Gallatin Point Capital LLC

Gallatin Point Capital LLC is a Delaware limited liability company with its principal place of business in Greenwich, Connecticut. Gallatin was formed in December 2016 and commenced operations as an investment adviser in February 2017. GPC MH Holdco LP is the sole member of Gallatin. The general partner of GPC MH Holdco LP is GPC MH Holdco GP LLC, whose sole member is Gallatin Point LP, a Delaware limited partnership principally owned and controlled by Matthew B. Botein and Lewis A. (Lee) Sachs. Gallatin, together with affiliated general partner entities (each, a “General Partner,” and collectively together with any future affiliated general partner entities, the “General Partners,” and for purposes of this Brochure any such affiliated entities are included in the term “Gallatin”), provides investment advice to both pooled investment vehicles and single investment vehicles (collectively, the “Funds” and individually a “Fund”) with respect to the acquisition, management, and disposition of debt and equity investments. For purposes of this Brochure, references to “Gallatin” receiving fees, carried interest or other compensation include receipt by affiliated entities, including General Partner entities. Gallatin currently manages two investing strategies, an equity strategy and an income strategy. The equity strategy consists of investment opportunities representing a portfolio of opportunistic businesses, with a primary focus on financial institutions, services and assets. This strategy primarily makes long-term private equity and equity-related investments. The income strategy consists of investments with lower volatility and lower absolute returns than the Gallatin equity strategy. Gallatin’s advisory services consist of investigating, identifying, and evaluating investment opportunities, structuring, negotiating, and making investments on behalf of the Funds, managing, and monitoring the performance of such investments and disposing of such investments. Gallatin also establishes separate investment vehicles to invest in or facilitate the investment in a business, on a deal-by-deal basis. Gallatin also provides non-discretionary investment advice to certain institutional clients. Gallatin has formed one or more parallel entities (the “Parallel Funds”) to accommodate certain non-U.S. investors and certain U.S. tax-exempt investors that will invest in parallel with a Fund. To accommodate investments by certain other investors with special legal, tax or other considerations, Gallatin is authorized to form feeder entities (the “Feeder Funds”) to be used by certain investors to invest in a Fund or any Parallel Fund. Each Fund’s terms may be different, including with respect to different mandates, minimum investment size, and investment restrictions. Each Fund is a privately offered investment vehicle exempt from registration under the Investment Company Act of 1940, as amended (the “1940 Act”), and its securities are not registered under the Securities Act of 1933, as amended (the “Securities Act”). While Gallatin provides advice focused on opportunistic business investments, Gallatin is authorized to make other types of investments as appropriate under the terms of each Fund’s organizational documents, such as advice related to hedging transactions. Two separate institutional investors hold minority interests in Gallatin or a Gallatin Affiliate (each, a “Strategic Investor”). Neither Strategic Investor is a sponsor or promoter of the Funds and neither has duties to other investors. The Strategic Investors do not have a voting equity stake in Gallatin and are not involved in the day-to-day operation of the Funds or in the management of the Funds. Gallatin does not now, and does not intend to in the future, participate in any wrap fee programs.

As of December 31, 2025, Gallatin managed $5,651,158,944 on a discretionary basis, and $0 on a nondiscretionary basis.

Advisory compensation Each investor in a Fund is charged an investment management fee (the “Management Fee”) that is based on capital commitments, invested capital or adjusted capital contributions, depending on the stage of a Fund’s lifecycle. Generally, Management Fees are a percentage of a Fund’s capital commitments, converting after a designated investment period to a percentage of the cost of the remaining assets and decreasing in the later years of the Fund. The exact amount of, and the manner and calculation of, the Management Fee is established through negotiations between Gallatin and each Fund and is set out in each Fund’s organizational documents and/or other documentation received by or agreed upon with an investor prior to investment in such Fund (the “Fund Documentation”). Gallatin expects that Management Fees will be deducted from the capital called from each Fund investor’s committed capital on a quarterly basis and paid in advance to Gallatin or an affiliated entity. The Management Fee is prorated for any period less than a calendar quarter for which it is payable. As is generally the case in private equity funds, the Fund Documentation provide that a Fund’s Management Fees will be calculated and charged on a basis that generally is not tied to the Fund’s then-current net asset value. As further specified in the Fund Documentation, from the effective date of the relevant Fund until a date specified in the Fund Documentation (the “Stepdown Date”), Management Fees generally will be charged based on a formula tied to the amount of the relevant Fund’s aggregate capital commitments. After the Stepdown Date, Management Fees generally will be charged and calculated based on a formula tied to the amount of investment contributions (including, where applicable, a Fund borrowing component (including interest expense) and the amount of any other capitalized fees or expenses) made by the relevant Fund relating to the Fund’s investments that have not been realized or are written down (such investments, “Impaired Value Investments”). Under the Fund Documentation, where the fair market value of an investment exceeds the total amount of investment contributions relating to such investment, post-Stepdown Date Management Fees will not be calculated based upon such appreciated value and will instead continue to be calculated based on the amount of applicable investment contributions. As a result, and as is generally the case for private equity funds, the amount of Management Fees generally will not correspond with fluctuations in the net asset value of individual investments or of a Fund, including following the relevant investment period, and will not be reduced in connection with any write downs (whether temporary or permanent), except in the case of Impaired Value Investments. In many circumstances, the post-Stepdown Date Management Fee base will include capitalized transactionspecific fees and expenses of unrealized investments, including certain fees and expenses paid to service providers (including suppliers, vendors, consultants, lenders, law firms (including Fund or transaction counsel), transaction service providers and their respective affiliates, personnel and related investment vehicles (together, “Investment Service Providers”)), Gallatin, or its affiliates. Subject to the Fund Documentation, a portion of cumulative net profits from the investments of such Fund (customarily referred to as a “Carried Interest”) is generally allocated to one or more affiliates of Gallatin. The compensation described herein may be modified and may differ from one Fund to another, as well as among investors in the same Fund. The Management Fee and Carried Interest has been reduced, rebated or

waived for some investors in the Funds, and Gallatin expects that any future strategic partners or significant investors will typically be charged lower Management Fees and Carried Interest than other investors in each Fund. Gallatin also expects to reduce or waive Management Fees and/or the Carried Interest for investors affiliated with Gallatin or Gallatin employees. As described below, the Management Fee is often reduced in connection with the receipt by Gallatin or its related persons of various fees paid by actual or prospective Fund portfolio companies or by certain organizational or other expenses borne by such Fund. Other Expenses Paid by the Funds In addition to paying Management Fees and Carried Interest, each Fund will generally be subject to the payment of other fees and expenses, as set out in the Fund Documentation for each Fund, including but not limited to: •

expenses incurred in connection with the organization of a Fund,

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fees, costs, and expenses incurred in connection with the dissolution, liquidation and winding up of a Fund,

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expenses incurred in connection with preparing any amendment, restatement, or other modifications to certain Fund Documentation,

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legal, administrator, accounting, auditing, and other professional expenses including, but not limited to, regulatory, compliance, filings, and reporting expenses (to the extent related to a client or its investments),

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fees, expenses, and other compensation of any operating partners retained to provide management, consulting, or other business services to, or relating to, potential or current portfolio companies,

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principal, interest, and expenses relating to, or arising out of, borrowings by such Fund and all reasonable brokerage fees, commissions, and discounts,

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costs and expenses incurred in connection with the evaluation, research, purchase, retention or sale of securities (whether or not consummated), including, without limitation, loan fees, private placement fees, sales commissions, brokerage fees, auditing fees, underwriting commissions and discounts, investment banker fees, insurance costs, and all other expenses that are directly related to particular investments or proposed investments, whether or not actually consummated,

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expenses incurred in connection with any meeting with investors and meetings of any committees formed by a Fund (such as an advisory committee),

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fees, costs, and expenses associated with the preparation and delivery of Fund financial statements, tax returns and Schedule K-1s, capital calls, distribution notices, other reports, and notices and other required or requested information (including the fees, costs and expenses incurred to provide access to such reports or information (including through a website or other portal)),

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the reasonable costs of any litigation, D&O liability, or other insurance,

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fees, costs and expenses associated with the valuation of Fund investments, and

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any indemnification or extraordinary expense or liability relating to the affairs of such Fund.

The inclusion of an expense category in a Fund under the Fund Documentation will not impose on Gallatin an obligation to charge an expense (or the full amount of that expense) to that Fund; instead, permitted expenses will be allocated and charged in Gallatin’s discretion to the Fund(s) it deems appropriate. Gallatin expects that each Fund may be subject to a cap on the amount of organizational expenses that may be charged to the investors in the Fund, and each existing Fund contains such a cap. To the extent such expenses are incurred for the benefit of multiple Funds, Gallatin will make a good faith allocation (generally, but not exclusively, pro rata based on the asset size of the Fund) of such expenses among the Funds. As a general matter, Fund expenses typically will be allocated among all relevant Funds or co-invest vehicles receiving the benefit of such expenses (in the relevant General Partner’s sole discretion) and eligible to reimburse expenses of that kind. In all such cases, subject to applicable law and legal, contractual or similar restrictions, expense allocation decisions generally will be made by Gallatin or its affiliates using their reasonable judgment, considering such factors as they deem relevant, but in their sole discretion to be fair and equitable across these vehicles. The allocations of such expenses are permitted to be made on a non-proportional basis, and any such determinations involve inherent matters of discretion, e.g., in determining which Funds or co-invest vehicles benefit (or the extent to which they actually or potentially could benefit) from the relevant service relating to the expense, or whether to allocate pro rata based on number of Funds or co-invest vehicles receiving related benefits or proportionately in accordance with Fund size (including amount of remaining committed capital), asset size, or fair value, number of investors, number of investments, number of users, or in certain circumstances determining whether a particular expense has greater benefit to a Fund or Gallatin. The Funds generally are expected to have different expense reimbursement terms, including with respect to Management Fee offsets, which are expected in certain cases to result in the Funds bearing different levels of expenses with respect to the same investment. Expenses paid by non-discretionary institutional clients will be determined by the agreement with the client. As a result, it is possible that a Fund or co-invest vehicle will benefit (or benefit disproportionately) from expenses borne in whole or in part by another Fund. Other Compensation Gallatin employees are permitted to receive from a portfolio company fees or stock in connection with serving on the board of directors of the portfolio company. Gallatin and its affiliates reserve the right to, and in certain instances do, receive monitoring fees pursuant to monitoring agreements with portfolio companies of the Funds governing the advice, consultation and other similar ongoing services provided by Gallatin to such portfolio companies. Gallatin and its affiliates are permitted to perform negotiation, consulting, investment banking, financial advisory and other services for, and may receive fees from, the issuer, seller or purchaser of a portfolio company including fees in connection with investment banking, advisory, or similar fee with respect to such portfolio companies. In certain cases, Gallatin, and its affiliates are eligible to receive fees in connection with an unconsummated transaction such as broken deal, toppedbid or similar fees (“Break-Up Fees”). The amount and timing of Break-Up Fees received by Gallatin are generally negotiated at the time of the proposed investment and specified in the agreement or other documentation governing the transaction. To the extent Gallatin receives any of the fees described above, Gallatin generally will reduce or offset the amount of Management Fees paid by the applicable Fund in connection with the receipt of a portion of such fees. The amount and manner of such reduction or offset, if any, is and will be set out in the Fund Documentation for the applicable Fund. In addition, portfolio companies generally reimburse Gallatin for certain expenses incurred by Gallatin in connection with its performance of services for such portfolio companies. In certain circumstances, such as those relating to short- or long-term portfolio company cash or liquidity needs, and regardless of whether the portfolio company is undergoing financial stress, Gallatin reserves the right to accrue, defer or forego payments of the fees described above. In such cases, in accordance with the Fund Documentation, investors will not receive the benefit of Management Fee offsets with respect to such amounts until they are actually received. Even in circumstances where the fees

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Methods of Analysis and Investment Strategies Gallatin seeks to identify opportunities that arise from complexity, dislocation or changes in technology and regulation that create the potential for outsized returns relative to the amount of risk attributable to the investment. Gallatin actively seeks opportunities with rewards and risks that are more idiosyncratic and uncorrelated in nature, for example, opportunities that may be less reliant on favorable performance of the equity and bond markets. Gallatin believes that the rewards for creatively applying its investment strategy to investment opportunities are often superior to those available by competing in broad auction processes. Gallatin seeks to implement its strategy by forming collaborative partnerships with investors in the Funds it manages and with management teams of the companies in which it invests debt and equity capital, in an effort to find a favorable combination of capital with managerial competencies. Gallatin also believes in an intensive approach in seeking to guide and add value to the Fund portfolio companies, including by providing strategic counsel to management of portfolio companies and access to Gallatin’s experience, resources, and professional networks. Gallatin seeks to invest in businesses at all stages of development, including by: •

partnering with experienced founders at inception of a business, where Gallatin believes a new entrant in an industry or market has the greatest chance for success and an investment can be structured with downside protection for a Fund’s investment;

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providing growth capital to existing businesses where Gallatin believes the management team is particularly strong and where Gallatin’s experience, along with our capital, can help the company grow and succeed; and

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collaborating with more mature companies to help them achieve their particular objectives by partnering with Gallatin.

Material Risks (Including Significant, or Unusual Risks) Relating to Investment Strategies and Conflicts of Interest Set out below is a brief summary of some of the important risks and conflicts of interest to which Gallatin expects a Fund or other client to be subject as a result of Gallatin’s investment strategies. Before deciding to invest in a Fund, prospective investors should carefully consider all of the risk factors and other information set out here and, if applicable, in the Fund Documentation. Prospective investors should also consult with their own financial, tax and legal advisors regarding the suitability of an investment in a Fund. Investing in securities involves risk of loss that clients and Fund investors should be prepared to bear. The following risk factors and potential conflicts should be understood to generally apply to a Fund and any Parallel Fund or Feeder Fund (and where appropriate, the General Partner acting in its capacity as the General Partner or managing member of the relevant Parallel Fund or Feeder Fund). Public Health Emergencies. Pandemics and other widespread public health emergencies, including outbreaks of infectious diseases such as SARS, H1N1/09 flu, avian flu, Ebola and COVID-19 have resulted in numerous deaths, have adversely impacted global commercial activity, and have contributed to significant volatility in certain equity and debt markets. Future such emergencies have the potential to materially and adversely impact economic production and activity in ways that are impossible to predict, all of which may result in significant losses to the Funds. The extent of the impact of any public health emergency on client accounts’, the Funds’ and their portfolio companies’ operational and financial performance will depend on many factors, including the duration and scope of such public health emergency, the extent of any related travel advisories and restrictions implemented, the impact of such public health emergency on overall supply and demand, goods and services, investor liquidity, consumer confidence and levels of economic activity and the extent of its disruption to important global, regional and local supply chains and economic markets, all of which are highly uncertain and cannot be predicted. The effects of a public health emergency may materially and adversely impact the value and performance of the client accounts’ and Funds’ portfolio companies, the ability to source, manage and divest investments and the ability to achieve their investment objectives, all of which could result in significant losses to client accounts and the Funds. In addition, the operations of portfolio companies and the Adviser may be significantly impacted, or even temporarily or permanently halted, as a result of government quarantine measures, voluntary and precautionary restrictions on travel or meetings and other factors related to a public health emergency, including its potential adverse impact on the health of any such entity’s personnel. International Conflicts and Geopolitical Events. Wars and other international conflicts, such as the Israeli-Palestinian conflict and the ongoing military conflict between Russia and Ukraine, have caused disruption to global financial systems, trade and transport, among other things. In response, multiple other countries have put in place sanctions and other severe restrictions or prohibitions on certain of the countries involved, as well as related individuals and businesses. The ultimate impact of these conflicts (and other geopolitical events, including national referenda, elections, interest rates, political movements, humanitarian crises, national and international policy changes, actual

or perceived trade wars, import or export controls, tariffs, executive orders, laws, legal systems and regulatory regimes) and their effect on global economic and commercial activity and conditions, and on the operations, financial condition and performance of the Funds or any particular industry, business or investee country and the duration and severity of those effects, is impossible to predict. These matters may have a significant adverse impact and result in significant losses to the Funds. This impact may include reductions in revenue and growth, unexpected operational losses and liabilities, supply chain disruptions and reductions in the availability of capital. It may also limit the ability of a Fund to source, diligence and execute new investments and to manage, finance and exit investments in the future. Developing and further governmental actions (military or otherwise) may cause additional disruption and constrain or alter existing financial, legal and regulatory frameworks and systems in ways that are adverse to the investment strategy which any Fund intends to pursue, all of which could adversely affect the Fund’s ability to fulfill its investment objectives. Social Media and Publicity Risk. The use of social networks, message boards, internet channels and other platforms has become widespread within the United States and globally. As a result, individuals now have the ability to rapidly and broadly disseminate information or misinformation, without independent or authoritative verification. Any such information or misinformation regarding Gallatin, the Funds or one or more portfolio companies could have a material and adverse effect on the value of the Funds. No Assurance of Investment Returns. Gallatin cannot give assurance that investments will generate returns or that returns will be commensurate with the risks of investing in the type of companies and transactions that fall within such Fund’s individual investment objectives. The interests are not readily marketable, and a Fund’s investments are generally illiquid. Partial or complete sales, transfers, or other dispositions of investments which may result in a return of capital or the realization of gains, if any, are generally not expected to occur for a number of years after an investment is made. An investment in a Fund should only be considered by persons who can afford a loss of their entire investment. Past performance of investment entities associated with Matthew Botein or Lee Sachs is not necessarily indicative of future results of a Fund, and there can be no assurance that projected or targeted returns for a Fund will be achieved. CFIUS and National Security Clearance Considerations. Certain investments by a Fund that involve the acquisition of, or investment in, a U.S. business (including a U.S. subsidiary of a portfolio company domiciled outside of the United States) or U.S. assets could be subject to review and approval by the U.S. Committee on Foreign Investment in the United States (“CFIUS”) depending on, among other factors, the structure, beneficial ownership and control of interests in the Fund and the nature of the U.S. business. CFIUS reform legislation (the Foreign Investment Risk Review Modernization Act) and related regulations empower CFIUS to scrutinize more closely investments in U.S. “sensitive personal data,” “critical infrastructure” and “critical technology” companies, including investments involving non-U.S. limited partners or co-investors that may be deemed “non-passive.” Certain transactions involving non-U.S. persons and U.S. “critical technology” companies, as well as sovereign investments in “critical technology,” infrastructure or data businesses, can be subject to mandatory pre-closing notification requirements, and monetary penalties may attach to a party’s failure to file such a notification. In addition, non-U.S. countries are increasingly taking action to strengthen their own foreign investment clearance (“FIC”) regimes, and as a result, certain investments by a Fund could likewise be subject to review by non-U.S. FIC regimes if the investments are perceived to implicate national security policy priorities. CFIUS and other FIC regulatory practices are evolving rapidly, and CFIUS and other FIC regulators have substantial discretion in deciding how to interpret, apply and enforce the relevant regulations. Any review and approval of a Fund investment by CFIUS or another FIC regulator could have outsized impacts on transaction certainty, timing, feasibility and cost, among other things. In the event that CFIUS

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Gallatin provides discretionary investment advice to both the Funds and separate investment vehicles and provides non-discretionary investment advice to one or more institutional clients. Each Fund specifies a minimum subscription amount, but the terms will depend on the Fund Documentation. The applicable General Partner (or other affiliate with management discretion) reserves the right to waive the minimum investment amount for investors. Any investment advisory relationships with institutional clients will be negotiated on a case-by-case basis.

As noted in Item 5, Carried Interest from each Fund is generally received by Gallatin and/or its affiliates. The payment of Carried Interest to Gallatin and/or its affiliates will be made at different rates, is subject to varying hurdle rates (including varying effective rates based on the past performance of the Fund) and is determined on a Fund-by-Fund basis and on an investor-by-investor basis. Certain Funds, and certain investors in each Fund, therefore pay lower rates than other Funds or investors.

In addition, Gallatin and/or certain of its affiliates are authorized in certain instances to collect Carried Interest directly via a holding company or other aggregator owned by the Fund, or to collect a profits interest at the portfolio company level in lieu of Carried Interest, which profits interest would generally be a percentage of the profits earned on the relevant portfolio company; provided that any such profits interest is received without duplication of Carried Interest at the Fund level. This creates an incentive for Gallatin to disproportionately allocate time, services or functions to Funds paying Carried Interest at a higher effective rate or subject to a lower hurdle before paying Carried Interest. Generally, this conflict is mitigated by contractual provisions and procedures setting out specific resource allocation requirements through key person provisions that typically provide for the Gallatin principals to devote significant time to the management of the portfolio. The conflict associated with Carried Interest is often further mitigated by the requirement that the General Partner have a capital commitment to a Fund, and a General Partner clawback obligation upon dissolution of a Fund. For a discussion of material conflicts regarding allocation, please see “Allocation of Investment Opportunities among Funds” in Item 11 below.

Material Relationships or Arrangements with Industry Participants. Gallatin forms affiliated General Partners or managing members for each Fund or separate investment vehicles and other affiliates that provide advisory services to, and/or receive fees from, the Funds. These affiliates are formed for tax, regulatory or other purposes in connection with the organization of the Funds. In addition, Gallatin has in the past contracted with a Strategic Investor and may in the future contract with either Strategic Investor to provide management, consulting or other business services to, or with respect to, the Funds or potential or current portfolio investments. When engaging a Strategic Investor to provide such services, Gallatin and its employees may have or may be seen to have incentive, including as a result of existing business relationships, to recommend the Strategic Investor even if another person is more qualified to provide the applicable services and/or can provide such services at a lesser cost. To address these actual and potential conflicts of interest, Gallatin has adopted policies and procedures to ensure that Investment Service Providers, including those affiliated with a Strategic Investor, are not selected based on reasons unrelated to the best interests of its clients and instead are selected taking into account factors such as expertise, availability and quality of service and the competitiveness of compensation rates in comparison with other Investment Service Providers satisfying the manager’s Investment Service Provider selection criteria. However, Gallatin’s and its employees’ relationships with a Strategic Investor could influence or be seen as influencing Gallatin’s decision to select or recommend an Investment Service Provider affiliated with such Strategic Investor to perform services for the Funds or their portfolio investments (the cost of which will generally be borne directly or indirectly by the fund or its portfolio investments, as applicable). It is also possible that Investment Service Providers consider the overall level of work performed for Gallatin, the Funds or their portfolio companies in determining whether to provide reduced rates or benefits to Gallatin. Based on the foregoing factors, limited partners should not expect Investment Service Providers to Gallatin or any Fund to provide services that will be the most beneficial to any limited partner or group of limited partners. Gallatin will, in accordance with its policies and procedures, seek the approval of the relevant Fund advisory committee for transactions between a Strategic Investor and its affiliates on the one hand and the Fund(s) on the other. The Funds enter into agreements, or “side letters,” with certain prospective or existing investors whereby such investors are subject to terms and conditions that are more advantageous (and which could be materially different) than those set out in the relevant Fund Documentation. The modifications are solely at

the discretion of Gallatin and are often, among other things, based on the size of the investor's investment in a Fund, an agreement by an investor to maintain such investment in a Fund for a significant period of time, or other similar commitment by an investor to a Fund. Board Memberships Gallatin’s investment professionals serve as directors of other companies in the financial industry and often serve as directors of companies in which a Fund invests. As a director of a company, an investment professional also owes a fiduciary duty to the company. Board memberships may place an investment professional in a position where they must make a decision that is not in the best interests of a Fund. Investment professionals serving as directors may receive non-public information as a result of their duties and such knowledge may restrict a Fund’s ability to buy or sell securities of the relevant company. Gallatin’s investment professionals have in the past and are likely to continue to also sit on the boards of public companies. Gallatin does not expect the Funds to purchase the securities of public companies except as the result of a private company making an initial public offer. Personal Interests in Other Businesses Gallatin’s investment professionals have interests in other businesses in the financial industry, including investments in other private investment vehicles; however, they do not expect to spend any significant time or resources in conducting such other businesses and Gallatin does not expect such interests to create a material conflict of interest. Gallatin will review each future request for participation in an outside business activity and determine whether a conflict exists and what, if any, policies, or procedures should be applied to mitigate the conflict. In addition, Mr. Botein continues to hold passive investments in certain private equity funds managed by affiliates of a Strategic Investor and is entitled to receive Carried Interest distributions from certain funds managed by affiliates of such Strategic Investor in connection with his previous employment. Each Strategic Investor also has referred and may refer investors to the manager. These ongoing business arrangements, as well as the business relationship the manager has built with each Strategic Investor, could present at least an appearance of a conflict of interest. To address these actual and potential conflicts of interest, Gallatin will, in accordance with its policies and procedures, seek the approval of the relevant Fund advisory committee for transactions between a Strategic Investor and its affiliates on the one hand and the Fund(s) on the other.

Code of Ethics Gallatin has adopted a Code of Ethics in accordance with Rule 204A-1 under Advisers Act that is applicable to its managers and employees (collectively, “Personnel”). The Code of Ethics contains provisions that remind Personnel of their obligations to Gallatin’s clients and obligations to comply with federal securities laws, set forth standards of conduct, restrict certain personal securities trading and requires reporting of personal securities transactions and holdings. Personnel who violate the Code of Ethics may be subject to disciplinary or other action (including, without limitation, termination of employment). Personnel are required to acknowledge that he or she received, read, and understands the Code of Ethics. The Code of Ethics, among other benefits, helps Gallatin detect and prevent potential conflicts of interest. The Code of Ethics is designed to prevent the personal securities transactions and interests of Personnel from interfering with (i) making decisions for Funds and (ii) implementing such decisions while, at the same time, allowing Personnel to invest for their own accounts where appropriate. The Code of Ethics

restricts trading in the securities of any issuer included on Gallatin’s restricted list and requires preapproval before making a transaction in an initial public offering or limited offering. Under the Code of Ethics, Personnel are also required to file certain periodic reports consistent with Rule 204A-1 under the Act. Such reporting and review helps Gallatin detect and prevent potential conflicts of interest. Gallatin will provide a copy of the Code of Ethics to any Client or prospective investor upon written request addressed to: ATTN: Chief Compliance Officer, Gallatin Point Capital LLC, 660 Steamboat Road, Greenwich, CT 06830; email info@gallatinpoint.com; or call 203-742-0200. However, Gallatin reserves the right to refine and modify the Code of Ethics and its other policies and procedures over time. No investor or prospective investor should invest with Gallatin on the basis of, or otherwise rely on, the provisions thereof, and any such refinements or modifications have the potential materially to affect the investments available to the Funds or the expenses borne thereby. Participation or Interest in Client Transactions Through the limited partnership structure, Gallatin’s affiliates have indirect beneficial interests in the securities owned by the Funds and will share in any profits and losses generated by Fund investments. Gallatin will always endeavor to act in the best interest of the Funds; however, investors should be aware that Gallatin’s and the General Partner’s receipt of compensation from the Funds creates a potential conflict of interest with respect to such transactions. Gallatin employees are not permitted to co-invest directly into any portfolio company or other investment made by the Funds. Conflicts of Interest In the ordinary course of conducting its investment advisory activities, the interests of a Fund can conflict with the interests of Gallatin, other Funds, or their respective affiliates. Certain of these conflicts of interest, as well a summary of how Gallatin addresses such conflicts of interest, can be found below. Other conflicts are disclosed throughout this Brochure and applicable Fund Documentation. Resolution of Conflicts In the case of all conflicts of interest, Gallatin’s determination as to which factors are relevant, and the resolution of such conflicts, will be made using Gallatin’s best judgment, but in its sole discretion. In resolving conflicts, Gallatin will consider various factors, including the interests of the applicable Funds with respect to the immediate issue and/or with respect to their longer-term courses of dealing. Many important conflicts of interest will generally be disclosed in and resolved by defined procedures, restrictions or other provisions contained in the Fund Documentation for the Funds. The Funds usually establish advisory committees, consisting of representatives of investors not affiliated with Gallatin, to evaluate conflicts and their resolutions. Management of the Funds Gallatin will be responsible for managing all of the Funds. Conflicts of interest arise in allocating time, services, or functions of Personnel. To mitigate such conflicts, the Fund Documentation generally limit and describe when the manager can fundraise for a new fund. Invested Capital Fee Structure Because there is expected to be a fixed investment period after which capital from investors in the Funds will only be drawn down in limited circumstances and because Management Fees could, at certain times

during the life of the Funds, be based upon capital invested by the Funds, such fee structure could create an incentive to deploy capital when Gallatin would not otherwise have done so. Allocation of Investment Opportunities Among Funds As more fully detailed in Item IV, each opportunity that will be recommended to certain existing Funds will first be offered to the Strategic Investor, who will be permitted to invest up to a certain percentage of the available investment. After the Strategic Investor determines whether to invest and in what amounts, Gallatin, on behalf of the Funds, will determine the amount of Fund investment or investments. This Strategic Investor Allocation Arrangement ended in June 2024 and, accordingly, only relates to investment opportunities offered to certain existing Funds formed prior to such date. Following the Strategic Investor’s option and decision to invest (if relevant), investment opportunities may be available to more than a single Fund and may be appropriate investments for one or more other Funds. Gallatin seeks to reduce the risk of any inequitable allocation of investment opportunities by formulating investment allocation and sharing guidelines. However, Gallatin cannot anticipate all possible investment structures required during the life of a Fund and certain investment structures are not contemplated in Fund Documentation. In such cases, Gallatin seeks to allocate such opportunities on an equitable basis using its best judgment and in its sole discretion. Nonetheless, except as required by relevant Fund Documentation, Gallatin is not obligated to recommend any investment to any particular investment vehicle. Follow-on Investments A follow-on investment in an existing portfolio company could present a conflict of interest, such as with respect to a determination of terms or the allocation of the investment opportunity to different Funds (for example when the Fund Documentation of a Fund would not permit such follow-on investment). A Fund is expected to participate in releveraging and recapitalization transactions involving portfolio companies in which another Fund has already invested or will invest. Conflicts of interest arise, including determinations of whether existing investors are being cashed out at a price that is higher or lower than market value and whether new investors are paying too high or too low a price for the company or purchasing securities with terms that are more or less favorable than the prevailing market terms. To the extent that these conflicts arise, Gallatin will seek to mitigate them by taking all steps it deems reasonable, including but not necessarily limited to seeking the approval of the advisory committee of the appropriate Fund or Funds. Portfolio Valuation Valuation represents a conflict of interest for investment advisers. The exercise of discretion in valuation by Gallatin gives rise to conflicts of interest, as fees and Carried Interest in certain Funds are calculated based, in part, on these valuations and such valuations affect performance return calculations. Valuations are inherently subjective as there is no public exchange for a Fund’s underlying assets or for the trading of limited partnership interests in the Funds themselves. The process of valuing assets for which reliable market quotations are not available is based on inherent uncertainties and the resulting values may differ from values that would have been determined had an active market existed for such assets and may differ from the prices at which such assets are ultimately sold. Gallatin cannot fully mitigate the conflicts and risks inherent in the valuation process but manages these conflicts and risks through its investment process and compliance program. In the absence of a perpetual market for such interests, Gallatin determines a value for each underlying portfolio company based on the periodic application of its internal valuation policies and methodologies. As a fiduciary to the Funds and investors, Gallatin has adopted formal valuation policies and procedures designed such that portfolio holdings reflect current, fair, and accurate asset valuations. Valuation policy

attributes include but are not limited to: (a) written valuation procedures; (b) periodic reviews of portfolio valuations carried out by Gallatin’s investment team; (c) advisory committee participation in valuation processes as required by a Fund’s Fund Documentation; and (d) external auditor review of written valuation policies and records prior to issuance of annual Fund financial statements. Cross Transactions One or more of the Funds may engage or may in the future engage in activities that are considered internal cross-trading transactions. Such transactions create conflicts of interest because, by not exposing such buy and sell transactions to market forces, a Fund may not receive the best price otherwise possible, or Gallatin might have an incentive to improve the performance of one Fund by selling underperforming assets to another Fund. To address these conflicts of interest, Gallatin maintains policies and procedures regarding the disclosure and best execution requirements for such transactions. Principal Transactions If a Fund enters into a principal transaction, it will only do so in accordance with all of the requirements of the Advisers Act and will obtain the required prior consent to the transaction from the relevant funds. Allocation of Co-investment Opportunities Gallatin offers investors in the Funds or other unrelated third parties the ability to co-invest in an investment alongside a Fund and, depending on the Fund, potentially the Strategic Investor, as well as Investment Service Providers. In certain cases, determinations to allocate such amounts or investment opportunities to Investment Service Providers will be made prior to the determination of the availability of opportunity for other co-investors, and as such generally will decrease the amount of co-investment opportunities available. Co-investment opportunities arise due to the size of an investment opportunity or desire for a co-investor based on strategic considerations including, but not limited to, relevant knowledge of an industry, geographic region or contacts with prospective managers, board members or advisors. Gallatin considers whether offering a co-investment would pose a conflict with the Funds before making any investment available to such potential co-investors. Gallatin is authorized to offer co-investment opportunities to any potential investor in its sole discretion and is not required to offer the opportunities to investors in the Funds. Gallatin reserves the right to grant certain third-party investors (including anchor or other early-committing investors or investors making large commitments) the opportunity to evaluate specified amounts of prospective co-investments in Fund portfolio companies or otherwise to have priority in co-investment opportunities. In the event Gallatin determines to offer a co-investment investment opportunity, there can be no assurance that Gallatin will be successful in offering such co-investment opportunity, in whole or in part, that the closing of such co-investment will be consummated in a timely manner or that the co-investment will take place on the terms and conditions that will be preferable for the Fund. In the event that Gallatin is not successful in offering a co-investment opportunity to potential co-investors, in whole or in part, the Fund may consequently hold a greater concentration than was initially intended, experience delays in the investment process, and/or lose, or cause the Fund to renegotiate, the investment opportunity, each of which could result in less favorable terms or economics for the Fund. Due in part to the fact that investors and potential investors in a Fund or a co-investor ask different questions and request different information (for example, within side letters), Gallatin provides certain information to one or more prospective investors that it has not provided to all of the investors or prospective investors.

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Gallatin reserves the right to engage broker-dealers in the normal course to effect transactions in publicly traded securities but does not expect such transactions to occur in the normal course because each Fund will generally make privately negotiated purchases of interests in businesses. Relative to the purchase and sale of certain portfolio companies however, in certain cases, Gallatin will engage a broker or dealer to ensure that a private transaction is closed in a manner most advantageous to participating vehicles. When

executing portfolio transactions using brokers or dealers, Gallatin seeks the best overall execution terms available to close the deal expeditiously and on terms most favorable to the participating vehicles. Gallatin will, when appropriate, engage in certain hedging transactions and, in some cases, use brokerdealers as necessary to sell a Fund’s publicly traded securities consistent with an exit strategy as a result of an initial public offering. Gallatin will select brokers based on a number of factors, including, but not limited to, the size and type of transaction, the markets for securities to be purchased or sold, execution, efficiency, settlement capability, financial condition of the broker-dealer, the quality of the broker-dealer’s portfolio execution on a continuing basis and reasonableness of brokerage commissions. Gallatin will always attempt to achieve the best overall price for the Funds, considering the circumstances of the transaction and the reputability of the executing broker-dealer and will evaluate each transaction to ensure that the execution price is in line with, or exceeds, that of the current market. The lowest possible commission cost is not necessarily sought if it does not result in the best quality execution of transactions effected for the Funds. A “soft dollar” arrangement is an arrangement whereby an investment adviser directs client brokerage, or pays higher commissions, to a particular broker-dealer in return for research or other services from such broker-dealer. Gallatin may in the future enter into soft dollar arrangements in accordance with applicable law but does not do so at this time. Gallatin may also receive proprietary research and certain other limited benefits from broker-dealers as an incident of doing business with such broker-dealers where it does not involve the payment of soft dollars. Gallatin does not expect to enter into directed brokerage arrangements or recommend a broker-dealer to anyone.

As stated above, Gallatin reserves the right to engage one or more placement agents or finders in connection with the placement of limited partner interests and has in the past utilized one or more such placement agents. Gallatin enters into a legal agreement with any placement agent it retains. Such agreement includes the requirement that the placement agent abide by federal securities statutes in discharging activities on behalf of Gallatin. In accordance with the terms of the relevant Fund’s Fund Documentation, any such placement agent fees will be payable by Gallatin and/or its affiliated entities. A Fund investor will not bear any additional charges because of an introduction through a placement agent or other unaffiliated third party.

Although common, such referral arrangements do create a potential conflict of interest because, in theory, the referrer is motivated, at least partially, by financial gain and not because a Fund is suitable to the prospective investor’s needs. To address this potential conflict of interest, all referred investors are carefully screened to ensure that the Fund is suitable to the prospective investor’s investment needs, objectives and risk tolerance before any subscription is accepted.

Gallatin has no legal or disciplinary events to disclose.

Oversight and Monitoring After an investment is made by a Fund, Gallatin will continuously monitor the investment for the Fund. Gallatin enters into investments with the expectation of being a significant and active investor. Gallatin generally holds a board seat for the investment or serves as a board observer if precluded from being a board member. In addition, all Funds will be reviewed on an ongoing basis in seeking exit opportunities. Reporting Investors in the Funds will receive audited financial statements for the year within 120 days after the fiscal year end. Investors in the Funds also receive periodic reports pursuant to the terms of the relevant Fund Documentation. In addition to the general Fund reporting, Gallatin expects to provide additional or more frequent information relating to a Fund to one or more investors in such Fund that other investors will not receive (e.g., under a side letter or in response to diligence or other requests).

Each Fund (and each separate investment vehicle where applicable) is audited at least annually by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board. Audited financial statements are prepared in accordance with generally accepted accounting principles (“GAAP”). Each Fund (and each separate investment vehicle where applicable) distributes its audited financial statements on an annual basis to all investors no later than 120 days after the end of the applicable Fund’s fiscal year end. Upon the final liquidation of a Fund or separate investment vehicle, Gallatin will obtain a final audit and distribute audited financial statements prepared in accordance with GAAP to all investors promptly after completion of the audit. Gallatin does not have custody of assets of institutional clients for which it provides non-discretionary investment advice.

Gallatin provides investment advisory services on a discretionary basis to the Funds. Gallatin’s advice with respect to the Funds is provided in accordance with the investment objectives, limitations, and guidelines as set out in the relevant Fund Documentation. Prior to assuming discretion in managing a Fund’s assets, Gallatin enters into an investment management agreement or other agreement that sets out the scope of Gallatin’s discretion. Gallatin generally has the authority to determine the securities to be purchased and sold for the Fund and the amount of securities to be purchased or sold for the Fund. Where Gallatin manages assets on a non-discretionary basis for institutional clients (other than the Funds), each such client will determine in its sole discretion whether to participate in an investment opportunity, and the terms under which such participation will occur.

The Funds are active investors in their respective portfolio companies. Gallatin often designates a representative at the board of directors of the portfolio company. It is expected for these representatives to potentially remain on the board for a period of time if the portfolio company were to go public. In addition, the Funds stay closely involved with the investments as shareholders. Gallatin reviews and votes on proxy and shareholder consent matters on a case-by-case basis. Gallatin stays apprised of developments that affect a portfolio company in which a Fund invests, carefully reviews matters submitted to the Funds for a vote as holders of portfolio company securities and votes on those matters on a case-by-case basis in a manner that Gallatin believes is in the best interests of the applicable Fund. Investors may obtain information about how a proxy was voted and/or obtain a copy of the proxy voting policies and procedures upon written request to: ATTN: Chief Compliance Officer, Gallatin Point Capital LLC, 660 Steamboat Road, Greenwich, CT 06830; email info@gallatinpoint.com; or call 203-742-0200.

Gallatin and its affiliate entities have no financial obligation that impairs their capacity to meet contractual and fiduciary commitments to clients, nor has Gallatin or its affiliate entities been the subject of a bankruptcy proceeding.