Diameter Capital Partners LP

Diameter Capital Partners LP (“DCP”, the “Adviser”, the “Firm”, “we” or “our”) is a Delaware limited partnership and investment adviser with its principal place of business in New York, New York. The Firm was founded in February 2017, registered with the SEC on August 17, 2017 in connection therewith as an investment adviser, and commenced investment activities on September 1, 2017. The Firm was co-founded by Scott Goodwin and Jonathan Lewinsohn, both of whom are Managing Partners and Portfolio Managers for global investing and are responsible for Firm-wide strategy. Messrs. Goodwin and Lewinsohn indirectly own and control DCP through certain partnerships/limited liability companies. In September 2022, DCP opened an office in West Palm Beach, Florida. In June 2022, Diameter Capital Partners (UK) LLP (“DCP UK”), an indirect, wholly-owned subsidiary of DCP, began operating in London, England. DCP UK has an office located at 21-23 Hill Street, London W1J 5LW, UK. DCP is a global credit asset manager that provides investment advisory services on a discretionary basis to its clients (the “Advisory Clients”), which include pooled investment vehicles that are structured as evergreen investment funds, closed-end drawdown investment funds, customized funds for co-investments or other special opportunities, and structured credit vehicles consisting of collateralized debt obligations and collateralized loan obligations for which the Firm acts as collateral manager, in each case, intended for sophisticated investors that are able to bear the risk of loss. Diameter Principal Finance LLC (“BDC Adviser”) provides investment advisory services to Diameter Credit Company (the “Diameter BDC”), a Delaware statutory trust that has elected to be regulated as a business development company under the Investment Company Act of 1940 (the “1940 Act”). The BDC Adviser registered with the SEC as an investment adviser in October 2023. The BDC Adviser is an indirect, wholly-owned subsidiary of Diameter Capital Partners LP. The BDC Adviser was formed for the purpose of serving as investment adviser to the Diameter BDC and does not serve as investment adviser to any other DCP-affiliated entity. Diameter Principal Finance Partnership LP (“DPF LP”), the parent entity of the BDC Adviser and a relying adviser of DCP, provides investment advisory services to specialized funds of one related to private credit strategies. Diameter DCF Advisor LLC (“Interval Fund Adviser”), a newly formed investment adviser, has entered into an investment advisory agreement with Diameter Dynamic Credit Fund (“Diameter Interval Fund”), a Delaware statutory trust which is a newly organized, non-diversified, closed-end management investment company that intends to be registered under the 1940 Act and intends to operate as an “interval fund”, pursuant to which the Interval Fund Adviser agrees to provide investment advisory services to the Diameter Interval Fund. The Interval Fund Adviser registered with the SEC as an investment adviser in August 2025. The Interval Fund Adviser is a wholly-owned subsidiary of Diameter Capital Partners LP. The Interval Fund Adviser was formed for the purpose of serving as investment adviser to the Diameter Interval Fund and does not serve as investment adviser to any other DCP-affiliated entity. Diameter EU CLO Advisors LLC – Management Series (“EU CLO Adviser”) and Diameter CLO Advisors LLC (“CLO Adviser”) are relying advisers of DCP, and provide or intend to provide investment advisory services to structured credit vehicles. This brochure is intended to cover the investment advisory activities of DCP and all of its investment advisory affiliates, except for the BDC Adviser and the Interval Fund Adviser, each of which files a separate Form ADV. The Diameter BDC files periodic reports with the SEC under the U.S. Securities Exchange Act of 1934 (the “Exchange Act”). We expect that the Diameter Interval Fund will file periodic reports with the SEC under the 1940 Act. Evergreen Investment Funds:

Diameter Onshore Fund LP, Diameter Offshore Fund LP and Diameter Offshore Fund II Ltd., each are feeder funds that invest substantially all their assets through a single master fund, Diameter Master Fund LP (collectively, the “Evergreen Funds”).

Closed-End Investment Funds:

Diameter Dislocation Onshore Fund LP, Diameter Dislocation Intermediate Fund LP and Diameter Dislocation Offshore Fund LP (through its investment in Diameter Dislocation Intermediate Fund LP) are feeder funds that invest substantially all their assets through a single master fund called Diameter Dislocation Master Fund LP (collectively, the “Dislocation I Funds”).

Diameter Dislocation Onshore Fund II LP and Diameter Dislocation Offshore Fund II LP are feeder funds that invest substantially all their assets through a single master fund called Diameter Dislocation Master Fund II LP (collectively, the “Dislocation II Funds” and, together with the Dislocation I Funds, the “Dislocation Funds”).

Diameter Dislocation Onshore Fund III LP and Diameter Dislocation Offshore Fund III LP are feeder funds that invest substantially all their assets through a single master fund called Diameter Dislocation Master Fund III LP, and Diameter Dislocation Onshore Fund III (Contingent) LP and Diameter Dislocation Offshore Fund III (Contingent) LP are feeder funds that invest substantially all their assets through a single master fund called Diameter Dislocation Master Fund III (Contingent) LP (collectively, the “Dislocation III Funds” and, together with the Dislocation I Funds and the Dislocation II Funds, the “Dislocation Funds”).

DCMALT LP is a standalone fund-of-one (the “DCMALT Fund”).

DCP IG Fund LP is a standalone fund-of-one (the “IG Fund”).

DCP Tree LP is a standalone fund-of-one (the “Tree Fund”).

DCP PCF LP is a standalone fund-of-one (the “PCF Fund”).

DIF Feeder LP is a feeder fund that invests substantially all its assets through a master fund called DIF LP (collectively, the “DIF Fund”).

DCP Blue Peak BBB Feeder Fund LP is a standalone fund-of-one that invests substantially all of its assets through a single master fund called DCP Blue Peak BBB Master Fund LP (collectively, the “BBB Fund”).

Diameter CLO Equity Fund LP (the “CLO Equity Fund”, and together with the Evergreen Funds, the Dislocation Funds, the DCMALT Fund, the IG Fund, the Tree Fund, the PCF Fund, the DIF Fund, the BBB Fund, the “Funds”) is a standalone fund.

Direct Lending Vehicles:

DPRR Fund I LP is a standalone fund-of-one with a specialized investment strategy focused on private capital (“DPRR”).

DPF LP may act as the investment manager to additional investment vehicles focused on direct lending in the future (together with DPRR, the “Direct Lending Vehicles”). Additional future Advisory Clients will be subject to investment objectives, management fees and performance-based compensation and other terms that are specific to each future Advisory Client and as set forth in the applicable governing documents of the future Advisory Client.

Structured Credit Vehicles:

The Firm acts as collateral manager to collateralized debt obligation structures pursuant to collateral management agreements. These CDOs are Diameter Credit Funding I, Ltd, Diameter Credit Funding II, Ltd, Diameter Credit Funding III, Ltd and Diameter Credit Funding IV, Ltd (collectively, the “CDOs”).

The Firm acts as collateral manager to collateralized loan obligation structures pursuant to collateral management agreements. These CLOs are Diameter Capital CLO 1 Ltd., Diameter Capital CLO 2 Ltd. Diameter Capital CLO 3 Ltd., Diameter Capital CLO 4 Ltd., Diameter Capital CLO 5 Ltd., Diameter Capital CLO 6 Ltd., Diameter Capital CLO 7 Ltd., Diameter Capital CLO 8 Ltd., Diameter Capital CLO 9 Ltd., Diameter Capital CLO 10 Ltd., Diameter Capital CLO 11 Ltd. and Diameter Capital CLO 12 Ltd. (collectively, the “CLOs”).

The Firm acts as an investment manager to the Funds pursuant to investment management agreements. Diameter Associates LLC (the “General Partner”) serves as general partner of the Funds that have been organized as limited partnerships. The Firm has also established, and may in the future continue to establish, customized investment funds with narrower investment strategies than the Funds and that may have different material terms (including regarding fees, rights and liquidity rights) than the Funds. DCP generally has broad and flexible investment authority with respect to the investment portfolios that it manages for its clients. The Firm provides investment advisory services to its Advisory Clients with respect to a wide range of investments including: investments in long and short positions in securities issued by U.S. and international high yield issuers and related instruments; investments in distressed/special situation opportunities across capital structures and market capitalizations; investments in the broader credit markets, including corporate and sovereign fixed income securities such as investment grade bonds, high yield bonds; loans; credit default swaps; structured credit instruments; investments in derivatives and other hedging instruments including, but not limited to: options, foreign exchange, commodities and swaptions and constant maturity swaps; trade claims; and publicly traded and private equities. As a general matter, the Firm does not tailor advisory services to the individual needs of investors in the Funds, CDOs or CLOs, but the Firm has established and may continue to establish customized investment funds which are subject to different investment objectives, restrictions and terms than those of the Funds, CDOs and CLOs. DCP may establish additional private investment funds in the future, structured as evergreen investment funds, drawdown harvest funds, funds with specialized investment strategies to take advantage of market opportunities or overflow opportunities with sizing, funds-of-one and/or other customized investment vehicles, for one or more investors. DCP may establish separately managed accounts for future strategies. DCP intends to act as collateral manager for additional CDOs or CLOs in the future. Additional future advisory clients will be subject to investment objectives, fee and incentive allocation and withdrawal terms that are specific to each future advisory client and as set forth in the applicable governing documents of the future clients. As described in the ADV Part 1, DCP has $28,755,794,425 in regulatory assets under management. This figure is as of December 31, 2025 except that it also includes any funds launched after the reporting period but prior to the date hereof. DCP manages all of these assets on a discretionary basis and does not currently manage any assets on a nondiscretionary basis.

A brief summary of the fees and compensation that is paid to the Firm for its advisory services is provided below with respect to each Advisory Client, but this summary is qualified in its entirety by the governing documents of each Advisory Client. Depending on the type of Advisory Client, such governing documents include private placement memoranda or offering circulars, limited partnership agreements, memorandum and articles of association, indentures and collateral management agreements (the “Governing Documents”). It is critical that investors invested in any Advisory Client carefully review the Advisory Client’s Governing Documents in order to fully understand how the Firm and its affiliates are compensated for its advisory services and reimbursed or paid for their expenses. Management Fee paid by Funds (Asset-Based Compensation) The management fee applicable to each Advisory Client varies and is described in detail in the applicable Governing Document of each Advisory Client. With respect to the Evergreen Funds, the Firm is paid an asset-based management fee generally charged at a rate that ranges from 1.125% to 1.625% per annum (depending on the series of interests/shares) of the net assets of the respective fund. With respect to the Dislocation I Funds, the Firm is paid an asset-based management fee generally charged at 1.0% to 1.5% per annum (depending on the date and the amount of capital commitment). With respect to the Dislocation II Funds, the Firm is paid an asset-based management fee generally charged at 1.25% to 1.5% per annum (depending on the date and the amount of capital commitment). With respect to the Dislocation III Funds, the Firm is paid an asset-based management fee generally charged at 1.00% to 1.50% per annum (depending on the date and the amount of capital commitment). With respect to the IG Fund, the Tree Fund, the PCF Fund and the DIF Fund, the Firm is paid an asset-based management fee charged at less than 1.0% per annum. The Firm does not earn a management fee from the DCMALT Fund or the BBB Fund. The Firm does not earn a management fee directly from the CLO Equity Fund, though the CLO Equity Fund will invest in certain CLOs managed by the Firm, and the Firm will receive management fees from those vehicles. The management fees for the applicable Funds are charged and paid quarterly in advance to the Firm, based on the value of the assets as of the beginning of each quarter, and are charged pro rata to each investor’s interests in the respective Fund. The management fee with respect to a Fund is calculated by the Fund’s administrator and deducted by the administrator and paid to the Firm pursuant to instructions from the Firm. If an investor invests in a Fund during a quarter or makes an additional subscription during a quarter, the management fee will be charged as of the effective date of the subscription or the date of the additional subscription based on the value of the assets as of the applicable date and will be prorated for the number of months remaining in the quarter. If an investor withdraws from an Evergreen Fund, the IG Fund, the Tree Fund, the PCF Fund or the DIF Fund prior to the end of a calendar quarter, the investor will generally be granted a pro rata reimbursement of any management fees paid for the remaining quarter. There are no withdrawal rights associated with the Dislocation Funds. Incentive Allocation (Performance-Based Compensation) The performance-based compensation, or incentive allocation, applicable to each Fund is described in more detail in the applicable Fund’s Governing Documents. The General Partner (or another affiliate of the Firm) receives an annual incentive allocation from the Evergreen Funds and the DCMALT Fund, which is calculated, in each case, based on a share of net capital appreciation of the assets of an investor in the Evergreen Funds or the DCMALT Fund, respectively. The performance-based compensation applicable to each Evergreen Fund varies, and will generally be calculated at a rate that ranges from 12.5% to 21.0% (depending on the series of interests/shares) and is subject to a loss carryforward. With respect to certain of the series of interests/shares, other factors apply to the calculation of the incentive allocation, which may result in a further reduced and/or no incentive allocation to the General Partner. The performance-based compensation applicable to the DCMALT Fund will generally be calculated at a rate of 10.0% and is subject to a loss carryforward. There is no performance-based compensation applicable to the IG Fund, Tree Fund, the PCF Fund, the DIF Fund or DPRR. Incentive allocations are generally determined at year end. Exceptions occur when an investor withdraws/redeems from a Fund, in which case the incentive allocation is determined and allocated at such time. Details related to the calculation of incentive allocation are provided in each applicable Fund’s Governing Documents. The incentive allocation with respect to a Fund is calculated by the Fund’s administrator, and deducted by the administrator and reallocated to the General Partner pursuant to instructions from the Firm. Incentive allocation is made to the General Partner as a reallocation of profits.

Carried Interest (Performance-Based Compensation Based on Distributions) The carried interest applicable to the Dislocation Funds, the BBB Fund and the CLO Equity Fund is described in greater detail in the relevant Fund’s Governing Documents. The general partner receives carried interest once it has made a distribution to all limited partners in the fund that exceeds the capital contributed by the limited partners and, to the extent applicable, a hurdle rate of return that can vary from fund to fund. There is a general partner catchup, after which distributions are split between the general partner and the limited partners pursuant to the relevant carried interest rate. Such rate varies from 15% to 20% for the Dislocation I Funds, from 18% to 20% for the Dislocation II Funds and from 17.5% to 20% for the Dislocation III Funds, in each case based on the amount and/or initial dates of capital committed to the applicable Dislocation Fund. Such rate is 12.5% for the BBB Fund and 20.0% for the CLO Equity Fund. Expenses related to Funds and the Direct Lending Vehicles In addition to the management fee and incentive allocation with respect to the Funds and the origination fee with respect to the Direct Lending Vehicles, the Funds and the Direct Lending Vehicles are also subject to other expenses, including, without limitation as set forth in this paragraph. With respect to the Funds, each investor in the Fund generally bears its pro rata share of such expense. The Fund and the Direct Lending Vehicle expenses include transaction-related and settlement-related expenses (which include all transaction-based expenses incurred in executing investments including brokerage commissions, expenses relating to short sales, clearing and settlement charges, expenses associated with consummating bank debt trades, dealer spreads, custodial fees, bank service fees, interest expenses and legal expenses associated with any potential or closed transaction); investment-related travel expenses (which are travel expenses related to the purchase, sale or transmittal of, or due diligence regarding, the Funds’ or the Direct Lending Vehicles’ investments, whether or not such investments are consummated, incurred by the Firm or, in the case of the Funds, the General Partner); professional fees (including, without limitation, expenses of consultants, investment bankers, attorneys, accountants and other experts) relating to investments; fees and expenses of any governance committee or limited partner advisory committee; board of directors fees and expenses; fees and expenses relating to software tools, programs or other technology utilized in managing the Funds or the Direct Lending Vehicles (including, without limitation, third-party software licensing, implementation, data management and recovery services, custom development costs and all costs and expenses of any order management systems utilized by the Firm to manage the Funds or the Direct Lending Vehicles); research and market data (excluding any computer hardware and connectivity hardware (e.g., telephone and fiber optic lines) incorporated into the cost of obtaining such research and market data); administrative expenses (including fees and expenses of the Administrator); legal expenses; external accounting and valuation expenses (including pricing services but, solely with respect to the Funds, excluding the cost of accounting software packages); audit and tax preparation expenses; costs related to errors and omissions insurance for, as applicable, the General Partner, the Firm, Board of Directors and the Governance Committee; costs of printing and mailing reports and notices; entity-level taxes; corporate licensing; regulatory expenses of the Funds, the Direct Lending Vehiclesand the Firm (including, without limitation, legal fees, filing fees and costs associated with FATCA and AML compliance, including AML officer fees); organizational expenses (with respect to the Funds); expenses incurred in connection with the offering and sale of interests/shares (including, without limitation, legal fees, registration and other filing fees and side letter negotiations, but excluding travel expenses) and other similar expenses related to the Funds and the Direct Lending Vehicles (other than any fees payable to any placement agent, which will be paid by the Firm either directly or indirectly by reducing the management fees owed to the Firm); indemnification expenses; and extraordinary expenses. Generally, with respect to the Funds and the Direct Lending Vehicles, Fund and Direct Lending Vehicle expenses, other than management fees and any expenses which the General Partner/the Firm determine in their sole discretion should be allocated to a particular investor or investors in the Fund(s) or the Direct Lending Vehicle(s), will be charged to the capital account of all the investors on a pro rata basis. To the extent that expenses to be borne by the Fund(s) or the Direct Lending Vehicles are paid by the General Partner or the Firm, the Fund(s) or the Direct Lending Vehicle(s), as applicable, will reimburse such party for such expenses.

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The Firm combines research and trading skills to exploit inefficiencies in global credit markets. DCP makes investments across the full range of markets and instruments, from new issue and performing to stressed, distressed and equities. This involves combining a focus on market technicals with fundamental research that begins with industry thematic analysis and continues through company-specific work. DCP strives for absolute returns and deemphasizes returns relative to a fixed market index. Each Advisory Client has its own specific investment objective as described in its Governing Documents, and the Firm generally does not invest in the same instruments or investments across all its Advisory Clients. DPF LP’s direct lending strategy is focused on generating current income by targeting direct lending and related investments with favorable risk-adjusted returns. DPF LP seeks to execute this strategy by primarily investing in the debt of private, U.S. domiciled, sponsored and non-sponsored middle-market and upper middle-market companies. DPF LP intends to focus on high quality, performing borrowers in stable or growing industries. DPF LP’s direct lending strategy will seek to prioritize borrower quality, and capital preservation over yield, in order to select investments that offer current income. RISKS The Firm seeks to manage risk actively in order to protect capital and enhance the stability of returns in its Advisory Client portfolios. The Firm actively monitors the Funds’ long-to-short position ratio, industry and company concentration, cash/credit default swap (“CDS”) basis risk, portfolio liquidity by individual position and risk bucket, interest rate exposure and foreign exchange exposure. The Evergreen Funds seek to hedge currency and interest rate risk exposure, where believed appropriate. The Firm actively manages the investment portfolios of the CDOs to ensure that each such one is in compliance with the concentration and other portfolio characteristics specified in the relevant CDO Governing Documents. The Firm actively manages the investment portfolios of the CLOs to ensure

that each such one is in compliance with the concentration and other portfolio characteristics specified in the relevant CLO Governing Documents. Investing in securities involves significant risks, including the risk of loss of some or all of an investment. An investment by investors in an Advisory Client may be deemed speculative and is not intended as a complete investment program as each Advisory Client is designed only for experienced and sophisticated persons who are able to bear the risk of substantial impairment or total loss of their investment. Prospective investors should speak with their legal, tax and financial advisors prior to making an investment with the Firm. The following summary identifies the material risks related to the Firm's significant investment strategies and should be carefully evaluated before making an investment with the Firm; however, the following does not intend to identify all possible risks of an investment with the Firm or provide a full description of the identified risks. It is critical that investors refer to the Advisory Client Governing Documents in order to obtain a fuller understanding of the risks associated with an investment in an Advisory Client. PRIMARY RISKS Risk of Loss – No guarantee or representation is made that an Advisory Client’s investment program, including its investment objective, diversification strategies or risk monitoring goals, will be successful. Investment results may vary substantially over time. No assurance can be made that profits will be achieved or that substantial or complete losses will not be incurred. Past investment results of the investments otherwise made by the investment professionals of the Firm are not necessarily indicative of an Advisory Client’s or the Firm’s future performance. Credit Risk – Deterioration in the credit quality of issuers can lead to a change in the value of the debt securities of the issuer. An improvement in credit quality of the issuer could lead to a spread tightening or rise in price of the issuer’s securities. The Firm will be focused on shorts with asymmetric payoffs primarily through the use of cash bonds, CDS, and equity put options to mitigate the potential downside of these positions. Market Risk – Market fluctuations are subject to a number of factors, most of which are outside of the Firm’s control. The Firm seeks to prioritize capital preservation in the face of market volatility through defensive portfolio construction, selectively chosen short positions that should underperform indices in all markets, methodical rates and currency hedges, and constant stress-testing. Liquidity Risk – The Firm will compare the liquidity of the portfolio with any expected redemption requests (if applicable to the Advisory Client) and other liquidity needs to ensure adequate coverage. While the Firm’s strategy focuses predominantly on liquid credit securities, there will be a distressed component to the portfolio of certain Advisory Clients, such as the Evergreen Funds. Companies that in many cases were initially encountered as performing, new issue or shorts, may be temporarily illiquid as they go through the restructuring process. The Firm will strive to mitigate this risk by limiting position size and, with regard to credit instruments, the Firm seeks to focus on larger, more liquid issues. Concentration Risk – Generally, DCP manages its Advisory Clients with a broad and flexible investment mandate, and the governing documents of the Advisory Client do not contain limitations on concentrations with respect to any particular issuer/obligor, region or industry. Redemptions from an Advisory Client (to the extent applicable) may result in a greater concentration in any one obligor, region or industry and such resulting concentration would subject the Advisory Client’s portfolio to a greater degree of risk with respect to collateral defaults by such obligor, and such concentration of the portfolio in any one industry or region would subject the portfolio to a greater degree of risk with respect to economic downturns relating to such industry or region. In certain Advisory Clients, such as the CDOs, the portfolios are expected to be constituted primarily of certain asset classes (e.g. below investment grade debt obligations), and to the extent that such obligations underperform as a class, the Advisory Client’s portfolio will likely experience losses. Cyber Security Breaches and Identity Theft – With the increased use of technologies such as the Internet and the dependence on computer systems to perform business and operational functions, Advisory Client portfolios and their service providers may be prone to operational and information security risks resulting from cyber-attacks and/or technological malfunctions. In general, cyber-attacks are deliberate, but unintentional events may have similar effects. Cyber-attacks include, among others, stealing or corrupting data maintained online or digitally, preventing legitimate

users from accessing information or services on a website, releasing confidential information without authorization, and causing operational disruption. Successful cyber-attacks against, or security breakdowns of, the Advisory Clients, the Firm, or a custodian, or other affiliated or third-party service provider may adversely affect the Advisory Clients or the investors in the Advisory Clients. For instance, cyber-attacks may interfere with the processing of transactions, affect the Firm’s ability to calculate net asset value on behalf of its Advisory Clients, cause the release of private investor information or confidential Client portfolio information, impede trading, cause reputational damage, and subject the Advisory Client or the Firm to regulatory fines, penalties or financial losses, reimbursement or other compensation costs, and additional compliance costs. Cyber-attacks may render records of Advisory Client assets and transactions, ownership of Client interests, and other data integral to the functioning of an Advisory Client inaccessible or inaccurate or incomplete. An Advisory Client may also incur substantial costs for cyber security risk management in order to prevent cyber incidents in the future. The Advisory Clients and investors could be negatively impacted as a result. While the Firm has established business continuity plans and systems designed to minimize the risk of cyberattacks through the use of technology, processes and controls, there are inherent limitations in such plans and systems, including the possibility that certain risks have not been identified given the evolving nature of this threat. The Advisory Clients rely on third-party service providers for many of their day-to-day operations, and will be subject to the risk that the protections and protocols implemented by those service providers will be ineffective to protect the Advisory Client from cyber-attack. Artificial Intelligence – The Firm and the issuers in which the Advisory Clients invest and/or the Advisory Clients’ service providers could incorporate novel uses of artificial intelligence (“AI”), including generative AI, into their businesses and operations. However, there are significant risks involved in utilizing AI, and no assurance can be provided that such use will enhance the businesses or operations or result in such businesses or operations being more efficient or profitable. For example, AI algorithms could be flawed, insufficient, of poor quality, reflect unwanted forms of bias, or contain other errors or inadequacies, any of which may not be easily detectable. AI has also been known to produce false or “hallucinatory” inferences or outputs and AI can present ethical issues and subject users to new or heightened legal, regulatory, ethical, or other challenges. Inappropriate or controversial data practices by developers and end-users, or other factors adversely affecting public opinion of AI, could impair the acceptance of AI solutions. If the AI solutions that the Advisory Clients, the Firm, the issuers in which the Advisory Clients invest or the Advisory Clients’ service providers create or use are deficient, inaccurate or controversial, the Firm or the Advisory Clients could suffer operational inefficiencies, competitive harm, legal liability, brand or reputational harm, or other adverse impacts on their businesses and financial results. If the party using AI does not have sufficient rights to use the data or other material or content on which its AI solutions or other AI tools rely, such party could also incur liability through the violation of applicable laws, third-party intellectual property, privacy or other rights, or contracts to which they are a party. In addition, regulation of AI is rapidly evolving worldwide as legislators and regulators are increasingly focused on this emerging technology. The technologies underlying AI and its uses are already subject to a variety of laws, including intellectual property, privacy, data protection and cybersecurity, consumer protection, competition, and equal opportunity laws, and are expected to be subject to increased regulation and new laws or new applications of existing laws. AI is the subject of ongoing review by various U.S. governmental and regulatory agencies, and various U.S. states and other non-U.S. jurisdictions are applying, or are considering applying, their platform moderation, cybersecurity, and data protection laws to AI or are considering general legal frameworks for AI, such as the European Union Artificial Intelligence Act, which entered into force on August 1, 2024. It is possible that the Advisory Clients, the Firm, or any of their respective affiliates will not be able to anticipate how to respond to these rapidly evolving frameworks, and such parties could be required to expend resources to adjust their activity in certain jurisdictions if the legal frameworks are inconsistent across jurisdictions. Furthermore, because AI technology itself is highly complex and rapidly developing, it is not possible to predict all of the legal, operational or technological risks that may arise relating to the use of AI. Foreign Exchange and Interest Rate Risk – Interest rate fluctuations are determined by macroeconomic policy which is beyond the Firm’s control. The Funds will invest in investment grade corporate bonds, investment grade municipal bonds, and investment grade sovereign bonds that have a trading convention of “spread over risk free rate of similar duration.” The Firm will hedge out the interest rate risk in these positions at the time of trade execution. The Firm will also hold sub-investment grade securities that have a component of interest rate risk. Each sub13

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DCP provides investment advisory services to the Funds, which are evergreen and closed-end investment funds, CDOs and CLOs. DCP also provides investment advisory services to customized funds. DCP may provide investment advisory services to additional Advisory Clients, including separately managed accounts in the future. With respect to the Funds, any initial and additional subscription minimums from investors are disclosed in the relevant Governing Documents; however, the General Partner has discretion to waive the minimum amounts and accept lesser subscription amounts. The General Partner exercises its discretion to waive the minimum subscription amounts on a case-by-case basis. With respect to the CDOs and the CLOs, the Governing Documents of the CDOs or the CLOs, as applicable, specify any minimum investment amounts. Generally, the minimum investment in the Advisory Clients for investors who are not affiliated with DCP ranges from $50,000 to $10,000,000 (depending on the Advisory Client and specific series of interest being subscribed to). Investors in the Advisory Clients can include institutional investors (including funds of funds, pension plans, charitable organizations, and sovereign/governmental investors), high net worth individuals, family offices and employees of the Firm. U.S. investors must be “accredited investors” under the meaning of Regulation D of the Securities Act of 1933, as amended and “qualified purchasers” or “knowledgeable employees” (as defined in Section 2(a)(52) of the Investment Company Act of 1940, as amended). Certain employees of DCP, their family members, or entities formed for the benefit of these individuals can also invest in the Advisory Clients, to the extent permitted by applicable laws and regulations.

As described in greater detail in the Advisory Client Governing Documents, and as noted in Item 5 of this Brochure, certain Advisory Clients allocate to the General Partner (which is an affiliate of DCP) or DCP an incentive allocation based on the performance of such Advisory Client, or a targeted carried interest distribution based on the return of capital to investors of such Advisory Client. The rates applicable to such performance-based compensation vary from Advisory Client to Advisory Client, and even within an Advisory Client (such as the Funds) based on the series of interests. In addition, certain personnel of the Firm are compensated on a basis that includes a performance-based component. Although the right to receive an incentive allocation or carried distribution is generally viewed as aligning the interests of the Firm and its Advisory Clients, conflicts arise from such arrangements, for example:

The General Partner’s receipt of incentive allocation or carried distribution may motivate DCP to make investments that are riskier or more speculative than it would make if its affiliate did not receive a performance-based compensation. This conflict may be particularly acute when the General Partner’s incentive allocation is fully payable only upon exceeding a high-water mark and the value of an investor’s investment in a Fund is below such high-water mark.

Certain Advisory Clients may have higher management fees or incentive allocation or carried interest rates which are more favorable to DCP than other Advisory Clients. As a result, DCP may seek to favor one Advisory Client over another in allocating investment opportunities.

The Firm manages more than one Advisory Client with varying investment objectives, and to mitigate the risk of favoring one Advisory Client over another, the Firm has implemented policies and procedures relating to the allocation of investment opportunities and related expenses among multiple Advisory Clients. DCP recognizes that it is a fiduciary and as such must act in the best interests of its Advisory Clients. Further, investors are provided with clear disclosure in applicable Governing Documents as to how the performance-based compensation is charged.

The General Partner is an affiliate of the Firm and receives performance-based compensation from certain of the Funds for which it serves as general partner. In addition, the Firm has its own general partner entity. Diameter CLO Advisors LLC serves as a “relying adviser” that is registered under the Advisers Act pursuant to the Firm’s registration and serves as the collateral manager to the CLOs. Diameter Principal Finance Partnership LP also serves as a “relying

adviser” that is registered under the Advisers Act pursuant to the Firm’s registration and serves as the investment manager of DPRR and will advise future Direct Lending Vehicles. Diameter EU CLO Advisors – Management Series also serves as a “relying adviser” that is registered under the Advisers Act pursuant to the Firm’s registration and will seve as the investment manager of future vehicles. Diameter Capital (UK) Limited (“Diameter UK”), a wholly owned subsidiary of Diameter, operates from its offices in London, United Kingdom. Certain of Diameter UK’s advisory personnel based in London have been seconded to Mirabella Financial Services LLP (“Mirabella”), which serves as a sub-manager to Diameter with respect to certain Advisory Clients. Mirabella is authorized and regulated by the UK Financial Conduct Authority. Diameter Principal Finance LLC (“BDC Adviser”), provides investment advisory services to Diameter Credit Company (the “Diameter BDC”), a Delaware statutory trust that has elected to be regulated as a business development company under the Investment Company Act of 1940. The BDC Adviser registered with the SEC as an investment adviser in October 2023. The BDC Adviser is an indirect, wholly-owned subsidiary of Diameter Capital Partners LP. The BDC Adviser was formed for the purpose of serving as investment adviser to the Diameter BDC and does not serve as investment adviser to any other DCP-affiliated entity. The BDC Adviser files a separate Form ADV. The Diameter BDC files periodic reports with the SEC under the Exchange Act. The Interval Fund Adviser registered with the SEC as an investment adviser in August 2025. The Interval Fund Adviser is a wholly-owned subsidiary of Diameter Capital Partners LP. The Interval Fund Adviser was formed for the purpose of serving as investment adviser to the Diameter Interval Fund (which, as of March 31, 2026, has not launched) and does not serve as investment adviser to any other DCP-affiliated entity. The Interval Fund Adviser files a separate Form ADV. We expect that the Diameter Interval Fund will file periodic reports with the SEC under the 1940 Act. Although it is not currently expected that the Advisory Clients, other than the Direct Lending Vehicles, will invest in the same securities or other financial instrument as the Diameter BDC, the relationship between the Diameter BDC and Advisory Clients may create certain conflicts of interest. For example, the Diameter BDC will invest alongside certain Advisory Clients, such as the Direct Lending Vehicles, in certain investments, which will reduce the portion of each investment that would otherwise have been allocated to such Advisory Client. In addition, as business development company, the Diameter BDC is subject to certain regulatory considerations that constrain its operations, which could have an adverse impact on Advisory Clients that coinvest alongside the Diameter BDC, including with respect to the structuring, terms, allocations, consummation and disposition of the Advisory Clients’ investments.

The Firm has adopted a Code of Ethics (the “Code”) that obligates the Firm and its “Access Persons” to put the interests of the Firm’s Advisory Clients before their own interests and to act honestly and fairly in all respects in their dealings with Advisory Clients. The Firm believes that high professional and ethical standards are essential for the success of Diameter. In addition to compliance with DCP’s policies and procedures, all Access Persons of the Firm are required to comply with all applicable laws including the federal securities laws. The Firm and its Access Persons may give and/or receive gifts, services or other items to/from any person or entity that does business with or potentially could conduct business with or on behalf of the Firm. To ensure that these exchanges are conducted in a manner that does not adversely affect DCP’s Advisory Clients and in a manner consistent with the fiduciary duty owed by DCP to its Advisory Clients, it has adopted policies and procedures governing gifts and business entertainment, which requires disclosure and/or pre-approval of certain gifts and business entertainment in excess of de minimis thresholds as detailed within the Code. The Firm, in the course of its investment management and other activities (e.g., board or creditor committee service), may come into possession of confidential or material, nonpublic information about issuers, including issuers in which

DCP or its Access Persons have invested or seek to invest on behalf of clients. The Firm and its Access Persons are prohibited from improperly disclosing or using such information for their own benefit or for the benefit of any other person, regardless of whether such other person is an Advisory Client. DCP maintains and enforces written policies and procedures that prohibit the communication of such information to persons who do not have a legitimate “need to know” such information and to assure that the Firm is meeting its obligations to its clients and remains in compliance with applicable law. In certain circumstances, the Firm may possess certain confidential or material, nonpublic information that, if disclosed, might be material to a decision to buy, sell or hold a security, but the Firm will be prohibited from communicating such information to the Advisory Clients(s) or using such information for the benefit of the client(s) or themselves. In such circumstances, DCP will have no responsibility or liability to the Advisory Clients(s) for not disclosing such information to the Advisory Clients(s) (or the fact that the Firm possesses such information), or not using such information for the benefit of the Advisory Clients(s), as a result of following DCP’s policies and procedures designed to provide reasonable assurances that it is complying with applicable law. Advisory Clients or prospective clients may review a copy of the Code by contacting Mr. Michael Cohn, the Firm’s Chief Compliance Officer, by telephone at (212) 655-1419 or email: mcohn@diametercap.com. It is DCP’s policy that its Access Persons, including employees, may not engage in any transactions in his or her personal account in single name securities without pre-approval from an appropriate member of the DCP compliance team. Pre-approval is generally granted for the disposition of pre-existing positions held by the Access Person prior to the commencement of his or her employment with the Firm, and for the acquisition of privately held, illiquid investments, so long as they do not pose a conflict to other Advisory Clients. DCP believes that such policy minimizes potential conflicts of interests presented when, because of the information the Firm has, the Firm or its Access Persons are in a position to trade in a manner that could adversely affect Advisory Clients (e.g., place their own trades before or after client trades are executed in order to benefit from any price movements due to the Advisory Clients’ trades). In addition to affecting DCP’s or its Access Persons’ objectivity, these practices by DCP or its Access Persons may also harm Advisory Clients by adversely affecting the price at which the Advisory Clients’ trades are executed. The Firm has adopted the following additional procedures in an effort to minimize such conflicts. Access Persons of DCP must pre-clear transactions in reportable securities in their personal accounts (with the exception of transactions in U.S. treasuries, shares issued by money market funds and CDs or other cash equivalents) with the an appropriate member of the DCP compliance team, who may deny permission to execute the transaction if such transaction will have any adverse economic impact on one (or more) of the Advisory Clients, or if holding period requirements are not satisfied with respect to certain instruments. All Access Persons of DCP are required to disclose their holdings upon commencement of employment with the Firm and on an annual basis thereafter. All Access Persons of the Firm are also required to certify to reportable security transactions on a quarterly basis. Access Persons’ accounts and transactions (if any) are reviewed by an appropriate member of the DCP compliance team. The Firm acts as collateral manager to the CDOs/CLOs. Certain partners, officers and employees of the Firm who are “knowledgeable employees” have, and may in the future, purchase(d) the junior subordinated tranche or equity of certain CDOs and CLOs. These interests can create an incentive to favor one Advisory Client over another, including with respect to placing trades or engaging in cross trades. Advisory Clients have purchased and as of the date of this Brochure, hold an interest in the junior subordinated tranche or equity of certain CDOs/CLOs. As stated in Item 11 herein, in order to address these potential conflicts DCP has implemented policies and procedures reasonably designed to identify such conflicts of interest and provide a means to resolve any such actual or potential conflict in favor of the Advisory Client. Such policies and procedures are designed to ensure that the Firm and its employees service all Advisory Clients in a manner consistent with the duties an adviser owes to its Advisory Clients, including pursuant to applicable law, without considering such persons’ ownership or other interest.

DCP considers a number of factors in selecting a broker-dealer or counterparty to execute transactions (or series of transactions) and determining the reasonableness of the broker-dealer’s (or counterparty’s) compensation. Such factors include, but are not limited to, financial stability or creditworthiness; the actual executed price and the commission or spread; research (including economic forecasts, investment strategy advice, fundamental and technical advice on securities and other financial instruments, valuation advice and market analysis), custodial and other services

provided for the enhancement of the Firm’s general portfolio management capabilities; type of settlement (delivery versus payment vs. free delivery); the size and type of the transaction; the difficulty of execution and the ability to handle difficult trades; willingness and ability of the broker or counterparty to make a market; and the operational facilities of the brokers and/or dealers involved (including back office efficiency). In selecting a broker-dealer or counterparty to execute transactions (or series of transactions) and determining the reasonableness of the brokerdealer’s compensation, the Firm does not solicit competitive bids and does not have an obligation to seek the lowest available commission cost. It is not DCP’s practice to negotiate “execution only” commission rates; thus, a Client is deemed to be paying for research, brokerage or other services provided by a broker-dealer which are included in the commission rate. Appropriate members of DCP’s compliance team and selected other employees of the Firm meet periodically to evaluate the overall quality of broker-dealers and counterparties used by the Firm to execute client trades using the foregoing factors. Section 28(e) of the U.S. Securities Exchange Act of 1934, as amended, is a “safe harbor” that permits an investment manager to cause a client to pay more than the lowest possible commissions rate in order to obtain research and brokerage services that provide lawful and appropriate assistance in the investment decision-making process. Among other things, the safe harbor permits an investment manager to use client commissions to offset certain expenses that it would otherwise be obligated to pay for itself. The governing documents of the Advisory Clients describe the expenses that are to be borne by the Advisory Clients and those expenses which are to be borne by DCP. Pursuant to the governing documents, the Advisory Clients bear all research expenses. Accordingly, any portion of commissions that can be attributable to research expenses does not cause the Firm to receive any benefit, since the commissions and the research expenses are both the expenses of the Advisory Clients. As a result, DCP does not face the kind of conflict of interest that Section 28(e) is intended to address, since it does not use client commissions to pay for research that it would otherwise have paid for itself. Nonetheless, DCP assesses the value and quality of the brokerage and research services provided by the broker dealers with which it does business to determine that the cost of such services is appropriate and reasonable in light of the brokerage and research services provided (see the foregoing paragraph). From time to time, the Firm participates in capital introduction programs arranged by broker-dealers, including firms that serve as prime brokers to a Fund managed by the Firm or recommend investments in the Funds as investments to the Advisory Clients of the broker-dealer. The Firm places Advisory Client portfolio transactions with firms who have provided capital introduction opportunities if the Firm determines that it is otherwise consistent with seeking best execution. In no event will the Firm select a broker-dealer as a means of remuneration for recommending the Firm or any other product managed by the Firm (or an affiliate) or affording the Firm with the opportunity to participate in capital introduction programs. In addition, while the Firm recognizes that it has an incentive to favor broker-dealers that provide capital introduction services to the Firm or otherwise refer prospective investors for an investment in an Advisory Client, the Firm does not select broker-dealers in recognition of the opportunity to participate in such capital introduction events or the referral of investors. The Firm addresses the potential conflicts of interest in connection with its brokerage practices through its best execution review process. The Firm’s best execution review process, led by the Firm’s compliance team, in collaboration with the quantitative analysts, appropriate members of the accounting team, portfolio managers, senior traders and operations analysts, includes an analysis of overall performance of broker-dealers in light of the amount of business directed to such broker-dealers. To the extent the Firm determines that the amount of business directed to a particular broker-dealer is inconsistent with the overall performance of such broker-dealer, the Firm will work towards scaling back the amount of business directed to the broker-dealer unless there is a compelling reason for such allocation, including, but not limited to, the availability of a particular security or their expertise in a particular sector. The Firm purchases or sells the same security or other financial instrument for multiple Advisory Clients contemporaneously and using the same executing broker/dealer or counterparty. It is the Firm’s practice, when appropriate, to aggregate Advisory Client orders for the purchase or sale of the same security or other financial instrument submitted at or near the same time for execution using the same executing broker/ dealer or counterparty. Such aggregation may enable the Firm to obtain a more favorable price or a better commission rate for clients based upon the volume of a particular transaction. DCP will act in a fair and equitable manner in allocating investment and trading opportunities among its Advisory Clients and will act in the best interests of its Advisory Clients, not itself. It reviews the investment strategy and current portfolio of each Advisory Client and evaluates a number of factors in order to determine how much of a particular investment is appropriate for each Advisory Client.

The Firm has adopted written procedures in connection with ensuring that investment opportunities are allocated fairly to each Advisory Client in an Investment Allocation Policy (which includes a Direct Lending Supplement that is applicable to the Direct Lending Vehicles and the Diameter BDC). In accordance with the Firm’s Investment Allocation Policy, the Firm will allocate a particular investment opportunity to Advisory Clients based on its consideration of various factors, including the investment objectives, guidelines and restrictions of the Advisory Client and an analysis of the risk and return profile of such investment opportunity (which analysis may include a review of the expected yield, the expected yield to maturity and the convexity or interest rate sensitivity of the investment opportunity). If, after consideration of such factors, the Firm determines such investment opportunity is appropriate for multiple Advisory Clients, then such investment opportunity will be allocated (i) pro rata, based on the AUM of the Advisory Clients as of the first day of the calendar month, among all such eligible Advisory Clients or (ii) with respect to allocations made pursuant to the Direct Lending Supplement, based on the targeted position size of the participating Advisory Clients and/or the Diameter BDC, in each case, unless the Investment Manager, acting in the best interest of such Advisory Clients and after its consideration of a number of factors, determines that such pro rata allocation (or, with respect to allocations made pursuant to the Direct Lending Supplement, such targeted position size allocation) will not result in a fair and equitable allocation of the investment opportunity. Examples of the factors that the Investment Manager will consider when determining whether non pro rata allocations (or, with respect to allocations made pursuant to the Direct Lending Supplement, such non targeted position size allocations) to eligible Advisory Clients are appropriate include, but are not limited to, the following: the availability of cash of a Advisory Client, the Advisory Client’s liquidity requirements, the terms and conditions of the Order and whether the Advisory Client is already at the target position size for such investment opportunity. It is not currently expected that the Direct Lending Vehicles and other Advisory Clients will invest in the same securities or other financial instrument, however, in the event an Advisory Client(s) does make an investment in the same securities or financial instrument as a Direct Lending Vehicle it will be conducted in accordance with the Investment Allocation Policy. The Direct Lending Vehicles and the Diameter BDC have overlapping investment strategies and may make investments in the same securities or other financial instrument. The Firm and the BDC Adviser may earn varied management fee percentages from such Advisory Clients and the Diameter BDC, as applicable, and its affiliated entities may receive varying percentages of incentive allocation/carried interest from the Advisory Clients and the Diameter BDC, as applicable. Under the terms of the Order and the Investment Allocation Policy, to the extent there is an investment opportunity that is suitable for both the Advisory Clients and the Diameter BDC, the Diameter BDC’s targeted position size will first be “filled,” followed by other Direct Lending Vehicles, in each case, in accordance with the requirements of the Investment Company Act of 1940 and the Order. The Firm has adopted written procedures in an Investment Allocation Policy, as supplemented by the Direct Lending Supplement, in connection with ensuring that investment opportunities are allocated fairly to each Advisory Client and the Diameter BDC, subject in all respect to the terms and conditions of the Order and any other restriction imposed under the Investment Company Act of 1940. The Firm’s compliance team regularly reviews the allocation of investment opportunities in order to ensure that investments are allocated in accordance with the Firm’s Investment Allocation Policy. The Firm’s Investment Allocation Policy is made available to all investors upon request. Each Advisory Client will on occasion experience errors with respect to trades made on its behalf. Trade errors may include, for example, (i) the placement of orders (either purchases or sales) in excess of the amount of securities the Firm intended to trade on behalf of an Advisory Client; (ii) the sale of a security when it should have been purchased; (iii) the purchase of a security when it should have been sold; (iv) the purchase or sale of the wrong security; (v) the purchase or sale of a security contrary to regulatory restrictions or an Advisory Client’s investment guidelines or restrictions; (vi) incorrect allocations of securities; (vii) keystroke errors that occur when entering trades into an electronic trading system; and (viii) typographical or drafting errors related to derivatives contracts or similar agreements. Trade errors may result in losses or gains. DCP will endeavor to detect trade errors prior to settlement and correct and/or mitigate them in an expeditious manner. To the extent an error is caused by a counterparty’s gross negligence or willful misconduct, DCP seeks to recover any losses associated with such error from the counterparty. Pursuant to the exculpation and indemnification provided by the Advisory Clients to DCP and its affiliates and personnel, DCP and its affiliates and personnel will generally not be liable to the Advisory Clients for any act or omission resulting in a trade error, absent bad faith, gross negligence, willful misconduct or actual fraud, and the Advisory Clients will generally be required to indemnify such persons against any losses they may incur by reason of any act or omission related to the Advisory Clients, absent bad faith, gross negligence, willful misconduct or actual fraud. As a result of these provisions, the Advisory Clients (and not DCP) will benefit from any gains resulting from trade errors and will be responsible for any losses (including additional trading costs) resulting from trade errors and

similar human errors, absent bad faith, gross negligence, willful misconduct or actual fraud. DCP will offset any such net gains and net losses resulting from trade errors and, in the case of net losses for which DCP is responsible under the exculpation provisions, DCP will reimburse the applicable Advisory Client for such net losses.

The Firm does not make any payments to third-party solicitors for client referrals. The Firm has, and may in the future, compensate third parties, such as placement agents, in connection with soliciting investors for Advisory Clients. Such compensation is typically based on a percentage of the assets initially invested from the investor.

DCP is not aware of any legal or disciplinary events that are material to an investor’s or prospective investor’s or an Advisory Client’s evaluation of its advisory business or the integrity of its management.

The investment objective of each Advisory Client is set forth in the Advisory Client’s Governing Documents. The active management of the Advisory Clients is the only business of DCP. DCP’s portfolio managers, including its Managing Partners, are actively involved in making investment decisions on behalf of the Advisory Clients. The Firm manages and reviews various aspects of each Advisory Client’s portfolio on a daily, weekly, monthly or other basis as it considers appropriate, with the frequency and nature of such reviews depending on the Advisory Client’s investment program and market conditions. The portfolio managers and investment analysts review on a daily basis position reports related to the Advisory Client portfolios. The portfolio managers also review a detailed risk package related to the Evergreen Funds and Dislocation Funds on a daily basis. While the Funds do not have a formal investment committee, investment analysts meet regularly with the portfolio managers to review specific names, sectors or themes. The CDOs and CLOs have an investment committee that consists of the managing partners and certain senior traders and senior analysts, who generally meet on a weekly basis. The investment team regularly communicates with respect to real-time market conditions that may have a material impact on an Advisory Client’s portfolio. DCP’s operations and compliance teams review the Advisory Client portfolios on a daily basis to ensure accurate trade booking and counterparty reconciliation, timely settlement and compliance checks (such as reviewing whether trades allocations have been made consistently with the Firm’s written policy). Investors in the Advisory Clients receive written reports in accordance with the terms of each Advisory Client’s Governing Documents. Investors in the Funds receive monthly or quarterly account statements from the respective Fund’s third party fund administrator regarding their capital accounts. Audited year-end financial statements are provided annually to investors in Funds. In addition, investors in the Evergreen Funds receive monthly reports, which may include certain information relating to investment performance and investment themes going forward. Investors in the Dislocation Funds receive quarterly reports, which may include certain information relating to investment performance and investment themes going forward. Investors in the CDOs and the CLOs have access to periodic reports from the CDO trustee or CLO trustee in accordance with the CDO Governing Documents or the CLO Governing Documents, as applicable.

The General Partner is deemed to have custody of assets of the Funds due to serving as the general partner to certain of the Funds, DCP is deemed to have custody by virtue of its status as being a related person of the general partner and DPF LP is deemed to have custody of the assets of the Direct Lending Vehicles because of the authority DPF LP has over such Advisory Client or its assets. The General Partner and the Firm comply with Rule 206(4)-2 under the Advisers Act (the “Custody Rule”) by meeting the conditions of the pooled vehicle annual audit provision of the Custody Rule, including providing investors in the Funds and the Direct Lending Vehicles with audited annual financial statements of the Funds and the Direct Lending Vehicles, as applicable, prepared by an independent public accountant, registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board (“PCAOB”), in accordance with generally accepted accounting principles, within 120 days of the applicable Fund’s

or Direct Lending Vehicle’s fiscal year end. Neither the Firm nor the General Partner maintain physical custody of client assets of the Funds or the Direct Lending Vehicles, which are held at accounts maintained in the applicable Advisory Client’s name with qualified custodians. DCP is not deemed to have custody with respect to assets of the CDOs or the CLOs because a third-party trustee (which is a qualified custodian), rather than DCP, controls the cash or securities that is held in the applicable CDO or CLO account.

The Firm provides investment advisory services to its Advisory Clients on a discretionary basis. Prior to assuming discretion over an Advisory Client’s assets, the Firm enters into an investment management agreement or other agreement that sets forth the scope of the Firm’s discretion. The Firm has full discretionary authority to determine the securities or other financial instruments and the amount of the securities or other financial instruments to be purchased or sold for each Advisory Client in accordance with that Advisory Client’s investment objectives, guidelines and restrictions set forth in its Governing Documents. The Firm has and may in the future enter into additional agreements, or “side letters”, with certain prospective or existing investors in pooled investment vehicles whereby such investors may be subject to terms and conditions that are more advantageous than those set forth in the applicable Governing Documents of a Fund, without notice to, or consent of, other investors in the applicable Fund. For example, certain government-related investors (e.g., public pensions), as a condition of their investment, may require that the Firm agree to certain notifications or to comply with the investor’s status-specific requirements. In addition, the terms and conditions of side letters have and may provide for special rights to make future investments; special redemption rights generally relating to regulatory issues; or such other rights as may be negotiated by the Funds and such investor.

To the extent the Firm has been delegated proxy voting authority on behalf of its Advisory Clients, the Firm complies with its proxy voting policies and procedures that are designed to ensure that in cases where the Firm chooses to vote proxies with respect to securities managed for clients, such proxies are voted in the best interests of its Advisory Clients. In fulfilling its obligations to clients, the Firm endeavors to act in a manner that will enhance the economic value of the underlying securities held by each of its Advisory Clients. In some cases, DCP may abstain from voting or may affirmatively decide not to vote if it determines that abstaining or not voting is in the best interests of the Advisory Clients. Investors in the Advisory Clients are not permitted to direct the votes in a particular solicitation. If a material conflict of interest between the Firm and an Advisory Client exists related to voting the proxies on behalf of the client, the Firm will determine whether voting in accordance with the guidelines set forth in its proxy voting policies and procedures is in the best interests of the client or whether to take some other appropriate action. Advisory Clients may review a copy of the Firm’s proxy voting policies and procedures and information about how the Firm voted proxies by contacting Mr. Michael Cohn, the Firm’s Chief Compliance Officer by telephone at (212) 655-1419 or email: mcohn@diametercap.com.

The Firm does not require or solicit prepayment of more than $1,200 in fees per Advisory Clients, six months or more in advance and therefore has not included a balance sheet. The Firm does not believe that there are any conditions that are reasonably likely to impair the Firm’s ability to meet contractual commitments to clients.

The Firm has never been the subject of a bankruptcy petition.