Fairmount Funds Management LLC

Fairmount Funds Management LLC, a Delaware limited liability company (“Fairmount” or the “Firm”), was founded by Peter Harwin and Tomas Kiselak, the principal owners of the Firm (the “Managing Members”) in August 2016. The Managing Members are responsible for the Firm’s daily management and portfolio selection. Fairmount Healthcare Fund II GP LLC, Fairmount Healthcare Co-Invest III GP LLC, Fairmount Healthcare Co-Invest IV GP LLC, and Fairmount Healthcare Co-Invest V GP LLC, all Delaware limited liability companies (the “General Partners”), are affiliated with the Firm and owned by the Managing Members. Fairmount provides discretionary investment management services to qualified investors through its privately placed pooled investment vehicles (the “Funds”): (i)

Fairmount Healthcare Fund II LP (“Fairmount Healthcare Fund II”) and Fairmount Healthcare Feeder Fund II LP (“Offshore Fund II,” and together with Fairmount Healthcare Fund II, the “Partnerships”); and

(ii)

Fairmount Healthcare Co-Invest III LP (“Co-Invest III”), and Fairmount Healthcare Co-Invest IV LP (“Co-Invest IV”) and Fairmount Healthcare Co-Invest V LP (“Co-Invest V,” and together with Co-Invest III and Co-Invest IV, the “CoInvest Vehicles”).

The Partnerships are organized in a master-feeder structure, with Offshore Fund II investing substantially all its capital in Fairmount Healthcare Fund II. The Funds are open only to certain financially sophisticated and high net-worth individuals and entities, as more fully discussed in Item 7. Fairmount Healthcare Fund II, Offshore Fund II, Co-Invest III, Co-Invest IV, and Co-Invest V limited partners are collectively referred to herein as the “Investors” where applicable. Fairmount tailors its advisory services to the objectives of the Funds, not to the individual needs of any Investor. The terms and investment objectives and strategies applicable to the Funds are set forth in their respective confidential private placement memoranda, or similar documents, provided to Investors prior to the time of their investment. Fairmount has broad and flexible investment authority with respect to the Funds. Fairmount manages investments primarily focused on the healthcare and life sciences sector, including companies developing drugs, devices, diagnostics, services, and healthcare IT. Portfolio investments are generally comprised of common stock, preferred shares, warrants, options, baskets of securities, exchange-traded funds, restricted shares, contingent value rights, and interests in privately held companies (including companies formed by the Fairmount or an affiliate) or investments in other assets related to drug discovery and development. The Firm focuses on small and mid-size market capitalization companies and may invest long and/or short, with the discretion to hedge some or all of its positions. As of December 31, 2025, Fairmount managed approximately $5,600,000,000 in client assets, all of which were managed on a discretionary basis. Information about the Funds presented in this Brochure is indicative of Fund terms and practices. Fund interests are offered to eligible investors only through their respective confidential offering memoranda and other offering and governing documents, which should

be read in their entirety prior to investment. This Brochure is not an offer of interests in any Fund.

Management Fee With respect to the Partnerships, Fairmount receives a management fee of 1.25% per annum based on the net asset value attributable to each Investor’s capital account. Management fees are paid quarterly in advance and are directly deducted from Investor accounts. The management fees are calculated independently by the Partnerships’ administrator and reviewed by Fairmount’s Chief Financial Officer. Fairmount may, in its discretion, waive, reduce, or rebate management fees with respect to certain Investors, including affiliates of the General Partners or Fairmount. No such waiver, reduction, or rebate will entitle any other Investor to similar treatment. Fairmount does not receive a management fee in connection with its management of CoInvest III, Co-Invest IV, or Co-Invest V. Additional Fees and Expenses The Funds pay certain specific and customary expenses, including those detailed in their respective governing documents and agreements. These expenses typically include: (i) fees, costs, and expenses relating to attorneys, accountants, advisers, consultants (including sourcing, operating, research, industry expert, and other subject-matter consultants, as well as scientists and engineers), administrators, custodians, depositaries and paying agents, domiciliation agents, valuation experts, and data providers (including related systems, services, data management software, and information technology incorporated into the cost of obtaining such data); fees for temporary or long-term personnel or consultants engaged by Fairmount, including strategic advisors, senior advisors, and similar professionals who are not Fairmount employees but may be employees of portfolio companies or other entities in which a Fund invests); and fees relating to audit and certification, preparation and distribution of Investor reports, maintaining accounts, calculating net asset values, processing subscriptions, and Investor communications; (ii) fees payable to any placement agent engaged pursuant to local legal or regulatory requirements in connection with the offering of Fund interests outside the United States; (iii) brokerage commissions, prime brokerage fees, custodial expenses, other bank service fees and other investment costs, fees and expenses; (iv) expenses associated with auditing; (v) trade support services, including, pre- and post-trade support software and related services (including any and all fees, costs and expenses of any investment, books and records, portfolio compliance and reporting systems such as Bloomberg terminals, including consultant, software licensing, data management and recovery services fees and expenses) and data services providing price feeds, news feeds, security and company information and company fundamental data; (vi) risk analysis, risk reporting, and risk-related and consulting services provided by third parties; (vii) fees of providers of specialized data or analysis related to portfolio companies and the sector and asset classes in which a Fund has made or intends to make investments; (viii) research and technology expenses (including newswire, quotation services, publications, periodicals, subscriptions, database services, data processing related to research activities, and other information services); (ix) expenses associated with Investor communications and reporting (including annual information sessions or meetings and the maintenance of a website or other investor portal); (x) investment-related travel expenses (including transportation, lodging, internet access fees, international cellular charges, out-of-office meals, and other similar expenses); (xi) fees, costs, and expenses incurred in developing, bidding on, evaluating, investigating, negotiating, financing, refinancing, structuring, obtaining regulatory approvals for, purchasing, trading, clearing, settling, monitoring, maintaining custody of, holding and

disposing of investments, whether or not consummated, including due diligence, valuation, financing, legal, accounting, advisory, and consulting expenses, costs related to proxy contests (including professional fees); foreign exchange and other currency transaction costs; insurance, indemnity, litigation, investigation, and similar expenses; and any expenses related to short sales; (xii) expenses associated with withdrawals, redemptions, distributions, admissions, issuances and transfers of Fund interests (including preparation of any form transfer agreements); provided that the applicable transferor/transferee shall bear the material costs of any such transfer; (xiii) expenses associated with the acquisition, holding, monitoring, and disposition of investments, including brokerage, trading, custody, and hedging costs, commissions, and similar expenses incurred in connection with receiving, buying, selling, exchanging, trading, and otherwise dealing in securities and other Fund property (including expenses relating to spreads, short dividends, negative rebates, financing charges, currency hedging costs, and temporary investments); (xiv) interest and other expenses incurred in respect of a Fund’s borrowings, guarantees and other financing arrangements; (xv) costs and expenses of any lenders, investment banks and other financing sources; (xvi) fees, costs and expenses associated with a Fund’s financial statements, reports, notices, tax returns and Schedule K-1s (or similar schedules), including any related audits and the costs of preparing, translating, and distributing such materials (whether by a Fund, any affiliate or any service provider or agent engaged in connection therewith); (xvii) out-of-pocket fees, costs, and expenses incurred in connection with a Fund’s legal, tax, and regulatory compliance with applicable U.S. federal, state, local, non-U.S., or other laws or regulations, including compliance with the rules of any self-regulatory organization; entity-level taxes (including withholding taxes to the extent not allocable to specific Investors or capital accounts) and governmental fees or charges payable by, with respect to, or levied against a Fund or its investments, including real estate, stamp or other transfer taxes; expenses related FATCA compliance; wind-up and liquidation expenses; and fees and expenses related to regulatory filings, including reports filed with the SEC or CFTC, state or national securities authority disclosures, filings, and notifications, and a Fund’s pro rata share information, technology, communication, research, and reporting costs (including internally allocated charges) utilized for the benefit of such Fund; provided that, for the avoidance of doubt, filing fees and expenses related to the preparation and filing of Form ADV and Form PF are excluded; (xviii) fees, costs, and expenses related to the organization, maintenance, and operation of any special purpose vehicle or other intermediate entity established for a Fund’s investment purposes, including related travel and accommodation expenses; (xix) out-of-pocket costs and expenses incurred by or on behalf of a Fund or any special purpose vehicle, or in anticipation of or to facilitate a potential co-investment, in connection with developing, bidding on, negotiating, or structuring a prospective investment that is not ultimately made or a proposed disposition that is not ultimately consummated (“Broken Deal Expenses”), including: (A) legal, accounting, advisory, consulting, and other third-party expenses and related travel and accommodation expenses; (B) fees (including commitment fees), costs, and expenses of lenders, investment banks, and other financing sources in connection with arranging financing for a proposed investment that is not ultimately made; (C) forfeited deposits or down payments of cash or other property; and (D) broker fees and expenses (including retainers and advancement of expenses), in each case to the extent not reimbursed by a portfolio company or other third party; provided that Fairmount shall use commercially reasonable efforts to cause applicable co-investors to bear their attributable share any Broken Deal Expenses associated with the potential co-investment; (xx) expenses of reorganizing (including in connection with an initial public offering, merger, consolidation, acquisition, transfer of assets, tender offer, exchange offer, recapitalization, liquidation, or similar transaction), reconstituting, recapitalizing, restructuring, winding up, or liquidating a Fund, any special purpose vehicle, or any other entity established for a Fund’s investments, including related third-party fees and expenses, and any broken deal costs associated therewith; (xxii) fees, costs, and expenses associated with Investor meetings; (xxiii) premiums and other costs of

directors and officers liability insurance and any other insurance maintained by Fairmount in its capacity as investment manager; (xxiv) fees, costs, and expenses relating to the maintenance of registered offices, corporate licensing, and similar matters; (xxv) fees, costs, and expenses incurred in connection with any amendments, modifications, or restatements of the constituent documents of a Fund or any special purpose vehicle; (xxvi) extraordinary expenses, including indemnification costs, litigation expenses, and the cost of any proceedings, actual or threatened, in which Fairmount, its affiliates, or their respective members, partners, directors, officers, employees, legal representatives, or persons formerly serving in such capacities are involved as a party or otherwise, arising out of or in connection with such person’s service to or management of the affairs or capital of a Fund, including any judgements or settlements paid in connection therewith. The Partnerships also pay expenses incurred in connection with negotiating and complying with the provisions of any side letters, including administering “most favored nations” provisions. Expenses relating specifically to a Designated Investment (as defined in the Partnerships’ offering documents) are charged pro rata against the capital accounts of those Partnership Investors participating in such Designated Investment. Accordingly, expenses related to Designated Investments are not necessarily allocated pro rata among all Partnership Investors, as allocations reflect each Investor’s level of participation. A portion of a Fund’s expenses may be shared with other investment entities or accounts managed by the Firm, General Partners, or any of their respective affiliates and will be allocated among such entities in a manner determined by Fairmount to be fair and equitable. Certain expenses deemed attributable solely to particular Investors will be allocated to those Investors. Similarly, expenses reasonably deemed attributable solely to the Partnerships and/or one or more Co-Invest Vehicles will be allocated to the Partnerships and/or the applicable Co-Invest Vehicle(s). Fairmount does not receive brokerage commissions or any other compensation in connection with the sale of securities or investment products, and its personnel similarly do not receive such compensation.

Risk of Loss Investment Objective Fairmount employs a long-only, event-driven diligence process, primarily focused on healthcare and life science companies, including companies developing drugs, devices, diagnostics, services, and/or healthcare IT. As founders, operators, and investors, the Firm seeks to identify biotechnology investments at their earliest stage of material de-risking, with the goal of building a concentrated portfolio of best-in-class commercial and research enterprises. The Firm’s investment universe is comprised of public and private biotech companies, as well as the creation of compelling new opportunities through Fairmount’s drug discovery and company formation efforts. Investments will likely be comprised of a combination of common stock, preferred shares, warrants, options, baskets of securities, exchange-traded funds, restricted shares, contingent value rights, and investments in privately held companies. Such privately held companies can include companies formed by Fairmount to facilitate investment in, for example, intellectual property rights relating to unique therapeutic concepts. The Firm generally focuses on small and mid-size market capitalization companies and will predominantly focus on long investments with the ability to engage in shorting and hedging where considered necessary or desirable in its discretion. Fairmount Healthcare Fund II’s investment objective is to outperform the NASDAQ Biotechnology Index (NBI) rounded to the nearest 0.01 in various market conditions. For the avoidance of doubt, the NBI is not a total return index and does not consider the reinvestment of dividend returns. There can be no assurance that the investment objectives of any of the Funds will be achieved, and certain investment practices (e.g., the use of leverage and short sales) may, in some circumstances, increase any adverse impact to which the investment portfolio may be subject. The specific risks of each Fund are described more fully in their respective governing documents. There are limitations inherent to all descriptions of investment strategies, techniques, and risks due to the complexity and subjectivity of such processes. New Company Formation As part of its investment research activities, Fairmount identifies assets that meet the threshold for clinical trial “success” but have identifiable flaws that could be remedied with existing technology. Where Fairmount believes that addressing such flaws would result in a target product profile with a meaningful commercial advantage over the incumbent, Fairmount may seek to (i) acquire or in-license a superior drug candidate or (ii) develop a superior drug candidate internally or through Paragon Therapeutics, Inc., a discovery engine and incubator for best-in-class biologics formed by Fairmount in 2021. If (i) the acquisition or in-licensing transaction is effectuated or (ii) proof of concept is validated, the resulting drug candidate could serve as the foundational asset for a new Fairmount-founded company. In certain cases, Fairmount may offer co-investment opportunities in connection with the launch of a new company. Investment Process Fairmount employs a rigorous due diligence process utilizing both internal and third-party tools, including management interviews, consultations with key opinion leaders in medicine and drug development, datasets and analysis from third-party research providers, and sell-side research. The Firm periodically commissions proprietary surveys or datasets and engages consulting or

research firms to validate its investment theses. Where significant capital is deployed, Fairmount’s employees or representatives may secure an appointment or be elected to the board of directors of the entity in which the Funds invest. Such positions may limit the actions such employee or representative may take on behalf of the Funds or require decisions that are not solely in the interests of the Funds. Any net compensation received for board service at a portfolio company held in the Funds is for the sole benefit of the Fund in which the portfolio company is held and not for the benefit of the individual employee. Drug development typically requires multi-year time horizons, and certain assets or instruments may require extended periods of time to reach valuations that merit disposition. While the strategy does not necessarily result in reduced trading liquidity, Fairmount expects it to produce low portfolio turnover. Fairmount pursues an opportunistic strategy in which entry into positions — either directly or through new company formation — may depend on drug development milestones or corporate events occurring at unpredictable times and generating material price movements in underlying securities. Fairmount believes that to take advantage of the material price moves following these events, the Partnerships need to maintain adequate cash reserves to facilitate (i) purchases of securities or (ii) the rapid launch and financing of a new Fairmount-founded company following these events. Accordingly, new capital is typically deployed over an extended period of time in anticipation of these discreet events. Risk of Loss The Funds are deemed to be a speculative investment and are not intended as a complete investment program. The Funds are designed only for sophisticated persons who are able to bear the risk of and an investment in the Funds. No assurance can be given that any investment implemented by Fairmount will be successful and, because of the speculative nature of the Funds’ investment and trading strategy, Investors may suffer a significant loss of their invested capital, including loss of the entire investment. The following list of risk factors is not a complete explanation of all the risks associated with an investment in the Funds. Investors should read this Brochure and any organizational or offering documents before determining whether to invest with us. Fairmount strongly encourages potential Investors to carefully consider and to consult regarding the same with their professional advisors, as they deem necessary. Certain Risks Relating to Investment Strategy Investment and Trading Risk Generally An investment in the Funds involves a high degree of risk, including the risk that the entire amount invested may be lost. No guarantee or representation is made that the Funds’ investment program will be successful. Fairmount will be investing the Funds’ assets in securities, some of which may be particularly sensitive to economic, market, industry, regulatory and other variable conditions. The markets in which the Funds expect to invest have historically experienced significant volatility and losses. No assurance can be given as to when or whether adverse events might occur that could cause immediate and significant losses to the Funds. Concentration of Investments The Funds invest primarily in publicly held healthcare and/or life sciences companies and certain in privately traded companies. Furthermore, historically, a majority of the Funds’ investments

have been concentrated in a limited number of long investments (excluding temporary investments and securities used to hedge the Funds’ portfolios) and it is expected that the Funds’ portfolio will continue to be concentrated in the future. The result of any such limited diversification and/or concentration is that a loss in any category or position could have a material adverse impact on the Funds’ capital. Because the Funds’ investments are generally limited to the healthcare and life sciences sector, their investments will become more susceptible to fluctuations in value resulting from adverse business or economic conditions affecting the healthcare and life sciences sector. The Funds will also be susceptible to losses disproportionate to market movements in general if there are disproportionately greater adverse price movements in the healthcare and life sciences sector. Event Driven Transactions Fairmount invests in securities whose market value is expected to be meaningfully affected by future events. These outcomes are, by definition, uncertain, and Fairmount’s investment decisions will be based on its assessment of whether the current market price accurately reflects the probability of particular outcomes. The Firm will need to forecast the likelihood of the events underlying its investment decisions and analyze the probable impact if such events occur. If an anticipated event does not occur or is delayed, the market price of the relevant securities could decline, resulting in losses to the Funds. In certain transactions, the Funds may not be hedged against market fluctuations unrelated to the anticipated event that nonetheless affect the value of the consideration to be received. This could result in losses even where the event occurs and its outcome is favorable to the position. Additionally, the short-term market reaction to a particular outcome may be adverse even where the long-term result is favorable. Healthcare and Life Sciences Sector Risk Fairmount invests primarily in the healthcare and life sciences sector. Many companies in this sector are unprofitable, lack products approved for market, and present substantial investment risks, including: (i) limited operating histories; (ii) scarcity of management and marketing personnel with appropriate scientific or medical training, which may impede growth; (iii) patents and product litigation; (iv) product obsolescence; (v) changes in government policy or regulation; (vi) shifts in investor sentiment towards the sector; (vii) broad equity market volatility that disproportionately affects healthcare and life sciences securities; (viii) challenges in securing intellectual property protection across medical devices, diagnostics, pharmaceuticals, and biotechnology; (ix) extensive regulatory oversight; and (x) difficulty obtaining FDA approval. Competitive Landscape. The healthcare and life sciences industry is generally dominated by large multinational corporations with substantially greater financial and technical resources than the companies in which Fairmount invests. These larger competitors may be better positioned to navigate rapid scientific, regulatory, and technological change, as well as evolving government and third-party reimbursement policies. Rapidly Evolving Nature of the Healthcare and Life Sciences Sector. The markets for many healthcare and life sciences products and technologies are rapidly evolving and, in some cases, are only beginning to develop. Several risks are characteristic of markets defined by rapid change and frequent new product and service introductions. First, public markets for healthcare and life sciences companies remain volatile. Market conditions may adversely affect the development of portfolio companies and the market value of the securities they issue. Second, products and technologies may become obsolete due to the pace of technological change, uncertain levels of demand

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As previously described in Item 4, Fairmount’s clients are the Funds. With respect to the Funds, any initial and additional subscription minimums are described in the relevant offering documents and may be waived or modified by Fairmount or its affiliates. The Funds are open only to certain financially sophisticated investors who meet eligibility criteria.

Management Incentive Allocation In addition to the management fees described in Item 5, the General Partner is entitled to receive performance-based compensation from the Partnerships. Fairmount may, in its discretion, waive, reduce, or rebate performance-based compensation with respect to certain Investors, including affiliates of the General Partner or Fairmount. No such waiver, reduction, or rebate will entitle any other Investor to similar treatment. Performance-based compensation arrangements create an incentive for Fairmount to recommend investments that are riskier or more speculative than those it might otherwise recommend under a different fee structure. Such arrangements also create an incentive to favor Funds subject to performance-based or higher fees over other Funds in the allocation of investment opportunities. Fairmount has adopted and implemented Trade Allocation and Aggregation procedures reasonably designed to ensure that all Funds are treated fairly and equitably and to mitigate this conflict of interest in the allocation of investment opportunities among Funds. Co-Investment Opportunities Fairmount may, in its discretion, offer co-investment opportunities in certain Partnership investments to: (i) certain Investors and/or their respective affiliates; (ii) other investment funds, managed accounts, joint ventures, proprietary accounts, or other accounts managed or advised by Fairmount or its affiliates; or (iii) affiliates of the General Partners or Fairmount, or other third parties that the General Partners or Fairmount believe may benefit the Partnerships or a particular investment. Co-investment opportunities are made available when Fairmount determines that, while it is in the best interests of the Partnerships to acquire the full amount of a particular investment (as opposed to not making the investment), it is nonetheless in the best interests of the Partnerships — due to diversification, portfolio management, leverage management, investment profile, risk tolerance, exposure guidelines or limitations, cash flow, or other considerations — for the Partnerships to acquire or otherwise hold less than the full economic exposure to that investment. Co-investment opportunities may or may not give preference to Investors who have made commitments above a specified threshold. Such opportunities may be offered at the same time and on the same terms as the Partnerships’ primary investment, or at different times or on different terms. With respect to the Co-Invest Vehicles, Fairmount is entitled to receive carried interest based on net profits, after a full return of capital to investors and subject to a preferred rate of return. Fairmount may, in its discretion, waive, reduce, or defer carried interest with respect to certain Investors, including affiliates of Fairmount. No such waiver, reduction, or rebate will entitle any other Investor to similar treatment. Please see Item 12 for a discussion of Fairmount’s allocation methodology.

Neither Fairmount, nor any of its affiliates, is registered or has an application pending to register with the SEC as a broker-dealer. Neither Fairmount, nor any of its affiliates, is registered or has an application pending to register as a futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of the foregoing entities.

Transactions, and Personal Trading Fairmount’s Code of Ethics (the “Code”) is designed to meet the requirements of Rule 204A-1 of the Advisers Act. The Code applies to Fairmount’s Access Persons. “Access Persons” include, generally, any partner, officer, or director of Fairmount and any employee or other supervised person of Fairmount who, in relation to the Funds, (1) has access to non-public information regarding any purchase or sale of securities, or non-public information regarding securities holdings, or (2) is involved in making securities recommendations, or has access to such recommendations that are non-public. All Fairmount employees are deemed to be Access Persons, as well as certain affiliated employees/consultants as determined by the Chief Compliance Officer. The Code sets forth a standard of business conduct for Fairmount and requires Access Persons to place the interests of the Funds above their own interests and those of the Firm, and to comply with all applicable laws and regulations. Access Persons are also required to promptly report any violations of the Code to the Chief Compliance Officer. All Access Persons receive a copy of the Code and must acknowledge receipt upon hire and annually or upon any material amendment to the Code. The Code also establishes reporting and pre-clearance requirements governing personal securities transactions by Access Persons. Under the Firm’s personal trading policies, Access Persons are generally prohibited from transacting in the securities of any issuer in the Healthcare sector, including synthetic instruments that provide exposure to such issuers. Notwithstanding the foregoing, Access Persons may retain Healthcare securities acquired in the following circumstances: (i) prior to their employment by or association with Fairmount; (ii) prior to the implementation of the current applicable prohibitions; (iii) through an Access Person’s investment in a private co-investment vehicle offered by the Firm; and/or (iv) as part of an Access Person’s compensation in connection with the launch of a Fairmount-founded company. Access Persons seeking to divest such retained positions must obtain the prior written consent of Chief Compliance Officer. Access Persons are permitted to transact in securities outside of the Healthcare sector provided they obtain preclearance from the Chief Compliance Officer prior to executing any such transaction. Preclearance is generally valid until the close of trading on the day it is granted, or, if approval is granted after the close of trading, until the close of the following trading day. The Chief Compliance Officer may extend the applicable trading window if circumstances warrant. Access Persons are generally prohibited from participating in IPOs and must obtain Chief Compliance Officer preclearance prior to investing in any private placement or private fund. Within ten (10) days of becoming an Access Person, each Access Persons must provide the Chief Compliance Officer with a complete list of their personal securities accounts and an initial holdings report. Access Persons must also submit securities holdings and transaction reports on a quarterly basis. Employees, their affiliates, and relatives may make investments in the Funds. Such investments may present a conflict where an employee is positioned to trade in a manner that could adversely affect the Funds (for example, by placing personal trades before or after Fund trades are executed in order to benefit from resulting price movements). As noted above, Fairmount has adopted a personal trading policy designed to minimize such conflicts. Without the consent of a majority in interest of the limited partners of the relevant Partnership, Fairmount shall not cause the Partnerships to invest in any privately held

company in which the Managing Members, the General Partners, or their respective affiliates hold an investment; provided that a Partnership may invest in companies that the Managing Members, the General Partners, or their respective affiliates are invested (i) alongside Investors through a Co-Invest Vehicle or other similar alternative investment vehicle (each a “Permitted Vehicle”) or (ii) prior to such Managing Member’s, General Partner’s or affiliate’s employment by or association with the Firm. Additionally, without the consent of a majority in interest of the limited partners of the Partnerships, the Managing Members, the General Partners, and their respective affiliates shall not invest in the securities of any company in which a Fund is invested, other than through their indirect interests in the Partnerships or any Permitted Vehicle, unless such Managing Member, General Partner, or affiliate acquired such securities prior to their employment by or association with the Firm. While Fairmount endeavors to provide all investors with equal information, it may from time to time, in response to questions and requests and in connection with due diligence meetings and other communications, provide certain prospective and existing investors in the Funds with additional information that other prospective or existing investors do not receive through ordinary-course reporting. Prospective and existing investors may request additional information, though Fairmount retains the discretion to decline some or all such requests. In either case, such information could affect an investor’s investment or redemption decisions. Each prospective and existing investor is responsible for asking such questions as it deems necessary to make its own investment decision and must determine for itself whether the limited information Fairmount provides, and the Funds themselves, are or will be sufficient for its needs. Fairmount will provide a copy of the Code to current Investors, or any prospective investor or client, upon request. A request may be made by contacting the Firm’s Chief Compliance Officer, Erin O’Connor, at 267-262-5300 or eoconnor@fairmount.com.

Fairmount is authorized to select the broker-dealers and other counterparties used for executing securities transactions for the Funds and to negotiate the commission rates and other terms applicable to such transactions. In selecting broker-dealers, the Firm is not required to solicit competitive bids and is not obligated to seek the lowest available commission rates. The Funds may be deemed to be paying for research, brokerage, or other services provided by the broker which are included in the commission rate. Fairmount also has the authority to select and appoint custodians for the assets of the Funds. The exercise of this authority is subject to the Firm’s internal policies and procedures and each Fund’s applicable investment guidelines. Best Execution When selecting a broker-dealer to execute a transaction for a Fund, Fairmount seeks to obtain “best execution,” meaning the most favorable overall execution reasonably obtainable under the prevailing circumstances. Although the best net price — taking into account applicable commissions, spreads, and other transaction costs — is an important consideration, it is not the sole determinant. The Firm evaluates a range of qualitative and quantitative factors that may, depending on the circumstances, outweigh the best available price. Relevant factors considered in the broker-dealer selection process include, but are not limited to: the Firm’s knowledge of prevailing negotiated commission rates and spreads (where applicable); the characteristics of the security or instrument involved; the nature, size, and type of the transaction; the nature and liquidity of the relevant market; the desired timing and urgency of the transaction; the existing or anticipated market activity in the security; confidentiality considerations; the execution, clearance, and settlement capabilities of the counterparty, including its systems, operational infrastructure, and recordkeeping; the financial stability, reputation, and regulatory standing of the counterparty; the Firm’s knowledge of any actual or apparent operational or compliance issues associated with a counterparty; the counterparty’s overall execution quality and prior experience handling similar transactions; and the reasonableness of applicable commissions or spreads in light of the services provided. As a result, the commission rates or spreads charged by a selected broker-dealer may be higher than those available from other broker-dealers who do not offer equivalent execution capabilities or ancillary services. Fairmount has established a Best Execution Committee responsible for overseeing the Firm’s trading practices and activities. The Best Execution Committee monitors trading activity to assess whether transactions are being executed in a fair and equitable manner consistent with the Firm’s best execution obligations. As part of this oversight function, the Best Execution Committee conducts periodic reviews of the performance of broker-dealers and other counterparties utilized by the Firm. The Firm does not currently use soft dollars generated by the Funds’ trading activities to purchase research services or products that would otherwise have been the Firm’s expense. The Investment Management Agreement permits the use of soft dollars, and should the Firm elect to use such arrangements in the future, the Firm intends to operate within the Safe Harbor provisions of Section 28(e) of the Exchange Act. In selecting broker-dealers for Fund transactions, Fairmount does not consider whether a broker-dealer has referred Investors to the Funds. However, broker-dealers that provide

execution services to the Funds may also provide Fairmount with “capital introduction” opportunities and other ancillary services for which neither Fairmount nor the Funds provide compensation. This arrangement creates a conflict of interest: Fairmount may have an incentive to select a broker-dealer that provides such services when determining whether to engage that broker-dealer in connection with brokerage, financing or other activities on behalf of the Funds. See Item 14. Client Referrals and Other Compensation. Allocation Methodology Fairmount’s Trade Allocation and Aggregation policies require the Firm to treat all clients (i.e. the Funds) in a fair and equitable manner. In no event shall the allocation of orders be based on considerations other than the best interests of the Funds. On a given trading day, when a purchase or sale of the same security or instrument is made on behalf of multiple Funds, the transactions shall be averaged as to price, and may be allocated as to amount, in a manner which the Firm believes to be equitable to the Funds.

Fairmount does not pay cash compensation to anyone for introductions to potential Investors. From time to time, broker-dealers who provide trade execution and related services to the Partnerships provide Fairmount with capital introductions. Fairmount does not pay for those services. The broker-dealers are not contractually obligated to provide capital introductions to Fairmount and those introductions do not result in any additional charge to the Funds. Such introductions create a conflict of interest because they are an incentive for Fairmount to select a broker-dealer that provides capital introductions. Fairmount does not consider capital introductions in its selection of brokers. See Item 12. Brokerage Practices as it relates to Selection of Broker-Dealers.

There are no legal or disciplinary events material to an Investor’s or prospective investor’s evaluation of Fairmount’s advisory business or the integrity of its management.

The Funds’ portfolios are reviewed regularly by Fairmount’s Managing Members and other relevant personnel. These reviews encompass existing and potential investments, cash availability, and investment objectives. In conducting these reviews, Fairmount considers, among other things, investment performance, the portfolio’s sensitivity to market conditions, and developments since the initial investment decision that may affect risk or potential return. Account Reporting Investors in the Partnerships receive the following written reports: • monthly performance estimates (unaudited); • monthly account statements from the Funds’ Administrator (unaudited); • monthly portfolio holdings (unaudited); • semiannual investor letters (unaudited); • annual financial statements (audited); and • Schedule K-1s (taxable investors only). Investors in the Co-Invest Vehicles receive the following written reports: • monthly account statements (unaudited); • annual financial statements (audited); and • Schedule K-1s (taxable investors only). Fairmount also communicates with Investors on an as-needed basis to address additional questions. These communications, conducted virtually or in person, may address investment performance, risk management, individual portfolio positions, or other relevant matters. As discussed in Item 11, Fairmount may from time to time provide certain prospective or existing investors with additional information — in response to questions, due diligence requests, or other communications — that may not be available to other investors through ordinary course reporting.

Rule 206(4)-2 of the Advisers Act (the “Custody Rule”) imposes specific conditions on investment advisers who have actual or deemed custody of client assets. The General Partners are deemed to have custody of the Funds’ assets by virtue of their status as the general partners of the Funds. Fairmount complies with the Custody Rule by meeting the conditions of the pooled vehicle annual audit provision. Annually, the Funds are subjected to an audit (as defined in section 2(d) of Article 1 of Regulation S-X) by an accountant registered with the Public Company Accounting Oversight Board and audited financials are distributed to Investors within 120 days of the respective Fund’s fiscal year end. Fund Investors should carefully review such statements. Fairmount routinely purchases privately offered securities and securities evidenced by stock certificates. Such investments when owned by a private fund are generally exempted from the requirement that client assets be maintained with a qualified custodian. Fairmount sometimes maintains such securities with the issuer or the issuers’ transfer agents rather than with a qualified custodian.

Fairmount has full discretionary authority over the Funds including the authority to determine which securities are bought and sold, and the amount and price of those transactions. This discretion is governed by an investment management agreement entered into prior to Fairmount assuming management of the Funds' assets. Fairmount also retains full discretion over the selection of broker-dealers and the commissions to be paid to those broker-dealers in connection with portfolio transactions. The terms of this discretionary authority are set forth in each Fund's offering documents.

Fairmount accepts the authority to vote the Funds’ securities, as applicable. In accordance with Rule 206(4)-6 of the Advisers Act, Fairmount has adopted a written proxy policy governing the exercise of this authority. The policy reflects Fairmount’s intent and obligation to vote (or abstain from voting) proxies in a manner it reasonably believes to be in the best interest of the Funds. Fairmount’s objective in voting proxies is to make decisions that enhance the economic value of the underlying securities held by each Fund. The Firm’s procedures also require identifying and addressing any potential conflicts of interest associated with a particular proxy vote. Where a material conflict of interest is identified, Fairmount will determine whether voting in accordance with its guidelines, or taking an alternative course of action, is most consistent with the best interests of the relevant Fund. Investors cannot direct voting of proxies. The Managing Members are responsible for all proxy voting decisions. The Trader is responsible for facilitating the voting process, and the Chief Compliance Officer is responsible for monitoring the effectiveness of the proxy voting policy. Investors may request a copy of Fairmount’s proxy voting policies and procedures, as well as a record of all proxy votes cast by the Funds by submitting a written request to the Firm.

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