ENTRUST GLOBAL PARTNERS L L C

EnTrust Global Partners LLC (“Partners”), a Delaware limited liability company, commenced business operations in February 1999. EnTrust Global Partners Offshore LP (“Offshore”), a Delaware limited partnership, commenced business operations in December 1999. Blue Ocean GP LLC (“BO GP”), a Delaware limited liability company, commenced business operations in June 2018. Offshore and BO GP are investment advisers relying on the SEC registration of Partners. Unless otherwise noted, references herein to “Advisor” generally refers collectively to Partners, Offshore and BO GP. On May 2, 2016, the EnTrust business combined with that of the Permal Group, a Legg Mason subsidiary and global alternative asset manager that was established in 1973 and acquired by Legg Mason in 2005. Gregg S. Hymowitz, the Managing Partner of EnTrust, or entities controlled by him, received a 35% ownership stake in the combined group of companies. Legg Mason retained a 65% ownership stake. On July 31, 2020, EnTrust Global (“EG” or the “Firm”) completed its return to an independent, private company after closing on a previously reported transaction with Franklin Resources pursuant to which Mr. Hymowitz reacquired the 65% interest that Legg Mason, Inc. held in EG. Mr. Hymowitz, founder of the Firm, is the Chairman and Chief Executive Officer of EG, oversees the investment management function of the Advisors and is responsible for managing the EG business on a day-to-day basis. In September 2022, a sovereign wealth fund purchased a minority stake (less than 10%) in EnTrust Global and in January 2024, acquired an additional equity interest in the Firm, bringing its ownership interest to approximately 20%. The investment is passive with no exercise of control or involvement in the daily activities, investments or operations of the Firm, which continue to be managed by Mr. Hymowitz and the Firm’s Management Committee, comprised of EnTrust Global senior executives. In connection with these transactions, a Firm-level Board of Directors was established to periodically discuss business updates and related matters.

Description of Advisory Services EnTrust Global’s business platform offers a variety of investment opportunities across a range of asset classes, strategies, and liquidity profiles, in both the public and private markets. The Firm provides commingled solutions (“Commingled Funds”) as well as individually customized managed accounts or single investor fund structures (collectively, “Strategic Partnerships”). The Firm’s business lines include: Opportunistic Investments, Opportunistic Credit, EnOne Ventures, Blue Ocean Maritime Finance, Blue Ocean 4Impact, Hedge Fund Solutions, and Liquid Alternatives. Investment sub-committees lead each of the Firm’s business lines, with the goal of fostering collaboration, communication, and information flow as necessary. Opportunistic Investments: Opportunistic investments generally stem from dislocations – whether companyspecific or market-based – and focus on catalyst-driven theses that involve a high level of engagement and influence with respect to the target situation. The Firm’s approach to opportunistic investing allows for flexibility across asset classes, sectors, strategies, and geographies, and while agnostic between private and public markets, is designed to earn a premium with longer duration capital. Within the private sphere, the Firm’s Opportunistic-investment strategy has included a number of pre-IPO equity deals, identifying companies that we believe are well-situated for the public markets. Opportunistic Credit: The Advisor’s Opportunistic Credit strategy flexibly targets investments across the credit spectrum, including by aiming to fill a gap in direct lending markets, where middle market financing needs are not being met by traditional lenders given elements of complexity, elevated perceived risk, or time sensitivity. The Opportunistic Credit strategy specifically targets off-the-run situations, where exposures are difficult to replicate and are generally capacity constrained. These investments are primarily in opportunities in more predictable jurisdictions, focusing on situations that require a tailored approach and are actively negotiated. Returns are achieved with no/minimal leverage, with a focus on downside protection via

collateral and creditor protections. The Opportunistic Credit strategy seeks diversification by sourcing and underwriting opportunities across different parts of the capital structure, types of instruments, strategies and sectors, such that returns are not dependent on one particular part of the credit universe. EnOne Ventures: EnTrust Global’s new venture capital/growth equity investment strategy will focus on sports, media, and entertainment (“SME”). EnOne Ventures is a collaboration between EnTrust Global and OneTeam Partners, a leading athlete-built platform that holds proprietary rights to athlete intellectual property through long-term contracts with 8 professional players associations and approximately 30,000 college athletes. EnOne Ventures will target high-growth commercial categories in the SME ecosystem, where EnTrust Global and OneTeam Partners’ collective expertise and resources can attempt to catalyze value and facilitate accretive exits. EnOne Ventures will focus on investments where athletes play a central role in product development, brand credibility, customer acquisition, and value creation across areas such as technology, consumer platforms, health and wellness, youth sports, and similar growth categories. Blue Ocean Maritime Finance: EnTrust Global’s maritime finance strategy (“Blue Ocean”) – which is part of the Firm’s broader maritime-focused Blue Ocean Group – was launched in 2016 to capitalize on the demand for alternative sources of liquidity in the sector given the retrenchment of “traditional” bank lenders. The Blue Ocean strategy focuses on private debt/direct lending opportunities in connection with small- and mediumsized companies in the maritime sector, including the origination of asset-backed financings and opportunistic purchases of such loans. The strategy also opportunistically invests in second lien, mezzanine, lease and equity structures. The Blue Ocean strategy is managed by the Firm’s Blue Ocean Team, which has a dedicated investment committee. The Blue Ocean strategy is comprised of both commingled funds and Strategic Partnerships (collectively, the “Blue Ocean Funds”). Blue Ocean 4Impact: The sole investment of Blue Ocean 4Impact fund (“BO 4Impact”) is Purus Marine Holdings LP (“Purus”), a maritime shipping company launched by the Firm. Purus owns and operates environmentally-advanced ships, with a focus on gas carriers and offshore infrastructure support vessels, and leases them to large corporate operators and end-users, in order to help enable the global maritime energy transition. Hedge Fund Solutions: The Advisor provides discretionary investment advisory services to commingled private funds of hedge funds as part of a multi-strategy platform, which includes the Firm’s Opportunistic investment strategy (“Hedge Fund Solutions”). These funds are offered primarily to institutional and private client investors. The funds are managed according to the objectives and policies described in their respective offering documents (discussed more fully in Item 8). EnTrust Global leverages an extensive network of investment partners as well as an inhouse structuring capabilities to provide a diverse range of exposures that emphasize its expertise across credit, equity, and macro strategies. Liquid Alternatives: EnTrust Global offers access to liquid alternative investment strategies through its minority interest in Alma Capital Investment Management. Founded in 2006, Alma Capital is a European-based asset management company with offices in Luxembourg, Paris, and London. Alma Capital provides liquid alternative investment options in regulated UCITS funds for European institutional investors through both an individual product and multi-manager approach, spanning alternative credit, event driven, managed futures, and global macro strategies. Consulting Arrangements. In connection with the investment activities performed on behalf of the Funds, the Advisor and its affiliates may be presented with opportunities to provide consulting, advisory or other services to companies that involve advice on capital structure, financing arrangements, restructurings and related matters. Such companies may or may not be existing portfolio company investments for a Fund. Subject to applicable law, to the extent that the Advisor or its affiliates wish to perform such consulting services on behalf of a company, any fees for such services may be paid to a Fund who has an investment in that company, used to offset management fees otherwise payable to the Advisor or its affiliates, retained

by the Advisor or its affiliates, or paid to a Fund to the extent the Advisor or its affiliates believe that such opportunity was related to other investment activities being performed on behalf of such Fund or if the Advisor or its affiliates believe that the Fund may make an investment in the company as a result of the consulting services performed. In connection with these consulting arrangements, the Advisor or its affiliates may have access to material non-public information. The Advisor will consider any impact to a Fund prior to accepting any consulting arrangement to evaluate whether such consulting arrangement would not affect trading in securities of a company held by a Fund due to the potential receipt of material non-public information. To seek to address any potential conflict of interest issues that may arise in these consulting arrangements, where a Fund has an existing investment in a company for which the Advisor or its affiliates are being retained to provide consulting services, the Advisor or its affiliates will ensure the company is aware of the pre-existing investment and will seek to ensure that any consulting advice will not be made that is adverse to the Fund’s interest. Unless otherwise noted, references herein to: (i) “Commingled Funds” shall refer to all commingled private investment funds managed by the Advisor across a range of asset classes; and (i) “Funds” shall collectively refer to the Commingled Funds and the Strategic Partnerships. The Advisor may manage other funds in the future with investment strategies that may or may not be similar to those of the Funds, including funds that make direct investments in securities, loan portfolios or other financial products. Certain of the Funds may invest all or substantially all of their assets in a master fund, and references herein to investments made, held or disposed of by such Funds shall include investments made, held or disposed of by their respective master funds. Investor transparency and communication have been a cornerstone of the Advisor’s culture since inception. The Advisor strives to be at the forefront of investor transparency and communication by providing to investors information regarding each Fund’s investments, aggregated and summarized in a clear and concise fashion, and distributed on a timely basis. These investor communications typically include not only monthly and quarterly reports regarding investment performance, but also updates regarding significant events in the financial markets and the opportunity to attend an “Investor Summit” where various fund managers and other global financial industry participants, as well as the Firm’s investment teams, discuss market views and investment strategies. In addition, the Advisor takes a proactive approach to risk management and, through a dedicated operational due diligence process, conducts initial and ongoing due diligence with respect to potential and existing underlying managers of its multi-manager funds (See Item 8). The Advisor has separate strategy-specific investment committees (the “Sub-Committees”) (see Item 8 below) and a Risk Committee that monitors and assesses operational risk across the Firm (the “Risk Committee”).

Availability of Customized Vehicles Strategic Partnerships/Separately Managed Accounts: The Advisor offers institutional clients and high net worth individuals the flexibility of investing through Strategic Partnerships, which invest directly and indirectly in one or more strategies or investments. The Strategic Partnerships, which may invest pari-passu with the Commingled Funds, may follow a strategy sub-set or may follow a differentiated investment strategy specifically tailored to suit the relevant investor’s investment objectives and guidelines. The Advisor may provide advisory services to Strategic Partnerships on a discretionary or non-discretionary basis. The Advisor may establish Strategic Partnerships, individually customized managed accounts or single investor fund structures for certain investors. Customization can assume various forms based on specific investor preferences relating to, among other things: (a) returns; (b) liquidity; (c) volatility; (d) exposure to specific investment strategies, asset classes, and/or geographies; (e) tail risk protection solutions for a strategic partner’s broader portfolio; and/or (f) middle and back office solutions. Aside from portfolio construction and composition issues, such arrangements may afford transparency through periodic calls and

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The fee structure for each Fund is set forth in the offering documents for that Fund, or in the account agreement for the relevant Strategic Partnership, as the case may be. Offshore serves as the management company of the Funds for which EnTrust Global Partners LLC or Blue Ocean GP LLC serve as general partner and, in exchange for providing certain administrative and managerial services, receives a management fee from the Funds (the “Management Fee”). The Management Fee is calculated monthly and may vary for different classes of limited partnership interests, limited liability company interests, or shares in the Funds (collectively, the “Interests”), but generally ranges from 0.10% (0.40% per annum) to 0.50% (2.0% per annum) of each limited partner’s capital account, the net asset value of a particular class of Interests, committed (but unfunded capital) or invested capital, as the case may be. In addition, the Advisor may receive an incentive fee/allocation (the “Performance Allocation”) on an annual basis (or, in some cases, quarterly or as agreed to with investors) in certain classes of Fund interests or for certain Funds, generally ranging from 5% to 20% per annum of net profits (typically 15% per annum for the Blue Ocean Funds and certain other Funds, pursuant to a waterfall rather than an annual fee, as described below). As set forth more fully in the offering documentation for a particular Fund, the Performance Allocation for Interests in some Funds is subject to hurdle rates or clawback provisions. The Performance Allocation is generally subject to the recoupment of unrecovered net losses incurred previously. For certain of the Funds (including the Blue Ocean Funds), the Performance Allocation is typically structured as a carried interest, payable after investors have received all of their capital contributions back, plus a preferred return, and subject to a catch-up for the Advisor. Investors in Funds where the Performance Allocation is charged at the overall Fund level or to a particular class as a whole should note that as equalization or series accounting is not used, the Performance Allocation will be based on the overall performance of the Fund or class of Interests, as applicable, as opposed to the specific performance of the shares held by a particular Investor. The Advisor, in its sole discretion, may waive or reduce all or any portion of the Management Fee and/or Performance Allocation for certain investors in the Funds. New Interests may also be created with different fee structures. For Strategic Partnerships, fees generally will track the range of Management Fees/Performance Allocation for the Commingled Funds depending on the amount of assets in the account or as may be negotiated. Any Performance Allocation for a Strategic Partnership will be subject to negotiation between the Advisor and the investor. In addition, the Advisor and/or Funds may, without notice to investors, enter into agreements with certain investors who, in the Advisor’s judgment, make a significant investment in a Fund, granting them, among other things, greater portfolio transparency, fee waivers or reductions, additional rights to reports or other information and other more favorable investment terms than the terms set forth in the offering documentation. The Funds have the power to create different classes of Interests for certain substantial investors and may create additional classes having different rights for the purpose of implementing such agreements. For example, such additional classes of Interests may have different voting rights, management fees or performance compensation arrangements. In offering more favorable investment terms to certain investors, the Advisor and/or Funds shall have no obligation, subject to any applicable “most favored nations” agreements, to offer such additional rights, terms or conditions to any other investors. Each Fund’s expenses are set forth in the respective offering documents for the particular Fund and may include, the Management Fee and the Performance Allocation (if applicable); fees of the Fund’s independent auditors, legal counsel and Administrator; fees for the maintenance of the Fund’s books and accounts, including license fees and costs associated with any software used to maintain the books and records of the Fund, including portfolio management, risk management and investor reporting and technology expenses; fees of any separate accountants retained for the Fund and fees paid pursuant to the

Services Agreement (see discussion below on the Services Agreement); registration, licensing and custodian fees; taxes (including withholding and transfer taxes); bank service fees; insurance premiums; organizational expenses; governmental fees, preparation and distribution of investor reports and other communications with investors and the public, the costs incurred in connection with marketing the Fund Interests (including but not limited to travel, car service, car rental and parking and lodging expenses incurred in attending conferences and related business entertainment at such conferences, and presentations with investors and prospective investors), the cost of updating the Fund’s offering documents, professional fees of consultants (including risk management and compliance consultants and, where appropriate/applicable, valuation experts, agents and ratings agencies) incurred in connection with the operations of the Fund, manager research costs and background checks, subscription fees for market data services, databases, investment data and other news to assist business development efforts and related research expenses and other due diligence tools (including travel and expenses in connection with monitoring and conducting due diligence on investments) and the costs and expenses of securing and maintaining any line of credit or liquidity facility, including interest expense and commitment fees. All travel and lodging expense reimbursements are subject to the Advisor’s Code of Ethics and its Travel & Entertainment Reimbursement Policy, which limit the types of expenses that may be incurred and provide that expenses will only be reimbursed if they are ordinary and reasonable. In addition to the fees and expenses described above, the Funds will bear, directly and indirectly, certain additional expenses, which are described in the relevant offering documentation or separately managed account agreement. Some of these expenses may include, as applicable: 

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Dealing fees for subscribing to/redeeming from the Funds – depending upon the class of Interests subscribed to and amount purchased, dealing fees, such as front end or back-end sales charges, may apply to the investor. These amounts are not typically paid to EnTrust Global but are charged and retained by financial intermediaries who offer the Funds for sale to their clients. Distribution fees – for Investors subscribing into a class of Interests of a Fund with a back-end sales charge, an ongoing distribution fee, typically up to 1% will be charged. This fee is also generally paid to the financial intermediary that made the Fund available for sale.

In addition, as discussed further in Item 12 – Brokerage Practices, the Advisor may, on occasion, buy and sell securities traded in secondary markets, including exchange traded funds (“ETFs”), open-end and closed-end funds and other securities. In these cases, investors will bear the costs and expenses (such as commissions or spreads) associated with such trading. For those expenses which relate to or which benefit one or more specifically identifiable Funds, each such expense will be allocated solely to those Funds. For those expenses which cannot reasonably be allocated to a Fund or specific Fund(s) or which benefit all Funds, the expense will be allocated across all Funds on a pro rata or other basis that is fair and equitable to all clients. Each Fund also bears a pro rata portion of the expenses of each underlying fund (where applicable) in which it invests, including the management fees and incentive fees payable to the managers of such funds. In certain cases, the Advisor has been able to negotiate more favorable fee terms than those otherwise payable by an investor in such fund. Organizational costs, including marketing expenses, incurred prior to the launch of a Fund are amortized over five years and shared by all investors in that Fund. A Fund may hold multiple closings. Marketing expenses are borne by investors from the most recent closing through the closing at which they invest, on a pro rata basis according to their respective capital commitments. Certain of the Funds have entered into or are expected to enter into a Services Agreement with the Advisor, pursuant to which certain personnel of the Advisor perform services for both the Advisor and the Funds, including accounting, legal and compliance (including but not limited to oversight of certain risk management and ancillary services). Under the Services Agreement, fees are payable by the relevant Funds

and are currently set at 10 basis points per annum of a Fund’s Net Asset Value (the “Fee”). The amount of the Fee is subject to adjustment (up or down) generally on an annual basis, subject to the sole discretion and approval of the independent board of directors for the offshore Funds, based on its assessment of the reasonableness of the Fee, taking into consideration, among other things, the cost to EnTrust Global to provide the services. The Fee is intended to be sufficient to cover the total compensation and benefit costs and EnTrust Global’s share of taxes for such personnel who typically also provide significant services to the Advisor. Services provided to any particular Fund in any given year may not be the same as provided to other Funds and, from time to time, no services may be provided to a particular Fund in a given year. Certain Funds managed by the Advisor or its investment advisory affiliates may not pay the Fee but may, nonetheless, receive the services set forth above. Investors will be notified of any change in the Fee prior to its implementation. The Services Agreement is available upon request. Certain of the Funds (who do not enter into the Services Agreement) pay a Shareholder Service Fee to the Advisor as set forth in the applicable Fund’s offering documentation. As discussed further in Item 4 – Advisory Business, as compensation for providing portfolio monitoring services to the PMAP Funds, Offshore receives an expense reimbursement or “Chargeback” from the PMAP Funds, a fixed fee currently set at 10 bps of average assets under management for each PMAP Fund investor in any year and reviewed on an annual basis by the independent Board of the PMAP Funds. The offering documents for a particular Fund, or the managed account agreement for a Strategic Partnership, specify the withdrawal terms for such Fund or account, as the case may be. In general, no withdrawal/redemption is permitted other than as set forth in such governing documents, subject to the right of the Advisor or the Fund, as applicable, in its sole discretion and without notice to other investors, to waive such requirements for investors on a case by case basis. EnTrust Global utilizes Best Alternative Advisory Services (“Best”), based in India, for support regarding Fund accounting, operations, compliance/regulatory surveillance and client reporting. Best was acquired by Apex Group Ltd., a global financial services provider. Notwithstanding the acquisition, the team of people at Best dedicated solely to the EnTrust Global business is expected to continue in that capacity and to continue to work collaboratively with EnTrust Global on a daily basis and across different business units to attempt to achieve operational efficiencies in the areas noted above. Where operating a particular Fund is, in EnTrust Global’s discretion, no longer viable, including but not limited to when operating costs have become outsized relative to the Fund’s assets, where the Fund has experienced significant redemptions, or otherwise, or where a Fund liquidates pursuant to its own terms, such Fund will be liquidated in accordance with its constituent documents. Once EnTrust Global decides to liquidate, it will endeavor to treat all investors fairly and equitably in the Fund’s wind-down. In order to do so, EnTrust Global may suspend redemptions (even redemptions already submitted) for Funds that permit redemptions, suspend payment of redemption proceeds, continue to actively manage a portion or all of the Fund’s assets, sell highly illiquid and nonmarketable positions at a loss, and take other steps consistent with its fiduciary duty. In these circumstances, EnTrust Global will attempt to provide investors with an estimated timeline regarding the payment of liquidation proceeds, which will be impacted by the nature of the underlying securities, the global markets, economic and financial conditions and other factors.

Methods of Analysis Blue Ocean Funds The Blue Ocean Funds’ deal workflow when originating loans/leases is typically a four-step process: Sourcing, Underwriting, Closing and Post-Funding. The Blue Ocean team actively assesses and closely monitors the loans/leases throughout the tenor of the loans/leases. The primary purpose of the review is to reassess and monitor the borrowers’ continuing credit quality and to conduct ongoing stress testing at the portfolio level. Reviews will typically include financial performance, covenants, collateral and liquidation analysis and a market summary. The Blue Ocean team actively monitors the financial and reporting covenants established in the loan agreements or security documents. When engaging in other types of transactions (for instance, preferred equity investments), the workflow is generally similar, but is tailored to the type of transaction at hand. The Blue Ocean Executive Committee meets to help oversee the origination, purchase, sale or other disposition (among other actions) regarding the Blue Ocean Funds’ investments. The Blue Ocean Executive Committee consists of Gregg S. Hymowitz, Chairman and Chief Executive Officer of EnTrust Global, Svein Engh, Committee Chair and Portfolio Manager of the Blue Ocean Funds, and Omer Donnerstein, Co-Portfolio Manager. The Blue Ocean Executive Committee approves investment decisions for the Blue Ocean Funds. The Blue Ocean team has grown methodically since inception through organic and inorganic means as key resources were added strategically to enhance the team’s network and industry expertise, and to provide local coverage across key end markets. In October 2021, the Blue Ocean Funds invested in and acquired the portfolio of Netherlands-based Maas Capital, a specialized equity provider in the maritime industry. This portfolio included joint ventures in varied ocean businesses such as commodity shipping and in intermodal and offshore services. The Maas Capital management company (“MC”) and the Blue Ocean Funds (through special purpose investment vehicles) entered into a Master Servicing Agreement whereby MC provides certain services to the Blue Ocean Funds, including but not limited to the sourcing of new investment opportunities and the servicing of the portfolio companies owned by the legacy Maas portfolio. In April 2024, certain of the Blue Ocean Funds invested in and completed their acquisition of Offshore Merchant Partners, an Oslo-based alternative investment fund manager in the maritime and energy industries and OMP’s investment portfolio, consisting of, among other things, investments in varied businesses focused on offshore energy and liquefied natural gas transportation. Subsequent to the acquisition, the legacy Offshore Merchant Partners investment team formed its own independent entity (“OMP”) and entered into agreements whereby OMP provides certain services to the Blue Ocean Funds, including but not limited to the sourcing of new investment opportunities and the servicing of the portfolio companies owned by the legacy Offshore Merchant Partners portfolio. OMP and an affiliate of the Advisor share office space in Oslo. All fees and terms in connection with the above agreements were negotiated on an arm's length basis. The Blue Ocean Funds noted above pay the general operating and overhead expenses incurred by MC and OMP, including in connection with their investment activities for their legacy investment portfolios and these Blue Ocean Funds, such as sourcing, diligencing, servicing and structuring of loan originations and other investment opportunities. All new transactions, whether sourced from the internal Blue Ocean team or from the MC or OMP teams must receive prior approval from the Blue Ocean Investment Committee.

Opportunistic Credit The Opportunistic Credit strategy employs a disciplined, multi-stage investment process designed to identify differentiated opportunities while maintaining rigorous underwriting standards and capital preservation discipline. Given the complex and often bespoke nature of private credit transactions, the process emphasizes thorough screening, independent analysis, structured decision-making, and committee oversight at each stage. The framework is designed to progressively narrow a broad sourcing funnel into a highly selective portfolio of investments that meet risk/return objectives. EnOne Ventures The EnOne Ventures investment process begins with an extensive global sourcing network. This network generates inbound opportunities from a wide variety of investment partners, athletes, and commercial parties. The EnOne team attempts to identify compelling, differentiated opportunities that align with the strategy’s objectives. Once opportunities are identified, rigorous financial, business, and legal due diligence are conducted. The underwriting process emphasizes deep fundamental analysis and scenario testing to assess the risk-reward profile of each investment. The team applies a disciplined relative-value lens to attempt to identify attractive risk-adjusted returns. The investment committee for EnOne Ventures consists of senior personnel of the Advisor and OneTeam Partners, the Advisor’s joint venture partner for this strategy. Hedge Fund Solutions/Opportunistic With respect to the Hedge Funds Solutions’ investment portfolios, although a particular Fund may be strategy specific or specific to a defined universe of investment strategies, the primary objective of the Advisor is to construct a portfolio of investments with consistent risk-adjusted rates of return within different non-correlated investment strategies, thereby seeking to diversify risk and down-side exposure. Position sizing is determined by the relevant Sub-Committee based on quantitative analysis, as well as information gained from feedback from investment analysts during their regular contact with underlying managers, from interaction with portfolio managers and industry investment professionals and from any macro market conditions believed to possibly impede or enhance specific strategy investment opportunities. In selecting managers for a portfolio, the Advisor does not follow a rigid asset allocation policy but instead seeks diversification through a combination of managers trading a range of strategies. The Funds are designed not only to utilize expert managers but also to deploy and redeploy investment capital within a range of investment strategies which the Advisor regards as likely to provide favorable opportunities in changing economic environments. Certain Funds may have more restrictive investment guidelines. The screening process for underlying managers includes a review of a number of different factors, the most important being: A definable investment strategy and process - Each manager must have a clearly defined investment strategy, process and methodology. Just as importantly, the Advisor verifies that the manager has consistently maintained its investment strategy throughout various market conditions. A consistent, risk-adjusted historical performance record – The Funds typically invest with managers who have historical risk-adjusted performance records of significant duration and which are uncorrelated to returns of other managers in the portfolio. Such performance records must demonstrate an ability to achieve returns during both favorable and unfavorable market cycles. Disciplined risk management techniques - Managers are also evaluated on their ability to manage risk to an acceptably low level. Each prospective manager is required to complete the Advisor’s due diligence questionnaire, which is extensive and incorporates questions related to investment strategy, exposures, concentrations, leverage, transparency and performance, as well as risk management, valuation procedures, pricing policies, cash controls and service providers. Once invested with a manager, the Advisor

regularly reviews the overall market risk exposure, hedging and other risk management techniques utilized by the manager to limit market exposure and downside risk. A commonality of financial interests – The Funds typically invest with managers who have meaningful financial commitments jointly with their clients, demonstrated by having significant amounts of their personal capital invested in their own portfolios. The members of the investment team meet regularly to discuss the allocation and sizing of particular investments, the status of investments being considered and matters concerning the investment portfolio generally. Such meetings, both formal and informal, may also include applicable members of the Legal and Compliance Team, the CCO, the Advisor’s financial controllers and other colleagues to discuss among other things, portfolio positioning, construction and risk parameters. The portfolio is reviewed regularly and rebalanced on a monthly basis.

Operational Due Diligence The Advisor takes a proactive approach to risk management and the extensive risk management procedures it has implemented are critical to, although independent of, the investment process. The exact nature of operational due diligence conducted and the amount of time devoted to operational due diligence in any particular circumstance can vary depending on a number of factors, including but not limited to familiarity with the operational infrastructure of an underlying manager and anticipated timeframe of making an investment. The Advisor has engaged an operational due diligence consulting firm (“Consulting Firm”) to assist the Advisor’s internal operational due diligence team in helping to identify and remediate operational risks. The scope of work to be conducted by the Consulting Firm will generally include, but is not limited to, meeting with underlying managers and their key personnel, evaluating their infrastructure and internal controls, helping to perform background checks and preparing operational due diligence responses. As such, references in this section to activities conducted by the Advisor also include activities undertaken by the Consulting Firm. The managers are sourced primarily from referrals from the Advisor’s network of investment professionals and existing managers. Through the interview process, the Advisor garners an in-depth understanding of the manager’s investment thesis and processes. As investment due diligence progresses, the Advisor performs in-depth operational due diligence (as set forth in more detail below). Ongoing due diligence reviews are generally conducted on existing managers approximately every 18-24 months. Operational due diligence is conducted on managers sourced for opportunistic investment opportunities, specifically as it relates to the potential investment. Investment managers generally complete an extensive due diligence questionnaire, which incorporates questions related to firm-level data, investment strategy, as well as risk management, valuation procedures, pricing policies, cash controls, cybersecurity, compliance monitoring and service providers. The Advisor will determine the scope and adequacy of the back-office infrastructure, internal controls, compliance function, valuation and pricing procedures, financial reporting, disaster recovery plans and service providers. Information obtained from the meeting, the questionnaire and other materials available is reviewed and outstanding questions are resolved via follow-up calls, meetings or e-mails. Prior to making an investment with any new manager, members of the Advisor’s team contact individuals within its network for background checks/referrals and contact the administrator and other key service providers of the underlying portfolio to confirm the relationship. The Advisor utilizes certain independent investigative firms to perform background checks on all prospective managers, which may include senior members of their management team, those with trading discretion or cash signatory authority, or who otherwise have been deemed material to certain internal controls. The decision of whether to conduct such background checks is in the discretion of the Advisor, based on the underlying manager’s control processes,

and are conducted in accordance with local jurisdictional restrictions. Decisions regarding initial Fund investments or opportunistic investments with managers and any additional capital allocations are made by the relevant Sub-Committee. Operational due diligence is not conducted on transaction counterparties in direct investing strategies such as Blue Ocean, Opportunistic Credit and EnOne Ventures. Such due diligence is conducted by the appropriate investment team (with support from service providers, as applicable) prior to making an investment.

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The Advisor’s clients are noted in response to Item 4 above. The minimum initial investment amount for the Funds (or capital commitment amount, as applicable) is set forth in the offering documentation for the particular Fund. Minimum investment requirements are subject to waiver or reduction in the sole discretion of the Advisor (subject to any requirements imposed by applicable law). For certain Funds, the Advisor may refuse to permit a partial withdrawal if the withdrawing investor’s remaining capital account balance or the value of the investor’s Interests, as the case may be, would be less than an amount set forth in the offering documentation, as applicable. In addition, each prospective investor must satisfy the accreditation requirements set forth in the offering documents of each Fund in which the Investor intends to invest. Investors in the Funds may include public, corporate and Taft-Hartley pension funds, foundations, endowments, sovereign wealth funds, insurance companies, high net worth individuals and family offices or other investors. In addition, the Advisor may provide investment advisory services to Strategic Partnerships for the benefit of such types of investors. Minimum account sizes for such accounts are subject to negotiation.

Performance Based Fees and Side-by-Side Management

The Advisor’s fee structure, including as it relates to performance-based fees, is set forth in response to Item 5 above. In general, the Funds follow the same investment strategy for each separate class of Interests within that particular Fund. Accordingly, the Advisor is not generally incentivized to favor or pursue more speculative investment strategies for those classes of Interests for which it may receive a Performance Allocation. Statement of Allocation Policy and Procedure. It is the Advisor’s policy that no Fund or other account for which the Advisor has investment discretion (collectively, “EnTrust Global Clients”) shall receive preferential treatment over any other EnTrust Global Client. In allocating securities among EnTrust Global Clients with a substantially similar investment strategy, it is the Advisor’s policy that all such EnTrust Global Clients should be treated fairly and equitably over time and that, to the extent possible, all EnTrust Global Clients with a substantially similar investment strategy should receive equivalent treatment. Investment opportunities generally will be allocated among those EnTrust Global Clients for which participation in the respective opportunity is considered appropriate by the Advisor taking into account, among other considerations: (a) the nature of the proposed investment and the size of the aggregate position available to EnTrust Global Clients; (b) each EnTrust Global Client’s investment objective and strategies and any investment restrictions applicable to the particular EnTrust Global Client; (c) whether the risk-return profile of the proposed investment is consistent with the EnTrust Global Client’s objectives, whether such objectives are considered (i) solely in light of the specific investment under consideration or (ii) in the context of such EnTrust Global Client’s overall holdings; (d) existing exposure to the proposed investment, if any, and the potential for the proposed investment to create an imbalance in the EnTrust Global Client’s portfolio; (e) liquidity requirements of the EnTrust Global Client and time horizon applicable to the particular client; (f) the EnTrust Global Client’s available cash to invest; (g) tax considerations; (h) legal and/or regulatory restrictions that would or could limit an EnTrust Global Client’s ability to participate in a proposed investment; (i)

the risk parameters for the EnTrust Global Client’s portfolio;

(j)

overall portfolio construction for the EnTrust Global Client;

(k) where a proposed investment is time-sensitive, the ability of the EnTrust Global Client to fund the investment on an expedited basis; (l)

other criteria the Advisor deems relevant (the nature and extent of the differences will vary from client to client); and

(m) the exposure of a new or recently launched Fund to a particular investment strategy. As a result of the application of these factors, allocations and performance across EnTrust Global Clients that are similarly situated will differ for particular investments or over time. Without limiting the generality of the foregoing, the Advisor may enter into investment relationships with strategic investors, for which the Advisor may exercise its discretion to offer such strategic investors certain investment opportunities on a priority basis and/or on preferential terms when such opportunities arise. In exercising such discretion, the Advisor may consider a wide range of factors, including but not limited to, one or more of the following: 

The size and financial resources of the investor, as well as its execution timing and certainty, including the ability of that investor to act as an “anchor” investor for a particular transaction;



Whether allocating investment opportunities to a potential investor will help establish or strengthen relationships that may provide indirectly longer-term benefits (including strategic, sourcing or other similar benefits); and Whether a particular potential investment party has provided value in the sourcing, establishing relationships, participating in diligence and/or negotiations for such potential transaction or is expected to provide value to the business or operations of a portfolio company post-closing



Where an investment opportunity has limited capacity and the investment is suitable for more than one EnTrust Global Client: (i) the Advisor is not obligated to cause an EnTrust Global Client that invested first to withdraw to free up capacity for another EnTrust Global Client; (ii) where two or more EnTrust Global Clients are considering the investment at the same time, the investment generally will be made pro rata based on the capital available among the participating EnTrust Global Clients for the proposed investment and on assets under management. Such pro rata allocations will also be made in consideration of the factors listed above which, as applied in any particular case, may result in one or more EnTrust Global Clients not participating in an investment, or participating in the investment but at a lower allocation percentage than the EnTrust Global Client may request or prefer, or participating at a higher than pro rata allocation percentage.

EnTrust Global is a global organization with affiliates regulated by the SEC, the U.K. Financial Conduct Authority (“FCA”), the Monetary Authority of Singapore, the Korean Financial Supervisory Commission, the French Authorité des Marchés Financiers, the Australian Securities and Investments Commission, and the Japan Financial Services Agency. In January 2020, EnTrust Global acquired a 25% interest (now 22.5%) in Alma Capital Management (“Alma”), a Luxembourg based and Commission de Surveillance du Secteur Financier regulated fund management company. The Advisor believes that this acquisition expands its ability to offer investors more liquid alternative strategies, including UCITS funds. As a large asset management firm, EnTrust Global, from time to time, provides information to various government agencies and regulators or responds to information requests, document requests, subpoenas, or requests for interviews from various government agencies and regulators. EnTrust Global Ltd. (“EGL”) is regulated by the FCA as a full service Alternative Investment Fund Manager (“AIFM”), holds an Australian Wholesale Client Exemption, and is authorized by the Central Bank of Ireland to serve as investment manager to Irish domiciled funds. EGL acts as investment manager to certain offshore products where Offshore is the sub-advisor. EGL may provide discretionary investment advisory services as investment manager to offshore private investment funds and may provide discretionary or non-discretionary advisory services in offering customized strategic alternative solutions through a multi-strategy fund of hedge funds platform or otherwise. EGL delegates day-to-day discretionary management for certain of its clients, including the EnTrust Global Funds, to the Advisor, which receives a percentage of EGL’s gross revenue with respect to these clients as a fee for its services. EGL incorporated a subsidiary, EnTGA Pty Ltd, in November 2021 which serves as a representative office of EGL for the purposes of business development in Australia and to act as EnTrust Global Ltd’s representative to market wholesale clients in the region. EnTrust Global SAS (“SAS”) is regulated by the French Authorité des Marchés Financiers, including full AIFM authorization. SAS may provide discretionary investment advisory services as investment manager to offshore private investment funds and may provide discretionary or non-discretionary advisory services in offering customized strategic alternative solutions through a multi-strategy fund of hedge funds platform or otherwise. SAS is under common control with the Advisor. EnTrust Global SAS Italia, a branch office of SAS, is based in Milan, Italy and focuses on business development in Europe. EnTrust Global SAS NUF, a branch office of SAS, is based in Oslo, Norway and focuses on the Blue Ocean strategy. EnTrust Global (Singapore) Pte. Ltd., regulated by the Monetary Authority of Singapore, provides regional business development support and is under common control with the Advisor. SaintCo Ltd., a Bahamian corporation and a subsidiary of EnTrust Global, provides directorship services for a fee to certain private investment funds in which certain investment vehicles managed by EnTrust Global invest and for which the Advisor serves as portfolio monitor. These portfolio monitoring services, for which the

Advisor is reimbursed for certain expenses, are provided in connection with the Permal Managed Account platform in which the investment vehicles are generally managed by unaffiliated third-party managers. In addition to responsibilities with respect to the management and investment activities of any particular Fund or account, senior management will have similar responsibilities with respect to various other existing and future pooled investment vehicles and separately managed accounts and will devote such time to the business of the Funds as is deemed necessary. However, additional clients or other business responsibilities at the Firm may have the effect of reducing the time devoted to the investment activities of any particular Fund. Refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss and Item 11 – Code of Ethics for a further discussion on potential conflicts of interest.

The Advisor recognizes that, as a fiduciary, it must serve the interests of its clients. The Advisor further recognizes that it must adhere to the highest standard of care and diligence in conducting its business activities and must be particularly sensitive to situations in which the interests of its advisory clients may be directly or indirectly in conflict with those of the Advisor. Compliance obligations are a priority of the Advisor and, as such, the Advisor has adopted written policies and procedures in accordance with those standards. In addition, the Advisor has adopted a Code of Ethics intended to limit or mitigate potential conflicts of interest arising from ownership of securities by the Advisor’s employees that may also be purchased or sold for advisory clients (either directly or through an underlying portfolio). The Code of Ethics may generally be summarized as a “no trading” policy, although exceptions may be made if, in the discretion of the CCO, a proposed employee investment does not present a potential conflict of interest with the Fund’s investment activities or with the Advisor’s business activities, and is not otherwise problematic. The Code of Ethics also contains guidelines and reflects expectations regarding business entertainment, gifts and the standard of conduct required of employees. The Code of Ethics is based on the notion that the Advisor’s employees must act in the best interests of advisory clients and should avoid engaging in business activities, including making personal investments, that create or appear to create a conflict of interest, and is intended to prevent and detect such conflicts or potential conflicts of interest. The Code of Ethics generally prohibits employees of the Advisor from purchasing or selling securities on a discretionary basis for their own accounts, including all securities accounts in their own name and under their control or management. This does not include accounts that hold exclusively open-ended mutual funds, exchange traded funds or notes or government securities, Bitcoin/ Ethereum and other crypto coins or tokens or other accounts over which the employee has no direct or indirect investment discretion (nor does it include the Employee Fund- See Item 8). On a quarterly basis, employees submit to the CCO or his designee attestations to confirm that they are in compliance with the policy. In addition, employees are required to provide links to such accounts that hold any “reportable” securities and complete periodic reports listing their holdings and/or transactions. The CCO or his designee reviews such reports and information on a periodic basis. The CCO may also grant exceptions to the Code of Ethics and take appropriate corrective action with respect to any violations of the Code of Ethics. Notwithstanding the foregoing, the Advisor believes that it is important that employees invest in securities that the Advisor purchases for clients and, therefore, align their interests with and share in the same investment risks and benefits as clients. Accordingly, the Advisor permits eligible employees to invest in any of its Funds. Copies of the Code of Ethics are available upon request by contacting Bruce Kahne, Global General Counsel/CCO (tel. 212.224.5548). The Advisor may determine that it would be in the best interests of one Fund and one or more other Funds to transfer an investment from one account to another (each such transfer, a “Cross Trade”) for a variety of reasons, including, without limitation, tax purposes, liquidity purposes, to rebalance the portfolios of the Funds, or to reduce transaction costs that may arise in an open market transaction. If the Advisor decides to engage in a Cross-Trade, the Advisor will determine that the trade is in the best interests of both Funds involved and take steps to ensure that the transaction is permitted under all applicable laws and regulations and is consistent with the Advisor’s fiduciary duties. In an effort to avoid any potential conflicts of interest, employees of the Advisor are prohibited from using their position at the Advisor to give to or receive from any person or company that does business with the Advisor or that the employee hopes to do business with on behalf of the Advisor, including prospective

investors, their investment consultants or representatives, a gift, favor, special accommodation or similar item of value, so frequently or of such high value as to raise a question of impropriety. Gifts and business entertainment must be consistent with customary business practices and employees are instructed that care should be taken that the entertainment or gift does not appear to be intended to unduly influence the recipient in the exercise of his or her judgment and discretion. The Advisor maintains a hospitality suite at Madison Square Garden (“MSG”) for which it pays a set annual lease payment. While the lease of the suite was initially intended to help establish and maintain business relationships, use of the suite is often made by the Advisor and its employees, employee family members and friends. Unused tickets may be donated to charity or sold. Prospective investors, investors and/or investment consultants are subject to the rules and guidelines of their own organizations, if any, regarding business entertainment. It is the responsibility of each attendee at an MSG event or participant in another form of business entertainment, not the Advisor’s responsibility, to ensure compliance with such rules and guidelines including, for example, paying their own way if required. As a general matter, if an employee of the Advisor provides tickets to an MSG event or other form of business entertainment to persons with whom he or she has professional relationships, he or she should attempt to accompany the recipient of the tickets to the event with at least some reasonable frequency. The Advisor does not generally permit employees to make political contributions, although the CCO grants exceptions in certain circumstances. In addition to the policies described above, the Advisor has adopted and implemented written policies and procedures designed to prevent the misuse of material nonpublic information by the Advisor or persons associated with the Advisor (pursuant to Section 204A of the Advisers Act), as well as the intentional spreading of misinformation or rumors intended to influence the market price of a security. The Advisor’s Insider Trading Policy explains the concepts of an “insider” and “material, nonpublic information,” contains procedures for employees to evaluate the types of information received and requires employees immediately, and prior to affecting any trade or communicating such information, to notify the CCO. The Advisor’s policies and procedures regarding the making of political contributions, social media, and insider trading, among others, are reinforced in training sessions and by the execution of quarterly employee certifications confirming compliance with such policies and procedures. Violations of the Advisor’s Code of Ethics or other policies and procedures may be addressed by various corrective measures. The nature of the corrective action will depend on the severity of the violation committed, in the judgment of the CCO, senior management, the Compliance and Conflicts Committee and, as appropriate, outside counsel. Factors to be considered in determining the appropriate corrective action may include, but not be limited to, whether investors were harmed, whether the violation was intentional, whether the incident was isolated or part of a pattern, and recidivism on the part of the employee.

For those Funds that invest in funds managed by underlying managers, the Advisor does not select brokerdealers to execute securities transactions. For Funds that may make direct investments in securities, including, but not limited to, the Blue Ocean Funds, the Opportunistic Credit Funds and EnOne Ventures, the Advisor will select broker-dealers. The CCO or his designee will periodically evaluate the nature and amount of such direct trading to determine the additional compliance obligations to be conducted regarding the necessary monitoring and oversight of such direct trading. To fulfill any applicable “best execution” obligation, the Advisor generally must execute securities transactions in such a manner that the clients’ total cost or proceeds in each transaction is the most favorable under the circumstances. In deciding what constitutes best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution. The Advisor’s direct investment business has traditionally been very limited, resulting in fewer potential options among brokers. In evaluating available options, the Advisor will take into account such relevant factors as price of the security, commission rate, the ability of the broker to handle the order, reliability and financial responsibility, confidentiality, the ability of the broker to handle execution of aggregated or volume orders and research and other services, if any, provided by such broker to the Advisor. Soft Dollars The Advisor’s current policy is not to use commissions generated by trading for client accounts to pay for third party research services. Brokerage for Client Referrals The Advisor does not use brokerage relationships for client referrals. However, the Advisor does have distribution relationships and placement agreements with broker-dealers as further discussed in Item 14 – Client Referrals and Other Compensation. Trade Errors To the extent the Advisors engage in direct trading, consistent with their fiduciary duties, the Advisors’ policy is to act with the utmost care in executing trades and allocating investments on behalf of investors. When an error is made on behalf of an investor account, the Advisors will attempt to ensure that the best interests of investors are served. The Advisors may from time to time inadvertently purchase, sell or allocate incorrectly an issue, class or number of securities. The Advisors will attempt to legally reverse or unwind trading errors in a fair and equitable manner as soon as practicable and place the account in the same position it would have been in had there been no error. Notwithstanding the foregoing, in order to achieve the goal of placing the account in the same position as it would have been in had there been no error, the Advisors may, in certain circumstances and in their discretion, utilize a different approach than as set forth above.

The Advisor has arrangements with third-party placement agents where the Advisor may compensate such agents for referring prospective investors to the Funds. Any such compensation is paid by the Advisor and not the Funds, the amount of which is negotiated by the Advisor. All such arrangements are memorialized in a written agreement subject to the prior review and approval of the CCO or his designee and in compliance with relevant anti-fraud requirements. The Advisor and/or its affiliates also have agreements in place with certain banks/financial intermediaries for the distribution of Funds domiciled outside the U.S. to investors (predominantly non-US) of such banks/financial intermediaries. This forms part of EnTrust Global’s global fund distribution network worldwide. Any compensation paid by EnTrust Global to these financial intermediaries is generally paid by the Advisor or its affiliates out of the investment management fee received from the Funds. The Advisor has also engaged third-party solicitors to market its services and such solicitors may receive a fee based on the average net asset value of a referred Investor’s account. Any such arrangement is disclosed to the relevant investor. The Advisor pays the solicitors’ fees directly and the investor is not subject to any increased or additional fees nor will the use of a solicitor, if any, be a factor in fee negotiations.

There are no legal or disciplinary events believed to be material to a client’s evaluation of EnTrust Global.

Review and Monitoring of Underlying Managers Mr. Hymowitz and the Advisor’s investment analysts monitor positions of underlying managers on a regular basis and contact managers frequently to discuss, among other things, strategy developments, market outlook and current thinking. Meetings are held periodically with managers as appropriate. One of the Advisor’s key investment criteria is transparency, and the Advisor’s investment team has established relationships with underlying managers such that there is ongoing communication concerning specific investment ideas, their market views/opinions and business issues in order to gain a better sense of their outlook regarding the general investment environment. The Advisor requires managers to comply, at a minimum, with regular, basic exposure requirements that portray an accurate snapshot of the portfolio. The Advisor typically receives performance updates from underlying managers on a monthly or quarterly basis, in addition to updates that are part of ongoing communication. Additionally, the Advisor generally (although not in all cases) receives exposure reports, risk management reports and a listing of the largest positions, both long and short and, where available, full position reports. The investment team reviews and analyzes this data and, in instances where there are divergences from customary trading, unusual position sizes, or types of securities, members of the investment team will speak with the underlying managers to understand the underlying reasons for them. The effects of any divergences are monitored closely and members of the investment team remain in direct contact with the managers. In addition, the Advisor takes a proactive approach to risk management and, has instituted extensive risk management procedures which pervade all aspects of the initial and ongoing due diligence process as it relates to the selection and monitoring of underlying managers, including through the activities of the operational due diligence team. The Advisor uses internally and externally developed systems to monitor risk on both the individual manager level as well as the fund of funds level. Model portfolios of managers and strategies are constructed within varying parameters, and these model portfolios are measured for correlations, risk and performance. The models are employed to analyze how the prospective fund would optimally impact the relevant portfolio vis-à-vis correlation, volatility and performance.

Investor Communications The Advisor strives to provide investors with a high level of transparency by generally providing a variety of communications on a timely basis. A summary of these communications (depending on the particular Fund, the timing and frequency of reports may vary) is set forth below: Performance Update - On a monthly or quarterly basis, depending on the Fund, investors receive a preliminary performance summary. NAV Statement - Additionally, the independent administrator(s) for the Funds sends a monthly NAV statement (quarterly for the Special Opportunities and Blue Ocean Funds) including the value of the Interests and account balance. Investor Summit - An Investor Summit meeting is generally held each year to give investors a chance to hear discussions regarding market views and investment strategies among various fund managers, other global financial industry participants and the Firm’s internal maritime, Opportunistic Credit and EnOne Ventures investment teams. Performance Summary - On a monthly or quarterly basis, depending on the Fund, investors receive a written performance summary, which may include, depending on the Fund, information such as detailed

performance and portfolio exposure information, including underlying manager allocations and strategy exposures. Market Developments Summaries – The Advisor provides investors with a written summary of newsworthy market developments as they occur and invites investors to ask questions concerning such developments. Such summaries were provided, for example, regarding newsworthy events such as the 2008 credit crisis, the 2020 global pandemic, President Trump’s imposition of tariffs in 2025 and the conflicts in Ukraine and Iran. Website - The Advisor also makes available to Fund investors and distributors certain information on a password-protected portion of its website (www.entrustglobal.com). This information generally includes: Funds’ monthly balances and monthly performance of the Funds and underlying investments, fund updates, and the like.

The Advisor may be deemed to have custody of client assets as a result of serving as general partner or investment manager of the Funds and the Blue Ocean Funds. The Advisor generally complies with the custody requirements of the Advisers Act by providing GAAP-compliant audited financial statements for the Funds to their respective clients within the required time period following the end of the fiscal year. Additionally, SAS 99 requires auditors to plan and perform their audit to obtain reasonable assurances about whether the financial statements are free of material misstatements, whether caused by error or fraud. Investors in the Funds receive account statements directly from the independent administrator for those Funds. Investors should carefully review all account statements they receive. The Advisor may also be deemed to have custody of some or all the assets of clients if one or more of the following apply:    

the Advisor or an affiliate serves as managing member for client portfolios organized as an LLC; employees of the Advisor or an affiliate serve on the Board of Directors for client portfolios organized as corporate entities; clients are invested in special purpose funds; or employees of the Advisor or its affiliates are authorized to move cash to pay expenses or open accounts on behalf of the clients.

Assets of these Funds are custodied with an independent third-party custodian by registering the ownership of each underlying portfolio in which these Funds invest with the custodian for the benefit of these Funds.

The Advisor exercises investment discretion in managing the Funds, which relationship is established through offering documents, Strategic Partnership agreements, investment management agreements or equivalent documentation with respect to the relevant Fund. In exercising discretion, the Advisor will observe the investment policies, limitations and restrictions imposed by the relevant Fund. In the case of a Strategic Partnership, discretionary authority is set forth in the Strategic Partnership agreement, which the client may limit as set forth in that agreement. Under certain circumstances, the Advisor may only provide non-discretionary or advisory services to a client.

Proxy Voting

In providing investment advisory services to the Funds, the Advisor generally does not vote proxies with respect to the securities held by the underlying portfolios. Proxies are typically voted by underlying managers in accordance with their proxy voting policies. From time to time, the Advisor may receive requests for consent from underlying managers with respect to the underlying portfolios managed by such managers in which the Funds invest. All such requests are evaluated by the Global General Counsel or his designee, and outside counsel will be consulted as necessary, with respect to whether providing such consent: (i) is in the best interest of the Fund; and (ii) raises any potential conflict of interest with respect to the Advisor’s/Fund’s relationship with such underlying manager or portfolio. At all times, the Advisor will be guided by a determination based on the best interest of the Funds. The Advisor will view proposals as being in the best interests of the Fund and generally will vote in favor of proposals that:     

maintain or strengthen the shared interests of Fund investors and management of the underlying portfolio; increase shareholder value; maintain or increase shareholder influence over the underlying portfolio’s board of directors and management; maintain or increase the rights of shareholders generally; and allow the underlying manager to take advantage of investment opportunities believed to be attractive.

Votes generally will be cast against proposals having the opposite effect, or proposals that increase fees, restrict liquidity or increase risk in an inappropriate or unacceptable manner. With respect to Funds that make direct investments in securities and the Blue Ocean Funds, as applicable, the Advisor will also vote proxies guided by a determination based on the best interest of the Funds. The Advisor may elect to not vote on routine, non-contested matters when the costs (including indirect costs or restrictions) exceed the potential benefit of the vote. The Advisor will abstain from voting proxies when the Advisor believes it is appropriate. These procedures are designed to ensure that proxies are voted in an appropriate manner and should complement the Advisor’s policies and procedures. In exercising its voting discretion, the Advisor shall identify and avoid any direct or indirect conflict of interest raised by such voting decision and will resolve such conflicts before voting. Such conflicts of interest may result from any personal or business relationship between the Advisor, its employees or affiliates, and the underlying manager. In such circumstances, prior to voting, the Advisor will present the matter to the Compliance and Conflicts Committee for a determination. If the conflict is not material, the Committee may determine the manner in which the proxy is voted. In the case of a material conflict, the Committee may direct the Advisor to submit the matter to the Fund’s investors for a determination. If the investors consent or fail to respond within a reasonable time, the Advisor will vote the proxy as described above. If a majority of investors object to the Advisor’s proposed vote response, the proxy will be voted according to the investors’ direction. Alternatively, the Advisor may, in lieu of pass-through voting, elect to vote the interests held by the Fund in the same manner as other investors (i.e., in the same proportion as the “yes” and “no” votes provided by other investors in the underlying portfolios). In all cases, the Advisor will evaluate the facts and circumstances specific to the Funds before deciding whether and how to vote.

The Advisor will evaluate its proxy voting policy on an ongoing basis to determine whether any policy change is warranted.

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