Garda Capital Partners

Garda Capital Partners LP (“Garda”) is a Delaware limited partnership established in 2015, which is majority-owned by Garda Holdings LP through a holding company, Garda Management LP. Garda Holdings LP is controlled by Jeffrey Drobny and Timothy Magnusson, who hold their respective economic interests in Garda Holdings LP through individual trusts. GCP Acquisition LLC, a subsidiary of Affiliated Managers Group, Inc. (“AMG”), holds a minority equity interest in Garda. AMG is a publicly traded global asset management company (NYSE: AMG). Please see Item 10 – Other Financial Industry Activities and Affiliations for more information relating to AMG. Garda provides discretionary investment management services to private pooled investment vehicles (the “Funds”) offered to Investors on a private placement basis. In addition to its headquarters in Wayzata, Minnesota, Garda maintains primary offices in New York, New York, Palm Beach Gardens, Florida, and Scottsdale, Arizona. Garda also has affiliates located outside the United States: Garda Capital Partners Sàrl, a Swiss limited company with operations in Geneva and Zug, Switzerland, that is registered as an asset manager with the Swiss Financial Market Supervisory Authority (“Garda Switzerland”), Garda Capital Partners Copenhagen Fondsmæglerselskab A/S, a Danish limited company with operations in Copenhagen, Denmark that is registered as an investment firm with the Danish Financial Supervisory Authority (“Garda Denmark”), and Garda Capital Partners Singapore Pte. Ltd., a Singapore private company with operations in Singapore that is registered as a fund management company with the Monetary Authority of Singapore (“Garda Singapore”). Each of Garda Switzerland, Garda Denmark, and Garda Singapore (collectively, the “Advisory Affiliates”) implement certain trading strategies on behalf of Garda Funds related primarily to European and Asian investment assets. The Advisory Affiliates are listed on Schedule R of Garda’s Form ADV Part 1A as “Relying Advisers.” The Funds are managed according to the terms and investment objectives set forth in each Fund’s Confidential Private Placement Memoranda, Confidential Offering Memoranda, and other governing documents applicable to each Fund and provided to Investors (collectively referred to as the “Offering Documents”). The roles and responsibilities of Garda are defined in investment advisory agreements between Garda and the Funds, and in the relevant agreements

between Garda and the Advisory Affiliates. Investment restrictions for the Funds, if any, are established in the applicable Offering Documents for the Funds. The interests in the Funds offered by Garda are not registered under the Securities Act of 1933, as amended, and the Funds themselves are not registered under the Investment Company Act of 1940, as amended. Accordingly, interests in the Funds are offered and sold exclusively to U.S. and non-U.S. Investors satisfying the eligibility and suitability requirements in private transactions within and outside the United States. Persons reviewing this Brochure should not construe this as an offering of any Fund. Any offer or solicitation of interests will be made pursuant to the delivery of the Offering Documents for the respective Funds, which should be read carefully prior to investing for a description of the merits and risks of such an investment. Throughout this Brochure, the Funds may also be referred to as “Clients.” The individual investors in the Funds are referred to as “Investors.” Garda and the Advisory Affiliates collectively are referred to throughout this Brochure as “Garda,” “we," “our,” or “us.” As of December 31, 2025, Garda had approximately US $12.461 billion in discretionary net assets under management. Garda’s Regulatory Assets Under Management (as defined in Form ADV Part 1A) was approximately US $207.104 billion.

The compensation each Fund pays Garda is set forth in each Fund’s respective Offering Documents. Garda is paid a management fee (the “Management Fee”) calculated and payable monthly in arrears. Garda deducts this fee directly from such Fund’s assets each month based on the calculated net asset value (“NAV”). The Management Fee is generally calculated on the value of that Fund’s assets minus liabilities, which include the applicable expenses summarized in the Garda Funds Operating Expenses section below. Additionally, Garda may receive performance-based compensation (the “Performance Fee”) based on the specific terms of each Fund’s Offering Documents. Please see Item 6 – Performance-Based Fees and Side-by-Side Management for details on the Performance Fees paid by the Funds. Garda and certain current and former executives and other personnel related to Garda are permitted to invest in a Fund without being subject to the Management Fee or Performance Fee. The fees and expenses associated with an investment in the Funds can vary depending on the Fund and are described in detail in each Fund’s Offering Documents. At our discretion, we may manage Funds with substantially similar or the same investment strategy with higher or lower fees, different fee structures, and different expense payment arrangements. Garda Funds Operating Expenses Each Fund is typically responsible, pursuant to the terms of its Offering Documents, for its ongoing direct, administrative, operating, and other operational and transactional expenses (collectively “Operating Expenses”). These Operating Expenses may be incurred directly by the Fund, or in some instances, Garda will incur the expense and obtain reimbursement from the Fund. Operating Expenses generally paid by the Funds, either directly or by reimbursement to Garda, include, but are not limited to:

Organizational and initial offering expenses (if applicable based on age of Fund);

Government fees, jurisdictional filing fees, regulatory reporting expenses;

Bank and wire transfer fees (including fees of custodians providing services required under the European Union Directive on Alternative Investment Fund Managers or other regulations);

Professional fees and expenses related to the Funds, including for such services as audit, accounting,

consulting,

outside

directors,

board

reporting,

outside

anti-money

laundering officer, and tax preparation;

Legal fees incurred in connection with revisions of the Funds’ Offering Documents, side letters, or other Fund-related legal documents, as well as legal advice related to the Funds;

Directors’ and Officers’ insurance premiums of the Funds as well as all expenses incurred as a result of a Fund’s obligation to indemnify Garda, the Directors, the Administrator, and any other parties to which a Fund has indemnity obligations;

Fees and expenses associated with market data or other data pertaining to trading and investment activity of the Funds, research, data feeds, valuation or quotation services, software platforms that distribute data, and related costs of connectivity (e.g., software platforms that provide data, including Bloomberg™ costs and associated required hardware expenses, inclusive of back-office employee use to support the activities of the Funds);

Systems used to manage the Funds (e.g., analytics, portfolio management, order management, data and research management, and risk management systems);

Fees and expenses related to third-party research or other financial services incurred in connection with evaluating prospective investment opportunities or that support trading and/or investment decisions;

Administrator, registrar, transfer agent, corporate secretary, valuation, and risk aggregator fees and expenses;

Computer software and/or technology specific to the management or reporting obligations of the Funds;

Certain printing, mailing, and communications fees;

Taxes and duties payable by the Funds, together with tax-related expenses, such as professional services for filings required to be made under the Foreign Account Tax Compliance Act or the Common Reporting Standard or taxes, fees, or penalties resulting from any audit adjustments;

Costs of regulatory and self-regulatory filings, and in certain cases ongoing monitoring in support of such filings, relating to the Funds and their trading activities, including Forms PF, N-PX, PQR, 13F, SHO and Annex IV, as well as any costs required by the European Union Directive on Alternative Investment Fund Managers, MAS Regulations, and other U.S. and non-U.S. regulatory reporting forms relating to the offering of the Shares or activities of the Funds or Garda with respect to the Funds;

Other operating expenses incurred in connection with a Fund’s operations, such as bank or custodian fees (including fees of custodians providing services required under AIFMD or other regulations);

Fees and expenses related to Garda and its Advisory Affiliates personnel hiring and retention, including recruitment fees, signing bonuses, buy-out, retention, and similar payments and related expenses, but for the avoidance of any doubt excluding salaries and benefits; and

Other expenses and liabilities incurred in connection with or arising out of a Fund’s operations, including extraordinary or non-recurring charges such as litigation expenses.

Garda Funds Transaction Costs Each Fund also bears all the transaction costs and expenses incurred in connection with its trading and investment activities, which can be significant. Garda’s strategies involve a high degree of portfolio turnover, leverage, complex instruments, and settlement processes. As a result, each Fund incurs correspondingly high transaction costs. These costs include, but are not limited to:

Commissions, access fees, exchange fees, membership fees, clearing fees, execution fees, and fees and expenses assessed by custodians, prime brokers, counterparties, banks, futures commission merchants, and other financial service providers to the Funds;

Interest and other financing charges, as well as costs related to repurchase agreements;

All costs, fees, and other expenses related to any currency hedging and over-the-counter derivatives trading;

Custodial fees, regulatory and self-regulatory fees, and costs of Fund-related filings (including any regulatory, transactional, and other oversight reporting requirements applicable to the Funds ), including fines or assessments;

Costs related to proxy voting;

All Fund-related legal fees and fees related to consulting, research, and other financial services that support trading and/or investment decisions, and third-party analyses or research related to proposed or existing investments (whether or not such investments are consummated); and

Fees associated with the purchase and holding of ETFs or other similar funds, such as brokerage commissions and management fees charged by such ETFs and other similar funds.

Additionally, the Funds employ the administrative services of SS&C Technologies, Inc. (“SS&C”). SS&C serves as the administrator to the Funds and provides certain accounting, middle and back office administrative and operational services, such as trade reconciliations and valuation, on their behalf. Additionally, SS&C provides registrar and transfer agent, antimoney laundering compliance, Cayman Islands Beneficial Ownership Transparency Act compliance, and regulatory reporting services to the Funds. An affiliate of SS&C is also engaged to provide depositary services as may be required by certain countries in the European Union. Each Fund pays SS&C fees for its services at a rate generally comprised of basis point fees based on the Fund’s investment capital (subject to a monthly minimum) as well as a series of agreed-upon fees for certain specific services. Garda may also pursue strategies where a Fund invests in securities of investment companies or other collective investment vehicles (i.e., open-end mutual funds, closed-end funds, ETFs, and other private funds) that are not managed by Garda. In such cases, the Fund will pay the fees charged by these vehicles, which typically include management or other advisory fees, although Garda expects these fees to be not material. Garda does not discount the fees it charges for investments in the vehicles that charge the Fund advisory fees; in these instances, the Fund will pay multiple layers of advisory fees for the assets invested.

In cases where an allocation of an expense between Funds is necessary, Garda will follow such expense allocation methodologies as Garda may approve from time to time, including, for example, methodologies that make allocations based on each Fund’s NAV, position counts, or staffing levels. Garda believes such allocation methodologies are reasonable; however, other methodologies may exist that would yield different results, including results that would be more beneficial to one or more of the Funds. Garda will also incur expenses on behalf of the Funds and itself. The Funds and Garda will typically bear an allocable portion of any such expenses in such manner as Garda, in good faith, determines in accordance with its internal policy or procedures. Garda faces conflicts of interest in implementing the expense terms of the Funds it manages given that expenses generally not borne by one or more such Funds are generally borne by Garda. Furthermore, as noted above, the Funds also bear expenses related to Garda personnel hiring and retention. This creates a conflict of interest for Garda because such personnel are also compensated by Garda. As such, Garda faces an incentive to increase the amounts of personnel hiring and retention expenses in order to reduce amounts of compensation otherwise paid by Garda. In addition, certain personnel hiring and retention payments are subject to vesting and similar conditions determined by Garda from time to time. These conditions (and the enforcement thereof) may differ from similar conditions that govern payments to Garda personnel under Garda’s compensation program, which are borne by Garda rather than the Funds. Garda has broad discretion to set the terms of personnel hiring and retention payments and payments under its own compensation program, including with respect to the vesting and forfeiture terms for each type of payments. Garda seeks to mitigate this conflict of interest by observing its fiduciary duties to the Fund, causing the Funds to bear personnel hiring and retention expenses only when Garda believes it is in the interests of the Fund to do so, and by

disclosing the amounts of such payments in normal-course reporting of expenses borne by the Fund. Valuation Each Fund’s NAV, as of any date of determination, is the value of its assets minus its liabilities as determined by us in accordance with the Fund’s Offering Documents and generally accepted accounting principles. Garda is responsible for determining the fair market value of each Fund’s investment instruments and, in doing so, has considerable discretion in valuing certain privately-placed

and

less

liquid

investment

instruments.

Garda

has adopted

pricing

methodologies for the valuation of the Funds’ investment instruments as described in each Fund’s Offering Documents. We will generally face a conflict of interest involving the valuation of such investment instruments because these values will typically affect our compensation. Garda has established a Valuation Committee to mitigate this conflict and ensure valuations reflect fair market value. Multiple persons participate in and oversee the valuation determinations, including Garda’s Chief Operating Officer, General Counsel, Chief Financial Officer, Head of Finance and Liquidity, and Chief Compliance Officer. Differential Business Terms and Access to Information We have entered, and have caused the Funds to enter, into “side letters” which modify certain terms applicable to certain Investors’ investments in a Fund — including, for example, information reporting, notice provisions, and “most favored nations” protection. Additionally, we respond to requests from Investors or otherwise agree to provide additional information to certain Investors. Further, Garda’s investment of certain employee deferred compensation in a Fund is redeemed in accordance with such terms disclosed in the applicable Fund Offering Documents. Garda will not grant any Investor preferential redemption rights, nor will we provide any Investor preferential access to information that Garda believes to be material. Method of Fee Payment The specific manner in which fees and expenses, including the Performance Fee, are charged by Garda is stated in each Fund’s respective Offering Documents. Garda deducts fees and expenses directly from the Funds, and the Investors’ capital accounts are reduced proportionately by the amount of such fees.

Methods of Analysis Garda generally employs proprietary investment strategies based on fundamental research and quantitative analysis. Investment ideas and information are generated internally through various Garda sources of expertise and market information and externally through an extensive network of brokers and other industry professionals who may provide research or other information supporting our investment analysis. Garda may also, at its discretion, elect to pay fees for trade-specific research from certain providers. Depending on the strategy implemented, we may consider broader macro-economic and geo-political analysis of world markets and economies, including, but not limited to, general or specific economic indicators, inflation rates, trends in international trade, energy and commodity production and supply, foreign exchange trends, governments’ political, fiscal and monetary policies, market liquidity measures, supply and demand measures of industries, sectors and products, assessment of the general market appetite for risk and investment in various financial instruments and products, and other measures we believe are relevant to identifying and assessing available investment opportunities. Investment Strategies Garda implements investment strategies that seek positive returns primarily through leveraged relative value trading strategies and directional positions focused primarily on liquid fixed-income instruments originating in a region that generally extends throughout the Eurozone (countries for which home currency is the Euro), the United States, the United Kingdom, Sweden, Denmark, Norway, Switzerland, Canada, Japan, Australia, and New Zealand. The strategies employed may pursue a variety of relative value, directional, macro, arbitrage, event-based, and other value-driven approaches which involve active trading, with many positions being held on a short-term basis and rapid redeployment of capital. The strategies implemented focus primarily on developed market sovereign debt and interest rate and foreign exchange derivatives, including inflation products, and leverages its trades through repurchase agreements and other instruments. The strategies also trade a variety of supranational, federal agency, semi- or quasi-government debt, commercial and residential mortgage-related instruments, covered bonds, and other instruments. Derivatives are used extensively to hedge and obtain leverage on underlying positions, initiate market access, take outright directional positions, and/or arbitrage market anomalies. Derivatives traded include

both exchange-traded and over-the-counter products, including futures, options (including options on futures), swaptions, repurchase agreements, interest rate swaps, currency swaps, credit default swaps, and total return swaps. Other types of securities and derivatives may also be incorporated into Garda’s strategies. There is generally no material limit within a Fund’s Offering Documents regarding the markets or instruments that may be traded. The investment objectives, strategies, and risks specific to the Funds managed by Garda are set out in the Fund's respective Offering Documents provided to Investors. Unless otherwise restricted in the Offering Documents, each of the Funds generally has the flexibility to pursue a wide or unlimited range of strategies and investment instruments, including strategies and instruments not previously described or disclosed to Investors and without restrictions on asset type, industry, geographic market, concentration, degree of leverage, or other portfolio characteristics. Garda’s strategies and techniques are continually evolving in response to market conditions and other factors. Additionally, we may elect to incubate novel investment strategies. There can be no assurance that we will be successful in doing so, or that the resources allocated to the implementation of new strategies will not diminish the effectiveness of Garda’s implementation of its established strategies. We generally are not required to, and do not intend to, notify Investors in advance of changes in our investment strategies or portfolio composition. Investors and potential Investors should understand that the investment objectives and strategies the Funds implement are generally speculative, highly leveraged, and involve a substantial degree of risk. There can be no assurance that any Fund will achieve its objectives, and Investors could lose all or substantially all of their investment. The following describes some of the characteristics and risks associated with the more significant strategies and investment instruments we may implement or invest in on behalf of Garda’s Clients. The descriptions presented here do not include all risks and conflicts of interest that may apply to an investment in the strategies offered by Garda. Investors and prospective Investors should refer to the relevant Offering Documents for a more complete discussion of applicable risks and conflicts specific to each Fund. Significant Risks - Methods of Analysis Technical Analysis We utilize the analysis of historical and current market data, or technical analysis, in our investment decisions. This type of analysis is subject to the risk that unexpected fundamental factors or other factors may dominate the market during certain periods. Furthermore, a frequent premise of technical analysis is that past market conditions are indicative of future market prices. The influx of

different market participants, structural changes in the markets, the introduction of new financial products, and other developments could materially and adversely affect the profitability of investments made based on technical analysis. Fundamental Analysis Fundamental analysis, which is based on the premise that market mispricing exists because market prices do not incorporate all knowable economic and other relevant data, is subject to the risk of inaccurate or incomplete market information, as well as the difficulty of predicting future prices based upon analysis of all known information. Investments based on fundamental analysis are subject to significant losses when market sentiment leads to investment instruments’ market prices being materially different from the expected prices indicated by fundamental analysis or when technical factors, such as price momentum encouraged by trend following, dominate the market. Model Risk Certain strategies we employ are highly dependent on quantitatively based pricing theories and risk and valuation models, which we use to evaluate investment opportunities. These models generally seek to forecast future price changes and portfolio performance based on a limited number of factors and inputs. The forecasts generated by these models may differ substantially from actual future price realizations, potentially resulting in substantial losses. There can be no assurance that the models we use will be effective. Since the models we use may depend upon inputs from various sources, inaccuracies in such inputs or the calculations we apply may result in unexpected losses. Risk Management We actively take risks on behalf of our Funds, directly exposing the Funds to the risk of loss under a wide variety of market conditions. We have established risk management processes to identify, measure, and monitor risks associated with the investment activities undertaken on behalf of the Funds. The risk management processes are intended to assist us in our investment decision-making process and identify risk exposures we may choose to hedge or otherwise mitigate. However, the risk management processes may fail to identify or anticipate a wide variety of risks that may adversely affect the Funds, potentially exposing the Funds to material, unanticipated losses. Dependence on Garda

The Funds depend on Garda's ability to manage its trading and investment programs. Garda, in turn, depends on the skill, judgment, and expertise of a relatively small number of key investment and business management personnel integral to successfully implementing Fund strategies. Although Garda has retained substantial personnel resources, the investment and business management professionals that specialize in certain strategies implemented by Garda may be strictly limited in number, and the highly specialized nature of the markets in which Garda trades may make these professionals particularly difficult to replace if they were to leave. Losing the services of any such key investment or business management personnel could impair the ability of Garda to manage one or more strategies in a manner consistent with a Fund’s investment objectives, and the consequence to a Fund could be material and adverse, potentially including the premature termination of that Fund. Significant Risks - Strategies Portfolio Turnover Many of the strategies implemented by Garda utilize frequent trading and exhibit high portfolio turnover. Profit opportunities from investments based on short-term market considerations, mispricing, or other criteria can be short-lived. The turnover rate of the Funds’ positions may be significant, involving substantial brokerage commissions and fees as well as clearing costs. Portfolio Diversification Although diversification is an integral part of Garda’s overall portfolio risk management process, the Funds are generally not restricted to the percentage of any Fund’s assets that may be invested in any country, asset class, industry, issuer, instrument, market, sector, or strategy. For certain Funds and strategies where such an approach is consistent with that Fund’s investment objectives, we may take highly concentrated positions in an attempt to maximize a Fund’s returns. Consequently, a loss in any such concentrated position could ultimately result in significant losses to a Fund and proportionately higher losses than if such Fund’s capital had been spread over a wide number of positions. Hedging In executing many of its strategies, Garda may enter into hedging transactions with the intention of reducing or controlling risk but does not generally attempt to hedge all market or other risks inherent in the strategies implemented by the Funds. Garda is not obligated to utilize hedging strategies; Garda may choose not to hedge certain risks or may determine that hedging

is economically unattractive — either in respect of particular positions or with respect to a Fund’s overall portfolio. It is possible that the hedging strategies employed may not be effective in controlling risk and may, due to unexpected changes in correlation between the hedging instrument and the position being hedged, increase rather than reduce both risk and losses. Leverage The Funds typically use leverage extensively and regularly borrow from brokers, banks, and other lenders to finance investments and enhance returns. Through the use of leverage, the Funds acquire substantially more assets and market exposure than a Fund has equity, and the Funds are typically not limited in the amount of leverage they can use. The use of leverage may significantly increase the strategy’s market exposure and associated risks. In addition to the risk that the interest expense and other costs incurred in connection with this borrowing may not be recovered by appreciation in the investments purchased, Garda strategies, which depend on borrowing, frequently have “on-demand” repayment risk. As a general matter, the leverage counterparties that provide financing to the Funds can apply discretionary margin, haircut, financing, security, and collateral valuation policies. Changes by the leverage counterparties in such policies, or the imposition of other credit limitations or restrictions, whether due to market circumstances or governmental, regulatory, or judicial action, breaches of any financing agreement terms and covenants due to poor performance or otherwise, may result in increased margin calls, loss of financing, forced liquidation of positions at disadvantageous prices, termination of swaps, repurchase agreements and other leveraging arrangements, as well as cross-defaults to agreements with other leverage providers. The financing available from leverage counterparties is particularly likely to be restricted or withdrawn in disrupted markets. Any such adverse effects may be exacerbated in the event that such limitations or restrictions are imposed suddenly and/or by multiple market participants at or about the same time. The imposition of such limitations or restrictions could compel Garda to liquidate all or a portion of a Fund’s portfolio at disadvantageous prices. In light of these considerations, there can be no assurances that strategies dependent on leverage will be able to maintain adequate financing arrangements under all market conditions, and the lack of adequate financing could result in significant losses or the inability to pursue the Funds investment strategies. Currency Hedging and Exchange Rate Risk Many of the strategies pursued on behalf of the Funds trade and invest in securities and instruments denominated in non-U.S. currencies. Such investments are subject to the risk that the value of a particular currency will change in relation to the U.S. dollar. Among the factors

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Garda provides investment advisory services to the Funds based on the investment objectives and strategies described in the applicable Fund’s Offering Documents. Investors in the Funds include: corporations, pension plans, sovereign wealth funds, endowments and foundations, private wealth management firms, fund-of-funds and other business entities, Garda, and current and former employees of Garda and other related parties. Investors must meet eligibility, suitability, and minimum investment requirements. The shares or interests in the Funds are not registered under the Securities Act of 1933, and the Funds are not registered under the Investment Company Act of 1940. Accordingly, interests in the Funds are offered and sold exclusively to sophisticated Investors satisfying certain eligibility and suitability requirements in private transactions within the United States or in offshore transactions with non-U.S. Investors. Additionally, each Fund imposes a minimum investment requirement (waived in certain circumstances at the discretion of Garda). The applicable eligibility, suitability, and minimum initial investment requirements are described in more detail in the Offering Documents of each Fund.

Garda generally receives performance-based fees from Funds it manages consistent with the terms of the respective Offering Documents. Typically, the fee is received as a Performance Fee from each Fund equal to a percentage of the positive difference between the NAV of each Investor’s investment in a Fund and the “high water mark” attributable to such investment as of a Fund’s fiscal year end (December 31), and as of each date that an Investor withdraws capital. The specific terms governing the structure and calculation of the Performance Fee and high-water mark are described in detail in the Offering Documents applicable to each Fund. The Performance Fee is calculated pursuant to the terms of each Fund’s Offering Documents. Garda’s compensation is based on our calculation of the NAV, which may provide an incentive to engage in more speculative investment strategies in an effort to maximize a Fund’s gross profits and receive greater compensation. In addition, Garda’s calculation of NAV may provide an incentive to overstate profits and/or understate losses. However, Garda believes its Valuation Policy, external pricing services, review of valuation decisions by its internal Valuation Committee, and the valuation services provided by each Fund’s respective administrator mitigate these inherent risks. Such fee arrangements also may create an incentive to favor higher fee-paying Funds over other Funds in allocating investment opportunities (see Item 12 - Allocation of Investment Opportunities). Garda has implemented policies and procedures that are reasonably designed to ensure that all Funds are treated fairly over time and to prevent this conflict from influencing the allocation of investment opportunities among Funds.

Garda Capital Partners LP is the investment adviser to the Funds. Garda GP LLC, a Delaware limited liability company, is the general partner of Garda Capital Partners LP. As further explained in Item 4, Garda Switzerland, Garda Denmark, and Garda Singapore are affiliates of Garda Capital Partners LP. Garda Switzerland is registered as an asset manager with the Swiss Financial Market Supervisory Authority (“FINMA”), Garda Denmark is registered as an investment firm with the Danish Financial Services Authority (“FSA”), and Garda Singapore is registered as a fund management company with the Monetary Authority of Singapore (“MAS”). As Garda Switzerland, Garda Denmark, and Garda Singapore each provide investment advisory services only to Garda Capital Partners LP in connection with its management of the Funds, Garda does not believe that these relationships create a material conflict of interest for the Funds. Registrations with FINMA, FSA, and MAS do not imply any level of skill or training. As stated in Item 4 — Advisory Business, AMG holds a minority equity interest in Garda. AMG is a publicly-traded global asset management company (NYSE: AMG) with equity investments in boutique investment management firms. AMG does not have any role in Garda's day-to-day operations. More information regarding AMG, including a list of all AMG Affiliates, is available at www.amg.com. Garda has engaged AMG subsidiaries in consulting, marketing, and client services. Additional information regarding this arrangement and the AMG subsidiaries involved is set forth in Item 14 — Client Referrals and Other Compensation. Registered Broker-Dealers Garda is not a registered broker-dealer nor are its employees registered broker-dealer representatives. Selection or Recommendation of Other Advisers Garda does not recommend or select other investment advisers for the Funds and does not have different business relationships with other investment advisers that create a material conflict of interest. However, the Advisory Affiliates may direct Garda’s management of the

Funds in certain countries and markets. The Funds do not incur any additional management fees as a result of the Advisory Affiliates’ participation in the management of the Funds.

Garda has adopted a written code of ethics (the “Code”), which establishes a standard of conduct and compliance with federal securities laws required of all Garda employees. The Code contains policies and procedures intended to avoid actual or potential conflicts of interest related to personal trading and other employee activities. It incorporates throughout the general fiduciary principle that the interest of the Funds must always be placed ahead of the employee’s personal interests or those of Garda or its affiliated entities. Provisions of the Code also prohibit certain actions, including, among other matters, forbidding any employee of Garda from trading, either personally or on behalf of the Funds or others, on material non-public information. All personal investment activities by employees, certain family members, and other accounts in which employees have a financial interest must be conducted in accordance with the requirements of the personal trading policies contained in the Code. Personal trading investment activities may involve purchasing or selling securities that are similar or the same as securities bought or sold for the Funds but are subject to certain guidelines and restrictions intended to minimize potential conflicts with Fund interests. These restrictions include a general prohibition on any personal transaction that would disadvantage or appear to disadvantage a Fund. This includes, among other restrictions, a specific prohibition on personal transactions in anticipation of a Fund’s order and limitations on employee transactions in initial public offerings and limited offering securities. Garda generally requires written pre-clearance for securities transactions. However, Garda may decide not to grant preclearance, particularly if the transaction appears to pose a conflict of interest or otherwise appears improper. As a means to monitor compliance with our policies, the Code requires employees to: (i) report transactions in reportable securities on at least a quarterly basis, and (ii) provide Garda with a detailed summary of certain holdings, both initially upon commencement of employment and at least annually thereafter, to include all portfolios, accounts or securities over which such employees have control or beneficial interest. Garda’s reporting requirements and restrictions on personal securities trading apply to all employees, as well as to each employee’s immediate family members living in the same household and to other parties to whom the employee provides material financial support.

In addition to the policies and procedures contained within the Code, Garda maintains the following policies and procedures relating to our employees’ conduct: Gifts and Entertainment, Political Contributions, and Outside Business Activities. The provisions of these additional policies have been implemented in a manner consistent with the principles contained in the Code and are intended to limit potential conflicts of interest. Insider Trading Garda employees may acquire or come into possession of material, non-public confidential information during our business activities or otherwise. Garda prohibits the buying or selling of securities based on, or while in possession of, material non-public information and considers the knowledge of such information by any Garda employee to be held by Garda generally. Transactions in securities whose issuers are the subject of material non-public information in our possession are thus prohibited for all Garda employees, whether the transactions are on behalf of Garda, the Funds, or the employee’s personal trading accounts. As a result, Garda and our employees may not be able to initiate a transaction for a Fund that may otherwise have been initiated and, further, may be required to maintain a position that otherwise might have been sold or refrain from acquiring a position that might otherwise have been acquired. Related Party Security Transactions Garda Funds may occasionally purchase and/or sell investment securities with other Garda Funds or Garda-related parties unless the Funds Offering Document provisions otherwise restrict such transactions. Certain transactions may be principal trades initiated only when Garda has determined, in good faith, that the transaction is beneficial to the Fund, does not favor the interests of Garda or its affiliates over the Fund’s interests, and is otherwise fair and equitable. Any principal transactions will be affected only in accordance with and as permitted by applicable law and generally require the prior consent of Investors. Whenever possible, Garda will transact a principal trade at, or with reference to, the market price of the securities involved, which may also affect the transaction through a broker-dealer, bank, or other thirdparty market participant. Notwithstanding the foregoing, all principal trades include conflicts of interest, particularly the conflict between acting in our own best interests and those of the Fund. Unless otherwise restricted by provisions of the applicable Offering Documents, cross trades may also occur between the Funds where no participating Fund is deemed to be a Garda proprietary account for principal trade purposes. All principal and cross trades between Funds are subject to Garda’s written policies and procedures that govern transactions between Funds

and are intended to ensure that the transaction is in each participating Fund’s best interest and does not favor one Fund over another. These policies, in addition to other provisions, require the consideration and approval of any Fund-to-Fund transaction by Garda’s Chief Operating Officer, Chief Compliance Officer, and Chief Financial Officer. Garda and its affiliates will not receive commissions or other compensation for effecting cross-trades between the Funds. Clients, prospective Clients, and Investors or prospective Investors in the Funds may obtain a copy of the Code by contacting us at the address or telephone number listed on the first page of this document.

Broker Selection Garda generally has complete discretion to determine, subject to each Fund’s objectives, strategies, and contract terms, the assets to be purchased and sold, in what amounts, the counterparties used, and the commission rates and other costs to be paid for such transactions. Fund Investors should anticipate that transactions executed at our discretion will generate a substantial amount of brokerage commissions and other costs, all of which will be borne by the Fund and not by Garda. Garda selects broker-dealers, banks, and other financial intermediaries (“counterparties” or “brokers”) that we believe will provide execution in a manner such that the Fund’s total cost or proceeds in each transaction is most favorable under the circumstances. In seeking the best available execution for the Funds, we generally consider various factors that may vary significantly from one transaction to the next based on the nature of the exposure or opportunity sought, the type of asset traded, and the geographic location of the relevant markets. The factors considered may be quantitative and qualitative, and the brokers or counterparties Garda determines to be most likely to provide the most favorable outcome for the Fund may not have the lowest available commission costs. Garda has adopted best execution policies and procedures (the “Best Execution Policy”), which set out what Garda considers to be relevant factors in selecting counterparties likely to achieve the most favorable outcome for the Fund. Under the Best Execution Policy, Garda may consider a wide variety of factors including, but not limited to:

Execution price;

Costs, including commission;

The reputation and integrity of the counterparty, including financial strength and stability;

Likelihood of execution;

Speed of execution;

Ability to execute desired volume (size);

Ability to execute with minimum impact on the market;

Ability to make a market in a transaction;

Ability to commit its own capital to facilitate trades;

Ability and willingness to handle complex transactions;

Ability to operate in “limited access” markets;

Other execution capabilities, including confidentiality; and

The full range and quality of services offered by the counterparty;

Quality of research provided;

Availability/access to analysts;

Access to, or participation in, allocations from limited offerings;

Other services such as funding arrangements that benefit Garda’s Funds;

The market knowledge of the counterparty as well as knowledge of the specific asset traded;

Broad market coverage resulting in information flow regarding bids and offers, news and market activity; and

Other considerations relevant to the transaction.

Please note that the list above is representative and should not be considered inclusive of all relevant factors that may be considered in determining the counterparty most likely to provide the most favorable outcome under the circumstances of the transaction. Additionally, the Funds trade options, futures, and other derivative instruments, which can have substantial transaction costs with a limited choice of counterparties. CME and CBOT Memberships The Funds may purchase, and in certain cases have purchased, membership interests in the Chicago Mercantile Exchange and the Chicago Board of Trade (collectively, the “Memberships”)

when Garda anticipates that the Memberships will allow Funds with sufficient volume in exchange-traded derivatives to reduce overall trading costs by clearing transactions at lower clearinghouse commission rates than would otherwise be available. Any Memberships purchased by a Fund are assets of the Fund and not assets of Garda. As a result, the purchase price and all initial and ongoing costs associated with the Memberships will be borne by the Fund, and there can be no assurance that a Fund that purchases a membership interest will realize lower overall transaction costs. Research and Other Soft Dollars Benefits Garda receives certain products and services from counterparties in addition to execution services, which constitute “brokerage and research services” within the meaning of Section 28(e) of the U.S. Securities Exchange Act of 1934, as amended. Such services may include proprietary and third-party research, general market commentary, economic information, industry and company commentary, general reports, quotations, and other market data, discussions with research analysts, and meetings with issuer representatives. While Garda does not enter into “soft dollar” arrangements with counterparties that require specific transaction or commission levels, the Funds may still bear the costs of these brokerage and research services directly and/or through “soft dollar” commissions, which fall under the safe harbor for such services established by Section 28(e). Garda may be incentivized to select a counterparty based on Garda’s interest in receiving brokerage and research services rather than on the Funds’ interest in receiving the lowest cost commission rate. The selection of counterparties based on any consideration other than the applicable commission rates, including the availability of brokerage and research services, may result in higher transaction costs than would otherwise be obtainable. Garda benefits from these arrangements because it does not have to produce or pay for the research, products, or services. Brokerage and research services obtained by the use of commissions arising from a Fund’s transactions may be used by Garda in its other investment activities or on behalf of other Clients. A Fund may not directly or indirectly benefit from the brokerage and research services received in consideration of the “soft dollars” generated by the Fund’s transactions. Directed Brokerage Garda has discretionary authority to select brokers or dealers for the Funds transactions. Fund Investors are not permitted to direct Garda to use a particular broker or dealer to execute portfolio transactions on behalf of the Funds.

Brokerage for Investor Referrals Garda does not consider whether it or a related person receives Client referrals from a counterparty or third party when selecting or recommending counterparties to its Funds. Trade Aggregation Garda’s policies and procedures are implemented with the intent to treat all Funds fairly and equitably over time, although not necessarily identically. When investment decisions in a particular instrument are made contemporaneously on behalf of multiple Funds, executing the decisions as a bunched order ensures that no Fund receives preferential trade execution. When investment mandates are shared by like investment strategies across Funds, Garda is permitted to aggregate orders for bunched execution of multiple Fund orders to eliminate the potential for price discrepancies between Funds. Funds participating in an aggregated order generally will receive the average price of all transactions executed pursuant to the aggregated order. Aggregated orders and the associated transaction costs are generally allocated pro rata among all participating Funds in a manner consistent with each Fund’s level of participation in the order. Garda generally does not aggregate orders when the investment decisions in a particular instrument are not made contemporaneously. Such instances may typically occur when a security or other investment asset is incidentally traded on behalf of multiple Funds under discrete investment mandates or strategies. Allocation of Investment Opportunities In allocating investment and trading opportunities among Funds, Garda determines, for each Fund, using our judgment in good faith as to whether an opportunity is appropriate and in what quantity. We may consider a number of factors in making this determination, including, among others, a Fund’s overall investment strategy, existing portfolio composition, the size or amount of the available opportunity, the risks involved, and other factors relevant to the Fund and investment opportunity. If Garda determines that an investment opportunity is appropriate for more than one Fund, we will determine the allocation of such opportunity prior to the execution of the order and in a manner that we determine to be fair and equitable over time, considering all allocations among such Funds as a whole. In some instances, we may determine that it is in a Fund’s best interest not to participate in an investment opportunity, and we are not required to provide every opportunity to every Fund.

Garda has implemented policies and procedures specific to the allocation of investments purchased or redeemed for the Fund that are intended to ensure that each Fund, over time, is treated fairly and equitably with respect to investment opportunities. Garda will typically consider a number of factors in determining the allocation of investment opportunities to multiple Funds that may include, but are not limited to, the following considerations:

Minimum transaction size or quantity multiples (odd lots) determined by the nature of the security;

Changes in underlying capital in participating Funds;

Existing exposure to the securities, issuer, or market of the proposed transaction;

The different liquidity positions and requirements of the participating Funds;

Tax considerations;

Regulatory considerations (e.g., QIB status);

The relative capitalization and cash availability of the participating Funds;

The relative risk and VAR profiles of the participating Funds;

Strategy alignment;

Portfolio concentration considerations;

Formal diversification requirements imposed by the respective Fund’s constituent documents;

Borrowing base considerations;

Different historical and anticipated subscription and redemption patterns;

Minimum investment criteria;

Fund ramp-up and ramp-down periods;

Investment time horizon;

Availability of ISDA relationship(s) with a trading counterparty; and

Availability of prime brokerage or other specialized relationships with a counterparty.

Absent other considerations, pro-rata allocations based on measurable factors such as each Fund’s NAV or relative portfolio exposure capacity are the most common allocation methods utilized by Garda. Trade Errors While carrying out investing and trading responsibilities on behalf of a Fund, Garda employees may make trading errors — i.e., errors in executing specific trading instructions. Examples of trading errors include: (i) buying or selling at a price or quantity that is inconsistent with the specific trading instructions generated by a particular strategy, or (ii) buying rather than selling a particular investment (and vice versa). Trading errors are distinguishable from errors in judgment, due diligence, or other factors leading to a specific trading instruction being generated, as well as from unauthorized trading or other improper conduct by Garda employees. Garda will treat all operational or trading errors (including those that result in losses and those that result in gains) as for the account of the Fund unless they are the result of conduct on the part of Garda employees that does not meet the standard of care set forth in the applicable Fund's Offering Documents.

Garda may choose to use outside solicitors for Investor referrals and/or enter into solicitation agreements in the future without notice or consent of our Clients. If any Investor is directly subject to placement and/or referral fees to persons who introduce them to Garda, any such fees and applicable conflicts of interest will be disclosed to the Investor prior to investing. Garda currently uses the services of an exempt market dealer to meet certain regulatory obligations in Canada. Additionally, Garda is party to consulting, client service, and marketing agreements with AMG affiliates. These include Affiliated Managers Group Limited ("AMG Ltd") and AMG Distributors Inc. ("AMG Distributors"), collectively (“AMG Subsidiaries”). AMG Ltd is not a broker-dealer, investment adviser, or any other financial institution described in Item 7.A. of Form ADV Part 1A. Depending on the foreign jurisdiction, AMG Ltd may be registered or exempt from registration, as appropriate, with the relevant foreign financial regulatory authorities. AMG Distributors is a limited-purpose broker-dealer registered with the SEC. The AMG Subsidiaries are engaged in providing certain consulting services to Garda. Such consulting services include, without limitation, information and assistance regarding general market intelligence, sales data, product and service positioning, local marketing rules and practices, and other assistance as may be requested from time to time. Additionally, AMG Subsidiaries provide client services upon request on behalf of Garda and assist Garda in responding to requests for proposals and assembling marketing materials. Further, AMG Subsidiaries perform liaison and reporting services (which may include attending periodic Investor meetings, participating in telephone and/or video conference calls, providing reports, compiling data, and responding to inquiries and questions with assistance from Garda). Garda pays the AMG Subsidiaries a fee for these services. Such fee is based either upon a percentage of the amount invested with Garda or pursuant to an annual fee arrangement with Garda. Due to these engagements, the AMG Subsidiaries are deemed to be providing an endorsement of Garda and its applicable Funds. Because the AMG Subsidiaries receive payment for services that support the fundraising efforts of Garda and its Funds, and because AMG has an equity interest in Garda, AMG has a conflict of interest because it has an ongoing economic incentive to endorse and make positive statements about Garda, any fund managed by Garda, and Garda’s officers, principals, employees, or affiliates. This conflict is further enhanced by AMG’s equity interest in Garda, through which AMG will financially benefit from Garda’s profits.

In addition, AMG is incentivized to endorse Garda and its Funds to maintain goodwill with Garda. Garda will then be incentivized to select AMG to provide similar services for future fundraising. Prospective Investors referred to Garda by AMG Subsidiaries should ask AMG or their investment professionals for more information. From time to time, Garda participates in conferences, programs, and other capital introduction services sponsored by brokerage firms or banks that provide custodial, financing, or execution services to the Funds. These conferences and capital introduction programs are generally incidental to other brokerage-related services and may be a means by which Garda can be introduced to qualified institutions that are potential Investors in the Funds. While these types of introductory services provided by a brokerage firm or bank may influence us in evaluating whether to use the brokerage firm or bank in connection with transaction execution, financing, custody, or other activities of the Funds, neither Garda nor the Funds compensate brokerage firms directly or through any “soft dollar” execution arrangements for introduction services.

Garda and its employees have not been involved in any legal or disciplinary events in the past 10 years that would be material to an Investor’s or a prospective Investor’s evaluation of our advisory business, personnel, or the integrity of our management.

For each of Garda’s investment strategies, one or more senior members of the portfolio management team are primarily responsible for reviewing Fund accounts and may do so individually or as a group, depending upon market conditions or Fund needs. The Senior Portfolio Managers and Portfolio Managers collectively perform the intraday, daily, weekly, or monthly reviews of positions, risks, and opportunities as they deem appropriate and as market conditions warrant. Such reviews will consider portfolio composition in light of current and anticipated market conditions, including assessments of portfolio performance, exposures, risks, and potential investment opportunities consistent with the Fund’s investment objectives. Senior officers of Garda, including the Fund's Chief Investment Officer, conduct additional periodic reviews of investment strategies and portfolio exposures for each Fund account. The frequency of such reviews is determined by the nature of the strategy being reviewed and market conditions. In addition to the portfolio management teams responsible for effecting investment strategies on behalf of Fund accounts, Garda has dedicated risk management staff responsible for risk management systems, measurements, and controls, as well as conducting daily risk and exposure reviews of Fund accounts. The reviews performed consider systemic, portfolio-level, and position-specific risks and include exception testing against internally established risk thresholds and portfolio limits. Garda utilizes proprietary and commercially licensed computer systems and information services to assist in monitoring, analyzing, and managing the risks inherent in the Funds’ investments. Garda may modify any risk management techniques or applicable risk thresholds or limits at any time. In addition to the reviews undertaken by Garda, each Fund has an independent administrator who reviews security valuation monthly and reconciles positions and cash details directly with Fund custodians daily. Garda has also engaged an independent public accounting firm to conduct annual audits of the Funds. As part of the annual audit process, the accounting firm independently verifies certain security prices and positions in the Funds and confirms the Funds’ ownership of investment assets. The Funds provide Investors with weekly Fund performance estimates, unaudited monthly performance reports, audited annual fund financial statements, quarterly expense reporting, and, as applicable, tax information related to their investments in the Fund.

Although the Funds provide information that Investors may use for tax purposes, Garda does not provide legal or tax advice. Investors should consult their legal and tax advisors before making any investment decisions.

Garda does not serve as the qualified custodian of any assets owned by the Funds and does not possess or maintain physical custody of any securities or cash. However, Garda is deemed to have custody of the cash and investment securities held by the Funds because of the breadth of authority delegated to it under the terms of the advisory agreements in place between Garda and the Funds. The Funds’ cash and investment securities are held with qualified custodians, and each Fund receives at least quarterly statements from the qualified custodians. The Funds’ Investors do not receive account statements from the Funds’ custodians; rather, the Funds are subject to an annual audit conducted by an independent public accounting firm registered and examined by the Public Company Accounting Oversight Board. The audited financial statements are distributed to each Fund Investor within the applicable required timeframe of each respective Fund’s fiscal year-end, which in no instance will be more than 120 days. The Funds’ Investors also receive account statements from the relevant Fund’s administrator on either a monthly or quarterly basis, including the Fund’s estimated performance and NAV after the end of each reporting period. Investors should carefully review all account statements and other communications from the Fund’s administrator.

Garda exercises discretionary authority in managing the investments of each Fund based on each Fund’s particular investment objectives, policies, and strategies disclosed in its Offering Documents. The provisions of the advisory agreements between Garda and each Fund define discretionary authority over the Funds.

Garda has adopted written proxy voting policies and procedures (the “Proxy Voting Policy”) applicable to all Clients where we have voting authority for proxy proposals, amendments, consents, or resolutions relating to Client securities, including, if any, interests in private investments (collectively “proxies”). Under the Proxy Voting Policy, our primary goal is to vote proxies prudently and solely in the best interest of our Clients without subordinating the Clients’ interests to our own. When a Client has authorized Garda to vote proxies on its behalf, Garda will generally not accept instructions from the Client regarding how to vote proxies. Garda will vote for each Fund’s proxies in the manner that it believes is consistent with achieving the Fund’s investment objectives. Unless otherwise specified in a written agreement between Garda and the Fund or otherwise set out in the Offering Documents, the only factors to be considered in voting proxies are those that would affect the value of Fund assets. Absent a particular reason to the contrary, it is Garda’s practice to generally vote in accordance with the recommendation of the applicable company’s management on routine matters. In the case of non-recurring or extraordinary matters, such as a material change in business terms, Garda may consider the vote on a case-by-case basis in accordance with the goals of maximizing the value of the Fund’s positions. Garda may also occasionally abstain from voting a proxy or a specific proxy item when we conclude that the potential benefit of voting is outweighed by the cost or otherwise believe it is not in the Fund’s best interest to vote. Garda may have a conflict of interest in connection with voting on a particular matter. If a conflict exists that cannot be otherwise addressed, Garda will address it by either obtaining the informed consent of the Fund or obtaining the services of an independent third party or outside counsel to provide a recommendation and vote in accordance with that recommendation. Garda has engaged a third party to assist with identifying, casting, and recording information regarding proxy voting. The Proxy Voting Policy also addresses Clients’ participation in class actions. Garda’s standard advisory agreement authorizes Garda to direct Client participation in class actions and has the discretion to decide whether a Client participates or opts out of any applicable class action. Garda will evaluate the necessity of participating in shareholder class action litigation and similar matters as they arise but will not participate in class action litigation unless it is determined it would be in the best interest of the Clients. Garda has engaged a third party to assist in identifying and processing class action litigation. Garda will compensate such third

parties on a contingency basis, whereby they will receive a percentage of any recovery obtained. The Clients will bear the cost (i.e., receive a reduced amount of any class action proceeds) for the third party that is used for class action recovery services. Garda will credit any class action settlements received for the Clients to the Clients at the time of receipt. Clients and Investors in Funds managed by Garda may request a copy of our Proxy Voting Policy and proxy voting records relevant to their account by contacting us at the address or telephone number listed on the first page of this Brochure.

As of the date of this Brochure, Garda does not solicit fees more than six months in advance. As such, a balance sheet is not required to be provided. In addition, Garda has no financial condition that is reasonably likely to impair its ability to meet contractual commitments to Clients and has never been the subject of a bankruptcy petition.