CITADEL ADVISORS LLC

Citadel Advisors LLC (“Citadel Advisors”) is a Delaware limited liability company and has its principal place of business in Miami, Florida. Citadel Advisors and its predecessors have been in the investment advisory business since 1990. Citadel Advisors manages private investment funds offered exclusively to sophisticated investors, in certain cases with assistance from its affiliates Citadel Advisors Europe Limited (“Citadel Europe”), Citadel Asia Limited (“Citadel Asia”), Citadel France SAS (“Citadel France”), and Citadel Advisors Singapore Pte. Limited (“Citadel Singapore” and, together with Citadel Advisors, Citadel Europe, Citadel Asia, and Citadel France, the “Advisers”). The Advisers are affiliated advisers organized as separate legal entities conducting a single advisory business. As such, the Advisers are permitted to satisfy their obligation to register with the SEC through the filing of a single Form ADV by Citadel Advisors, with Citadel Europe, Citadel Asia, Citadel France, and Citadel Singapore as relying advisers. The private investment funds managed by the Advisers generally invest their assets directly or indirectly in other private investment funds (referred to as the “sub-funds”), which are also managed by the Advisers and through which the Advisers pursue their investment strategies. In this Brochure, each of the private investment funds managed by the Advisers, and the sub-funds in which they invest, are generally referred to as a “Fund,” and are generally referred to collectively as the “Funds.” As of December 31, 2025, the Advisers had approximately $65,017,503,000 of assets under management, all of which was managed on a discretionary basis. Citadel Advisors is wholly owned by Citadel Advisors Holdings LP. Citadel Europe is majority‑owned by Citadel Americas LLC. Citadel Asia and Citadel Singapore are each wholly owned, and Citadel France is majority-owned, by Citadel Hedge Fund Holdings LP. The Advisers are indirectly controlled by Citadel GP LLC or its related persons and use the investment personnel, infrastructure and support provided by Citadel Americas LLC, Citadel Americas Services LLC, Citadel HFP Services Group LLC and their affiliates. Citadel GP LLC and Citadel Americas LLC, Citadel Americas Services LLC and Citadel HFP Services Group LLC are controlled by Kenneth Griffin, their Founder, Chief Executive Officer and Co-Chief Investment Officer. The Advisers are members of a group of affiliated entities that together comprise a leading global financial institution with a diverse business platform (collectively, the “Citadel Parties”), which includes two separate and distinct units: (i) a global investment firm (“Citadel”) and (ii) a global market maker (“Citadel Securities”). The Advisers have discretion with respect to investment decisions they make for the Funds, and also with respect to the selection of brokers, dealers and other counterparties for such transactions, and the amount of commissions or other compensation to be paid by the Funds. The Advisers provide investment advisory services to the Funds based on the particular investment objectives and strategies described in the applicable Fund’s Offering Documents (defined below). All discussions of the Funds in this Brochure, including but not limited to their investments, the investment strategies used in managing the Funds, the fees and other costs associated with an investment in the Funds, and conflicts of interest faced by the Advisers in connection - 3-

with their management of the Funds, are qualified in their entirety by reference to each Fund’s respective confidential offering memorandum (if any) and governing documents (referred to collectively as the “Offering Documents”).

The Advisers do not currently have a general fee schedule. The fees and expenses associated with an investment in the Funds vary, depending on the Fund, and each Fund’s Offering Documents describe them in detail. The Advisers may, in their discretion, manage other funds or accounts with higher or lower fees, different fee structures, and different expense payment arrangements, than those of the Funds. Certain Funds require investors to pay a withdrawal charge to withdraw an investment, depending upon the amount and timing of the withdrawal and other factors, which is paid to the Fund, not to Citadel. In addition, Citadel Enterprise Americas LLC (together with its subsidiaries and related entities, as applicable, “Citadel Enterprise”), Citadel Enterprise Americas Services LLC, Citadel HFP Services Group LLC, Citadel ENTP Services Group LLC, Citadel Hedge Fund Holdings LP, Citadel Americas Services LLC and/or certain other affiliated entities (collectively, the “Citadel Service Parties”) provide certain administrative and investment-related services to the Funds pursuant to one or more written agreements. The Funds Direct Expenses of the Funds Each Fund is responsible for direct expenses incurred in connection with or otherwise related to its operations and activities, including expenses associated with its investment portfolio and its proportionate share of the direct expenses of the underlying sub-funds in which it invests, including brokerage commissions and other transaction costs. Item 12 of this Brochure discusses how the Advisers select brokers, and how the Advisers determine the reasonableness of their compensation. Each Fund pays its expenses directly or reimburses the Citadel Service Parties, as instructed, for expenses paid on its behalf. The direct expenses incurred by each Fund vary depending on the nature of the operations and activities of the Fund, and each Fund’s respective Offering Documents describe them in detail. The Citadel Service Parties seek to allocate direct expenses of the Funds that are incurred on behalf of multiple Funds fairly among the applicable Funds, in accordance with one or more allocation protocols established by the Citadel Service Parties from time to time. The Citadel Service Parties believe such allocation protocols are reasonable; however, other reasonable options exist that may yield different results, including results that would be more beneficial to one or more Funds. Reimbursable Expenses The Funds fully reimburse the Citadel Service Parties for all of their costs and expenses other than those costs and expenses that are entirely unrelated to the services the Citadel Service Parties provide to the Funds (the “Reimbursable Expenses”). The Reimbursable Expenses allocated to each Fund are material, both on an absolute basis and as a percentage of a Fund’s net asset value. Reimbursable Expenses include the compensation of all employees and third-party consultants/contractors of the Citadel Service Parties and costs related to office space, including rent payments, building operating expenses, including utilities and real estate taxes, impairments, - 4-

and occupancy related expenses, leasehold improvements, including costs associated with financing. The Reimbursable Expenses allocated to each Fund vary depending on the nature of the operations and activities of the Fund, and each Fund’s respective Offering Documents describe them in detail. The Citadel Service Parties seek to allocate Reimbursable Expenses fairly among the Funds. The Citadel Service Parties determine the allocation of Reimbursable Expenses among the Funds in accordance with one or more allocation protocols established by the Citadel Service Parties from time to time. The protocols used in making such allocation determinations may vary based on the type of cost or expense being allocated and may take into account such factors as the Citadel Service Parties deem appropriate (e.g., relative headcount, time tracking by personnel, projected usage, investment capital, and/or other factors), including those based on estimates and projections. The Citadel Service Parties believe such allocation protocols are reasonable; however, other reasonable options may exist that may yield different results, including results that would be more beneficial to one or more Funds. While the allocation of Reimbursable Expenses among the Funds is designed to generally reflect each Fund’s consumption of resources of the Citadel Service Parties and generation of revenue, certain Reimbursable Expenses will be specifically allocated only to certain Funds, other Reimbursable Expenses will be disproportionately allocated to certain Funds, and some Reimbursable Expenses will be allocated ratably among the Funds. The apportionment of Reimbursable Expenses among the Funds involves subjective determinations, which may involve conflicts of interest. Conflicts of interest have arisen, and are expected to arise, in connection with the reimbursement of expenses related to office space, where entities owned and controlled by Citadel’s Chief Executive Officer own or have an interest in the applicable office building. The Advisers may take such actions to address these conflicts of interest as they determine appropriate (e.g., through the establishment of an independent real estate committee to serve as representative of investors), as described in each Fund’s respective Offering Documents. Management Fees In addition to bearing direct expenses and their allocable portion of Reimbursable Expenses, certain Funds also pay Citadel Hedge Fund Holdings LP (and/or an affiliate) a management fee (the “Management Fee”) in respect of such Funds calculated and payable monthly, at an annual rate of 1% of the net asset value of the applicable Fund. The Management Fee generally offsets the Performance Allocation in respect of such Funds. The Offering Documents applicable to each Fund that pays a Management Fee describe in detail the specific terms governing the structure and calculation of the Management Fee and the corresponding Performance Allocation offset. Citadel Intellectual Property The intellectual property and trademarks of alternative asset managers are generally regarded as having significant value. It is in Citadel’s interest to continue expending substantial sums, some of which will be funded from direct expenses of the Funds, certain expenses reimbursed by the Funds and/or the Management Fee applicable to certain Funds, to acquire, develop, enhance, register and protect, including via litigation, its intellectual property. The Funds have no right to or property interest in Citadel’s intellectual property.

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Directors’ Fees Funds that are governed by a board of directors remunerate the directors at market rates. Such Funds also reimburse the directors for all travel, hotel and other expenses properly incurred by them in connection with their performance of services to the Funds, and, in particular, in attending and returning from any meetings of the directors, committees of the directors and general meetings. Administrator’s Fee Northern Trust Hedge Fund Services LLC (the “Administrator”) performs certain administrative and operational services for the Funds and acts as the administrator to the Funds. The Funds pay the Administrator a fee for its services at an annual rate agreed upon by the Administrator and the relevant Fund. The Administrator’s fee may be based on the investment capital of the Fund and may take into consideration the aggregate investment capital of the Fund and certain other Funds. For certain Funds, the Administrator’s fee is subject to certain monthly minimum levels. The Administrator’s fee is not included in the Reimbursable Expenses.

For certain Funds, the Advisers will take both long and short positions in a broad range of investment instruments, while the Advisers will utilize a narrower range of investment instruments for certain other Funds. The Funds’ investment policies generally do not prohibit them from taking management control of entities in which they invest. The Advisers generally employ, for the benefit of the Funds, proprietary investment strategies based upon fundamental research as well as on quantitative analysis. The sub-funds generally invest on a highly leveraged basis, and the Funds may leverage their investments in the underlying sub-funds. Certain of the Funds managed by the Advisers are multi-strategy Funds that impose no limitations on the investment instruments, markets or countries in which the Advisers may invest, on the investment strategies which the Advisers may employ, or on the type or amount of borrowings which the Advisers may enter into on their behalf. For these Funds, the Advisers will opportunistically implement whatever investment strategies or discretionary approaches the Advisers believe from time to time may be best suited to prevailing market conditions. Over time, the investment strategies implemented on behalf of these Funds can be expected to expand, evolve and change, perhaps materially. The Advisers generally will not be required to implement any particular investment strategies for the multi-strategy Funds and may discontinue employing any particular strategy, whether or not such investment strategies are specifically described in the relevant Fund’s Offering Documents, without notice to the Funds or investors. The Advisers manage other Funds that have a more specific strategy or set of investment strategies, investment instruments, markets or countries in which they may invest. Each such Fund’s respective Offering Documents describe these in detail. Following is a description of some of the more significant investment strategies that the Advisers may use on behalf of the Funds generally, investment instruments in which the Advisers may have the Funds invest, and the risks associated with them. Not all of the investment strategies, investment instruments and associated risks are relevant to all Funds.

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Investment Strategies Equities The equities strategy invests in the equity and equity-linked securities of companies globally, with a primary focus on United States and European issuers. The Advisers may take directional and/or relative value positions on behalf of the Funds, both long and short, on a global basis, investing in a broad range of investment instruments (which include securities, options, futures, currencies, derivatives and other instruments) and may employ such sub-strategies as they determine, including event-driven. The equities strategy primarily employs fundamental research, financial analysis and quantitative modeling to identify and capture opportunities. Fixed Income and Macro The fixed income and macro strategy primarily invests in the global currency, equity and fixed income markets, with a focus on G-10 and, to a lesser extent, emerging markets. The Advisers may take directional and/or relative value positions on behalf of the Funds, both long and short, on a global basis, investing in a broad range of investment instruments, including sovereign debt, currencies and currency forwards, futures, interest rate derivatives, equity indices, options, assetbacked securities, and other derivatives. The fixed income and macro strategy primarily employs macroeconomic analysis and quantitative modeling to identify and capture opportunities. Commodities The commodities strategy invests in a range of products in the global commodities markets including agricultural products, crude oil and refined products, natural gas, power, coal, environmental products and metals, including in North America, EMEA and Asia. The Advisers may take directional and/or relative value positions on behalf of the Funds, both long and short, on a global basis, investing in a broad range of investment instruments, including futures, forwards, currencies, options, securities, and other derivatives. The commodities strategy also includes buying and selling physical commodities (e.g., natural gas) and related derivatives thereof, and contracting for transportation and storage capacity for such commodities. The commodities strategy also involves principal investments in equity securities and debt instruments of public and private companies in the sector. The commodities strategy primarily employs fundamental analysis and quantitative modeling to identify and capture opportunities. The commodities strategy invests via organized trading venues, as well as by originating and structuring over-the-counter (“OTC”) investment opportunities bilaterally with counterparties. Credit The credit strategy focuses on investments in the corporate debt, equity, and equity-linked securities of companies globally, with a primary focus on United States and European issuers. The Advisers may take directional and/or relative value positions on behalf of the Funds, both long and short, on a global basis, investing in a broad range of investment instruments, including options, credit indices, equities, sovereign debt, convertible debt securities, credit derivatives, collateralized loan obligations, and other derivatives and structured investment products, and may originate or purchase corporate or other loans. The credit strategy primarily employs fundamental research and - 8-

financial analysis in the pursuit of its directional positions and quantitative modeling in the pursuit of its relative value positions. Quantitative Strategies The quantitative strategies focus on investments in the equity, fixed income, commodities and currency markets globally. The Advisers may take directional and/or relative value positions on behalf of the Funds, both long and short, on a global basis, investing in a broad range of investment instruments, including equities, sovereign debt, corporate debt, currencies and currency forwards, futures, interest rate swaps, equity indices, options, and other derivatives. The quantitative strategies team employs primarily statistical and quantitative modeling and predictive analytics to identify and capture opportunities. Multiple Portfolio Management Teams In implementing investment strategies on behalf of the Funds, the Advisers use multiple portfolio management teams, transacting in the same markets and instruments, subject to the ultimate supervision of the Advisers. Third Party Managers The Advisers from time to time, on behalf of certain Funds, allocate a portion of their assets to funds or accounts managed by investment managers that are not affiliates of the Advisers. For example, from time to time, the Advisers will agree, on behalf of certain Funds, to invest and retain capital in a fund managed by a third-party manager in exchange for both an interest in the fund and a right to share in certain additional profits of the fund or the manager. Such funds or accounts may be subject to asset-based or performance-based fees payable to the investment managers (and such fees will not reduce the Performance Allocation, Management Fee, or expenses borne by any such Fund). Significant Risks Investing in securities, derivatives and other financial instruments involves risk of loss that investors in the Funds should be prepared to bear. There can be no assurance that a Fund’s objective will be achieved or that the investment strategies the Advisers employ will be successful. Investors must be prepared to lose all or substantially all of their investment. The following describes the principal risks involved in the Advisers’ investment strategies, generally. Not all of these risks will be equally relevant to each Fund at any given time. General Risks Risk of Loss An investment in a Fund involves a high degree of risk, including the risk that the entire amount invested may be lost. Hedge funds are subject to significant risks to which traditional investments are not.

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Performance Volatility The Funds’ performance may be highly volatile. The investment results of a Fund may vary substantially over time, and sustained losses could result in the inability of the Fund to retain or deploy capital. Past Performance Not Indicative of Future Results The past performance of the Funds is not indicative of the Funds’ future results. There can be no assurance that the Funds will achieve their objectives or avoid substantial losses. Competition The activities in which the Funds engage are highly competitive. There can be no assurance that the Funds will be able to compete successfully against a broad array of competitors. Further, in the event of additional industry concentration among market participants that compete with the Funds, such competition could reduce or erode opportunities available to the Funds and/or contribute to greater correlations of the investment strategies used by the Advisers with those of such other market participants. Concentrated Investment Strategy Certain Funds focus on investing in a single investment strategy. Although the range of investment opportunities within a single investment strategy may be broad, structural, economic and regulatory changes or general market conditions could adversely affect the investment strategies employed by the Advisers on behalf of such Funds. There have been periods, including recently, when market conditions were adverse to these investment strategies. The single-strategy focus of certain Funds’ portfolios may cause their performance to be more volatile than that of a portfolio more diversified across asset classes and could cause such Funds to suffer severe losses if the applicable securities market remains disrupted for an extended period. Reliance on the Citadel Service Parties The Funds have no employees. The Funds must rely on the Advisers’ management, and the administrative and investment-related services provided by the Citadel Service Parties. The performance of the Funds depends to a large degree on the efforts of the individuals employed by the Citadel Service Parties. The Citadel Service Parties face intense competition in attracting and retaining talented professionals. Any circumstances which might result in a diminution of service levels provided to the Funds by the Citadel Service Parties could materially adversely affect the Funds. Certain investment professionals responsible for the activities undertaken on behalf of the Funds have other responsibilities on behalf of the Citadel Service Parties and conflicts of interest may arise as a result in the allocation of personnel. There are no limitations on the ability of Citadel to form or manage other Funds of any nature whatsoever or on any such Funds engaging in transactions with other Funds. Moreover, there are no limitations on the ability of the Citadel Parties to engage in other business or investment activities, whether related or unrelated to the Funds. - 10-

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The Advisers provide investment advisory services to the Funds based on the particular investment objectives and strategies described in the applicable Fund’s Offering Documents. Investors in the Funds generally are required to complete and submit a subscription agreement binding them to the terms of a Fund’s Offering Documents. Certain Funds admit only sophisticated U.S. taxable investors that are both “accredited investors,” as defined in Rule 501(a) of Regulation D under the Securities Act of 1933 (the “1933 Act”), and “qualified purchasers” (or “knowledgeable employees”), as defined in the Investment Company Act of 1940 (the “Investment - 6-

Company Act”) and the rules thereunder. Other Funds generally admit only sophisticated non-U.S. investors, or sophisticated U.S. tax-exempt investors that are both “accredited investors” and “qualified purchasers.” Additionally, certain Funds admit only eligible employees (or related qualified participants) that are “accredited investors” in accordance with such Funds’ status as “employees’ securities companies” that are operated in reliance on the exemption set forth in Section 6(b) of the Investment Company Act. Minimum investment amounts are disclosed in the applicable Offering Documents of the Funds. The Advisers generally may waive these minimums in their discretion, subject to the requirements of applicable law or regulation. Other limitations also may apply.

The Advisers generally receive an allocation from each Fund equal to a percentage of the positive difference between the net asset value of each investor’s investment in the Fund and the “high water mark” attributable to such investment (the “Performance Allocation”) as of each December 31. The Advisers also generally receive the Performance Allocation as of each date that the Fund makes a distribution or capital payout to an investor or the date that an investor withdraws capital or transfers an interest in the Fund. The Offering Documents applicable to each Fund describe in detail the specific terms governing the structure and calculation of the Performance Allocation and high water mark, which may vary between Funds. The Performance Allocation arrangements may give the Advisers an incentive to engage in more speculative investment strategies in an effort to maximize a Fund’s profits and receive greater compensation. While the Advisers seek to allocate investment opportunities among the Funds in a manner which the Advisers deem equitable over time (giving due consideration to the differences among the investment strategies employed on behalf of the various Funds), there can be no assurance that any Fund will be treated equally or pro rata. For more information, please see Item 11 of this Brochure.

Investment Advisers As described in Item 4, Advisory Business, Citadel Europe, Citadel Asia, Citadel France and Citadel Singapore are relying advisers of Citadel Advisors. Citadel Europe, Citadel Asia, Citadel France and Citadel Singapore provide investment advisory services in connection with the Advisers’ management of the Funds. Broker-Dealers The Advisers have related persons that are broker-dealers. Certain of these broker-dealers are owned by the Funds while the other broker-dealers are owned by affiliates of the Advisers. The Advisers and their affiliates may earn fees and receive other benefits when the Funds transact with and use the services of these broker-dealers. In addition, certain of the persons who are registered representatives of the Advisers’ related broker-dealers are management persons of the Advisers. - 43-

Citadel Securities Citadel Securities LLC, a part of Citadel Securities, is a broker-dealer registered with the SEC and a member of FINRA. Although Citadel and Citadel Securities generally operate independently with separate investment personnel, they both utilize the infrastructure and support provided by Citadel Enterprise and share other resources and non-investment personnel. The Citadel Parties have established certain policies and procedures, including certain information barriers, between Citadel and Citadel Securities that are designed to mitigate and reduce the number of potential conflicts of interest, to protect the confidentiality of information where appropriate or necessary and to prevent the misuse of material non-public information. As a result, Citadel and the Funds generally are not permitted to access certain information in Citadel Securities, and similarly Citadel Securities generally is not permitted to access certain information in Citadel. In addition, regardless of information barriers, Citadel Securities has no obligation to provide or make available to the Advisers, for the benefit of the Funds or otherwise, any information, strategies, models or technology used, purchased or developed by Citadel Securities. Citadel and Citadel Securities do not coordinate their trading activities, and as with any two market participants that do not coordinate trading activities, the trading activities of Citadel Securities may inadvertently have adverse impacts on the trading activities and performance of one or more Funds, and vice versa. Such adverse impacts could relate to the availability, pricing, terms or other characteristics of securities or other investments of the Funds, and investors should assume that any such impacts could be material, as discussed in the Funds’ respective Offering Documents. Citadel and Citadel Securities each operate certain businesses, and pursue certain investment strategies, that overlap and compete with one another for investment opportunities, finite resources such as corporate access, and candidates when recruiting personnel. Such overlap and competition, which may increase over time, could exacerbate the adverse impacts described above. The Citadel Parties’ principals and their related persons own a substantial majority of Citadel Securities, which could incentivize Citadel Related Parties to favor Citadel Securities and to make decisions on behalf of such Citadel Parties and/or the Funds that favor Citadel Securities. As noted above, certain regulations impose limitations on the amount of securities or other instruments that can be held by related parties or require disclosure of, or impose restrictions or obligations on purchases or sales of securities or other instruments held by, related parties. Certain of these regulations require the aggregation for regulatory purposes of instruments held by the entities or accounts managed or owned by Citadel and Citadel Related Parties, including Citadel Securities, notwithstanding the separation between Citadel and Citadel Securities. From time to time, in connection with such regulations, internal policies or other considerations, Citadel may prohibit the Funds from acquiring or selling particular securities or instruments, limit the amount of particular securities or instruments that the Funds may acquire or sell, and/or be required to disclose the Funds’ ownership of such securities.

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Citadel Clearing One of the Fund BDs, “Citadel Clearing,” provides Clearing Services to certain Self-Clearing Funds. Citadel Clearing is comprised of three legal entities: Citadel Clearing LLC, Citadel Institutional Finance Company Ltd., and CCLC Holdings LLC (“Citadel Clearing Holdco”). Citadel Clearing LLC is registered as a broker-dealer with the SEC and is a FINRA member. Each of Citadel Clearing LLC and Citadel Institutional Finance Company Ltd. are wholly owned by Citadel Clearing Holdco and perform Clearing Services for the Citadel Self-Clearing Funds. Citadel Clearing Holdco is substantially owned by the Citadel Self-Clearing Funds, although a small portion of Citadel Clearing Holdco is owned directly by entities owned and controlled by principals of the Citadel Parties. There are conflicts of interest associated with decisions made by the Advisers on behalf of a SelfClearing Fund in respect of the indirect investment in Self-Clearing Providers, as actions taken by or on behalf of one Self-Clearing Fund may have a material adverse effect on another Self-Clearing Fund. For example, in the event that fulfilling a loan obligation, or making an additional capital contribution, to a Self-Clearing Provider would cause stress to a Self-Clearing Fund’s portfolio, the Advisers will face conflicts of interest in determining whether to cause such Self-Clearing Fund to make such payments to the detriment of such Self-Clearing Fund, or advising the SelfClearing Fund not to make such payments to the detriment of such Self-Clearing Provider and the other Self-Clearing Funds. There are inherent conflicts of interest associated with the determination of the commission rates, transaction costs, custodial fees and clearing and financing costs paid by the Self-Clearing Funds to Self-Clearing Providers and the reallocation of any equity/debt therein among the relevant SelfClearing Funds, including as a result of Citadel Related Parties holding investments in one or more Self-Clearing Funds. Certain personnel provide services for both Citadel Clearing and Citadel Securities, and the allocation of their time and attention may involve conflicts of interest. Furthermore, because each of the Funds (through Citadel Clearing) and Citadel Securities conducts its own Clearing Services, they may compete for counterparty capacity and financing in connection therewith. Palafox Palafox Trading LLC (“Palafox”) is registered with the SEC as a broker-dealer, is a member of FINRA, a member of the Securities Investor Protection Corporation and a clearing member of a number of fixed income and futures clearing houses. Palafox’s business focuses on repurchase and reverse repurchase transactions involving certain types of government securities and related clearing activities.

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Commodities and Futures Commodity Pool Operator; Commodity Trading Advisor Citadel Advisors has claimed relief from registration with the CFTC as a commodity pool operator (a “CPO”) with respect to the Funds pursuant to CFTC No-Action Letter 25-50 and, accordingly, is not subject to certain regulatory requirements with respect to the Funds that Citadel Advisors would otherwise be subject to, absent reliance on such relief. Citadel Advisors may in the future elect to claim relief from registration with the CFTC as a CPO with respect to the Funds pursuant to any final rule or guidance promulgated by the CFTC or the CFTC staff codifying the relief provided under CFTC No-Action Letter 25-50, which may include CFTC Rule 4.13(a)(4), in such form as it may be promulgated. Citadel Advisors has filed to deregister as a CPO and a commodity trading advisor and withdraw from membership in NFA. Futures Commission Merchant Each of the Fund FCMs is an FCM exempt from registration with the CFTC, but subject to limited oversight by certain regulatory authorities and required to comply with certain laws, rules and regulations. The Advisers may clear a substantial portion of certain Funds’ futures trades in various asset classes through the Fund FCMs. The Advisers believe that obtaining such services from the Fund FCMs is in the best interests of the relevant Funds because, among other things, it reduces reliance on and exposure to third-party FCMs, and creates a direct risk-management relationship with relevant futures clearing houses.

Trading Code of Ethics and Personal Trading Policy Citadel has adopted a code of ethics and personal investment policies in furtherance of its commitment to compliance with applicable laws and standards of business conduct. Citadel prohibits employees from using or attempting to use their position at Citadel to obtain improper personal benefits for themselves or any other person. Citadel Parties’ personal investment policies permit employees to invest for their personal accounts, subject to certain guidelines and restrictions. All personal securities transactions by employees, by certain of their family members, and in accounts in which supervised persons or certain of their family members have a financial interest, must be conducted in accordance with the requirements of Citadel Parties’ personal investment policies. Among other things, Citadel Parties’ policies require that certain personal securities transactions by employees or certain of their family members be approved in advance by the compliance department. Certain personal securities transactions are subject to a minimum holding period. Employees must report certain personal securities holdings upon employment and periodically thereafter. Citadel Parties’ compliance department receives electronic feeds of personal securities transactions at approved brokers.

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Citadel will provide a copy of its code of ethics and personal investment policies to an investor or prospective investor in the Funds upon request. The Citadel Parties have adopted policies and procedures intended to prevent employees from being unduly influenced in their decisions by the receipt of gifts or other inducements from third parties, such as trading counterparties, vendors or investors. Employees are required to report and obtain approval for certain business gifts and are prohibited from accepting or giving certain types of business gifts. In addition, the Citadel Parties policies and procedures set forth standards for business entertainment provided by third parties, or provided by employees of the Citadel Service Parties to others. Conflicts of Interest The interests of Citadel Related Parties (including the Advisers) may conflict with the interests of the Funds. The following discussion details certain potential or existing conflicts of interest; however, the following does not purport to be a complete list or description of all of such potential or existing conflicts of interest. The Citadel Parties have established policies and procedures to address certain of the conflicts addressed below; however, such policies and procedures will not necessarily eliminate or mitigate all effects that such conflicts (and any other conflicts) may have on the Funds. Management of Other Citadel Funds Certain Citadel personnel implement investment strategies on behalf of multiple Funds, including the Funds in which Citadel Related Parties hold a significant interest. The Advisers may have incentives to favor certain Funds over others because performance-based compensation is calculated separately for each Fund. For example, if a particular Fund suffered losses early in a year and the prospects for it generating Performance Allocations were remote, while the investors in other Funds were generally above their “high water marks” for incentive compensation purposes, the Advisers would have an incentive to favor the Funds whose investors are above their “high water marks.” See Item 6, Performance-Based Fees and Side-By-Side Management. Certain Citadel personnel may also be compensated separately and using different formulas with respect to the performance of the Funds or particular investment strategies within those Funds, which may create an incentive for such personnel to favor the Funds that are more likely to impact their compensation. While the Advisers use reasonable efforts to allocate investment opportunities among the Funds, including Funds in which Citadel Related Parties hold a significant interest, in a manner which the Advisers deem equitable over time (giving due consideration to the differences among the investment strategies employed on behalf of the various Funds), there can be no assurance that any Fund will be treated equally or pro rata. The Advisers consider factors that they deem relevant in determining how to allocate investment opportunities among the Funds, including (but not limited to) investment objectives, time horizons, investment strategies, current portfolio holdings and weightings, tax considerations, regulatory considerations, working capital, risk levels, potential disclosure obligations and/or other considerations, each of which may be considered individually or in combination with other considerations. There is no requirement that any Fund receive any preference with respect to investment strategies or investment opportunities. In certain situations, - 47-

including when an investment is subject to limited capacity, investment opportunities that might have been available to and appropriate for a Fund may be allocated to another Fund (including a Fund in which Citadel Related Parties have a substantial interest) or to a proprietary account of a Citadel Related Party. The Advisers have no obligation to allocate (or continue to allocate) any given investment opportunity to any Fund, even if (i) such investment opportunity would be consistent with such Fund’s investment objectives or (ii) such investment opportunity (or any similar opportunity) has been allocated to such Fund in the past and/or is allocated to one or more other Funds (including Funds in which Citadel Related Parties have a substantial interest). In addition, no Fund will have any right to participate or to obtain an interest in any investment opportunities, business opportunities or other activities of the Advisers and the Citadel Related Parties, including Citadel Securities. Due to regulatory restrictions, certain Fund investors generally may not be permitted to participate in certain increases and decreases in a Fund’s asset value. Consequently, such increases and decreases generally are allocated entirely to the other investors’ capital accounts. As a result of such non-pro rata allocations, it is possible that losses properly attributable to one or more Fund investors could be borne by other Fund investors. Citadel Related Parties have different economic interests in different Funds. Certain personnel who implement investment strategies on behalf of the Funds hold, either directly or through employee incentive programs, an investment in one or more Funds, but not other Funds, or hold a substantially larger investment in one or more Funds than they hold in other Funds. Accordingly, such personnel have incentives to cause investments to be made, managed or realized in a manner that benefits certain Funds or to otherwise favor certain Funds over other Funds. From time to time, the Advisers determine, as a result of different investment objectives, time horizons, investment strategies, current portfolio holdings and weightings, tax considerations, regulatory considerations, working capital, risk levels, potential disclosure obligations and/or other considerations (each of which may be considered individually or in combination with other considerations), that certain investments or investment strategies (or the investment personnel that manage such strategies) should be allocated to some Funds rather than other Funds or that certain Funds should be given priority access thereto. Further, the Advisers may determine not to pursue, or to cease pursuing, certain investment opportunities, strategies or delay the execution timing of a particular transaction on behalf of a Fund if such opportunities or strategies, or the execution timing, may have an adverse impact on one or more other Funds that invest in some or all of the same sub-funds as such Fund or the investors therein, or Citadel Related Parties. The Advisers may have an incentive to cause investments to be made, managed or realized, or to allocate investment strategies in a manner designed, to advance the interests of one or more particular Funds over those of one or more other Funds. The Advisers, on behalf of a Fund, may take a position that is different from, and potentially adverse to, a position taken by another Fund, invest in a different security of an issuer’s capital structure in which another Fund is invested, invest in the same security but on different terms than another Fund, obtain exposure to an investment using different types of securities or instruments than another Fund, engage in short selling securities that another Fund holds, vote securities in a - 48-

different manner than another Fund, and/or acquire or dispose of its interests at different times than another Fund. This could have a material adverse effect on one or more of such Funds, including by diluting or otherwise disadvantaging the values, prices, or investment strategies of such Funds. When the Advisers, on behalf of a Fund, manage or implement a portfolio decision ahead of, or contemporaneously with, portfolio decisions for another Fund, market impact, liquidity constraints, or other factors could result in such Fund receiving less favorable pricing or trading results, paying higher transaction costs, or being otherwise disadvantaged. In addition, in connection with the foregoing, the Advisers, on behalf of a Fund, may pursue or enforce rights or actions, or refrain from pursuing or enforcing rights or actions, with respect to a particular issuer in which another Fund has invested, even though such actions or inaction could materially adversely affect such other Fund. Furthermore, to the extent that a particular Fund has an investment in the same issuer as another Fund, the Advisers may be incentivized to take the interests of such other Fund into account in connection with making decisions on behalf of the particular Fund, or the interests of the particular Fund into account in connection with making decisions on behalf of the other Fund, even though taking such interests into account could materially adversely affect the particular Fund or such other Fund. Certain of the transactions in which the Advisers engage create the risk that the capital attributable to one Fund could be subject to liabilities relating to other Funds. Other Activities of the Advisers and Citadel Related Parties Citadel Related Parties pursue investment opportunities, business opportunities or any other activities beyond management of the Funds. In certain situations, an opportunity may have been first presented to or considered by Advisers for a Fund or made available to Citadel Related Parties directly or indirectly because of the reputation, activities and/or relationships of a Fund or a subfund. No Fund or underlying investor therein (in their capacity as such) will have any right to participate in, receive any benefit of, or otherwise share in the risks or rewards of such opportunities or other activities. There are no limits on the nature or the extent of those other opportunities/activities, even though they will compete for the time and attention of the Citadel Related Parties, thereby creating conflicts of interest. In addition, because Citadel Related Parties are likely in the future to expand the number, variety, and/or breadth of their other opportunities/activities, conflicts of interest are expected to become more frequent and/or pronounced over time. Citadel Related Parties, including Citadel Securities, are engaged in a wide range of investment opportunities and other activities, and the principles of the doctrine of “corporate opportunity” or other similar rights or claims will not apply to such investment opportunities or other activities of such Citadel Related Parties. The Citadel Related Parties, including Citadel Securities, are under no obligation or other duty to provide investment opportunities, information, discounts or any other opportunities or benefits to any Fund. Citadel Related Parties, including Citadel Securities, buy and sell investment instruments for their own accounts and/or the accounts of others, which raises conflicts of interests, including those described herein in connection with the management of other Funds by the Advisers. Such transactions may be the same as or different from, and in some cases likely adverse to, those which the Advisers executes for a Fund. In some cases such transactions will be structured as co- 49-

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Subject to each Fund’s disclosed investment objectives, policies and strategies, the Advisers have complete discretion to determine the securities they will buy or sell and in what amounts, the broker-dealers and other financial intermediaries the Advisers will use in effecting transactions for the Funds, and what commission rates the Advisers will pay for such transactions. A more detailed discussion of how the Advisers make use of this authority follows. Brokerage The Advisers select the broker-dealers and other financial intermediaries used to effect transactions on behalf of the Funds and may select or recommend the selection of broker-dealers and other financial intermediaries. The Advisers extensively use the Clearing Services of Citadel Clearing on behalf of the Citadel Self-Clearing Funds in an effort to optimize their funding framework and achieve certain operational efficiencies. In selecting or recommending broker-dealers and other financial intermediaries to effect portfolio transactions, the Advisers may cause a Fund to enter into arrangements pursuant to which the Fund pays transaction costs in an amount greater than would be incurred if another broker-dealer or other financial intermediary were used. The Advisers are not required to solicit competitive bids or seek the lowest available commission or transaction costs. The transactions executed by the Funds may be cleared through, and the Funds’ investment instruments may be held by, a number of financial institutions selected by the Advisers on terms negotiated with each such financial institution individually. The Advisers, on behalf of the Funds, generally use a variety of financial institutions both to take advantage of differing expertise and capabilities and to avoid, due to credit and confidentiality considerations, having all investment instruments concentrated at one or only a few firms. Certain Funds often invest on the basis of short-term market considerations. The turnover rate of such Funds’ positions may be significant, potentially involving substantial brokerage commissions and other fees and expenses. Use of Soft Dollars to Obtain Research In addition to brokerage services, and subject to applicable law, the Advisers receive products and services from a Fund’s broker-dealers (in respect of the Fund’s investing). The Advisers generally will use “soft dollars” that they believe are within the safe harbor created by Section 28(e) of the 1934 Act. Services the Advisers may receive from such broker-dealers may include research, general market commentary, economic information, trading advice, industry and company commentary, technical data, recommendations, general reports, quotations and other market data or information, and the arrangement of meetings with the management of issuers. The Advisers benefit from these arrangements because the Advisers do not have to produce or pay for the research, products or services received. The Advisers may have an incentive to select or recommend a broker-dealer based on their interests in receiving soft dollar benefits rather than on the Funds’ interest in receiving most favorable execution. The services a Fund receives and pays for from broker-dealers may be used by Citadel Related Parties, including in servicing other Funds, and the Advisers may not use certain of such services to benefit the Funds. The Advisers follow - 56-

procedures they believe are reasonably designed to ensure that soft dollars are used in a manner consistent with seeking best execution, and to ensure that the Advisers identify which services are within or outside the safe harbor. Aggregation of Trade Orders Subject to the Advisers’ principal objectives of seeking to obtain best execution and treating each Fund fairly, the Advisers are permitted to aggregate orders they send to the market for more than one Fund managed by the Advisers and determine an allocation method for aggregated orders. The Advisers may use various allocation methods. Regardless of the allocation method chosen, adjustments may be made to allocations, such as to avoid excessively small allocations.

Information required by this item is not applicable to the Advisers.

The Advisers have no information to report with respect to this item.

One or more senior members of a portfolio management team have primary responsibility for reviewing Fund investment portfolios and do so either individually or in a group depending upon each Fund’s needs and the conditions of each market. Portfolio managers typically perform intraday, daily, weekly or monthly reviews of positions as they deem appropriate, or otherwise as they feel is needed. Among other reasons, portfolio managers may undertake reviews because of changes in market conditions, changes in security positions, or changes in the Advisers’ strategy for a Fund. Performance in connection with investment objectives, security positions and other investment opportunities are among the matters that a portfolio manager might consider. The number of Funds the Advisers assign to portfolio managers varies as a result of differing Fund characteristics and changes in strategy over time. The Advisers manage certain positions using automated systems and/or trade using automated systems. The Funds typically provide in writing to investors audited annual financial statements, periodic unaudited performance reports, and, for U.S. Funds, all tax information relating to their investments in the Fund necessary for U.S. federal income tax purposes. Other information may be provided as agreed upon with a Fund or an investor.

The funds and securities owned by the Funds are held by qualified custodians. Fund investors receive annual financial statements audited by an independent public accounting firm for the Funds in which they have invested. Fund investors are urged to carefully review such statements.

The Advisers exercise discretion in managing the investments of each Fund, based on the Fund’s particular investment objectives, policies and strategies disclosed in its Offering Documents.

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The Advisers have adopted written Proxy Voting Policies and Procedures intended to satisfy the requirements of Rule 206(4)-6 under the Advisers Act. Conflicts of interest between the Advisers and the Funds with respect to voting proxies are identified and addressed pursuant to the Proxy Voting Policies and Procedures. Following is a summary of the key provisions: When the Advisers vote proxies on behalf of a Fund, the Advisers generally will do so in the interest of maximizing value to such Fund (taking into consideration both the short- and long-term implications of the proposal). The Advisers may choose not to vote if doing so would be costly or impractical or the Advisers otherwise deem it unnecessary or unwarranted for any other reason. The Advisers utilize a third-party service provider to assist in implementing their proxy voting procedures. Funds may obtain information about how the Advisers voted proxies for securities in their accounts or obtain a copy of the Advisers’ written proxy voting policy by contacting Citadel’s Client and Partner Group. The Advisers will generally file class action claims on behalf of a Fund when doing so is in the interest of maximizing value to such Fund (taking into consideration both the short- and long-term implications of such claim). The Advisers utilize a third-party service provider to assist in class action claim filings and settlement processing.

Information required by this item is not applicable to the Advisers.

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Appendix A Notice of Privacy Policy Citadel considers privacy to be a fundamental component of its overall business, and it is particularly critical with respect to its relationship with its investors. In the course of managing the Funds, the Advisers collect personal information (“Personal Information”) about their natural person investors and the employees, partners, members, directors, representatives or similar of corporate investors who are located in the European Economic Area (“EEA”), Switzerland or the United Kingdom (“UK”) (each an “EEA/Swiss/UK investor representative”). Please read this notice carefully to understand what the Advisers do with Personal Information pursuant to Citadel’s Privacy Policy. The Advisers collect this information in order to know who their investors are and to meet their obligations under applicable laws and regulations. Please note that the Advisers are committed to maintaining the confidentiality, integrity and security of Personal Information at all times. Collection of Personal Information Citadel collects and retains Personal Information only as permitted by law and when Citadel reasonably believes doing so would be useful in furtherance of carrying out Citadel’s responsibilities. Citadel may collect Personal Information from: •

subscription and other forms submitted to Citadel;

•

correspondence, written or electronic, and/or telephone discussions or contacts with investors;

•

use of the Investor Portal;

•

transaction history of investor account(s) with Citadel; and

•

information made available from third parties (e.g., transfer applications).

Personal Information that Citadel collects may include, but is not limited to, investor and EEA/Swiss/UK investor representative: •

names, addresses and telephone numbers;

•

social security numbers, national insurance and/or tax identification numbers;

•

passport details including but not limited to identification numbers;

•

financial circumstances and income;

•

account holdings and transactions;

•

wire transfer instructions; and

•

other Personal Information provided to us.

Citadel uses Personal Information in the course of business, for tasks such as complying with or carrying out Citadel’s regulatory or other obligations and/or responsibilities, such as processing

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transactions, maintaining investor accounts, and responding to court orders and legal or regulatory investigations. The Advisers may also use this information to communicate with investors and offer products and services to investors. For further details regarding the use of Personal Information under EU, UK and Swiss data protection laws, please refer to the Privacy Notice for Data Subjects in the EEA, Switzerland and UK or for the use of Personal Information under the California Consumer Privacy Act, please refer to the Privacy Notice for California Residents, both published on www.citadel.com/privacy. Disclosure of Personal Information The Advisers do not knowingly disclose or transfer Personal Information to third parties, except: (1) to professional service providers who need to know such information in order to carry out Citadel’s operations; (2) to regulators (for example, Citadel may be required to report an investor’s income to taxation authorities); (3) to market intermediaries; or (4) as otherwise permitted or required by applicable law. The disclosure practices set forth above are consistent with U.S. Federal privacy and related laws, and in general, investors may not limit the Advisers’ use of their Personal Information for these purposes under such laws. The Advisers note that the U.S. Federal privacy laws only give investors the right to limit certain types of information sharing in which they do not engage (e.g., sharing with their affiliates certain information relating to their investors’ transaction history or creditworthiness for their use in marketing to such investors, or sharing any Personal Information with non-affiliates for them to market to such investors). Due to the international operations of Citadel, where necessary to deliver relevant services, Personal Information for EEA/Swiss/UK natural person investors or EEA/Swiss/UK investor representatives may be transferred to countries outside of the EEA, Switzerland or the UK which may not have data protection laws equivalent to those in the EEA, Switzerland or the UK -including to the U.S. for the purposes of sharing the data with non-EEA/Swiss/UK Citadel affiliates and third parties listed in or contemplated by the preceding paragraph. In addition, such Personal Information may be stored on servers outside the EEA, Switzerland or the UK. Citadel will only transfer Personal Information of EEA/Swiss/UK natural person investors and EEA/Swiss/UK investor representatives outside the EEA, Switzerland or the UK if it has a lawful basis for such a transfer, and after putting appropriate safeguards and any supplementary contractual, organizational and/or technical measures in place to seek to ensure an adequate essentially equivalent level of protection for Personal Information to the protection offered by the EU GDPR, the UK GDPR and the Swiss Data Protection Act (as in force and applicable). Personal Information for natural persons who have a relationship with Citadel Asia is being transferred outside of Hong Kong. Citadel processes this personal information in accordance with its Privacy Policy. In addition, the Advisers’ use of personal information may be subject to various privacy laws of Hong Kong, including the Hong Kong Personal Data (Privacy) Ordinance.

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Security of Personal Information Citadel maintains reasonable physical, electronic and procedural safeguards designed to protect against unauthorized access, use, modification and disclosure of Personal Information in our custody and control. Citadel restricts access to Personal Information to employees and service providers who are involved in administering those accounts. The Advisers generally limit access to those who have a need-to-know the information in furtherance of a legitimate Citadel business purpose. Should you have any questions regarding the Advisers’ privacy policies, please feel free to contact Citadel’s Client and Partner Group at ClientandPartnerGroup@citadel.com. *******

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