Glendon Capital Management LP

Glendon Capital Management L.P. is a limited partnership organized under the laws of the state of Delaware and is registered with the U.S. Securities and Exchange Commission (“SEC”) as an investment adviser. GCM is owned by Holly Kim, Christopher Sayer, Alexander Thain, Christopher Delaney, Brian Berman, Matthew Barrett, Michael Keegan and Glendon Employee Company M, LP. Other than Mr. Barrett, who retired in 2025, and Mr. Keegan, who retired in 2021, all of GCM’s individual owners are active in managing the business of GCM (such active partners, the “Glendon Partners” or the “Partners”). Ms. Kim and Messrs. Sayer and Thain serve as the Firm’s Portfolio Managers and are the current members of the Glendon Investment Committee. GCM was founded by Matthew Barrett, Holly Kim and Brian Berman, among others, and commenced operations on April 26, 2013. Christopher Sayer became a Partner on January 1, 2018. Alexander Thain and Christopher Delaney became Partners on October 1, 2021. Prior to forming GCM, Messrs. Barrett and Berman, and Ms. Kim (the “Founding Partners”) were the Managing Directors of Barclays Asset Management Group (“BAMG”), a subsidiary of Barclays Bank PLC (“Barclays”). The Founding Partners had previously worked together as Managing Directors of the Oaktree Capital Management Opportunities Fund (the “OCM Opportunities Fund”) investment team. From 2007 – 2014, the Glendon Partners and certain members of the Glendon Investment Team (as defined below) managed an account for Barclays (the “Barclays Account”). The Partners are supported by additional investment professionals (together with the Glendon Partners, the “Glendon Investment Team”). GCM is focused primarily on investing in credit opportunities and other special situations resulting from markets experiencing distress or dislocation, as well as adjacencies to those markets. Clients (as defined in the immediately following paragraph) may invest in and hold a variety of instruments, including, but not limited to, bank loans, public and private corporate bonds, municipal and sovereign debt, asset‐backed securities, bankruptcy claims, equity securities (including those received in connection with debt restructurings or otherwise (including, occasionally, through initial public offerings)), and investments in private equity. Clients may also hold a variety of derivative instruments or short positions for investment and hedging purposes. GCM provides advisory services as described in the investment program of each Client’s Governing Documents (defined below) or as set forth in the advisory contract with such Client. Please refer to Item 8 for a more detailed description of our investment strategies and the types of investment instruments held by our Clients. GCM acts as the investment manager to Glendon Opportunities Fund, L.P. and its associated feeder funds (“G1”), Glendon Opportunities Fund II, L.P. and its associated feeder funds (“G2”), Glendon Opportunities Fund III, L.P. and its associated feeder funds (“G3”), and to certain separately managed accounts of institutional investors. In the future, GCM may provide discretionary or non‐discretionary investment advisory services to other investment funds (collectively with G1, G2, and G3, the “Funds”) and separate account clients (collectively with the managed accounts of institutional investors, the “Separate Accounts” and together with the Funds, the “Clients”). The Funds may use master‐feeder structures, parallel funds, alternative investment vehicles or other structures. To the extent that such

structures are employed, references to a particular Fund will mean collectively the associated master fund, feeder funds and/or any parallel funds or alternative investment vehicles. GCM tailors its advisory services as described in the investment program of each Fund’s private placement memorandum and organizational documents (collectively, “Governing Documents”) or the advisory contract with each Separate Account client (each, an “Account Agreement”), as applicable. Investors and prospective investors are urged to consult such applicable Governing Documents or Account Agreements for more complete information about the investment objectives and investment restrictions with respect to a particular investment program. In managing assets for a particular Fund, GCM will enter into “side letters” or other arrangements with certain investors of a Fund granting such investors certain specific rights, benefits or privileges that are not made available to other investors. GCM also provides investment advice to Altair Global Credit Opportunities Fund (A), LLC on a sub-advisory basis and may sub-advise other third‐party Funds in the future. Glendon does not participate in any wrap fee programs. As of December 31, 2025, GCM managed regulatory assets of $5,238,483,111 on a discretionary basis (approximately $4.6 billion AUM), inclusive of GCM private funds’ undrawn capital commitments.1

Potential Fund investors and Separate Account clients should review the applicable Governing Documents or Account Agreements in conjunction with this brochure for more complete information about the fees and compensation payable and expenses reimbursable to GCM. GCM does not currently have a fee schedule. Fees payable to GCM under its Separate Account arrangements are generally subject to negotiation. Fees payable to GCM with respect to its Funds may be waived or modified by GCM in its sole discretion with respect to certain investors, as more fully disclosed in the applicable Fund’s Governing Documents. The specific manner by which GCM will charge fees to a Fund or a Separate Account will be established in the applicable Governing Documents or Account Agreements. Our fees will generally consist of a management fee, which typically is calculated based on invested capital and billed on a quarterly basis payable in advance, and performance-based compensation that may take the form of a performance fee billed on an annual basis, an incentive allocation or a carried interest distribution. Subject to the applicable Governing Documents or Accounts Agreements, accounts initiated or terminated during a calendar quarter may be charged a prorated fee. Upon termination of the relationship with any Separate Account client or Fund investor, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable.

As of the date of this brochure, GCM has commenced fundraising for its fourth private fund, Glendon Opportunities Fund IV, L.P. (“G4”). Although G4 is not yet active, it will have a substantially similar investment strategy to G1, G2 and G3.

GCM’s fees are exclusive of brokerage commissions, transaction fees and other related costs and expenses, which shall be incurred and paid by the Client. Clients will incur and pay certain charges imposed by custodians, brokers, fund administrators, and other third parties, including, but not limited to, fees charged by managers, custodial fees, deferred sales charges, odd‐lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Such charges, fees and commissions are exclusive of and in addition to GCM’s fees, and GCM shall not receive any portion of these commissions, fees and charges. Additionally, GCM will charge its Clients for other costs and expenses as set forth in the applicable Governing Documents or Account Agreement, including, but not limited to, research expenses (including, but not limited to, Bloomberg terminal access and general industry or sector research that may not be specific to a particular investment), trading-related expenses (including, but not limited, expenses associated with trade order management systems), investment-related attorneys’ fees and expenses, auditor and tax advisory expenses, insurance premiums and related expenses, broken deal expenses, and other investment-related advisory fees, including the use of “expert network” consultants, and other due diligence related expenses (including, but not limited to, GCM staff travel that is investment‐related). The expenses referred to herein (and as more fully set forth in the applicable Governing Documents and Account Agreements) will be charged regardless of whether an investment is made and will be allocated on a fair and equitable basis where more than one GCM Client invests or potentially would have invested. GCM generally will allocate investment-related expenses pro rata based on each Client’s relative holdings of such investment(s) as of the end of the quarter in which the expense was paid. GCM may adjust such allocation, however, as it deems appropriate to account for disproportionate changes in the relative holdings among the Clients. For expenses relating to a potential investment that has not been made (including broken deals and general research in industries or sectors where an investment has not yet been made), GCM generally will allocate such expenses pro rata based on each Client’s expected participation in the potential investment(s). In addition, in some cases, GCM will allocate expenses associated with industry or sector research expenses pro rata based on each Client’s relative holdings of investments in such industry or sector. Item 12 further describes the factors that GCM considers in selecting broker‐dealers for client transactions and determining the reasonableness of their compensation (i.e., commissions). In addition to the fees and expenses described above, investors in Funds and Separate Account clients will be subject to additional expenses associated with managing, operating or servicing a Separate Account or Fund, as applicable. Potential Fund investors and Separate Account clients should consult the relevant Governing Documents or Account Agreement for a more complete discussion of the fees, expenses and other compensation arrangements to which such Clients and investors will or may be subject.

GCM’s staff integrates experienced professionals in the disciplines that are critical to successful analysis of distressed debt, including accounting, law, bankruptcy, capital markets and fundamental credit and securities analysis. They combine extensive experience in distressed bank debt, defaulted securities and bankruptcy situations with proven expertise in valuing companies and assets, negotiation and restructuring. However, investing in distressed debt and special situations involves risks that are more fully discussed in Item 8.B below. There can be no assurance that a Client’s investment return objectives will be achieved or that substantial loss of a Client’s investment principal will be avoided. Clients should be prepared to bear the loss of all of their investment principal managed by GCM. A. Methods of Analysis and Investment Strategies

GCM’s investment strategy is to seek to execute credit and equity investments in markets experiencing distress and dislocation as well as adjacencies to those markets. This strategy seeks to exploit the cyclicality of credit markets and the assets financed by traditional credit investors. Investment in debt and equity securities involves risk of loss that investors in a Fund or Separate Account Clients must be prepared to bear. This brochure describes our investment process, which is subject to further refinement and development by GCM and its Investment Team. This summary should not be interpreted to limit in any way GCM’s investment strategies or activities. GCM may offer advisory services, provide advice with respect to any investment strategy (whether or not described in this brochure), and make any investments (including those not described in this brochure) that GCM considers appropriate subject to each Client’s stated investment objectives and guidelines. The foundational tenets of Glendon’s investment philosophy, applied across industries, markets and cycles, are built upon Glendon’s beliefs that: • The cyclical nature of distressed markets is best exploited by matching investable capital to the distressed opportunity set. • Extended periods of low volatility can lead to the creation of credit excesses and asset inflation, which bring about the conditions for high market volatility. Stresses and/or exogenous shocks can trigger the recognition and reversal of these excesses, creating scalable distressed market opportunities. • The prices and yields of credit instruments can overreact to stresses and exogenous shocks across various industries, markets and regions, creating attractive investment opportunities in credit and the assets financed by traditional credit investors. • When properly analyzed and underwritten, these investment opportunities can generate equity like returns, often while providing the greater downside protections of credit instruments. • Shocks and stresses in markets are episodic and global in nature. The Glendon team seeks to actively migrate its efforts and resources to where these dislocations occur. Glendon believes that distressed investment opportunity or pricing dislocations can result from market disruptions, including the effects of economic cycles, supply and demand imbalances, regulatory changes, litigation, and other exogenous shocks. As these events occur, Glendon believes that the pro‐cyclical nature of traditional credit investors (highly leveraged financial institutions, securitization vehicles with heightened risk aversion, and fixed income funds subject to capital outflows) can cause credit prices to overreact to volatility, creating investment opportunities.

The types of distressed opportunities Glendon pursues can occur abruptly, across different regions, industries, asset classes and types of instruments. To capitalize on these opportunities, Glendon has positioned itself as a responsive and analytical investor with a flexible investment mandate described below. Glendon believes that these characteristics are essential to its investment strategy because specific sources and/or timing of exogenous shocks are generally not foreseeable, and deep values presented by pockets of dislocation may develop, and close, quickly. Glendon will invest across regions, industries, asset classes and types of instruments as dislocations are inherently episodic in nature. Glendon believes that a flexible approach is likely to yield a wide range of attractive risk-adjusted investments for credit opportunities and special situations for its Clients. Glendon will seek to generate substantial appreciation in its investments as market stresses subside, often as a result of restructuring, reorganization or the return of normal markets and liquidity conditions. Preservation of capital is a primary goal of Glendon, and Glendon expects to focus on conservative underwriting of the investment opportunities it pursues and seek appropriate downside protections with respect to its investments. As part of its investment strategy, Glendon also considers certain responsible investment factors in accordance with its Responsible Investment Policy. Investment Types GCM expects its investment strategy will be executed primarily through the following categories of distress / dislocation:2 • Stressed and Distressed Company Securities. Glendon’s primary strategy is to purchase the instruments – bonds, loans, unsecured claims, convertible instruments, preferred stock and equity – in the secondary market issued by companies that are undergoing financial stress, including companies involved in insolvency proceedings. Deterioration in a company’s financial condition can result from a downturn in general economic conditions or a decline in its industry conditions or company performance and is often exacerbated by a highly leveraged capital structure and liquidity pressures. Glendon focuses on claims that are senior and/or secured in the capital structure of target companies undergoing distress in order to insulate its investment from the risk of bankruptcy, valuation decline, the costs of distress, and/or an elongated cycle. Glendon also may invest in the more junior securities of a company if it believes there is strong valuation coverage. Glendon may also purchase different types of claims to reduce the risk of intercreditor issues that may result from collateral valuation or process risk. Glendon may also enter into credit default swaps, short sales of securities and other structured investments as part of its overall investment strategy. Glendon values a company in the context of its market distress—whether going concern or liquidation—and, through its analysis, estimates a recovery value for the different claims in the 2 The opportunities Glendon pursues depend on a variety of factors, including prevailing market conditions and

investment availability. There is no assurance that any particular investment or strategy will be successful, or that Clients will be able to achieve their investment objectives or avoid substantial losses.

company’s capital structure. The Glendon Investment Team is experienced in valuing and investing in distressed companies across many different sectors, including industrials, consumer goods, retail, chemicals, metals and mining, energy, transportation, media and telecommunications, auto suppliers, building materials, real estate and infrastructure. The Firm also has experience investing in opportunities across regions, generally focusing on jurisdictions with strong creditors’ rights protections and an established rule of law. At times, Glendon may be the lead investor and ultimately gain control of an entity or participate with other creditors in a restructuring process. Typically, distressed investment opportunities occur episodically across these different categories and, as such, the composition of GCM’s portfolio will likely depend in large part on the particular industries, asset classes or regions experiencing cyclical downturns or impacted by exogenous shock. • Post‐Reorganization Securities. These securities are issued to creditors of companies that have completed a reorganization in satisfaction of a creditor’s claims and may include both fixed income and equity securities. Glendon may receive these securities in connection with a claim it held in a company’s bankruptcy, or it may purchase these securities after a company’s reorganization on a secondary basis from traditional credit investors as well as non‐traditional investors receiving these securities in exchange for prior claims. The markets for these securities – frequently issued by companies in out-of-favor industries – are often characterized by limited liquidity, wider bid/asked spreads, an absence of major broker‐dealers and limited research. Glendon believes that the limited market participation of traditional buy‐ side investors in these securities results in volatile price swings, and the limited published research can result in overlooked inherent value of the company, including tax attributes such as net operating loss carry‐forwards that may have been preserved as part of the company’s reorganization. • Downgraded Securities (“Fallen Angels”). An important component of Glendon’s investment strategy is investments in fixed‐income securities that have been downgraded by credit agencies. Ratings decisions (in particular, a downgrade to below investment‐grade ratings) can create heavy selling, as investment‐grade funds may have limits for investing in lower‐rated securities, and regulated entities may face punitive capital charges in holding these instruments. Due to the large size of the investment‐grade fixed‐income market, Glendon is often able to readily scale its sourcing of downgraded securities given the relative lack of buying interest in these securities. Glendon typically performs a recovery analysis that takes into consideration the stress the target company is undergoing and the process and period of time over which those stresses may be resolved. Broadly, three outcomes are weighed in Glendon’s analysis to determine an entry point: (i) if the stress is transitory, the instrument may regain its rating; (ii) if the stress is ongoing, the instrument may be relegated to a different, more speculative, asset class, such as high yield; or (iii) if the stress is profound, the instrument may be restructured in a workout or insolvency proceeding. Generally, the catalyst for the investment is the eventual return of traditional investors to the market for the instrument. The Firm

has a particular focus on the securities of financial institutions with capital adequacy concerns, including hybrid securities of banks and insurance companies. Glendon believes its experience in the valuation of credit instruments held by financial institutions is vital in assessing outcomes in this particular sector. • Tax‐Exempt Bonds. Glendon believes that the volatility of the U.S. tax‐exempt bond market is highly correlated to the pro‐cyclical fund flows for the retail funds that dominate this market. In Glendon’s experience, fund flows are very reactive to news reports regarding the financial health of the municipalities and commonwealths of the United States, given the prospect of low recovery rates for unsecured bonds issued by municipalities that have undergone Chapter 9 reorganizations. Retail outflows have at times led to indiscriminate selling. Glendon focuses on those tax‐ exempt bonds where (i) it believes that the likelihood of insolvency is low, (ii) and/or the bond is protected by an enforceable security interest or other features that may limit downside or (iii) the bond’s credit is unrelated to the underlying creditworthiness of any municipality. • Asset‐backed Securities. The Firm periodically participates in the securitization markets, with participations coinciding with credit cycle turns for the assets financed by these instruments. Asset‐backed securitizations in which Glendon has invested include securitizations involving aircraft, residential mortgages, commercial mortgages and student loans, among others. Glendon generally focuses on the more senior instruments in securitizations as determined by securitization documentation and cash‐flow or “waterfall” analysis. In addition, the Firm focuses on those instruments that have been downgraded below investment‐grade and, as a result, may carry punitive capital charges to the financial institutions that may hold them, which may incentivize these institutions to sell at prices that Glendon believes are undervalued. • Special Situations. Glendon also focuses on “special situation” investments, which include investments in (whole) asset platforms, liquidations of companies or financial institutions, rescue or debtor‐in‐possession financing and securities or claims, including litigation trusts, where the enforcement of creditors’ rights or a litigation outcome is determinative. Glendon also seeks to invest in equities and other securities of non‐distressed and non‐stressed companies by utilizing Glendon’s knowledge of and experiences with companies that are reorganizing or the credit markets in general. Glendon may also invest in equities and other securities not implicated in the dislocation of credit markets if, in its judgment, these investments are important for portfolio construction purposes. B.

Risk of Loss

The investment strategies employed by GCM on behalf of our Clients involve significant risks. Prospective investors in our investment funds should carefully review the risks described in the relevant Governing Documents for the relevant investment fund and should evaluate the

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As stated above, GCM provides portfolio management services to the Funds and the Separate Accounts. GCM expects to provide portfolio management services to other private investment funds in the future and, potentially, other separately managed account clients, including, but not limited to, accounts for institutions such as banking organizations, foreign investment companies, educational endowments, corporate pension and profit‐sharing plans, Taft‐Hartley plans, charitable institutions, foundations, endowments, municipalities, trust programs, sovereign funds, foreign funds, and other U.S. and international institutions. GCM will also offer its services to registered investment companies, high net worth individuals, and family offices. The minimum separately managed account size that GCM will manage is typically $100,000,000.

GCM charges performance‐based compensation to the Funds and the Separate Accounts, which may take the form of performance fees, incentive allocations or carried interest distributions. Performance-based compensation is subject to individualized agreements

with each Client. GCM will structure any performance-based compensation to comply with Section 205(a)(1) of the Advisers Act and Rule 205‐3 thereunder. Performance-based compensation arrangements may create an incentive for GCM to recommend investments that may be riskier or more speculative than those that would be recommended under a different fee arrangement. Such performance-based compensation arrangements also create an incentive to favor Clients that pay higher performance-based compensation over other Clients that pay lower or no performance-based compensation in the allocation of investment opportunities. GCM has adopted policies and procedures designed to ensure that all Clients are treated fairly and equitably, and to prevent this potential conflict from influencing the allocation of investment opportunities among Clients. The amount of performance-based compensation, if any, varies amongst our Clients and will be subject to the terms of the applicable Governing Documents or Account Agreement. In addition, performance-based compensation will be paid by Clients at different times such as annually or upon distributions exceeding various thresholds. Any given performance-based compensation may be more or less advantageous for a particular Client depending on performance and timing of distributions.

GCM is affiliated with and under common control with (i) Glendon Capital Associates, LLC (“GCA”), which is the general partner in G1, (ii) Glendon Capital Associates II, LLC (“GCA II”), which is the general partner in G2, and (iii) Glendon Capital Associates III, LLC (“GCA III”). GCM serves as the investment adviser to each of G1, G2 and G3 (each, a “GCM Fund”). Each of GCA, GCA II and GCA III (each, a “GCM GP”) also serves as general partner of the feeder funds of the applicable GCM Fund. It is anticipated that GCM will form additional affiliates to act as general partner for its Funds that are formed as limited partnerships. Each GCM GP has claimed an exemption from registration with the CFTC with respect to its status as a commodity pool operator pursuant to CFTC rule 4.13(a)(3). GCM is also affiliated with and under common control with Glendon Services L.P. (“GSLP”), a research consultant located in New York, N.Y. that is exempt from registration. GSLP provides research services and support to GCM and does not have its own Clients.

The personal transactions and investment activities of employees of investment advisory firms are the subject of various federal securities laws, rules and regulations. GCM requires pre‐clearance with respect to personal trading by access persons in certain investments and all of GCM’s access persons must provide the Chief Compliance Officer with a list of their personal accounts and an initial holdings report within 10 days of becoming an access person. In addition, GCM’s access persons must provide annual holdings reports and quarterly transaction reports in accordance with SEC Rule 204A‐1. Access persons must conduct all personal securities transactions in a manner that avoids a conflict between their personal interests and those of GCM and its Clients. GCM’s Code of Ethics prohibits access persons from personal account dealings in any investment in which a Client holds a position or is actively under consideration as an investment for a Client of GCM’s. GCM has adopted a Code of Ethics for all supervised persons in the firm describing its high standard of business conduct and fiduciary duty to its Clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts

and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at GCM must acknowledge the terms of the Code of Ethics at the commencement of their employment with GCM, annually and whenever the Code of Ethics is amended. GCM’s Clients or prospective clients may request a copy of the firm's Code of Ethics by contacting Haig Maghakian, Chief Compliance Officer at (310) 907‐0459 or by e‐mail at hmaghakian@glendoncap.com. GCM and its personnel do not purchase any securities for their own accounts from, or sell any securities for their own accounts to, Funds. However, from time to time, subject to applicable Client investment guidelines and restrictions, GCM may direct one Client to sell securities to another Client through an internal cross transaction. These “cross transactions” also may occur with managed accounts. Cross trades may be executed as an “internal cross” where one Client may book the transaction at a price determined in accordance with GCM’s policies and procedures. No fees will be charged to Clients in connection with the completion of a cross trade. Cross transactions and principal transactions may give rise to conflicts of interest between Clients. For example, one Fund could be advantaged to the detriment of another Fund in the event that the securities being exchanged are not priced in a manner that reflects their fair value. To the extent that any such cross transaction may be viewed as a principal transaction due to the ownership interest in the Funds by GCM and its personnel, GCM will comply with the requirements of Section 206(3) of the Advisers Act and the governing documents of the relevant fund Client. B. Potential Conflicts of Interest. Please note the following section primarily relates to but is not exclusive to conflicts investors should be aware of prior to investing with GCM. Investors should be aware that, potential and actual conflicts of interest may occur between Clients, on the one hand, and GCM and its affiliates, on the other. The following discussion describes certain potential conflicts of interest that should be carefully evaluated before making an investment with GCM. Dedication of Glendon Personnel Time to the Glendon Clients. The investment professionals and other employees of GCM and its affiliates will be permitted to spend a portion of their business time on activities other than a specific Client or its portfolio investments. As a result, such persons may spend less time on the activities of a Client than may be required under certain circumstances. These activities could be viewed as creating a conflict of interest in that the time and effort of GCM and its officers and employees will not be devoted exclusively to the business of a Client, but will be allocated between the businesses of all GCM Clients. Interests in Portfolio Companies or Service Providers. GCM and/or its affiliates may employ or engage personnel with pre-existing ownership interests in or who were employed by portfolio companies owned by one or more GCM Clients or other investment vehicles advised by GCM and/or its affiliates. Similarly, GCM, its affiliates and/or personnel may (i) invest in financial institutions, service providers and other market participants, including,

but not limited to, managers of private funds, banks, brokers, advisors, consultants, and finders, and (ii) maintain relationships with executives, attorneys, accountants, institutional investors, family offices, lenders, current and former employees, and current and former portfolio company executives, as well as certain family members or close contacts of these persons. Certain of these persons or entities will engage in transactions with and/or provide services (including at reduced rates) to GCM, its affiliates, and/or its Clients or other investment vehicles advised by GCM or its affiliates. In other circumstances, these service providers are expected to provide personal banking, private wealth or lending arrangements to GCM personnel and their estate planning vehicles. GCM expects to be subject to a potential conflict of interest with its Clients in recommending the retention or continuation of a portfolio company or third-party service provider if such recommendation, for example, is motivated by a belief that the service provider or its affiliate(s) will continue to invest in one or more GCM Clients, will provide GCM with information about markets and industries in which GCM operates (or is contemplating operations) or will provide other services that are beneficial to GCM or one or more other Clients. GCM expects to be subject to a potential conflict of interest in making such recommendations, in that GCM has an incentive to maintain goodwill between it and the existing and prospective portfolio companies or service providers for the Fund, while the products or services recommended may not necessarily be the best available to the Fund or its portfolio companies. Personal Trading. GCM, its affiliates, and equity holders, officers, principals and employees of GCM and its affiliates may buy or sell securities or other instruments that GCM has recommended to one or more of its Clients. In addition, officers, principals and employees may buy securities in transactions deemed unsuitable for GCM Clients, but will not in such circumstances be required to share in, reimburse or compensate any Client for due diligence or other expenses (including broken deal expenses) incurred by such Client in connection with such Client’s consideration of the relevant investment opportunity. The investment policies, fee arrangements and other circumstances of these investments generally vary from those of a Client. Employees and related persons of GCM have, and are expected to continue to have, capital investments in or alongside GCM Clients, or in prospective portfolio companies directly or indirectly, as well as in investment vehicles (including private funds) sponsored by potential competitors, and therefore expects to have additional potential conflicting interests in connection with these investments. Any such transactions are subject to any restrictions in the Governing Documents and Account Agreements of any GCM Clients and GCM’s officers, principals and employees engaging in any such transactions are subject to GCM’s code of ethics and other related compliance policies and procedures. Investments Involving Other Glendon Funds. Glendon, in its sole discretion, may decide not to proceed with an investment or not to pursue an investment opportunity for a Client, or may otherwise be restricted in doing so, because of a conflict of interest. Allocation of Investments and Investment-Related Expenses. If GCM determines, in its sole discretion, that a particular investment opportunity would be suitable for investment by more than one of its Clients, then such Clients may co‐invest in such investment alongside each other, provided that each Client’s investment therein is on substantially the same terms and conditions applicable to the investment made by such other Client(s). In the case of any

such co‐investment, such investment opportunity will be allocated between (or among) the Clients based on (a) net asset value of each such Client as of the date of determination (as determined by GCM in its sole discretion), (b) as described in the Governing Documents of each such Client or (c) on such other equitable basis as determined by GCM in its sole discretion, in good faith to be fair and reasonable, taking into consideration such factors as may be deemed relevant including, but not limited to, (i) the sourcing of the investment opportunity, (ii) the investment strategy, guidelines or restrictions, (iii) the risk profile or the need to re‐size risk in the Clients’ portfolios (including the potential for the proposed investment to create an industry, sector, issuer, portfolio company, geographic or currency imbalance in the relevant portfolio), (iv) the operating currency and hedging strategies (if applicable), (v) the target return and investment hold period, (vi) the existing portfolio composition and diversification, (vii) any applicable transfer, assignment or minimum hold restrictions relating to the investment opportunity, (viii) the amount of capital available for investment, (ix) the liquidity then available or anticipated future available liquidity, (x) the proximity of the Clients to the end of their investment period or term, (xi) any tax, regulatory, structural or contractual restrictions or consequences, (xii) the management of any actual or potential conflicts of interest, and (xiii) the magnitude of the investment and any outsized or de minimis allocation. In the case of any such co‐investment, GCM will generally seek to dispose of each Client’s interests in such co‐investment at a similar time and on similar terms, subject to the considerations referenced above. Expenses related to consummated investments, including fees and expenses of outside counsel, accountants and consultants, research firms, financial analysts and travel, will generally be allocated among the Clients participating in such investment based on the Clients’ notional holdings of such investment as of the end of the quarter in which the expense was incurred. Expenses and fees generated in the course of evaluating and making investments that are not consummated, such as out‐of‐pocket fees associated with due diligence, attorneys’ fees and the fees of other professionals, will be allocated among the Clients based generally on the expected participation in such investment (although, as discussed further below, co‐ investors may in certain circumstances not bear any broken deal expenses). If any transaction or other fees are paid by a portfolio company in which the Clients are invested, then only such portion of the fee that is allocable to the Client based on capital committed to such portfolio company will be included in the management fee offset. Insurance premiums are generally allocated among the Clients based on the net asset value of the respective accounts. Management Fee Calculations. GCM has the ability to, pursuant to its valuation policy, determine whether a portfolio investment has suffered a permanent impairment in value sufficient to warrant a complete write off and thereby whether to exclude such investment, diligence or structuring costs from the amount of a Client’s invested capital. Such determinations have a direct impact on the amount of management fees payable by a Client to GCM. As such, GCM has certain conflicts of interest when making such determinations and may specifically be incentivized to delay or avoid writing off assets as having a fair market value is equal to zero in order to receive higher management fees. In deciding whether a portfolio investment has suffered a permanent impairment, GCM is entitled to make its own determination taking into account all facts and circumstances it deems relevant. As a general

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GCM is responsible for the placement of its accounts’ transactions and the negotiation of prices and commissions, if any, with respect to such transactions. Fixed income and unlisted equity securities are generally purchased from a primary market maker acting as principal on a net basis without a stated commission but at prices generally reflecting a dealer spread. Listed equity securities are normally purchased through brokers in transactions executed on securities exchanges involving negotiated commissions. Both fixed income and equity securities are also purchased in underwritten offerings at fixed prices that include discounts to underwriters and/or concessions to dealers. In selecting brokers‐dealers and executing transactions for its accounts, GCM seeks to obtain the best combination of price and execution on transactions effected for its accounts. For GCM, getting the best net price is an important but not the deciding factor in selecting a broker or dealer to execute an account’s transaction. Other considerations include the nature of the security being traded, the size and type of the transaction, the desired timing of the trade, and the reputation of the broker‐dealer for confidentiality, the perceived financial and operational soundness of the broker‐dealer and the research services and products furnished by the broker‐dealer. GCM does not consider whether it may receive client referrals in selecting or recommending broker-dealers. GCM does not attempt to put a specific dollar value on the services rendered or to allocate the relative costs or benefits of those services among accounts, believing that the research received is, in the aggregate, of assistance to GCM in fulfilling its overall duty to its Clients. However, each and every research service may not be used to service each and every account managed by GCM and GCM may use research services to service accounts that did not pay commissions to the broker‐dealers providing such research services. Moreover, GCM may benefit from those services as it may not have to pay for such research services out of its own resources. Certain Client accounts generally trade in the same securities as other Client accounts on an aggregated basis when consistent with GCM's obligation of best execution. In such

circumstances, all participating Client accounts will share commission costs equally and receive securities at a total average price. GCM will retain records of the trade order (specifying each participating account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro rata basis. Any exceptions will be explained on the order. We generally aggregate the purchase and sale of securities for various accounts that have a similar investment strategy. In doing so, we seek to allocate on a fair and equitable basis investment opportunities in situations when the opportunity to buy or sell a security or financial instrument or pursue a trading strategy is limited. GCM has adopted procedures that are designed to provide a fair allocation of aggregated purchases or sales of such investments among our Clients. The procedures are designed to produce fairness over time but may not produce mathematical precision in the allocation of individual transactions. The factors GCM considers in allocating an investment include, but are not limited to, (i) whether the investment will fit within the investment guidelines of the account; (ii) the size of the account; (iii) the liquidity of the investment and other liquidity considerations, including redemption/withdrawal requests received by such accounts; (iii) the diversification of the account; (iv) geographical, sector, industry and asset class concentrations in the account; (v) risk characteristics of the relevant investment and the Client’s risk appetite; (vi) whether the investment can be hedged (in connection with Client accounts with guidelines that call for hedging); and (vii) the maturity of the investment and the proximity of an account to the end of its specified term, if any (i.e., whether the account is in “wind down” or “ramp up” mode). In allocating the sale of an investment that is held in one or more accounts, GCM has the discretion to sell for only one account or multiple accounts based on the factors discussed above and also where sales are required to realize liquidity (i) for a redemption in an account; (ii) to reallocate funds to a different investment strategy; or (iii) to purchase investments that GCM determines are appropriate for one account but not others. The General Partner, however, ultimately retains sole discretion as to how investment purchases and sales will be allocated among the Clients. Clients should consult their respective Governing Documents for a more complete discussion of GCM’s investment allocation strategy. GCM may receive research or other products or services other than execution from a broker‐ dealer in connection with client securities transactions. This is known as a “soft dollar” relationship. GCM will generally limit the use of “soft dollars” to obtain research, including third party research, within the meaning of Section 28(e) of the Securities Exchange Act of 1934 (“Section 28(e)”). Research services within Section 28(e) may include, but are not limited to, research reports and consultants’ advice on portfolio strategy. When GCM uses Client commissions to obtain Section 28(e) eligible research, GCM’s Chief Compliance Officer and trader will confer periodically to review and evaluate its soft dollar practices and to determine in good faith whether, with respect to any research or other

products or services received from a broker‐dealer, the commissions used to obtain those products and services were reasonable in relation to the value of the brokerage, research or other products or services provided by the broker‐dealer. This determination may be viewed in terms of either a specific transaction or GCM’s overall responsibilities to its Clients. The use of client commissions to obtain research and brokerage products and services raises potential conflicts of interest, since GCM will not have to pay for the products and services itself. Although, in general, research purchased with “soft dollars” would be re‐charged to clients if permitted under the applicable written agreement. This may create an incentive for GCM to select a broker‐dealer based on its interest in receiving those products and services. GCM does not seek to allocate soft dollar benefits to client accounts proportionately to the soft dollar credits the accounts generate. Given the nature of the investment strategies, trade errors are not likely to, but may occasionally, occur with respect to trades executed on behalf of a Client. Trade errors can result from a variety of situations, including, for example, when the wrong security is purchased or sold, the correct security is purchased or sold but for the wrong account, or the wrong quantity is purchased or sold. Trade errors frequently result in losses but may occasionally result in gains. It is GCM’s policy that its clients will not incur any losses resulting from trade errors caused by GCM’s gross negligence, fraud or willful misconduct. If a trade error occurs, we will make a good faith determination regarding the cause of the error. However, in making such a determination, we will have a conflict of interest in light of the foregoing.

GCM has entered into and may in the future enter into compensated arrangements with solicitors and placement agents (“marketers”) for the referral of qualified potential Separate

Account clients and Fund investors. These arrangements will comply with the requirements of Rule 206(4)‐1 under the Advisers Act, including the disclosure of the material compensation terms and material conflicts of interest under these arrangements to any potential Clients and Fund investors that are solicited by a marketer. As of December 31, 2025, GCM retained PJT Partners LP to provide placement agent services in connection with the ongoing marketing and fundraising activities of G4. Referral arrangements are subject to negotiation. Fees payable to marketers generally are based on a percentage of Glendon’s advisory fees or a percentage of the capital raised from any Fund investors or Separate Account clients referred by such marketer. If a Fund’s Governing Documents limit the period for marketing and fundraising activities, any placement agent’s services to the Fund will cease at the end of such period, but GCM’s obligation to pay fees to such placement agent with respect to any referred investors may continue during the term of the Fund under its referral arrangement.

As a registered investment adviser, GCM is required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of us or the integrity of our management. GCM has no information applicable to this report in this regard.

GCM engages in ongoing monitoring of each Client’s account and investment portfolio. Members of GCM’s investment team and other relevant personnel will meet at least quarterly to review each Client account and as needed from time to time. Substantively, account reviews will include performance of the account, adherence of the account to its investment mandates, potential transactions for the account and any other consideration that may be pertinent. There is informal monitoring of accounts with the positions and trades of all accounts reviewed periodically by the Partners, relevant analysts, and the Chief Compliance Officer. Investors in our investment funds will typically receive annual and quarterly reports from the investment fund pursuant to the terms of such fund’s Governing Documents or as otherwise agreed with such investors. Separate Account clients will receive reports as agreed upon in the relevant advisory contract with such client.

GCM has an obligation to safeguard Client assets and protect them from loss or destruction. Rule 206(4)‐2 under the Advisers Act (the “Custody Rule”) imposes specific conditions upon registered investment advisers who have actual or deemed custody of Client assets. The Custody Rule contains a definition of the term “custody” which includes “holding, directly or indirectly, Client funds or securities or having any authority to obtain possession of them.” The definition also includes three non‐exclusive examples of custody, including when an investment adviser acts as general partner of a limited partnership. Accordingly, GCM is deemed to have custody of the assets of any Fund for which GCM or an affiliate serves as general partner. GCM adheres to the applicable requirements of the Custody Rule with respect to each Fund for which it or an affiliate serves as general partner. All Fund securities are held with at least one qualified custodian. In addition, GCM arranges for the delivery to investors in each of the Funds of a copy of the audited financial statements for their Fund, prepared in accordance with U.S. generally accepted accounting principles, on an annual basis, and within the required time frames set forth in the Custody Rule. These audits are conducted by an accounting firm of national recognition that is a member of the Public Company Accounting Oversight Board. In addition, Fund investors receive unaudited quarterly account statements from their Fund’s administrator and a statement of their capital account / share holdings as of the fiscal year‐end. Fund investors should carefully review their quarterly account statements, their annual statements and their Fund’s audited financial statements. Separate Account clients select their own custodian to maintain custody of their funds and securities. As discretionary investment adviser, GCM has trading discretion over the funds and securities maintained in a Separate Account client’s custodial account, but GCM does not hold such funds or securities or have authority to obtain possession of them. However, to the extent GCM is deemed to have custody of a Separate Account client’s funds or securities, GCM will take steps to meet its obligations under the Custody Rule. Separate Account clients should carefully review their quarterly account statements from the custodian and compare any statements received from GCM with the account statements from the custodian.

GCM expects that it will usually receive discretionary authority from its Client at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular Client account. When selecting securities and determining amounts, GCM observes the investment policies, limitations and restrictions of the Clients for which it advises. Investment guidelines and restrictions must be provided to GCM in writing.

Rule 206(4)‐6 under the Advisers Act requires all investment advisers who exercise voting authority over Client proxies to: (1) adopt policies and procedures for voting proxies in the best interest of the Client; (2) describe the procedures to Clients; and (3) inform Clients how they may obtain information about how the adviser has actually voted their proxies. The procedures by which GCM will vote securities held by Separate Accounts will be addressed in the Account Agreements between the Clients and GCM. If a Client in a Separate Account retains authority to vote securities, the Client should arrange with their custodian to receive proxy statements and similar materials directly. GCM or the general partner of each Fund will generally vote proxies for the Fund’s investments in accordance with GCM’s policies and procedures for voting proxies described below. GCM recognizes that how it votes proxies for its Clients’ investments forms a part of its overall fiduciary duty to its Clients and for this reason GCM has policies and procedures that it believes are reasonably designed to ensure that proxies are voted in the best interests of the Clients and to recognize and resolve any material conflicts of interest that may arise in the course of such voting. GCM engages an independent third party service provider to make recommendations regarding the voting of proxies, including, to ensure that proxies are voted in the best interests of GCM’s Clients and to recognize and resolve any material conflicts of interest that may arise in the course of such voting; however, GCM retains discretion with respect to proxy voting and in circumstances may vote proxies differently than the recommendations of the independent third party service provider if GCM believes doing so is in the best interests of the Client. If you would like additional information regarding how GCM has voted on specific proxies, or a copy of its proxy voting policies and procedures, please contact Haig Maghakian, Chief Compliance Officer, at (310) 907‐0459 or by e‐mail at hmaghakian@glendoncap.com.

GCM has no financial commitment that is reasonably likely to impair its ability to meet contractual and fiduciary commitments to Clients and has never been the subject of a bankruptcy proceeding.