Citigroup Global Markets

Introduction This brochure provides information about Citigroup Global Markets Inc. (“CGMI”) and certain investment advisory services it provides to clients of Citi Private Bank (“CPB”) and Citi Global Wealth at Work (“WaW”) and to certain private investment funds as described herein. Each of CPB and WaW is a business unit of Citigroup Inc. (“Citigroup”), and CGMI is a subsidiary of Citigroup. CGMI is registered as an investment adviser and a broker-dealer with the U.S. Securities and Exchange Commission (the “SEC”). The advisory services described herein were previously provided by Citi Global Alternatives, LLC (“CGA”), an affiliate of Citigroup Global Markets Inc. (“CGMI”), and are now provided by CGMI. On June 30, 2025, Citigroup entities sold their interests in CGA to Institutional Capital Network, Inc. (“iCapital”), and the parties entered into certain related agreements. The name of the investment manager has been changed from “Citi Global Alternatives, LLC” to “iCapital Global Alternatives, LLC” (“iCapital Adviser”). The teams previously engaged in providing portfolio management services to the respective funds and managed accounts on behalf of CGA, as described herein, have been transferred to CGMI as a result of the iCapital transaction. CGMI provides advisory services (as a sub-adviser) to private investment funds, including funds of hedge funds (each, a “Fund of Hedge Funds”), funds of private equity and real estate funds (each, a “Fund of PERE Funds,” and collectively with the Funds of Hedge Funds referred to as “Funds of Funds”), and private funds that invest in a portfolio of co-investment opportunities sourced from third-party managers (“Co-Investment Funds” and together with the Funds of Funds, the “Sub-Advised Funds”). CGMI also provides investment advice to separately managed accounts (“Managed Accounts”) on either a fully discretionary or nondiscretionary basis. In addition, CGMI provides certain non-fee services as described below. This brochure is limited to CGMI’s alternative investments advisory services. Other advisory services and wrap programs are described in different brochures, which can be accessed at: https://www.privatebank.citibank.com/adv.htm and http://www.citi.com/investorinfo/advisoryprivacy. Clients should read and consider carefully the information contained in this brochure. While CGMI believes that its professional investment advice can work to benefit many clients, there is no assurance that the objectives of any Fund of Funds, Co-Investment Fund, Managed Account or other investment program described herein will be achieved. General The third-party portfolio managers (“Portfolio Managers”) and the underlying funds and coinvestment opportunities managed by such advisers (“Funds”) are selected by CGMI for inclusion in the Sub-Advised Funds and/or Managed Accounts. CGMI applies its experience in manager sourcing, due diligence and risk management to evaluate and select third-party Portfolio Managers (and their funds or products) for inclusion on the Citi platform (the “Citi platform”). CGMI will only select Portfolio Managers for inclusion in the portfolios of the SubAdvised Funds and Managed Accounts if they have been reviewed by Citi’s Alternatives and Investment Manager Solutions team (“AIMS”). In selecting Portfolio Managers for inclusion on the Citi platform, AIMS generally will consider various factors as appropriate for the relevant Platform, including, but not limited to: (i) investment strategy and targeted sectors;

(ii) the Portfolio Manager’s investment team and personnel; (iii) the overall sustainability risk profile of the Portfolio Manager; and (iv) the track record and transactions effected by the Portfolio Manager’s investment team. In respect of underlying funds that are hedge funds, AIMS also considers, among other factors: (i) the Portfolio Managers’ historical ability to generate attractive risk-adjusted returns over time; (ii) the Portfolio Managers’ historical ability to monitor and control risk appropriate to their strategy; and (iii) the adequacy of the Portfolio Managers’ business and operational infrastructure to support current and future projected assets under management. Within each of these two sets of broad areas, AIMS uses an extensive list of questions and metrics designed to assist it in deciding whether to allow a particular Portfolio Manager onto the Citi platform. Interviews with other investors and lenders and verification from independent professionals may also be undertaken. Citi relies on iCapital Advisors, LLC (“iCapital Advisors”), an affiliate of iCapital, to perform initial and ongoing due diligence on certain investment fund products, including business development companies, closed-end funds, private funds, and 1934 Act reporting companies, and the sponsors of such fund products. While iCapital Advisors will use criteria approved by AIMS in conducting due diligence, it should be expected that iCapital Advisors may apply those criteria differently than Citi. iCapital Advisors also conducts due diligence on the fund products that utilize Environmental, Social, and Governance (“ESG”) or sustainability factors in their respective investment strategies. Citi has adopted policies and procedures reasonably designed to oversee iCapital Advisors’ diligence. Prior to being admitted to the Citi platform, the Portfolio Manager and its relevant advised Fund must be approved by an internal investment committee and are also subject to various Citigroup approval processes. The members of this investment committee include officers of CGMI and officers of other Citigroup entities. For certain investments, CGMI or its delegate may serve as a member of the relevant limited partner advisory committee or serve in a similar function. The terms of any such advisory committee or similar function will be disclosed in the relevant governing documents. CGMI’s role with respect to Underlying Funds is generally limited to ongoing due diligence, performance monitoring, review of adherence to regulatory and investment guidelines, assessment of the use of leverage and examination of risk management procedures. Services Provided: Managed Accounts CGMI provides investment advice to Managed Accounts that will primarily acquire interests in Funds advised by Portfolio Managers and included on the Citi platform. CGMI provides such advice either directly to the client or, in certain regions outside the U.S., on a sub-advisory basis (with a local Citigroup affiliate generally serving as the direct advisor). The Managed Accounts are managed on a fully discretionary basis (“Discretionary Managed Accounts”) or a non-discretionary basis (“Non-Discretionary Managed Accounts”). Individual account agreements will provide for client notice or approval procedures, if any. With respect to a Discretionary Managed Account, CGMI and its affiliates will enter into an advisory agreement and related account opening documents with the client pursuant to which CGMI will construct and manage on a discretionary basis the Discretionary Managed Account. With respect to a Non-Discretionary Managed Account, CGMI and its affiliates will enter into an advisory agreement and related account opening documents with a client pursuant to which CGMI will provide investment advice relating to investment funds and will construct on a non-discretionary basis the Non-Discretionary Managed Account’s portfolio. Individual agreements may provide for other services to be provided by CGMI which may include: overall

allocation advice, due diligence services, consolidation of certain accounts, analytical and reporting services and certain administrative services. Citibank, N.A. or other Citigroup affiliates or third parties are often retained by the Managed Account clients or CGMI to provide administrative, custodial or other services to the Managed Accounts. In 2015, The Bank of New York Mellon (“BNY”) was appointed to perform certain sub-custodial and other functions in respect of the Managed Accounts established as of such date and has been appointed to perform such services for subsequent Managed Accounts in certain regions. The Managed Accounts program is generally referred to as the “Custom Hedge Fund Portfolios” program. In constructing a Managed Account portfolio, CGMI will first consider and assess the Managed Account client’s financial goals, investment objectives, investment time horizon, risk tolerance, investment preferences and other considerations deemed appropriate by CGMI. CGMI expects that it will utilize its proprietary asset allocation methodology and processes to determine strategic allocations for the portfolio. CGMI will also consider macroeconomic and market factors along with its qualitative views in both constructing the initial portfolio as well as providing ongoing monitoring and rebalancing advice. In certain instances, depending on an individual client’s needs and preferences, CGMI may construct portfolios that are either concentrated in terms of strategy or sectors or in terms of the number of funds. See Item 8 “Methods of Analysis.” Services Provided: Fund of Hedge Funds General CGMI has been engaged by iCapital and its affiliates as a sub-advisor (the “Sub-Advisor”) of each Fund of Funds. In this role, CGMI provides investment advice to Funds of Hedge Funds that are organized to invest primarily in other hedge funds (“Underlying Hedge Funds”). The iCapital Adviser will serve as the portfolio manager or investment adviser to each Fund of Hedge Funds and CGMI serves as the sub-investment manager or sub-portfolio manager of the Funds of Hedge Funds in accordance with the relevant sub-advisory agreement (the “SubAdvisory Agreement”). Subject to the terms of the relevant Sub-Advisory Agreement, the Underlying Hedge Funds will be selected by CGMI, which takes advantage of AIMS’ sourcing, due diligence and risk management capabilities in evaluating and selecting third-party hedge fund managers. CGMI will determine the initial allocation among the Underlying Hedge Funds, perform ongoing due diligence on the Underlying Hedge Funds, and regularly rebalance the allocation among the Underlying Hedge Funds based on, among other factors, the Funds of Hedge Funds’ strategies, investment limitations and investment restrictions as well as CGMI’s assessment of the individual Underlying Hedge Funds and the global market conditions. CGMI expects that it will utilize its proprietary asset allocation methodology and processes to determine strategic allocations for each Fund of Hedge Funds. It will also consider macroeconomic and market factors along with its qualitative views in both constructing the initial portfolio as well as providing ongoing monitoring and rebalancing advice. See Item 8 “Methods of Analysis.” Structure There are two Fund of Hedge Funds vehicles, one onshore and one offshore, that have been structured as “umbrella” structures which either issue shares in separate sub-funds or issue interests in series, depending on the vehicles’ jurisdiction of organization. Each series or subfund (each a “HF Portfolio”) will seek to achieve its own investment objective and policy, have separate rights and privileges as established in the vehicles’ respective constitutive

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CGMI offers investment management and advisory services for a fee that is calculated as a percentage of assets under management, and fees based on performance as described below and in Item 6. Such fees are based upon the scope of the engagement and the services required by the relevant Fund of Funds, Co-Investment Fund, or Managed Account and disclosed in the relevant investment advisory agreement, Sub-Advisory Agreement, or account documentation, as applicable. As among Funds of Funds and Co-Investment Funds, fees differ based upon a number of factors, including the structure of such Fund of Funds or Co-Investment Fund and the complexity and trading strategy of such fund and any relevant Underlying Funds or Co-Investments. For the Managed Accounts, fees may differ based upon a number of factors, including without limitation, account complexity and size, assets under management, overall relationship with CGMI and its affiliates and relevant negotiated commercial terms, including any relevant investment objectives and restrictions. As compensation for its investment management and advisory services, CGMI’s advisory or management fees are typically calculated based on committed capital, net asset value, current fair value and/or remaining invested capital, with respect to such CGMI’s clients. The amounts of such fees and allocations, including how and when fees are calculated, charged and paid, and how allocations are calculated and made, are described in detail in the offering documents for each Fund of Funds and Co-Investment Fund and the account documentation for each Managed Account, and investors and potential investors should review these materials carefully when making their investment decisions so that they have a complete understanding of the fees and expenses that can be charged to investors. In its role as Sub-Advisor to the Sub-Advised Funds, CGMI is receives certain sub-advisory fees (the “Sub-Advisory Fees”). CGMI generally shares Sub-Advisory Fees with the Distributors for the relevant Sub-Advised Fund up to 50% of the Sub-Advisory Fees and, where applicable, up to 100% of any performance compensation. “Distributors” of the SubAdvised Funds are CGMI and its various affiliates, including Citibank, N.A. and its branches and Citi Private Alternatives, LLC (“CPA”), that serve as placement agents or distributors of a Fund. The following descriptions of fees are current as of the date of this brochure. CGMI may in the future charge other types of fees and use different fee structures, including variations of performance or incentive fees and allocations (referred to herein as “incentive” fees or allocations), payment and termination terms. The management fees, other fees and distributions described herein are generally subject to modification, waiver or reduction by CGMI in its sole discretion, both voluntarily and on a negotiated basis with selected investors and clients via side letter and other arrangements, which may not be disclosed to other investors in the same CGMI’s client or other clients. The fee structures described herein may be modified from time to time. Fees may differ from one CGMI client to another, as well as among investors in the same Fund. Employees of CGMI and its affiliates invest in Funds of Funds, Co-Investment Funds and Managed Accounts on the same terms as other clients; however, employees who are Managing Directors receive a 50% discount on placement fees payable to the Distributors. Additionally, in respect of certain products, commitment level requirements that otherwise

would apply for an investor to be eligible for a series or share class are waived by CGMI and/or on behalf of its products for certain investors, such as for Citigroup employees and members of their families. This may result in such investors paying lower fees than would be charged for the series or share class for which they would otherwise be eligible. Fees Charged: Managed Accounts The investment advisory agreement and account documentation relating to each Managed Account will specify the fees payable to CGMI or its affiliates. Such fees will typically include management fees that are asset-based and range from 0.00% to 1.60% per annum for the presently advised Managed Account clients, and will vary for each particular client based on a number of factors and considerations, which may include size of the account, account investment mandate and related complexity, assets under management and requested commercial terms which are subject to negotiation, such as whether the account is discretionary or non-discretionary. Clients with similar investment objectives or other similarities (such as account size) may be charged different management fees. There are no current arrangements for performance fees, which are typically determined as a percentage of profits, or for non-asset-based fixed management fees. Fees are payable in arrears, typically monthly or quarterly as provided in the relevant account documentation. CGMI will typically share a portion of such fees with certain placement, sales or referral agents. Any servicing fees or incentive payments received by CGMI or its affiliates in respect of a Managed Account’s investment in an Underlying Fund or other investment vehicle will be credited or refunded to the Managed Account holder. To the extent that a Managed Account invests in a feeder advised by the iCapital Adviser, it will generally invest in a “no fee” share class, which is a class that charges reduced management fees or incentive fees. In the event of a termination of a Managed Account, such investor will no longer be eligible to participate in such “no-fee” share class and such shares/interests will be exchanged for or converted into shares/interest of the corresponding class for which such investor qualifies for and such feeder will charge the fees as provided in the relevant offering documents. Citigroup affiliates will in most instances provide certain administrative and custodial services related to the support of the Managed Accounts at no additional cost. It is expected that CGMI will share a portion of its fees with such affiliated service providers. As noted above, BNY has been appointed to provide certain sub-custodial and related services for the Managed Accounts. For Managed Accounts established after February 2015, such Managed Accounts will be subject to any fees charged by BNY. For Managed Accounts established prior to such date, CGMI or one of its affiliates shall pay any fees charged by BNY. Managed Account clients will generally be able to terminate their contractual relationship upon written notice given within certain specified times as provided in the relevant account documentation. If a Managed Account is terminated, CGMI will be entitled to fees so long as any assets remain in the Managed Account as compensation for administrative services provided by CGMI in connection with the termination of the Managed Account. Nevertheless, CGMI will aim to wind down the Managed Account as soon as reasonably practicable. Fees Charged: Funds of Hedge Funds Each Fund of Hedge Funds will pay the iCapital Adviser a management fee either monthly or quarterly in arrears, at an annual rate up to 1.25% per annum, which varies by share class, based on the amount invested. The iCapital Adviser will retain up to 0.25% per annum of the management fee, and CGMI will receive the remaining portion of the management fee, for its services as Sub-Advisor. There are no current arrangements for incentive fees or allocations,

which are typically determined as a percentage of profits, or for non-asset-based fixed management fees. However, in addition to the management fee, certain Dedicated Portfolios may in the future pay or allocate to the iCapital Adviser and/or CGMI an incentive allocation and/or incentive fee based on the return of the Dedicated Portfolio and its investments. The amount of the management fee, incentive allocation and/or incentive fee for a particular HF Portfolio within a Fund of Hedge Funds vehicle will be set forth in the account documentation for that HF Portfolio. In certain cases, CGMI will agree to waive part or all of the asset-based fee and/or otherwise reimburse or pay a Fund of Hedge Funds, to the extent necessary to prevent such Fund of Hedge Funds’ expenses from exceeding a certain amount, as may be contemplated in such Fund of Hedge Funds’ offering documentation. The management fee paid to iCapital (and thus the portion shared with CGMI) is calculated based on the value of the assets of the Underlying Funds as provided by the manager of each Fund as of a particular date. Such Fund valuations are based on the value of underlying alternative investments, which may trade rarely if at all, and are thus difficult to value. iCapital and CGMI rely on these valuations to calculate management fees, and there is a risk that these valuations will be higher than the actual value of such Funds. Fees Charged: Funds of Private Equity/Real Estate Funds CGMI will receive a portion of the management fee paid by each Fund of PERE Funds to the iCapital Adviser, for its services as Sub-Advisor, as set forth in the offering documents of the Funds of PERE Funds. Each Fund of PERE Funds will pay the iCapital Adviser a management fee quarterly in arrears, at an annual rate ranging at present from 0.00% to 0.75% per annum based on the aggregate unreturned invested capital called from the Fund of PERE Funds’ investors. There are no current arrangements for incentive fees or allocations, which are typically determined as a percentage of profits, or for non-asset-based fixed management fees. The amount of the management fee, incentive allocation and/or incentive fee for a particular PERE Portfolio within the Fund of PERE Funds vehicle will be set forth in the account documentation for that PERE Portfolio. CGMI, CPA and certain other affiliated placement agents typically also receive servicing fees, incentive payments and upfront fees from a Portfolio Manager of an Underlying PERE Fund. Investors will typically also be subject to a placement fee payable to the placement agents affiliated with CGMI which is in addition to the upfront fees. Fees Charged: Co-Investment Funds CGMI will receive a portion of the management fee paid by each Co-Investment Fund to the iCapital Adviser, for its services as sub-adviser, as set forth in the offering documents of the Co-Investment Fund. Each Co-Investment Fund will pay the iCapital Adviser a management fee quarterly in arrears, at an annual rate ranging at present from 0.50% to 1.00% per annum based on the aggregate capital commitments made to each Co-Investment Fund during the investment period, and based on aggregate invested capital thereafter. CGMI or an entity that it designates will generally receive an incentive allocation of 10% of profits after an 8% annual preferred return to investors. For certain series of interests available to early investors in a Co-Investment Fund, CGMI or an entity that is designates will receive an incentive allocation of 5% of profits after an 8% annual preferred return to investors, with all such amounts then paid to the Distributors. Investors will typically also be subject to a placement fee payable to the placement agents affiliated with CGMI.

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Methods of Analysis See Item 4 for a description of the method of selecting and monitoring the selection of CoInvestments for the Co-Investment Funds and the selection of Underlying Hedge Funds and Underlying PERE Funds for inclusion in the Fund of Funds. In constructing portfolios for the Managed Accounts and the Funds of Hedge Funds, CGMI’s process is iterative and includes multiple levels of research inputs from both research teams within CGMI and other areas of Citigroup. CGMI and the AIMS team each use a proprietary and innovative hedge fund portfolio construction, management and monitoring tool created specifically for and by CGMI. This tool provides real time oversight of the portfolios, quality statistical analysis and enhanced connectivity to relevant systems and databases. The strategic asset allocation process of portfolio construction formulates a top down and bottom up review incorporating both quantitative and qualitative components. The top down and bottom up reviews are overlaid with thematic investment ideas and forward looking views on market opportunities. The monitoring and rebalancing process is designed to dynamically assess the portfolio based on, among other things, market themes, opportunities and views and benchmark and performance analysis. With respect to Managed Accounts, Custom PERE Portfolios, and Dedicated Portfolios, CGMI may also consider, among other factors, the client’s lifestyle, needs and objectives and its risk and return expectations. In certain instances, depending on an individual client’s needs and preferences, CGMI may construct more concentrated portfolios that are more concentrated in terms of strategies, sectors or number of funds. See Item 4 “Particular Investment Restrictions.” The processes described above will also be utilized in varying degrees with respect to the Portfolio Diagnostic Reviews. Risks Alternative Investments entail a high degree of risk. Investors should give careful consideration to the following risk factors and conflicts of interest detailed in this Item 8 and also review the more detailed risk factors and conflicts of interests set forth in the relevant offering memorandum and other product-specific information provided by the product or CGMI, which are incorporated herein by reference, in evaluating the merits and suitability of any Alternative Investment products. The following does not purport to be a comprehensive summary of all the risks and conflicts of interest associated with Alternative Investments. “Alternative Investments” means the Funds of Funds, the Co-Investment Funds, the Managed Accounts and the Dedicated Portfolios, and unless the context indicates otherwise, all references to “Alternative Investments” in this Item 8 should be read to include “Underlying Funds.” “Investment Managers” includes CGMI and the Underlying Fund Managers unless the context indicates otherwise. “Underlying Fund” includes, where applicable, a Co-Investment, an Underlying Hedge Fund and an Underlying PERE Fund. “Underlying Fund Manager” means

the investment manager or investment adviser to the Underlying Fund, including a Portfolio Manager. General Investment Risks General. Any prospective client or investor must be able to bear the risks involved and must meet the suitability requirements of the Alternative Investments. Alternative investment strategies employed by the Alternative Investments are not suitable for all investors. No assurance can be given that the Alternative Investments’ investment objectives will be achieved. Investments in hedge funds, private equity funds, real estate funds and other types of private investment funds are typically speculative and involve a substantial degree of risk. Past results of the Alternative Investments or any other private investment funds or accounts managed by Investment Managers are not necessarily indicative of future performance of any Alternative Investment and the performance of such Alternative Investment may be volatile. Moreover, CGMI will place an Alternative Investment’s assets with an Underlying Fund Manager based upon CGMI’s evaluation of, among other factors, the past performance of such Underlying Fund Manager. Such past performance may not be an accurate indicator of future returns delivered by such Underlying Fund Manager. Investment results may vary substantially on a monthly, quarterly or annual basis. The establishment and use of an Alternative Investment does not constitute a complete investment program. A prospective client or investor must realize that it could lose all or a substantial amount of its investment in an Alternative Investment. Certain Alternative Investments may underperform or experience financial difficulties, which difficulties may never be overcome. Certain Alternative Investments may be highly illiquid and/or permit redemptions infrequently and under very restrictive terms. Investment Managers may utilize highly speculative investment techniques, including extremely high leverage, highly concentrated portfolios, workouts and startups, control positions and illiquid investments. Neither CGMI nor any investor will have the ability to direct or influence the management of an Underlying Fund Manager’s investments. As a result, the returns of any Alternative Investment that allocates to an Underlying Fund will depend primarily on the performance of such Underlying Fund Manager and could suffer substantial adverse effects by the unfavorable performance of such Underlying Fund Manager. There are no assurances that any Investment Manager will be able to identify suitable investment opportunities. No assurance can be given that an Alternative Investment will achieve its goals or investment objectives. If an Alternative Investment receives distributions in kind from an Underlying Fund, it may incur additional costs and risks to dispose of such assets. Dependence on the Investment Managers. Subject to the terms of the Sub-Advisory Agreement, all decisions with respect to the assets and the general management of the Funds of Funds and Co-Investment Funds will be made by CGMI and all decisions with respect to Underlying Funds’ assets and the general management of the Underlying Funds will be made by the Underlying Fund Managers. All decisions with respect to the assets and the general management of the Discretionary Managed Accounts and Dedicated Portfolios will be made either directly by CGMI or where CGMI is serving as a sub-adviser to another Citi affiliate, directly by such Citi affiliate as provided in the relevant account information. All recommendations made to clients with respect to the Non-Discretionary Managed Accounts will be made either directly by CGMI or where CGMI is serving as a sub-adviser to another Citi affiliate, directly by such Citi affiliate as provided in the relevant account information. Investors in the Alternative Investments will have no right or power to take part in the management of the Alternative Investments. As a result, the success of the Alternative Investments will depend largely upon the ability of the Investment Managers and their personnel, in particular the ability of the Investment Managers to identify and consummate

appropriate investments that generate a profit or which the Alternative Investments dispose of at a profit. There can be no assurance that an Investment Manager will be able to identify a sufficient number and/or mix of appropriate investments for the particular Alternative Investment, that such investments generate a profit or that an Investment Manager will be able to dispose of such investments in a timely and/or profitable manner. There can be no assurance that any key persons of an Investment Manager will continue to be associated with the relevant Alternative Investment throughout its term. The loss of the services of one or more key persons with respect to any Alternative Investment could have an adverse impact on such Alternative Investment’s ability to realize its investment objective. Additional risks associated with Investment Managers include significant structural changes to an Investment Manager’s operations; fraud or misrepresentation on the part of an Investment Manager or its personnel; an Investment Manager’s failure to comply with applicable legal, registration, tax or regulatory requirements; human error or poor judgement on the part of an Investment Manager’s personnel; and system malfunctions and other operational failures of an Investment Manager. Illiquidity of the Alternative Investments. The documents governing the Alternative Investments generally impose substantial restrictions on transfers of interests in the Alternative Investments and require the consent of the Investment Managers to be obtained before any such transfer. Some Investment Managers may withhold such consent for any reason or no reason. Interests in the Alternative Investments will be offered without registration under the Securities Act, in reliance upon an exemption contained in Section 4(a)(2) of the Securities Act, Regulation D and/or Regulation S under the Securities Act. There will be no public market for such interests in the Alternative Investments and, for a variety of regulatory reasons, no such market will be permitted to exist. The only source of liquidity typically lies in an investor’s right to redeem from the Alternative Investments (if any such right even exists). Redemptions from the Alternative Investments, may be subject to various restrictions, including prior notice and minimum redemption requirements, lock-up periods of one year or more, side-pocketed investments, and the right of the Alternative Investments to reduce the amount of redemptions in accordance with a redemption gate. In addition, in the event of a complete redemption from an Alternative Investment, a portion of the redemption proceeds may be retained by such Alternative Investment until the completion of such Alternative Investment’s annual audit. The Alternative Investments may have discretion to further defer payment of redemption proceeds, to suspend redemptions indefinitely and to satisfy redemptions in kind. In addition, redemption payments from certain Alternative Investments may be based on inaccurate/or estimated data, and may be subject to a return of any overpayments by the investor. Accordingly, an investment in an Alternative Investment is suitable only for certain sophisticated investors who have no need for immediate liquidity in their investment. Illiquidity of Underlying Investments. Generally, there may be no readily available market for certain of the underlying investments of the Alternative Investments. Market illiquidity could prevent an Alternative Investment from effecting dispositions of its assets at desired times or require the Alternative Investment to accept “in-kind consideration” and consequently result in distributions “in-kind” to investors, all of which could negatively impact the rate of return achieved on such investments. Certain underlying investments of an Alternative Investment may consist of securities that are subject to restrictions on sale if they were acquired from the issuer in “private placement” transactions or if the Alternative Investment is deemed to be an affiliate of the issuer. Generally, an Alternative Investment will not be able to sell these securities publicly in the United States without the expense, time and other burdens required to register the securities

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With respect to the Funds of Funds and Co-Investment Funds, CGMI’s clients are the respective funds, not the underlying investors. The Funds of Hedge Funds (other than the Dedicated Portfolios) require minimum investments ranging from $100,000 to $5,000,000, which may be waived, subject to applicable law. The Funds of PERE Funds (other than Custom PERE Portfolios) and the Co-Investment Funds require minimum investments ranging from $250,000 to $5,000,000, which may be waived, subject to applicable law. CGMI expects that investors in the Dedicated Portfolios and Custom PERE Portfolios may include individuals, trusts, institutions and pension plans. CGMI generally requires a minimum investment of $10,000,000 for Dedicated Portfolios and Custom PERE Portfolios, which may be waived, subject to applicable law, and which can be made in cash or in the form of one or more in kind contributions (each, an “In Kind Contribution”). The acceptance of an In-Kind Contribution will be made on an ad hoc basis and will be subject to the approval of the governing body of the applicable Dedicated Portfolio or Custom PERE Portfolio.

With respect to the Managed Accounts, the clients are the holders of the Managed Accounts. CGMI expects that such clients may include individuals, trusts, institutions and pension plans. CGMI generally requires a minimum investment of $10,000,000 for both Discretionary Managed Accounts and Non-Discretionary Managed Accounts, which may be waived, subject to applicable law.

CGMI will not charge incentive fees directly at the Fund of Hedge Funds or Fund of PERE Funds level. Underlying Funds may charge such fees (other than Dedicated Portfolios as described below). CGMI expects that it (or an entity that it designates) will charge incentive fees or allocations for the Co-Investment Funds, for Custom PERE Portfolios, for certain Managed Accounts and for certain Dedicated Portfolios within the Fund of Hedge Funds. See Item 8 “Use of Underlying Fund Managers” and “Valuation Risks.” Incentive fees can vary depending upon the Fund of Funds, Co-Investment Fund or Managed Account. In certain instances, the incentive-based compensation will create an incentive for CGMI to cause certain of the Funds of Funds, CoInvestment Funds or Managed Accounts to make investments which would be riskier or more speculative than those made under a different compensation arrangement. This conflict is mitigated through our adoption and implementation of allocation policies and procedures that are designed to treat clients fairly and equitably. See “Statement of Allocation Policy and Procedure” above.

Many of the officers and employees of CGMI making investment decisions have in the past held, and will continue to hold, similar positions as officers and employees of affiliates of CGMI. CGMI may share resources, other employees and management, as well as investment ideas and opportunities, with any or all affiliates engaged in similar activities. Certain employees of CGMI are registered as broker-dealer representatives of CGMI and/or CPA. Other Registrations CGMI is registered as an investment adviser, broker-dealer and security-based swap dealer with the SEC and is registered as a Commodity Trading Advisor, a futures commission merchant and a swap dealer with the U.S. Commodity Futures Trading Commission (“CFTC”) and is a member of the National Futures Association. CGMI is a member of all principal

securities and commodities exchanges in the United States and the Financial Industry Regulatory Authority (“FINRA”). Certain Funds of Funds operate under relief from commodity pool operator reporting requirements pursuant to CFTC Rule 4.7, other Funds of Funds, Co-Investment Funds and the Managed Accounts are operated in accordance with the certain applicable exemptions from commodity pool operator and commodity trading advisor registration, as applicable, in each case as described in the applicable account documentation. Material Relationships or Arrangements with Certain Related Persons Broker-Dealer CGMI, a registered broker-dealer, and CPA, a registered broker-dealer, each serve as a distributor or placement agent of the Funds of Funds, Co-Investment Funds and Managed Accounts. Citibank, N.A. and other Citigroup affiliated entities also serve as distributors or placement agents for these CGMI-advised funds and accounts. Such affiliated distributors charge placement or other fees to clients as provided in the relevant account documentation. CGMI, CPA and certain other affiliated placement agents may also receive from a Portfolio Manager an investor servicing fee which may give such placement agents an incentive to place investments in Alternative Investments with higher servicing fees. In addition, the Distributors may share in certain fees paid to CGMI in its capacity as investment manager to an Alternative Investment. See Item 5 “Fees and Compensation” and “Compensation from Portfolio Managers” below. Custodian Citibank, N.A., a national bank, serves as custodian for the assets in the Managed Accounts and it has appointed an unaffiliated sub-custodian for some Managed Accounts, as described in Item 4, above. This arrangement is fully disclosed in the Managed Accounts terms and conditions. Banking Institutions As described above, certain Citigroup affiliates serve as distributors or referral agents for CGMI-advised funds and accounts. As described in Item 4 “Services Provided: Managed Accounts,” Citibank, N.A. and other Citigroup affiliates provide administrative, custodial and other services to the Managed Accounts. Certain Funds of Funds and Co-Investment Funds may retain Citibank, N.A. to provide certain cash account services. Material, Non-Public Information As a result of the activities of, and investments made by, CGMI and its affiliates for their own and others accounts, CGMI may acquire confidential or material non-public information and therefore be restricted from initiating certain transactions. Disclosure of such information to CGMI’s personnel responsible for the affairs of Alternative Investments will be on a need-toknow basis only, and Alternative Investments may not be free to act upon any such information. Therefore, Investment Managers of Alternative Investments may not be provided access to material non-public information in the possession of CGMI that might be relevant

to an investment decision to be made by an Investment Manager of an Alternative Investment, and an Investment Manager of an Alternative Investment may take actions that, if such information had been known to it, may not have been undertaken. In the event any material non-public information is disclosed to any of the personnel of CGMI, any provisional advisory board member or any other person responsible for the affairs of an Alternative Investment, then such Alternative Investment may be prohibited by applicable securities laws and CGMI’s internal policies from acting upon any such information. Due to these restrictions, such Alternative Investment may not be able to take certain actions. CGMI and its affiliates have no obligation to seek information and there is no obligation on the part of CGMI, its affiliates or their personnel to make available to an Alternative Investment any information known or developed in connection with other clients or in connection with activities unrelated to such Alternative Investment. Compensation from Portfolio Managers Certain companies will pay CGMI, CPA, or other affiliates of CGMI, as consideration for investor services provided by CGMI and its affiliates in connection with the investment in such company by the Fund of Funds, a servicing fee or upfront fee. Other investment vehicles may also pay CGMI, CPA or other affiliates servicing fees or upfront fees. See Item 5 “Fees and Compensation.” Such servicing fees and upfront fees may influence CPA, CGMI and such other affiliates to make positive statements about and to recommend investments in these Master Companies. CGMI and other Citigroup affiliates will receive fees or other compensation for services, including placement or distribution services, (including but not limited to financial advisory, prime brokerage, lending, investment banking and custodian services) rendered to the Portfolio Managers on the Citi platform (including the servicing fee) or to issuers of any securities in which such Portfolio Managers invest. This arrangement presents certain conflicts of interest as the servicing fee and other fees or compensation payable to the CGMI and Citigroup-affiliated placement agents can vary among the Funds of Funds and Co-Investment Funds, which may give the Citigroup affiliated placement agents an incentive to propose investments in Funds of Funds and Co-Investment Funds with higher fees. The Funds of Funds and Co-Investment Funds will not share in any such compensation; however, Managed Account clients will receive rebates or credits of any servicing fees attributable to the Managed Accounts as provided in the relevant account documentation.

Personal Trading General Employees and certain other persons who perform services that support the investment advisory business of CGMI are bound by the Personal Trading and Investment Policy (“PTIP”) and the Fiduciary Code of Ethics Standard (“Code of Ethics”). The Code of Ethics is designed to comply with applicable regulatory requirements including Rule 204A-1 of the Advisers Act. Both the PTIP and the Code of Ethics govern the trading of employees who support the investment advisory business of CGMI and the family member/related persons accounts over which the employee has investment discretion.

Certain representatives within CGMI are considered covered persons under the PTIP. This policy governs the manner in which the covered persons’ trading account information is made available to the firm’s compliance department and defines instances where pre-clearance or supervisory pre-approval may be appropriate. Covered persons are subject to a number of restrictions including 1) prohibition on conduct of personal trades in securities for which they are in possession of material, non-public information; 2) prohibition on securities noted on the firm’s restricted list; and 3) prohibition on trading in securities where new and material research has been published. Other restrictions exist with respect to “new issue”/public offerings and trading of Citigroup shares. Covered persons are further prohibited from engaging in market timing strategies with respect to mutual fund transactions in covered accounts. Certain supervisory staff are responsible for reviewing all personal trading activity of their covered employees for indications of improper trading activity and insider trading. When CGMI personnel purchase or sell certain securities for their own accounts on the same day that transactions in these securities are affected for client accounts, the price paid or realized by advisory personnel generally may not be more advantageous than the price at which the client transactions are effected. If orders by CGMI personnel are part of a batched client order and the entire block of securities is then not executed on the same day, no part of the order executed is permitted to be allocated to any advisory personnel. The Code of Ethics describes the standards of business conduct for CGMI’s investment advisory business, including the fiduciary obligations owed to the clients and the obligation to comply with applicable laws. The Code of Ethics incorporates and is supplemented by other Citi policies and procedures, including policies and procedures designed to protect the flow of material non-public information and the confidentiality of client information and those imposing personal trading and investment restrictions, maintenance of personal securities trading accounts and reporting of personal securities holdings and transactions. The purposes of the Codes of Ethics and the related policies and procedures include minimizing potential conflicts of interests between employees and investment advisory clients and assuring compliance with applicable laws and regulations. Each person covered under the Code of Ethics receives a copy of the Code of Ethics upon being designated as a covered person and annually thereafter. They must sign an attestation that indicates that they have read and understand such Code of Ethics. In conjunction with this attestation, all covered persons are required to report any violation or potential violation of which they might become aware. A copy of the Fiduciary Code of Ethics will be provided to any client or prospective client who mails a written request to: Citigroup Global Markets Inc. 388 Greenwich Street, 29th Floor New York, NY 10013 Attention: Robert Cole, Global Head of Wealth Independent Compliance Risk Management Participation and Interest in Client Transactions CGMI and its affiliates from time to time recommend securities in which they directly or indirectly have a financial interest and may buy and sell securities that are recommended to clients for purchase and sale. They also may provide advice and take action in the performance of their duties to clients which differs from advice given, or the timing and nature of action taken, for other clients’ accounts. Moreover, CGMI or any of its affiliates may advise

or take action for itself or themselves differently than for clients. In addition, CGMI, its affiliates, and employees, may invest with any investment manager. Citigroup and certain of its affiliates manage a number of affiliated funds and investment products for their own account that may invest in Alternative Investments. CGMI or its affiliates may, from time to time, act as principal for their own accounts in connection with a Fund of Funds’ or Co-Investment Fund’s securities transactions. CGMI or its affiliates may retain any profits that they may make in such transactions. Subject to applicable law, CGMI or its affiliates may retain any commissions, remuneration or other profits which may be made in such transactions. From time to time, CGMI imposes restrictions to address the potential for self-dealing by CGMI and conflicts of interest that may arise in connection with CGMI’s businesses. CGMI has adopted various procedures to guard against insider trading. However, CGMI personnel are not subject to additional personal trading restrictions, such as extended blackout periods, that are applicable to CGMI employees who are associated with an affiliated manager. Conflicts of Interest Between Citi Ventures and iCapital Citi Ventures, Inc. (“Citi Ventures”), an affiliate of Citigroup, has made a minority equity investment, and owns a non-controlling interest, in iCapital. As a result of this equity investment, Citi Ventures may receive dividends, proceeds and/or other consideration from iCapital, the level of which will vary depending on iCapital’s overall performance. Citi Ventures’ investment creates conflicts of interest. In addition, Citi Ventures’ investment in iCapital creates an incentive for the participating broker-dealers to offer clients funds sponsored, controlled, advised, or contracted with iCapital or its affiliates instead of funds sponsored, controlled, or advised by other asset managers. A representative appointed by Citi Ventures will serve as an observer to the board of directors of iCapital, and in such capacity will receive non-public information about iCapital that it will not be able to share with the participating broker-dealers or its clients. As a result of possessing such non-public information, the participating broker-dealers may be unable to take certain actions for the benefit of their clients that they would be able to take in the absence of such non-public information. The inability to take such actions may be detrimental to the participating brokerdealers and their clients. Secondary Sales of Fund Investments CGMI, subject to applicable law, may, in its sole discretion, seek to sell on the secondary market an Alternative Investment’s interest in any Underlying Funds late in the life of the Alternative Investment in order to facilitate the timely liquidation of the Alternative Investment. There can be no guarantee that any such secondary sales will maximize value of such Underlying Funds in the same manner as if such Underlying Funds were not sold as a secondary sale. Additionally, Alternative Investments may be invested side by side in an Underlying Fund but may have conflicting objectives depending on the investment strategy of the Alternative Investments and where the Alternative Investments are in their life cycles. CGMI may face conflicts of interest with respect to determinations to cause an Alternative Investment to sell an interest in an Underlying Fund and a competing determination to cause another Alternative Investment to retain an interest in the same Underlying Fund. Finally, in the event that a representative of CGMI is a member of an advisory committee of an Underlying Fund in which the Alternative Investments are invested, such representative may face conflicts of interest

with respect to participation in decisions of such advisory committee and managing competing concerns of the Alternative Investments in connection with such decision making. Follow-on Investment Opportunities Investments to finance follow-on acquisitions may be part of the business of certain Alternative Investments. Follow-on investments present conflicts of interest, including determination of the equity component and other terms of the new financing. In addition, the Underlying Funds may participate in releveraging and recapitalization transactions involving portfolio investments in which Alternative Investments have invested or will invest. Recapitalization transactions may present conflicts of interest, including determinations of whether existing investors are being cashed out at a price that is higher or lower than market value and whether new investors are paying too high or too low a price for the company or purchasing securities with terms that are more or less favorable than the prevailing market terms. Investments by Citigroup, Citigroup Clients, Alternative Investments and Employees Under certain circumstances, an Alternative Investment may be offered an opportunity to make an investment in connection with a transaction in which Citigroup, a Citigroup client, another Alternative Investment or an individual at CGMI or its affiliates is expected to participate or in an entity in which Citigroup, a Citigroup client, an Alternative Investment or an individual at CGMI or its affiliates already has made, or concurrently will make, an investment. In connection with such investments, an Alternative Investment (including any Underlying Fund), on the one hand, and Citigroup, a Citigroup client, other Alternative Investment(s) (including any Underlying Fund) or an individual at CGMI or its affiliates, on the other hand, may have conflicting interests and investment objectives, including with respect to the operation of the entity, the targeted returns from the investment and the timeframe for and method of exiting the investment. In addition, the terms of an Alternative Investment’s investment, including the type of security purchased, may be different from the terms of Citigroup’s, a Citigroup client’s, another Alternative Investment’s or an individual at CGMI or its affiliates’ investment. If an Alternative Investment invests in a different type of security from the security purchased by Citigroup, a Citigroup client, another Alternative Investment or an individual at CGMI or its affiliates, additional conflicts may arise, in particular if the entity experiences financial difficulties. If an entity in which Alternative Investments, Citigroup, a Citigroup client or an individual at CGMI or its affiliates hold different classes of securities encounters financial problems, decisions over the terms of any workout will raise conflicts of interest (including conflicts over proposed waivers and amendments to debt covenants). For example, a debt holder may be better served by a liquidation of the entity in which it will be paid in full, whereas an equity holder might prefer a reorganization that could create value for the equity holders. It is possible that Citigroup, a Citigroup client, an Alternative Investment or an individual at CGMI or its affiliates will invest in a company which is or becomes a competitor of an investment of another Alternative Investment (including an Underlying Fund). Such investment could create a conflict between an Alternative Investment (including an Underlying Fund) and Citigroup, such Citigroup client, other Alternative Investments or such individual at CGMI or its affiliates. In such a situation, Citigroup may also have a conflict in the allocation of investment banking resources to the investment. Conflicts will also arise in cases where an Alternative Investment (including an Underlying Fund) makes an equity or other subordinated investment in an entity that has issued or is

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CGMI does not utilize client’s commission dollars to purchase research and other services (i.e., soft dollars). Given the nature of CGMI’s investment management services in respect of the products described in this brochure, which typically do not involve direct investing or selecting brokers, it is not expected that CGMI’s activities in the normal course will involve selecting brokerdealers in respect of its advised funds and accounts. However, a Managed Account, Fund of Funds or Co-Investment Fund may receive in-kind distributions from an Underlying Fund in the form of securities or otherwise and such in-kind distributions may be illiquid or in the form of restricted securities. With respect to such distributions, CGMI may have the discretion to sell such securities and distribute the cash proceeds, distribute such securities in-kind or offer an Alternative Investment’s investors the option, subject to CGMI’s consent, either to receive the securities in-kind or have the Alternative Investment sell them and distribute the cash proceeds. To the extent CGMI engages in services which require selecting broker-dealers, CGMI generally is not limited in its authority to select broker-dealers for trade execution. CGMI generally considers it appropriate (unless there are relevant factors such as customer direction or legal requirements or policy decisions to the contrary) to use the execution services of affiliated broker-dealers for the purchase and sale of such securities for investment advisory clients. CGMI’s affiliates will receive compensation in connection therewith. As discussed below in connection with unaffiliated broker-dealers, in light of all of the factors bearing upon the execution services provided by CGMI’s affiliated broker-dealers, the commissions charged may exceed those that other broker-dealers may charge. Any such transactions will be executed by CGMI’s affiliated broker-dealers only to the extent permitted by, and in compliance with, applicable law and regulations, including Section 11(a) of the Securities Exchange Act of 1934. In selecting an unaffiliated broker-dealer for trade execution, CGMI uses its best judgment to select a broker-dealer that provides prompt and reliable execution at favorable securities prices and reasonable commission rates. Ordinarily, the best net price, giving effect to brokerage commissions and other costs, is the determining factor, but a number of other factors also may enter into the decision. These factors may include: the nature of the security being traded; the size and complexity of the transaction; the desired timing of the transaction; the existing and expected activity in the market for particular securities; confidentiality; and the execution, clearance, and settlement capabilities and financial condition and other relevant and appropriate services of the broker-dealer. CGMI does not intend to aggregate the securities to be sold or purchased with respect to the Funds of Funds, Co-Investment Funds or the Managed Accounts.

CPA, Citibank, N.A. and other affiliates may act as placement agents for securities issued by vehicles or accounts managed by CGMI and will receive fees in respect of such activities. See Item 10 “Compensation from Portfolio Managers” for a discussion of the servicing fees that affiliates of CGMI may receive from certain Portfolio Managers.

Below are summaries of certain legal and disciplinary events that may be material to clients and prospective clients. Additional information about legal and disciplinary events is available in Item 11 of our Form ADV, Part 1A, available at www.adviserinfo.sec.gov. SEC Claims Related to CitiFX Alpha Sold to MSSB Clients On January 24, 2017, CGMI entered into a settlement with the SEC related to a foreign exchange trading program known as “CitiFX Alpha,” which was sold to certain brokerage customers and advisory clients of Morgan Stanley Smith Barney LLC (“MSSB”) during 2010 and 2011. At the time, CGMI held a 49% ownership interest in MSSB. The SEC alleged that CGMI omitted material information from investor presentations, including failure to disclose that a substantially higher leverage could be used than was disclosed and that mark-ups on trades would be charged, that caused the investors to suffer significant losses. Without admitting or denying the findings, CGMI agreed to cease and desist from violating Section 17(a)(2) of the Securities Act and pay disgorgement of $624,458.27, prejudgment interest of $89,277.34, and a civil money penalty of $2,250,000.00.

TRAK Fund Solution Settlements CGMI settled two matters relating to overcharges in certain advisory client accounts. The overcharges related primarily to the TRAK Fund Solution program, which CGMI offered between 1991 and 2011. On January 26, 2017, the SEC issued an Order finding that CGMI violated various provisions of the Investment Advisers Act of 1940 by overcharging or causing to be overcharged approximately 60,000 advisory client accounts in the amount of $18 million and by failing to keep proper books and records with respect to maintenance of client contracts. Those overcharges had, at the time of the Order, been reimbursed with interest, to the extent they could be identified. Pursuant to the Order, CGMI agreed to pay disgorgement and prejudgment interest in the amount of $4,000,000, pay a civil money penalty in the amount of $14,300,000 and undertake certain reporting obligations to the SEC and remedial actions to the extent not already implemented. Copies of the Order can be obtained at www.sec.gov/litigation/admin/2017/34-79882.pdf or from your CGMI representative. On January 12, 2017, the New York Attorney General’s Office (“NYAG”) and CGMI entered into a settlement in which the NYAG found that CGMI had violated the Martin Act and Executive Law § 63(12) by overcharging certain advisory client accounts. CGMI agreed to pay a monetary penalty in the amount of $1,000,000 and undertake certain reporting obligations to the NYAG. FINRA Claims Related to Research Ratings On December 28, 2017, CGMI entered into a settlement with FINRA. As part of that settlement, FINRA alleged that for a period of time, CGMI displayed (both internally and externally) inaccurate research ratings for certain equity securities. FINRA alleged that this inaccuracy, which resulted from errors in the electronic feed of ratings data that the firm provided to its clearing firm, caused CGMI to display the wrong rating for some covered securities (e.g., “buy” instead of “sell”), display ratings for other securities that CGMI was not actively covering at the time, and not display ratings for securities that CGMI, in fact, rated. FINRA also alleged that CGMI failed to establish and maintain a supervisory system and written supervisory procedures designed to ensure the accurate and complete dissemination of research ratings. Without admitting or denying the allegations, CGMI consented to a censure, a fine of $5.5 million, and an undertaking to pay compensation of at least $6 million to customers who were solicited to purchase or sell securities affected by the ratings display issues.

With respect to the Funds of Funds and Co-Investment Funds, CGMI’s clients are the respective Funds of Funds or Co-Investment Funds, not the underlying investors. Subject to the Sub-Advisory Agreement, CGMI will provide either the iCapital Adviser or each Fund of Funds’ or Co-Investment Fund’s governing body with periodic reports from its senior portfolio

managers and/or research analysts concerning such Fund of Funds’ or Co-Investment Fund’s investments and performance. Such reports will be provided at least annually. While the Funds of Funds’ and Co-Investment Funds’ underlying investors are not advisory clients of CGMI and will not receive periodic reports from CGMI as advisory clients, such investors will be provided by the Funds of Funds and Co-Investment Funds with annual audited financial statements of the applicable Funds of Funds or Co-Investment Funds. In addition, investors will receive monthly statements, certain periodic performance reporting (either monthly or quarterly depending on the Funds of Funds or Co-Investment Funds) from the applicable Fund of Funds or Co-Investment Fund that is available to the Fund of Funds’ or Co-Investment Fund’s placement agents and investors can receive such reports upon request. With respect to the Managed Accounts, CGMI’s clients are the holders of the Managed Account. The relevant advisory agreement and related account documentation will specify the reports to be provided to the client, but generally holders of Managed Accounts receive at least a monthly statement. Non-Discretionary Managed Account clients will receive directly any reporting provided by the Underlying Funds in which such accounts invest. Clients will also receive periodic “Client Reviews,” which are statistical reviews and analysis of their Managed Accounts performed by either senior portfolio managers or senior research analysts. CGMI consults with clients on an ongoing basis regarding their investment objectives, risk constraints, and overall goals with respect to their allocations to Alternative Investments. Such consultations consist of a discussion on the various fund strategies that are available and a review of the proposed portfolio, including the rationale for the various selected funds and quantity of the investments in those funds. Generally, absent extraordinary circumstances, CGMI does not intend to review accounts except as otherwise described above or set forth in the particular account documentation.

CGMI will cause the Funds of Funds, Co-Investment Funds and any other Citi fund client to maintain its funds and securities with a qualified custodian, which includes a U.S. bank, an SEC-registered broker-dealer, a CFTC-registered futures commission merchant, and a foreign financial institution that segregates client assets. In addition, each Fund of Funds, Co-Investment Fund or other Citi fund client is required to be audited by an independent auditor (i.e., independent of Citigroup, Inc., as determined by applicable SEC rules and/or regulations) at least annually and to provide audited financial statements to its investors within 120 days (or longer time periods as permitted) after the end of its fiscal year, or the relevant fund custodian will send each such fund investor an account statement at least quarterly showing such fund’s quarter-end positions and NAV, and the Feeder’s, Fund of Funds’ or other fund client’s aggregate account transactions during the quarter. With respect to Managed Accounts, CGMI will be deemed to have custody of a client’s funds and securities in certain circumstances, including if CGMI has possession of those funds or securities or is authorized or permitted to withdraw funds or securities held by the account

custodian by instruction to the custodian. Quarterly account statement procedures will apply to any Managed Account for which CGMI is deemed to have custody. Further, CGMI engages an independent public accountant to perform a surprise audit on an annual basis as required by the Custody Rule. CGMI clients receiving quarterly statements from a broker-dealer, bank, or other qualified custodian should carefully review such statements. In certain cases and/or for certain Managed Accounts, CGMI or its affiliates or service providers also send a client, or a client’s independent representative, a separate quarterly or monthly statement, and CGMI urges the client to carefully review such statements and compare such official custodial records to any account statements that CGMI provides. CGMI’s statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. As discussed above a third-party sub-custodian has been appointed to maintain custody of certain funds and securities.

Funds of Funds and Co-Investment Funds Subject to the terms of the Sub-Advisory Agreements, CGMI has the authority to determine, without obtaining specific client consent, the investments and temporary investments a Fund of Funds or Co-Investment Fund will acquire, subject in each case to the limitations and restrictions described in the Fund of Funds’ or Co-Investment Fund’s account documentation and governing documents. A Fund of Funds or Co-Investment Fund may receive in kind distributions from an Underlying Fund or Co-Investment in the form of securities or otherwise and such in kind distributions may be illiquid or in the form of restricted securities. With respect to such distributions, CGMI may have the discretion to sell such securities and distribute the cash proceeds, distribute such securities in kind or offer the Fund of Funds or Co-Investment Fund investors the option, subject to CGMI’s consent, either to receive the securities in kind or have the Fund of Funds or Co-Investment Fund sell them and distribute the cash proceeds. While CGMI will generally endeavor in such instances to sell or to distribute marketable securities promptly, investors will bear any associated costs or market risks during the disposition process. With respect to a Dedicated Portfolio of a Fund of Funds, the related account documentation will specify any limitations on an Investment Manager’s investment authority. Managed Accounts The relevant advisory agreement and related account documentation will specify the investment authority (including limitations on it) granted to CGMI or its affiliates by the holder of the Managed Account.

In providing investment advisory services to its clients, CGMI generally does not vote proxies with respect to the securities held by the underlying portfolios. Proxies are typically voted by Underlying Fund Managers in accordance with their proxy voting policies. Because CGMI’s products are Managed Accounts, Funds of Funds, and Co-Investment Funds and rarely engage in direct trading of equities, the exercise of proxy voting rights typically involves votes with respect to terms and structure changes governing underlying, third-party funds. In evaluating these proxies, CGMI considers numerous factors relating to each product, which may include how the vote could affect the value of the investment, the liquidity of the

underlying fund in the overall context of the portfolio as well as in comparison to peer fund managers implementing similar strategies. In voting or abstaining from voting a proxy, CGMI will act as it deems is in the best interest of the relevant Alternative Investment, and in accordance with CGMI’s proxy voting policy and subject, where applicable, to the SubAdvisory Agreement. In voting proxies, CGMI is guided by general fiduciary principles. The goal to act prudently, solely in the best interest of the beneficial owners of the accounts and funds it manages. CGMI will attempt to consider all factors that could affect the value of the investment and will vote proxies in the manner that they believe will be consistent with efforts to maximize investor values.

CGMI is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to clients, nor has CGMI been the subject of a bankruptcy petition at any time during the past ten years. Other Information CGMI has adopted an error policy aimed at ensuring the prompt and proper detection, reporting and correction of errors involving the accounts of CGMI clients. A trade error is deemed to have occurred when CGMI has: (i) purchased or sold an incorrect financial instrument in a client account; (ii) purchased or sold an incorrect amount of a financial instrument in a client account; (iii) purchased or sold an unauthorized or client restricted security in a client account; (iv) not entered an order for a client account that should have been entered; (v) entered an order for a client account more than once when it should have been entered once (duplicate trade); (vi) misallocated a trade in one or multiple client accounts; or (vii) made an operational mistake that requires market action to correct. The requirements of the error policy apply to the extent that CGMI and/or its affiliates has control of resolving errors for client accounts. Subject to the Sub-Advisory Agreement where applicable, to correct a trading error, CGMI generally effects a trade with a client using an error account in order to place the client in the position the client would have been in if the error had not occurred. CGMI will receive no additional compensation and no other benefits from such trade. For all Programs, gains from trading errors corrected after settlement date are not retained by CGMI and are credited to the client’s account at no expense to the client. Losses arising from pre- or post-settlement error corrections are closed out at no expense to the client. Losses arising from postsettlement error corrections in retirement accounts are credited to the client’s account with interest at the federal tax penalty rate. If an Investment Manager erroneously purchases a particular security for a client account and the error is discovered prior to settlement of the transaction, then, the erroneously purchased security generally will be transferred to a separate CGMI error account at no cost to the client, subject to the terms of the Sub-Advisory Agreement, where applicable. For all Managed Accounts and sub-advised Funds, gains from trading errors attributable to an Investment Manager that are corrected prior to settlement date are credited against Investment Manager losses resulting from errors on a quarterly basis, subject to the terms of the Sub-Advisory Agreement, where applicable. At the end of each quarter, net gains, if any, from trading errors attributable to an Investment Manager that are corrected prior to settlement are remitted as a donation to a charity, subject to the terms of the Sub-Advisory Agreement, where applicable.

The error policy applies with equal force when CGMI acts as investment manager and subadviser, but with respect to the sub-advised Funds, are subject to the terms of the SubAdvisory Agreement.