for their services rendered. Brokerage for Client Referrals Bridger may place transactions with a broker or dealer that (i) provides Bridger (or an affiliate) with the opportunity to participate in capital introduction events sponsored by the broker-dealer or (ii) refers investors to Clients, if otherwise consistent with seeking best execution; provided Bridger is not selecting the broker-dealer in recognition of the opportunity to participate in such capital introduction events or the referral of investors. Trade Aggregation In managing the Clients, Bridger will generally aggregate trades, subject to best execution. Aggregation (or “bunching”) describes a procedure whereby an investment adviser combines the orders of two or more Clients into a single order for the purpose of obtaining better prices and lower execution costs. Bridger allocates multi-Client trades in a manner Bridger believes to be in each Client’s best interests. When the Funds participate in a multi-Client trade, Bridger will allocate the trade, as between the Funds, on a basis that it believes is fair and equitable to each Fund taking into account the best interests and account-specific mandates of each Fund as well as other pertinent factors. Each Client that participates in the allocation of an aggregated order will participate at the average price for all of the participating transactions necessary to fill the trade order, with aggregated transaction costs shared equally based on each Client’s participation in the transaction.

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These trade allocation and aggregation procedures apply to investments that are made by Bridger through aggregate or block trades for the Clients. In certain situations, regulatory, market, and/or portfolio management considerations may render the participation by a Client in an investment impermissible or inadvisable. Trade and Other Errors Bridger may make mistakes with respect to investment management decisions, trading, processing or other functions performed by the Adviser or its affiliates. Bridger seeks to ensure that each trade error is corrected in a prompt and efficient manner to minimize any adverse effect to the Clients. However, not all mistakes are considered trade errors compensable by Bridger. The cost of any trade errors is borne by the Clients unless a trade error is the result of, in the case of the Funds, fraud, willful misconduct, gross negligence or breach of Bridger’s fiduciary duty.

Bridger does not receive any economic benefit from someone who is not a client for providing investment advice or other advisory services to its clients. Bridger does not currently pay compensation for client referrals.

Bridger provides continuous advisory services to the Clients and reviews Client accounts on an ongoing basis. The Manager is the principal portfolio manager of the Swiftcurrent Fund. Blake Goodner is the portfolio manager of the Healthcare Fund. Bridger provides reports in accordance with the applicable Client’s Offering Documents. Bridger currently provides monthly, quarterly and annual written reports containing various financial data and information to Fund investors. The annual audited financial statements of the applicable Fund are sent to investors within 120 days after the end of each fiscal year. Certain Fund investors may receive additional information or reports as noted in Item 11 (see Conflicts Relating to Different Information), and, therefore, may be able to act on such information before other Fund investors.

Bridger is generally deemed to have custody over the assets of the Funds. Bridger maintains the Funds’ assets with qualified custodians to the extent required by applicable law. The Funds are subject to an annual audit and the financial statements are distributed to each investor within 120 days of the Funds’ fiscal year ends. An independent public accountant that is registered with the Public Company Accounting Oversight Board prepares the audited financial statements in accordance with U.S. generally accepted accounting principles.

Bridger provides discretionary investment advice directly to the Funds pursuant to a written investment management agreement with each Fund, subject to the discretion and control of the general partner/managing member or board of directors of the applicable Fund and not directly to -33-

the investors in the Funds. Powers of attorney and any restrictions on Bridger’s authority are set forth in the Offering Documents of the Funds.

Bridger has adopted proxy voting policies and procedures that set forth the principles and procedures by which Bridger votes or gives consent with respect to securities owned by the Clients for which Bridger exercises voting authority and discretion. Bridger’s proxy voting policies and procedures have been designed to help ensure that Bridger votes proxies in the best interest of the Clients. The Clients generally cannot direct Bridger’s vote. Bridger has determined that the most efficient and effective method in which to vote is through the engagement of an independent third-party proxy voting service (the “Proxy Service”). Generally, Bridger votes with management or in accordance with the recommendations of the Proxy Service, except in certain circumstances. For the avoidance of doubt, Bridger retains the authority to vote, has not delegated such authority to the Proxy Service or any other party, and may abstain or vote against any Proxy Service recommendation if the relevant portfolio manager determines that doing so is in the best interests of the relevant Client and otherwise consistent with Bridger’s voting policies and procedures. Bridger has designated certain employees to review the Proxy Service’s recommendations regarding upcoming votes and notify the portfolio manager or analyst of the upcoming votes. The portfolio manager or analyst will make his vote recommendations and if such recommendations are different from the Proxy Service’s recommendations, such portfolio manager or analyst will be required to document his rationale for overriding the Proxy Service’s recommendations. The designated employees will inform the portfolio manager of any analyst votes which are inconsistent with the Proxy Service’s recommendations and the portfolio manager, or their designee, will resolve any inconsistencies in a way that reflects the relevant Client’s best interest. The CCO has the responsibility to monitor voting decisions for any conflicts of interest, regardless of whether they are actual or perceived. If a conflict of interest were to arise, Bridger will take no action, abstain from voting or vote in the manner recommended by the Proxy Service. Clients may request a copy of Bridger’s proxy voting policies and procedures and information about how Bridger voted their securities by calling (212) 984-2114 or emailing investorrelations@bridgercapital.com. Bridger has retained an independent third-party class action service (“Class Action Service”) to identify whether the Clients are eligible to (i) participate in a recovery achieved through a class action or (ii) opt out of the class action and separately pursue their own remedy. If the Clients participate in a class action lawsuit and ultimately receive proceeds, the proceeds typically are credited to the Clients for the benefit of their current investors, after a percentage of the proceeds are paid to the Class Action Service as part of its compensation. Employees must notify the CCO if they are aware of any material conflicts of interest associated with a Client’s participation in a class action and the CCO will determine an appropriate course of action.

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Bridger does not require or solicit prepayment of fees six months or more in advance. In addition, Bridger is not currently aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to the Clients and Bridger has not been the subject of a bankruptcy petition at any time since its inception. Item 19: Requirements for State-Registered Advisers