Caledonia (Private) Investments Pty Ltd

Caledonia is an SEC-registered investment adviser with its principal place of business in Sydney, Australia. Caledonia was founded in 1992. Caledonia’s principal owner is Caledonia Holdings Co Pty Limited. (For purposes of this Brochure, principal owners include those with at least a 25% interest in Caledonia). Caledonia provides discretionary investment management services, directly or through its affiliates, to U.S. and to non-U.S. pooled investment vehicles and single investor funds (“Funds”), as well as to separately managed account clients (“SMAs”) (the “Funds” and “SMAs” collectively together are, the “Clients”). The investment objective of Caledonia is to seek high absolute returns over a long-term horizon by investing on a long/short basis primarily in corporate equity securities, predominantly listed securities, and related instruments in global markets. Caledonia manages Client assets generally within a single long-short global equity strategy. While there is primarily a single long-short global equity strategy across Caledonia’s various investment vehicles, in 2025, Caledonia launched a second strategy, which invests long only. The investment objective of the long only strategy is to seek high returns over a longterm horizon above the MSCI World Index by investing on a long only basis primarily in corporate equity securities, predominantly listed securities, and related instruments in global markets. The securities/investments within the long only strategy typically overlap with the long securities/investments within the long/short strategy, with the major difference in the portfolios being no short positions. Both strategies are managed in accordance with the terms set forth in the applicable governing documents, which may include, but is not limited to, the offering memorandum, organizational documents, private placement memorandum, prospectus, limited partnership agreement, limited liability company agreement, investment management agreement, and/or subscription agreements (each and collectively, the “Governing Document”). Caledonia does not tailor advisory services to the individual needs of Clients. Caledonia’s investment program is speculative and entails substantial risks. Since market risks are inherent in all investments to varying degrees, there can be no assurance that Caledonia’s investment objectives will be achieved. In fact, certain investment practices can, in some adverse circumstances, substantially increase the adverse impact of Caledonia’s investment portfolio. Please refer to Item 8 of this Brochure for additional information regarding Caledonia’s methods of analysis and investment strategies, and their associated risks. Prospective investors should refer to the appropriate Governing Document for important additional information and considerations. Clients, in limited circumstances per the Governing Document, may impose restrictions on investing in certain securities. Caledonia US, LP (“Caledonia US”), a US Limited Partnership, an affiliate of Caledonia and an SECregistered investment adviser, serves as the investment adviser to some of the Clients. Another affiliate of Caledonia, Caledonia GP, LLC (“Caledonia GP”), a Delaware limited liability company, serves as the general partner of certain U.S. based Funds. Caledonia Co-Invest GP, LLC (“Caledonia Co-Inv GP”), also an affiliate of Caledonia, serves as the general partner of certain Funds registered in the Cayman Islands. Caledonia US, Caledonia GP, and Caledonia Co-Inv GP are related persons of Caledonia. Caledonia US, Caledonia GP and Caledonia Co-Inv GP and their employees and personnel are subject to the Investment Advisers Act of 1940 (the “Advisers Act”) and rules thereunder, and to all of Caledonia’s compliance policies and procedures. Each of the personnel of Caledonia US, Caledonia GP and Caledonia Co-Inv GP are deemed “persons associated with” Caledonia (as that term is defined in section 202(a)(17) of the Advisers Act) and are subject to SEC examination. As of June 30, 2026, Caledonia managed Client regulatory assets under management of approximately U.S. $5.25 billion, of which approximately U.S. $4.78 billion was managed on a discretionary basis and approximately U.S. $465 million on a non-discretionary basis.

For Caledonia’s services to Clients, Caledonia or its affiliates will charge a management fee (“Management Fee”) and performance-based compensation in the form of either an incentive allocation or a performance fee (each, a “Performance Fee”) as described below. These fees and compensation are negotiable. Management Fee In general, Caledonia will receive from each Client an asset-based Management Fee in the range of 0.5% to 1.5% per annum. The Management Fee will generally be calculated and payable monthly, in arrears, as of the first day of each month. Please refer to the applicable Governing Document for additional information. Performance Fee In general, subject to certain adjustments and a “high water mark,” Caledonia is entitled to a Performance Fee from each Client which generally ranges from 5% to 20% of all net realized and unrealized income and gains derived from portfolio investments. The long only strategy, while similar in fee structure, pays a Performance Fee of 20% on the net realized and unrealized income and gains in excess of the benchmark amount, which represents the return for the same period for the MSCI World Index. This Performance Fee will generally be calculated and payable annually, in arrears, as of the applicable Client’s fiscal year end and as agreed in the Governing Documents. Please refer to the applicable Governing Document for additional information. General Information The Management Fee and Performance Fee may be waived, reduced or calculated differently with respect to Caledonia’s affiliates, members or employees or any particular affiliated or unaffiliated investor at Caledonia’s discretion. Fees and compensation paid or allocated to Caledonia or its affiliates by Clients are generally directly debited from the assets of such Clients. Except as set forth in the applicable Governing Document, each Client bears all other expenses incidental to and incurred in relation to its operations and business as well as its pro rata share of such Client’s expenses, including, but not limited to, brokerage (see Item 12 of this Brochure), each Client bears its own costs, fees and expenses and its attributable share of the relevant fund’s expenses, as well as any similar expenses incurred by any special purpose vehicles and/or trading or investing vehicles in which the investor or the master fund invests, including, without limitation, the Management Fee (if any); expenses relating to the formation, maintenance and winding up of the Client, special purpose vehicles and/or trading or investing vehicles formed to facilitate the Client’s investments and/or coinvestment vehicles (including fees, costs and expenses incurred in connection with establishing coinvestment vehicles in connection with proposed investments that are not consummated, to the extent not borne by such vehicles); investment expenses (e.g., expenses that, in Caledonia’s discretion, are related to the investment of the Client’s assets, whether or not such investments are consummated, such as brokerage commissions, expenses relating to short sales, clearing and settlement charges, custodial fees, bank service fees and interest expense; expenses of outsourced “treasury” services whereby a thirdparty service provider manages and advises on matters pertaining to cash reserves and cash management (e.g., cash management, securities finance, collateral management, counterparty management and margin management)); expenses relating to research generated through the use of third-party consultants and similar service providers, news and quotation equipment and services, portfolio risk management

services and market information systems and computer software and information expenses; professional fees (including expenses of consultants, investment bankers, attorneys, accountants and other experts) relating to investments; external accounting and valuation expenses, including expenses incurred by certain non-investment personnel in this regard, as determined appropriate by Caledonia; research and market data (including quotation and market data services (e.g., Bloomberg)); administrative expenses, including fees and expenses of the Administrator; legal expenses (which includes, without limitation, responding to formal and informal inquiries, audit, examination, proceeding or claim expenses on behalf of or for the benefit of the Client or in connection with their business); expenses related to the preparation and filing of regulatory filings related to the Client, Caledonia, any sub-advisor and any consultant as well as other blue sky, AIFMD (as defined below) and corporate filing fees and expenses (except for expenses relating to any compliance costs associated with registration as an investment adviser in the U.S., the preparation of Form ADV and Form PF); external accounting and valuation expenses; expenses relating to FATCA, and preparation costs of financial statements, tax returns (including schedules thereto) and reports to investors and Schedule K-1s (or any other required Form 1065 schedules) to investors; audit expenses and tax compliance and preparation expenses; costs and expenses with respect to the Clients representative’s representation of the Client and the partners; costs of printing and mailing reports and notices; taxes (including, for the avoidance of doubt, any entity-level taxes, withholding taxes and/or similar charges that may be incurred or payable by the Client); corporate licensing; regulatory expenses (including filing fees and expenses relating to filings made in connection with the Client’s holdings or activities); organizational expenses; expenses incurred in connection with the offering and sale of the Participating Shares, including the negotiation of Side Letters; expenses incurred in connection with meetings of the investors; expenses of the UCC (as defined herein); indemnification expenses; and extraordinary expenses and other similar expenses related to the Client. For purposes of this paragraph, third-party consultants shall mean consultants, agents and other experts who Caledonia believes ordinarily spend a not-insignificant portion of their business time providing services to bona fide third-party clients not affiliated with Caledonia or their affiliates. For the avoidance of doubt, “similar expenses” refers to any expenses that are similar in type and nature to the expenses described in the previous paragraphs, and is intended, given the dynamic ongoing nature of the business of the Client, to cover any expenses determined by Caledonia to be primarily related to the categories listed above but not specifically enumerated. Caledonia considers that such similar expenses include, but are not limited to: (i) broken deal expenses, initial and variation margin, loan fees, private placement fees, appraisal fees, commitment fees and other transactional charges, fees or costs (all of which Caledonia considers investment expenses); (ii) any judgments or settlements paid in connection with any formal and informal inquiries, audit, examination, proceeding or claim expenses on behalf of or for the benefit of the Client or in connection with its business (which Caledonia considers legal expenses); (iii) entity-level taxes and governmental fees or other charges payable by or with respect to or levied against the Client, its investments, or to U.S. federal, state or other governmental agencies, U.S. or non-U.S., including real estate, stamp or other transfer taxes (which Caledonia considers tax expenses); (iv) expenses related to the offering of interests in compliance with the Directive 2011/61/EU of the European Parliament and the Council of 8 June 2011 on Alternative Investment Fund Managers (“AIFMD”) (which Caledonia considers offering expenses); (v) directors’ and officers’ liability or other similar insurance policies, errors and omissions insurance and other similar policies for the benefit of the Client and all other costs and expenses arising out of the Client’s indemnification obligations (which Caledonia considers indemnification expenses); (vi) any and all fees, costs and expenses incurred in connection with any amendments, modifications, revisions or restatements to the constituent documents of the Client, Caledonia, any special purpose vehicles and/or trading or investing vehicles; and (vii) wind-up and liquidation expenses of the foregoing entities (all which Caledonia considers organizational expenses and/or legal expenses). The above expenses, other than the Management Fee (if applicable) and Incentive Fee, will generally be borne, directly or indirectly, on a pro rata basis by all Participating Shareholders, based on the

aggregate NAV of the Participating Shares they hold. Certain expenses incurred on behalf of or for the benefit of one or a few Series of Participating Shares, may be borne only by such Series of Participating Shares, as determined by Caledonia. Consequently, it is anticipated that certain investment and offering and sale expenses that Caledonia determines are related exclusively to a particular Series of Participating Shares will be borne only by such Series of Participating Shares. Conversely, it is anticipated that those expenses that Caledonia determines as being related to the overall operation of the Client will generally continue to be borne by all Participating Shares, irrespective of Series designation. If any of the foregoing expenses are also attributable to one or more other accounts, such expenses will be allocated among the Client and such other accounts in a manner determined by Caledonia in its discretion to be fair and reasonable. In certain circumstances, Caledonia and/or the general partner may elect to bear certain expenses otherwise incurred for or allocated to other accounts or the Client. Any such election by Caledonia and/or the general partner will not obligate either party to bear such expenses in any other instance. Investors or prospective investors should carefully review the applicable Governing Documents for additional information regarding the expenses borne by each respective Client. The information contained in this Item 5 is a summary only and is qualified in its entirety by such Governing Documents. Caledonia has adopted an expense allocation policy that is designed to ensure that expenses are allocated to Clients in a fair and equitable manner. Caledonia allocates expenses to each Client in accordance with the Client’s Governing Documents. Caledonia generally allocates common client expenses among multiple Clients pro rata based on gross assets under management as at the beginning of the month in which the expenses are incurred. Caledonia may deviate from this standard allocation method if it determines that an expense disproportionately benefits a particular Client or group of Clients. Neither Caledonia nor its Access Persons accepts compensation for the sale of securities or other investment products, including asset-based sales charges or service fees.

Methods of Analysis and Investment Strategies Caledonia generally employs a single long-short global equity investment strategy across most Clients. While there is primarily a single long-short global equity strategy across Caledonia’s various investment vehicles, in 2025, Caledonia launched a second strategy, which invests long only. Caledonia’s investment objective is to seek high absolute returns over a long-term horizon by investing on a long/short basis primarily in corporate equity securities, predominantly listed securities, and related instruments in global markets. The investment objective of the long only strategy is to seek high returns over a long-term horizon above the MSCI World Index by investing on a long only basis primarily in corporate equity securities, predominantly listed securities, and related instruments in global markets. Caledonia aims to achieve this investment objective by focusing on stock picking and what Caledonia believes is deep fundamental research with respect to smaller issuers whose equities Caledonia believes the markets are generally less efficient in pricing to drive alpha. The investment strategies and methods of analysis used to achieve this objective are described below, together with the associated risks of loss. Generally, Caledonia seeks to conduct detailed bottom-up financial modelling on an individual issuer basis in an attempt to understand the driver and magnitude of such issuer’s earnings advantage. Caledonia is agnostic as to the sector or geography in which it invests (within reason), and will attempt to adapt its investment universe to take advantage of the environment and/or compelling opportunities. For example, Caledonia will fully immerse itself in industries of interest which often leads to a thematic line of investing, whereby Caledonia invests across geographies within one distinct vertical or business model. Caledonia typically takes a three- to five-year and beyond view when making an investment on the long side, and typically a one-year to two-year view on the short side. Caledonia’s investment process with respect to investments includes what Caledonia views as rigorous initial due diligence on potential investments, seeking to identify value-based investment opportunities with attractive risk/reward characteristics. Caledonia performs ongoing due diligence with respect to all investments through (i) company management, competitor and industry contact and (ii) quantitative analysis to continually confirm and test an investment thesis. Risk management is a critical component of the investment approach. Caledonia focuses its investment universe to public issuers listed on stock exchanges in countries where there is a longstanding history of protection of shareholder rights and the rule of law. Also it seeks to own securities which to the greatest extent possible convey true ownership of the profits and cash flows of the underlying company. This means Caledonia tends to concentrate its efforts on the developed markets around the world while eschewing emerging and frontier markets where the rule of law is less well-established. Typically, Caledonia’s investment strategies are best described as high conviction with Client portfolios concentrated in a small number of investments. In implementing its strategies, Caledonia is typically not limited as to the variety of instruments it may deploy but Client portfolios would generally include: listed equities, unlisted equities, swaps and other derivatives, options, futures, forward foreign-exchange contracts and fixed income securities. Conflicts Relating to Material Nonpublic Information From time to time, Caledonia may enter into confidentiality agreements with companies or their

representatives in connection with a prospective or current investment. Through these and other relationships, Caledonia may obtain material nonpublic information that might restrict its ability to buy or sell the securities of such company on behalf of its Clients. In order to mitigate and limit the instances in which Caledonia will be subject to these restrictions, Caledonia has adopted a policy that establishes controls with respect to the acceptance, use and handling of confidential information. Material Risks (including significant, or unusual risks) relating to investment strategies and method of analysis Please note that an investment in a Client is highly speculative and not intended as a complete investment program. Investing in the securities markets in general and in one or more Clients advised by Caledonia in particular involves significant risk. Investments in a Client are designed only for experienced and sophisticated persons who are able to bear the economic risk of the loss of their entire investment and who have a limited need for liquidity in their investment. The method(s) and investment strategies described above involve certain risks. Investors or prospective investors should review the applicable Governing Documents for a complete description of the material risks related to their investment. A summary of some of the principal risks are set out below:

Limited Diversification - Caledonia intends to seek to diversify Clients’ investments as it deems appropriate and consistent with the Client’s investment objective. However, Clients’ investment portfolios are likely to be concentrated in a small number of investments which is likely to make the portfolio subject to a greater level of volatility and increase the relative impact that each issuer will have on the overall portfolio. Also, the use of a single investment manager applying generally similar trading programs could mean lack of diversification and, consequentially, higher risk.

Concentrated Positions - Notwithstanding investment guidelines which reflects the Caledonia Group’s current intentions, there are no limits on Caledonia’s investment discretion with respect to the size of any investment and the Clients will not be limited in the amount of capital that may be committed to any single investment. A substantial portion of the Clients’ portfolio may be concentrated in a few sectors, industries, or issuers, and may not necessarily be widely diversified. Therefore, the Clients face the risk that the value of its portfolio will be greatly affected by changes in the prices of a small number of investments. This limited diversity could expose the Clients to substantial losses that are disproportionate to market movements in general if there are disproportionately greater adverse price movements in those investments. Consequently, the Clients may be subject to more rapid change in value than would be the case if the Clients were required to maintain a wide diversification among portfolio positions.

Possible Positive Correlation with Traditional Portfolios – Typically, one of the objectives of an investor in incorporating a non-traditional investment such as the Client into a portfolio is to provide a potentially valuable element of diversification. However, there can be no assurance, particularly during periods of market disruption and stress when the risk control benefits of diversification may be most important, that the Clients will, in fact, experience a low level of correlation with traditional portfolios.

Speculative Nature of Certain Investments – Certain investments by the Clients may be regarded as speculative in nature and involve increased levels of inherent risk. An inherent part of a strategies may be to identify financial products which are undervalued (or, in the case of short positions, overvalued) by the marketplace. Success of such strategies necessarily depends upon the market recognizing such value in the price of the financial products within the time frame Caledonia desires, which may not necessarily occur.

Directional Trading – The positions taken by Clients may be directional in that they are designed to profit from forecasting absolute price movements in a particular security.

Directional investing is subject to all the risks inherent in incorrectly predicting future price movements. Often these price movements will be determined by unanticipated factors, and even if the determining factors are correctly identified, Caledonia’s analysis of those factors may prove inaccurate, in each case, potentially leading to substantial losses. Predicting future prices is inherently uncertain and the losses incurred, if the market moves against a position, will often not be hedged. The speculative aspect of attempting to predict absolute price movements is generally perceived to exceed that involved in attempting to predict relative price fluctuations.

Long and Long/Short Investment Strategies – The identification of investment opportunities in the implementation of the Clients’ long/short investment strategies is a difficult task, and there are no assurances that such opportunities will be successfully identified or realized. If the perceived opportunities underlying the Client’s positions were to fail to converge toward, or were to diverge further from values expected by Caledonia, the Clients may incur a loss. In the event of market disruptions, the Clients could be forced to close out one or more positions at unfavorable prices, thereby incurring significant losses. Furthermore, the models and analytics used to determine whether an investment presents an attractive opportunity consistent with Caledonia’s long and long/short strategies may become outdated and inaccurate as market conditions change.

Short selling - Caledonia engages in short selling strategies as part of its long/short global equity strategy. A Short sale involves the sale of a security that the Clients do not own. To make delivery to the buyer, the Clients generally must borrow the security, and the Clients are obligated to pay the lender of the security a stock borrow fee as well as any dividend or interest payable on the security until it returns the security to the lender. When the Clients make a short sale in the U.S., it must leave the proceeds thereof with the lender as collateral. If short sales are effected on a non-U.S. exchange, such transactions will be governed by local law. Short selling allows the investor to profit from declines in market prices to the extent such decline exceeds the transaction costs and the costs of borrowing the securities. Selling securities short creates the risk of losing an amount greater than the initial investment, and can also involve borrowing and other costs which can reduce profits or create losses in particular positions. Short sales theoretically involve unlimited loss potential, as the market price of securities sold short may increase continuously. Under adverse market conditions the Clients might have difficulty maintaining the ability to borrow securities sold short. If so, the Clients might have to sell portfolio securities to raise the capital necessary to meet its short sale obligations at a time when fundamental investment considerations would not favor such sales. There also can be no assurance that the securities necessary to cover a short position will be available for purchase at or near prices quoted in the market. Purchasing securities to close out the short position can itself cause the price of the securities to rise further, thereby exacerbating the loss. In addition, the Clients can be “bought in” (i.e., forced to purchase securities in the open market to return to the lender). During the severe market disruptions following the bankruptcy of Lehman Brothers in September 2008, securities regulators in a number of countries imposed “emergency” bans on the short selling of financial sector securities. Short selling may be subject to further regulations or even bans. Short selling is integral to Clients’ investment strategy and any regulatory limitations on short selling could materially adversely affect Caledonia’s ability to implement its long/short strategy for the benefit of the Clients. Absent an exemption and subject to certain limited exceptions, Rule 105 of Regulation M promulgated under the Exchange Act prohibits the Clients from purchasing securities in any firm commitment, underwritten follow-on or secondary offering of equity (or equity linked) securities for cash when the Clients have effected short sales in such securities within a “restricted period” prior to the pricing of the offering. If the Clients cannot meet an exemption

to Rule 105, this will result in restrictions in the Clients’ trading activity and may adversely impact the results of the Clients. Although the Clients generally seeks to generate alpha from its short selling strategy, Caledonia may use short sales in an attempt to hedge against the risk of declines in the market value of the Clients’ long portfolio, and there can be no assurance that such hedging operations will be successful. Additionally, the CFTC and the U.S. commodities exchanges impose limits, referred to as “speculative position limits,” on the maximum net long or net short speculative positions that any person may hold or control in any particular futures or options contracts traded on U.S. commodities exchanges.

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Caledonia’s Clients consist of Funds and SMAs, beneficial owners of which are sophisticated and institutional investors which may include, but are not limited to, individuals, high net worth individuals, pension funds, trusts, charitable organizations, endowments, foundations, corporations, family offices and funds of funds. Caledonia, however, is not precluded from advising types of clients that are not previously listed. With respect to Funds offered in the U.S., the minimum required initial investment is $25 million, subject to the discretion of Caledonia GP to accept lesser amounts. A minimum initial account size is generally required of SMA clients. As of 1 January 2018, SMAs are no longer offered to new US clients. Caledonia US currently has no separately managed account clients. Any separately managed account clients are managed by Caledonia. Depending on the exemptions relied upon by the Clients, as applicable, investors may be required to meet certain qualification requirements prior to investment. For example, the Clients in the U.S. currently rely on the exclusion from the definition of an investment company provided by Section 3(c)(7) of the Investment Company Act of 1940. Accordingly, investors in such Clients are required to be “accredited investors” as defined for purposes of Regulation D under the Securities Act of 1933 and “qualified purchasers” as defined in Section 2(a)(51) of the Investment Company Act of 1940. Admission to the Clients is not open to the general public. Prospective investors should refer to the appropriate Governing Documents for important qualifications requirements for investment.

As disclosed in Item 5 of this Brochure, Caledonia is generally entitled to receive a Performance Fee from Clients, calculated and payable on an annual basis and as otherwise set out in the Governing Documents. The fact that Caledonia or its affiliates are entitled to receive Performance Fees creates a potential conflict of interest in that it may create an incentive for Caledonia to effect transactions in investments that are riskier or more speculative than would otherwise be the case. Several of Caledonia’s investment personnel are compensated in a manner that includes a performance-based component. The Client’s performance-based compensation is generally calculated on a basis that includes unrealized appreciation of the Client’s assets; such compensation may be greater than if it were based solely on realized gains. While Caledonia has the right to waive performance-based compensation as to particular investors in a Client, Caledonia manages each Client’s portfolio as an undivided pool. Caledonia also generally manages SMAs in parallel with the same investment strategy of the Funds (subject to any investment limitations or other special requirements as set forth in the applicable Governing Document). As a result, Caledonia does not favor any Client over another because of its performance-based fee arrangements. Performance-based fees will only be charged in accordance with the provisions of Rule 205-3 of the Advisers Act. Investors must understand the performance-based method of compensation and its risks prior to subscribing to interests in any Client. Side-by-side management refers to multiple client relationships where an adviser manages more than one advisory client relationship or portfolio on a simultaneous basis. Potential conflicts of interest arise under such side-by-side management including incentives to favor certain clients over others or proprietary accounts over client accounts. As Caledonia endeavors to treat all Clients fairly at all times and to put the interest of Clients first as part of its fiduciary duty as an investment adviser, Caledonia takes the following steps to address any potential conflicts of interest:

Caledonia discloses material conflicts of interest;

Given Caledonia’s long-short global equity strategy is generally applied uniformly across all Clients, subject to other factors described below. Caledonia generally allocates investment opportunities on a pro-rata basis based on the NAV or the “available capital” (the latter takes into account leverage, and is important if two funds or accounts follow the same strategy but differ in terms of the leverage employed) of such funds or accounts after taking into account the “target allocation” to a particular strategy, geography, sector or other relevant characteristics of the subject opportunity, including, without limitation, (i) the investment objectives, risk profile, guidelines or restrictions of such fund or account; (ii) the current portfolio composition of such fund or account; (iii) the need for cash to satisfy redemption requests or other obligations; (iv) tax considerations; (v) the need to bring such fund or account in compliance with its investment guidelines, restrictions by virtue of applicable law and/or internal risk policies; (vi) whether such opportunity will be de minimis for such fund or account; (vii) cash balances, liquidity, leverage and other operational factors, including those inherent at the inception of a fund or account, or at the time of acceptance of a significant inflow of investor capital by a fund or account, in each case, until the applicable subscription proceeds have been invested or substantially invested, and in the case of funds or accounts using leverage, the need to sell positions in order to comply with or avoid margin calls from lenders (or otherwise take steps to improve its standing relative to its lenders); and (viii) on the basis of such other then-current factors that Caledonia may deem appropriate under the circumstances;

Factors that may be considered when allocating trades include, but are not limited to: investment objectives and policies, risk profile, guidelines or restrictions applicable to each Client; the current portfolio composition of such fund or account; tax considerations; actual and targeted cash availability; liquidity requirements for payment of redemptions or other purposes; risk tolerances; restrictions imposed under applicable laws or regulations; counterparty arrangements; account size; industry and security weightings and concentrations; and hedging objectives and activity; and any other factor as set out in the Governing Documents;

Caledonia compares holdings and performance of all Clients to identify any significant performance disparities and underlying causes;

Caledonia educates its employees regarding the responsibilities of a fiduciary, including the need for having a reasonable and independent basis for the investment advice provided to Clients and equitable treatment of all Clients; and

Caledonia maintains written policies to address any potential conflicts including the steps taken above.

Caledonia, on an ongoing basis and in its sole discretion, offers co-investment opportunities in certain investments to certain investors or third parties. Co-investment opportunities may be effected through limited partnerships or other entities formed to effect co-investments. Caledonia will allocate available co-investment opportunities in such a manner as it determines is fair and equitable in its reasonable discretion in accordance with its written policies to address the allocation of investment opportunities. Participation in such opportunities may be limited to a select number of clients or investors based on Caledonia’s consideration of factors, including but not limited to: (i) whether the potential co-investor has expressed an interest in participating in co-investment opportunities; (ii) Caledonia’s evaluation of the potential co-investor’s size and financial resources; (iii) the ability of the potential co-investor to expeditiously participate in the investment opportunity without harming or otherwise prejudicing the other clients participating; (iv) Caledonia’s perception of whether the investment opportunity may subject the potential co-investor to legal, regulatory or other burdens that make it less likely that the potential co-investor would accept the investment opportunity; (v) whether Caledonia believes that allocating the investment opportunity to a potential co-investor will help establish, recognize or strengthen relationships that may provide indirectly longer-term benefits to current or future clients or to Caledonia; (vi) any confidentiality concerns Caledonia has that may arise in connection with providing the potential co-investor with specific information regarding an investment opportunity in order to allow it to evaluate the opportunity; and (vii) other factors deemed relevant by Caledonia.

Neither Caledonia nor any of its management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. Neither Caledonia nor any of its management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor or an associated person of the foregoing entities. An affiliate of Caledonia, Caledonia GP, serves as the general partner of U.S. based feeder funds registered in the Cayman Islands and Delaware. Caledonia Co-Invest GP, also an affiliate of Caledonia, serves as the general partner of a Client and its feeder funds registered in the Cayman Islands. Caledonia US, Caledonia GP and Caledonia Co-Invest GP are related persons of Caledonia.

In this Item 11, “Caledonia” refers to Caledonia and its affiliates. Caledonia has adopted a Code of Ethics (the “Code”), designed to comply with Rule 204A-1 of the Advisers Act. The Code applies to Caledonia’s “Access Persons.” Access Persons include, generally, partners, officers, directors (or other person occupying a similar status or performing similar functions), employees and any other person who provides advice on behalf of Caledonia and is subject to Caledonia’s supervision and control. All of Caledonia’s employees are deemed to be Access Persons. Caledonia and its Access Persons owe a duty of loyalty, fairness and good faith towards Caledonia’s Clients, and have an obligation to adhere not only to the specific provisions of the Code but to the general principles that guide the Code. The Code sets forth a standard of business conduct that takes into account Caledonia’s status as a fiduciary and requires Access Persons to place the interests of Clients and investors above their own interests. The Code is designed to: (i) establish guidelines for professional conduct and personal trading procedures; (ii) prevent improper personal trading by Access Persons; (iii) prevent improper use of material, non-public information about securities recommendations made by Caledonia or securities holdings of the Clients; (iv) identify conflicts of interest; and (v) provide a means to resolve any actual or potential conflict in favor of the Clients and their investors. The Code requires Access Persons to comply with applicable securities laws and regulations. Further, Access Persons are required to promptly bring violations of the Code to the attention of Caledonia’s Chief Compliance Officer. All Access Persons are provided with a copy of the Code annually and upon amendment. Access Persons are required to acknowledge receipt of the Code upon distribution and annually are required to certify that they have read the Manual and agree to abide by its policies and procedures. The Code also sets forth certain requirements with respect to personal trading by Access Persons. Caledonia adopted a prohibition on certain personal securities transactions on 30 June 2018. After this date, within a Discretionary Personal Trading Account, Access Persons are generally limited to holding or selling (subject to Legal and Compliance’s approval) securities or cryptocurrencies held prior to the later of June 30, 2018 or the beginning of the Access Person’s affiliation with Caledonia. Legal and Compliance have discretion to overrule this prohibition if necessary and their approval will remain in effect only for the duration as prescribed in the approval. Participation in placements of securities will also be permissible where (1) the Access Person has a legacy position, (2) Caledonia is not actively trading the relevant security, (3) the placement is offered pro rata to existing shareholders, and (4) Legal and Compliance approved the participation. Access Persons are also permitted to invest in nonreportable securities as defined by the Advisers Act and exchange-traded funds. Access Persons must provide the Chief Compliance Officer with a list of their personal accounts and an initial holdings report within 10 days of becoming an Access Person. In addition, Access Persons must provide annual holdings reports and quarterly transaction reports in accordance with Advisers Act Rule 204A-1. In addition to the Confidentiality Policy discussed in Item 8 of this Brochure, the Code includes further restrictions on and procedures to prevent the misuse of material non-public information. All Access Persons are reminded that any use of such information is strictly limited by the Confidentiality Policy and the Code. Caledonia maintains a “Restricted List” of companies about which a determination has been made that it is prudent to restrict trading activity. Securities included on the Restricted List may include securities held by or being considered for purchase or sale on behalf of a Client or securities of a company about which investment personnel may have acquired material nonpublic information or a position where

Caledonia may have a securities filing obligation. In general, transactions in the securities of a company appearing on the Restricted List (whether on behalf of Advisory Clients or in personal accounts of Access Persons) will not be allowed. Investors or prospective investors may obtain a copy of Caledonia’s Code of Ethics by contacting Caledonia at mmoses@caledonia.com.au or by calling +61 405 568 768. The Code is designed to assure that the personal securities transactions, activities and interests of Access Persons will not interfere with making decisions in the best interest of Clients. Caledonia, its Access Persons or their related persons may also invest directly in some or all of the Clients. Caledonia and/or its Access Persons may buy or sell legacy positions for their personal accounts securities identical to or different from those recommended to Clients. In addition, any related person(s) may have an interest or position in certain securities which may also be recommended to a Client. Each such related person transaction is separately identified and made strictly in accordance with the Code and the terms of the applicable Governing Documents. Caledonia’s procedures require the objective allocation for limited opportunities to ensure fair allocation among accounts. In addition, Caledonia has adopted the aggregation policies and procedures discussed in Item 12 of this Brochure. No Access Person may purchase or sell any security prior to a transaction(s) being implemented for an advisory account, thereby preventing such Access Person from benefiting from, or appearing to benefit from, any transactions placed on behalf of advisory accounts. Caledonia and its Access Persons are prohibited from engaging in principal transactions except as permitted by the Advisers Act. A principal transaction occurs when Caledonia or its Access Persons buy securities for Caledonia or for themselves from a Client; or sell securities owned by Caledonia or the individual(s) to a Client. The Advisers Act makes it unlawful for any investment adviser, directly or indirectly, acting as principal for its own account, to knowingly sell any security to, or purchase any security from, a Client without disclosing to the Client in writing the capacity in which the adviser is acting and obtaining the Client’s consent to the transaction. This rule may apply to certain transactions involving accounts in which investment advisers have interests, such as private fund investments by Caledonia’s owners or Access Persons. The SEC has indicated that when an investment adviser and/or its controlling persons own more than 25% of a fund’s outstanding securities, it would be effectively treated as a principal transaction if such an account were to engage in a trade with another client account or fund. Caledonia has adopted specific policies and procedures for monitoring the level of proprietary ownership in each Client and for obtaining the requisite consent (including through consent granted in the Governing Documents to appoint an “Unaffiliated Consultation Committee”) before engaging in a transaction that would be considered a principal transaction under applicable SEC interpretations. Caledonia and its Access Persons are also prohibited from engaging in agency cross transactions. An agency cross transaction occurs where Caledonia acts as an investment adviser in relation to a transaction in which any person controlled by or under common control with Caledonia, acts as broker for both the advisory client and for another person on the other side of the transaction. The fact that Caledonia, its Access Persons or their related persons have a financial ownership interest in the Clients creates a potential conflict in that it could cause Caledonia to make different investment decisions than if they did not have such a financial ownership interest. Further, Caledonia charges management fees based on a percentage of assets under management. Such an asset-based fee is payable without regard to the overall success or income earned by the Clients and therefore may create an incentive on the part of Caledonia to raise or otherwise increase assets under management to a higher level than would be the case if Caledonia were receiving a lower or no management fee. The receipt of performance-based compensation by Caledonia or its affiliates may create an incentive for Caledonia to make investments that are riskier or more speculative than would be case in the absence of a

performance-based fee structure. Caledonia has adopted the Code which requires Access Persons to act with integrity and place the interests of Clients above their own, avoid actual and potential conflicts of interest and comply with relevant securities laws.

As investment manager to its Clients, Caledonia has discretionary authority to determine which securities and the amounts of securities that are bought or sold. When performing investment management services, Caledonia generally has complete discretion in deciding which brokers and dealers to use for Client transactions and in negotiating the commissions or other compensation payable to such brokers and dealers. In addition to using brokers as “agents” and paying commissions, Caledonia may buy or sell securities directly from or to dealers acting as principal at prices that include markups or markdowns, and may buy securities from underwriters or dealers in public offerings at prices that include compensation to underwriters and dealers. Selection Criteria It is the policy and practice of Caledonia to strive for the best value that is competitive in relation to the value of the transaction (“best execution”). In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the overall best qualitative execution, taking into consideration the full range of a broker-dealer’s services. In selecting a broker, dealer or other intermediary, Caledonia will consider such factors that in good faith and judgment it deems reasonable under the circumstances. Some of the factors Caledonia considers in selecting a broker or dealer include without limitation: (i) price (including commission rate), (ii) the broker-dealer’s facilities, reliability, responsiveness, and financial responsibility, (iii) the ability of the broker-dealer to effect securities transactions, particularly with regard to such aspects as timing, order size and execution of orders and (iv) the research, brokerage and other services provided by such broker-dealer. Caledonia has established prime brokerage arrangements on behalf of Clients with one or more Prime Brokers. Under these arrangements, the Prime Broker, among other things, settles and clears trades, extends margin and securities loans, maintains custody of cash and securities held by Clients and provides detailed portfolio and related reports. Caledonia and its affiliates may, in their sole discretion, change the Prime Brokers, alter the terms of the arrangements with the Prime Brokers or make alternative arrangements to receive the services provided by the Prime Brokers. Caledonia uses additional brokers (in addition to the Prime Brokers) to execute transactions. Caledonia periodically evaluates the execution performance of broker-dealers to ensure that the services provided are consistent with best execution. Dark Pools and Other Private Trading Venues Caledonia, on behalf of its Clients, utilizes so-called “dark pools” and other private trading venues to execute trades of securities. In a dark pool, buyers and sellers do not reveal their identities and often reveal very little, if anything, about their order sizes, as opposed to a traditional exchange, like the NYSE Euronext, where orders are transparent. There are a number of different types of non-displayed liquidity providers, including electronic communications networks (“ECNs”), broker-sponsored dark pools, crossing networks and broker-led consortium dark pools. Dark pools and other anonymous venues may provide price improvement and the ability to protect trade orders from others in the market that would take advantage of information revealed during a trade. Dark pools and other private trading venues generally look to traditional exchanges to get their pricing information. However, if more and more trades are conducted through dark pools and other private trading venues, the prices used in dark pool trades might not be as reliable and up-to-date as they should be. Moreover, the use of dark pools means that firms cannot take advantage of changes in prices because the market cannot react immediately to

transactions occurring in dark pools. Furthermore, different entities in a dark pool cannot see each other and therefore do not have a sense of what each other’s strategies and motives are. In addition, the prices charged by dark pools and crossing networks can be complex and may be higher than those charged by traditional exchanges. The prices charged by dark pools and independently operated crossing networks also may cover execution only and not investment research and other services and may also be used to fund contributions to commission-sharing arrangements. Research and Other Soft Dollar Benefits Caledonia may select a broker-dealer in recognition of the value of various services or products, beyond transaction execution, that such broker-dealer provides where, considering all relevant factors, it believes the broker-dealer can provide best execution. The amount of compensation paid to such brokerdealer may be higher than what another, equally capable broker-dealer might charge. Selecting a brokerdealer in recognition of the provision of services or products other than transaction execution is known as paying for those services or products with “soft dollars.” Accordingly, the commission rates charged by brokers in the foregoing circumstances may be higher than those charged by other brokers who may not offer such services. Caledonia may therefore use a broker who provides soft dollar services and products even though a higher or lower commission may be charged by a broker who does not offer the same level of products and services. Caledonia aggregates all soft dollars received into a pooled account. Research services and other soft dollar benefits may be used in servicing all of Caledonia’s Clients and not all of such research will necessarily be used for the Client for which the particular transaction was effected. Although customary, these arrangements present potential conflicts of interest in allocating securities transactional business to broker-dealers in exchange for soft dollar benefits, including an incentive to select a broker-dealer based on Caledonia’s interest in receiving research or other products or services, rather than on the Clients’ interest in receiving the most favorable execution. Caledonia’s use of soft dollars is intended to comply with the requirements of Section 28(e) of the Securities Exchange Act of 1934 (the “Exchange Act”), to the fullest extent possible under current law and SEC interpretive guidance. Section 28(e) provides a “safe harbor” for investment managers who use commissions or transaction fees paid by their advised accounts, with respect to transactions in securities effected on an agency basis and certain types of riskless principal transactions, to obtain investment research services or other products and services within the meaning of Section 28(e). Section 28(e) does not cover securities transactions effected on a principal basis or transactions in futures or other assets that are not considered to be securities under the Exchange Act. Transactions effected outside the United States (e.g., in the Australian or European markets) are often conducted on a principal basis and, therefore, would not be covered by the Section 28(e) safe harbor. Caledonia will use Client commissions with respect to transactions that would not be covered by Section 28(e) to obtain brokerage and research services provided that the brokerage and research services obtained are of a type that would qualify under Section 28(e). “Research” products and services Caledonia may receive may include economic surveys, data and analysis; financial publications; recommendations or other information about particular companies and industries (through research reports and otherwise); and other products or services (e.g., computer services, software and data bases) that provide lawful and appropriate assistance to the firm in the performance of its investment decision-making responsibilities. Consistent with Section 28(e), “brokerage” products and services (beyond traditional execution services) consist primarily of computer services and software that permit Caledonia to effect securities transactions and perform functions incidental to transaction execution. Research and other soft dollar benefits may be used in servicing all

of Caledonia’s Clients and may be used in connection with Clients other than those which generated the brokerage, as permitted by Section 28(e). During Caledonia’s last fiscal year, as a result of client brokerage commissions (or markups or markdowns), Caledonia and/or its related persons acquired data services (including services providing real time exchange data, market data, company financial data and economic data), software used to transmit orders, proprietary and third party research reports (including market research), certain financial newsletters and trade journals, attendance at certain seminars and conferences, discussions with research analysts, meetings with corporate executives, and services related to execution, clearing and settlement of securities transactions and functions incidental thereto (i.e., connectivity services between Caledonia and a broker-dealer and other relevant parties such as custodians). Section 28(e) does not cover securities transactions effected on a principal basis or transactions in futures or other assets that are not considered to be securities under the Exchange Act. Transactions effected outside the United States (e.g., in the Australian or European markets) are often conducted on a principal basis and, therefore, would not be covered by the Section 28(e) safe harbor. Caledonia will use Client commissions with respect to transactions that would not be covered by Section 28(e) to obtain brokerage and research services provided that the brokerage and research services obtained are of a type that would qualify under Section 28(e). In the event any products or services obtained by Caledonia with Client commissions have “mixed uses,” (i.e., for research and non-research purposes), Caledonia will make a good faith effort to determine the relative proportion of the product or service it used to assist it in carrying out its investment decisionmaking responsibilities and the relative proportion used for administrative or other purposes outside Section 28(e). Such determination will be made in accordance with the SEC’s interpretive guidance. The proportion of the product or service attributable to assisting Caledonia in carrying out its investment decision-making responsibilities will be paid through brokerage commissions generated by client transactions (“soft dollars”) and the proportion attributable to administrative or other purposes outside Section 28(e) will be paid for by Caledonia from its own resources (“hard dollars”). Although Caledonia will make a good faith and reasonable allocation of the eligible costs of the product or service for brokerage or research, the allocation determination itself poses a potential conflict of interest as Caledonia may have an incentive to overestimate the soft dollar portion allocated to the “mixed use” product or service in order to avoid paying for such brokerage or research with hard dollars. Brokerage for Client Referrals Representatives of Caledonia, from time to time, may speak at conferences and programs for investors interested in investing in hedge funds which are sponsored by prime brokers or other broker-dealers. These conferences and programs may be a means by which Caledonia can be introduced to prospective investors in the Clients. Generally, the sponsoring brokers are not compensated by Caledonia, the Client(s) or prospective investors for providing such “capital introduction” opportunities. However, the provision of these opportunities, as well as other introductions to prospective investors, by a broker may influence Caledonia in deciding whether to use the services of such broker in connection with the activities of the Client(s). Accordingly, Caledonia will have a conflict of interest when allocating brokerage business to a broker who has referred investors to the Clients or who has provided Caledonia with the opportunity to participate in capital introduction events. To prevent brokerage commissions from being used to compensate brokers for investor referrals, Caledonia will not allocate Client brokerage business to a referring broker unless Caledonia determines in good faith that the commissions payable to such broker is consistent with seeking best execution.

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Other than as already disclosed at Item 5 of this Brochure, neither Caledonia or its Access Persons receive compensation from third parties in connection with providing investment advice to its Clients. Caledonia has not entered into arrangements to compensate any third-party solicitor, placement agents and/or others, for referring prospective clients or investors to Caledonia. Caledonia reserves the right to enter into arrangements in the future to compensate certain third-party placement agents and/or others for referring prospective clients to Caledonia. Although common, such referral arrangements do create a potential conflict of interest because, in theory, the referrer may be motivated, at least partially, by financial gain and not because the Clients are the most suitable to the needs of the prospective investor. To address this potential conflict of interest, all referred investors and SMA clients will be carefully screened to ensure that the particular Client is suitable to the prospective investor’s investment needs, objectives and risk tolerance before any subscription is accepted. In the event Caledonia enters into such arrangements in the future, all such arrangements will be conducted in a manner that is consistent with relevant SEC guidance and all fees paid to solicitors, if any, will be fully disclosed to investors consistent with applicable law.

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client’s or investor’s evaluation of the adviser or the integrity of the adviser’s management. Neither Caledonia nor any of its officers, directors, employees or other management persons have been involved in any legal or disciplinary events in the past ten (10) years that would require disclosure in response to this Item.

Caledonia monitors the underlying investments of Clients on a regular basis. Client positions will be reviewed in the overall context of the Client’s investment objectives and guidelines as well as geopolitical and macroeconomic events. All reviews are conducted by the Co-Chief Investment Officers, General Counsel / Chief Compliance Officer or Chief Financial Officer. Client investors receive unaudited monthly performance reports in accordance with applicable Governing Documents. Each Client’s investors will also receive, as soon as practicable after the end of each taxable year (or as otherwise required by law), annual reports containing financial statements audited by Client’s independent auditors as well as such tax information as is necessary for each investor to complete federal and state income tax or information returns, along with any other tax information required by law. Each SMA client will generally receive unaudited monthly performance reports and annual reports from Caledonia detailing the SMA account’s exposures and positions as well as other reasonable information on an as requested basis in accordance with the Governing Document or as otherwise separately agreed.

As previously disclosed at Item 5 of this Brochure, Caledonia directly debits advisory fees from Client accounts. As part of this billing process, the Client’s administrator is advised of the amount of the fee to be deducted from that Client’s account. Any U.S.-based Client to engage Caledonia will receive a statement at least quarterly (typically monthly) from their account administrator. This statement should reflect all withdrawals and other transactions that have taken place in the account, including fee deductions. It is important for Clients to carefully review their statements to verify the accuracy of the calculation, among other things. Clients should contact Caledonia directly if they believe that there may be an error in the calculation of their fees as reflected on their statement. In addition to account statements received directly from the account administrator, as agreed, certain SMA clients will also receive unaudited monthly performance reports from Caledonia. Caledonia urges its Clients to carefully compare the information provided on these performance reports with the statements received from the account administrator to ensure that all account transactions, holdings and values are correct. Finally, because of Caledonia’s authority with respect to the assets of the Clients, Caledonia is deemed to have custody of client assets under the provisions of SEC Rule 206(4)-2 (the “Custody Rule”). With respect to Clients that are domiciled in the United States and/or are offered to U.S. investors, Caledonia’s related persons are deemed to have custody of the Clients’ assets because these related persons serve as general partner (or in similar capacity) to the Clients. To ensure compliance with Rule 206(4)-2 under the Advisers Act, Caledonia will ensure that the Clients are subject to annual audit by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board in accordance with its rules. In addition, such Clients’ audited financial statements will prepared in accordance with U.S. generally accepted accounting principles (“U.S. GAAP”) and will be distributed to all investors within 120 days of the end of each Client’s fiscal year. The Clients are also subject to audit upon liquidation and the audited financial statements will be distributed to all investors promptly after the completion of such audit. Pursuant to SEC interpretations, as set forth in the “SEC Staff Response to Questions About the Custody Rule,” Question VI.5 and SEC Staff Letter to the ABA, Subcommittee on Private Investment Entities, issued December 8, 2005, offshore advisers registered with the SEC are not subject to the Custody Rule with respect to offshore funds. Certain of the Clients that are domiciled outside of the United States and are not offered to U.S. investors may be able to rely on such exemptions. Nevertheless, as would be required under the Custody Rule, each of the relevant Clients is subject to an annual audit by an independent public accountant and Caledonia seeks to send the audited financials in accordance with the Governing Documents to each Client investor within 120 days of each Client’s fiscal year end, in accordance with the provisions of the Custody Rule, as described above. Clients organized outside of the United States, or having a general partner or other manager with a principal place of business outside the United States, may have their financial statements prepared in accordance with accounting standards other than U.S. GAAP so long as they contain information substantially similar to statements prepared in accordance with U.S. GAAP. Any material differences with U.S. GAAP must be reconciled in the financial statements delivered to U.S. persons.

As investment adviser to the Clients, Caledonia is granted the discretionary authority in the relevant Governing Documents to determine which securities and the amounts of securities that are bought or sold for the Clients. SMA clients may limit this authority by giving Caledonia written instructions in accordance with the Governing Documents and may change/amend such limitations in certain circumstances by once again providing Caledonia with written instructions.

As applicable, Caledonia is generally granted the authority and responsibility in relevant Governing Documents to vote proxies solicited by the issuers of securities held in Client accounts. Caledonia has adopted written policies and procedures governing the voting of such proxies. According to such policies, Caledonia will vote proxies in a manner that it determines in good faith to be in the best interest of its Clients, typically with the goal of maximizing value for Clients. To that end, Caledonia endeavors to vote proxies in the manner that it determines in good faith to be most likely to cause Clients’ investments to increase the most, or decline the least, in value. Consideration is given to both the shortterm and long-term implications of the proposal being voted on. If a material conflict of interest between Caledonia and a client exists, Caledonia will determine whether voting in accordance with the guidelines set forth in its proxy voting policies and procedures is in the best interests of the client or take some other appropriate action. In the event of any actual or potential conflicts of interests in the voting of any Client proxies, Caledonia will make appropriate disclosures to clients and either abstain from voting or request that the Client vote the proxy(s). Clients may obtain a copy of Caledonia’s proxy voting policies and procedures and information about how Caledonia voted a Client’s proxies by contacting Caledonia at mmoses@caledonia.com.au or by phone at +61 2 9255 7600. It is Caledonia’s policy to not participate in class action lawsuits on behalf of Clients. Caledonia would develop procedures should Caledonia’s policy regarding participation in class action lawsuits change.

This Item is not applicable.