Burkehill Global Management

Burkehill is organized as a Delaware limited partnership with a principal place of business in New York, New York. Burkehill was founded in July 2021 by Christopher Rich (the “Principal”), who principally owns and controls (directly or indirectly), and serves as Managing Partner of, Burkehill. Burkehill serves as the investment adviser to pooled investment vehicles (each, a “Fund” and, collectively, the “Funds”), each of which relies on the Section 3(c)(7) exemption from registration under the Investment Company Act of 1940, as amended (the “Investment Company Act”). Burkehill commenced its investment advisory business on January 3, 2022. Burkehill HK, a wholly-owned subsidiary of Burkehill, is a “relying adviser” with respect to Burkehill (i.e., an investment adviser eligible to register with the SEC that, as reflected in Part 1A of Burkehill’s Form ADV, is relying on Burkehill’s registration rather than filing its own Form ADV). Burkehill HK is also principally owned indirectly by the Principal. Burkehill HK provides services to the Funds pursuant to a services agreement between Burkehill HK and Burkehill. The description of Burkehill’s business and activities throughout this Brochure includes the business and activities of Burkehill HK. The Funds are as follows: •

Burkehill Fund Ltd is incorporated as an exempted company with limited liability in the Cayman Islands formed in June 2021 (the “Arleigh Fund”). Burkehill has full investment discretion over the Arleigh Fund’s investable assets pursuant to an investment management agreement and certain other related agreements. Burkehill commenced advising the Arleigh Fund in January 2022.

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Burkehill Master Fund LP (the “Master Fund”) is an exempted limited partnership established and registered in July 2023 under the laws of the Cayman Islands. The Master Fund was organized for the purpose of trading and investing in securities and is a “master” fund in a “master-feeder” fund structure with two feeder funds: o Burkehill Partners LP (the “U.S. Feeder”), a Delaware limited partnership established primarily for investments by U.S. taxable investors, and o Burkehill International Ltd (the “Cayman Feeder” and together with the U.S. Feeder, the “Feeder Funds”), an exempted company incorporated in the Cayman Islands established primarily for investments by U.S. tax-exempt and non-U.S. investors.

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Burkehill Helios Partners LP (“Helios”) is a Delaware series limited partnership that was organized in November 2024. Each series of limited partnership interests of Helios (each, a “Series”) is generally expected to be invested in a single investment idea or investment strategy at any given time determined by Burkehill. Each Series may have an investment program that overlaps with the other Funds’ respective investment programs, and Helios and the other Funds may invest in the same securities. As of the date of this Brochure, Helios has not accepted any subscriptions from investors and has not made any investments.

The U.S. Feeder is a limited partner of the Master Fund. The Cayman Feeder invests in the Master Fund indirectly through Burkehill Intermediate Fund LP, a Cayman Islands exempted limited partnership (the “Intermediate Fund” and collectively with the Master Fund and the Feeder Funds, the “Admiral Funds”), which is also a limited partner of the Master Fund. Burkehill expects to invest most of the investable assets of the Feeder Funds (directly or indirectly through intermediate entities) in limited partnership interests of the Master Fund, but reserves the right to invest investable assets of the Feeder Funds independent from the Master Fund (directly or indirectly through intermediate entities). Through this mechanism, the Master Fund acts as a central trading and investment mechanism for the Feeder Funds. Burkehill Fund GP LLC (the “General Partner”) is the general partner of the Master Fund, the U.S. Feeder, the Intermediate Fund and Helios. Unless and only to the extent that the context otherwise requires, references to “Burkehill”, “we”, “us”, “our” and similar terms herein are deemed to include references to the General Partner as well. As of December 31, 2025, we have regulatory assets under management of $3,536,880,964, including a commitment by one of the Arleigh Fund’s investors to contribute amounts to the Arleigh Fund, which is cancellable under certain conditions. All of our assets under management are managed on a discretionary basis. This Brochure does not constitute an offer to sell or a solicitation of an offer to buy any securities. The Funds’ securities are offered and sold on a private placement basis under exemptions promulgated under the Securities Act of 1933, as amended (the “Securities Act”) and other applicable state, federal or non-U.S. laws. Significant suitability requirements apply to prospective investors in the Funds, including requirements that they be “accredited investors” as defined in the Securities Act and “qualified purchasers” as defined in the Investment Company Act. Persons reviewing this Brochure should not construe this as an offer to sell or a solicitation of an offer to buy the securities of the Funds described herein. Our investment decisions and advice with respect to the Funds are subject to the Funds’ respective investment objectives, guidelines, and other terms as set forth in the confidential private placement memoranda, limited partnership agreements and other governing documents applicable to the Funds, and investor agreements (including side letters) (collectively, the “Governing Documents”). Burkehill provides investment advice directly to the Funds and not individually to the Funds’ investors. The investment advisory services provided to a Fund are based on the objectives and restrictions set forth in such Fund’s Governing Documents. Please see Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss for a description of the investment strategies employed by Burkehill on behalf of the Funds and their related risks. See also Item 16: Investment Discretion below. Burkehill does not currently participate in any Wrap Fee Programs.

The fees applicable to the Funds are set forth in detail in their respective Governing Documents. A brief summary of such fees is provided below. Investors and prospective investors are advised to review the Funds’ Governing Documents for a more comprehensive description of applicable fees and expenses. Neither Burkehill nor its employees accept compensation, including sales charges or service fees, from any person for the sale of securities or other investment products. The Arleigh Fund The Arleigh Fund or an affiliate of the Arleigh Fund pays to Burkehill an annual performancebased incentive fee, as well as an annual fixed base fee (which ultimately reduces the performancebased fee on a dollar-for-dollar basis). The Arleigh Fund bears certain expenses incurred in connection with services provided by Burkehill on behalf of the Arleigh Fund in accordance with its Governing Documents, including, without limitation, an amount to cover certain budgeted operations-related expenses of Burkehill, including certain employee compensation expenses. The Admiral Funds Burkehill is entitled to receive from the Admiral Funds both asset-based compensation in the form of management fees and performance-based compensation in the form of incentive fees. We may, in our sole discretion, waive all or part of the management fees and/or incentive fees with respect to any investor in the Admiral Funds. Investors in the Admiral Funds are provided with detailed disclosure in the Admiral Funds’ Governing Documents as to how the relevant management fees and incentive fees are calculated and charged. For the Admiral Funds, management fees are generally deducted in advance on a quarterly basis and incentive fees are generally deducted at the end of a performance period or upon the withdrawal or redemption of capital, as more fully described in the Admiral Funds’ Governing Documents. Management fees paid by the Admiral Funds are generally not refundable. Fees and compensation paid to Burkehill or its affiliates by the Admiral Funds are generally deducted from the assets of the Admiral Funds. All current and potential investors in the Admiral Funds should review the Governing Documents of the Admiral Funds in conjunction with this Brochure for more complete information on the fees and compensation payable with respect to a particular Admiral Fund investor. The Admiral Funds bear, or reimburse Burkehill and/or the General Partner for advancing, the Admiral Funds’ expenses, to the maximum extent permitted by applicable law, including, without limitation, the following: (i) expenses related to the research, execution and monitoring of actual and prospective investments (whether or not consummated) and the consummation of investments,

including, without limitation, the following: third-party investment sourcing fees; consulting fees; expert fees; fees and expenses of and related to obtaining research, analytics and market data (including, without limitation, third-party data sources and any information technology hardware, software and data subscriptions (such as Bloomberg) or other technology incorporated into the cost of obtaining such research and market data); due diligence expenses including, without limitation, consulting and appraisal fees; investment- and research-related travel expenses (consistent with Burkehill’s policies, including first and business class fares and non-standard airfare costs to the extent necessary); any outsourced trading provider fees; brokerage and prime brokerage fees, commissions and expenses (including the costs of negotiating, documenting and/or amending agreements with prime brokers, ISDAs and other agreements with trading and financing counterparties); expenses relating to borrowing securities to be sold short; clearing and settlement charges; custodial fees and expenses; bank service fees; interest expenses and other borrowing costs; fees and expenses of proxy research and voting services; broken deal expenses; fees and expenses of third-party professionals, including, without limitation, consultants, investment bankers, attorneys, accountants and service providers who, in each case, provide services to the Funds or provide services to Burkehill, the General Partner or the Principal (on matters that would not have arisen but for their respective advisory relationships with the Admiral Funds); and expenses relating to engagement with a company irrespective of the outcome of such engagement, such as shareholder and management communication, soliciting proxies, hiring proxy advisory consultants, hosting shareholder forums, hiring public relations consultants and proposing or nominating directors or executives, including sourcing, recruiting, standby and indemnification and other expenses, regardless of whether the nomination is successful; (ii) organizational fees and expenses and fees and expenses incurred in connection with the offering and sale of limited partnership interests of the U.S. Feeder and shares of the Cayman Feeder, including, without limitation, the following: the preparation and amendment of the Admiral Funds’ Governing Documents (including the investment management agreement between the Admiral Funds and Burkehill); fees and expenses of Burkehill incurred in connection with “world sky” matters and private placement regimes, including the European Alternative Investment Fund Managers Directive, and Form D and blue sky and similar fees and expenses; placement fees and other charges payable to dealers or local representatives in order to comply with local securities distribution laws and regulations; and expenses incurred in connection with negotiating, documenting and complying with provisions of side letter agreements with investors; (iii) operational expenses, including, without limitation, the following: fees and expenses relating to information technology hardware, software or other technology (including, without limitation, costs of software licensing, implementation, data management and recovery services and custom development) used to research investments, evaluate and manage risk, facilitate valuations, facilitate accounting functions, facilitate compliance with the rules of any self-regulatory organization or applicable law (including, without limitation, reporting obligations) in connection with the activities of the Admiral Funds, and facilitate and manage the order execution of securities or otherwise manage the Admiral Funds (such as portfolio management systems and order management systems); fees and expenses of third-party risk management products, models and services; third-party administrative fees and expenses, including fees and expenses of the Administrator and any middle and/or back office service provider; fees and expenses of third-party professionals, including, without limitation, consultants, valuation service providers, attorneys, accountants and tax preparers; third-party audit and tax preparation expenses; insurance expenses, including, without limitation, premiums for cybersecurity insurance and liability insurance

(including directors and officers liability insurance and errors and omission insurance) covering the Admiral Funds, the General Partner, Burkehill and the current or former principals, officers, employees, managers, partners, members, affiliates or agents of any of the foregoing, and the directors of the Cayman Feeder (each, a “Director”) and the members of the governance committees (each, a “Governance Committee”) of the Admiral Funds (in each case, even if such insurance covers conduct for which indemnity would not be available from the Admiral Funds); fees and expenses associated with Director and Governance Committee meetings and meetings of the Admiral Fund investors as a whole, including, without limitation, expenses related to the organization and conduct of such meetings (including, without limitation, travel, lodging and meal expenses), and Director fees (including registration fees) and Governance Committee member fees; costs of preparing and distributing reports and notices to Admiral Fund investors (including the development, implementation and maintenance of an investor electronic delivery site and/or system and related costs thereto); entity-level taxes; fees and expenses related to compliance with applicable law and regulations in connection with the activities of the Admiral Funds, including, without limitation, any governmental, regulatory, licensing, filing, reporting or registration expenses, fees or taxes (including, without limitation, fees and expenses incurred in connection with the Cayman Islands Monetary Authority registration, and the registration or licensing of the Admiral Funds, Burkehill (or its affiliates), the General Partner or the Principal in other non-U.S. jurisdictions, and ongoing compliance in connection therewith; the preparation and filing of Form PF, Section 13 filings, Section 16 filings and other similar regulatory filings for the Admiral Funds or Burkehill, the General Partner or the Principal on matters that would not have arisen but for their respective advisory relationships with the Admiral Funds; and any filings or reporting with respect to compliance with FATCA, AEOI (each as defined in the offering documents of the Feeder Funds) or similar laws enacted in other jurisdictions, as well as any foreign tax regime registrations, tax filings and associated annual fees and expenses); and any fees and expenses related to compliance with anti-money laundering laws and regulations applicable to the Admiral Funds (including AML officer fees, expenses and training); and (iv) extraordinary expenses, including, without limitation, the following: the costs of any litigation or investigation involving the activities of the Admiral Funds (including attorney’s fees and investigative fees and expenses); the cost of settlements and indemnification expenses (including advances thereof) (for clarity, Burkehill and the General Partner are authorized to commit the Admiral Funds to potential indemnity obligations towards certain counterparties entering into agreements with the Admiral Funds for the provisions of services and otherwise); fees and expenses incurred in connection with any tax audit by any U.S. federal, state or local authority, including, without limitation, any related administrative settlement and judicial review; and fees and expenses incurred in connection with the reorganization, restructuring, termination, winding-up or dissolution of any of the Admiral Funds. Generally, all expenses of the Admiral Funds will be borne by the Master Fund, other than any expenses that we determine in our discretion should be allocated to the Intermediate Fund, the U.S. Feeder or the Cayman Feeder. The Directors or Burkehill, with respect to the Cayman Feeder, and the General Partner, with respect to the U.S. Feeder, in their or its discretion, may allocate Feeder Fund expenses among the different classes or sub-classes of shares, in the case of the Cayman Feeder, and limited partnership interests and general accounts and separate memorandum accounts, in the case of the U.S. Feeder, based on the portion of such expenses that are reasonably attributable to such classes or sub-classes of shares or limited partner interests and general accounts

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Investment Objectives Burkehill employs a global equity event-driven investment strategy on behalf of the Funds and strives to achieve consistent, uncorrelated high-quality returns by leveraging robust fundamental analysis, disciplined process, and prudent risk management. Underpinned by a fundamentally anchored investment philosophy, Burkehill implements long and short positions across geographies and sectors, and conducts analysis to identify companies whose valuation, competitive landscape, growth prospects and management teams create the potential for alpha generation. Burkehill retains flexibility to capitalize on market dislocations and other event-driven investment opportunities, subject to the Funds’ respective investment objectives and guidelines as set forth in their Governing Documents. In addition, as permitted under the Governing Documents, Burkehill may utilize other financial instruments to seek to hedge company-specific, foreign exchange, and market risks, amongst others. Risk Factors A brief summary of the material risks involved with our investment strategies and methods of analysis follows. An investment in the Funds involves substantial risk, and prospective investors should carefully consider, among other factors, the risks described below. The use of the term “may” in this section is not intended to signify that the Funds have not in the past engaged in the applicable investment strategy, and the use of the term “will” in this section, or any indication in this section that the Funds are currently engaged in a particular investment strategy, is not

intended to signify that all Funds will engage in or are currently engaged in such strategy or that the Funds will not cease engaging in such investment strategy. These risk factors are not intended to be an exhaustive listing of all potential risks associated with such an investment. Investors are urged to review the written agreement, offering documents and Governing Documents applicable to their investment for additional information concerning the risks applicable to them. Investing in securities involves risk of loss (including complete loss) that clients should be prepared to bear. General Investment and Trading Risks. All securities investments present a risk of loss of capital. Volatile financial markets increase that risk. If our evaluation of an investment opportunity should prove incorrect, the Funds could experience losses as a result of a decline in the market value of securities in which the Funds hold a long position or an increase in the value of securities in which the Funds hold a short position. Our investment program uses investment techniques such as leverage, margin transactions, put and call options and other derivatives, and short sales, which practices can involve substantial volatility and can, in certain circumstances, substantially increase the adverse impact to which the Funds may be subject. The risk management techniques that may be used by us do not provide any assurance that the Funds will not be exposed to a risk of significant investment losses. No guarantee or representation is made that the Funds’ respective investment programs will be successful, that the Funds will achieve their targeted returns or that there will be any return of capital invested to investors. In addition, investment results may vary substantially over time. Changes in Investment Strategy. We have considerable discretion in choosing the securities that may be acquired and have the right to modify the investment strategy, selection criteria, or hedging techniques used by the Funds, subject to the limitations set forth in their respective Governing Documents. Any of these new investment techniques may not be thoroughly tested in the market before being employed and may have operational or theoretical shortcomings, which could result in unsuccessful investments and, ultimately, losses to the Funds. In addition, any new investment strategy or hedging technique developed may be more speculative than earlier techniques and may increase the risk of an investment in the Funds. Concentration of Investments. The Funds at times may hold a relatively large concentration in a limited number of companies, securities, industry sectors and/or geographic regions. Losses incurred in connection with those investments could have a material adverse effect on the Funds’ overall financial condition as the value of the Funds’ investment portfolios will be more susceptible to any single occurrence affecting one or more of those companies, securities, industry sectors or geographic regions than would be the case with more diversified investment portfolios. In particular, each Series of Helios is expected to be invested in a single investment idea or investment strategy and, therefore, is anticipated to have an extremely concentrated investment portfolio. Money Market Instruments. Burkehill may invest, for defensive purposes or otherwise, some or all of the Funds’ assets in high quality fixed-income securities, money market instruments or money market mutual funds, or hold cash or cash equivalents, in such amounts as it deems appropriate under the prevailing market conditions. Money market instruments are high quality, short-term fixed-income obligations, which generally have remaining maturities of one year or less, and may include U.S. government securities, commercial paper, certificates of deposit, bankers’ acceptances and repurchase agreements. In some market dislocations, investments in

money market instruments have led to investor losses. Equity Securities. We invest the Funds’ assets in equity and equity-related securities. Equity securities fluctuate in value in response to many factors, including the activities, results of operations and financial condition of individual companies, the business market in which individual companies compete, industry market conditions, interest rates and general economic environments. In addition, events such as political instability, terrorism and natural disasters may be unforeseeable and contribute to market volatility in ways that may adversely affect investments made by the Funds. Convertible Securities. We invest the Funds’ assets in convertible securities. The market value of convertible securities, as with all fixed income securities, tends to decline as interest rates increase and, conversely, tends to increase as interest rates decline. However, when the market price of the common stock underlying a convertible security exceeds the conversion price, the convertible security tends to reflect the market price of the underlying common stock. As the market price of the underlying common stock declines, the convertible security tends to trade increasingly on a yield basis and thus, may not decline in price to the same extent as the underlying common stock. If a convertible security held by the Funds is called for redemption, the Funds will be required to permit the company to redeem the security, convert it into the underlying stock or sell it to a third party. Any of these actions could have an adverse effect on the Funds’ ability to achieve their objectives. Fixed Income Securities. We may trade in bonds and other fixed income securities of U.S. and non-U.S. issuers on behalf of the Funds, including, without limitation, bonds, notes and debentures issued by corporations, or debt securities issued or guaranteed by a sovereign government or one of its agencies or instrumentalities. Fixed income securities pay fixed, variable or floating rates of interest. The value of fixed income securities will change in response to fluctuations in interest rates. In addition, the value of certain fixed income securities can fluctuate in response to perceptions of credit worthiness, political stability or soundness of economic policies. Fixed income securities are subject to the risk of the issuer’s inability to meet principal and interest payments on its obligations (i.e., credit risk) and are subject to price volatility due to such factors as interest rate sensitivity, market perception of the creditworthiness of the issuer and general market liquidity (i.e., market risk). The Funds may trade in fixed-income securities which are not protected by financial covenants or limitations on additional indebtedness. In addition, evaluating credit risk for foreign debt involves greater uncertainty because credit rating agencies throughout the world have different standards, making comparisons across countries difficult. “High Yield” Securities. The Funds may invest in “higher yielding” (and, therefore, higher risk) debt securities. Such securities are generally considered to be below “investment grade” and face ongoing uncertainties and exposure to adverse business, financial or economic conditions which could lead to the issuer’s inability to meet timely interest and principal payments. In certain periods, there may be little or no liquidity in markets for these securities. Furthermore, it is likely that a major economic recession or financial crisis could have a materially adverse impact on the value of such securities. High yield securities have historically experienced greater default rates than has been the case for investment grade securities. The market values of certain of these lower

rated debt securities tend to reflect individual corporate developments to a greater extent than do higher rated securities, which react primarily to fluctuations in the general level of interest rates. The markets for high yield securities tend to be more volatile, less liquid and less active than those for higher-rated securities, which can adversely affect the price at which these securities can be sold and may make it impractical or impossible to sell such securities at times of market dislocation. In addition, adverse publicity and investor perceptions, whether or not based on fundamental analysis, may also decrease the value and liquidity of these securities. Small to Medium Capitalization Companies. We invest the Funds’ assets in the securities of companies with small- to medium-sized market capitalizations. These securities, particularly those of smaller-capitalization companies, involve higher risks in some respects than do investments in securities of larger companies. For example, prices of such securities are often more volatile than prices of securities of large-capitalization companies. Smaller companies often lack the management experience, financial resources, product diversification, and competitive strength of larger companies. In addition, due to thin trading in some such securities, an investment in these securities may be more illiquid than those of larger capitalization companies. Short Sales. Short selling is part of the Funds’ investment programs. A short sale involves the sale of a security that the Funds do not own in the expectation of purchasing the same security (or a security exchangeable therefor) at a later date at a lower price. To make delivery to the buyer, the Funds must borrow the security and the Funds are obligated to return the security to the lender, which is accomplished by a later purchase of the security by the Funds. When the Funds make a short sale in the United States, they must leave the proceeds thereof with the broker and they must also deposit with the broker an amount of cash or U.S. government or other securities sufficient under current margin regulations to collateralize their obligations to replace the borrowed securities that have been sold. If short sales are effected on a foreign exchange, such transactions will be governed by local law. A short sale involves the risk of a theoretically unlimited increase in the market price of the security that would result in a theoretically unlimited loss to the Funds. The extent to which we will engage in short sales on behalf of the Funds will depend upon our investment strategy and perception of market direction and the value of individual securities. We may engage in short sales on behalf of the Funds as a hedge against potential market declines and/or as an investment strategy based on our analysis of the subject companies. Leverage. The Funds use leverage as part of their investment programs and the amount of leverage which the Funds have outstanding at any time may be substantial in relation to their respective capital. Leverage may be obtained by borrowing funds to make trades or by purchasing or entering into derivative instruments that are inherently leveraged, such as swaps, options, futures, and forward contracts. If the interest expense on borrowings were to exceed the net return on the positions acquired with borrowed funds, the use of leverage would result in a lower rate of return than if the Funds’ accounts were not leveraged. If the amount of borrowings which the Funds may have outstanding at any one time is large in relation to their capital, fluctuations in the market value of the Funds’ portfolios will have a disproportionately large effect in relation to their capital and the possibilities for profit and the risk of loss will therefore be increased. Any gains made with the additional monies borrowed will generally cause the value of the Funds’ assets to rise more

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Our only clients are the Funds, as described in Item 4 above. The minimum initial investment in the Feeder Funds is $10,000,000, subject to Burkehill’s discretion to accept lesser amounts. Any minimum commitment amount for a Series of Helios will be set forth in the applicable Governing Documents of such Series.

As noted in Item 5: Fees and Compensation above, we will receive both asset-based fees and performance-based fees or special allocations (which are based on a percentage of the capital appreciation of client assets) from the Funds, and the Arleigh Fund bears certain of our overhead expenses. Investors in the Funds are or will be provided with detailed disclosure in the applicable Governing Documents as to how the relevant performance-based compensation is calculated and charged. Performance-based compensation may create an incentive for us to recommend investments which may be riskier or more speculative than those which we would recommend under a different arrangement. We will have an incentive to favor client accounts that pay higher performance-based compensation than other client accounts. Additionally, our senior personnel and/or other related persons have invested or will invest in one or more of the Admiral Funds, and may invest in one or more Series of Helios. Accordingly, we will also have an incentive to favor the Funds (or Series) in which they have a greater economic interest and allocate investment opportunities to such Funds (or Series) over other Funds (or Series) and client accounts. To seek to avoid such conflicts of interest, we generally follow documented procedures in allocating opportunities among such accounts, which do not take into account the compensation to which such accounts are subject or the economic interest of our senior personnel and/or other related persons in such accounts.

Burkehill will follow substantially the same investment strategy for the Admiral Funds as it does for the Arleigh Fund and, subject to the applicable Fund’s Governing Documents, is generally required to purchase and sell investments on behalf of the Admiral Funds on a pari passu basis with the Arleigh Fund based on the respective Funds’ targeted gross exposure. In certain circumstances, we may allocate securities among such Funds on a different basis. In such cases, we will seek to allocate such opportunity in a manner we deem fair and equitable under the circumstances existing at such time and/or over time. The factors that we may consider when determining which securities to allocate to each client account include (but are not limited to): the relative amounts of capital in each client’s account available for new positions of the type at issue; the mandate of each client account; our perception of the appropriate risk/reward ratio for each client account; the intended objective and strategy of each client account and any applicable investment or risk targets, restrictions or guidelines; the liquidity of each client account at the time of investment and thereafter; the ability to add positions to a client account on a leveraged basis; liquidity of the security; whether the position is an “odd lot”; whether certain accounts would receive nominal or de minimis allocation amounts; transaction costs; position size; industry exposure; market exposure; gross, net, long and short exposure; applicable legal, tax and regulatory considerations; the overall portfolio composition of each client account; and such other considerations that we determine to be relevant at such time. Additionally, participation in specific trading opportunities may be appropriate, at times, to both the Arleigh Funds and the Admiral Fund, on one hand, and a Series of Helios, on the other. In such event, the Admiral Funds and/or the Arleigh Fund may (or may not) invest alongside a Series of Helios and we will seek to allocate such opportunity in a manner that we deem fair and equitable under the circumstances existing at such time and/or over time. The factors we may consider when making such allocation decisions include (without limitation) the factors noted in the above paragraph. Notwithstanding the foregoing, there can be no assurance that certain allocation decisions will not directly or indirectly adversely affect our clients, even if such decisions are made in good faith. Allocations are subject to a significant degree of discretion exercised by us, including, but not limited to, in connection with portfolio rebalancing, investing in new, different or additional investment strategies and in connection with admissions and withdrawals or redemptions of investors to and from the Funds. Even allocations designed to mitigate conflicts do not eliminate the possibility that an allocation of assets will not adversely affect our clients. Subject to the Governing Documents, we will have no obligation to purchase or sell a security for, enter into a transaction on behalf of, or provide an investment opportunity to, a client solely because we purchase or sell the same security for, enter into a transaction on behalf of, or provide an opportunity to, another client if, in our reasonable opinion, such security, transaction or investment opportunity does not appear to be suitable, practicable or desirable for such other client. Management fees and incentive fees are based on the net asset value of the Funds. In most circumstances, the valuations of client assets will be based on observable market prices and independent market quotations from relevant counterparties, but obtaining such valuations is not required in each instance. In making valuation determinations, we are subject to a conflict of interest, especially with respect to securities or other financial instruments which are not traded on

an organized or liquid market, as the valuation of such assets and liabilities affects our compensation. The valuation of such illiquid assets and liabilities will likely involve more discretion on our part. However, we will not take our compensation into account when making valuation determinations. There is no guarantee that the value determined with respect to a particular client asset or liability by us will represent the value that will be realized by such client on the eventual disposition of the related investment or that would, in fact, be realized upon an immediate disposition of the investment, and the difference between such value and the ultimate disposition price could be material. To the extent we are responsible for valuing a client’s assets, Burkehill will follow the valuation policies described in the client’s Governing Documents and/or Burkehill’s internal valuation policies, as applicable, in order to seek to mitigate these risks. Prospective investors and investors in the Funds are urged to review the Funds’ applicable Governing Documents for information regarding the specific fees, performance-based compensation and expenses applicable to them.

As described above in Item 4: Advisory Business, Burkehill, the General Partner and Burkehill HK are principally owned (directly or indirectly) by the Principal. Burkehill HK provides services to the Funds under the supervision and oversight of Burkehill. We and our affiliates are subject, and each of us and our clients are exposed, to a number of actual and potential conflicts of interest. Any such conflict of interest could have a material adverse effect on our clients (and on investors in the Funds). However, the existence of an actual or potential conflict of interest does not mean that it will be acted upon to the detriment of any client. When a conflict of interest arises, we will endeavor to ensure that the conflict is resolved fairly and in an equitable manner that is consistent with our fiduciary duties to the relevant client(s). We have in place policies and procedures that we believe are reasonably designed to identify and resolve actual and potential conflicts of interest. However, there can be no assurance that these policies and procedures will be successful in identifying or mitigating all actual or potential conflicts of interest. The following briefly summarizes some of the conflicts that may arise in connection with the business of Burkehill; it is not intended to be an exhaustive list of all such conflicts. Prospective clients or investors in the Funds should understand that (i) the relationships between Burkehill and its clients are complex and dynamic, and (ii) as Burkehill’s business changes over time, Burkehill may be subject, and its clients may be exposed, to new or additional conflicts of interest that are not presently known or anticipated. There can be no assurance that this document addresses or anticipates every possible current or future conflict of interest that may arise or that is or may be

detrimental to our clients. Prospective clients or investors in the Funds should consult with their own advisers regarding the possible implications on their investments of the conflicts of interest described in this document. Our management of clients may result in conflicts of interests when we and our related persons allocate time and investment opportunities among our clients (including clients in which we or our related persons are invested). In addition, terms regarding fees and performance-based compensation differ among our clients. This results in a conflict of interest when we allocate opportunities among our clients because we have an incentive to favor clients that have higher fee and/or performance-based compensation arrangements as well as clients in which we or our related persons have invested. To avoid such conflicts of interest we generally follow documented procedures in allocating opportunities among such accounts, which do not take into account the fees or performance-based compensation to which such clients are subject or the investment in such clients by us or our related persons. See Item 6: Performance-Based Fees and Side-By-Side Management. Burkehill, our affiliates and the Principal may determine, in their sole discretion, to participate in investments with persons not affiliated with our clients. In addition, we may offer to certain clients, or to any third party, the opportunity to co-invest in opportunities in which a client has invested or that become available to a client. We may offer such opportunities to investors that we select in our sole discretion without notice to or the consent of any other client or investor. The economic and other terms of any co-investment will be determined by us in our discretion on a case-by-case basis, and we may receive fees and/or allocations from co-investors, which may differ among coinvestors and also may differ from the fees and/or allocations borne by our clients (or investors in the Funds). As noted in Item 6: Performance-Based Fees and Side-By-Side Management above, the Principal and other senior personnel of Burkehill are personally invested, directly and/or indirectly, in certain of the Funds. Such investors are in possession of information relating to those Funds that are not available to other investors and prospective investors. In addition, the Arleigh Fund’s investors will be in possession of information that is not available to investors in the Admiral Funds or Helios. Certain advisors and other service providers, or their affiliates, to our clients may also provide services to or have business, personal, familial, political, financial or other relationships with us or our affiliates. Such advisors and service providers may be our clients or investors in the Funds, sources of investment opportunities for us or our clients, or co-investors with or counterparties to transactions involving the foregoing. These relationships may influence us in deciding whether to select or recommend any such advisor or service provider to perform services for our clients (the cost of which will generally be borne directly or indirectly by such clients). Notwithstanding the foregoing, we will generally seek to engage advisors and service providers for our clients on the basis of, without limitation, the overall quality of advice and other services provided. In addition, we have a conflict of interest where a service provider (e.g., legal counsel or accountants) provides services directly to us or one of our affiliates, and separately provides services to one or more clients, in that we or our affiliates may potentially obtain services at a lower cost (or obtain other terms that are more beneficial) than we or our affiliates otherwise could

have as a result of the service provider’s work performed on behalf of, and the compensation paid to the service provider by, such clients. In particular, unless inconsistent with our applicable written client agreement, costs associated with services rendered to the benefit of a client may be borne by such client. We and our affiliates may use some of the same service providers as are retained on behalf of one or more clients and, in some cases, fee rates, amounts or discounts may be offered to us and our affiliates by a third-party service provider which differ from those offered to a client as a result of scheduled or ad hoc rate changes, differences in the scope, type or nature of the service or transaction, alternative fee arrangements and negotiation.

Trading Code of Ethics Burkehill has adopted a “Code of Ethics” that establishes the high standard of conduct that we expect of our employees (including, for the avoidance of doubt, any employees of Burkehill HK) and procedures regarding our employees’ personal trading of securities. • •

Our employees are required to certify their adherence to the terms set forth in the Code of Ethics upon commencement of employment and annually thereafter. Employees also are required to provide quarterly certifications of compliance with certain Code of Ethics provisions.

The foundation of our Code of Ethics is based upon the following underlying fiduciary principles: • • • •

Employees must at all times place the interests of our clients first; Employees must ensure that all personal securities transactions are conducted consistent with the Code of Ethics’ Employee Personal Investment Policy (described below); Employees should not take inappropriate advantage of their position at Burkehill; and Independence in the investment decision-making process must be maintained at all times.

The Code of Ethics places restrictions on personal trades by employees and requires our employees to disclose their personal securities holdings and transactions to us on a periodic basis. The Code of Ethics prohibits employee personal trades in any listed, individual equity, debt or derivative securities, but allows employees to liquidate holdings with the pre-approval of our CCO or his or her designee. Employees are also prohibited from purchasing or selling securities that appear on our Restricted List for our clients’ accounts or for their own personal accounts. Employees must obtain pre-approval from our CCO or his or her designee before: (i) engaging in any outside business activities; or (ii) making any private investments. We will provide a copy of our Code of Ethics to any client or prospective client upon request. Subject to applicable law, we may effect transactions between clients (generally for rebalancing purposes and to correct misallocations of trades) where one client will purchase securities from

another client (including a private investment fund or account in which we, our affiliates, principals or employees may have a significant interest). Such transactions (i.e., cross trades) will be effected only when we believe that such transactions are in the best interest of the applicable clients. Such transactions will be placed through an unaffiliated broker-dealer or custodian, will not involve any accounts subject to ERISA (unless permitted to do so under applicable law), and will be effected for cash consideration, at prices that reflect prevailing market conditions or at such other price as determined by Burkehill in accordance with its policies and procedures. In addition, no brokerage commission or transfer fee will be paid to us or our affiliates in connection with any such transaction. Any transaction costs incurred in connection with any such transaction will be shared pro rata between the applicable clients. In the event that we effect a cross trade between an account in which we or the Principal owns more than twenty five percent (25%) and a client account, such transaction may be deemed to be a principal transaction under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Such transactions would create a conflict of interest for us because we may put our or the Principal’s interests in such account before the interests of our client in the other account. We will not effect any cross trades between accounts if we believe that such trade would result in a principal transaction, unless: 1) We believe that such transaction is in the best interest of the clients participating in the transaction; and 2) We obtain the consent of the applicable clients to the extent required under the Advisers Act. The Governance Committees and the Directors, as applicable, are authorized to provide any such consent on behalf of the Admiral Funds in accordance with the applicable Governing Documents of the Admiral Funds. If a governance committee is established for Helios (or any Series thereof), then the applicable Governing Documents of Helios are similarly expected to authorize such governance committee to provide any such consent on behalf of Helios and/or the applicable Series. We may buy or sell securities for one client at the same time that we or our related persons buy or sell the same security for one or more other clients (including the Funds which are our related persons). This will typically happen when more than one client is capable of purchasing or selling a particular security based on investment objectives, available cash and other factors. This may create a conflict of interest if one account may benefit from making the trade before or after the other account. We will generally seek to aggregate trades, as described below in Item 12: Brokerage Practices under “Aggregation of Orders,” to avoid any such conflict of interest.

Selection of Brokers Burkehill is authorized to determine the broker-dealer(s) to be used for executing securities transactions for the Funds, subject to the terms of the Funds’ respective Governing Documents. In selecting broker-dealers to execute transactions, we do not need to solicit competitive bids and do not have an obligation to seek the lowest available commission cost. It is not our practice to

negotiate “execution only” commission rates; therefore, the Funds may be deemed to be paying for research, brokerage or other services provided by the broker which are included in the commission rate. Burkehill’s authority is limited by its own internal policies and procedures and the Governing Documents. Best Execution In selecting an appropriate broker-dealer to effect a client trade, we seek to obtain “Best Execution,” meaning generally the execution of a securities transaction for a client in such a manner that a client’s total costs or proceeds in the transaction are most favorable under the circumstances. Accordingly, in seeking Best Execution, we will take into consideration the price of a security offered by a broker-dealer, as well as a broker-dealer’s full range and quality of services including, without limitation, its facilities, reliability and financial responsibility, execution capability, commission rates, responsiveness to us, brokerage and research services provided to us (for example, research ideas, analysis, and investment strategies), special execution and block positioning capabilities, clearance, and settlement and custodial services. Soft Dollars Soft dollar arrangements arise when an investment adviser obtains products and services, other than securities execution, from a broker in return for directing client securities transactions to the broker. Soft dollar arrangements pose a conflict of interest for us in that such arrangements allow us to pay with client commissions expenses that would otherwise be borne by us. In the event that we use client brokerage commissions (or markups or markdowns) to obtain research or other products or services, we would receive a benefit because we do not have to produce or pay for the research, products or services. We believe that this conflict is mitigated because our clients will generally pay for research as a “hard dollar” expense pursuant to their respective investment management agreements. We may have an incentive to select a broker based on our interest in receiving the research or other products or services offered by such broker, rather than on our clients’ interests in receiving most favorable execution. We do not currently have any formal soft dollar arrangements in place. However, we execute securities transactions on behalf of client accounts with broker-dealers that provide us with access to proprietary research reports (such as standard investment research and credit reports). To our knowledge, these services are generally made available to all institutional investors doing business with such broker-dealers. These bundled services are made available to us on an unsolicited basis and without regard to the rates of commissions charged or paid by client accounts or the volume of business that we direct to such broker-dealers. In the event that we engage in soft dollar transactions, we intend to comply with the safe harbor requirements of Section 28(e) of the Securities Exchange Act of 1934, as amended. Under this provision, in exercising our discretionary authority to select or arrange for the selection of brokers for execution of transactions for our clients, and, subject to our duty to obtain best execution, we may consider the value of research and brokerage products and services (collectively, “Research”) provided by such brokers. Accordingly, if we determine in good faith that the amount of commissions charged by a broker is reasonable in relation to the value of the brokerage and

products or services provided by such broker, the Funds may pay commissions to such broker in an amount greater than the amount another broker might charge. Research that we acquire from brokers may include, among other things, proprietary research, which may be written or oral. Research products that we acquire from brokers may include, among other things, databases and quotation services, and Research services may include, among other things, research concerning market, economic and financial data, a particular aspect of economics or on the economy in general, statistical information, pricing data and availability of securities, financial publications, electronic market quotations, performance measurement services, analyses concerning specific securities, companies, industries or sectors, market, economic and financial studies and forecasts, appraisal services, and invitations to attend conferences or meetings with management or industry consultants. We may in the future acquire other Research with client brokerage commissions in accordance with our policies and procedures. Research provided by brokers may be used to service all of our client accounts and not exclusively in connection with the management of the client account that generated the particular soft dollar benefit. Where a product or service obtained with client commission dollars provides both research and non-research assistance to us, we will make a reasonable allocation of the cost which may be paid for with client commission dollars. During our last fiscal year, we acquired with client brokerage commissions (or markups or markdowns) (i) research, such as proprietary research from brokers, which may have been written and/or oral; (ii) research products, such as databases and quotation services; and (iii) research and brokerage services, such as research concerning market, economic and financial data; a particular aspect of economics or on the economy in general; statistical information; pricing data and availability of securities; financial publications; electronic market quotations; performance measurement services; analyses concerning specific securities, companies, industries or sectors; market, economic and financial studies and forecasts; appraisal services; invitations to attend conferences or meetings with management or industry consultants, and order management and allocation systems. During our last fiscal year, we have taken into account the quality, comprehensiveness and frequency of available research services and products considered to be of value provided by brokers when directing client transactions to a particular broker. We directed transactions to such brokers only consistent with Best Execution and Burkehill’s internal policies. Brokers sometimes suggest a level of business they would like to receive in return for the various services they provide. We have not committed to provide any level of brokerage business to any broker to date, and 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. Our prime broker(s) generally provide us with certain front and back-office services, such as trading, securities lending, clearing, reporting and settlement for equities, fixed income, foreign currency and options, and talent recruiting, among other services. Subject to applicable law, our

prime brokers may also provide us with capital introduction services. The Funds pay fees to the prime brokers in accordance with the fee schedules negotiated with such prime brokers. Brokerage for Client Referrals Burkehill does not consider, in selecting or recommending broker-dealers, whether Burkehill or any related person receives client referrals from such broker-dealer or any third party. However, subject to applicable law, Burkehill may direct some client brokerage business to brokers who refer prospective investors to the Funds, consistent with Best Execution. Because such referrals, if any, are likely to benefit us but will provide an insignificant (if any) benefit to our clients, Burkehill has a conflict of interest with our clients when allocating client brokerage business to a broker who has referred investors to the Funds. To prevent client brokerage commissions from being used to pay investor referral fees, Burkehill will not allocate client brokerage business to a referring broker unless Burkehill determines in good faith that the commissions payable to such broker are not materially higher than those available from non-referring brokers offering services of substantially equal value to the client account. Trade Errors Subject to applicable law and the terms of our written agreements with clients, our clients will (i) be responsible for any losses resulting from trading errors and similar human errors, absent our willful misconduct, gross negligence or material breach of certain Governing Documents in the performance of our obligations and duties (or those of our affiliates or personnel) in respect of our clients, and (ii) receive the gain from such trading errors, as the case may be. Burkehill faces a potential conflict of interest because, should a trade error occur, generally we (and not an independent third party) would be the party that determines whether such trade error resulted from our willful misconduct, gross negligence or, if applicable, material breach of a Governing Document. However, notwithstanding this potential conflict of interest, in all cases, we would make such determination in good faith. Burkehill may correct misallocations of trades among client accounts by re-allocating the applicable trade using the intended allocation methodology prior to the trade’s settlement date. If an erroneous allocation cannot be corrected prior to or after settlement, we may, if appropriate and subject to applicable law, correct such erroneous allocation by effecting a cross trade between client accounts at the price at which the initial trade was effected. Aggregation of Orders Burkehill will generally aggregate client trades, subject to Best Execution. Aggregation 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. Aggregation opportunities for Burkehill generally arise when more than one client is capable of purchasing or selling a particular security based on investment objectives, available cash and other factors. In such event, securities purchased or sold will generally be allocated among client accounts on an average price basis. When an aggregated order is only partially filled, we will allocate the

investment opportunity as described above in Item 6: Performance-Based Fees and Side-By-Side Management. Burkehill may also aggregate orders for the same security entered at the same time, with the same side, direction and the same execution instructions, subject to the allocation considerations described above in Item 6: Performance-Based Fees and Side-By-Side Management. Clients may pay more to the extent that we do not, or are unable to, aggregate trades, as seeking to place separate, non-simultaneous transactions in the same security for multiple clients may negatively affect market price, transaction commissions and/or trade execution. A client’s nonparticipation in aggregated trades may result in lost opportunities to purchase securities for such client’s account that other clients participating in aggregated trades were able to purchase.

We do not receive economic benefits from non-clients for providing investment advice and other advisory services. Neither we nor any of our related persons, directly or indirectly, compensate any person who is not a supervised person for client referrals.

There have been no legal or disciplinary events that would be material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management.

Our Managing Partner and his designees continuously review and monitor the Funds’ portfolios to ensure that they conform with the investment objectives and guidelines that are stated in their respective Governing Documents. In these reviews, particular attention is paid to any changes in an investment’s fundamentals, overall risk management and changes in the markets that may affect price levels. Burkehill periodically distributes reports and statements to the Funds’ investors in accordance with the terms of the Funds’ respective Governing Documents, including without limitation, account statements directly from the administrator of the Funds. Burkehill may supplement this regular reporting with reports provided during investor meetings or as requested. Such additional reports may include information regarding a Fund’s positions, performance, finances, and management and/or other information about such Fund or Burkehill (including notification of senior employee departures, the commencement of disciplinary actions, legal proceedings, investigations or similar matters, or redemptions from the Funds by Burkehill, our affiliates, our respective personnel and/or other investors or clients). Audited financial statements of the applicable Funds are provided to all investors generally within 120 days of each Fund’s fiscal year end. Burkehill will also provide information necessary for its Funds’ investors to complete their respective U.S. federal, state and local income tax returns. As noted above, we may provide certain additional information to any investor, or prospective investor, in a Fund (or to any of our clients or prospective clients) who requests such information. This information may be provided in response to questions and requests and in connection with due diligence meetings and other communications, but will not be distributed to other investors and prospective investors (or other clients or prospective clients) who do not request such information (absent a regulatory or other obligation for Burkehill to do so). Such information may affect a prospective investor’s (or prospective client’s) decision to invest, and investors and clients (which may include our personnel, affiliates and/or related persons) who receive such additional information may be able to act on such additional information and redeem their investments potentially at higher values than other investors (or clients). Each investor and client is responsible for asking such questions that it believes are necessary in order to make its own investment decisions and must decide for itself whether the limited information provided by Burkehill is sufficient for its needs.

We may be deemed to have custody of the Funds’ cash and securities. Qualified custodians and/or Burkehill send account statements to the Funds in accordance with the Funds’ respective Governing Documents, which the Funds’ investors should carefully review. To the extent that investors in a Fund receive account statements both from us and such qualified custodians, they are urged to compare such statements. We will comply with Rule 206(4)-2 of the Advisers Act (i.e., the “custody rule”) with respect to the Funds by meeting the conditions of the pooled vehicle annual audit approach. Each Fund’s financial statements will be subject to an annual audit by an independent auditor that is registered with, and subject to inspection by, the Public Company Accounting Oversight Board (PCAOB).

We have full and sole discretionary investment authority with respect to the Funds, including authority to make decisions with respect to which securities will be bought and sold by the Funds, as well as the amount and price of those securities, subject to the limitations contained in the Funds’ respective Governing Documents.

We have full and sole authority to vote securities and grant proxies on behalf of the Funds. We adhere to our proxy voting policies and procedures that are designed to ensure that such proxies are voted in the best interest of our clients on a case-by-case basis. Clients may not directly vote securities or grant proxies. We have contracted with a third-party proxy voting services firm to provide proxy analysis, voting recommendations and voting services on behalf of the Funds. Burkehill reviews the analysis and recommendations and determines how to vote each proxy in accordance with its proxy voting policies and procedures. Our goal is to vote proxies in a prudent and diligent manner and in the best interests of our clients. In some instances, Burkehill may determine that the best interests of our clients involve abstaining from voting proxies. Clients who wish to understand our proxy voting rationale and process may contact our CCO at the address on the cover page of this Brochure.

We are not required to include a balance sheet for our most recent fiscal year, are not aware of any financial condition reasonably likely to impair our ability to meet contractual commitments to the Funds, and have not been the subject of a bankruptcy petition at any time during the past ten years.