Capricorn Investment Group LLC

Overview of Capricorn Investment Group, LLC This Brochure provides information for ten investment advisers, as detailed below: (i) Capricorn Investment Group, LLC; (ii) Capricorn Advisers, LLC; (iii) Capricorn Management, LLC; (iv) Capricorn-Libra Partners, LLC; (v) TIF Partners, LLC; (vi) TIF Partners II, LLC; (vii) TIGF Partners, LLC, (viii) TIGF Partners II, LLC, (ix) SIF Partners LLC, and (x) Sustainable Investors Fund GP S.à r.l. In accordance with the 2012 ABA SEC No-Action Letter, Capricorn Investment Group, LLC (“Capricorn”) is the “filing adviser.” The following entities serve as the “relying advisers”: (i) Capricorn Advisers, LLC; (ii) Capricorn Management, LLC; (iii) Capricorn-Libra Partners, LLC; (iv) TIF Partners, LLC; (v) TIF Partners II, LLC; (vi) TIGF Partners, LLC, (vii) TIGF Partners II, LLC, (viii) SIF Partners LLC, and (ix) Sustainable Investors Fund GP S.à r.l. References to Capricorn in this Brochure are generally intended to encompass the relying advisers, except where otherwise noted. Capricorn and its relying advisers operate as a single advisory business. Capricorn supervises the advisory activities of its relying advisers and is responsible for ensuring that such activities comply with applicable regulatory requirements. Capricorn Investment Group, LLC is a Delaware limited liability company that provides investment advisory services to high-net-worth individuals, families and their related entities, charitable organizations, and pooled investment vehicles. Capricorn was established in April of 2007 to continue the business of Capricorn Management, LLC (“Capricorn Management”), which commenced business in 2001 as a family office for Capricorn’s anchor client. Capricorn provides certain advisory services in conjunction with a wholly-owned subsidiary, Capricorn Advisers, LLC, a Delaware limited liability company (“Capricorn Advisers”). Capricorn has entered into a services agreement with Capricorn Advisers pursuant to which Capricorn Advisers provides investment advice and related services to Capricorn in exchange for a portion of the management fees paid with respect to Capricorn client investments. The principal owner of Capricorn is a limited liability company that is owned by the Jeffrey S. Skoll Revocable Trust. Other owners of Capricorn hold ownership interests of less than 25%, which is disclosed in Schedule A of Capricorn’s Form ADV Part 1. On a day-to-day basis, Capricorn is managed by Dr. Ion Yadigaroglu, Managing Principal and Member. B. Description of Advisory Services Capricorn provides ongoing investment advisory services to individuals, families, and related entities, including high-net-worth individuals, charitable foundations, endowments, and other institutional clients (collectively, “Clients”). Capricorn delivers these services through three primary service offerings (described in Item 4 below): (1) the Investment Advisory Client Program; (2) the Discretionary Client IHP Program; and (3) the Private Fund Strategies. Capricorn also provides investment advisory services through certain legacy advisory arrangements that are maintained for existing Clients (described in Item 4 below).

C. Investment Advisory Client Program Capricorn provides investment advisory services under the Investment Advisory Client Program to Clients on an ongoing basis (each, an “Investment Advisory Client”). Advisory services under the Investment Advisory Client Program are tailored to each Client’s financial circumstances, investment objectives, time horizon, liquidity needs, and risk tolerance. Capricorn gathers this information through discussions with the Client and other information provided by the Client. Capricorn relies on information provided by Clients and does not independently verify the accuracy or completeness of such information. Based on this information, Capricorn develops investment guidelines and an asset allocation framework designed to align the Client’s portfolio with the Client’s stated objectives and constraints. Capricorn implements a scenario-based and mean variance approach to guide capital allocation and risk management for its Investment Advisory Clients. Capricorn’s vision is to provide consistently strong investment performance and risk management, with a principled investment approach. Capricorn believes that achieving superior investment returns does not preclude a principled investment approach, meaning that Capricorn’s people, processes and underlying investments seek to be of uncompromising quality, aligned with the interests of its Clients, ethical, fair, long-term oriented and not directly harmful to our world or people. Discretionary and Non-Discretionary Services Capricorn manages Investment Advisory Client portfolios on both a discretionary and nondiscretionary basis. Discretionary or non-discretionary authority is granted by Investment Advisory Clients through the applicable investment advisory services agreement or other written authorization. When Capricorn has discretionary authority, it may make investment decisions and implement transactions without obtaining prior Client approval for each transaction, subject to the Client’s investment objectives and any agreed-upon restrictions. For non-discretionary accounts, Capricorn obtains Client approval before implementing investment decisions. Investment Advisory Clients may impose reasonable restrictions on investments in certain securities, asset classes, or industries, provided Capricorn determines that such restrictions are operationally feasible and consistent with the overall management of the account. Such restrictions are documented in each Client’s investment advisory services agreement or investment policy statement. Use of Third-Party Investment Managers Capricorn may allocate all or a portion of an Investment Advisory Client’s portfolio to independent managers (“Third-Party Managers”). Capricorn assists Clients in evaluating and selecting ThirdParty Managers and may recommend allocating assets among multiple managers or strategies. In recommending Third-Party Managers, Capricorn considers factors, including the Client’s investment objectives and risk tolerance, liquidity requirements, account size, the manager’s investment strategy, historical performance and operational considerations. Third-Party Managers are responsible for the day-to-day management of assets allocated to them. Capricorn monitors the performance of Third-Party Managers and evaluates their continued suitability for Client portfolios but does not control their investment decisions. If Capricorn determines that a Third-Party Manager is no longer appropriate for a Client’s portfolio, Capricorn may recommend reallocating assets to another manager or strategy. For discretionary accounts, Capricorn may implement such changes without prior Client approval. For non-discretionary accounts, Capricorn will obtain Client consent before implementing such changes. Certain strategies implemented by Third-Party Managers may involve investments in private funds or other

illiquid securities that may be subject to lock-up periods or other restrictions on withdrawals. Clients should review the applicable offering documents carefully. Direct Investments and Public Securities In addition to allocating assets to Third-Party Managers, Capricorn may allocate Investment Advisory Client assets directly among various investment vehicles and securities. These may include: mutual funds, exchange-traded funds (ETF’s), interval funds, equities, options, fixed income securities, commercial paper, certificates of deposit, and other investment products. Asset allocations are determined based on the Client’s investment objectives, risk tolerance, time horizon, liquidity needs, and other relevant factors. When selecting mutual funds or other pooled investment vehicles, Capricorn may consider factors such as, but not limited to, the fund’s investment objectives, investment strategy, portfolio management team, historical performance, sector exposure, and fee structure. Advisory Platform Overview Capricorn provides advisory services under the Investment Advisory Client Program through a variety of investment structures, including separately managed accounts, limited partnerships, and other investment entities established for the benefit of individual Clients. Depending on a Client’s circumstances, assets may be invested directly in securities or through investment entities designed to facilitate investment in private funds, co-investments, or other investment opportunities. These structures may be used for legal, tax, operational, or administrative reasons. In connection with these investment vehicles, Capricorn or its affiliates may serve in one or more roles, including investment adviser, manager, or general partner. Capricorn may have multiple Investment Advisory Clients and affiliated investment vehicles that may be eligible to participate in the same investment opportunities. In such cases, Capricorn allocates investment opportunities among Clients and affiliated vehicles in a manner that it believes is fair and equitable over time and consistent with each Client’s investment objectives, available capital, investment guidelines, and other relevant factors. D. Discretionary Client IHP Program Capricorn allocates and manages the assets of certain discretionary Clients through limited partnerships and other investment entities (the “Discretionary Client IHP Program”). Under the Discretionary Client IHP Program, Capricorn advises single-investor Delaware limited partnerships (each, an “Investor Holding Partnership” or “IHP”) or single-investor Cayman Islands limited partnerships (each, a “Cayman Partnership”). Each Cayman Partnership invests in a Delaware limited partnership created specifically for that Cayman Partnership (also an IHP). Capricorn serves as the general partner of each IHP and Cayman Partnership. Each IHP invests its assets in a range of investment opportunities (each an “Underlying Investment”), including: funds managed by third parties, funds managed by Capricorn or its relying advisers and affiliates, direct investments, co-investment opportunities and other opportunities. For certain non-US clients, Capricorn has established a structure similar to the IHP structure described above in which a Luxembourg SICAV serves as the primary investment vehicle and allocates capital to third-party investment managers and funds (“Underlying Investments”). Where

applicable, references to IHPs in this Brochure include references to the activities of the Luxembourg SICAV structure. E. Legacy Client Program Capricorn provides both discretionary and non-discretionary investment advisory services under a legacy arrangement with a particular high-net-worth client (the “Individual Client”) and certain non-taxable entities established by the Individual Client (the “Non-Taxable Entities”)(collectively, the “Legacy Client Program”). The Legacy Client Program operates independently from the Investment Advisory Client Program and the Discretionary Client IHP Program, though Capricorn’s fiduciary obligations, compliance program, and Code of Ethics apply equally across all programs. With respect to the Individual Client’s personal assets, Capricorn provides non-discretionary advisory services through a series of entities ultimately controlled by Capricorn Management, LLC (“Capricorn Management”), an entity wholly owned by the Individual Client. Capricorn is a nonmanaging member of Capricorn Management and has entered into an investment advisory services agreement (the “Advisory Agreement”) with an indirect subsidiary of Capricorn Management (the “Advisory Subsidiary”). Pursuant to the Advisory Agreement, Capricorn provides investment advice with respect to the investment of the Individual Client’s assets. Capricorn Management is a relying adviser of Capricorn. With respect to the Non-Taxable Entities, Capricorn provides discretionary investment advice pursuant to an investment management agreement between Capricorn and the Non-Taxable Entities. The assets of the Non-Taxable Entities are invested directly in Underlying Investments, often alongside the IHPs. The Individual Client is a control person of Capricorn. Although Capricorn is 50% owned by an entity that is wholly owned by a trust under the control of the Individual Client, that entity holds only 42.5% of Capricorn’s economic interests. As a result, Capricorn’s advisory relationship with the Individual Client and related entities presents potential conflicts of interest because Capricorn may have an incentive to favor accounts associated with the Individual Client over other Clients. Capricorn addresses these conflicts through policies and procedures designed to ensure that investment opportunities are allocated in a manner that Capricorn believes is fair and equitable over time and consistent with its fiduciary obligations. These conflicts are discussed further in Item 11. F. Private Fund Strategies Below provides a description of the investment strategies and respective funds managed by Capricorn and Capricorn’s relying adviser entities (the “Private Fund Strategies”). Capricorn-Libra Strategy (“LIBRA”): Capricorn acts as investment adviser to Capricorn-Libra Investment Group, LP (the “LIBRA Fund”), which pursues investments primarily in the sustainable technology sector. The general partner of the LIBRA Fund is Capricorn-Libra Partners, LLC, a relying adviser of Capricorn. The principal of LIBRA is Dipender Saluja. Conflicts of interest relating to LIBRA are discussed in Item 10 and Item 11 below. Technology Impact Fund Strategy (“TIF”): Capricorn acts as investment adviser to Technology Impact Fund, LP, TIF Partners, LLC, Technology Impact Fund II, LP, and TIF Partners II, LLC (collectively, the “TIF Funds”), which pursue investments primarily in early-stage companies

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Compensation and Fee Schedule Detailed information with respect to how Capricorn is compensated for the advisory services it provides is contained in the operative governing documents and/or advisory contracts for the Clients. Generally, Capricorn is compensated by the receipt of management fees and certain performance-based allocations, also described in Item 6 below. Prospective investors should carefully review the operative documents for the relevant investing vehicle prior to making an investment and/or retaining Capricorn as an investment adviser. It should be noted that certain advisory fees are negotiable in that Capricorn has waived (in whole or in part) the fees paid by certain Clients and investors in the Funds and may enter into different fee agreements with different Clients or investors, including employees and affiliates of Capricorn, in its discretion. Capricorn has in certain circumstances invested Client assets in affiliated private investment funds or in private funds for which Capricorn retains certain economic interests. Under such circumstances, Capricorn’s Clients may be subject to two layers of fees for the management of these assets, one to Capricorn and one to the adviser of the vehicle, who may be Capricorn or a Capricorn affiliate. For a discussion of the conflicts of interest posed by such related party transactions, see Item 10 and Item 11. Neither Capricorn nor its supervised persons accept compensation for the sales of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds.

B.

Deduction of Advisory and Incentive Fees Advisory Fees Capricorn generally deducts advisory fees directly from its Clients’ assets. Advisory fees are typically calculated and charged quarterly, either in advance or in arrears, based on the terms of each Client’s investment advisory services agreement, offering documents, or governing partnership agreement, as applicable. The specific advisory fee rate, calculation methodology, and billing frequency applicable to each Client or Fund are set forth in the relevant advisory agreement or offering documents. Advisory fee rates may differ among Clients and Fund investors based on factors including, but not limited to, the size of the investment, the scope of services provided, the nature of the Client relationship, and individually negotiated terms (including side letter arrangements). With respect to certain Clients and legacy arrangements, Capricorn does not charge or receive advisory fees. In such cases, Capricorn may receive compensation solely through incentive allocations, as described below, or may provide advisory services on a fee-waived basis. Capricorn waives all advisory fees for its employees who invest in its Private Fund Strategies or who enter into an investment advisory services agreement with Capricorn. Incentive Compensation Capricorn or its affiliated general partner entities may receive incentive-based compensation in the form of a carried interest allocation or incentive fee, as applicable, from certain Funds and Client

accounts. Incentive compensation is calculated and recorded annually or quarterly, depending on the terms of the applicable Fund’s governing documents or the Client’s advisory agreement. The receipt of incentive-based compensation creates a potential conflict of interest, as it may incentivize Capricorn to make investments that are riskier or more speculative than would be the case in the absence of such compensation. Additionally, incentive-based compensation may create an incentive for Capricorn to favor accounts or Funds that pay incentive compensation over those that do not, or to allocate investment opportunities in a manner that benefits accounts or Funds with higher incentive compensation potential. These conflicts are discussed further in Item 6, Item 10, and Item 11 below. Fee Deduction Process Advisory fees and, where applicable, incentive allocations are deducted directly from Client assets or allocated from Fund assets in accordance with each Client’s advisory agreement or the applicable Fund’s governing documents. C. Fees and Expenses of the Investment Advisory Client Program In addition to advisory fees and incentive compensation described above, Investment Advisory Clients bear all direct costs and expenses incurred in connection with the management of their accounts (whether or not an investment is ultimately consummated), including but not limited to: (i) all general investment expenses (i.e., brokerage commissions, transaction fees, and other related costs and expenses); (ii) management fees and carried interest, if any, of any Underlying Investments; (iii) fees, costs, and expenses of third-party service providers; and (iv) custodial fees, bank charges, and wire transfer fees. The specific fees and expenses applicable to each Investment Advisory Client are set forth in the Client’s investment advisory services agreement. Clients should review their applicable agreement for a complete description of all fees and expenses. D. Fees and Expenses of the Private Fund Strategies In general, the Funds are responsible for all expenses and fees related to an investment including, without limitation, will bear all direct costs and expenses incurred in the holding, purchase, sale or exchange of any investments in the portfolio (whether or not ultimately consummated), including, but not by way of limitation, (i) all general investment expenses (i.e., brokerage commissions, transaction fees, and other related costs and expenses); (ii) management fees and carried interest, if any, of any Underlying Investments (if applicable); (iii) all administrative, legal, accounting, auditing, record-keeping, tax form preparation; (iv) fees, costs and expenses of third-party service providers that provide such services. E. Fees and Expenses of the Discretionary Client IHP Program Each IHP will bear all direct costs and expenses incurred in the holding, purchase, sale or exchange of any IHP investments (whether or not ultimately consummated), including, but not by way of limitation, (i) all general investment expenses (i.e., brokerage commissions, transaction fees, and other related costs and expenses); (ii) management fees and carried interest, if any, of any Underlying Investments; (iii) all administrative, legal, accounting, auditing, record-keeping, tax form preparation; (iv) fees, costs and expenses of third-party service providers that provide such services.

F. Fees and Expenses of the Legacy Client Program Each Client in the Legacy Client Program will bear all direct costs and expenses incurred in the holding, purchase, sale or exchange of any investments in the portfolio (whether or not ultimately consummated), including, but not by way of limitation, (i) all general investment expenses (i.e., brokerage commissions, transaction fees, and other related costs and expenses); (ii) management fees and carried interest, if any, of any Underlying Investments; (iii) all administrative, legal, accounting, auditing, record-keeping, tax form preparation; (iv) fees, costs and expenses of thirdparty service providers that provide such services. G. Ancillary Fees and Management Fee Offsets As described in greater detail in the applicable Fund’s governing documents, Capricorn, certain affiliates and its employees may receive break-up and topping fees, commitment fees, monitoring and directors’ fees and transaction, financing, divestment and other fees from portfolio companies as compensation for financial advisory and other services such persons provide to portfolio companies. If Capricorn (and/or any affiliate or employee) is paid such fees, such fees will be directly or indirectly offset against the management fees payable by the applicable Fund to the extent required by such Fund’s governing documents. For additional details regarding the management fee offset arrangements in effect for a particular Fund, please review such Fund’s governing documents. These fees, and the associated conflicts of interest they present, are further described in Item 11 below. H. Prepayment of Fees With respect to Investment Advisory Clients, fees are paid in arrears or in advance, as described in the Client's investment advisory services agreement. For Clients whose fees are paid in advance, if an advisory contract is terminated before the end of a billing period, the amount of the fee paid in advance will be pro-rated and rebated. With respect to the Private Fund Strategies, investors pay any applicable management fees in advance on a quarterly or semi-annual basis, as described in the applicable Fund’s governing documents. Typically, investors cannot withdraw from the Private Fund Strategies. Accordingly, such investors would not be entitled to a refund. With respect to Clients in the Discretionary Client IHP Program, fees are paid in arrears or in advance, as described in the Client’s operative governing documents and/or advisory contracts. For Clients whose fees are paid in advance, if an advisory contract is terminated before the end of a billing period, the amount of the fee paid in advance will be pro-rated and rebated. With respect to the Clients in the Legacy Client Program, a portion of the fees are paid in advance., If an advisory contract is terminated before the end of a billing period, the amount of the fee paid in advance will be pro-rated and rebated.

Method of Analysis and Investment Strategies Investment Advisory Client Program, Discretionary Client IHP Program and Legacy Client Program The following relates primarily to the investment advisory activities engaged in by Capricorn. The method of analysis and investment strategies used in formulating advice for Capricorn’s Investment Advisory Client Program, the Discretionary Client IHP Program, and the Legacy Client Program are generally the same. However, with respect to non-discretionary clients, including Investment Advisory Clients who have not granted discretionary authority and the Individual Client under the Legacy Client Program, investment decisions are ultimately made by the Client. Capricorn’s principal objective in managing Client assets is to construct and manage an investment portfolio oriented toward long-term capital appreciation. The basic elements underpinning this objective include the following: • • • •

Developing, in conjunction with the Client, a strategic asset allocation strategy for the Client which will guide the Client’s allocations among a variety of asset classes and investment strategies; Integration of impact factors in developing Clients’ investment portfolios; Implementing the Client’s asset allocation strategy by constructing and actively managing a portfolio of investments across one or more asset classes; Constructing and actively managing a portfolio for each Client that is expected to be generally consistent with such Client’s investment objectives.

Capricorn employs a scenario-based model to determine the appropriate long-term strategic asset allocation for each Client. This approach also incorporates the risk, return, and liquidity parameters of the Client, as well as Capricorn’s subjective investment perspectives on future opportunities. It is important to note that the asset allocation strategies are long-term targets and not expected, due to the time required for investment ramp-up, asset valuation volatility, the natural flows of capital and other factors, to be fixed or static at the target levels. Rather, these strategic targets will function as objectives guiding the overall portfolio exposures. Capricorn’s investment strategy provides diversified exposure to the following asset classes. Capricorn expects to modify this list of investment strategies as necessary from time to time. • • • • • • • •

Cash Fixed income Absolute return Global public equities Private equity & venture capital Real Assets Credit Strategies Hard assets (e.g. gold)

Selection of Underlying Investments Capricorn will conduct sourcing, due diligence, and selection of the Underlying Investments, and will monitor and manage such selections across asset classes on an ongoing basis. The ultimate number of Underlying Investments will be determined in the discretion of Capricorn. Capricorn will seek to have an adequate level of diversification among the Underlying Investments while maintaining enough concentration to achieve the Client’s investment objectives. The objective of the investment analysis process is to select a set of investments that assist in meeting the overall investment objective of long-term capital growth. Capricorn intends to follow a comprehensive investment selection process. In general, the selection process begins by assessing a wide variety of investment funds and opportunities across the various investment strategies. A high number of investments are rejected at an initial high-level review if they do not meet Capricorn’s quality standards or the prevailing strategic framework. Investment opportunities that are deemed a potential fit with the investment objectives are then subject to a due diligence and review process during which additional research is performed on the investment opportunity. Many investment opportunities are rejected at this stage and do not proceed past the comprehensive due diligence process. Investment opportunities that are not rejected move to a final phase of due diligence, which is the final step toward investment. The objective of the investment analysis process is to select a set of investments which underpin the overall investment objective of long-term capital growth. Portfolio Impact Allocation Capricorn generally categorizes investments across client portfolios according to its Portfolio Impact Allocation framework, which classifies investments by their alignment with one of the following key impact issue areas: Climate Change Mitigation. Investments oriented toward energy transition, natural resource conservation, sustainable food and agriculture, regenerative systems and circular economy, earth and space systems monitoring, sustainable real estate and infrastructure, and climate change resilience. Healthcare. Investments focused on health equity, healthcare access, healthcare innovation, and consumer health applications. Responsible Stewardship. Investments in sustainable markets, including strategies that actively engage companies on environmental and social issue areas, align capital with companies demonstrating strong sustainability practices, and promote responsible long-term corporate stewardship. Economic Opportunity. Investments targeting capital access and economic growth, housing access and infrastructure, education and workforce development, employment opportunities and mobility, and new services and market development. Neutral. Investments that are not specifically aligned with one of the above impact issue areas but are selected to fulfill portfolio objectives such as, but not limited to, diversification, risk management, or return generation. This framework enables Capricorn to integrate impact themes across a multi-asset class portfolio while aligning with each Client's specific risk-return profile and mission objectives. The core

impact objectives underpinning this framework are to accelerate innovation, scale effective solutions, broaden access and catalyze progress, and drive sustainable growth. Any impact goals are aspirational and are not guarantees or promises that all such goals will be met. There is no guarantee that any investment will have or create a positive impact or that any impact considerations by Capricorn will ultimately align with the goals of Capricorn or any individual investor. Impact goals may be subject to change. Risk Management Capricorn intends to follow a rigorous program to seek to manage investment risks. Overall, managing risks in an investment portfolio begins with a quality sourcing, due diligence and selection process with the objective of having a diversified portfolio of Underlying Investments. Once investments are executed, Capricorn uses a series of portfolio reporting and management systems and tools to track investments against expectations and reviews a range of return and risk analyses on a regular basis. As part of the risk management process, Capricorn monitors allocations across the Underlying Investments, and allocations across other categories including geographies and industries. A series of regular internal reports are provided by the Operations team and reviewed frequently by the Portfolio Management team. Capricorn seeks regular interactions with representatives from Underlying Investments, which include in-person meetings and teleconferences. LIBRA: LIBRA’s focus area is early to expansion stage energy technology, IT, agriculture, and emerging markets. TIF: TIF’s focus area is early to expansion stage companies operating within the technology sector. TIGF: TIGF’s focus area is growth-stage companies operating within the technology sector. CIG DS: CIG DS’ focus area is growth-stage companies operating within the technology sector. CIG LC: CIG LC’s focus area is low-carbon public equities. SIF: SIF’s focus area is early-stage investment and ownership in public and private asset managers who incorporate sustainability as a primary attribute of their investment thesis. B.

Risk Factors Investing in securities and other investments involves the risk of loss of principal. Clients should be prepared to bear such losses. Capricorn is of the view that all of the investment strategies used by Capricorn are subject to significant risks and are meant for financially sophisticated clients and investors. These risks include the risk of total loss as well as risks related to making illiquid investments. Clients should not retain Capricorn as an investment adviser unless they are able to bear these risks and are able to sustain long periods of illiquidity with respect to the investments made by Capricorn and in funds managed by Capricorn. As noted above, Clients of Capricorn presently access Capricorn’s investment strategies through the Investment Advisory Client Program, the Discretionary Client IHP Program, the Private Fund Strategies, and other investment vehicles that comprise LIBRA, TIF, TIGF, CIG DS, CIG LC, and SIF or, in the case of Clients in the Legacy Client Program, by investing directly in Underlying Investments. A significant portion of these investments, and the investments of LIBRA, TIF, TIGF,

CIG DS, and SIF, tend to be with privately-placed vehicles with significant liquidity constraints. Clients need to be ready to bear their investments for an extended period of time. Discretionary Authority and Client Decision-Making. The investment decisions of the Capricorn-managed private Funds are made exclusively by Capricorn. Investors will have no right or power to take part in the management of the Capricorn-managed Funds. Key Personnel Risk. Capricorn’s operations are substantially dependent upon the skill, judgment, and expertise of certain key personnel and its employees or agents. Capricorn’s investment strategy requires knowledge in areas such as impact analysis, impact measurement, and sustainable finance. The market for professionals with knowledge in these areas is competitive, and there can be no assurance that Capricorn will be able to retain or replace qualified personnel. The death, disability, departure, or other unavailability of any key personnel could have a material and adverse effect on Capricorn’s Clients. Underlying Investment Manager Risk. Capricorn constructs and manages Client portfolios by allocating capital to Underlying Investments. The performance of Client portfolios depends in significant part on the skill, judgment, and operational integrity of these underlying managers. There can be no assurance that Capricorn’s due diligence and ongoing monitoring processes will identify all material risks associated with an underlying manager, including the risk that a manager may underperform in benchmarks or peers, deviate from its stated investment strategy, experience key personnel departures, encounter operational or compliance failures, or engage in fraud or other misconduct. Capricorn’s ability to obtain timely and accurate information from underlying managers may be limited, particular with respect to private and illiquid investments, and there may be delays in detecting adverse developments. The termination of or withdrawal from an Underlying Investment may be subject to lock-up periods, notice requirements, or other restrictions that could prevent Capricorn from acting promptly to protect Client interests. Conflicts of Interest. Capricorn and its respective affiliates may encounter potential conflicts of interest in connection with Advisory Client interests, assets or activities (including certain conflicts of interest as among the interests of different Private Fund Strategy vehicles). If any matter arises that Capricorn determines in its good faith judgment constitutes an actual conflict of interest, Capricorn will take such actions as may be necessary or appropriate to ameliorate the conflict. Affiliated Sector Overlap. Capricorn and its affiliated entities frequently make investments in a wide variety of sectors, including clean technology, which is similar across a variety of Clients. Capricorn and its affiliated entities may invest in a company in one Client and not another because the investment may be more suitable for one. Cybersecurity Risk. Capricorn, its service providers, and other market participants increasingly depend on complex information technology and communications systems to conduct business functions. These systems are subject to a number of different threats or risks that could adversely affect Clients and investors, despite the efforts of Capricorn and its service providers to adopt technologies, processes and practices intended to mitigate these risks and protect the security of their computer systems, software, networks and other technology assets, as well as the confidentiality, integrity and availability of information belonging to Clients and investors. For example, unauthorized third parties may attempt to improperly access, modify, disrupt the operations of, or prevent access to these systems of Capricorn, its service providers, counterparties or data within these systems. Third parties may also attempt to fraudulently induce employees, customers, third-party service providers or other users of Capricorn’s systems to disclose sensitive information in order to gain access to Capricorn’s data or that of Capricorn’s Clients and investors.

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As described in Item 4, Capricorn (as of the date of this ADV Part 2A) provides investment advisory services to high-net-worth individuals, families and their related entities, charitable organizations, and pooled investment vehicles.. Investors in Capricorn’s Private Fund Strategies generally must meet the definition of “qualified purchaser” as defined in Section 2(a)(51) of the Investment Company Act of 1940, as amended. Certain investors may also be required to meet the definition of “accredited investor” under Regulation D of the Securities Act of 1933, as amended, or other qualification standards as set forth in each Fund’s offering documents. Capricorn does not impose a minimum account size for Client accounts. However, certain Funds may impose minimum investment amounts as set forth in their respective offering documents.

The fact that Capricorn is eligible to receive performance-based compensation creates a potential conflict of interest in that it may create an incentive for Capricorn to make more speculative investments than it might otherwise make. Such performance-based compensation arrangements also create an incentive to favor higher fee-paying accounts over other accounts in the allocation of investment opportunities. It should be noted that investors are provided with clear disclosure as to the risks associated with the payment of such performance-based compensation. Capricorn (or an affiliate) will receive performance-based compensation from certain Clients, but not from others. In addition, the amount of performance-based compensation that Capricorn is entitled to receive varies from Client to Client. Each of these creates a potential conflict of interest in that it may create an incentive for Capricorn to direct more profitable investment ideas to, or allocate investment opportunities in a manner that favors, those Clients and investors that pay a performance fee or allocation. In order to manage such potential conflicts, the Client portfolios are under continuous review by the key individuals of the firm (as described in Item 13). In an effort to mitigate this inherent conflict of interest, Capricorn has implemented a detailed allocation policy and Capricorn regularly reviews its investment allocations to seek to confirm that investments are allocated among its Clients on what Capricorn deems to be an equitable basis. Capricorn, to the extent within its control, will act in a manner that it believes over the long term is fair and equitable to all its Clients. There are other significant risks related to the management of multiple Client accounts; please see the response to Item 11 for a description of some of those risks.

Broker-Dealer Registration Not applicable. Capricorn and its management persons are not registered and do not have an application pending to register as a broker-dealer, or as a registered representative of a brokerdealer.

B.

Futures Commissions Merchant, Commodity Pool Operator, Commodity Trading Advisor Registration Capricorn and its management persons are not registered and do not have an application pending to register as a futures commission merchant, a commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities.

C.

Material Relationships Relying Advisers As discussed in Item 4 Capricorn has nine relying advisers. Capricorn manages any potential conflict of interest by ensuring that each relying adviser and its supervised persons are subject to the Capricorn compliance program and Code of Ethics. 1. Capricorn Advisers, LLC: Capricorn has entered into services agreements with a whollyowned subsidiary, Capricorn Advisers, LLC, pursuant to which it will provide investment advice to Capricorn. Certain employees of Capricorn Advisers are officers and/or members of Capricorn. 2. Capricorn Management, LLC: Capricorn provides certain non-discretionary investment advisory services to the Individual Client pursuant to the Advisory Agreement and is whollyowned by the Individual Client. Although Capricorn is 50% owned by an entity that itself is wholly-owned by a trust under the control of the Individual Client, that entity holds only 42.5% of Capricorn’s economic interests. The wholly-owned entity holds 50% of the voting authority of Capricorn. 3. LIBRA Fund: The general partner of the LIBRA Fund is Capricorn-Libra Partners, LLC, a relying adviser of Capricorn. Capricorn acts as an investment adviser to the LIBRA Fund. Please see additional disclosure regarding conflicts of interest in Item 10D and Item 11. 4. TIF Funds: The general partners of the TIF Funds are TIF Partners, LLC and TIF Partners II, LLC, each of which is a relying adviser of Capricorn. Capricorn acts as an investment adviser to the TIF Funds. Please see additional disclosure regarding conflicts of interest in Item 10D and Item 11. 5. TIGF Funds: The general partners of the TIGF Funds are TIGF Partners, LLC and TIGF Partners II, LLC, each of which is a relying adviser of Capricorn. Capricorn acts as an investment adviser to the TIGF Funds. Please see additional disclosure regarding conflicts of interest in Item 10D and Item 11.

6. SIF Fund: The general partner of the SIF Fund is SIF Partners, LLC, a relying adviser of Capricorn. Capricorn acts as an investment adviser to the SIF Fund. Please see additional disclosure regarding conflicts of interest in Item 10D and Item 11. 7.

Sustainable Investors Fund GP S.à r.l: This is the general partner of the SIF feeder fund based in Luxembourg and is a relying adviser of Capricorn. Please see additional disclosure regarding conflicts of interest in Item 10D and Item 11.

Other Fund Relationships CIG DS Funds. Capricorn Investment Group, LLC (the filing adviser) serves directly as the general partner of the CIG DS Funds and acts as an investment adviser to the CIG DS Funds. The general partner of the CIG DS Funds is not a separate relying adviser entity. Please see additional disclosure regarding conflicts of interest in Item 10D and Item 11. Strategic Relationships Capricorn has formed certain strategic relationships with third party investment managers to private funds whereby Capricorn, its affiliates and/or Clients receive a share of the management fee and incentive allocation payable to the manager of the private fund (“Third-Party Managers”). Such advisers may or may not be registered with the SEC as investment advisers. In some cases Capricorn, its affiliates and/or an Advisory Client has acquired an interest in such Third-Party Managers. Additionally, Capricorn personnel may hold a limited partner interest in a vehicle managed by such Third-Party Managers. From time to time, in connection with such strategic relationships, Capricorn may provide strategic advice, or support services to a Third-Party Manager and/or any investment vehicles it manages. This poses a potential conflict of interest in that Capricorn may spend a portion of its business time providing such advice or support services. In addition, the investment vehicles managed by the Third-Party Managers may be in competition with Capricorn for investment opportunities. It should be noted that certain of the Clients share in the revenues generated in connection with these relationships and therefore Capricorn’s interests are aligned with its Clients’ interests. Capricorn manages this conflict of interest by disclosing such relationship to Clients, through adherence with its allocation policy, and by ensuring that all Access Persons adhere to the Capricorn Code of Ethics. Please see Item 10D and Item 11 below for further discussion regarding conflicts of interests related to recommending Clients to invest in the funds or vehicles managed by Third-Party Managers. Capricorn Affiliated Managers In addition to its strategic relationships with third party investment managers described above, Capricorn holds minority ownership interests in certain fund managers (collectively, “Capricorn Affiliated Managers”). These ownership interests are held at the Capricorn entity level rather than through any fund. Capricorn's ownership interests in the Capricorn Affiliated Managers create potential conflicts of interest similar to those described with respect to the SIF Fund's GP Stake investments (see Item 11 below). Specifically, Capricorn may recommend that other Clients invest in funds managed by Capricorn Affiliated Managers. Since Capricorn has a direct ownership interest in such managers, it may receive a share of the management fees and performance-based compensation generated by client investments in those funds. This creates an incentive for Capricorn to recommend investments in funds managed by Capricorn Affiliated Managers over other investments where no such ownership interest exists.

Additionally, Capricorn employees may serve on the board of directors, advisory board, or similar governing body of Capricorn Affiliated Managers, which may provide Capricorn with access to information about the manager's operations, performance, and investment pipeline that is not available to other investors, including Capricorn's Clients. Capricorn manages these conflicts through disclosure to affected Clients, independent evaluation of each investment recommendation, adherence to its allocation policy and Code of Ethics, and review by Capricorn's Chief Compliance Officer where appropriate. Please see Item 11 for additional discussion of conflicts arising from GP ownership interests and governance roles. D.

Selection of Third-Party Managers and Other Compensation As noted throughout this Item 10 Capricorn, its Clients, and Capricorn affiliates have relationships with Third-Party Managers, and their respective investment vehicles that could present potential or actual conflicts of interest. Capricorn may recommend that its Clients invest in funds or vehicles managed by Third-Party Managers. Capricorn and its affiliates may have a conflict of interest recommending Third-Party Managers to Clients in that Capricorn, its affiliates and Clients may have a financial interest (including but not limited to receipt of management fees, or incentive fees) that could create an incentive for Capricorn to recommend investments in Third-Party Managers over other, more suitable investments from which no such supplemental financial benefit is derived. Capricorn mitigates such potential conflicts through disclosure to Clients, and adherence to its allocation policy and Code of Ethics. Capricorn Clients may be subject to additional layers of asset-based fees and performance-based fees or allocations in respect of investments managed by Third-Party Managers. E. Special Purpose Acquisition Companies Capricorn sponsors special purpose acquisition companies (the “SPACs”), which are publiclytraded “blind pool” entities that raise a pool of capital from public investors and looks to deploy that cash to acquire all or a part of a private (or potentially public) company. Special purpose acquisition companies are created and managed by a “sponsor” or “founder,” an individual or group with expertise in sourcing and executing acquisition opportunities and/or operational experience in a particular industry (in this case Capricorn). Because the SPACs target a different investment profile than the Clients, SPAC’s target profile, Capricorn believes that there would be no conflict when deciding whether to pursue an investment through a SPAC or through capital from the Clients for the SIF Fund, although both could potentially benefit investors. The SPACs are generally treated like any other SIF Fund portfolio investment. F. Other Outside Activities Principals, employees and consultants (together “Access Persons”) of Capricorn and the relying advisers may engage in outside activities unrelated to Capricorn or the relying advisers. While the amount of time spent by access persons on such activities may vary, such activities could be viewed as competing with the time needed in fulfilling fiduciary obligations to clients of Capricorn and/or the relying advisers. Capricorn manages this conflict of interest by ensuring that Access Persons adhere to the Capricorn Code of Ethics.

Ion Yadigaroglu acts as manager of an investment vehicle in which certain officers, employees, and friends of Capricorn hold a passive economic interest. While the vehicle is not managed by Capricorn, actual or potential conflicts of interest could result in that this vehicle may compete with Capricorn clients in obtaining an allocation in future investment opportunities. Capricorn manages this conflict of interest by ensuring that Mr. Yadigaroglu adheres to the Capricorn Code of Ethics. If you have any questions about these conflicts, please contact Capricorn’s Chief Compliance Officer.

Code of Ethics Capricorn and its relying advisers have jointly adopted a Code of Ethics (“Code of Ethics”) that sets forth the standards of conduct expected of its officers, managers and employees. The Code of Ethics requires each entity’s personnel to report their personal securities holdings and transactions and requires the Chief Compliance Officer to pre-approve certain investments. Capricorn is required to keep copies of the Code of Ethics and records relating to the Code of Ethics. Capricorn personnel are required to submit an annual report of brokerage accounts and holdings along with an annual acknowledgement and certification stating that the individual will comply with the Code of Ethics. In addition, personnel are required to submit quarterly transaction reports (or brokerage statements in lieu of such reports) that detail the individual’s securities transactions for the quarter. All employees, managers and officers of Capricorn must comply with the Code of Ethics. The Code of Ethics states that personnel owe a duty of loyalty to Capricorn’s Clients, requiring personnel to act for the best interests of the Clients. In addition, personnel must avoid actions or activities that allow (or appear to allow) them or their family members to profit or benefit from their relationships with Capricorn, its affiliates, and its Clients. The Code of Ethics also contains policies involving the safeguarding of proprietary and non-public information by Capricorn’s personnel along with restrictions on the use of insider information and the use of non-public information regarding a Client. The Chief Compliance Officer is required to report issues that arise under the Code of Ethics with respect to Capricorn to Capricorn’s Board of Directors at least annually. Capricorn will provide a copy of its Code of Ethics to any investor or prospective investor upon request.

B.

Structural Conflicts Between Capricorn’s Advisory Business Lines Capricorn operates two primary business lines: an investment advisory practice serving high-networth individuals and institutional Clients through the Investment Advisory Client Program, the Discretionary Client IHP Program, and the Legacy Client Program, and an asset management business that includes the Private Fund Strategies (including SIF and TIF/TIGF) and affiliated manager relationships (including Capricorn Affiliated Managers as described in Item 10). The concurrent operation of these business lines creates potential conflicts of interest, as Capricorn may recommend that Clients invest in Funds or vehicles managed by Capricorn, its relying advisers, or managers in which Capricorn or a Capricorn-advised Fund holds an ownership interest. These conflicts, and the specific scenarios in which they arise, are described in detail throughout this Item 11.

C.

Conflicts of Interest Related to Recommendations to Clients As noted elsewhere in the Form ADV Part 2A, Clients invest in legal entities where Capricorn or an affiliate acts as general partner or investment manager or where Capricorn has another material financial interest. Technically, these are securities in which Capricorn has a material financial interest.

As discussed in Item 10D, Capricorn may recommend that its Clients invest in funds or vehicles managed by Third-Party Managers. Capricorn and its affiliates may have a conflict of interest recommending Third-Party Managers to Clients in that Capricorn, its affiliates and Clients may have a financial interest (including but not limited to receipt of management fees, or incentive fees) that could create an incentive for Capricorn to recommend investments in Third-Party Managers over other, more suitable investments from which no such supplemental financial benefit is derived. Capricorn Clients may be subject to additional layers of asset-based fees and performance-based fees or allocations in respect of investments managed by Third-Party Managers. As described in Item 5 above, Capricorn (or an affiliate or employee) may receive certain advisory fees, director’s fees, break-up fees or other ancillary fees in connection with portfolio investments of Clients as compensation for financial advisory and/or other services provided by such persons to the portfolio companies. Payment of such fees may create a conflict of interest because it could create an incentive for Capricorn (or an affiliate or employee) to choose portfolio investments for an Advisory Client based on whether the target portfolio companies will pay Capricorn (or an employee or affiliate) such ancillary fees as opposed to choosing portfolio investments on the basis of which target portfolio companies may be most suitable for an Advisory Client (based on its investment objectives, strategies and other appropriate factors). Capricorn will typically mitigate such potential conflicts of interest by directly or indirectly off-setting a portion or all of the transaction fees received by Capricorn (or an affiliate or employee) against the management fees payable by Clients. For specific details regarding such fees and the management fee offset mechanism in effect for a particular Advisory Client, please refer to the Advisory Client’s governing documents. Capricorn further mitigates this conflict of interest by negotiating such fees at arm’s length with such portfolio company and generally seeking to ensure that such fees are, in the good faith opinion of Capricorn, in accordance with prevailing market rates in the relevant industry. Capricorn does not take into consideration whether a portfolio company will pay Capricorn or its affiliate a services fee when making an investment determination. Capricorn occasionally recommends the purchase or sale of securities or other investment products to Clients, in which Capricorn, its Clients, its affiliates, or other related persons have a financial interest as the investment manager, general partner, director, officer, trustee or as a co-investor (e.g. securities offered by Capricorn relying advisers). The financial interests of Capricorn or its related persons may create a conflict between the economic interests of these related persons and the interests of Capricorn’s clients. Additionally, Capricorn Clients may be subject to additional layers of asset-based fees and performance-based fees or allocations in respect of investments managed by Capricorn relying advisers. D. Conflicts of Interests Arising from Fund GP Ownership Interests As described in Item 4, certain Funds advised by Capricorn, including the Sustainable Investors Fund (“SIF”), may acquire ownership interests in the general partner entities or management companies of third-party investment funds (“GP Stakes”). Additionally, as described in Item 10, Capricorn holds direct minority ownership interests in certain fund managers (the “Capricorn Affiliated Managers”). Where Capricorn also recommends or approves an investment by an Investment Advisory Client, an IHP Client, or other Client account in a fund whose general partner or management company is partially owned by a Capricorn Private Fund Strategy or by Capricorn directly, a conflict of interest arises. Specifically, when a Client invests as a limited partner in such a fund, the Client's capital commitment generates management fees and potentially performance-based compensation for the

fund's general partner — a portion of which may flow to the Capricorn Private Fund Strategy that holds the GP Stake or to Capricorn directly in the case of Capricorn Affiliated Managers. Capricorn, in turn, may earn advisory fees and performance-based compensation on the gains attributable to that GP Stake. As a result, Capricorn has an indirect financial interest in directing Client capital into funds where a Capricorn Private Fund Strategy or Capricorn itself holds a GP Stake, which may create an incentive to recommend such investments over other investments where no such ownership interest exists. Additional conflicts may include: Layered Fees. A Client investing in a fund where a Capricorn Private Fund Strategy or Capricorn holds a GP Stake may bear management fees and performance-based compensation at both the underlying fund level (paid to the GP) and the Capricorn advisory level (paid to Capricorn on the Fund holding the GP Stake), resulting in multiple layers of fees attributable, directly or indirectly, to the same Client's capital. Information Asymmetry. Capricorn may, through its Fund's GP Stake or direct ownership interest, have access to information about the underlying fund's operations, performance, or investment pipeline that is not available to other limited partners, including the Client. This informational advantage could influence investment recommendations or the timing of investments and dispositions. Conflicting Interests in GP Oversight. As an adviser to a Fund with a GP Stake or as a direct owner of a Capricorn Affiliated Manager, Capricorn has an interest in the financial success and stability of the GP. This may conflict with the Client's interest as an LP in the underlying fund, particularly in circumstances involving GP fee negotiations, fund term extensions, key person events, or other governance matters where the interests of the GP and its limited partners may diverge. Governance Roles at Portfolio Companies and Affiliated Managers. Capricorn employees may serve on the board of directors, advisory board, or similar governing body of asset managers, general partner entities, or portfolio companies in which Capricorn’s Private Fund Strategies hold an ownership interest or in which Capricorn holds a direct ownership interest (including Capricorn Affiliated Managers). Such governance roles may provide Capricorn with access to information about the manager's operations, performance, strategy, and investment pipeline that is not available to other investors, including Capricorn's Clients who may invest in funds managed by that same entity. Additionally, Capricorn's governance role may influence its evaluation of the manager when making investment recommendations to Clients or may create a perception that Capricorn's recommendations are influenced by its governance relationship rather than by an independent assessment of the investment's merits. Recommending Against or Redeeming from GP Stake Investments. Capricorn may recommend that a Client reduce its allocation to, decline to invest in a subsequent fund managed by, or redeem from an open-end fund managed by, a general partner or management company in which a Capricorn-advised Fund holds a GP Stake or in which Capricorn holds a direct ownership interest. Such a recommendation may adversely affect the GP's assets under management and fee revenue, which may in turn reduce the value of the Capricorn-advised Fund's GP Stake (or Capricorn's direct ownership interest) and Capricorn's associated advisory fees and performancebased compensation. As a result, Capricorn may have an incentive to delay or avoid recommending a reduction, non-investment, or redemption even when such action may be in the Client's best interest. Capricorn has an obligation to make investment recommendations based on each Client's

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Brokerage 1.

Research & Soft Dollar Benefits Private company securities are generally purchased in private placement transactions, without the assistance of a broker-dealer. However, Capricorn may distribute securities to Clients and investors in Private Fund Strategies or sell such securities, including through using a broker-dealer, if a public trading market exists. In addition, from time to time, Capricorn trades public securities for certain Clients. In all cases where Capricorn is placing transactions in the public markets, Capricorn intends to select brokers based upon the broker’s ability to provide best execution for the Client. “Best execution” refers to the duty to seek the best overall qualitative execution for a Client in a particular circumstance. “Best execution” is not synonymous with the lowest brokerage commission. Consequently, it should clearly be noted that in a particular transaction the Client may pay a brokerage commission in excess of that which another broker might have charged for executing the same transaction. At this time, Capricorn does not engage in “soft dollar” arrangements with broker-dealers. Capricorn is generally authorized to make the following determinations, subject to each Client’s investment objectives and restrictions, without obtaining prior consent from the relevant Client: (1) which securities or other instruments to buy or sell; (2) the timing and total amount of securities or other instruments to buy or sell; (3) the executing broker or dealer for any transaction; and (4) the commission rates or commission equivalents charged for transactions. In assessing best execution, Capricorn considers, among other things, all or some of the following factors: (i) the broker’s execution capability, (ii) the commission rate charged by the broker, (iii) a broker’s past history of successful, prompt and reliable execution of Client trades, and (iv) the financial strength and stability of the broker.

2.

Brokerage for Client Referrals As noted above, on certain occasions an investment by a Capricorn Client will require that Capricorn select a broker-dealer to execute a transaction. Although not presently done, Capricorn reserves the right in the future to select broker-dealers based upon Capricorn’s interest in receiving Client referrals as opposed to simply seeking the most favorable execution (although Capricorn would still seek to obtain overall best execution).

3.

Directed Brokerage Capricorn does not participate in directed brokerage arrangements. However, as noted above Capricorn typically utilizes a specific broker to execute portfolio transactions, when necessary, on behalf of a Client.

B.

Aggregated Purchase or Sales of Securities Capricorn does not generally aggregate the purchase or sale of securities for various Client accounts. At the present, the majority of the securities purchased for Client accounts are interests in underlying funds and other private securities and Capricorn will not aggregate orders for investments in such funds as it is not permitted and would not provide any benefits to its Clients. Please also see the conflicts noted in response to Item 11 above.

Capricorn utilizes third parties (each a “Placement Agent”) for referral and placement services in the solicitation of Clients and/or investors. Capricorn pays cash or a portion of the advisory fees paid by Clients and/or investors referred to it by those Placement Agents. When Capricorn engages parties for any referral or solicitation activities, such activities will be conducted in a manner that is consistent with Rule 206(4)1 under the Investment Advisers Act of 1940, as amended, and relevant SEC guidance. Due to the agreements Capricorn has with Placement Agents, the Placement Agents have an incentive to recommend Capricorn, resulting in a material conflict of interest.

Capricorn has experienced no legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of Capricorn or the integrity of its management.

Review of Client Accounts Capricorn monitors and reviews Client accounts on a periodic basis. The frequency of Client account reviews and reports varies by metric. Reviews and reports are prepared by Capricorn’s Portfolio Management and Operations teams. Asset allocations, exposure levels and upcoming trades are generally reviewed on a weekly basis for all Client accounts. Rebalancing trades are executed if deemed necessary. On a monthly basis, fair market values and performance metrics are reviewed by the Operations team. After review, a portfolio summary and capital statement are distributed to each Client. Several times a year, in-depth portfolio reviews, which include analyses pertaining to portfolio positioning, performance, attribution, risk, liquidity and other relevant metrics, are prepared by the Investment and Portfolio Management teams as a detailed update to and basis for discussion and planning with each Client. The LIBRA, TIF, TIGF, CIG DS, CIG LC, and SIF teams continually monitor the respective investment portfolios, and receive monthly, quarterly and/or annual financial and qualitative information from their portfolio companies. Each TIF, TIGF, CIG DS, CIG LC, and SIF investor receives a capital account statement on a quarterly basis. Upon request, Capricorn provides each Client with the information they need regarding their accounts. Additionally, Capricorn seeks to meet with each Client on an annual basis and perform an annual review of their overall portfolio.

B.

Frequency of Reports Discretionary Client IHP Program IHPs are audited at the end of each fiscal year by an independent certified public accountant. Capricorn will deliver to each IHP Client audited financial statements of its IHP, including an income statement for the year then ended, a balance sheet as of the end of such year and a statement of changes to such Client’s capital account in its IHP. Such audited financial statements are to be delivered as promptly as practicable and in any event by the latter of (a) fifteen (15) days after receipt of the last audited report from the IHP’s Underlying Investments or (b) one hundred eighty (180) days after the close of the IHP’s fiscal year. Capricorn will use its reasonable efforts to provide to each IHP Client such other information related to the Client’s IHP and its investments, as is reasonably requested by such Client. Capricorn will furnish a Schedule K-1 to each IHP Client as promptly as practicable after the close of the fiscal year. An Underlying Investment’s delay in providing a Schedule K-1 or other required information could delay Capricorn’s preparation of its information return and Schedule K-1’s. Delivery of the relevant information by an Underlying Investment will be subject to delay in the event of the late receipt of any necessary tax information from an entity in which the Underlying Investment holds an interest. Private Fund Strategies

Investors in the LIBRA Fund and the CIG LC Fund will receive annual audited financials. Schedule K-1’s will be provided as soon as reasonably practicable after the end of the fiscal year of the LIBRA Fund and the CIG LC Fund. Investors in the TIF, TIGF, CIG DS, and SIF Funds will receive annual audited financials, as well as a quarterly position summary and capital statements. Schedule K-1’s will be provided as soon as reasonably practicable after the end of the fiscal year of the Funds. As Capricorn cannot provide annual tax information until such information is received from the Underlying Investments, it is likely that, in any taxable year, annual tax information will not be provided by Capricorn until sometime after April 15. Consequently, it is anticipated that investors will need to apply for an extension of time to file tax returns.

Capricorn is deemed to have custody of the assets of its Clients (in its or its affiliates’ role as the general partner or investment manager of those entities). It should be noted that Capricorn will maintain the cash assets of discretionary Clients and securities directly invested in by Capricorn Clients (other than privately offered securities) in custodial accounts with a “qualified custodian” pursuant to Rule 206(4)-2 under the Investment Advisers Act of 1940. Quarterly account statements sent to investors in the Funds will be sent by Capricorn, not by any qualified custodian used by Capricorn. Investors in the Funds should carefully review those statements and compare those statements to the information contained in the audited financial statements prepared by an independent public accountant registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board (“PCAOB”). In addition, it should also be noted that in satisfaction of the requirements of Advisers Act Rule 206(4)-2, Capricorn will ensure that all investors in each Fund are provided with GAAP compliant audited financial statements for that Fund within 120 or 180 days of the end of the applicable Fund’s fiscal year. Investors should carefully review those annual audited financial statements.

As noted above, Capricorn has discretionary authority to manage securities accounts on behalf of its Clients in certain Investment Advisory Client accounts where discretionary authority has been granted, the Discretionary Client IHP Program, the Legacy Client Program (with respect to the Non-Taxable Entities), and the Private Fund Strategies. As noted elsewhere in this Form ADV Part 2A (in particular in Item 8 above), the investment strategy of Clients is set forth in the operative governing documents and/or advisory contracts. Prospective investors are provided with an offering document, operative governing documents and/or advisory contracts, as applicable, prior to their investment and are encouraged to carefully review the documents and to be sure that the proposed investment is consistent with their investment goals and tolerance for risk. Prospective investors must also execute a subscription agreement, in which they make various representations, including representations regarding their suitability to invest in a high-risk investment pool. Similarly, the relying advisers have discretionary authority to manage their respective Clients’ accounts.

Capricorn understands and appreciates the importance of proxy voting. To the extent that Capricorn has discretion to vote proxies on behalf of Clients, Capricorn will vote any such proxies in the best interests of Clients and in accordance with its compliance procedures. Capricorn votes any proxies related to underlying funds and portfolio companies. For proxies pertaining to publicly traded investments Capricorn utilizes a third-party provider, ISS, to vote such proxies. Capricorn has directed ISS to vote proxies in accordance with the ISS Socially Responsible Investing (“SRI”) policy. Occasionally, Capricorn may deviate from voting in line with the SRI policy if it believes that voting in another manner is in the best interest of the Client or if there is a conflict of interest present. Proxies pertaining to underlying funds and portfolio companies are often related to proposed term changes to be made by such underlying funds or portfolio companies. Prior to voting proxies of this nature, Capricorn’s Investment team and Chief Compliance Officer will determine if there are any conflicts of interest related to the underlying fund or portfolio company proxy in question. If a conflict is identified, the Investment team will then make a determination with the Chief Compliance Officer (which may be in consultation with outside legal counsel or third-party compliance consultants) as to whether the conflict is material or not. If no material conflict is identified pursuant to its procedures, the Investment team and Chief Compliance Officer will make a decision on how to vote the proxy. LIBRA, TIF, TIGF, CIG DS, CIG LC, and SIF Funds vote all proxies pertaining to their respective portfolio companies. If you have any questions about Capricorn’s proxy policy, its proxy record-keeping procedures or if you would like any further information about how proxies are voted, please contact the Chief Compliance Officer, Alexandra Acosta via email at aacosta@capricornllc.com.

Capricorn has discretionary authority and custody of Client funds and securities. Capricorn is not currently aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to Clients. In addition, Capricorn has not been the subject of a bankruptcy petition at any time during the past ten years.