GordonMD Global Investments LP

GordonMD Global Investments LP “the Firm”, or “Adviser”) was established in June 2021 by Craig Gordon MD who is the managing member of the general partner and majority owner of GordonMD Global Investments LP. GordonMD, a Delaware limited liability company, is headquartered in Beverly Hills, California. GordonMD Global Investments LP (“GordonMD”) is an alternative asset manager focused on both private and public companies in the biopharmaceutical, life sciences, biotechnology, diagnostic and other healthcare-related sectors. GordonMD through the general partners of the Funds, (GordonMD Long Biased Fund GP LLC, GordonMD PE Fund GP LLC, GordonMD PE Fund II GP LLC, and GordonMD SPV Managing Member) collectively referred to as the Funds ("General Partners”) provides advisory services on a discretionary basis to privately offered pooled investment vehicles (GordonMD Long Biased Master Fund, LP, GordonMD Long Biased Fund LP, GordonMD Long Biased Offshore Fund LTD, GordonMD PE Fund LP, GordonMD PE Offshore Feeder Fund LP, GordonMD PE Fund II LP, and GordonMD SPV I LLC) collectively known as the ("Funds") that are exempt from registration under the Investment Company Act of 1940, as amended (“1940 Act”) and whose securities are not registered under the Securities Act of 1933, as amended (“Securities Act”). Each fund is organized as a limited partnership or a limited liability company with an affiliated entity to GordonMD serving as General Partner or Managing Member. Each General Partner is subject to the Advisers Act of 1940, as amended, and the rules and regulations promulgated thereunder, pursuant to the Adviser’s registration in accordance with SEC guidance. This brochure also describes the business practices of the General Partners, which operates as a single advisory business together with the Adviser hereafter collectively referred to as “GordonMD.” GordonMD provides discretionary investment advisory services based on each private Fund’s investment guidelines as outlined in each Fund’s offering documents. GordonMD does not participate in wrap fee programs. As of December 31, 2025, GordonMD managed $322,272,133 in regulatory assets under management on a discretionary basis and did not manage any assets on a non-discretionary basis.

The governing documents of each Fund set forth in detail the fee structure relevant to such Fund. GordonMD typically receives compensation from fees based on a percentage of assets under management, and Performance-Based Compensation. As discussed below, GordonMD will also be reimbursed for certain fees or expenses, in each case, as disclosed in each Fund’s governing documents. See the sections below on Management fees and Performance-Based Compensation for further details. Investors should review Fund documents detailing all fees and expenses incurred by the Funds to fully understand the total amount of fees and expenses to be paid by a Fund. GordonMD may negotiate fees and waive all or a portion of the fees paid by investors in the Funds. GordonMD may, in its discretion, enter into different fee arrangements with different Funds or

investors in the Funds for the same investment management services, including the Firm’s Employees and affiliates. Management fees payable by a Fund are generally deducted from cash held by such Fund in accordance with such Fund’s governing documents. The fee schedules for the Funds are described in detail in each Fund’s offering memorandum. Investment Management Fees With respect to Fund’s that employ a public equity strategy (GordonMD Long Biased Master Fund, GordonMD Long Biased Fund LP, and GordonMD Long Biased Offshore Fund Ltd), GordonMD receives an asset-based quarterly management fee, paid in advance, equal to 1.5% of the value each Limited Partner’s Basic Capital Account of the net assets of such Public Equity Fund, and 2.0% of the value of each Limited Partner’s Designated Capital Accounts of the net assets of such designated investments (the “Management Fee”). GordonMD may, in its sole discretion, waive or modify the Management Fee for any investors, including without limitation, investors that are members, principals, Employees or affiliates of Adviser and its respective affiliates, relatives or entities of such persons and for certain strategic or large investors. With respect to Funds that employ a private equity strategy (GordonMD PE Fund LP, GordonMD PE Offshore Feeder Fund LP, GordonMD PE Fund II LP, and Gordon SPV I LLC), GordonMD receives an asset-based quarterly Management Fee, payable in advance, equal to 2% per annum of invested capital of such Private Equity Fund. GordonMD may, in its sole discretion, waive or modify the Management Fee for any investors, including without limitation, investors that are members, principals, Employees or affiliates of Adviser and its respective affiliates, relatives or entities of such persons and for certain strategic or large investors. Performance-Based Compensation GordonMD is paid performance-based compensation (“Performance-Based Compensation”) by the Fund investors, which is compensation that is based on a share of capital gains on or capital appreciation of the assets of the Fund. The performance-based compensation is generally 20% of the net profits of the assets within the Funds subject to a loss carryforward provision. GordonMD may waive or modify the Performance-Based Compensation for any investors, including without limitation, investors that are members, principals, Employees or affiliates of GordonMD or its respective affiliates, relatives or entities of such persons and for certain strategic or large investors. Expenses In addition to bearing the Management Fee and Performance-Based Compensation, if any, the Funds also are subject to other expenses related to their investments and operations, such as (i) all investment-related costs and expenses (i.e., expenses that, in the General Partner’s sole discretion, are related to the investment of the Funds’ assets, whether or not such investments are consummated), including commissions and charges, clearing and settlement charges, option premiums and custodial and service fees, research-related expenses (including research-related travel expenses with respect to conferences, capital raising, including travel and lodging related thereto or otherwise), fees and expenses relating to consultants, including healthcare-related consultants and physician networks (and their expert fees and/or lobbyist fees), and expenses

relating to attorneys, brokers or other professionals or advisors who provide research, advice or due diligence services with regard to investments; (ii) fees and expenses related to portfolio exposure and performance management systems, risk management services and software related to trade reconciliation, treasury, margin, financial and counterparty management, risk monitoring, performance reporting, valuation quotation services (e.g., Bloomberg terminals, historical and live financial data and other similar services and data feeds) and trade order management systems (including systems that facilitate trade compliance, commission management, stock locates and transaction cost analysis, and third party service providers used for implementation, custom reporting, updates, consultations, support, maintenance, monitoring and data extracts); (iii) the Funds’ legal, accounting, tax preparation and other tax-related expenses (including preparation and mailing costs of financial statements, tax returns and other reports to Members), auditing, consulting and other professional expenses, including any fees paid to third party valuation agents; (iv) third-party administration costs and costs of outsourced Chief Compliance Officer, Chief Financial Officer and Chief Operating Officer services, fees and expenses (including any costs, fees and expenses related to investor communications, relations, reporting or other investor materials, tax preparation and related reporting, performance information, data extraction and other types of reporting and any audit or accounting services provided by a third-party administrator) and directors’ fees and expenses, including, but not limited to, travel-related costs for board of directors’ meetings; (v) all fees and charges of custodians, clearing agencies and banks; (vi) compliance and reporting expenses and expenses attributable to regulatory filings that are made with respect to the Funds or assets of the Funds’ (including Section 13, Section 16, Form D, Form PF, FATCA, anti-money laundering compliance, state security filings, general regulatory compliance and non-U.S. position reporting filings, if applicable, and non-U.S. filings, if any and the regulatory and compliance expenses directly related to the Partnership and the Offshore Limited Partner, including costs incurred in complying with anti-money laundering laws and regulations (inter alia the fees and expenses of the Partnership’s and Offshore Limited Partner’s AML officers) and costs associated with such funds’ registration under Private Funds Act (if applicable); (vii) the Funds’ pro rata share of Fund-related insurance costs (including the Funds’ pro rata portion of director’s and officer’s insurance, errors and omissions insurance, fidelity insurance and other similar policies covering the General Partner and GordonMD); (viii) any taxes (including but not limited to any withholding taxes, transfer taxes, stamp duties and other governmental or self-regulatory agency-related charges or duties); (ix) all costs and expenses incurred in attempting to protect and enhance the value of a Fund investment (including any fees and expenses associated with any pending or threatened litigation, audit, investigation, administrative or other proceeding, as well as any settlement costs); (x) fees and expenses related to any activist-related activities; (xi) any fees and expenses related to the Funds’ liquidation, if applicable; (xii) fees paid to proxy and securities class action advisory firms; (xiii) expenses relating to the offer and sale of Interests including costs and expenses attributable to meetings with current investors and capital raising (including costs and expenses with respect to conferences or otherwise), and withdrawals and transfers thereof; (xiv) other reasonable expenses related to the purchase, sale, preservation or transmittal of the Funds’ assets; and (xv) any extraordinary expenses (e.g., indemnification expenses). Private Equity Funds are subject to transaction and investment-related costs and fees, including without limitation, commissions, interest on margin accounts and other indebtedness, fees, costs, any expenses, and other obligations, including principal, interest, fees (including commitment fees), expenses and other amounts directly attributed to a particular Designed Investment as determined by the General Partner in its sole

discretion, and is charged only to those Partners participating in such Designated Investment, pro rata based on such Partner’s participation in the respective Designated Investment. The allocation of expenses by GordonMD between it and a Fund and among Funds represents a conflict of interest for GordonMD. GordonMD adopted an expense allocation policy that is designed to address this conflict. GordonMD allocates expenses to each Fund in accordance with the Fund’s governing documents. GordonMD seeks to allocate any shared expenses for products and services benefiting multiple Funds or both GordonMD and a Fund, and not covered in the Fund’s governing documents, in a fair and reasonable manner. GordonMD’s management fee is generally payable quarterly in advance. Subject to the terms of the applicable governing documents, if GordonMD does not provide services for the full period in respect of which such management fees are paid, GordonMD will generally return a pro rata portion of such management fees calculated based on the number of days remaining in the applicable period.

Investment Objective and Strategy With respect to GordonMD’s private equity strategy, the investment objective is to deliver consistent positive returns through investments in private global growth and innovative biopharmaceutical companies. This portfolio focuses on private companies that are mid/late stage. The companies may be preclinical or clinical development in nature. Board of director observation or board of director representation may occur either via an Employee of GordonMD or an appointed representative. Once a company becomes a publicly traded entity board participation generally would end, although GordonMD expects that the Fund will continue to hold investments following an initial public offering. Investment periods for investments may vary, with the majority held over a multi-year period. GordonMD seeks to achieve this private equity investment objective by employing investing in the private equity securities of biopharmaceutical companies in search of superior risk-reward opportunities. GordonMD's mandate is to identify businesses with favorable long-term prospects and invest in such businesses at attractive prices. Most of the exposure will be in the U.S., Europe, and Japan. With respect to GordonMD’s public equity strategy, the investment objective is to deliver consistent positive returns through investments in private and publicly traded global growth and innovative biopharmaceutical companies. Investment periods for the public and private investments may vary, with the majority held over a multi-year period.

The following discussion of investment considerations and risk factors does not purport to be a complete disclosure or explanation of all risks that may be relevant to a decision to make a investment in a Fund. Prospective investors should read the entire Memorandum, the respective Fund limited partnership agreement (“Partnership Agreement”) and the subscription agreement entered into in connection with its admission to the Fund and must rely upon their own examination of, and ability to understand the nature of, the investment, including the risks involved in making a decision to invest in the Fund. There can be no assurance that the Fund will be able to achieve its investment objective or that investors will receive a return of their capital. General An investment in the Fund requires a long-term commitment with no certainty of return. The Interests are not readily marketable and the Fund’s investments may be illiquid. There can be no assurance that the Fund will achieve its investment objectives. The performance of the portfolio companies in which the Fund invests, and therefore the value of the Fund’s investments, will be subject to many factors over which the Fund may have limited or no control. There can be no assurances that any of the portfolio companies in which the Fund invests will succeed. The possibility of a partial or total loss of capital will exist, and prospective investors should not subscribe unless they can readily bear the consequences of such loss. Past performance of investments managed by GordonMD is not necessarily indicative of the future results of the Fund, and there can be no assurance that the projected or targeted returns for the Fund will be achieved. Risk Related to Investment in the Healthcare Sector Healthcare and Related Risks The Funds invests in the securities of biopharmaceutical, life sciences, biotechnology, diagnostic and other healthcare-related companies or in related assets involving a high degree of business, financial, technological and regulatory risk which can result in substantial losses. Some of these risks relate to the underlying biopharmaceutical assets themselves, and others to the companies that manufacture or market these products, their distribution, competitors and in some cases partners in manufacturing or distribution. These risks include but are not limited to: (i)

certain companies that manufacture and/or market the products may have limited operating histories, making it difficult to assess the potential effectiveness of a company’s management, and thus the likelihood of the products’ commercial success.

(ii)

certain companies may not have sufficient management or marketing personnel with appropriate scientific or medical training in order to adequately produce or market these products, which may slow or impede the revenue stream generated by the product;

(iii)

the prices at which these securities in the company or its related assets will be acquired by the Funds will often be based, in part, on sales projections with respect to the underlying biopharmaceutical products, which projections may prove to be inaccurate;

(iv)

to the extent that the Funds makes an investment in a company that is dependent on a product that has not yet received all applicable governmental approvals, there is a risk that the product will not obtain such approvals and that the product will not be able to

be sold to consumers, as obtaining such approvals can often be a lengthy and expensive process the outcome of which can be uncertain; (v)

even if all applicable governmental approvals are obtained with respect to such a product, previously unknown or undisclosed side-effects or complications relating to the product may be disclosed, resulting in a loss of market acceptance or a withdrawal of previously-granted approvals, thereby reducing or eliminating the revenue stream supporting the securities or other assets held by the Funds;

(vi)

certain of these companies may become involved in lawsuits with respect to these products, or with respect to intellectual property rights or other rights relating to them, which lawsuits may result in an inability to market these products or may otherwise impair the related revenue stream, additionally, issuers of foreign securities may not have similar protections with respect to intellectual property rights as are applied in the United States;

(vii)

in the case of any direct investments in biopharmaceutical assets, the Investment Manager may not be successful in structuring these investments in a way that shields the Funds from liability in the event of lawsuits relating to any products or rights in which the Funds has a direct or indirect interest, thereby potentially resulting in the Funds bearing such liabilities and, in such event, the Funds may suffer potentially significant losses beyond its investment;

(viii) the prices at which these investments will be made by the Funds may be based, in part, on assumptions that a limited number of other products will compete with the relevant underlying products in the markets in which they are sold, or that the underlying products will otherwise command a pricing premium in these markets, which assumptions may prove to be inaccurate; (ix)

some of the underlying products that drive value of a company or other asset may become obsolete;

(x)

some of the licensing agreements or other rights relating to the investments held by the Funds may be terminated;

(xi)

certain of the companies in which the Funds expects to invest may also experience adverse impact from: (1) unanticipated delays in research and development efforts; (2) previous preclinical testing or clinical trial results that ultimately are not indicative of future clinical trial results; (3) errors in the conduct of clinical trials; (4) adverse safety findings regarding drugs; (5) clinical trial results that do not support submission of a marketing approval application for drug product candidates; (6) reliance on third party manufacturers, collaborators, and clinical research organizations who may fail to perform according to agreed specifications; (7) inability to control the development of out-licensed drug compounds or drug candidates; (8) inability of collaborators to develop and commercialize product candidates; (9) costs associated with prosecuting, maintaining, defending and enforcing patent claims and other intellectual property rights; (10) inability to maintain or obtain adequate product liability and other insurance

coverage; (11) adverse impact of technological advances and competition; (12) inability to compete against third parties with greater resources; (13) changes in pricing and reimbursements in the markets in which they compete; (14) stronger than expected competition to develop and commercialize similar drug products; (15) inability to obtain patent protection for discoveries; (16) inability to in-license potential drug compounds or drug candidates or other technology; (17) excessive leverage; limitations on their ability to incur additional indebtedness and incur liens on their assets restricting their ability to obtain additional capital when needed; (18) cost of goods sold remaining high enough that it is difficult to achieve profitability; (19) third-party payors for drugs or diagnostics rescinding or modifying their contracts or reimbursement policies or delaying payments; (20) inability to expand as expected outside the United States; (21) failure to receive reimbursement for a drug or diagnostic under changing Medicare rules; (22) failure of physicians to prescribe a drug or diagnostic to the extent anticipated; (23) inability to obtain inputs necessary to the manufacture of a drug or diagnostic at the anticipated cost; (24) failure of information technology and telecommunications systems that are critical to their business; (25) failure to appropriately handle or dispose of biological and hazardous materials; misplaced reliance on third-party distributors; (26) difficulties in integrating legacy companies from a merger or acquisition; and (27) inability to recruit talented personnel, including scientists; (xii)

government policies and regulations applicable to certain of these companies or their products may change in ways that adversely affect the companies or their products’ marketability and, thus, the revenue streams generated by the related assets held by the Funds; and

(xiii) investor sentiments and preferences with regard to life sciences sector investments (some of which are generally perceived as risky) may change, which may have an adverse effect on the values of the securities held by the Funds in such companies. Research and Development Risks Certain of the companies in which a Fund invests may allocate greater than usual amounts to research and product development. The securities of such companies may experience above-average price or valuation movements associated with the perceived prospects of success of the research and development programs. In addition, companies in which a Fund invests could be adversely affected by lack of commercial acceptance of a new product or products or by technological change and obsolescence. Some of these companies may have limited operating histories. As a result, these companies may have inexperienced management, face undeveloped or limited markets, have limited products, have no proven profit-making history, may operate at a loss or with substantial variations in operating results from period to period, have limited access to capital and/or be in the developmental stages of their businesses. Risks Related to an Investment in the Fund Nature of Investments The Investment Manager has broad discretion in making investments for the Funds. Investments will generally consist of global equity securities and other assets that may be affected by business, financial market or legal uncertainties. As further described herein, up to 25% of the aggregate assets of the Master Fund, measured at the time of designation, may be

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GordonMD provides investment advisory services to the Funds. Investors in the Funds are required to meet certain eligibility and suitability qualifications and make certain representations prior to investing in a Fund. Subscription minimums are disclosed in the relevant Fund’s offering documents (although GordonMD maintains the discretion to accept less than any minimum investment commitment). Each of the Funds may enter into agreements, or “side letters,” with certain prospective or existing Fund investors whereby such investors, including such persons that may be affiliated with GordonMD or its related persons, may be subject to terms and conditions that are more advantageous than those set forth in the offering memorandum for the Fund. For example, such terms and conditions may provide for special rights to make future investments in the Funds, other investment vehicles or managed accounts, special redemption rights (including those relating to frequency or notice),; a waiver or rebate in fees or redemption penalties to be paid by the and/or other terms, rights to receive reports from the Fund on a more frequent basis or that include information not provided to other investors (including, without limitation, more detailed information regarding portfolio positions) and such other rights as may be negotiated by the GordonMD and such investors. The modifications are solely at the discretion of the GordonMD and may, among other things, be based on the size of the investor’s investment in the Fund, an agreement by an investor to maintain such investment in the Fund for a significant period, or other similar commitment by an investor to the Fund.

As described in Item 5, GordonMD or the General Partners are entitled to receive performancebased compensation in the form of performance-based fees from certain Funds. A detailed description of the performance-based calculation methodology applicable to a Fund can be found in the relevant Fund’s governing documents. Such performance-based compensation arrangements may create an incentive to invest a Fund’s capital more speculatively than would otherwise be prudent in an effort to generate higher performance-based compensation. However, this incentive is mitigated in part by the financial commitment that GordonMD or the General Partners and its personnel generally make to the Funds. GordonMD has implemented policies and procedures intended to address conflicts of interest relating to the management of multiple accounts, including accounts with different fee arrangements, and the allocation of investment opportunities. Pursuant to these policies and procedures, GordonMD reviews investment decisions for the purpose of ensuring that all accounts with the same or substantially similar investment objectives, strategies and restrictions are treated equitably. The performance of accounts with the same or substantially similar investment objectives, strategies and restrictions is also reviewed to determine whether there are any unexplained significant discrepancies. In addition, GordonMD’s procedures relating to the allocation of investment opportunities require that eligible Fund portfolios with the same or substantially similar investment objectives, strategies and restrictions participate in investment opportunities pro rata based on the relative value of the assets of each participating account to all participating accounts; provided, however that GordonMD may allocate investment opportunities to such accounts on a non-pro rata basis due to a consideration of factors including but not limited to timing of cash inflows/outflows, ability to participate in new issues, etc. To the extent orders are aggregated, the Fund orders are price-averaged and allocated in accordance with the aggregated order; provided, that the aggregated order may be allocated on a different basis for reasons including but not limited to partially filled orders and to avoid odd lots or excessively small allocations. Finally, GordonMD’s procedures also require the objective allocation for limited opportunities (such as initial public offerings and private placements) to ensure fair allocation among accounts. These areas will be monitored by GordonMD’s Chief Compliance Officer.

GordonMD has claimed an exemption from registration with the Commodity Futures Trading Commission (the “CFTC”)` as a commodity pool operator pursuant to CFTC Rule 4.13(a)(3). There is a possibility that the firm’s principal may end up serving on the board of a portfolio company in connection with our engagement strategy with the company. The GordonMD principal(s) may receive compensation for serving on the boards of portfolio companies either in the form of cash, stock, or options on stock.

Trading GordonMD has adopted a written Code of Ethics that is applicable to all of its members, officers, principals, employees and other personnel, as well as certain officers, principals, employees and other personnel of its affiliates and certain independent contractors (collectively, “Employee”). The Code of Ethics, which is designed to comply with Rule 204A-1 under the Advisers Act, establishes guidelines for professional conduct and personal trading procedures, including certain pre-clearance and reporting obligations. GordonMD Personnel and their families and households may purchase investments for their own accounts, including the same investments as may be purchased or sold for a Fund subject to the terms of the Code of Ethics. Under the Code of Ethics, GordonMD Personnel are also required to file certain periodic reports with GordonMD’s Chief Compliance Officer as required by Rule 204A-1 under the Advisers Act. The Code of Ethics helps Accord detect and prevent potential conflicts of interest. GordonMD Personnel who violate the Code of Ethics may be subject to remedial actions, including, but not limited to, profit disgorgement, fines, censure, demotion, suspension or dismissal. GordonMD Personnel are also required to promptly report any violation of the Code of Ethics of which they become aware. GordonMD Personnel are required to annually certify compliance with the Code of Ethics. A copy of the Firm’s Code of Ethics is available to Clients or investors and prospective Clients or prospective investors upon their individual request. GordonMD has adopted an insider trading policy. During its investment management and other activities, GordonMD or its Employees may come into possession of confidential or material nonpublic information about issuers, including issuers in which GordonMD has invested or seek to invest on behalf of Funds. GordonMD is prohibited from improperly disclosing or using such information for its own benefit or for the benefit of any other person, regardless of whether such other person is a Fund. GordonMD will maintain and enforce written policies and procedures that prohibit the communication of such information to persons who do not have a legitimate need to know such information and to assure that GordonMD is meeting its obligations to its Funds and remains in compliance with applicable law. In certain circumstances, GordonMD may possess certain confidential or material, nonpublic information that, if disclosed, might be material to a decision to buy, sell or hold a security, but GordonMD will be prohibited from communicating such information to the Fund or using such information for the Fund’s benefit. In such circumstances, GordonMD will have no responsibility or liability to the Fund for not disclosing

such information to the Fund (or the fact that GordonMD possesses such information), or not using such information for the Fund’s benefit, as a result of following GordonMD’s policies and procedures designed to provide reasonable assurances that it is complying with applicable law. As part of its personal trading policy, GordonMD Personnel are not permitted to transact in any security of an issuer that is (i) on GordonMD’s Restricted List (see Section IV.3. of the Code); (ii) in the biotech or pharma space; or (iii) held in a Fund account.

Factors Considered in Selecting or Recommending Broker-Dealers for Fund Transactions GordonMD considers a number of factors in selecting a broker-dealer to execute transactions (or series of transactions) and determining the reasonableness of the broker-dealer’s compensation. Such factors include, but are not limited to reputation, financial strength and stability, creditworthiness, efficiency of execution and error resolution, the actual executed price and the commission, research (including economic forecasts, fundamental and technical advice on securities, valuation advice on market analysis); custodial and other services provided for the enhancement of GordonMD’s portfolio management capabilities; the size and type of the transaction; the difficulty of execution and the ability to handle difficult trades; and the operational facilities of the brokers and/or dealers involved (including back office efficiency). In selecting a broker-dealer to execute transactions (or a series of transactions) and determining the reasonableness of the broker-dealer’s compensation, GordonMD need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost. It is not GordonMD's practice to negotiate “execution only” commission rates, thus a Fund may be deemed to be paying for research, brokerage or other services provided by a broker-dealer which are included in the commission rate. GordonMD’s Chief Compliance Officer and traders will meet periodically to evaluate the broker-dealers used by GordonMD to execute Fund trades using the foregoing factors. Research and Other Soft Dollar Benefits While generally not expected due to GordonMD’s investment strategy, GordonMD may from time to time receive research or other products or services other than execution from a broker-dealer and/or a third party in connection with Fund securities transactions. This is known as a “soft dollar” relationship. If using “soft dollars,” GordonMD will limit the use to obtaining research and brokerage services to services that constitute research and brokerage within the meaning of Section 28(e) of the Securities Exchange Act of 1934, as amended (“Section 28(e)”). Research services within Section 28(e) may include, but are not limited to, research reports (including market research); certain financial newsletters and trade journals; software providing analysis of securities portfolios; corporate governance research and rating services; attendance at certain seminars and conferences; discussions with research analysts; meetings with corporate executives; consultants’ advice on portfolio strategy; data services (including services providing market data, company financial data and economic data); advice from broker-dealers on order execution; and certain proxy services. Brokerage services within Section 28(e) may include, but are not limited to, services related to the execution, clearing and settlement of securities transactions and functions incidental thereto (i.e., connectivity services between an adviser and a broker-dealer and other relevant parties such as custodians); trading software operated by a broker-

dealer to route orders; software that provides trade analytics and trading strategies; software used to transmit orders; clearance and settlement in connection with a trade; electronic communication of allocation instructions; routing settlement instructions; post trade matching of trade information; and services required by the SEC or a self-regulatory organization such as comparison services, electronic confirms or trade affirmations. When GordonMD uses Fund commissions to obtain Section 28(e) eligible research and brokerage products and services, GordonMD will periodically 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 will be viewed in terms of either the specific transaction or GordonMD’s overall responsibilities to the accounts or portfolios over which GordonMD exercises investment discretion. The use of Fund commissions (or markups or markdowns) to obtain research and brokerage products and services raises conflicts of interest. For example, GordonMD will not have to pay for the products and services itself. This creates an incentive for GordonMD to select or recommend a broker-dealer based on its interest in receiving those products and services. To address these conflicts of interest, GordonMD will execute Fund trades through broker-dealers that provide research and brokerage products to GordonMD only if it is determined by the Chief Compliance Officer of GordonMD that Fund trades with such broker-dealers are otherwise consistent with seeking best execution. Research and brokerage services obtained using commissions arising from a Fund’s portfolio transactions may be used by GordonMD in its other investment activities, including, for the benefit of other Fund accounts. GordonMD does not seek to allocate soft dollar benefits to Fund accounts proportionately to the soft dollar credits the accounts generate. In some instances, GordonMD may obtain a product or service that is used, in part, by GordonMD for Section 28(e) eligible purposes and, in part, for other purposes. In such instances, GordonMD will make a good faith effort to determine the relative proportion of the product or service used to assist GordonMD in carrying out its investment decision-making responsibilities and the relative proportion used for administrative or other purposes outside Section 28(e). Such determination will be made based on the actual use of the product or service by GordonMD’s personnel. The proportion of the product or service attributable to assisting GordonMD in carrying out its investment decision-making responsibilities will be paid through brokerage commissions generated by Fund transactions and the proportion attributable to administrative or other purposes outside Section 28(e) will be paid for by GordonMD from its own resources. The determination by GordonMD of the appropriate allocation of “mixed use” products and services creates a potential conflict of interest between GordonMD and Funds. In determining whether to direct Fund brokerage transactions to particular broker-dealers, GordonMD’s Chief Compliance Officer and portfolio managers periodically review and evaluate the soft dollar practices of GordonMD and 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. Brokerage for Investor Referrals From time to time, GordonMD will participate in capital introduction programs arranged by broker-dealers, including firms that serve as prime brokers to a private fund managed by GordonMD or recommend investments in these private funds as investments to the Investors of the broker-dealer. GordonMD may place Fund portfolio transactions with firms who have made such recommendations or provided capital introduction opportunities, if GordonMD determines that it is otherwise consistent with seeking best execution. In no event will GordonMD select a broker-dealer as a means of remuneration for recommending GordonMD or any other product managed by GordonMD (or an affiliate) or affording GordonMD with the opportunity to participate in capital introduction programs. GordonMD anticipates purchasing or selling the same security for more than one Fund at or near the same time and using the same executing broker. It is GordonMD's practice, where appropriate, to aggregate Fund orders for the purchase or sale of the same security submitted at or near the same time for execution using the same executing broker. Such aggregation may enable GordonMD to obtain for Funds a more favorable price or a better commission rate based upon the volume of a particular transaction. When an aggregated order is completely filled, GordonMD will allocate the securities purchased or proceeds of sale pro rata among the participating accounts, based on the purchase or sale order. Adjustments or changes may be made under certain circumstances, such as to avoid odd lots or excessively small allocations. If the order at a particular broker is filled at several different prices, through multiple trades, generally all such participating accounts will receive the average price and pay the average commission, subject to odd lots, rounding, and market practice. To the extent an order is price-averaged, a Fund account participating in the trade may pay a higher price than if GordonMD did not aggregate the order. If an aggregated order is only partially filled, GordonMD's procedures provide that the securities or proceeds are to be allocated in a manner deemed fair to Funds. Depending on the investment strategy pursued and the type of security, this may result in a pro rata allocation to all participating Funds.

GordonMD reserves the right, from time to time, to enter into arrangements pursuant to which it compensates third-party placement agents for referrals that result in a potential investor becoming a limited partner in certain funds. GordonMD has retained Swiss Alts Consulting GMBH and Alcant Capital Partners as placement agents, to solicit commitments from investors in certain Funds. As described in the service agreement, The compensation fees for this arrangement includes 20% of the Management Fees and 20% of the Performance Fees received of all capital commitments raised and accepted by the Fund from referred or solicited investors. Due to the service agreement, these firms have an incentive to recommend GordonMD, resulting in a material conflict of interest. These arrangements are in compliance with the new marketing rule, Rule 206(4)-1 of the Investment Advisers Act of 1940 as of the effective date, November 4, 2022.

GordonMD and its supervised persons have not experienced any legal or disciplinary events that are material to a client or prospective client’s evaluation of GordonMD or its management practices.

Each Fund will be reviewed by GordonMD’s investment professionals on an ongoing basis to determine whether securities positions should be maintained in light of current market conditions. Matters to be reviewed will include specific securities held, adherence to investment guidelines and the performance of each Fund. Significant market events affecting the prices of one or more securities in Fund accounts, changes in the investment objectives or guidelines of a particular Fund or specific arrangements with particular Funds may trigger reviews of Fund accounts on a more frequent basis. Pooled investment vehicle investors will receive reports from the Funds pursuant to the terms of each Fund’s offering memoranda or as otherwise described in the offering document of the Fund.

GordonMD maintains custody of assets held in the name of one or more Funds at one or more qualified custodians. In accordance with Rule 206(4)-2 under the Advisers Act (“Custody Rule”), each Fund will be subject to an annual audit by an independent public accountant registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board and audited financial statements of each Fund will be prepared in accordance with generally accepted accounting principles (US GAAP) and distributed to investors within 120 days of the end of each Fund’s fiscal year. Investors should carefully review the audited financial statements of the Funds upon receipt.

GordonMD will provide investment advisory services on a discretionary basis to Funds. GordonMD has discretionary authority to manage securities on behalf of the Funds and is authorized to make transaction recommendations for the Funds. Unless otherwise instructed or directed by a discretionary Fund as noted in Item 4 above, GordonMD will have the authority to determine (i) the securities to be purchased and sold for the Fund account (subject to restrictions on its activities set forth in the applicable investment management agreement and any written investment guidelines), and (ii) the amount of securities to be purchased or sold for the Fund account. Because of the differences in Fund investment objectives and strategies, risk tolerances, tax status and other criteria, there may be differences among Funds in invested positions and securities held.

To the extent GordonMD has been delegated proxy voting authority on behalf of its Funds, GordonMD will comply with its proxy voting policies and procedures that are designed to ensure that in cases where GordonMD votes proxies with respect to Fund securities, such proxies are voted in the best interests of its Funds. GordonMD generally will vote against proposals that make it more difficult to replace members of a board of directors. For all other proposals including

matters such as, without limitation, corporate events (mergers and acquisition transactions, dissolutions, conversions, or consolidations) or contested elections for directors, GordonMD will determine whether a proposal is in the best interests of the Fund and may take into account the following factors, among others: (i) whether the proposal was recommended by management and GordonMD’s opinion of management; (ii) whether the proposal acts to entrench existing management; (iii) whether the proposal fairly compensates management for past and future performance; and (iv) the potential effect of the vote on the value of Funds’ investments. Funds may obtain a copy of GordonMD’s proxy voting policies and procedures and information about how GordonMD voted a Fund’s proxies by contacting the Chief Compliance Officer, mkostolansky@gordonmdglobalinv.com

GordonMD does not require nor solicit pre-payment of more than $1,200 in fees per client, six months or more in advance. GordonMD is not aware of any financial condition that is reasonably likely to impact its ability to meet its contractual commitments to clients and has not been the subject of a bankruptcy petition at any time during the past ten years.