Chatham Asset Management, LLC

Chatham Asset Management, LLC (“CAM”) was founded and commenced operations in 2003. Anthony Melchiorre is the founder and principal owner of Chatham Asset Management, LLC. CTM Asset Management, LLC (“CTM”) is a majority-owned subsidiary of Chatham Asset Management, LLC and commenced operations in 2025. Chatham’s principal place of business is in Chatham, New Jersey. CAM and CTM use a single Form ADV in reliance on the position expressed in the American Bar Association, Business Law Section, SEC No-Action Letter (January 18, 2012). Unless otherwise indicated, references in this Brochure to the investment advisory activities of Chatham include both CAM and CTM. Chatham seeks to primarily invest its assets in high yield bonds, leveraged loans, credit derivatives, and may also invest long or short in “special situations” in the crossover, distressed debt and credit derivatives markets. The Firm seeks to exploit both fundamental and technical inefficiencies in the pricing of leveraged credits across the capital structure through identification and active trading to generate returns and manage risk. CAM manages three credit focused strategies on behalf of its institutional investors, including the Chatham Asset High Yield Fund structure (the “Open-end Fund”) and the Chatham Asset Private Debt and Strategic Capital Funds (the “Closed-end Funds” and collectively with the Openend Fund, the “Chatham Funds”) and certain investor funds (the “Investor Funds”) for large institutional investors and serves as a sub-adviser with respect to certain assets of a pooled investment vehicle (the “Sub-Advised Fund”) sponsored by an unaffiliated investment adviser (the “Sub-Advised Fund Manager”) pursuant to the terms and conditions of a written SubAdvisory Agreement. CTM Asset Management, LLC will manage a special purpose entity that functions as a collateralized loan obligation (“CLO”). CTM Asset Management, LLC, as the collateral manager to the CLO, will follow the investment mandate of the CLO and does not tailor advisory services to the individual needs of investors in the CLO. Collectively, the Chatham Funds, the Investor Funds, the Sub-Advised Fund and the CLO shall be referred to as a “Client” or the “Clients.” The Chatham Funds are organized as domestic and offshore partnerships, as well as offshore corporations, the Investor Funds are organized as domestic partnerships, the Sub-Advised Fund is organized as a domestic limited liability company and the CLO is organized as an offshore corporation. As of December 31, 2025, Chatham managed approximately $8.272 billion in regulatory assets under management on a discretionary basis on behalf of its Clients.

Management and Performance Fees Open-end Fund The Open-end Fund pays an annual management fee of 1.5% based on the fund’s assets and in accordance with the fund’s specific limited partnership agreement. The management fee is paid quarterly in advance. In addition, at the end of each fiscal year the fund pays a 20% performance fee to CAM based on the net increase of the Open-end Fund’s value subject to a highwater mark. Closed-end Funds The Closed-end Funds pay an annual management fee of 0.75% - 1% per annum based on each limited partner’s capital contributions. Following the end of the fund’s investment period, the general partner will distribute all cash proceeds (less a holdback for any future expenses or liabilities of the partnership). At such time, the funds will pay CAM through its ownership of the general partner a profits interest. This profits interest will be equal to 20% of proceeds after 100% of all limited partner capital contributions have been returned and after the limited partners realize a preferred annual return of 5%. After the preferred annual return is met, CAM will receive all distributions until it has received 20% of the cumulative amounts distributed. Then, all remaining distributions will be shared 80% to limited partners and 20% to CAM. Fees may be waived or reduced, at the sole discretion of CAM, such as for employees of CAM and their family members and certain large or strategic investors in the Chatham Funds. Any prepaid management fees that are collected in advance for the Chatham Funds will be rebated on a pro-rata basis to any investor upon withdrawal from the Chatham Funds, as applicable. Any transaction fees, directors’ fees, consulting fees, monitoring fees, break-up fees or any other similar fees paid to or receivable by CAM or its affiliates shall offset and reduce the amount of the management fees otherwise payable to CAM. To the extent that CAM is fully offset during a particular quarter, any excess other fees, as defined in the limited partnership agreement, shall serve to offset the management fee for subsequent quarters until the full amount of the other fees have been applied to offset the management fee. CLOs With respect to the CLO, and any additional CLOs CTM may manage in the future, CTM will receive an annual account management fee based on the assets under management for each CLO, which is paid quarterly in arrears. The management fee is typically split between a senior management fee and a subordinated management fee. The CLOs will pay the management fee from cashflow generated by the CLO investments. The senior management fee is payable from the cashflow on a priority basis (i.e., prior to payment of debt service on the notes issued by the CLO) and the subordinated management fee is payable on a subordinate basis (i.e., after payment of debt service on the notes issued by the CLO). CTM may also receive performance compensation based on the cashflow generated by the CLO

in excess of a hurdle. CLO investors and prospective investors should refer to the relevant offering circular for information regarding the fees associated with any CLO issued by CTM. The fee schedule with respect to the CLOs is not negotiable. Additional Fees and Expenses In addition to management fees, performance fees, and profits interest, Clients will bear various fees and expenses in accordance with their governing documents. Those fees and expenses as contractually determined include, but are not limited to, fees associated with fund administration, prime brokerage, legal and accounting, taxes, and commissions and brokerage. Additionally, the Chatham Funds and Investor Funds will pay legal; auditing; accounting (including out-sourced accounting and accounting software); pricing services and other professional expenses; administration expenses; research expenses (including research related travel costs); broken-deal fees and expenses (including related legal fees); investment expenses such as commissions; interest on margin accounts and other indebtedness; custodial fees; filing fees; bank service fees; Chatham Fund-related insurance costs (including D&O and E&O insurance for the management company and the General Partner); expenses of regulatory compliance, filings and reporting (including but not limited to Form PF, Section 13 and 16 filings) to the extent they are in connection with, relate to or derive from the Chatham Funds or its investment activities; and other expenses related to the purchase, sale or transmittal of Chatham Fund assets. Certain of the Chatham Funds will bear the cost of fees payable to Forza Investment Group, LP, Churchill Advisors and/or any of their respective affiliates (collectively, the “Forza Entities”). In particular, certain Chatham Fund portfolio investments will be indirectly owned through the Chatham Fund’s future investment in a financing vehicle managed by Forza Investment Group, LP (the “Forza Financing Vehicle”) as investment in the Forza Financing Vehicle will enable each Chatham Fund to obtain more favorable borrowing terms than the borrowing terms being offered (if any) by the fund’s prime brokers or other third-party lenders. As consideration for managing the Forza Financing Vehicle, Forza Investment Group, LP will receive a management fee based on the notional long market value of the investments therein (the “Forza Financing Vehicle Management Fee”). Further, the Chatham Funds or CAM on their behalf may engage one or more of the Forza Entities from time to time in the future to provide certain consulting or other services related to the Chatham Funds’ portfolio. While Chatham believes that the arrangement with the Forza Entities will provide value to the funds and that any additional services engagements with the Forza Entities in the future may similarly provide value to the funds, such engagements with the Forza Entities constitute a conflict of interest for Chatham since Anthony Melchiorre’s brother owns and operates the Forza Entities. Chatham manages the conflicts of interest associated with this arrangement by seeking to ensure that all engagements with the Forza Entities are on customary commercial terms negotiated on an arm’slength basis. The allocation of expenses by Chatham between it and any Client and among Clients represents a conflict of interest for Chatham. To address this conflict, Chatham has adopted and implemented policies and procedures for the allocation of expenses. Chatham allocates

expenses to each Client in accordance with the Client's arrangements with Chatham (including applicable Client disclosures). Chatham seeks to allocate shared expenses for products and services benefiting Chatham and the Client and not covered in the Client's arrangements in a fair and reasonable manner. Chatham generally allocates common Client expenses among multiple Clients based on each Client’s assets or position. Chatham may deviate from its standard allocation method if it determines that an expense disproportionately benefits a particular Client or group of Clients. All current and potential investors should review the offering or governing documents for each Client in conjunction with this brochure for more complete information on the fees and compensation payable with respect to a particular Client. Withdrawals The Open-end Fund allows for quarterly withdrawals. Investors in such Chatham Funds must provide at least 45 days’ prior notice to withdraw all or a portion of its capital account as of the last day of each calendar quarter. However, a 3% withdrawal fee of the amount being withdrawn will be paid to the Chatham Fund if an investor withdraws all or a portion of its capital account attributable to a particular capital contribution within one year of the date such contribution was made. In addition, Chatham’s Investor Funds have negotiated their own specific terms and conditions related to withdrawals that are outlined in the Limited Partnership Agreement between and among CAM, its affiliates and the Investor Funds. Withdrawals are not permitted in any Closed-end Fund. The terms and conditions related to withdrawals in respect of the Sub-Advised Fund are outlined in the Sub-Advised Fund’s governing fund documents. The terms regarding withdrawals, if any, and return of capital to noteholders will be disclosed in the offering circular for each CLO issued by CTM. CAM, the general partner and/or the Board of Directors of a Chatham Fund, in its sole discretion, may waive or modify any terms related to withdrawals for an investor in the Chatham Fund pursuant to a written agreement with the investor, and in accordance with the applicable governing documents. Other Compensation Chatham, the General Partner, or their respective employees and their affiliates may, but ordinarily do not expect to, earn fees and other income from services provided or related to a Client’s investments or in connection with a Client’s investments or prospective investments including but not limited to, advisory fees, consulting fees, due diligence fees, structuring fees, servicing fees, directors' fees, break-up fees or any similar fees. Any such fees received in excess of expenses incurred by Chatham with respect to such engagement will be applied to reduce the Management Fee paid by Clients on a dollar-for-dollar basis.

The following is a summary of the methods of analysis and investment strategies employed by Chatham as well as the material risks associated with investing in such strategies. Prospective and existing investors are advised to review the offering materials and other constituent documents for full details on each applicable Client’s investment, operational and other actual and potential risks. Method of Analysis and Investment Strategies Chatham seeks investment opportunities in securities and other investments that it believes are mispriced as a result of market inefficiencies. Chatham believes these inefficiencies can occur as existing holders of the investments are often unprepared or ill-equipped to evaluate the impact certain financial, legal or operational issues will have on the issuer. At the same time, Chatham believes that the number of market participants who are willing to evaluate such investments are limited, thus potentially causing an imbalance between sellers and buyers. Typically, Chatham begins its investment process by employing a top-down industry review with bottom-up fundamental credit analysis to identify potential opportunities. As part of the research process, Chatham’s investment team typically reviews annual and quarterly company reports, publicly available filings such as SEC, bankruptcy and other court filings, credit agreements and bond indentures. The investment team may also speak with company management, industry experts and Wall Street analysts. Once enterprise valuation is established through the research process, Chatham will overlay the valuation onto the capital structure in order to uncover the intrinsic value of each tranche of debt and equity. After detailed analysis and understanding of covenants, collateral and security, intrinsic value will be compared to market prices in order to determine which part of the capital structure to be long/short based on upside/downside and arbitrage potential. With respect to the CLOs managed by CTM, CTM will employ a similar process to create a complete assessment of credit quality. For investment decisions, CTM focuses mainly on the loans within a company's capital structure and seeks to access relative value to drive trading decisions. CTM’s investment committee, which is comprised of the CLO Chief Investment Officer/Group Head and CLO Portfolio Manager (the “Investment Committee”), and sector analysts have overall responsibility for selecting investments for the CLO portfolios. Once the fundamental analysis is completed, Chatham evaluates the technical trading aspects of a potential investment to assess the efficient entry and exit points for the position. Chatham believes that this is a part of the investment process that is frequently overlooked by traditional investment vehicles and less experienced fund managers. It is nearly as important as fundamental analysis because credit instruments often trade at levels at odds with intrinsic value, and these relationships can often persist indeterminately and for multiple price points through the inefficient trading relationship that is initially uncovered. This analysis encompasses a number of trading catalysts including the flow of capital in the relevant market, company specific credit news (e.g., earnings statements), ratings agency activity, market sentiment toward the credit, sector or general marketplace, size/vibrancy of the new issue market and buying/selling dynamics from the distressed, stressed, high yield and investment grade markets.

Chatham then synthesizes this information to determine the horizon of the investment. Positions will reflect Chatham’s investment team’s views on the broader debt and equity markets, the relative valuations of sectors of the credit markets, specific credits in the marketplace, and the relative pricing of the capital structure of such credits. The long/short balancing of each Client’s portfolio will vary according to the investment team's market outlook at any given time. Positioning strategies will include the determination of going long or short the credit on either an outright or hedged basis. Additionally, Chatham determines which securities should be positioned (i.e., bank debt vs. bonds vs. equity), in what relationship (i.e., long bank debt, short equity or sub debt), and in which market (i.e., cash vs. derivative). Chatham continually manages each Client’s portfolio by monitoring positions and sectors on a daily basis. Chatham seeks to primarily invest in high yield bonds, bank debt, senior notes and subordinated notes. However, Chatham has broad investment authority to invest in a wide variety of securities and financial instruments on behalf of its Clients such as preferred stocks and equities, private equity, credit default swaps and trade or vendor claims. Chatham notes that percentages held in various asset classes changes through time and is a function of both opportunities and circumstance. Further details relating to Clients’ investments are set forth in each relevant Client’s governing documents (e.g., offering documents and/or partnership agreement). Risk of Loss Chatham’s investment strategy involves a number of risks. Accordingly, an investment with Chatham is deemed a speculative investment and is not intended as a complete investment program. It is designed for sophisticated investors who fully understand and are capable of bearing the risks associated with such investment strategy. No guarantee or representation is made that a Client will achieve its investment objective or that investors or shareholders in a Chatham Fund, an Investor Fund or the Sub-Advised Fund will receive a return of their capital. All investing involves a risk of loss and the investment strategy offered by Chatham could lose money. The descriptions contained below are a brief overview of different risks related to Chatham’s investment strategy; however, it is not intended to serve as an exhaustive list or a comprehensive description of all risks and conflicts that may arise in connection with the management and operations of such strategy. With respect to the Chatham Funds, prospective and existing investors are advised to review the offering materials and other constituent documents for full details on each applicable Chatham Fund’s investment, operational and other actual and potential risks. Stressed and Distressed Securities: Clients invest in “stressed and distressed securities”— securities, private claims and obligations of entities that are experiencing significant financial or business difficulties or have filed for Chapter 11 protection under the U.S. Bankruptcy Code. Types of investments which are suitable dependent on the specific strategy include but are not limited to loans, bonds, stocks, partnership interests and similar financial instruments, executory contracts and options or participations therein not publicly traded. Among the risks inherent in investments in entities experiencing significant financial or business difficulties is the fact that it frequently may be difficult to obtain information as to the true condition of such issuers. Such investments can also be adversely affected by state and federal

laws relating to, among other things, fraudulent conveyances, voidable preferences, lender liability and the bankruptcy court's discretionary power to disallow, subordinate or disenfranchise particular claims. The market prices of such instruments are also subject to abrupt and erratic market movements and above average price volatility and the spread between the bid and asked prices of such instruments may be greater than normally expected. In trading stressed and distressed securities, litigation is sometimes required. Such litigation can be time-consuming and expensive, and can frequently lead to unpredicted delays or losses. Loans: Clients may invest in loans (in cash and synthetic form). The value of the loans may be detrimentally affected to the extent a borrower defaults on its obligations. Furthermore, circumstances could arise (such as in the bankruptcy of a borrower) that could cause a Client’s security interest in the loan’s collateral to be invalidated. Also, much of the collateral will be subject to restrictions on transfer intended to satisfy securities regulations, which will limit the number of potential purchasers if the Clients intend to liquidate such collateral. The amount realizable with respect to a loan may be detrimentally affected if a guarantor, if any, fails to meet its obligations under a guarantee. Finally, there may be a monetary, as well as a time cost involved in collecting on defaulted loans and, if applicable, taking possession of various types of collateral. Clients may invest in corporate secured loans acquired through assignment or participations. In purchasing participations, Clients will usually have a contractual relationship only with the selling institution, and not the borrower. This means that Clients will not have the right to directly enforce the borrower’s compliance with the terms of the loan agreement, nor any rights of set-off against the borrower, nor will it have the right to object to certain changes to the loan agreement agreed to by the selling institution. Clients generally will not directly benefit from the collateral supporting the related secured loan and generally will not be subject to any rights of set-off the borrower has against the selling institution. In addition, in the event of the insolvency of the selling institution, under the laws of the United States and the states thereof, the Clients generally will be treated as a general creditor of such selling institution, and will not have any exclusive or senior claim with respect to the selling institution’s interest in, or the collateral with respect to, the secured loan. Consequently, Clients are subject to the credit risk of the selling institution as well as of the borrower. Certain of the secured loans or loan participations may be governed by the law of a jurisdiction other than a United States jurisdiction which may present additional risks as regards the characterization under such laws of such participation in the event of the insolvency of the selling institution or the borrower. Private Investments: Investments in the equity or debt of early-stage, private companies at various stages in their development involve a high degree of business and financial risk. Private companies with limited operating histories may require substantial additional capital to support expansion or to achieve or maintain a competitive position, may produce substantial variations in operating results from period to period or may operate at a loss. Early stage companies may require additional capital after investment to develop technologies and markets, acquire customers and achieve or maintain a competitive position. This capital may not be available at all, or on acceptable terms. Further, the technologies and markets of such companies may not develop as anticipated, even after substantial expenditures of capital. Such companies may face intense competition, including competition from established companies with much greater financial and technical resources, more extensive development, manufacturing, marketing and service capabilities, and a greater number of qualified managerial and technical personnel. Chatham may not be represented on its portfolio

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Chatham’s Clients consist of private funds that are pooled investment vehicles and certain investor funds for large institutional investors. In addition, Chatham serves as a sub-adviser with respect to certain assets of a pooled investment vehicle sponsored by an unaffiliated investment adviser. Chatham also manages a special purpose entity that functions as a CLO. Chatham may in the future also serve as investment manager to other client accounts. Chatham provides investment advisory services to its Clients. Investment advice is provided directly to each Client, subject to the direction and control of the General Partner for the domestic Chatham Funds and the Board of Directors for offshore Chatham Funds, and not individually to the limited partners or shareholders of the Chatham Funds or to the noteholders of the CLO. Investors in Chatham’s Funds typically include, but are not limited to, high net worth individuals, pension plans, endowments, foundations, and corporate or business entities. Noteholders of the CLO must also meet certain eligibility requirements. The details concerning applicable investor suitability criteria are set forth in each Client’s respective offering documents. Although Chatham and/or its affiliates have the authority to accept subscriptions for lesser amounts, the minimum investment in the Chatham Funds is generally $1 million. Each investor is required to meet certain suitability qualifications, such as being an “accredited investor” and “qualified purchaser” within the meaning set forth under the United States federal securities laws.

Chatham provides concurrent advisory services to Clients of varying sizes and inception dates. The fees charged by Chatham to such Clients varies and includes those that are not charged a performance-based fee by Chatham or its related persons and Clients that are charged a performance- based fee. Accordingly, the potential for Chatham and its related persons to receive greater fees from performance-based accounts creates potential conflicts of interest with respect to the allocation of investment opportunities, as Chatham may have an incentive to direct the best investment ideas to, or to allocate investments in favor of, Clients that pay performance fees. To mitigate potential conflicts of interest, allocations of investment opportunities among Clients are determined by Chatham in accordance with its investment allocation policy and consistent with its fiduciary duties and corresponding investment mandates. It is Chatham’s policy that all investment opportunities will, to the extent practicable, be allocated among its Clients on a basis that over a period of time is fair and equitable to each Client relative to other Clients, taking into account relevant facts and circumstances. Clients and investors in the Chatham Funds should be aware that the foregoing procedures in certain circumstances may: adversely affect the price paid or received by a Chatham Fund or a Client account or the size of a position purchased or sold by the Chatham Fund or Client account, including commission prices; preclude a Chatham Fund or a Client account from participating in an investment; or limit the rights that a Chatham Fund or Client account may exercise with respect to an investment.

Pooled Investment Vehicles Chatham organizes and sponsors certain pooled investment vehicles which are managed by Chatham and are controlled by an affiliated General Partner entity (“GP Entity”). Chatham or the GP Entity will be responsible for all decisions regarding portfolio transactions of the Chatham Funds and have full discretion over the management of the Chatham Funds’ investment activities. While the GP Entity is not separately registered as an investment adviser with the SEC, all of its investment advisory activities are subject to the Advisers Act and the rules thereunder. In addition, employees and persons acting on behalf of the GP Entity are subject to the supervision and control of Chatham. Thus, the GP Entity, all of its employees and the persons acting on its behalf would be “persons associated with” the registered investment adviser so that the SEC could enforce the requirements of the Advisers Act on the GP Entity. Material Relationships or Arrangements with Industry Participants Principals and employees of Chatham may serve, from time to time, as directors or in a similar capacity with respect to companies the securities of which are purchased or held by Chatham (“Portfolio Companies”). In the event that Chatham or its principals or employees (i) obtains material non-public information with respect to any Portfolio Company on whose board of directors he or she serves or (ii) is subject to trading restrictions pursuant to the internal trading policy of such Portfolio Company, Chatham may be prohibited for a period of time from engaging in transactions in the securities of such Portfolio Company which prohibition may have an adverse effect of Chatham. Chatham maintains written policies and procedures that prohibit the communication of such information to persons who do not have a legitimate need to know such information and to assure that Chatham is meeting its obligations to Clients and remains in compliance with applicable law. Principals and employees of Chatham also face conflicts of interest because such individuals may receive compensation, including fees and options, for serving as a director, or have other financial interests in the company. In such cases, Chatham endeavors to mitigate this conflict by passing all income earned from portfolio companies to the appropriate Clients. Situations may arise in which there are conflicts in such an employee’s duties to Clients and other shareholders that are not clients. Material Conflicts of Interests Relating to Other Investment Advisers As discussed previously, CTM Asset Management, LLC is a majority-owned subsidiary, and relying adviser, of Chatham Asset Management, LLC. Chatham Asset Management, LLC controls the management and operations of CTM Asset Management, LLC and certain Chatham Asset Management, LLC’s employees provide services on behalf of CTM Asset Management, LLC. Chatham and CTM also share a principal place of business.

and Personal Trading Chatham has developed and adopted a Code of Ethics that is applicable to all employees. Chatham’s Code of Ethics is predicated on the principle that Chatham owes a fiduciary duty to its Clients. Among other things, the Code of Ethics requires employees to: − Act as fiduciaries, putting the interests of Clients ahead of the interests of the Firm and its employees, and fully disclosing all material conflicts of interest; − Comply with all applicable laws and regulations; − Periodically report personal securities transactions, and obtain pre-clearance before personally trading certain types of securities; and − Promptly report any suspected violations of the Code of Ethics to the Chief Compliance Officer. Employees are required to pre-clear all personal securities transactions with certain exceptions. Specifically, employees are not required to pre-clear transactions in certain types of securities that are exempt from the reporting requirements under SEC rules including treasury securities, certificates of deposits, commercial paper, money market securities and open-end mutual funds. Employees are also not required to pre-clear any transactions in accounts for which the employee does not maintain investment control or participate in making investment decisions. To mitigate any potential appearance of conflict, employees are prohibited from investing in the securities of companies that currently have high yield debt. Chatham also maintains a restricted list which is used to track and monitor issuers for which Chatham or any employee possesses material, nonpublic information. Restrictions on such issuers extend to options, rights, and warrants relating to such issuer’s securities. A security will be removed from restriction if the CCO determines that no insider trading issue remains with respect to such issuer (for example, if the information becomes public or no longer is material). Employees that receive inside information, even if accidentally or unintentionally, must report the receipt of such information to the CCO. In certain circumstances, the placement of an issuer on the firm’s restricted list does not necessarily mean that trading will not occur. For instance, the CCO will evaluate whether trading is permissible through the use of trading windows or enhanced written disclosure to trading counterparties (including waivers). The CCO or his designee is responsible for reviewing the personal securities transaction reports submitted by employees. A copy of Chatham’s Code of Ethics is available to current and prospective Clients upon request.

Best Execution Chatham’s selection of a broker-dealer to execute Clients’ transactions is based primarily upon the broker’s ability to deliver best execution. Factors that the Firm may use in making this determination include the price per unit of the security, the broker’s execution capabilities, commission rates or transaction costs, the value of advice and research reports, the broker’s ability to deliver prompt, accurate confirmations and on-time delivery of securities, the broker’s ability to maintain confidentiality of Chatham’s trading intentions, and any other relevant factors that impact the price or execution of a trade. The commissions or transaction costs (including spreads) charged by any broker may be greater than the amount another firm might charge if Chatham determines in good faith that the amount of such commission is reasonable in relation to the value of the brokerage services and research information provided by the broker. It should also be noted that the Investment Manager may at times direct trades to brokers that employ friends or relatives of members of the Investment Manager (and its principals, employees and affiliates). The Investment Manager monitors this conflict of interest and to ensure that it is acting in accordance with its obligations as a fiduciary of its Clients. Research and Soft Dollars Although Chatham does not maintain any formal soft dollar or commission sharing arrangements, the Firm does execute securities transactions with various counterparties many of whom provide Chatham with access to proprietary research reports and other brokerage products and services (such as standard investment research, trading desk access, capital introduction events, etc.) which are used to assist with the management of all accounts at Chatham. It is our general understanding that the investment research and other products and services that are made available to all institutional investors doing business with such trading counterparties is done so on an unsolicited basis and without regard to the rates of commissions or compensation charged or paid by Chatham or the volume of business Chatham directs to such counterparties. Since these products and services are merely made available by trading counterparties as part of a bundled business package to Chatham, which may or may not use them, it is Chatham’s understanding that such trading counterparties do not set discrete prices for such products and services. Therefore, Chatham does not believe it is “paying-up” for such proprietary research and services received by the firm from its various trading counterparties. Accordingly, Chatham does not separately compensate such broker-dealers for the provision of such services since the brokerdealers do not break out the costs for such services. Trade Aggregation and Allocation Chatham generally aggregates securities and other transactions on behalf of a number of Client accounts at the same time. In addition, Chatham will also execute securities transactions alongside or interspersed between aggregated orders when Chatham believes that such execution will not interfere with its ability to execute in a manner believed to be most favorable to its Clients as a whole and over time. CAM and CTM will place separate orders for new issues, and CAM and CTM will each allocate filled orders in accordance with their trade allocation policies and

procedures. Chatham will not enter into transactions in which it knowingly and deliberately favors itself or a single Client over another Client; however, Chatham is given considerable discretion to trade for other accounts, and intends to do so to a significant extent. When executing aggregate orders, trades will be allocated among accounts using procedures that Chatham considers fair and equitable. This can include making the allocation based on such considerations as cash availability, diversification requirements, duration, investment objectives, Client contractual or regulatory investment guidelines and restrictions, existing or targeted account weightings in particular securities or sectors, lot size, account size, amount of existing holdings (or substitutes) of the security in the accounts, and investment time horizons. These factors provide substantial discretion to Chatham in allocating investment opportunities. In addition, Chatham will exclude certain accounts from an allocation if the size of the allocation would not satisfy certain minimum size thresholds established by Chatham, a Client or by the issuer itself for operational reasons. Chatham’s compliance personnel monitor the trade allocation process on a routine basis, including the review of periodic reports and other records, to ensure that trade allocations occur fairly and equitably over time, even though a specific trade may have the appearance or the effect of benefiting one account as against another when viewed in isolation. Given all of the foregoing factors, the amount, timing, structuring, or terms of an investment by a Client may differ from, and performance may be lower than, investments and performance of other Clients, including but not limited to those Clients which may provide greater fees or other compensation (including performance- based fees or allocations) to Chatham. Cross Transactions As is consistent with Chatham’s duty to seek to obtain best execution, Chatham reserves the right to cross trades between its Clients’ accounts. A cross trade occurs when Chatham purchases and sells a particular security, or other investment product, between two or more of its Clients by instructing a specified broker-dealer to cross the trade. There is no requirement that all Clients participate in cross trading and Chatham shall use its judgment to determine when specific Clients will participate. Chatham does not anticipate executing, or recommending the execution of, any cross trades for: (i) any Client account subject to ERISA, or (ii) any Chatham Fund that is deemed a proprietary account (e.g., whereby Chatham and/or any of its controlling persons maintain a beneficial interest in excess of 25% in such Chatham Fund). Chatham may utilize cross trades during a month in order to rebalance its Clients’ portfolios, including in response to risk or concentration limits, as well as a result of investor subscriptions or redemptions. Chatham may also execute cross trades when launching a new fund or other client account. If Chatham engages in such cross transactions, Chatham must ensure that all relevant Clients are treated fairly and equitably and in accordance with applicable regulatory requirements, bearing in mind that Clients may have differing investment objectives, restrictions, strategies and liquidity profiles, among other things. In certain circumstances, such transactions may provide liquidity that the open market might not otherwise support. Cross transactions are typically

executed by a prime broker of the Clients by way of book entry transfers. In some cases, cross transactions may be executed by independent broker-dealers. Cross transactions executed by independent broker-dealers may affect the price of the security to the detriment or benefit of one or more funds or accounts. In addition, Chatham does not receive any commissions or other compensation in connection with such cross transactions. Trade Errors Trade errors resulting in gains will be for the benefit of Chatham’s Clients and will not be retained by Chatham. Chatham will absorb the cost of any trade error if required to do so pursuant to the standard of care required by a specific Client or resulting from an Employee’s failure to act in accordance with the standard of care applicable to the advisory relationship. In most cases, the standard of care will result in the Client bearing the cost of a trade error, except errors resulting from the Firm’s willful misconduct, gross negligence, or material breach of its responsibilities, as such errors are considered by the Firm to be a cost of doing business. Chatham, subject to its fiduciary obligations, will determine whether or not any trade error is required to be reimbursed in accordance with such liability and exculpation provisions. Chatham, in its sole discretion, reserves the right to reimburse its Clients for any trade error. Chatham’s reimbursement to its Clients for any particular error will not constitute a waiver of any policy to cause a Client to bear the losses from other trade errors. Chatham will endeavor to maintain a record of each trade error, including information about the trade and how such error was corrected.

Chatham has entered into agreements on behalf of its Clients with certain brokers-dealers that act as prime brokers for the Clients. From time to time, Chatham’s personnel speak at conferences and programs for potential investors interested in investing in hedge funds which are sponsored by those prime brokers. These conferences and programs are a means by which the Firm can be introduced to potential investors. Neither Chatham nor its Clients compensate prime brokers for organizing such “capital introduction” events or for any investments ultimately made by prospective investors attending such events. While such events and other services provided by a prime broker may influence Chatham in deciding whether to use such prime broker in connection with brokerage, financing and other activities of the Clients, the Firm will not commit to allocate a particular amount of brokerage to a broker-dealer in any such situation. Chatham compensates third-party solicitors or other promoters for referrals of clients or investors. Chatham’s arrangements with third-party solicitors or other promoters may vary. Any compensation paid pursuant to these arrangements creates an incentive for the third-party solicitor or other promoter to recommend Chatham, resulting in a material conflict of interest.

On April 3, 2023, CAM and Anthony Melchiorre, Chatham’s founder and principal owner, entered into a settlement (the “Settlement”) with the SEC relating to certain Client rebalancing trades (the “Rebalancing Trades”) conducted by CAM with respect to three high yield debt securities issued by American Media Inc. (the “AMI Bonds”) between 2016 and 2018 (the “Relevant Period”). The SEC’s Settlement order found that, during the Relevant Period, certain of the Rebalancing Trades violated the Advisers Act and the Investment Company Act of 1940 (the “Investment Company Act”) because the prices for those trades were not “independently derived from price discovery in the broader market”. In particular, CAM engaged in the Rebalancing Trades to address portfolio constraints such as industry or issuer fund concentration limits, to meet investor redemptions, and to allocate capital inflows and outflows. The SEC alleges that these trades were executed at prices CAM and Melchiorre proposed and that over time, the prices of the Rebalancing Trades increased at a higher rate than the prices of similar securities. CAM’s and Melchiorre’s trading in the AMI Bonds accounted for the vast majority of the trading in the AMI Bonds and therefore over time the SEC contends that the Rebalancing Trades had a material effect on their pricing of the AMI Bonds. Accordingly, the SEC estimated that the relevant Clients overpaid CAM $11,000,000 in aggregate management fees and/or performance fees during the Relevant Period. Without admitting or denying the findings in the Settlement, CAM and Mr. Melchiorre agreed to be censured and to cease and desist from committing or causing future violations of Section 206(2) of the Advisers Act and Sections 17(a)(1) and 17(a)(2) of the Investment Company Act. Each of CAM and Mr. Melchiorre also agreed to: (i) be prohibited from serving or acting as an employee, officer, director, member of an advisory board, investment adviser or depositor of, or principal underwriter for, a registered investment company or affiliated person of such investment adviser, depositor or principal underwriter; (ii) make an aggregate disgorgement payment of $11,000,000 and an aggregate prejudgment interest payment of $3,375,072; (iii) pay civil penalties to the SEC of $4,400,000 and $600,000, respectively; and (iv) assist the SEC in the administration of a distribution plan to distribute to the affected Client investors the amounts described in clauses (ii) and (iii).

All Client accounts are reviewed by Chatham’s portfolio managers and other investment, operations and accounting personnel on a regular basis. Such reviews are performed to assure conformity with the objectives and guidelines of each Client and include, among others, cash and position reconciliations, sector exposures and the performance of each Client. The CLO portfolios will be reviewed by CTM’s Investment Committee. Such reviews are performed to focus on the portfolios’ adherence to investment policy and the suitability of the investments used to meet policy and investment objectives. The portfolios are reviewed frequently to evaluate and assess, among other things, investment performance, sensitivity to market changes and whether CLOs continue to meet certain established investment criteria and guidelines. While there are no set factors that trigger review of the CLO portfolios and no procedure that determines the sequence in which portfolios are reviewed, the Investment Committee will review the portfolios in the event of the realization of certain events that drive a contemplated or actual trade or the occurrence of certain other market movements that materially impact the underlying investments of the portfolios. The Chatham Funds and Investor Funds employ a fund administrator, which provides all investors with capital account statements on a monthly basis, and includes detailed account balances and return information. CAM also provides investors in the Open-end Fund and certain Investor Funds with a risk report on a monthly basis and distributes a commentary letter to all investors on a monthly basis. On an annual basis, investors are sent the annual audited financial statements prepared by KPMG and Schedule K-1 of the applicable Chatham Fund. Investors in each CLO will have access to monthly trustee reports pursuant to the terms of the indenture for the CLO. In addition, Chatham provides certain investors with more frequent disclosure or enhanced reporting not contained in the above-mentioned reports and statements including, but not limited to, monthly conference calls and enhanced portfolio transparency.

All cash and non-privately offered securities of Clients are held in custody by unaffiliated brokerdealers; however, Chatham has access to certain Client accounts since an affiliate serves as the General Partner of the Chatham Funds and the Investor Funds. Limited partners and shareholders of the Chatham Funds will not receive statements from any custodians. Instead, the Chatham Funds are subject to an annual audit by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board. The audited financial statements are prepared in accordance with generally accepted accounting principles and distributed to each limited partner within 120 days of each Chatham Fund’s fiscal year end. For the CLO, CTM does not have access to CLO assets which are custodied with the collateral trustee and therefore does not consider that it has custody of CLO assets.

Chatham has discretionary authority to determine, without obtaining specific consent from its Clients or its investors, the securities and amount to be bought or sold for Clients. Any limitations on authority are included in each Client’s relevant governing documents (e.g., Confidential Private Offering Memorandum, Partnership Agreement, Supplemental Agreement, Sub-Advisory Agreement, indenture and offering circular).

Chatham has implemented written policies and procedures governing the voting of Client proxies. The policies and procedures were reasonably designed to ensure that Chatham votes Client securities in the best interest of Clients, and sets forth how Chatham addresses material conflicts of interest that arise between the Firm and its Clients. In addition, the Firm maintains a record of all proxy votes cast on behalf of Clients. If a material conflict of interest over proxy voting arises between Chatham and a Client, Chatham employees will notify the Chief Compliance Officer of the conflict. All conflicts of interest will be resolved in the Client’s best interest. The Chief Compliance Officer may consult with members of senior management or outside counsel to determine the appropriate resolution. Chatham maintains a record of all proxy votes cast on behalf of its Clients. Investors can request a copy of the policy or information with respect to a specific proxy vote.

This Item is not applicable.