CLOUGH CAPITAL PARTNERS L P

Clough Capital Partners L.P. ("Clough Capital", “we” or “us”) is a SEC-registered investment adviser with its principal place of business located in Boston, Massachusetts. Clough Capital is a limited partnership that began conducting business in 2000. Clough Capital’s principal owner (i.e., those individuals and/or entities controlling 25% or more of the partnership) is Charles I. Clough Jr. Mr. Clough’s interests in Clough Capital are held through his interests in two entities: Clough CGI, LLC and Charles I. Clough Jr. Trust of 2009. PRIVATE FUND PORTFOLIO MANAGEMENT Clough Capital provides investment management services to collective investment funds that are not registered as investment companies (the "Private Funds"). The Private Funds that are managed by Clough Capital include: • • • •

Clough Investment Partners I, L.P. ("Clough I") Clough Investment Partners II, L.P. ("Clough II") Clough Offshore Fund, Ltd. ("Clough Offshore") CCP SPV, L.P. (“CCP SPV”)

The Private Funds are either organized as (i) limited partnerships, where an affiliate of Clough Capital (Clough Associates LLC for Clough I and Clough II and CCP Associates, LLC for CCP SPV) acts as the general partner (each a “General Partner”) and each investor in that Private Fund is a Limited Partner, or (ii) an exempted offshore corporation offering shares to qualified investors, where Clough Capital acts as investment manager. MUTUAL FUND PORTFOLIO MANAGEMENT Clough Capital provides investment management services to the Clough Global Dividend and Income Fund, the Clough Global Equity Fund, and the Clough Global Opportunities Fund (the "Clough CEFs"), as well as to the Clough Select Equity exchange-traded fund (“ETF”) and the Clough Hedged Equity ETF (the “Clough ETFs”), and together with the Closed-End Funds, collectively the “Mutual Funds”). All five Mutual Funds are registered under the Investment Company Act of 1940. Clough Capital serves as the investment advisor to the Mutual Funds and continuously manages the Mutual Fund assets based on the investment goals and objectives as outlined in each Mutual Fund's prospectus. Interested investors should refer to each Mutual Fund's prospectus and statement of additional information ("SAI") for important information regarding objectives, investments, time-horizon, risks, fees, expenses, and additional disclosures. These documents are available on-line at www.cloughcapital.com/cefs for the Clough CEFs and www.cloughcapital.com/etfs for the Clough ETFs. Prior to making any investment in a fund, investors and prospective investors should carefully review these documents for a comprehensive understanding of the terms and conditions applicable for investment in the Mutual Funds.

SEPARATE ACCOUNT PORTFOLIO MANAGEMENT Clough Capital provides continuous asset management of client portfolios based on the individual needs of the client. Through discussions in which goals and objectives based on the client's particular circumstances are established, Clough Capital develops the client's investment guidelines. Clough Capital creates and manages a portfolio based on those guidelines. Clough Capital manages these advisory accounts on a discretionary basis. Account supervision is guided by the client's stated objectives and guidelines (e.g., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients can impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors, or such other investment restrictions as may be agreed between a client and Clough Capital, but in general management of an account is discretionary on the part of Clough Capital. AMOUNT OF MANAGED ASSETS All Clough Capital’s client accounts are managed on a discretionary basis. As of December 31, 2025, Clough Capital was managing approximately $1,435,052,530 of client assets.

Each Private Fund typically pays Clough Capital a fixed quarterly management fee as of the beginning of each fiscal quarter that ranges from 0.25% to 0.375% (1.00% - 1.50% annualized) of the Private Fund’s beginning net asset value for that quarter. Such fixed management fees payable by the Private Funds are generally not negotiable, although in certain circumstances management fees may be waived or reduced. In addition, each Private Fund also typically pays a performance-based fee or profit allocation of 15% to 20% of the net realized and unrealized capital appreciation in the Private Fund. This performance-based compensation may be waived or reduced by Clough Capital, in its sole discretion, and is waived for certain Limited Partners in a Private Fund. Clough Capital has waived the performance-based compensation for certain affiliates of Clough Capital (the General Partners of the Private Funds), family members of the Principals of the General Partner of the Private Funds, and other entities created for a family member's benefit. The performance-based compensation is charged only on profits in excess of a Private Fund’s previous "high water mark."

MUTUAL FUNDS Clough Capital charges an asset-based fee for Mutual Fund investment management services. The fee arrangement, termination, and refund policies are described in each Mutual Fund's prospectus and SAI. For these services, Clough Capital typically charges annual management fees that range from 0.70% to 1.35% of the average daily total assets or net assets of the Mutual Fund, depending on the type of assets being managed. Fees charged with respect to Mutual Funds are subject to annual review and approval by the Board of Trustees of each Mutual Fund. These fees and expenses are described in each Mutual Fund's prospectus, and clients should review the fees charged by the Mutual Funds and the fees charged by Clough Capital to fully understand the total amount of fees to be paid by the client. SEPARATELY MANAGED ACCOUNTS For separately managed accounts, management fees are normally charged based on a percentage of assets under management. Clough Capital may be paid a management fee in advance at the beginning of each calendar quarter based on an agreed percentage of the market value of the holdings in the separately managed client account as of the beginning of the quarter, or the client may pay the management fee based on an agreed percentage of the market value of the holdings in the separately managed client account quarterly in arrears based on the average of the net asset value as of the last day of each month during such calendar quarter. Management fees are generally billed to the client, not deducted from the client’s account. Clough Capital is also entitled to be paid a performance-based fee as mutually agreed between a separately managed account client and Clough Capital (so long as the client is a "qualified client" under the applicable securities regulations). The performance-based fee is based on an agreed percentage of net realized and unrealized capital appreciation on an annual basis and may be subject to a hurdle or target performance amount that must be reached before the performancebased fee will be paid. In addition, the performance-based fee will be subject to a “highwater” mark such that if the account suffers a net capital loss, no performance-based fee will be charged until the account has recovered that loss. A minimum of $50 million in assets under management is required for separately managed accounts, subject to Clough Capital’s discretion to accept more or less. This account size may be negotiable under certain circumstances. A separately managed client account agreement generally may be canceled at any time, by either party, for any reason upon receipt of written notice. The Investment Management Agreement between the client and Clough Capital will give the specific notice period required, which is generally 30 days. As disclosed above, certain fees are paid in advance of services provided. Upon termination of any separately managed account that pays management fees in advance, any prepaid, unearned fees will be promptly refunded. In calculating a client’s reimbursement of fees, Clough Capital will pro rate the reimbursement according to the number of days remaining in the billing period.

OTHER FEES AND EXPENSES In addition to our advisory fees, our clients are also responsible for the fees and expenses charged by custodians and imposed by broker-dealers, including, but not limited to, any transaction charges imposed by a broker-dealer that effects transactions for the client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this Form ADV for additional information. Our clients will generally also bear all other costs and expenses related to their investments and operations, including, without limitation, brokerage commissions and other transaction costs, clearing and settlement charges, interest and commitment fees on debit balances or borrowings, borrowing charges on securities sold short, stock borrowing fees, proxy solicitation expenses, costs of liability insurance obtained on behalf of a client, initial and variation margin, custodial fees, costs of any litigation or investigation involving client activities, indemnification expenses, consulting expenses, the fees and expenses of professionals providing services to the client, including legal and other professional fees relating to potential and actual investments, audit, accounting, tax and administration, regulatory costs, any issue or transfer taxes chargeable in connection with any securities transactions, any entity level taxes, regulatory filing and license fees, costs of reporting and providing information to investors in such clients (if any), and any extraordinary expenses. A portion of certain client’s operating expenses may be shared with other clients managed by Clough Capital on an equitable basis as determined by Clough Capital, and if permitted pursuant to a client’s applicable governing documents. Not all of Clough Capital’s clients will pay all of the types of expenses and costs listed above, and clients may also pay different expenses not listed above. In each case, reference should be made to each client’s applicable governing documents for further information. More information regarding fees and expenses applicable to the Mutual Funds is also available on the Mutual Funds’ website. See Item 4 for the website for the Mutual Funds.

Clough Capital may use any or all of the following methods of analysis in formulating the investment advice that we use in managing client assets. Clough Capital believes that attractive investment returns can be achieved when key, proprietary insights into industry or economic trends are uncovered by Clough Capital through its fundamental research process before the value of the relevant securities has been impacted by such information. Within this context, the investment process will focus on investing in a limited number of major global investment themes identified by Clough Capital (“Global Thematic”). Investment themes will be generated for both long and short investment opportunities, with an emphasis on the long side. Attractive investment themes will often be influenced by global trends, which make investments in certain industries across more than one geographic market likely. Clough Capital expects that it will generally employ these methods across most of its various clients, including Separately Managed Accounts that follow this investment strategy, taking into account in each case the particular investment objectives of our clients. However, some of our clients’ assets, particularly for exchange-traded funds (“ETFs”) are managed in accordance with alternative methods of analysis that are further described below. Additional information regarding the particular methods of analysis, investment strategies and investment risks associated with investing in each of our client accounts is contained in such clients’ respective offering and/or governing documents. GENERAL – GLOBAL THEMATIC INVESTING Clough Capital, through a fundamental research–driven investment process, will seek to earn superior long-term rates of return for its Global Thematic clients, generally relative to broad equity market indices, such as the S&P 500 Index and the Bloomberg World AllCap Index. Clough Capital invests its clients’ assets primarily in equity and equity-related securities in both US and non–US markets. Clough Capital may also invest its clients’ assets in fixed income securities and other financial instruments, including but not limited to equity and index options, futures, currencies, and commodities. Investments in non– US markets are made primarily through securities that trade on non-US exchanges and through securities that do trade on US exchanges such as exchange traded funds (“ETFs”), Global Depository Receipts (“GDRs”), and American Depository Receipts

(“ADRs”). Along with capital appreciation, capital preservation is an important objective of Clough Capital. Clough Capital may use hedging strategies to seek to provide a degree of protection against market declines, such as shorting individual stocks and using index options and futures. In addition, short positions and put options may also be used to implement independent investment strategies. Clough Capital generally expects to keep accounts in a net long position and will also utilize leverage when deemed appropriate. Clough Capital believes that attractive investment returns can be achieved when key, proprietary insights into industry or economic trends are uncovered by Clough Capital through its fundamental research process before the value of the relevant securities has been impacted by such information. Within this context, the Global Thematic investment process will focus on investing in a limited number of major global investment themes identified by Clough Capital. Industry consolidation, technological change, an emerging shortage of a product or raw material which derives from a period of under–investment, changes in government regulation, or major economic or investment cycles are examples of themes Clough Capital may emphasize in its investment focus. Investment themes will be generated for both long and short investment opportunities, with an emphasis on the long side. Attractive investment themes will often be influenced by global trends, which make investments in certain industries across more than one geographic market likely. Once attractive themes are identified, analyzed and selected, Clough Capital will utilize a “bottom–up” research approach to identify companies it believes are best positioned to benefit from those specific themes. Individual positions will be selected based upon a number of qualitative and quantitative factors which may include, but are not limited to, such factors as a company’s competitive position, quality of company management, quality and visibility of earnings and cash flow, balance sheet strength and relative valuation. Client Accounts managed in accordance with our Global Thematic investing strategies will be actively managed and securities may be bought or sold on a daily basis. Investments may be added to the account if they satisfy value-based criteria or contribute to the account’s risk profiles. Investments may be removed from the accounts if Clough Capital believes that their market value exceeds full value, they add inefficient risk or the initial investment thesis fails. EXCHANGE-TRADED FUNDS (ETFs) The ETFs are actively-managed exchange-traded funds that seek to achieve their investment objective by purchasing securities Clough Capital believes either have • • •

above-average financial characteristics such as return on invested capital, profit margins, debt-to-equity ratio, or revenue and earnings growth as identified in financial statements, relative to the broader equity market; are undervalued based on valuation metrics such as (i) enterprise value to sales, (ii) enterprise value to earnings before interest, taxes, depreciation, and amortization, or (iii) price to earnings ratios; or have higher growth potential as indicated by sales growth, earnings growth, or free cash flow growth.

The Clough ETFs primarily invest in U.S.-listed equity securities and sponsored depositary receipts, including American Depositary Receipts (“ADRs”), European Depositary Receipts (“EDRs”) and Global Depositary Receipts (“GDRs”). The Clough Hedged Equity ETF also enters into short sale transactions. While the ETFs’ equity exposure strategy focuses on investments in U.S. equity securities, the ETFs’ strategies also include investments in companies organized in the U.S. but deriving revenue from international markets, including emerging markets. The ETFs will make investments in emerging markets using U.S.-listed securities of companies domiciled in emerging market countries. The ETFs define emerging markets as countries experiencing rapid economic growth, increasing per capita income, developing financial systems, and potential for high growth. A short sale is a transaction in which the ETF sells a security it does not own, typically in anticipation of a decline in the market price of that security based on an analysis of market expectations, valuation multiples, or the likelihood of a contraction in the stock’s valuation multiple. While the Adviser seeks companies it believes will outperform over a full market cycle (typically 5-11 years), the ETFs may experience higher portfolio turnover in the short term as the ETFs respond to changing market conditions or when Clough Capital identifies new opportunities. Clough Capital seeks to manage the ETFs in a tax-aware manner in order to enhance after tax returns without compromising the duty to maximize risk-adjusted returns. Clough Capital's investment process is built on seeking to identify and capitalize on industry or economic trends that other investors have not yet recognized. Clough Capital believes that it can identify industry or economic trends by analyzing industry and economic related information such as capital flows that affect natural resource scarcity, technological innovations which have the potential to disrupt traditional industries, impacts of demographic shifts, and changes in profit or credit cycles. Clough Capital then interprets the information analyzed to identify emerging patterns or changes in various sectors of the economy and develops a strategy for the ETFs to allocate its capital into investible securities. Clough Capital identifies investible securities through rigorous research, including analysis of public company filings, customer preferences, relevant supply chains, and additional publicly available company information. The investment process focuses on several significant global investment themes identified by the Adviser through its research process. Global investment themes include industry or economic trends that Clough Capital believes will significantly impact multiple sectors or regions of the global economy. Clough Capital believes that the ETFs can invest in companies affected by an attractive global investment theme which it anticipates will result in positive investment returns. For instance, an attractive global investment theme could be the emergence of artificial intelligence (AI) as a transformative technology. When such a theme is identified, Clough Capital then conducts bottom-up research to find specific companies that are wellpositioned to benefit from this trend. In the AI example, this research might uncover potential investments in leading chip designers, manufacturers of specialized AI hardware, cloud computing providers offering AI services, or software companies developing innovative AI applications. This approach allows the ETFs to invest in the global trends identified by selecting individual securities that Clough Capital believes will offer the best potential for positive returns. Individual security positions are selected after an evaluation of various company characteristics, such as an assessment of a company's

market position compared to its competitors, which involve analyzing company specific factors including market share, product differentiation, and brand strength. Clough Capital also evaluates the quality of company management by examining its track record, strategic decisions, and ability to execute business plans effectively. The company selection assessment also includes analyzing a company’s financial performance metrics, reviewing a company’s public statements and interviews, and evaluating a company's reputation within its industry. Clough Capital also analyzes a company's earnings, cash flow, and balance sheet to assess its financial stability and potential for positive investment returns. In addition, Clough Capital evaluates whether a company's market share, profitability and market valuation is justified and likely to persist over time, compared to both its own and peer historical metrics. The evaluation process involves analysis of various financial ratios and metrics, including price-to-earnings, earnings per share, return on equity, and debt-to-equity ratios, to determine if a company's stock price accurately reflects its fundamental value and growth potential. Clough Capital employs a tax-aware approach to managing investments across several dimensions. First, the ETF structure provides inherent tax efficiency through in-kind creation/redemption mechanisms that defer capital gains. Second, a long/short strategy can create natural tax efficiency, as market advances may generate gains in the long positions and corresponding losses in the short positions, while market declines may produce gains in the short positions and offsetting losses in the long positions, allowing these net realized results to partially offset each other and may reduce net taxable gains while maintaining targeted exposure. Finally, Clough Capital employs systematic monthly monitoring of gains and losses to identify offset opportunities, and use of tax-lot accounting to strategically harvest losses when consistent with investment objectives. These tax-aware procedures are intended to enhance after-tax returns without compromising the primary duty to maximize risk-adjusted returns, which Clough Capital believes makes the ETFs suitable for both taxable and tax-advantaged accounts. MATERIAL RISKS - ALL ACCOUNTS Investments in a Clough Capital client account (a “Client Account”) presents potentially significant risks and is not intended as a complete investment program. Investing in securities involves risk of loss that investors should be prepared to bear. The following material risks relate generally to the investment strategy and methods of analysis Clough Capital uses for its clients. Not all of these risks will be equally relevant to each client whose assets we manage at any time, and some may not be applicable or equally relevant to each of Clough Capital’s clients. Each client’s governing documents should also be consulted for additional details on applicable risks. Investment and Trading Risks. An investment in a Client Account involves a high degree of risk, including the risk that the entire amount invested may be lost. Client Accounts will invest in and actively trade securities and other financial instruments using strategies and investment techniques with significant risk characteristics, including risks arising from the volatility of the equity, fixed income, commodity and currency markets, the risks of borrowings and short sales, the leverage associated with trading in the currency and derivatives markets, the potential illiquidity of derivative instruments and the

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Clough Capital provides advisory services to: closed end mutual funds; exchange-traded funds; private funds; and separately managed accounts, which may include private foundations, corporations, state pension plans, and high net-worth individuals.

Account Opening Requirements: Clough Capital Private Funds have minimum investment amount requirements, generally $1-2 million, with lesser amounts accepted subject to the sole discretion of Clough Capital, and investors must meet certain regulatory standards, as described in each Private Fund's Private Placement Memorandum. Mutual Funds managed by Clough Capital generally have minimum investment requirements as well, and these are described in each Mutual Fund's prospectus. A minimum of $50 million of assets under management is generally required for separately managed accounts, subject to Clough Capital’s discretion to accept more or less.

For client accounts that are subject to a performance-based fee or allocation, which are currently the Private Funds and a separately managed account, there is an inherent conflict of interest built into the fee structure since the performance-based compensation may create an incentive for Clough Capital to recommend investments which may be riskier or more speculative than those which would be recommended under a different compensation structure. Because Clough Capital manages accounts that pay performance-based compensation and those that do not, there is an incentive to favor the accounts with performance-based compensation. There is also an inherent conflict of interest between client accounts that pay performance-based compensation and client accounts that do not, since Clough Capital has the ability to earn higher fees from the performance-based compensationpaying accounts. This could give an incentive to place higher performing securities in the accounts that pay performance-based compensation. Clough Capital seeks to mitigate this by requiring the allocation of securities to be done in advance of trade execution so

that trades are not allocated after their performance is known. In addition, for initial public offerings (IPOs) and other limited issues including certain limited availability secondary offerings, which historically have seen large initial gains, Clough Capital generally requires all eligible accounts to have the opportunity to participate in the offering, on a pro rata basis in proportion to the managed assets in such eligible accounts. To the extent possible, investment themes identified as attractive, and the specific security selections within those themes, are considered for all eligible accounts in the same investment strategy and these trades will generally be done pro rata among such eligible accounts. At present, the only accounts for which this pro rata standard applies are the global thematic long/short Private Funds. For the allocation policy for IPOs and limited issue secondary offerings, see IPO and Limited Issue Allocations in Item 12. Among the Clough CEFs, generally trades are done pro rata to total asset size, although from time to time certain funds may be given a different allocation due to cash availability issues, strategy differences, or to compensate for other structural factors (for example, the Clough Global Equity Fund must be at least 80% invested in global equities, so it may receive a larger allocation of an equity security in order to maintain this weighting, and the Clough Global Dividend and Income Fund may invest in income producing securities not held in the other closed-end funds). At times, securities considered as investments for client accounts in the same investment strategy may also be appropriate for client accounts in a different investment strategy managed by Clough Capital, but the portfolio weightings and specific holdings periods for a particular security may not necessarily be the same across accounts in the various investment strategies because of various considerations outlined above, or for other reasons. The portfolio managers, exercising investment discretion and judgment, will be responsible for the determination as to the amount of a particular security to be allocated across a group of accounts in different investment strategies. This allocation must be done in advance of execution. When the same security is traded on the same day for accounts having different investment strategies, whenever possible the order should be combined and the weighted average execution price per broker for that day will be used for all accounts that participate. Trades of the same security for accounts in different investment strategies, however, might not be combined if there is a different trading execution strategy being employed. For example, one portfolio manager may want to trade in the market without regard to a specific price, whereas a second portfolio manager may want to trade at a certain limit price or at VWAP (volume weighted average price) over the course of the day. In those instances, a different average price may result. If two or more brokers or trading facilities are used to trade the same security on the same day using the same trading execution strategy, the allocation percentage amongst the various accounts participating will be approximately the same, unless a valid exception applies and is documented.

Conflicts of Interest Common to all Accounts Clough Capital and affiliated entities, including their members, partners, officers and employees (the “Clough Affiliates”) are subject to several actual and potential conflicts of interests. Clough Capital provides investment management services to Mutual Funds, Private Funds, as well as to Separately Managed Accounts and may in the future provide investment management services to other entities and clients, other collective investment vehicles, registered investment companies and accounts held by single investors, which may or may not utilize investment programs substantially similar to that of the Mutual Funds, Private Funds, and Separately Managed Accounts. By the terms of partnership agreements and investment management agreements, Clough Capital and Clough Affiliates are not restricted from forming additional investment funds, from entering into other investment advisory relationships, or from engaging in other business activities, even though such activities may be in competition with the Private Funds, Mutual Funds, or Separately Managed Accounts, and/or may involve substantial time and resources of Clough Capital or Clough Affiliates. It is anticipated that the Mutual Funds and certain of the Separately Managed Accounts will invest in many of the same securities in which the Private Funds invest. Non-Exclusive Activities. Clough Capital and Clough Affiliates will devote as much of their time to the activities of the Private Funds, Mutual Funds and Separately Managed Accounts as Clough Capital and Clough Affiliates deem necessary and appropriate. These activities could be viewed as creating a conflict of interest in that the time and effort of the members of Clough Capital and Clough Affiliates will not be devoted exclusively to the business of the Private Funds, Mutual Funds and Separately Managed Accounts, but will be allocated between the business of the Private Funds, Mutual Funds and Separately Managed Accounts and other business activities of Clough Capital and Clough Affiliates. Limited Resources. Clough Capital portfolio managers may, and often do, manage accounts for more than one Client Account or type of account, and cannot devote their full time and attention to the management of each single account. Accordingly, Clough Capital portfolio managers may be limited in their ability to identify investment opportunities for each of the accounts that are as attractive as might be the case if Clough Capital were to devote substantially more attention to the management of a single

account. The effects of this potential conflict may be more pronounced where the accounts have different investment strategies. Limited Investment Opportunities. If Clough Capital identifies a limited investment opportunity that may be appropriate for more than one account, the investment opportunity may be allocated among several accounts. This could limit any single account's ability to take full advantage of an investment opportunity that might not be limited if Clough Capital did not provide investment advice to other accounts. Liquidity of investments held across more than one account. If Clough Capital determines that a particular security is appropriate for several accounts but the security is in limited supply or trades with low volume, such holdings may be both difficult to acquire for the several portfolios, as well as difficult to sell, effecting the ability to move into or out of the position at a desired price level or time frame, or for a particular holding period, and such limitations might not be present if only one or only a couple of accounts had invested in that security. Different Investment Strategies. The Client Accounts managed by Clough Capital have differing investment strategies. Clough Capital may give advice or take action with respect to any of the other accounts (including those that have investment objectives and/or investment strategies similar to a Private Fund, Mutual Fund or Separately Managed Account) which may be the same as or differ from the advice given or the timing or nature of any action taken with respect to investments of such Private Fund, Mutual Fund or Separately Managed Account. If Clough Capital determines that an investment opportunity may be appropriate for only some of the accounts or decides that certain of the accounts should take different positions with respect to a particular security, Clough Capital may effect transactions for one or more accounts which may affect the market price of the security or the execution of the transaction, or both, to the detriment or benefit of one or more other accounts. Securities considered as investments for the Private Funds, Mutual Funds or Separately Managed Accounts may also be appropriate for other funds and Client Accounts managed by Clough Capital, including for initial public offerings and other new issues (see IPOs and Limited Issue Allocations in Item 12). It is anticipated that a Private Fund, Mutual Fund or Separately Managed Account and certain other funds and accounts managed by Clough Capital will invest in some or a substantial portion of the same underlying securities. Clough Capital maintains policies and procedures to seek to ensure that the Private Fund, Mutual Fund or Separately Managed Account will be treated fairly over time with respect to such securities. There is no assurance that the Private Fund, Mutual Fund or Separately Managed Account will purchase securities or sell securities at the same time or in the same proportions. Variation in Compensation. A conflict of interest may arise where Clough Capital is compensated differently by different accounts. If certain accounts pay higher management fees or performance-based fees, Clough Capital might be motivated to prefer certain accounts over others. Clough Capital might also be motivated to favor accounts in which they have a greater ownership interest or accounts that are more likely to enhance Clough Capital's performance record or to otherwise benefit Clough Capital.

Selection of Brokers. Clough Capital selects the brokers that execute securities transactions for the Client Accounts that it manages. In addition to executing trades, some brokers provide Clough Capital with research and other services which generally require the payment of higher brokerage fees than might otherwise be available. Clough Capital's decision as to the selection of brokers could yield disproportionate costs and benefits among the accounts that they manage, since the research and other services provided by brokers may be more beneficial to some accounts than to others. Shorting of Securities: In a shorting transaction, a Client Account must borrow the shares to be shorted in order to effectuate the short and pay a borrow rate, which can vary based on a number of factors, including whether the custodian has access to the particular security to be shorted from other accounts under its supervision. Securities that are in demand or thinly traded can require a higher borrow rate. The borrow typically is done with the Client Account’s custodian, but if the Client Account has a different custodian than other Client Accounts, the cost of the borrow can vary between custodians based on each Client Account custodian’s particular access to the security. As a result, Client Accounts can end up paying different borrow rates for the same security to be sold short. Use of Soft Dollars. The use of brokerage commissions to obtain research services may create a conflict of interest between Clough Capital and the Private Fund, Mutual Fund, or Separately Managed Account. This may result in the Private Fund, Mutual Fund, or Separately Managed Account paying higher brokerage commissions than might be paid if transactions were affected through brokers that do not provide such services. To the extent that Clough Capital can acquire these products and services without expending its own resources or at reduced prices, Clough Capital’s use of “soft-dollars” would tend to increase its profitability. In addition, the availability of these non-monetary benefits may influence Clough Capital to select one broker rather than another to perform services for the Private Fund, Mutual Fund or Separately Managed Account. In general, the use of soft dollars to pay for research products or services will fall within the safe harbor created by Section 28(e) of the Securities and Exchange Act of 1934, as amended (see Use of Soft Dollars under Item 12). Sharing of Security Research. Clough Capital will provide certain anonymized research data on a delayed basis with a third-party asset manager in return for a share of the asset manager’s returns generated by the research data provided. Research data includes security names, position sizing, price targets, estimates of the probability of achieving targets, estimates of potential returns, and research on current and future investment ideas. In return, Clough Capital will be eligible for compensation from the third-party asset manager, including performance fee payments, trade market impact payments, and research credits to be applied toward certain portfolio optimization and risk management software products. This arrangement may create a potential conflict of interest if the thirdparty asset manager trades using the research data in a manner that is disadvantageous to Clough Capital Clients or results in increased competition for limited investment opportunities available to Clough Capital Clients. Clough Capital believes that the anonymization of and the delay in providing the research data helps to mitigate these conflicts, as does the ability for Clough Capital to exclude certain security information through a “black-out” option in the software used to share the information with the third34

party asset manager. The fees and research credits provided to Clough Capital under this arrangement will not reduce or offset any management or other fees payable by Clough Capital Clients. Service on Boards of Directors. Representatives of Clough Capital and/or a Clough Affiliate may serve on the board of directors of one or more private or publicly traded companies, including, but not limited to, companies in which a Private Fund, Mutual Fund or Separately Managed Account may invest. In addition, representatives of Clough Capital and/or a Clough affiliate, as a result of an investment in a private transaction, may be awarded board of directors’ observer rights on behalf of Clough Capital for securities in which Client Accounts may invest. As a result, the Private Fund, Mutual Fund or Separately Managed Account may be restricted from transacting in securities of such issuers. Cross Transactions. If permitted under applicable law, Clough Capital may, on behalf of a Private Fund, Mutual Fund or Separately Managed Account, for liquidity, portfolio rebalancing, trade allocation or other reasons, purchase investments from, sell investments to or enter into agreements with other accounts managed by Clough Capital and its affiliates (i.e., “cross transactions”). The terms of any such cross transactions will be commercially reasonable and will not be materially less favorable to the Private Fund, Mutual Fund or Separately Managed Account than those available in the market. Clough Capital will receive no special fees or other compensation in connection with cross transactions. Expenses incurred in a cross transaction will be allocated equitably in the sole discretion of Clough Capital between the Private Fund, Mutual Fund or Separately Managed Account, and the other accounts that are parties to the cross transaction. Similarly, if a transaction is cancelled, any costs incurred will be allocated equitably in the sole discretion of Clough Capital between the Private Fund, Mutual Fund or Separately Managed Account and the other accounts that are parties to the cross transaction. Personal Securities Trading. Clough Capital and Clough Affiliates may trade in certain securities for their own accounts, including securities that are held by, or may be traded by, Client Accounts, subject to restrictions and reporting requirements as may be required by law or as determined by Clough Capital, and further provided that no transactions may be entered into that would violate federal securities laws. Clough Capital has adopted a Code of Ethics and Professional Conduct (the “Code of Ethics”) to govern the personal securities trading of all partners and employees. See Item 11. Additional Conflicts of Interest - Mutual Funds: Clough Capital previously disclosed in "Advisory Business" (Item 4) and "Fees and Compensation" (Item 5) of this brochure that our firm is the investment adviser to the Clough Global Dividend and Income Fund, the Clough Global Equity Fund, and the Clough Global Opportunities Fund (collectively, the “Clough CEFs”) and the Clough Select Equity ETF and the Clough Hedged Equity ETF (the “Clough ETFs”, and together with the Closed-End Funds, collectively the “Mutual Funds”), all of which are investment companies registered under the Investment Company Act of 1940 (the ICA”). Registration under the ICA means that these Mutual Funds are subject to the various ICA rules and

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Code of Ethics: Clough Capital has adopted a Code of Ethics which sets forth the standards of business conduct that Clough Capital requires of our partners and employees, including compliance with applicable federal securities laws. Clough Capital and our personnel owe a duty of loyalty, fairness and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code of Ethics. Our Code of Ethics includes policies and procedures for the pre-clearance of certain employee personal security transactions, the review of quarterly securities transactions reports, as well as initial and annual securities holdings reports that must be submitted to and reviewed by our CCO. Among other things, our Code of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement) and generally prohibits employee participation in initial public offerings (IPOs). Our Code of Ethics also provides for oversight, enforcement and recordkeeping provisions. Clough Capital's Code of Ethics further includes a policy prohibiting the use of material non-public information. All employees are reminded that to the extent they come into possession of material non-public information, such information may not be used in a personal or professional capacity, and they must report this to the CCO so that the security can be added to the Restricted List as necessary. A copy of our Code of Ethics will be provided upon request to our advisory clients and prospective clients. You may request a copy by email sent to investorrelations@cloughcapital.com, or by calling us at 617-204-3400. Clough Capital and employees and certain related individuals are prohibited from engaging in principal transactions (buying or selling of securities to or from clients from our own accounts). Our Code of Ethics is designed to seek to ensure that the personal securities transactions, activities and interests of our employees will not interfere with (i) making decisions in the

best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Personal Trading: Except as otherwise provided below, Clough Capital and/or individuals associated with Clough Capital may buy or sell for their personal accounts securities identical to or different from those recommended to our clients. In addition, employees and certain related individuals may have an interest or position in a certain security(ies) which may also be recommended to a client. Clough Capital partners and employees that are portfolio managers or research analysts may not purchase or short individual equity securities of issuers that have a market-capitalization of less than $2 billion (as of the issuer’s most recent quarterly report), but may sell or cover shares of previously held individual equity securities, subject to pre-clearance review and holding period requirements. As these situations represent actual or potential conflicts of interest to our clients, Clough Capital has established the following policies and procedures for implementing our firm’s Code of Ethics, to ensure Clough Capital complies with its regulatory obligations and provides our clients and potential clients with full and fair disclosure of such conflicts of interest: 1. No partner or employee of Clough Capital may put his or her own interest above the interest of an advisory client. 2. No partner or employee of Clough Capital may buy or sell securities for their personal portfolio(s) where their decision is a result of information received as a result of his or her employment unless the information is also available to the investing public. 3. It is the policy of Clough Capital that no person employed by us may purchase or sell any security (with certain exceptions) within 7 days of a transaction(s) being implemented for an advisory account. This prevents such employees from benefiting from transactions placed on behalf of advisory accounts. 4. Clough Capital requires prior approval for any private placement investments by partners or employees. IPO purchases by partners and employees are generally prohibited. 5. All of our partners and employees must act in accordance with all applicable federal and state laws and regulations governing registered investment advisory practices. 6. Clough Capital requires delivery and acknowledgement of the Code of Ethics by each partner and employee of Clough Capital, upon initial employment and annually thereafter. 7. Clough Capital has established policies requiring the reporting of Code of Ethics violations to our CCO. Participation or Interest in Client Transactions: If a client with a separately managed account invests a portion of that account’s assets in one of the Private Funds, then no additional account management fee is paid on the portion of assets in the Private Fund, but rather, the normal management and performance-based fees of the Private Fund are charged on those assets.

The Private Funds are not required to register as investment companies under the Investment Company Act of 1940 in reliance upon an exemption available to funds whose securities are not publicly offered. Clough Capital manages the Private Funds on a discretionary basis in accordance with the terms and conditions of the Private Funds' offering and organizational documents.

Selection of Broker-Dealers for Client Transactions Clough Capital is provided with written authority from all clients to determine the brokers to use for client transactions and the commission costs that will be charged to our clients for these transactions. In selecting a broker-dealer for a particular transaction for a Client Account, Clough Capital will seek the most advantageous terms reasonably available under the circumstances for an account’s transactions (i.e. best execution). Price alone is not the determinative factor, but is considered along with the broker’s execution capabilities, financial responsibility, responsiveness, and market information and research services provided. Clough Capital will consider certain factors which may include the ability of the brokers to affect the transactions, the brokers’ facilities, reliability and financial responsibility and the provision or payment of the costs of brokerage or research products or services. Clough Capital need not solicit competitive bids and does not have an obligation to seek the lowest commission cost available. Accordingly, if Clough Capital determines in good faith that the commissions charged by a broker are reasonable in relation to the value of the brokerage and research products or services provided by such broker to the Client Account or Clough Capital, the Client Account will generally pay commissions to such broker in an amount greater than the amount another broker might charge. Use of Soft Dollars Research products or services provided to Clough Capital include general economic, political, business and market information, industry and company reviews, evaluations of securities and portfolio strategies and transactions, proxy voting data and analysis, technical analysis of various aspects of the securities markets, recommendations as to the purchase and sale of securities and other portfolio transactions, financial, industry, and trade publications, news and information services, pricing and quotation services, and other research services. Any particular research services obtained through a brokerdealer may be used by Clough Capital in connection with Client Accounts other than those accounts that pay commission to such broker-dealer. Any such research services may be broadly useful and of value to Clough Capital in rendering investment advisory services to all or a significant portion of its clients, or may be relevant and useful for the management of only one client’s account or a few clients’ accounts, or may be useful for the management of merely a segment of certain clients’ accounts, regardless of whether any such account or accounts paid commissions to the broker-dealer through which such

research services was obtained. Advisory fees are not reduced because Clough Capital receives such services. Clough Capital evaluates the nature and quality of the various research services obtained through broker-dealer firms and attempts to allocate sufficient portfolio security transactions to such firms to ensure the continued receipt of research services which Clough Capital believes are useful or of value to it in rendering investment advisory services to its clients. The use of commissions or “soft dollars” to pay for research products or services will fall within the safe harbor created by Section 28(e) of the Securities Exchange Act of 1934, as amended. Under Section 28(e), research obtained with soft dollars generated by a Client Accounts may be used by Clough Capital to service accounts other than such Client Account. Where a product or service obtained with soft dollars provides both research and non-research assistance to Clough Capital, Clough Capital will make a reasonable allocation of the cost which may be paid for with soft dollars. Non-permitted uses based on this allocation will be paid for by Clough Capital with hard dollars. It is anticipated that any use by Clough Capital of soft dollars to pay for research products or services will fall within the safe harbor created by Section 28(e) of the Exchange Act. A Client Account’s securities transactions can be expected to generate brokerage commissions and other compensation, all of which such Client Account, not Clough Capital, will be obligated to pay. Clough Capital will have complete discretion in deciding what brokers and dealers a Client Account will use and in negotiating the rates of compensation the Client Account will pay. In addition to using brokers as “agents” and paying commissions, a Client Account may buy or sell securities directly from or to dealers acting as principals at prices that include markups or markdowns, and may buy securities from underwriters or dealers in public offerings at prices that include compensation to the underwriters and dealers. In some situations, payment for the provision of research or trade ideas by a broker-dealer is included in the overall commission rate charged by the broker-dealer. This "bundled" commission rate is an informal soft dollar arrangement and Clough Capital makes no attempt to separate the cost of the research and the cost of trade execution, but rather considers the range of the broker's services as described above to determine if best execution has been achieved. Clough Capital does, however, attempt to ensure that the services received in these informal arrangements are eligible for soft dollar treatment and that the values of such services are comparable to the commission dollars expended upon them. In other situations, however, a more formal understanding is made and a specific per share rate for trade execution and for soft dollar provision is assigned. These agreements in which a broker provides products or services in exchange for executing brokerage transactions through that broker is referred to as a soft dollar arrangement. Clients should consider that these arrangements may create a potential conflict of interest between Clough Capital and its clients. This conflict of interest may exist because Clough Capital's decision to use a particular broker may be based in part on that broker's ability and/or willingness to provide certain products or services to Clough Capital. Products and services acquired with client brokerage commissions within the last fiscal year included the following: research newsletters; credit research; access to on-line research/information portals; access to meetings with company senior managements; invitations to meetings with industry analysts; attendance at industry conventions,

webinars, and other information sessions; research analysis of short sales opportunities; financial data & other security fundamentals; research services concerning regulatory filings; market industry/trends information; bankruptcy/reorganization research; quantitative-based research; daily technical research letters; online news & reports; macroeconomic research & forecasting; proprietary brokerage research; access to software platforms to conduct our own research; securities pricing services related to trading of securities; trade order management software and trading capabilities; electronic utilities to communicate trade and order fill details. Brokers sometimes suggest a level of business they would like to receive in return for the various services they provide. Actual brokerage business received by any broker may be less than these suggested allocations, but can (and often does) exceed the suggestions, because total brokerage is allocated based on the considerations described above. A broker is not excluded from receiving business merely because it has not been identified as providing research services. Aggregation of Client Trades Clough Capital will aggregate trades where possible and when advantageous to clients. This aggregation of trades permits the trading of aggregate blocks of securities composed of assets from multiple Client Accounts, so long as transaction costs are shared equally and on a pro-rata basis between all accounts included in any such block. If two or more brokers or trading facilities are used to trade the same security on the same day, the allocation percentage amongst the various accounts participating should generally be the same. Block trading generally allows us to execute equity trades in a timelier, more equitable manner, at an average share price. Clough Capital will typically aggregate trades among clients whose accounts can be traded at a given broker, and generally may split the trade between two or more brokers or trading facilities on any particular day. Clough Capital's block trading policy and procedures are as follows: 1. Transactions for any Client Account may not be aggregated for execution if the practice is prohibited by or inconsistent with the client's advisory agreement with Clough Capital, or our firm's order allocation policy. 2. The portfolio manager must determine that the purchase or sale of the particular security involved is appropriate for the client and consistent with the client's investment objectives and with any investment guidelines or restrictions applicable to the client's account. 3. The portfolio manager must reasonably believe that the order aggregation will benefit, and will enable Clough Capital to seek best execution for each client participating in the aggregated order. This requires a good faith judgment at the time the order is placed for the execution. It does not mean that the determination made in advance of the transaction must always prove to have been correct in the light of a "20-20 hindsight" perspective. Best execution includes the duty to seek the best quality of execution, as well as the best net price.

4. Prior to entry of an aggregated order, an order ticket must be completed in our trade order management system, which identifies each Client Account participating in the order and the proposed allocation of the order, upon completion, to those clients. 5. If the order cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated pro rata among the participating Client Accounts in accordance with the initial order ticket or other written statement of allocation. However, adjustments to this pro rata allocation may be made to participating Client Accounts in accordance with the initial order ticket or other written statement of allocation. Furthermore, adjustments to this pro rata allocation may be made to avoid having odd amounts of shares held in any Client Account, or to avoid excessive ticket charges in smaller accounts. 6. Generally, each client that participates in the aggregated order must do so at the average price for all separate transactions made to fill the order and must share in the commissions on a pro rata basis in proportion to the client's participation. 7. If the order will be allocated in a manner other than that stated in the initial statement of allocation, a written explanation of the change must be provided to and approved by the CCO no later than the morning following the execution of the aggregate trade. 8. Clough Capital's Client Account records separately reflect, for each account in which the aggregated transaction occurred, the securities which are held by, and bought and sold for, that account. 9. Funds and securities for aggregated orders are clearly identified on Clough Capital's records and on the broker-dealers or other intermediaries handling the transactions, by the appropriate account identifiers for each participating client. 10. No client or account will be favored over another. IPO and Limited Issue Allocations It is the policy of Clough Capital to strive to achieve fair and equitable treatment of Client Accounts with respect to the allocation of initial public offerings (IPO’s) and other new issues, as well as for certain secondary offerings. Due to the often limited availability of IPO’s, it is sometimes difficult to secure a complete allocation for all eligible accounts on every issue, so the policy is designed to ensure that over time, each Client Account has been treated fairly and equitably. In general, due to the often limited nature of the IPO market and the opportunity for significant initial gains, to the extent an IPO or other new issue is appropriate for a Client Account, then that account should have an equal opportunity to participate in the purchase of that IPO with other accounts across the various investment strategies, on a pro rata basis based on account size (based on net assets). If a particular IPO may be more appropriate only for a certain account or group of accounts, however, based on investment strategy or related limitations, or if the portfolio manager believes that an eligible account already has a sufficient allocation weighting (industry or geographic) to the sector the IPO represents so that it should be left out of the allocation or receive a

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In general, Clough Capital does not use solicitors or pay related or non-related persons for referring potential client accounts to Clough Capital. It is Clough Capital’s policy not to accept or allow our related persons to accept anything of value, either directly or indirectly, from broker-dealers or other persons providing services to Clough Capital in exchange for any action being taken by such person on behalf of Clough Capital or any of the Client Accounts or that might otherwise create a conflict of interest or interfere with the impartial discharge of his or her responsibilities to the Client Accounts.

There are no legal or disciplinary events to report that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management.

REVIEWS: Clough Capital periodically reviews and monitors each Private Fund's holdings in accordance with the investment objectives as detailed in its Private Placement Memorandum or other governing documents. In addition, the Private Funds are reviewed on at least a monthly basis by the Clough Capital Investment Review Committee for industry sector allocations, cross-holdings, and other issues relating to trade allocations, exposures, and performance. REPORTS: Investors in Clough I, Clough II, and CCP SPV will receive audited financial statements and K-1 statements, if applicable, within 120 days of the Private Fund's year end. These statements are audited by the Private Funds' auditors, Ernst & Young. Investors in these Private Funds also receive unaudited performance reports monthly during the year. These statements are generated by the Private Funds' administrator, Morgan Stanley Funds Services. Investors in Clough Offshore receive audited annual financial statements and unaudited monthly performance statements as described above. With the exception of CCP SPV, where updates are expected to be less frequent by

nature, Private Fund investors also receive quarterly management commentary letters from Clough Capital. MUTUAL FUND PORTFOLIO MANAGEMENT REVIEWS: Clough Capital periodically reviews and monitors each Mutual Fund's holdings in accordance with the investment objectives as detailed in the Fund Prospectus. In addition, the Mutual Funds are reviewed on at least a monthly basis by the Clough Capital Investment Review Committee for industry sector allocations, cross-holdings, and other issues relating to trade allocations, exposures, and performance. REPORTS: Clients should refer to the Fund Prospectus for information regarding regular reports to the Mutual Fund by Clough Capital, which are generally available on each Mutual Fund's website. See Item 4 for the website for the Mutual Funds. SEPARATELY MANAGED PORTFOLIOS REVIEWS: While the underlying securities within Separately Managed Accounts are periodically monitored, these accounts are reviewed at least quarterly by the Clough Capital Investment Review Committee. Accounts are reviewed in the context of each client's stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. REPORTS: In addition to the monthly statements and confirmations of transactions that Separately Managed Account clients receive from their custodians, Clough Capital provides periodic reports summarizing account performance, balances and holdings.

Clough Capital does not have custody of the assets of Separately Managed Accounts, nor does it have custody of the assets of the Mutual Funds for which it serves as investment advisor. Clients should carefully review the account statements received from their custodians for errors and contact Clough Capital with any questions. For the Private Funds, Clough Capital will seek to ensure compliance with the Advisers Act and the

Custody Rule by ensuring that their cash and securities are held with qualified independent custodians. For the Clough Capital Private Funds, monthly statements are produced and delivered by the Private Funds’ administrator, Morgan Stanley Funds Services, and an annual audit using generally accepted accounting principles (GAAP) is conducted by the Funds’ auditors, Ernst & Young, and the audited financial statements are provided to investors in the Private Funds within 120 days of each Fund’s applicable fiscal year end.

Clients generally hire us to provide discretionary asset management services. In general, Clough Capital is given full investment discretion over client portfolios in the investment management agreement including the Private Funds and Mutual Funds, without obtaining any prior approval from the client. Clients give us discretionary authority when they sign the investment management agreement with Clough Capital, and any limitations or restrictions are listed in the investment guidelines attached as part of the investment management agreement. Clients may change/amend such limitations by once again providing us with written instructions.

Clough Capital will vote proxies for all Client Accounts if given this authority in the investment management agreement. Clough Capital has adopted policies and procedures pursuant to SEC rule 206(4)-6 with respect to voting proxies on behalf of the Private Funds, Mutual Funds, and Separately Managed Accounts. Generally, Clough Capital will vote proxies in the best interests of its clients and in accordance with our established policies and procedures. Clough Capital will retain all proxy voting books and records for the requisite period of time, including a copy of each proxy statement received, a record of each vote cast, a copy of any document created by us that was material to making a decision how to vote proxies, and a copy of each written client request for information on how the adviser voted proxies. In exercising its voting discretion Clough Capital will seek to avoid any direct or indirect conflicts of interest presented by the voting decision. If any substantive matter or foreseeable result of the matter to be voted on presents a conflict or potential conflict of interest involving Clough Capital or an affiliate, or any issuer of a security for which Clough Capital or an affiliate acts as a sponsor, advisor, or manager, or any person with whom Clough Capital or an affiliate has a material contract or business relationship (all considered “Interested Parties”), Clough Capital will make a written disclosure of the conflict to the client indicating how Clough Capital proposes to vote on the matter and the reasons for doing so. If Clough Capital does not receive timely written instructions as to voting or not voting on the matter from the client, Clough Capital may take any of the following actions which it deems to be in the best interests of the client:

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Engage an independent third party to determine whether and how the proxy should be voted and vote that way, or refrain from voting on the matter as determined by the third party;

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Vote on the matter as proposed to the client if the vote is against the interests of Clough Capital or any Interested Party; or

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Refrain from voting on the matter.

Clients may obtain a copy of our complete proxy voting policies and procedures by contacting us by telephone, email, or in writing. Clients may request, in writing, information on how proxies for his/her shares were voted. If any client requests a copy of our complete proxy policies and procedures or how we voted proxies for his/her account(s), we will promptly provide such information to the client.

Clough Capital believes that it is not subject to any financial condition that is reasonably likely to impair its ability to meet contractual commitments to its clients, and Clough Capital has not been the subject of any bankruptcy proceeding.