Crescat Portfolio Management LLC

A. Description of Firm: CPM is a Colorado limited liability company that provides investment advisory services to private investment funds (“Funds”) and separately managed accounts (“SMAs” or “SMA Clients” and together with the Funds “Clients”). Kevin C. Smith, CFA, is the principal owner of CPM, and has been the primary portfolio manager for each of CPM’s private investment funds and SMA strategies since their inception. Mr. Smith started the “Large Cap Long-Only SMA” strategy (defined below) in 1999 and launched the “Long/Short Funds” (defined below) in 2000 (originally a single fund). He formed CPM in 2005 and then launched the “Global Macro Funds” (defined below) in 2006 (originally a single fund), the “Precious Metals SMA” strategy (defined below) in 2019, and the “Precious Metals Funds” (defined below) in 2020. CPM currently advises five master-feeder structures, the Global Macro, Long/Short, Precious Metals, Institutional Commodity, and Institutional Macro Funds. The SMAs advised by CPM are primarily owned by high-net-worth individuals, family offices and retail investors, and generally follow two strategies: (i) large cap long-only (each a “Large Cap Long-Only SMA”); and (ii) precious metals (each a “Precious Metals SMA”). CPM is a wholly owned subsidiary of Crescat Capital LLC and is a global macro asset management firm. CPM and its affiliates each provide a variety of administrative and management services to CPM’s clients. CPM’s affiliates include: Crescat Partners LLC, the general partner of the Global Macro and Precious Metals Funds; Crescat Hedge Partners LLC, the general partner of the Long/Short Funds; Crescat Institutional Commodity Partners LLC, the general partner of the Institutional Commodity Funds; Crescat Institutional Macro Partners LLC, the general partner of the Institutional Macro Funds; and Crescat Capital LLC, the parent company of CPM. B. Description of Advisory Services Offered: CPM serves as the investment manager to the Funds. CPM affiliates typically serve as the general partner or directors of the Funds. The Funds are neither registered under the Securities Act of 1933, as amended, nor registered under the Investment Company Act of 1940, as amended. Accordingly, interests in any Fund are offered exclusively to investors satisfying the applicable eligibility and suitability requirements either in private placement transactions within the United States or in offshore transactions. No offer to sell interest in these Funds (or a solicitation of an offer to purchase interests) is made by the descriptions in this Brochure, nor is this Brochure an offer or agreement to provide advisory services to any person. As described above, CPM advises the following clients: 

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The “Global Macro Funds” are organized as a master-feeder structure comprised of and offered through both onshore and offshore feed Funds. There is no limitation on the duration of the Global Macro Funds. Our Global Macro Hedge Fund is all about capitalizing on big-picture trends and imbalances while hedging risk. Our global themes are enhanced by expert fundamental analysis and stock picking. The “Long/Short Funds” are organized as a mini-master structure comprised of and offered through

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an onshore feeder fund. There is no limitation on the duration of the Long/Short Funds. Investors in the Long/Short Fund value the fund’s strong risk-adjusted returns, achieved with a focus on long and short equities. The Precious Metals Funds are organized as a master-feeder structure comprised of And offered through both onshore and offshore feeder funds. There is no limitation on the duration of the Precious Metals Funds. This fund will devote a substantial allocation of its capital to activist positions in the gold and silver mining industry. Different than our Precious Metals SMA, we accomplish this through negotiated private placement investments in public companies that can come with activist perks such as discounts, warrants, and anti-dilution rights. The Institutional Macro Funds are organized as a master-feeder structure comprised of both onshore and offshore feeder Funds. The Institutional Commodity Funds are organized as a master-feeder structure comprised of both onshore and offshore feeder Funds. The Large Cap Long-Only SMA is a separately managed account strategy offered to retail investors. Crescat’s longest running strategy. Crescat Large Cap is a value oriented, long only, large cap equity separately managed account strategy. The manager can hold a portion of the portfolio in cash and/or precious metals during expected market downturns. The strategy combines Crescat’s macro themes with bottom-up stock picking supported by the firm’s proprietary equity model. The Precious Metals SMA is a separately managed account strategy offered to retail investors. An actively managed portfolio of gold and silver mining stocks to navigate a variety of economic environments. Low correlation to common industry managed fund offerings. We believe the strategy has high long-term return potential with inflation and recession protection.

C. Tailored Investment Advice: CPM does not provide individualized advisory services to SMA Clients and generally limits its investment advice to SMA Clients to the Strategies described above. Divergence between accounts within the Strategies can occur as a result of specific investment restrictions imposed by the Client as agreed upon mutually within each Client’s investment management agreement. These restrictions and individual Client cashflows can result in performance returns that diverge from the applicable Strategy’s composite. CPM serves SMA clients whose objectives are a combination of growth, income, capital preservation, and diversification. CPM’s SMA strategies are typically more suitable to SMA clients whose investment time horizons are more long-term. CPM’s managed strategies may not be suitable for all potential SMA clients, and CPM generally does not tailor its strategy based recommendations to individual SMA client needs. On a limited basis, CPM can work with clients who impose investment restrictions only if they are invested in an SMA strategy. CPM manages the Funds in a manner consistent with the investment strategy described in the Funds’ offering documents. Investment advice is provided directly to the Funds. CPM does not provide specifically tailored advice to investors in the Funds. The Funds or their general partners may enter into agreements (“Side Letters”) with an investor in connection with the investor’s admission to a Fund without approval of any other investor, which would have the effect of establishing rights under or supplementing the terms of the applicable Fund’s limited partnership agreement with respect to such investor in a manner more favorable to such investor than

those applicable to other investors. Such rights or terms in any such side letter can include, without limitation: (i) rights or terms requested or necessary in light of an investor’s particular legal, regulatory, or public policy characteristics; special reporting or notice obligations; (ii) in extremely rare circumstances for warranted cause, reduced performance fees, carried interest or management fees; (iii) waiver of certain confidentiality obligations; and (iv) consent to certain transfers by an investor. D. Description of Wrap Fee Programs: CPM does not participate in wrap fee programs. E. Mix of Client Assets: As of December 31, 2025, CPM manages $536,060,213 of client regulatory assets under management. All assets are managed on a discretionary basis.

A. Basis of Compensation: CPM and its affiliates receive monthly management fees based on assets under management and, if earned, annual performance allocations, defined below, for managing the Funds. Until February 9, 2021, CPM received quarterly management fees paid in advance based on assets under management for managing the Large Cap Long-Only and Precious Metals SMAs. Starting with new accounts on February 9, 2021, CPM began receiving management fees for new Large Cap Long-Only and Precious Metals SMAs monthly in arrears. The payment terms and conditions of management fees and performance allocations available to CPM are detailed in each SMA client’s investment advisory agreement, and in the Funds’ offering memoranda. Private Fund Fees: Where these share classes are made available for any specific Fund, generally CPM is paid a 2% annual management fee from Main Class investors, a 1.5% annual management fee from Institutional (Class 2) investors, and a 1.25% annual management fee from Institutional (Class 1) investors. CPM is also paid an annual performance allocation equal to 20% from Main Class investors, 15% from Institutional (Class 2) investors, and 12.5% from Institutional (Class 1) investors. Current and prospective investors in the Funds should refer to the private placement memorandum or other offering documents of the respective Fund for additional information regarding fees and restrictions. The information contained herein summarizes representative fee arrangements and is qualified in its entirety by such documents. Lockups: Investors in the Global Macro Funds are subject to a 3-year partial lockup on new and additional subscriptions. Investors prior to 2022 are not subject to a lockup. Investors in the Long/Short Funds, prior to 2024, are subject to a 1-year soft lockup and a 2% early redemption fee during the first year of their investment. New investors, as of 2024, are not subject to a lockup. Investors in the Precious Metals Funds are subject to a 3-year partial lockup on new and additional subscriptions. Investors prior to 2022 are not subject to a lockup. Investors in the Precious Metals Funds are subject to a 3-year partial lockup on new and additional subscriptions. Investors in the Precious Metals Funds are subject to a 3-year partial lockup on new and additional subscriptions. With respect to the Funds, for purposes of calculating the management fee, the net asset value of an investor’s capital account is determined before reduction for accrued management fees and performance

allocations, if any. Annual appreciation, for the purpose of calculating the performance allocation means the increase, if any, in an investor’s capital account over the investor’s highest prior capital account balance, adjusted for contributions and withdrawals. The performance allocation is subject to a high- water mark. If an investor has any prior net losses from previous periods, CPM will not receive a performance allocation until such investor is allocated net profits to recoup the net losses. CPM, in its sole discretion, enters into arrangements from time-to-time with certain Fund investors such as side letters that provide favorable terms not offered to other investors, including but not limited to, waiving or reducing minimum investment amounts, management fees and/or performance allocations, and/or waiving or reducing partial lockups and/or early redemption fees. Large Cap Long-Only and Precious Metals SMA Strategies: CPM charges SMA investors a management fee based on the assets in their account. Fees may be negotiated for institutional accounts and other unique circumstances at the discretion of CPM. Beginning February 9, 2021, the fees below apply to new Large Cap Long-Only SMAs, with fees paid monthly in arrears: Portfolio Value

Monthly Rate

Annualized Rate

First $250,000 Next $250,000 Next $500,000 Above $1 million

0.16667% 0.1458% 0.1250% 0.1041%

2.00% 1.75% 1.50% 1.25%

Beginning July 15, 2021, the fees below apply to new Precious Metals SMAs, with fees paid monthly in arrears: Portfolio Value

Monthly Rate

Not Applicable

0.16667%

Annualized Rate 2.00%

Sub-Adviser Services: For accounts where CPM is the sub-advisor, CPM receives a separately negotiated fee for each sub-advised account, payable monthly in arrears or as dictated by the sub-advisory agreement. Fees for services provided as a sub-adviser are specified in the client sub-advisory agreement and are based on a percentage of assets under management. It is understood that such fees may differ from fees charged to other investors depending upon the extent of services provided and the cost of such services. B. Method of Fee Collection: CPM earns a management fee as of the end of each calendar month. If an investor withdraws funds from the Funds, a performance allocation may be paid on net new appreciation at the time of withdrawal. For the SMA strategies, CPM can either deduct or bill management fees based upon the advisory agreement in place between CPM and the SMA client. Management fees and performance- based fees may be waived or reduced for any SMA client or investor, including for investments made by CPM employees, Consultants, Advisors, or family members.

C. Other Fees and Expenses: SMA clients pay other fees and expenses in connection with CPM’s adviser services, including but not limited, to brokerage commissions, transaction costs, and custodial fees. See Item 12 for a description of CPM’s brokerage practices. The Funds each pay costs, liabilities and expenses incurred in connection with the operation and conduct of its business, including, without limitation, brokerage commissions and other transaction fees, errors and omissions (E&O) insurance, directors and officers (D&O) insurance, fidelity bonds, legal, accounting fees, administrative fees, custodial fees, third party valuations, preparation of all reports to investors, expenses of reproducing and mailing reports to investors and any unanticipated and extraordinary expenses (e.g., defense of a lawsuit brought against a Fund by a third party). D. Timing of Fees: On February 9, 2021, CPM began charging new SMA clients management fees monthly in arrears. For pre-February 9, 2021 SMA clients, the timing of fee modifications, if any, are based on the investment advisory agreement between CPM and each SMA client. For SMA clients, fees paid in advance are partially refunded if the investment adviser agreement is terminated. The amount of such refund is determined by the number of days remaining in the billing period. CPM charges management fees to the Funds monthly in arrears. E. CPM Commissions: No supervised person at CPM accepts commissions for the sale of securities or other investment products. Current and prospective investors in the Funds should refer to the private placement memorandum or other offering documents of the respective Fund for additional information regarding fees and restrictions. The information contained herein summarizes representative fee arrangements and is qualified in its entirety by such documents.

A. Methods of Analysis and Investment Strategies: Investing in any of CPM’s Funds or SMA strategies involves risk of loss that clients and investors should be prepared to bear. Global Macro Funds – The Global Macro Funds comprise CPM’s most versatile portfolio strategy with exposure to all of CPM’s macro themes. The strategy invests globally across equities, commodities, fixed income securities and currencies. The strategy employs both long and short positions and may use leverage. Positioning is determined largely by CPM’s proprietary multi-factor macro and fundamental equity quant models, with the goal of identifying and capitalizing on secular trends. Positioning is adjusted on a discretionary basis using CPM’s thematic investment framework. The strategy typically invests across five to ten macro themes at any one time. The Global Macro Funds invest alongside the Precious Metals Funds following the strategy described below as just one of their thematic components. The strategy may invest in private companies expected to go public within a year or two, warrants and Private Investments in Public Equity (PIPEs). Long/Short Funds – The Long/Short Funds follow an equity-only strategy with actively managed long and short positions in equities and options. A primary objective of the strategy is to deliver alpha from long and short stock picking combined with CPM’s macro themes. The strategy may also employ modest leverage. Positioning is determined largely by CPM’s proprietary multi-factor macro and fundamental equity-quant models, and it may be net long or short based on market conditions. Positioning is adjusted on a discretionary basis using CPM’s thematic investment framework. The Long/Short Funds invest alongside the Precious Metals Funds following the strategy described below as just one of their equity thematic components. The strategy may invest in private companies expected to go public within a year or two, warrants and Private Investments in Public Equity (PIPEs). Precious Metals Funds – The Precious Metals Funds follow a friendly activist investment strategy in the precious metals mining industry. The strategy principally invests in companies focused on gold and silver exploration. It may also invest in companies focused on industrial base metal exploration, including copper,

zinc, and nickel. The goal of the strategy is to generate long-term capital appreciation and inflation protection predominantly in the public equity markets. The strategy may also invest in private companies expected to go public within a year or two. Position sizing and rebalancing is further determined on a discretionary basis by CPM’s investment team with the aid of its proprietary exploration and mining model and often following consultation with experts in the mining industry. The strategy may employ short positions and modest leverage with the goal of enhancing overall risk-adjusted returns. The friendly activist investment strategy includes the following components: identifying undervalued companies that control gold, silver or other base metal deposits in viable global mining jurisdictions with potential to be proven out after further exploration and drilling; getting capital directly to those companies to put it to work on making discovery, which sometimes includes CPM subscribing as a lead investor in a PIPE offering (private investment in public entity), which can include shares at a discount to the public market price, warrants and/or future participation rights; attempting to acquire a meaningful stake in those companies at an early stage, sometimes up to 20% or more partially diluted including warrants; providing technical expertise and assistance with the companies’ exploration program, at times advocating for new management, board members or technical experts; and collaborating with existing management and board members to further joint interests of CPM’s clients, the company and pre-existing shareholders. Institutional Macro Funds – The Institutional Macro Funds invest globally across equities, commodities, fixed income securities and currencies. The strategy employs both long and short positions and may use leverage. Positioning is influenced largely by the Investment Manager’s proprietary macro and fundamental equity models, which may also include expert-guided industry-specific models, with the goal of identifying and capitalizing on varying market and economic cycles and trends. Positioning is adjusted on a discretionary basis using the Investment Manager’s thematic investment framework. The strategy typically invests across six to twelve macro themes at any one time, though there are no strict limits on the minimum or maximum number of themes. Institutional Commodity Funds – The Institutional Commodity Funds strategy will typically have a heavy emphasis on commodities and commodity-related industries and individual equities as well as commodity futures. It may employ both long and short positions and may use leverage. Positioning is influenced largely by the Investment Manager’s proprietary multi-factor macro and fundamental equity models, which may also include expert-guided industry-specific models, with the goal of identifying and capitalizing on both cyclical and secular trends. Positioning is adjusted on a discretionary basis guided by the Investment Manager’s models and thematic investment framework. Large Cap Long-Only SMA – The Large Cap SMA is a long-only equity strategy with a focus primarily on the 1,500 largest U.S. exchange-listed stocks and related ETFs. It can also hold a small percentage of non-U.S. exchange listed stocks and small cap stocks that, based on CPM’s analysis, have a high probability of becoming U.S. listed mid and large cap stocks. It does not employ leverage. The Large Cap strategy generally holds between twenty to fifty securities and may hold a significant cash position based on CPM’s overall macro views. Positioning is determined largely by CPM’s proprietary multi-factor macro and fundamental equity-quant models, which identify secular trends and individual opportunities. Positioning may be adjusted on a discretionary basis following both CPM’s macro thematic investment framework and its systematic stock scoring model. Precious Metals SMA – The Precious Metals SMA invests in precious metals mining companies in top

global jurisdictions. The strategy is exploration focused but may also invest in later stage development and production stage miners. The strategy’s objective is to deliver long term capital appreciation and enhanced protection during inflationary and stagflationary environments. It does not employ leverage. Positioning is determined on a discretionary basis often following consultation with experts in the mining industry. CPM’s investment team is responsible for overall position sizing and rebalancing with the aid of CPM’s proprietary exploration and mining model. Use of AI-assisted models – CPM has developed an artificial intelligence based (AI) assisted algorithm designed to help the investment team determine the optimal weights in CPM’s models in order to assist in its quantitative analysis of portfolio and potential portfolio companies. CPMs use of the AI assisted algorithm helps inform investment decisions however, it is one tool among others employed and ultimate discretion regarding all Client trades still resides with the Chief Investment Officer and the investment team. The team has developed this tool using data believed to be accurate and is verified on an ongoing basis. Client or investor sensitive information is not utilized in the implementation or development of this tool. Sub-Advisory Services – CPM or its affiliates act as sub-adviser to other investment advisers. When CPM provides such sub-adviser services, it has no direct relationship with the clients of the investment adviser to which it is providing services. B. Risks of Methods of Analysis: Despite CPM’s methods of analysis, as described in Section 8(A), CPM can miss important considerations in identifying macroeconomic investment themes and in conducting data-driven equity analysis. While CPM can analyze many factors, it cannot know every material fact about the securities it invests in. CPM may develop a strong conviction based on its macro themes and datadriven analysis, and accordingly take a position at a time when the markets do not agree with that position, and it may lose value. There are many factors that drive security prices that may be outside of CPM’s understanding and/or not captured by its investment process. In addition, CPM’s pro-active trading style could negatively impact performance through increased brokerage commissions, other transaction costs, and taxes. Use of technology: CPM relies extensively on computer programs and systems to trade, clear and settle securities transactions, to evaluate certain securities based on real-time trading information, to monitor its portfolio and net capital, and to generate risk management and other reports that are critical to the oversight of client’s activities. The ability of its systems to accommodate an increasing volume of transactions could also constrain CPM’s ability to manage the portfolio. In addition, certain of CPM’s operations interface with or depend on systems operated by third parties, including prime brokers and market counterparties and their respective sub-custodians, and other service providers, and CPM may not be in a position to verify the risks or reliability of such third-party systems. These programs or systems may be subject to certain defects, failures or interruptions, including, but not limited to, those caused by worms, viruses and power failures. Any such defect or failure could have a material adverse effect on CPM and its clients. For example, such failures could cause settlement of trades to fail, lead to inaccurate accounting, recording or processing of trades, and cause inaccurate reports, which may affect CPM’s ability to monitor its investment portfolio and its risks. Trading and investing: With respect to all of CPM’s strategies, the transactions involve significant

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CPM provides investment advisory services to the Funds, high-net-worth individuals, family offices, retail investors, fund of funds, and institutions, including other investment advisers. The minimum investment amounts for the Funds are described in their respective Fund documents, generally the minimum investment is $500,000. The minimum investment amount for the Large Cap-Long Only SMA is $100,000 and for the Precious Metals SMA is $100,000. CPM or its affiliates may waive any such minimums for the Funds or SMAs in their sole discretion.

CPM and its affiliates are entitled to a performance-based fee from the Funds based on their respective net annual appreciation at year-end, if earned. See Item 5A for details regarding these fees. Therefore, CPM faces a potential conflict of interest to execute trades in ways that favor its private investment Funds over its SMA clients. CPM addresses this conflict of interest through its Code (as defined in Item 11) and its trade allocation policy, described below: Trade Allocation Policy

CPM is dedicated to the principle of fair and equitable trade allocation and sequencing. CPM pre-determines where trades will be allocated among clients prior to execution. First, CPM determines if a client’s investment objectives and suitability profile qualify the client for participation in a trade. After that, CPM will block trade and allocate trades to client accounts at the same average price based on the pre–determined order size for each client account whenever block trading is possible and practical considering CPM’s order management systems, trading platforms, brokerage, research, and custodial services. Where both SMA clients and Funds participate in the same investment opportunity, and the Funds are not subscribing through a private placement, CPM alternates the order of block trading between the SMA clients and Funds for each investment. CPM seeks to coordinate and integrate its various systems and services efficiently and in the best interests of its clients with respect to its fiduciary duty to seek best execution. CPM employees subscribing in a private placement alongside

CPM’s Funds may not acquire securities on terms more favorable than those provided to CPM’s Funds, or if the employee’s purchase would reduce the number of securities available to CPM’s Funds, which the funds otherwise would have purchased.

A. Broker-Dealer Registration: Neither CPM nor its affiliates or management persons are registered, or have an application pending to register, as a broker-dealer or as a registered representative of a brokerdealer. Relationships with Related Persons: CPM’s affiliates include: Crescat Partners LLC, the general partner of the Global Macro and Precious Metals Funds; Crescat Hedge Partners LLC, the general partner of the Long/Short Funds; Crescat Institutional Commodity Partners, the general partner of the Institutional Commodity Funds; Crescat Institutional Macro Partners LLC, the general partner of the Institutional Macro Funds; and Crescat Capital LLC, the parent company of CPM. B. Conflicts of Interests with Other Advisers: CPM does not recommend or select other investment

advisers or receive any compensation from other advisers in any way that creates a material conflict of interest. CPM may have sub-adviser agreements under which it receives compensation from other investment advisers and/or their clients. CPM believes that such sub-adviser agreements do not present a conflict of interest with CPM’s clients.

A. Code of Ethics: CPM’s Code of Ethics (the “Code”), based on Rule 204A-1 under the Investment Advisers Act of 1940, is important in setting and maintaining a strong compliance culture at CPM. The purpose of the Code is to deter wrongdoing, promote honest and ethical conduct, and to require prompt internal reporting of violations of the Code. The Code emphasizes CPM’s fiduciary duty to act in the best interests of its clients. The Code also defines CPM’s policies that forbid trading on material non-public information, managing conflicts of interest associated with personal securities transactions, and maintaining the privacy of client confidential information. The Code requires initial, quarterly, and annual reporting by CPM access persons. CPM will provide the Code to any client or prospective client upon request by contacting CPM at: Crescat Portfolio Management LLC 44 Cook Street, Suite 100 Denver, CO 80206 Telephone: 303-271-9997 Facsimile: 303-271-9998 Email: info@crescat.net B. Personal Investments: CPM employees and related persons are allowed to purchase covered securities held by CPM client accounts for their personal accounts. CPM’s Code requires all Access Persons to put the interests of all CPM Clients above their own, including where they are considering their own personal securities transactions. The Code details pre-clearance requirements for CPM Access Persons and generally requires CPM Access Persons who want to purchase covered securities held by CPM client accounts to obtain pre-clearance from the Chief Compliance Officer or their designee. The Code requires Access Persons to take certain steps to ensure Client interests are put first, this will typically include Access Persons trade after CPM Clients or, in the case of private placements, on substantially similar terms to CPM’s Clients. In addition, under the Code, CPM maintains a “restricted list” of companies about which CPM (or its Access Persons) may have acquired material, non-public information. Access Persons are prohibited from effecting trading in securities of issuers on the restricted list while they are on the restricted list. C. Cross Trades: From time to time, CPM cross-trades securities held by CPM’s private investment funds and SMAs, primarily for account rebalancing purposes and to liquidate terminating SMAs. Generally, CPM does not anticipate entering into principal transactions with its clients. In the event CPM engages in such transactions, it would do so in compliance with the requirements of Section 206(3) of the Advisers Act. For any cross-trade, CPM has a fiduciary obligation to ensure “best execution” for each client. Although there is no single objective standard that constitutes best execution, the SEC has described it as a

duty to execute various transactions for clients in such a way that the clients’ costs or proceeds in each transaction are the most favorable under the circumstances. To achieve “best execution”, for publicly traded securities, CPM generally uses the mid-point price on the primary exchange at the time of execution if during market hours, or the opening or closing price on the primary exchange if before or after market hours. CPM determines the fair valuation for private companies and may make gains or losses on such trades based on the price at which we buy or sell the company. CPM addresses these conflicts of interest through its Code of Ethics, trade allocation, cross trade, and valuation policies. For SMA clients, a brokerage commission is not charged on cross-trades, however a reasonable transfer fee may be passed through to the client by a third-party broker directly to defray its costs. For private funds, a reasonable commission may be charged on cross-trades by a third-party broker. See Item 12 (Brokerage Practices) for a description of CPM’s use of broker dealers, and the soft dollar commission benefits it receives.

A. Factors Considered in Selecting or Recommending Broker Dealers CPM uses several prime brokers, brokers, and custodians. CPM’s custodians hold on deposit CPM’s clients’ and private investment funds’ cash, securities, commodities and other investments in brokerage accounts. Purchases and sales of securities through brokers involve a commission to the broker. Purchases and sales of securities from dealers serving as market makers include the spread between the bid and ask price. In placing securities transactions with brokers, CPM seeks to obtain best execution, which requires CPM to consider the circumstances of each specific transaction. In selecting a broker for each specific transaction, CPM uses its best judgment to choose the broker most capable of providing “best execution.” Brokers are selected based on CPM’s evaluation of the overall value and quality of the services provided by the broker. No one factor controls CPM’s decision. In seeking the best price and execution quality, CPM considers not only the commission rate, spread or other compensation paid, but also the price at which the transaction is executed, bearing in mind that it may be in CPM clients’ best interest to pay a higher commission, spread or other compensation to receive better execution. 1. Research and Client Commission Benefits: CPM receives research and brokerage services in addition to execution services from its broker-dealers and from third parties in connection with client securities transactions: a. When CPM uses client brokerage commissions to obtain research and brokerage services, it receives a benefit because it does not have to produce or pay for that research or those brokerage services directly. b. CPM has an incentive to select or recommend a broker-dealer based upon research and brokerage services rather than selecting a broker-dealer solely based on lowest transaction costs. c. CPM may cause a client to pay commissions higher than those charged by other broker-dealers in return for research and brokerage services CPM deems valuable with respect to the management of its clients’ accounts. d. CPM utilizes soft dollar benefits to service all accounts and does not seek to allocate soft dollar benefits to client accounts proportionately to the soft dollar credits the accounts generate. e. Research refers to services and/or products provided by a broker, the primary use of which must

be to directly assist CPM in its investment decision making process and not in the management of the investment firm. The types of research and brokerage services CPM acquires through client commissions include Bloomberg Professional Service, electronic feeds of trade data, trading platforms, real-time quotes, order management systems, analyst research reports, macroeconomic research newsletters, and other research and brokerage services. Within CPM’s last fiscal year, the types of products and services CPM acquired with its clients’ brokerage commissions included but may not have been limited to Bloomberg LP, TSX Inc., Refinitiv, Energy Equilibrium Solutions, Digeteks quant research, Logix Pharmaceuticals Inc., the New York Stock Exchange, and Options Price Reporting. 2. In the last fiscal year, CPM sought best execution for its clients by directing transactions to brokerdealers where it received the best combination of valuable research and brokerage services, the lowest transaction costs, and the least trading slippage. CPM considers all of the above factors important in its duty to seek best execution for its clients. In selecting or recommending broker-dealers, CPM does not consider whether it receives client referrals from a broker-dealer. 3. CPM does not recommend, request, or require that clients engage in directed brokerage arrangements. CPM selects and retains certain consultants or third-party advisors (referred to here or on our website as either “Consultants” or “Advisors”) to assist CPM on various matters related to the Funds or strategies and its investments, including sourcing investments and conducting due diligence. The Consultants are not employees of CPM. CPM uses client brokerage commissions to pay for all or a portion of their research services. Services provided by the Consultants outside of qualifying research services, used to directly assist CPM in its investment decision making process, are not paid for by Soft Dollars or the Funds. Consultants receive Fund management fee and performance-based fee waivers for these additional services provided. The Consultants are subject to Crescat requirements including the restrictions on CPM employees related to conflicts of interest and Code of Ethics reporting. The involvement of such Consultants may present a number of risks primarily relating to reduced control of the functions that are outsourced and may entail significant third-party expenses, which will be borne by the Funds. Although the use of Consultants and the allocation of soft dollars paid to them subjects CPM and its affiliates to potential conflicts of interest, CPM believes that such potential conflicts are mitigated by the benefits provided by the availability of the Consultants to the Funds. B. Aggregation of the Purchase or Sale of Securities: CPM block trades and allocates trades to client accounts at the same average price based on the predetermined order size for each client account whenever block trading is possible and practical considering CPM’s order management systems, trading platforms, brokerage, research and custodial services. Clients may pay higher fees, including brokerage fees, where CPM is unable to block trade/aggregate. See Item 6 above for full details of CPM’s trade allocation policy.

A. Economic Benefits from Non-Clients: CPM and/or its affiliates may, from time to time, serve on the board of directors or provide consulting services to certain portfolio companies. In exchange for such services, CPM and/or its affiliates may be granted equity interests, warrants, stock options or other rights in the company that receives the services, or may be paid fixed or variable fees by the company. These arrangements could reduce the available cash of a portfolio company, decrease the value of a portfolio company, or result in such service-providing principal of CPM owning an interest in the portfolio company that is senior to, or in conflict with, that of CPM’s clients. In general, outside services provided to a portfolio company by CPM or its affiliates are expected to increase the overall value of the investment in the portfolio company for the benefit of CPM’s clients in a manner that is consistent with CPM’s activist investment objectives, but an increase in value may not always be the result. In addition, access to information at a company where a principal of CPM provides consulting or other outside services could result in that principal, or CPM as a whole, possessing material non-public information, which could restrict CPM’s ability to place certain transactions for its clients, thereby potentially reducing a clients performance. In addition, where a principal of CPM provides consulting and other outside services to a

company, that will reduce the amount of time such principal is able to dedicate to CPM. The compensation received by CPM and/or its affiliates for performing those services will be retained by CPM or the individual and such amounts will not offset the Management Fee or otherwise benefit CPM’s clients. The compensation retained by CPM and/or other personnel in their personal capacities create an incentive for CPM to enter into trades and transactions on behalf of its clients where such opportunities for additional compensation exist. With respect to such outside activities, applicable principals of CPM may give advice, and take action, with respect to any investments, clients or projects that may differ from the advice given, or the timing or nature of action taken, with respect to its clients. Notwithstanding the foregoing, CPM makes investment decisions for, and provides advice to, its clients without regard to whether any employe of CPM receives compensation from a third party for providing consulting, expert or other services. B. Compensation for Client Referrals: CPM provides compensation, in the form of a Fund Management Fee and Incentive fee reduction, to a third party for investor referrals. CPM has adopted policies and procedures designed to address the requirements under the amended Rule 206(4)-1 pertaining to compensated testimonials and endorsements. Such policies and procedures require CPM to have a reasonable basis to believe the person giving the testimonial discloses certain information regarding its relationship with CPM and the terms of its compensation arrangement.

Neither CPM nor anyone in management at CPM have been involved in a legal or disciplinary matter.

A. Periodic SMA Client Account Reviews: CPM invites each SMA client to participate in an account review at least annually. During the account review, CPM validates its clients’ investment objectives, reviews prior year performance, and discusses its investment outlook and macroeconomic investment themes. CPM also invites SMA clients to validate or modify investment objectives annually. Such reviews are generally conducted by a CPM portfolio manager. B. Non-Periodic Client Account Reviews: CPM reviews client accounts for suitability if it learns of a fact or situation which might change either the investment objectives of a client or the suitability of CPM’s strategies for that client. CPM reviews client accounts and adjusts positions, if warranted, when there is a material change in the market environment, its macro-economic themes, and/or its data-driven analytical models, which happens on a non-periodic basis as a normal part of CPM’s ongoing investment process. The Funds’ portfolios are under continuous review with regard to investment policy, the suitability of the investments used to meet policy objectives, cash availability and investment objectives. Additional or more frequent reviews may be triggered by investment performance, changes in market conditions or other nonmarket risk analysis. C. Content and Frequency of Reports: CPM provides monthly written reports with the composite performance for the prior month for the Funds and SMA strategies. In addition, CPM provides a quarterly investment letter including its investment outlook and opinion on the major causes of both positive and negative performance across its strategies. Past quarterly letters can be found on CPM’s website. CPM also provides clients with periodic investment commentary and performance estimates for each strategy.

Written monthly individual account statements are available through CPM’s broker/custodians for SMA clients. For SMA clients with a quarterly fee structure, CPM also sends written individual quarterly reports to each SMA client detailing clients’ fees and holdings. Investors in the Funds receive e-mail notifications when they can download monthly investor statements from CPM’s fund administrator, and also receive annual audited financial statements with 120 days of each private investment funds’ fiscal year-end.

CPM does not maintain physical possession of Fund and SMA client cash and/or securities. The SEC deems CPM and the general partners to have “custody” in several respects:  CPM has the authority and ability to debit its management fees directly from certain SMA clients’ accounts , per the terms of the investment management agreement with each SMA client.  The SEC deems that any general partner of a private investment fund has custody over the Funds by nature of its role for the Funds.  The general partners of the Funds authorize payment of management fees and performance allocations to CPM and to the general partners, per the terms of the applicable offering documents.  The general partners of the Funds authorize payment to third-party service providers from the Funds, per the terms of the applicable offering documents.  The general partners of the Funds authorize distribution of capital from investor accounts to investors upon an investor’s request, or by authority of the general partner, per the terms of the applicable offering documents. To mitigate any potential conflicts of interests due to this arrangement, all client account assets are maintained with an independent, non-affiliated qualified custodian. SMA clients receive quarterly statements from CPM’s custodian and quarterly statements directly from CPM. Investors in the Funds receive e-mailed statements or notifications when they can download monthly investor statements from CPM’s fund administrator, and also receive annual audited financial statements with 120 days of each private investment funds’ fiscal year-end. SMA clients should compare the account statements they receive from their custodians with those they receive from CPM.

CPM has full discretionary authority over the Funds and SMA clients pursuant to investment management agreements. Discretion is exercised in a manner consistent with the investment objectives and strategies described in the confidential offering memorandums for the Funds. This discretionary authority provides CPM with the sole discretion to invest and reinvest the assets of its Funds and SMA clients without prior consultation with the client. This will include, among other things, the authority to select the broker-dealer to be used and the commission rates to be paid for all transactions.

A. Voting Policies and Procedures: CPM does not vote proxies for securities held in SMA client accounts. CPM has authority to vote proxies on behalf of the Funds. CPM generally invests in companies whose managements we believe seek to serve the best interests of their shareholders. Since we have confidence in the managements of the companies in which we invest, we believe that management decisions and recommendations on issues such as proxy voting are likely to be in the shareholders' best interests. A proxy voting policy is maintained and followed to ensure proxies are voted in the best interests of the Fund and address any conflicts of interests that may arise. In rare cases, there could be the appearance of a potential conflict of interest. However, if we knowingly do business with a particular proxy issuer or closely affiliated entity and a material conflict of interest between CPM's interests and our Funds' interest may appear to exist, we generally would, in order to avoid any appearance of a conflict of interest, abstain from voting. B. Client Receipt of Proxy Materials: CPM’s SMA clients receive proxy materials and other solicitations directly from the custodian or transfer agent. Clients may contact CPM at info@crescat.net with any questions. Fund investors may obtain a copy of CPM’s Proxy Voting Policy and Procedure and/or information about how the securities were voted upon request.

A. CPM does not require or solicit prepayment of fees six months or more in advance. B. CPM does not have a financial condition that could impair its ability to meet contractual commitments to its clients. C. CPM has not been the subject of a bankruptcy petition at any time during the past 10 years.