Cross Ocean Partners Management LP

Cross Ocean Partners Management LP (“Cross Ocean”), a Delaware limited partnership, was formed in 2016 and is located in Greenwich, Connecticut. Cross Ocean provides investment management services on a discretionary basis to privately offered investment funds (each, a “Fund” and collectively, the “Funds”) and managed accounts (“Accounts” and together with the Funds, “Clients”). Affiliates of Cross Ocean serve as general partners of the Funds (each, a “General Partner”). Cross Ocean sub-advises certain of the Funds. Cross Ocean’s investment management services primarily relate to investments in a broad range of credit and hard asset classes, including corporate loans and bonds, liquidations, structured credit, commercial real estate and aviation. With respect to certain Clients, Cross Ocean’s strategy will focus primarily on the “stressed” and “distressed” debt obligations of issuers having a substantive nexus to the United States, although the Clients may opportunistically invest a limited portion of their capital outside the United States. Additionally, certain other Clients’ strategies will focus on stressed and distressed debt obligations of issuers having a substantive nexus to the United States or Europe, and such Clients may opportunistically invest their capital outside of such jurisdictions, and certain of such Clients focus on short term credit market dislocations. The strategy of certain Accounts focuses primarily on stressed and distressed debt obligations of U.S. energy companies, while certain other Accounts’ strategy focuses primarily on rated debt obligations of issuers having a substantive nexus to the United States. Certain Funds Cross Ocean manages focus principally on aviation related investments globally, in particular acquiring commercial aircraft and engines. Certain Funds Cross Ocean manages focus primarily on investments in secondaries limited partnership interest of funds and continuation vehicles as well as direct asset purchases from these types of funds and continuation vehicles. Certain Funds Cross Ocean manages focus primarily on real estate related investments. Although Cross Ocean does not currently do so, Cross Ocean’s investment management or advisory services may relate to other types of investments and asset classes in the future. Cross Ocean provides investment advice to each Client in accordance with the strategy and investment restrictions applicable to that Client as outlined in the applicable investment advisory agreement or offering document for that Client. Investment advice is provided directly to the Clients or, with respect to subadvised Funds, the Fund’s investment manager, according to the pertinent Client’s investment objectives and not individually to the Client investors. The General Partner of a Fund may establish an advisory committee comprised of representatives of selected Fund investors (each, an “L.P. Advisory Committee”). Cross Ocean in the future may also serve as sub-adviser to certain Clients. The principal owners of Cross Ocean are GG Managers LLC, which is wholly owned by Graham Goldsmith, the Chief Executive Officer of Cross Ocean, and various funds managed by Stone Point Capital LLC. Cross Ocean had $6,285,117,946 in regulatory assets under management, of which $6,285,117,946 is discretionary and $0 is non-discretionary. Information with respect to the amount of assets under management is generally provided as of December 31, 2025. This brochure generally includes information about Cross Ocean and its relationships with its Clients and affiliates. While much of this brochure applies to all such Clients and affiliates, certain information included herein applies to specific Clients and affiliates only. This brochure does not contain all of the terms and conditions related to an investment in the Funds or Accounts or all of the risks associated with any such investment, and certain of the information presented herein is in summary form. As a result, prior to any investment in any Fund or Account, all prospective investors should carefully review the offering memorandum for such Fund or Account.

This brochure does not constitute an offer to sell or solicitation of an offer to buy any securities. The securities are generally offered and sold on a private placement basis under exemptions promulgated under the Securities Act of 1933, as amended, and other exemptions of similar import under U.S. state laws and the laws of other jurisdictions where any offering may be made. Investors in Funds or Accounts generally must be both “accredited investors,” as defined in Regulation D, and “qualified purchasers,” as defined in the Investment Company Act of 1940, as amended. Cross Ocean is the discretionary sub-adviser over a portion of Cross Ocean Global SIF (A) L.P.’s and Cross Ocean Global SIF (H) L.P.'s and Cross Ocean Global SIF (H) Co-Invest L.P.’s and Cross Ocean SIF ESS Fund (K) L.P.'s capital commitments; note, however, that for purposes of the disclosure in Item 4 of this brochure, Cross Ocean has included each such fund’s total regulatory assets under management. With respect to Cross Ocean SIF ESS Fund (K) L.P., its investment manager Cross Ocean Adviser LLP (“Cross Ocean Europe”), an SEC exempt reporting adviser affiliate of Cross Ocean, reports information with respect to this private fund in Section 7.B.(1) of Schedule D of its Form ADV. Cross Ocean does not participate in, and is not a sponsor of any wrap fee program.

Compensation received by Cross Ocean and/or an affiliate for investment management services to the Clients is comprised of management fees based on a percentage of assets under management and performance-based fees. The following is a general summary of fees, which will be described in greater detail in the confidential private placement memorandum (“PPM”) of each Fund or the investment management agreement of each Account. Prospective investors and clients should be aware that Cross Ocean’s fees and performance allocation may change over time and that different fees may apply if Cross Ocean adopts new investment strategies. Management Fee Cross Ocean does not maintain a fixed fee schedule for the Clients. Generally, Cross Ocean will receive a management fee (“Management Fee”) from each Client of up to 2.0% per annum of the net asset value of the relevant fund, drawn capital, employed capital, committed capital or any combination of the foregoing. These fees will generally be payable monthly or quarterly in arrears. Other Fees, Management Fee Offset and Fees of Service Companies Cross Ocean or an affiliate may receive transaction, directors’, consulting, advisory, management, monitoring, closing, break-up, servicing, disposition or administration fees and other similar fees from portfolio companies in connection with a Client and its investments and potential investments (“Other Fees”). Although arrangements may vary from Client to Client, as described in the pertinent offering and/or governing agreements for each Client, generally 100% of such Other Fees will be applied to reduce the Management Fee for such quarterly period (net of any unrecouped expenses associated with the Client’s investments). To the extent such offsets would reduce the Management Fee for a given quarterly period below zero, such offsets will be carried forward and reduce future instalments of the Management Fee. With respect to certain Funds, certain Other Fees may not be applied to reduce the Management Fee (such as fees received with respect to securitization vehicles in which such Fund participates, provided that the Fund does not effectively bear any fees attributable to its own capital in any such securitization vehicles). The investment program of certain Funds is expected to include investing in assets subject to fees or profitsharing arrangements payable to servicers of specific assets owned by the Funds (“Service Companies”)

based upon the specialized expertise, systems or other relevant considerations with respect to each Service Company. Services are typically provided pursuant to service or management agreements between the holding companies in which a Fund owns a direct or indirect interest and the Service Companies that can provide for the payment of servicing or other fees. These Fees, which are in addition to the pertinent Management Fees and carried interest distributions, may be determined in accordance with one or more of the following methods: (i) a percentage of the value of the assets being serviced, (ii) a percentage of the equity invested in the assets being serviced, (iii) a percentage of the cash flows from the assets being serviced, (iv) a percentage of the net return from the assets being serviced or (v) a flat fee per asset serviced or service. It is possible that certain Service Companies may receive performance-based compensation, even though the pertinent Funds, as a whole, do not have net capital appreciation. With respect to such Funds, Cross Ocean and/or its affiliates may act as Service Companies and receive compensation from such Funds’ portfolio companies (e.g., securitization vehicles) or third parties, including without limitation management, servicing and disposition fees from third parties in connection with the Funds’ investments. Fees payable to any affiliated Service Companies will typically be structured so that the pertinent Funds do not effectively bear any such amounts with respect to its allocable portion of the applicable investments. This can be accomplished through special allocation of the relevant fees to investors other than the Funds, or if the Funds are subject to such fees payable to Cross Ocean or its affiliates, such amounts (net of related expenses) will be applied to offset the pertinent Management Fees. In the case of transaction fees received by Cross Ocean or an affiliate from any third parties solely as a result of the Funds’ investments, such fees will reduce the Management Fees on a dollar-for-dollar basis. For the avoidance of doubt, the offset shall not apply with respect to any portion of such fees that are not attributable to the Funds or activities that are not on behalf of the Funds (for example, if the Funds co-invest with any other Cross Ocean funder third party co-investors in any investment, the offset will apply solely with respect to a pro rata portion of transaction fees based on the Funds’ participation percentage in the relevant investment). With respect to certain of Cross Ocean’s managed Clients, in respect of certain targeted investments, after the initial investment decision is made by the Client’s investment committee, ongoing monitoring and the authority to make investment decisions on behalf of such Clients may be vested with affiliated investment advisors or sub- advisors of Cross Ocean or an independent board of an underlying offshore special purpose vehicle rather than the investment committee. Performance Allocation Cross Ocean or an affiliate will generally receive a performance allocation or carried interest in accordance with the distribution waterfall of the relevant Client which will, in general, not exceed 20% of all net profits generated by the Client. Certain of Cross Ocean’s Funds are assessed an incentive allocation of up to 20% of net profits allocable to the Fund during a particular performance period (which may be annually or for other periods of time). Such incentive allocation typically is subject to certain preferred returns or hurdle amounts, as well as a loss recovery account or “high water mark.” Other Types of Fees or Expenses Client investors bear indirectly the fees and expenses charged to the Client, which will typically include, but are not limited to: Organizational Expenses The costs and expenses incurred in connection with the organization, structuring and formation of the Clients, including third party advisers, registration and formation costs, and costs and expenses incurred in

connection with marketing the Clients. Operating Expenses The Clients (and, indirectly, Client investors) bear all costs and expenses directly related to the Clients’ investment programs. These typically include expenses attributable to the activities of the Client or Cross Ocean on behalf of the Client. With respect to the pertinent Client, these include, without limitation, fees, costs and expenses:

Incurred in connection with the evaluation, discovery, investigation, development, acquisition, monitoring or disposition of investments (whether or not consummated) of the Client, including fees, costs and expenses relating to accounting, auditing, investment banking, third-party industry and due diligence experts (including for credit and risk analytics, and loss mitigation), finders, originators, consultants (including if dedicated or partially dedicated).

Incurred in connection with the carrying or management of the Client’s investments;

Incurred in implementing or maintaining third party software tools, programs or technology for the benefit of the Client;

Incurred in connection with the incurrence of leverage and indebtedness by the Client;

Incurred in connection with computing the value and attributes of the assets of the Client;

Incurred in connection with the Client’s financial statements, reports, notices and tax returns;

In relation to any and all taxes and other governmental charges incurred or payable by the Client;

Related to the maintenance of registered offices, corporate licensing or similar matters;

Related to the appointment and engagement of independent and non-executive directors acting on behalf of the Client;

Related to the provision of insurance in connection with the activities of the Client;

Incurred to comply with any law or regulation related to the activities of the Client;

Related to the Client’s and Cross Ocean’s regulatory filings (including, without limitation, Forms 13D, 13F, 13G, 13H, PF, ADV and CPO-PQR);

Internal costs and expenses of Cross Ocean and/or its affiliates, including salaries, bonuses and benefit costs of “dedicated” employees, to the extent that the General Partner of the Fund or Investment Manager of the Account determines that such costs are directly attributable to the Client, as applicable, and obtaining the applicable services from internal resources reduces the comparable expenses that the Client would otherwise need to pay third-party service providers; and

With respect to other items as detailed in the pertinent PPM, limited partnership agreement and/or investment management agreement.

Some of the costs and expenses detailed above will be allocable across the Clients. Cross Ocean will allocate these costs generally on a pro rata basis, using a fair and reasonable allocation methodology given the circumstances of such expenses. Please also see “Item 12 – Brokerage Practices” below.

Fees Related to Co-Investments As discussed below, Cross Ocean may permit third parties to co-invest with the Clients and has no obligation to offer such opportunities to Client investors. Cross Ocean or an affiliate may (a) receive carried interest, management fees or other similar fees from any such co-investors with respect to any coinvestment and (b) collect customary fees in connection with actual or contemplated portfolio investments that are the subject of such co-investment arrangements. Any such carried interest, management fees or other similar fees charged to co-investors with respect to any co-investment may differ from those charged to the Clients and will not be considered Other Fees and will not offset the Management Fees. In general, the Clients will bear all out of pocket expenses (including, without limitation, legal and accounting costs and travel expenses) associated with any co-investment opportunity that is unconsummated, including any portion thereof that may or would have been allocated to potential investors had such co-investment been consummated. Notwithstanding the foregoing, Cross Ocean will seek to allocate expenses of such unconsummated investments to investors of the co- investment where it is appropriate and reasonable to do so. Side Letters Subject to applicable law, the pertinent General Partner and Cross Ocean may, in their sole discretion, negotiate and enter into agreements (“side letters”) on behalf of a Fund with certain Fund investors that will result in different terms of an investment in the Fund than the terms applicable to other Fund investors. As a result of such side letters, certain Fund investors may receive additional benefits that other Fund investors will not receive. These side letters may have the effect of establishing, altering or supplementing the terms of the partnership agreement for a particular Fund. The ability of Fund investors to obtain different or more favorable terms in this manner may disadvantage other Fund investors who do not have the benefit of such terms. Except as required by law or as agreed with a Fund investor, in general, neither the pertinent General Partner nor Cross Ocean will be required to notify any or all of the other Fund investors of any such side letters or any of the rights and/or terms or provisions thereof, nor will such General Partner be required to offer such additional and/or different rights and/or terms to any or all of the other Fund investors. Modification of Fund terms pursuant to a side letter may be made in relation to (but not limited to) “most favored nation” provisions, economic arrangements (including management fee, carried interest and hurdle or performance-based allocation rates), co-investment opportunities, the L.P. Advisory Committee, transfers, use of name, prohibited and excused investments, borrowing, confidentiality, notification of investigations, change of control, assignment of right to call capital, limitations of commitment percentage, distribution in specie and other legal and regulatory matters. Additionally, Clients may waive management fees and/or performance- based fees for certain investors in Clients, such as “friends and family” and employee investors. Designated Investments From time to time, certain Funds may be invested, directly or indirectly, through a special purpose vehicle, in assets that are deemed “designated investments,” which may be segregated from the Fund’s main portfolio. Designated investments may be designated as such for, among other reasons, if the investments are expected to be held longer than other investments, they are illiquid, they do not have a readily ascertainable fair value and/or their disposal may be prejudicial to other Clients. The designation may be made prior to or after the investment is made.

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Methods of Analysis and Investment Strategies Cross Ocean is a special situations asset management platform focused on an investment strategy that invests in investment opportunities in a broad range of credit and hard asset classes, including corporate loans and bonds, structured credit, commercial real estate and aviation. With respect to certain Clients, Cross Ocean’s strategy will focus primarily on the “stressed” and “distressed” debt obligations issued by U.S. companies (or, in the case of certain Clients, issuers located

across a broader geographic scope). Additionally, certain other Clients’ strategies will focus on stressed and distressed debt obligations of issuers having a substantive nexus to the United States or Europe, and such Clients may opportunistically invest their capital outside of such jurisdictions. The strategy of certain Accounts focuses primarily on rated debt obligations of such companies, while the strategy of certain other Accounts focuses primarily on stressed and distressed debt obligations of U.S. energy companies. Certain other Funds have been formed to make investments primarily in commercial aircraft, engines, debt and other aviation related investments throughout the globe. Certain other Funds have been formed to invest primarily in secondary limited partnership interests of funds and continuation vehicles and direct asset purchases from these types of funds and continuation vehicles. The Clients’ investments will be made in accordance with Cross Ocean’s strategy (the “Strategy”). There are three core elements to the Strategy:

Value investing: Seeking to purchase assets beneath their intrinsic value, as identified by fundamental research, detailed bottom-up investment analysis and, with respect to hard assets, technical asset evaluation.

Downside protection and capital preservation: Focusing on senior secured loans, aviation assets and other assets which Cross Ocean believes have characteristics that limit downside risk.

Sourcing Strategy: Having a specific sourcing strategy and utilizing dedicated sourcing capabilities where appropriate to seek to identify less competitive situations.

Investment Scenarios Typically, investments are likely to arise out of one, or a combination, of the following situations, without limitation:

Assets being sold by a motivated seller – for example, a non-domestic bank.

Corporate borrowers under some form of stress – either operational or financial.

“Hung” bridge loans and failed syndications – where an underwriter holds a large exposure and typically offers it at a discount.

A short- to medium-term catalyst that is expected to arise which Cross Ocean believes will be value accretive – for example, mergers and acquisitions activity or regulatory changes.

Assets being sold in a portfolio – either at an attractive valuation or, where a rump portfolio can be created, at an attractive valuation by selling off parts of the portfolio.

Liquidation or bankruptcy claims.

Restructured or “stub” equity – created out of a restructuring (frequently offers attractive value as it has no immediate investor base, since, for example, banks may be motivated to sell equity received in a restructuring).

Aircraft or engine backed loans from financial institutions which may lack the resources and/or sophistication to manage vintage assets in distressed, restructuring or repossession situations.

Aircraft asset-backed securitizations liquidating certain assets to meet amortization obligations.

Limited partner interests of funds and continuation vehicles and direct asset purchases from funds and continuation vehicles that are late-life or near-harvest and invested in private credit, special situations credit, natural resources, real estate and infrastructure industries, among others.

Real estate related assets.

Material Risks of Cross Ocean’s Strategies Investing in securities involves risk of loss that Client investors should be prepared to bear. The following is a summary of some of the material risks associated with the strategies expected to account for a significant portion of the Clients’ investments. This summary does not attempt to describe all of the risks associated with an investment in a Client or to provide a complete description of any of the individual risks referenced. Although no summary can fully describe all of the risks associated with such an investment, the pertinent PPM will contain a more complete description of the risks associated with an investment in a particular Client. Not all of the risks summarized below will pertain to any particular Client. No Assurance of Returns or Achieving Investment Objectives: There is no assurance that the Strategy will be able to generate returns for Client investors or that the returns will be commensurate with the risk of investing in the types of assets and transactions described in the pertinent PPM. There can be no assurance that the Strategy’s investment objectives will be met or that investors will receive a return of all their capital contributions. There can be no guarantee that the Strategy will be able to avoid losses. Structure of Investments: Investments made by the Clients may be made through intervening holding companies or other special purpose vehicles in order to minimize applicable taxes or for regulatory or securities reasons. No assurance is given that any particular structure will be suitable for all investors, and, in certain circumstances, such structures may lead to additional costs or reporting obligations for some or all of the investors. In addition, certain tax laws may change or be subject to differing interpretations, possibly with retroactive effect, that may have a negative impact on the Clients. The tax consequences of a particular special purpose vehicle may change after an investment has been made or a special purpose vehicle has been established, with the result that the issuer of investments held by a special purpose vehicle becomes subject to tax. Also, the special purpose vehicles themselves may become liable to tax or be required to withhold tax on payments or distributions to the Clients, or may need to be unwound or restructured, in each case resulting in the Clients’ returns being reduced. Dependence on Key Personnel: The success of the Clients will be highly dependent on the expertise and performance of Cross Ocean’s management team and investment professionals. There can be no assurance that these individuals will continue to be associated with Cross Ocean throughout the life of the Clients. The loss of the services of one or more of these individuals could have a material adverse effect on the performance of the Clients. In addition, although it is anticipated that members of the Cross Ocean team will commit a significant amount of their business efforts to the Clients, they are not required to devote all of their business time to the Clients’ affairs. Certain members of the Cross Ocean team will continue to be involved with the business activities of Cross Ocean affiliates.

Debt Securities: Debt securities, in general, are subject to price volatility due to various factors, including changes in interest rates, market perception of the creditworthiness of the issuer and general market liquidity. In addition to the sensitivity of debt securities to overall interest rate movements, debt securities involve a fundamental credit risk based on the issuer’s ability to make principal and interest payments on the debt it issues. Debt securities may pay fixed, variable or floating rates of interest, may include zero coupon obligations and may be subordinated (and thus exposed to the first level of default risk) or otherwise subject to substantial credit risks. The Clients invest in both investment grade debt securities and non-investment grade debt securities (commonly referred to as “junk bonds”). Non-investment grade debt securities in the lowest rating categories may involve a substantial risk of default or may be in default. The value of such debt typically trades almost entirely on the basis of credit risk rather than interest-rate fluctuations. Illiquid Investments: Cross Ocean expects that many of the Clients’ investments will be highly illiquid. The Clients will invest in non-publicly-traded securities and private debt instruments for which the number of potential purchasers and sellers, if any, is very limited. Typically, the larger the portfolio company in which a Client invests, the fewer the strategic buyers available and the more protracted the Client’s exit strategy is likely to be. The Clients also may invest in other assets and instruments, such as trade and litigation claims, for which there is little or no market. The illiquid nature of the Clients’ positions will make it difficult if not impossible for the Clients to close out unprofitable positions and redeploy capital. Bank Loans and Participations: Cross Ocean intends to invest a portion of the Clients’ assets in bank loans and participations. The special risks associated with these obligations include (i) the possible invalidation of an investment transaction as a fraudulent conveyance under relevant creditors’ rights laws, (ii) so called “lender liability” claims by the issuers of the obligations, (iii) environmental liabilities that may arise with respect to collateral securing the obligations, (iv) adverse consequences resulting from participating in such instruments with other institutions with lower credit quality and (v) limitations on the ability of a Client or Cross Ocean to directly enforce its rights with respect to participations. Cross Ocean will balance the magnitude of these risks against the potential investment gain prior to entering into each such investment. Successful claims by third parties arising from these and other risks, absent bad faith, may be borne by the Client. The Clients do not currently intend for a substantial portion of the respective portfolios to originate, organize or serve as an agent in connection with bank loans and participations. Risk of Portfolio Investments: The Clients may invest in distressed debt investments (e.g., investments in defaulted, out-of-favor or distressed bank loans and securities). Certain of the Clients’ investments will be in specific securities or other instruments of companies that typically are highly leveraged, with significant burdens on cash flow, and therefore involve a high degree of financial risk. The Clients may also make investments in companies that are experiencing financial or operational difficulties or are otherwise out-of-favor. Such companies’ instruments may be considered speculative, and the ability of such companies to pay their debts on schedule could be adversely affected by interest rate movements, changes in the general economic climate or the economic factors affecting a particular industry, or specific developments within such companies. Investments in companies operating in workout or bankruptcy modes also present additional legal risks, including fraudulent conveyance, voidable preference and equitable subordination risks. The Clients may invest in private debt, equity and warrants. These instruments may be acquired with or without registration rights. Unregistered securities are highly illiquid and may not be freely traded.

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Cross Ocean provides investment advice to private investment funds (defined previously as the “Funds”) and separately managed accounts (defined previously as “Accounts”). Investment advice is provided directly to the Clients and not individually to the Client investors.

Currently all Cross Ocean Clients are subject to payment of a performance-based fee, except for specific co-investment vehicles formed for the benefit of certain existing investors. As a result, Cross Ocean does not face the conflicts of interest that may arise when an investment adviser accepts performance-based fees from some clients, but not others. However, to the extent performance-based fees paid by clients may vary, Cross Ocean may have an incentive to favor one client over another. Cross Ocean addresses this possible conflict through its trade allocation policy, in which investment opportunities are allocated among clients according to each client’s investment objectives and in a fair and equitable manner.

Cross Ocean Partners is a special situations asset management platform focused on investment opportunities in a broad range of credit and hard asset classes. Graham Goldsmith is global chief executive officer of the Cross Ocean platform. The platform’s two components are Cross Ocean and its affiliate Cross Ocean Adviser LLP (“Cross Ocean Europe”). Cross Ocean, which is located in the United States, is headed by Mr. Goldsmith. Cross Ocean focuses on debt obligations issued by U.S. and non-U.S. companies and also manages certain Funds that focus on aviation-related investments globally. Cross Ocean Europe, which is headed by Steve Zander, is an investment adviser whose principal office and place of business is located in London, the United Kingdom. Cross Ocean Europe advises privately offered funds that focus on (i) European special situations investing, and (ii) other forms of investment vehicles, including collateralized loan obligation vehicles (“CLOs”). Certain of these funds may invest a limited portion of their capital outside Europe, including in North America. Cross Ocean Europe also sub-advises, with respect to European special situations and other investments, certain Funds managed by Cross Ocean that focus both on stressed and distressed debt obligations of issuers having a substantive nexus to the United States or Europe (“Global Special Situations”). Cross Ocean Europe is also the investment manager to certain Funds that focus on Global Special Situations, for which Cross Ocean Europe is a sub-adviser with respect to U.S. special situations and other investments. Cross Ocean Europe is also the manager of CLO vehicles investing in European income-oriented credit instruments. Cross Ocean Europe reports to the SEC as an exempt reporting adviser. Cross Ocean Europe became fully authorized by the FCA on February 1, 2017. Mr. Goldsmith sits on the investment committee of the funds advised by Cross Ocean Europe. Mr. Zander sits on the investment committee of the Clients advised by Cross Ocean. Each of Cross Ocean USSS GP LP, Cross Ocean USSS II GP LP, Cross Ocean USSS III GP LP Cross Ocean GSS GP LP, Cross Ocean Aviation Fund I GP LP, Cross Ocean GCDF I GP LP and Cross Ocean Global Secondaries I GP LP (the “GPs”), each an affiliate of Cross Ocean, serves as the general partner of Funds currently advised by Cross Ocean. The general partners of each GP have a board of independent directors. In accordance with SEC guidance, Cross Ocean USSS GP LP, Cross Ocean USSS II GP LP, Cross Ocean USSS III GP LP, Cross Ocean GSS GP LP, Cross Ocean GCDF I GP LP, and Cross Ocean Global Secondaries I GP LP will be registered as an investment adviser in reliance on the Form ADV filed by Cross Ocean. Cross Ocean Adviser (Ireland) Limited (“Cross Ocean Ireland”), an affiliate of Cross Ocean, is an investment adviser and servicing entity located in Ireland. Cross Ocean Ireland sub-advises certain Funds that focus on aviation-related investments. Cross Ocean Ireland reports to the SEC as an exempt reporting adviser. Stone Point Capital LLC (“Stone Point”), an SEC registered investment adviser, is the investment manager of certain funds that are indirect owners of Cross Ocean. Stone Point and its advised funds do not participate in the day-to-day management of Cross Ocean.

Participating Affiliates In providing investment advice to its clients, Cross Ocean may use the resources of Cross Ocean Europe and/or Cross Ocean Ireland to provide research, portfolio management, trading and related investment management services (collectively, “Advisory- Related Services”) to Clients. Any such arrangement is subject to a memorandum of understanding (“MOU”) among Cross Ocean, Cross Ocean Europe and Cross Ocean Ireland. Under the MOU, each of Cross Ocean Europe and Cross Ocean Ireland is a participating affiliate, as such term is used in relevant relief granted by the SEC staff. Under the MOU, each of Cross Ocean Europe and Cross Ocean Ireland and any of their personnel providing Advisory-Related Services to or for Clients are considered “persons associated with” Cross Ocean, which has the meaning of the term “person associated with an investment adviser” as defined in Advisers Act Section 202(a)(17). The MOU requires each of Cross Ocean Europe and Cross Ocean Ireland to agree to submit to the jurisdiction of U.S. courts for actions arising under the U.S. securities laws in connection with the Advisory-Related Services provided by Cross Ocean Europe or Cross Ocean Ireland, or any of their personnel, to Clients.

Code of Ethics As a fiduciary, Cross Ocean owes an undivided duty of loyalty to its clients and thus demands the highest standards of ethical conduct and care by all of its principals and employees (referred to herein as “supervised persons”). It is Cross Ocean’s policy that all supervised persons conduct themselves so as to avoid, to the extent possible, not only actual conflicts of interest with clients but any conduct that could give rise to the appearance of a conflict of interest that might compromise the trust placed in Cross Ocean by its clients. Cross Ocean’s policies and procedures have been designed to identify and properly disclose, mitigate and/or eliminate applicable conflicts of interest. Cross Ocean has adopted a Code of Ethics and personal trading policy (together, the “Code of Ethics”) that sets forth standards of ethical and business conduct expected of Cross Ocean’s supervised persons and addresses conflicts that may arise from personal trading by Cross Ocean’s supervised persons. The Code of Ethics, among other things, requires compliance with the federal securities laws, reflects Cross Ocean’s fiduciary responsibilities and those of its advisory personnel, prohibits misuse of material non-public information, prohibits certain personal securities transactions and requires Cross Ocean’s supervised persons to periodically report and/or preclear certain personal securities transactions. The Code of Ethics will be provided to any client or potential client upon request. Personal Trading Cross Ocean’s supervised persons are permitted to invest in their personal trading accounts, subject to certain restrictions. In order to reduce certain conflicts of interest that may arise between client accounts and the personal trading activities of Cross Ocean’s supervised persons, Cross Ocean has adopted a personal trading policy. The personal trading policy, among other things, requires preclearance of certain transactions and reporting of all transactions in and holdings of covered securities. Principal Transactions and Cross Trades It is not generally anticipated that any Client will enter into transactions in which Cross Ocean and/or an affiliate participates or has a significant economic interest. Moreover, while such transactions may occur from time to time, Cross Ocean does not generally anticipate effecting client cross-transactions where Cross Ocean causes a transaction to be effected between any client account advised by Cross Ocean and another

account advised by it or an affiliate, other than with respect to the usage of affiliated securitization vehicles for partial or full exit transactions. However, if Cross Ocean determines it is in the best interests of a Client or other client to enter into any such related party transaction, then, if required, such transaction will be conducted in compliance with the disclosure and consent requirements of Section 206(3) of the Investment Advisers Act of 1940 (the “Advisers Act”), which for certain Funds may entail appointing an independent representative to approve any such principal transaction on behalf of a Client. Cross Ocean must determine that any principal transaction is in the best interest of the participating client. Cross trades must be in the best interest of each participating client and, as pertinent, must be consistent with Cross Ocean’s duty to seek best execution. Cross Ocean is subject to a potential conflict of interest where it makes a determination with respect to both sides of a transaction and intends to manage it through compliance with its relevant policies. Co-Investments Cross Ocean may determine that certain investment opportunities appropriate for the Clients should not or cannot be allocated in their entirety to the Clients based on such factors as the size or composition of the overall Clients’ portfolios, concentration limits or other reasons deemed relevant by Cross Ocean. In such instances, Cross Ocean may (but is not required to) allocate any unallocated portions of such opportunities to one or more investors in a Client or other funds or accounts managed by Cross Ocean or an affiliate, or such other parties as are selected by Cross Ocean. Cross Ocean has no obligation to offer any such coinvestment opportunity to any Client investor, and no Client investor should have any expectation to be offered any such co-investment opportunity, by virtue of its investment in a Client. The PPM for each Fund will contain additional details regarding co-investment practices and policies.

Best Execution Cross Ocean is authorized to select the broker-dealers to be used for portfolio transactions for the Clients. In placing portfolio transactions, Cross Ocean will seek to obtain the best possible execution, taking into account the following factors, as pertinent: price, size of the transaction, conflict and/or market liquidity, time limitations, brokers’ ability to find and provide liquidity and (rarely) in consideration for such brokers’ and dealers’ provision or payment of the costs of research and other services or the property that is of benefit to the Clients and related funds and accounts. Cross Ocean does not need to solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Accordingly, if Cross Ocean determines in good faith that the amount of commissions charged by a broker is reasonable in relation to the value of the brokerage and products or services provided by such broker, a Client may pay commissions to such broker in an amount greater than the amount another broker might charge. Soft Dollar Benefits Cross Ocean will not knowingly make use of any “soft dollar” arrangements. Any such services that Cross Ocean does receive will qualify (in Cross Ocean’s opinion) for the “safe harbor” for “soft dollar” services constituting “bona fide research” established by Section 28(e) of the Securities Exchange Act of 1934. Allocation of Investment Opportunities Cross Ocean’s clients may or may not have investment objectives that are similar or overlap to a greater or lesser extent. Cross Ocean may determine that an investment opportunity is appropriate for one client but not for another or that the allocation to one client should be of a different proportion than that of another client. Investments will be allocated to the Clients, as applicable, pursuant to Cross Ocean’s allocation

policies and procedures then in effect. It is the policy of Cross Ocean to allocate investment opportunities fairly and equitably among its clients, where applicable, to the extent possible over a period of time. As a general matter, investment opportunities will be allocated among those accounts for which participation in the respective opportunity is considered appropriate pro rata based on available capital (taking into account, as applicable, among other factors, net or gross asset value, capital commitments, target hold size, target acquisition size or target sale size) or based on such other methodology as Cross Ocean determines to be appropriate under the circumstances. In addition, Cross Ocean may also consider other factors in making any allocation determinations (which may result in a different allocation of investment and/or sale opportunities), including, among other factors, the proportion of a portfolio dedicated to a particular strategy, any guidelines or restrictions set forth in the pertinent offering and/or governing agreements, the risk-return profile of a proposed investment relative to clients’ current risk profiles, tax consequences and regulatory or contractual restrictions or consequences. However, subject to various conditions set forth in the respective offering and/or governing agreements, certain accounts may have priority with respect to the allocation of certain investment opportunities. Certain accounts managed by Cross Ocean or an affiliate have been, and in the future are expected to be, organized, in whole or in part, to participate in specific investment opportunity sets and receive a primary allocation of such investment opportunities. For example, certain accounts have been designed to have a priority or primary allocation with respect to certain sectors, industries or geographic locations and will be given priority with respect to investment opportunities in those areas. Additional accounts with priority allocations in respect of opportunities may in the future be organized by Cross Ocean or an affiliate. Such other accounts organized with the expectation of receiving a primary allocation of a particular investment opportunity are referred to herein as “Primary Accounts.” In allocating opportunities, an account will be allocated an investment in respect of which a Primary Account has a priority over other accounts only to the extent that the amount of such investment opportunity exceeds the amount of the investment required to be made available or otherwise deemed appropriate for the relevant Primary Accounts. Affiliates of Cross Ocean (“Cross Ocean Affiliates”) are actively engaged in transactions in the same securities, currencies and instruments in which the assets of the Clients may be invested. Cross Ocean Affiliates, subject to applicable law, may purchase or sell securities of, or otherwise invest in or finance, issuers in which the Clients have an interest, and may manage or advise other accounts or investment funds that have investment objectives similar or dissimilar to those of the Clients and which engage in transactions in the same type of securities, currencies and instruments as the Clients. Trading activities of Cross Ocean Affiliates are carried out without reference to positions held directly or indirectly by the Clients and may have an effect on the value of the positions so held or may result in Cross Ocean Affiliates having an interest adverse to that of the Clients. Cross Ocean Affiliates are not under any obligation to share any investment opportunity, idea or strategy with the Clients or a Cross Ocean portfolio manager. As a result, Cross Ocean Affiliates may compete with the Clients for appropriate investment opportunities. It is possible that in the future certain operating units or affiliates of Cross Ocean may have relevant information about certain investments that may or may not be shared with Cross Ocean because of informational walls, confidentiality obligations or other disclosure constraints. Cross Ocean has procedures that outline the process by which Cross Ocean will determine whether to elect to receive or not receive material non-public information, in any given case. This determination will be made on an issuer-by-issuer basis using objective criteria established by Cross Ocean, which may have implications for the services Cross Ocean is able to provide to certain clients in certain situations, including the Clients. Investments in Different Classes of Securities The Clients and any other account managed by Cross Ocean or an affiliate may invest in securities or other instruments of the same issuer (or affiliated group of issuers) having a different seniority in the issuer’s

capital structure. If the issuer becomes insolvent or suffers financial distress, there may be a conflict between the interests of the Clients, on the one hand, and the interests of such other account, on the other, insofar as the issuer may be unable to satisfy the claims of all classes of its creditors and security holders. Under these circumstances it may not be feasible to reconcile the conflicting interests of the Clients and such other account in a way that adequately protects the Clients’ interests. Proprietary Trading Cross Ocean’s portfolio managers may manage other accounts for themselves, other clients and other investment companies, and may have financial incentives to favor certain of such accounts over the Funds. Although such account may not participate in an opportunity that the Funds are actively considering without the consent of the L.P. Advisory Committee if applicable, if such consent is given, such participation may conflict with the Clients’ participation or other clients even though their respective investment objectives may be the same as, or similar to, those of the Clients. Trade Errors In the course of carrying out trading and investing responsibilities on behalf of the Clients, Cross Ocean personnel may make “trading errors” — i.e., errors in executing specific trading instructions. Examples of trading errors include: (i) buying or selling an asset at a price or quantity that is inconsistent with the specific trading instructions generated by a particular strategy; or (ii) buying rather than selling a particular asset (and vice versa). The Cross Ocean trade error policy requires that any error be resolved promptly and fairly. This includes the requirement that any staff member who discovers an error shall promptly inform the Global Chief Financial Officer and Chief Operating Officer (the “Global CFO & COO”), and in their absence shall inform the General Counsel (the “GC”). The GC and/or the Global CFO & COO shall arrange for the reporting of errors in writing to the Enterprise Risk Committee (“ERC”) for consideration at regularly scheduled ERC meetings. The intent of the policy is to restore the Clients to the appropriate financial position considering all relevant circumstances surrounding the error. Cross Ocean’s senior management shall make a final determination as to whether any such error is due to the negligence, willful default or fraud of Cross Ocean or of any staff member of Cross Ocean. Where senior management determines that any such error is due to the negligence, willful default or fraud of Cross Ocean or of any staff member of Cross Ocean, Cross Ocean shall promptly reimburse any net loss resulting from the error to the relevant Client. In other circumstances, the net loss shall be borne by the Client. In the case of errors where there has been or may be an associated gain to any Client, any such gain shall be retained by the Client.

Aqueduct Capital Group, LLC, which has been acquired by Harris Williams Primary Fund Placement LLC, and Jefferies LLC serve as Placement Agent for certain Funds (the “Placement Agent”) and provide compensated endorsements as defined by the amended Advisers Act Rule 206(4)-1 (“Marketing Rule”). Cross Ocean entered into a placement agreement with each of the Placement Agent in connection with the offering of interests in such Funds. Such agreements provided for payments by Cross Ocean or the Funds of placement fees based on Capital Commitments, Management Fees, and/or Performance made to the Funds as well as for the indemnification of such placement agents. Cross Ocean reserves the right to enter into other arrangements with third parties for client or investor referrals, and any such arrangements will comply with the Marketing Rule’s requirements in connection with cash and non-cash compensation for an endorsement or testimonial, if applicable.

Cross Ocean has no legal or disciplinary events to report that would be material to a client’s or prospective client’s evaluation of Cross Ocean’s advisory business or the integrity of its management.

Review of Accounts Cross Ocean will review, as pertinent, the Clients’ portfolio holdings to determine that the investments held by the Clients remain consistent with the pertinent offering documents and will generally review the Clients’ performance on an ongoing basis. Although adhering to a hold-to-maturity mentality at the point of making investments, Cross Ocean strongly believes in active monitoring of the Clients’ investments as a means of both safeguarding and creating value. Depending on the Client, on a daily, monthly or quarterly basis the applicable Client’s portfolio managers will actively monitor the portfolio. Additionally, Cross Ocean will hold frequent (and typically weekly) Investment Committee meetings to assess actionable items within the portfolio.

On an ongoing basis, Cross Ocean’s analysts evaluate the applicable Client’s investments and update the members of such Client’s Portfolio Review Committee. Each investment will be given a ranking based on performance versus the original investment thesis. Cross Ocean believes in addressing any underperforming assets early, and revisiting the original investment thesis to provide a recommendation to buy more, hold or sell. Reports to Clients Client investors receive reports, including unaudited monthly or quarterly reports reviewing the Clients’ performance for the month or quarter as described in the Client’s governing documents, quarterly letters and performance information, and audited financial statements on an annual basis.

Although Cross Ocean does not physically hold the securities and other assets of the Funds, Cross Ocean is deemed to have custody of the assets of certain managed Clients, since a Cross Ocean affiliate serves as general partner of, or in a similar capacity for, certain of the Funds. Fund investors do not receive account statements from any custodians; rather, the Funds are subject to an annual audit and the audited financial statements are distributed to each Fund investor. With respect to the Accounts managed by Cross Ocean currently, Cross Ocean is not deemed to have custody of such Account’s assets. In the future, Cross Ocean may manage other Accounts over which it is deemed to have custody of such Accounts’ assets, and in that instance Cross Ocean will comply with the pertinent requirements of the U.S. Investment Advisers Act of 1940, as amended.

With respect to certain of the Clients, Cross Ocean has full discretion in all investment decisions made on behalf of the Clients, subject to the investment objectives, strategies and policies applicable to each Client. Cross Ocean may make investment decisions, without consultation with the Clients or the Client investors, regarding which securities are bought and sold for the Clients, the total amount of the securities to be bought and sold, the broker-dealers with which orders are placed for execution and the commission rates at which securities transactions are effected. Such discretionary authority is granted to Cross Ocean in the applicable limited partnership agreement, investment management agreement or other pertinent Client documentation. Cross Ocean provides investment advice on a discretionary basis to the Funds it sub-advises with respect to certain of the Funds’ assets.

Cross Ocean has voting authority and responsibility with respect to securities held by the Clients for which it has investment discretion. In addition to solicitations in connection with equity securities of traditional operating companies, proxy voting is also deemed to include any consent requested in matters such as bankruptcy or insolvency, covenant waivers in connection with debt approvals regarding the restructuring of debt and other rights and remedies with respect to securities. In voting proxies, Cross Ocean is guided by general fiduciary principles and votes in the manner it believes is consistent with efforts to achieve a client’s stated investment objectives. Cross Ocean retains the discretion to take no action with respect to a proposed vote if it determines that doing so is in the best interests of a client (for example, where Cross Ocean determines that the cost of voting exceeds the expected benefit to the client). Cross Ocean follows procedures designed to identify conflicts or potential conflicts that could arise between its own interests and those of its clients. If it is determined that any such conflict or potential conflict is not material, Cross Ocean may vote proxies notwithstanding the existence of the conflict. If it is determined, however, that a conflict of interest or potential conflict of interest is material, one or more methods may be used to resolve the conflict, including (i) engaging a third party to recommend a vote with respect to the proxy, (ii) disclosing the conflict to the client and obtaining its consent before voting or (iii) convening a proxy voting committee to review the conflict.

Cross Ocean is not aware of any financial condition reasonably likely to impair its ability to meet contractual commitments to its clients, and Cross Ocean has not been the subject of a bankruptcy petition.