Harraden Circle Investments, LLC

Harraden Circle Investments, LLC (hereinafter “Harraden Circle”, “we”, “us”, “our”, “Investment Manager” or the “Firm”) is organized as a Delaware limited liability company with a principal place of business in New York, New York. Harraden Circle provides discretionary investment management services to qualified investors through its private funds listed below. We serve as the investment adviser, with discretionary trading authority, to private, pooled investment vehicles, the securities of which are offered through a private placement memorandum to accredited investors, as defined under the Securities Act of 1933, as amended, and/or qualified purchasers, as defined under the Investment Company Act of 1940, as amended. We do not tailor our advisory services to the individual needs of any particular investor. Harraden Circle manages the following private, pooled investment vehicles:

Harraden Circle Investors, LP, a Delaware limited partnership; Harraden Circle Investors Offshore Fund, LP, a Cayman Islands exempted limited partnership; Harraden Circle Special Opportunities, LP, a Delaware limited partnership; Harraden Circle Special Opportunities Offshore, LP, a Cayman Islands exempted limited partnership; Harraden Circle Strategic Investments, LP, a Delaware limited partnership; Harraden Circle Strategic Investments Offshore, LP, a Cayman Islands exempted limited partnership; Harraden Circle Concentrated, LP, a Delaware limited partnership; and Harraden Circle Concentrated Offshore, LP, a Cayman Islands exempted limited partnership

Each fund listed above is herein each referred to as a “Fund,” or “Partnership,” and collectively referred to as the “Funds” or “Partnerships”. Each Fund has its own general partner. As used herein, “General Partner” means, with respect to any Fund, the general partner of such Fund. The Funds’ “Limited Partners” are hereafter collectively referred to as the “Investors” where appropriate. Harraden Circle currently does, and may in the future, serve as investment manager to other client accounts, including separately managed accounts. The Firm also serves as investment manager to three separately managed accounts (“SMAs”). The Funds, SMAs and any other clients of the Investment Manager are collectively referred to herein as “Clients”. Frederick V. Fortmiller, Jr. (the “Principal”) is the managing member of Harraden Circle Investments, LLC, and, as such, has ultimate control over the operations of the Firm. Our investment decisions and advice with respect to the Funds are subject to each Fund’s investment objectives and guidelines, as set forth in its respective “Offering Documents”. We do not currently participate in any Wrap Fee Programs. As of December 31, 2025, Harraden Circle had approximately $ 562,901,594 in Regulatory Assets Under Management “RAUM”. All assets managed by Harraden Circle are on a discretionary basis. -4-

The fees applicable to each of the Funds are set forth in detail in the corresponding Offering Documents. A brief summary of such fees is provided below. Management Fee Harraden Circle is paid an investment management fee (“Management Fee”) per annum of the net asset value of the Funds. The standard Management Fee ranges from 1.00%-1.50% per annum. The Investment Manager, in its sole discretion, may waive or modify the Management Fee for any Investor. Other Types of Fees or Expenses Harraden Circle is authorized to incur and pay in the name and on behalf of the Funds all expenses which they deem necessary or advisable. The Firm is responsible for and shall pay, or cause to be paid, all of their own ordinary administrative and overhead expenses, including, without limitation, all costs and expenses related to rent, furniture, fixtures, equipment, office supplies, clerical expenses and all salaries, bonuses and benefits paid to, or on behalf of, personnel of the Firm. The Funds bear all other expenses, which include, without limitation, the following expenses incurred by or allocable to the Funds: (a) organizational and offering expenses; (b) expenses associated with all investments and transactions considered, evaluated and/or consummated by the Funds, including, without limitation, those expenses incurred before the initial closing of the Funds, including, without limitation, expenses associated with sourcing, negotiating, investigating, researching, financing and structuring of investments and potential investments, whether or not consummated, including, without limitation, third-party research, data, analytics, modeling, structuring, pricing, execution and other third-party information systems, software and service fees (including, without limitation, the expenses with respect to data feeds, subscriptions, expert networks, political intelligence providers, and reports); (c) research-related computer hardware and software expenses, including, without limitation, Bloomberg terminals; (d) the Funds’ pro rata share of the Firm’s order management system, portfolio management system and any other software used for accounting and/or monitoring of the portfolio; (e) expenses associated with holding, financing, monitoring, hedging, maintaining and disposing of all investments of the Funds and all transaction and other costs associated therewith; (f) travel and related expenses associated with investments and potential investments; (g) professional fees associated with investments and potential investments, including, without limitation, consulting, due diligence, accounting, valuation, financial, legal, and other advisory fees and expenses; (h) transaction fees, brokerage commissions, custodial fees, clearing and settlement charges and similar fees and expenses associated with the acquisition, disposition and settling of investments and potential investments; (i) expenses associated with legal and regulatory filings of the Funds (including, without limitation, pursuant to Section 13 and 16 of the Securities and Exchange Act of 1934, as amended (the “Exchange Act”)) and the Funds’ pro rata portion of the expenses associated with preparation of the Firm’s Form 13F, Form 13H and Form PF, and any other similar filing in any other U.S. or nonU.S. jurisdiction; (j) administrative, custodial, appraisal, valuation, legal, regulatory, compliance, consulting, advisory and similar fees and expenses associated with the Funds’ operations,

-5-

investments and transactions, including, without limitation, fees and expenses of the Funds’ administrator; (k) expenses incurred in connection with responding to requests or inquiries from any U.S. federal, state, local or non-U.S. governmental entity or authority, regulatory body or self-regulatory organization and all extraordinary expenses; (l) broken-deal, failed transaction, break-up and similar fees, costs and expenses, if any; (m) costs and expenses of leverage or any other borrowings of the Funds, including, without limitation, interest charges and fees; (n) expenses incurred in the collection of monies owed to the Funds, as applicable; (o) auditing and accounting expenses of the Funds, including, without limitation, expenses associated with the preparation of financial statements, tax returns and Schedules K-1 and the fees and expenses of the auditor; (p) any entity level taxes, fees or other governmental charges on the Funds, including, without limitation, any withholding taxes not due to the status or noncompliance of a particular Investor; (q) costs and expenses associated with investor communications and reports and the delivery thereof to investors; (r) the costs of service providers or software to measure or monitor risk metrics, to aggregate positions and/or to provide reporting with respect to risk metrics and/or positions; (s) costs and expenses associated with meetings of the Investors; (t) insurance expenses; including, without limitation, directors’ and officers’ liability insurance, general partner liability insurance, errors and omissions insurance and other policies, if any; (u) costs and expenses (including, without limitation, entity-level taxes, fees or other governmental charges) associated with the formation, organization and operation of any subsidiary, special purpose vehicle, alternative investment vehicle, holding company, or similar entity formed with respect to investments, credit facilities or other transactions entered into for the benefit of the Funds; (v) wind-up, liquidation, termination and dissolution expenses; (w) costs, fees and expenses related to registration, qualification and/or exemption under any applicable U.S. federal, state, local or non-U.S. laws, rules or regulations, including, without limitation, blue sky fees, Form D, Form 8.3, CFTC filings and notices and other securities and/or investment-related filing expenses; (x) costs related to any transfers of interests in the Funds, unless otherwise charged to or borne by the applicable transferor and/or transferee; (y) expenses incurred in connection with the preparation of any amendment to the Funds’ governing documents and/or Offering Documents; (z) expenses incurred in connection with pursuing, defending or participating in any litigation, arbitration, mediation or similar proceeding by the Funds; (aa) any extraordinary expenses (including, without limitation, all litigation-related and indemnification and contribution expenses, including, without limitation, the amount of any judgment or settlement paid in connection therewith); (bb) the Management Fee; and (cc) all other fees, costs, charges and expenses associated with the business, affairs and/or operations of the Funds. The Firm allocates expenses among Clients on a fair and equitable basis in accordance with its policies. In general, each Investor will bear its proportionate share of Fund expenses on a pro rata basis with respect to the size of such Investor’s capital account(s) in such Fund or with respect to the relative net asset value of the shares held by such Investor, as applicable. Notwithstanding the foregoing, the General Partner and/or the Firm, as applicable, may specially allocate the expenses described herein in any other manner, including by allocating certain expenses to certain (but not all) Funds or Investors, if the General Partner and/or the Firm, as applicable, reasonably determines, in its discretion, that it is more equitable to do so. To the extent that expenses to be borne by the Funds are paid by the Firm or its affiliates, the Funds will reimburse the Firm or its affiliates for such expenses. We may waive any such reimbursement with respect to any Fund expenses. Any waiver by us for reimbursement of any Fund expenses shall not serve as a waiver of reimbursement for any future Fund expenses to be paid by us or our affiliates. Neither the Firm nor its employees accept compensation, including sales charges or service fees, from any person for the sale of securities or other investment products.

-6-

The descriptions set forth in this Brochure of specific advisory services that we offer to Clients, and investment strategies pursued and investments made by us on behalf of our Clients, should not be understood to limit in any way our investment activities. We may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that we consider appropriate, subject to each Client’s investment objectives and guidelines as set forth in the Offering Documents or SMA documentation. Investment allocations are determined by each Client’s investment objectives and guidelines. Different Clients have different investment objectives and strategies, which can impact allocations of investments. The investment strategies we pursue are speculative and entail substantial risks. Clients should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any Client will be achieved.

-7-

Partnership Investment Objectives Harraden Circle Investors, LP: The Partnership’s investment objective is to outperform the long-term returns of broad U.S. stock, bond and hedge fund benchmarks while offering protection during market declines. The Investment Manager seeks to achieve this objective by pursuing an event driven approach designed to capitalize on investment opportunities that offer an asymmetric risk/reward profile due to an elevated probability of favorable outcome or a particularly large ratio of upside to downside. Investments will be focused on a wide array of public and private investments associated with Special Purpose Acquisition Company (SPAC) teams and their businesses combinations. Harraden Circle Special Opportunities, LP: The Partnership’s investment objective is to outperform the long-term returns of broad U.S. stock, bond and hedge fund benchmarks. The Investment Manager seeks to achieve this objective by pursuing an event driven approach designed to capitalize on investment opportunities that offer an asymmetric risk/reward profile due to an elevated probability of favorable outcome or a particularly large ratio of upside to downside. Investments will be focused on a wide array of public and private investments associated with SPAC teams and their businesses combinations. The Partnership will often have substantial positions in financings that help support business combinations designed to allow private companies to transition to public market ownership by merging with SPACs. Harraden Circle Strategic Investments, LP: The Partnership’s investment objective is to outperform the long-term returns of cash as well as broad bond and hedge fund benchmarks. The Investment Manager seeks to achieve this objective by pursuing an event driven approach designed to capitalize on investment opportunities that offer an asymmetric risk/reward profile due to an elevated probability of favorable outcome. The Partnership will emphasize cash-backed investments including SPAC stocks and units. Harraden Circle Concentrated, LP: The Partnership’s investment objective is to outperform the long-term returns of broad U.S. stock, bond and hedge fund benchmarks. The Investment Manager seeks to achieve this objective by pursuing an event driven approach designed to capitalize on investment opportunities that offer a particularly large ratio of upside to downside. The Partnership may invest in a highly concentrated manner, holding a large percentage of total portfolio assets in one particular investment type or individual security. An investment in any of the Partnerships involves substantial risks, including, but not limited to, those described below. There can be no assurance that the Partnership’s investment objective will be achieved or that there will be any return of capital, and investment results may vary substantially on a monthly, quarterly or annual basis. The Interests are a potentially suitable investment only for sophisticated investors for whom an investment in the Partnership does not represent a complete investment program and who, in consultation with their own investment and tax advisors, fully understand and are capable of assuming the risks of an investment in the Interests. Risk Factors The following risk factors do not purport to be a complete list or explanation of the risks involved in an investment in the Clients advised by us. These risk factors include only those risks we believe to be material, significant or unusual and relate to particular investment strategies or methods of analysis employed by us.

-8-

An investment involves significant risks and is suitable only for those persons who can bear the economic risk of the loss of their entire investment who have limited need for liquidity in their investment. There can be no assurances that we will achieve our investment objectives. An investment carries with it the inherent risks associated with investments in publicly-traded stocks and bonds, options, and related instruments, including, without limitation, the risks described below. Each prospective investor should carefully review the Offering Documents or SMA documentation and other documents referred to herein before deciding to invest with Harraden Circle. General Investment Risks General Investment and Trading Risks. All securities investments present a risk of loss of capital. Volatile financial markets increase that risk. If the Investment Manager’s evaluation of an investment opportunity should prove incorrect, a Client could experience losses as a result of a decline in the market value of securities in which a Client holds a long position or an increase in the value of securities in which a Client holds a short position. The risk management techniques used by the Investment Manager do not provide any assurance that a Partnership will not be exposed to a risk of significant investment losses. Investment Judgment. The profitability of a significant portion of a Client’s investment program depends to a great extent upon correctly assessing the future course of the price movements of securities and other investments. There can be no assurance that the Investment Manager will be able to predict accurately these price movements. Concentration. A Client’s portfolio may be concentrated, possibly materially, in a particular market, issuer, instrument type, investment type or country without any investment limitations. Investments in a concentrated portfolio tend to be less stable and result in more rapid changes in the value of the portfolio (upward or downward) than would be the case with greater diversification. Downward movements by a Client’s portfolio could occur rapidly and have a material adverse impact on the value of a Partnership’s capital. If a Client’s investment portfolio becomes highly concentrated, its aggregate return may be volatile and may be affected substantially by the performance of only one or a few holdings. The General Partner is not obligated to hedge a Client’s positions. Price and Liquidity Fluctuations of Investments. It is expected that a significant portion of a Client’s investments will generally be in public securities. However, the market value of a Client’s investments may fluctuate with, among other things, changes in prevailing interest rates, general economic conditions, the condition of financial markets, developments or trends in the securities markets and the financial condition of the issuers of the securities in which a Client invests. During periods of limited liquidity and higher price volatility, a Client’s ability to acquire or dispose of its investments at a price and time that a Client deems advantageous may be impaired. As a result, in periods of rising market prices, a Client may be unable to participate in price increases fully to the extent that it is unable to acquire the desired positions quickly; a Client’s inability to dispose fully and promptly of positions in declining markets will conversely cause its net asset value to decline as the value of unsold positions is marked to lower prices. General Economic Conditions. A Client may be materially affected by general economic or market conditions or events throughout the world that are outside of the control of the Investment Manager, including but not limited to economic uncertainty, industry conditions, technological developments, changes in laws and regulations, geopolitical conditions (including potential impacts resulting from the U.S. administration), tariffs and national and international political circumstances. Market risk is a factor in any investment, and a higher level of volatility in the financial markets has increased risk generally. The most difficult type of market

-9-

environment for the Client’s strategy is expected to be a speculative environment, in which hype, promotional management teams and/or investor euphoria drive stock price movements instead of company fundamentals. This type of environment is of particular concern during short-covering driven rallies and/or for low-dollar short positions. The success of any investment activity is affected by general economic conditions, which may affect the level and volatility of interest rates and the extent and timing of investor participation in the markets for both equities and interest-sensitive securities. Unexpected volatility or illiquidity in the markets in which a Client holds positions, directly or indirectly, could impair a Client’s ability to carry on its business or cause it to incur losses. Natural Disasters, Terrorist Attacks and War. Natural or environmental disasters, such as earthquakes, fires, floods, hurricanes, tsunamis and other severe weather-related phenomena, generally can be, highly disruptive to economies and markets, adversely impacting individual issuers, companies, sectors, industries, markets, currencies, interest and inflation rates, credit ratings, investor sentiment, and other factors affecting the value of the Client’s investments. Given the increasing interdependence among global economies and markets, conditions in one country, market or region are increasingly likely to adversely affect markets, issuers, and/or foreign exchange rates in other countries, including the United States. In addition, terrorist attacks, or the fear of or the precautions taken in anticipation of such attacks, and other acts of war (e.g., war, invasion, acts of foreign enemies, hostilities and insurrection, regardless of whether war is declared) could, directly or indirectly, materially and adversely affect certain industries or countries or regions in which a Client invests. These disruptions could adversely affect where the Investment Manager has offices or where a Client or the Investment Manager otherwise does business and could prevent the Investment Manager from executing advantageous investment decisions in a timely manner and negatively impact its ability to achieve a Client’s investment objectives. Any such event(s) could have a significant adverse impact on the value and risk profile of Client investments. Global Pandemic; Public Health Emergency. Global pandemics and other public health emergencies can cause disruption in the global economy, business and travel disruption and extreme fluctuations in global capital and financial markets. This can lead to significant increases in unemployment levels, a decline in business and consumer confidence and spending, global supply chain issues, inflation, an economic recession in many economies throughout the world and significant increases in federal, state and local deficits and debt. The severity and extent of the impact of a pandemic or public health emergency on the U.S. and global capital and financial markets and economies will depend largely on the duration of the pandemic or health emergency and the policies implemented in connection with restoring business and other activity, all of which are highly uncertain and cannot be predicted. A prolonged period of economic contraction or stagnation can adversely affect a Fund’s performance and reduce available investment opportunities. Additional effects may arise that cannot be predicted currently, including the impact of the pandemic on a Fund’s service providers, a Fund, the Firm and its affiliates. Market Disruptions; Governmental Intervention. Disruptions to the global financial have at times led to government interventions. Such interventions are often unclear in scope and application, resulting in confusion and uncertainty which in itself is materially detrimental to the efficient functioning of the markets as well as previously successful investment strategies. A Client may incur major losses in the event of disrupted markets and other extraordinary events in which historical pricing relationships become materially distorted. The risk of loss from pricing distortions is compounded by the fact that in disrupted markets many positions become illiquid, making it difficult or impossible to close out positions against which the markets are moving. Market disruptions may from time to time cause dramatic losses for a Client, and such events can subject otherwise historically low-risk strategies to unprecedented volatility and risk.

-10-

Read the rest in the brochure

Our clients are the Funds and SMAs, as described in Item 4 above. The Funds are generally open to, among others, institutions, pension plans, endowments, high net-worth individuals, financially sophisticated individuals, and other sophisticated investors. The SMAs are for institutional investors with strategies that differ from the Funds’ strategies.

We and our affiliates are entitled to performance-based compensation from all of our Clients. As a result, we and our affiliates do not face certain conflicts of interest that may arise when an investment adviser accepts performance-based fees from some clients, but not from other clients, but performance-based arrangements may create an incentive for us to recommend investments which may be riskier or more speculative than those which we would recommend under a different arrangement. The General Partner shall be entitled to an annual performance allocation from each Partnership, whereby a portion of net profit, if any, otherwise allocable to the Capital Account of each Limited Partner (or Sub-Account of each Feeder Fund Investor) shall be reallocated to the General Partner by the Partnership, in accordance with the Partnership Agreement. The performance allocation shall accrue monthly, shall be finally allocated (or “crystallize”) at the end of each fiscal year or upon a limited partner’s (or feeder fund’s investor’s) withdrawal, and shall be calculated on a limited partner-by-limited partner (or feeder fund investor-byfeeder fund investor) basis, and, with respect to each limited partner (or each feeder fund investor) with more than one capital account (or sub-account), shall be calculated separately with respect to each such capital account (or sub-account).The standard performance allocation percentage is 12.5% to 17.5% based upon Series Interest type. With respect to Harraden Circle Strategic Investments, LP and Harraden Circle Strategic Investments Offshore, LP, there is a 5% soft hurdle. The Investment Manager, in its sole discretion, may waive or modify the Performance Fee for any Investor. Performance-based allocation arrangements may create an incentive for us to recommend investments which may be riskier or more speculative than those which we would recommend under a different arrangement.

Neither we nor our management persons are registered as broker-dealers, and neither of us has any application pending to register with the SEC as a broker-dealer or registered representative of a broker-dealer, respectively.

Personal Trading Code of Ethics Harraden Circle has adopted a “Code of Ethics” that establishes the standard of conduct that we expect of our employees and procedures regarding our employees’ personal trading of securities. Our employees are required to certify their adherence to the terms set forth in the Code of Ethics upon commencement of employment and annually thereafter. Employees also are required to provide quarterly certifications of compliance with certain Code of Ethics provisions. The foundation of our Code of Ethics is based upon the following underlying fiduciary principles:

Employees must at all times place the interests of Clients and Investors first; Employees must ensure that all personal securities transactions are conducted consistent with the Code of Ethics’ Employee Personal Investment Policy (described below); and Employees should not take inappropriate advantage of their position at the Firm.

Employees are permitted to maintain personal brokerage accounts for the purpose of trading “Reportable Securities” (as defined in the Code of Ethics, and which includes a wide variety of investments such as stocks, bonds, fixed income, options, warrants, futures, and derivatives). Employees may trade Reportable Securities, subject to preclearance requirements. Employees are permitted to liquidate positions held at the time of employment in Reportable Securities (a “Liquidating Trade”) subject to pre-clearance by the CCO or his designee. Employees are prohibited from participating in Initial Public Offerings (“IPOs”) or in SPAC securities. Employees are also prohibited from personally, or on behalf of a Client, purchasing or selling securities that appear on the Firm’s Restricted List. Employees must obtain pre-approval from the CCO or his designee before: (i) engaging in any outside business activities; or (ii) making any private investments. We will provide a copy of our Code of Ethics to our Investors, or any prospective investor, upon request, to be viewed on the premises.

Conflicts of Interest

-25-

Management of Clients Managing multiple Clients may create the potential for conflicts of interest between Clients, including with respect to the allocation of investment opportunities and management of time, services and functions. The Principal, the investment team and other employees, officers, directors, principals or members of the General Partner and the Investment Manager are not obligated to devote their full time to a particular Client but will devote such time as the Principal, the General Partner and the Investment Manager, in their respective sole discretion, deem necessary to carry out the operations of each Client effectively. Investments by the Principal and Certain Harraden Personnel The Principal and certain other officers and employees of the Investment Manager (collectively, the “Harraden Personnel”) have made and may in the future make personal investments in one or more of the Funds. In each case, the Harraden Personnel are not subject to a Management Fee or performance allocation but do bear their pro rata share of Fund expenses. These investments may create conflicts of interest, including the incentive for the Principal or other Harraden Personnel to favor Funds in which they hold personal investments because their returns in those vehicles are not reduced by management or performance-based fees. In addition, because Harraden Personnel may hold personal investments in one or more Funds, they could have greater economic exposure to the performance of certain Funds than others, which could create incentives to devote more attention, allocate more favorable investment opportunities or manage risks differently for those Funds where they have personal capital at stake. Conversely, the absence of a personal investment in other Funds may reduce their economic incentive to prioritize such Funds’ performance, which could result in decisions that do not align fully with the interests of investors in such Funds. Allocation of Investment Opportunities The Clients may invest alongside one another in investment opportunities that are held, or are being invested in, by such other Clients, subject to the Investment Manager’s investment allocation policy. The Investment Manager may allocate investment opportunities among one or more Clients in any manner that the Investment Manager in its sole and absolute discretion determines to be necessary, desirable or appropriate, in accordance with its investment allocation policy, as in effect from time to time, which requires that such allocations be made in a manner that is fair and equitable to each account. It is possible that one or more investment opportunities otherwise suitable for a Client, after taking into consideration such Client’s investment strategy, may be allocated in whole or in part to other Clients. If an investment is appropriate for one or more Clients, the investment generally will be allocated among such Clients pro rata based upon the respective net asset values of such Clients, subject to the target percentage holdings of that type of investment for each such Client. However, the Investment Manager, in its reasonable discretion, may make non-pro rata allocations among Clients based upon a variety of factors including, among other things, tax and regulatory considerations, the overall portfolio composition of such Clients, different terms governing Clients, and the risk profile and investment restrictions (including limitations with respect to leverage) for such Clients. To the extent any Client does not have sufficient capital available to fund its pro rata allocation of any particular investment (whether as a result of such Client’s existing investments, reserves for anticipated future cash needs, or otherwise), such Client will participate in such investment only to the extent of its capital available to do so, and any excess amount that otherwise would have been allocated to such Client for such investment will instead be allocated to other Clients, as applicable, as described above. As a result, performance results among Clients may differ. Similarly, although investments held by multiple Clients are expected generally to be disposed of by such Clients on a pari passu basis, the Investment Manager may, in its reasonable discretion, sell investments from various Clients on a non-pro rata basis, based on a variety of -26-

factors, including those described above with respect to allocations of investment opportunities. Accordingly, it is possible that one Client may be selling an investment, while another Client is retaining or investing more capital in the same investment. The Investment Manager may also determine that a portion of an investment opportunity available to a Client should be allocated to one or more other parties, including, without limitation, one or more co-investors. Proprietary Trading The Investment Manager, the General Partner or their affiliates may trade in the securities and derivatives markets for the accounts of their Clients and, in accordance with the Investment Manager’s policies and procedures, for their own accounts. Such trading may result in competition for investment opportunities or create other conflicts of interest on behalf of one or more such persons in respect of their obligations to a given Client. Records of this trading will not be available for inspection by Investors. The proprietary activities or portfolio strategies of the Investment Manager, the General Partner or their affiliates or the activities or strategies used for accounts managed by the Investment Manager, the General Partner or their affiliates for other customer accounts could conflict with the transactions and strategies employed by a Client and affect the prices and availability of the securities and instruments in which such Client invests. Co-Investments The General Partner may, in its sole and absolute discretion, offer co-investment opportunities to Limited Partners of the Partnerships. If the General Partner, in its sole and absolute discretion, chooses to offer co-investment opportunities to the Limited Partners, the General Partner or its affiliates may receive fees and/or allocations from such co-investors, which may differ as among co-investors and also may differ from the fees and/or allocations borne by a Partnership. Certain Side Pocket Investments The General Partner has the right to designate, subject to the investment management agreement of the applicable Fund(s), investments as Side Pocket Investments such as founder shares or other securities of SPACs. In particular, founder share investments (including warrants) are typically illiquid and their future value may remain uncertain until the SPAC completes a business combination or other transaction. While such securities may generate substantial value if the SPAC consummates a favorable transaction, they may also decline significantly in value or expire worthless if no such transaction occurs. The designation of Side Pocket Investments can give rise to inherent conflicts of interest. For example, Investors invested in a Fund at the time a founder share position is designated as a Side Pocket Investment will participate in the economics of that position, whereas Investors admitted at a later date will not. If such Fund subsequently participates in related financings for the same SPAC (such as through a convertible note, PIPE or other backstop arrangement), such financings may support or enhance the underlying business combination and, as a result, increase the potential value of the founder share investment. This may result in a potential misalignment between earlier Investors holding such founder share investments through their Side Pocket Investment exposure (who may realize gains from the low cost founder shares) and later Investors (whose capital may be used to fund subsequent investments that that indirectly benefit the earlier Investors but who do not share in the original Side Pocket Investment exposure). The General Partner will seek to manage conflicts in good faith and in a manner it believes to -27-

be fair and equitable and consistent with its fiduciary duties to the Funds. However, Investors should recognize that conflicts of this nature are inherent in the use of Side Pocket Investments and cannot be entirely eliminated. Side Pocket Investments in General Limited Partners will have differing exposures to Side Pocket Investments based on the timing of their subscriptions and their elections, and therefore may experience materially different performance results, fees, liquidity profiles and risk/return outcomes. Subject to the investment management agreement of the applicable Fund(s), the General Partner has broad discretion to designate, value and realize Side Pocket Investments, and its compensation and reported performance may be affected by these decisions. This creates conflicts of interest because the General Partner and the Investment Manager may benefit from designating investments as Side Pocket Investments, determining the timing of realizations, selecting valuation methodologies, administering the election process and restricting liquidity in ways that could increase fees, retain assets under management or improve reported performance, even if such decisions have differing effects on Limited Partners. Such matters will be determined by the General Partner in its discretion, subject to the investment management agreement of the applicable Fund(s), Offering Documents and applicable law. Material Non-Public Information From time to time, the General Partner or the Investment Manager may come into possession of material non-public information concerning specific companies. Under applicable securities laws, this may limit the General Partner’s or the Investment Manager’s flexibility to buy or sell portfolio securities issued by such companies. A Client’s investment flexibility may be constrained as a consequence of the General Partner’s or the Investment Manager’s inability to use such information for investment purposes. Alternatively, each of the General Partner and the Investment Manager and their affiliates may decline to receive material non-public information which it is entitled to receive on behalf of a Client in order to avoid trading restrictions for such Client as well as other accounts under its management, even though access to such information might have been advantageous to such Client and other market participants are in possession of such information.

Harraden Circle is authorized to determine the broker-dealer to be used for executing securities transaction for the Funds. In selecting broker-dealers to execute transactions, we do not need to solicit competitive bids and do not have an obligation to seek the lowest available commission cost. The Funds may be deemed to be paying for research, brokerage or other services provided by the broker which are included in the commission rate. We shall also have the authority to select and appoint custodians of the assets of the Funds. The Firm’s authority is limited by its own internal policies and procedures and each Fund’s investment guidelines. Best Execution In selecting an appropriate broker-dealer to effect a client trade, we seek to obtain “Best Execution,” meaning generally the execution of a securities transaction for a client in such a

-28-

manner that a client’s total costs or proceeds in the transaction are most favorable under the circumstances. Accordingly, in seeking Best Execution, we will take into consideration the price of a security offered by the broker-dealer, as well as a broker-dealers’ full range and quality of their services including, among other things, their facilities, reliability and financial responsibility, execution capability, commission rates, responsiveness to us, brokerage and research services provided to us (for example, research ideas, analysis, and investment strategies), special execution and block positioning capabilities, clearance, and settlement and custodial services. Soft Dollars The Firm does not use Soft Dollars. If in the future the Firm utilizes Soft Dollars, the Firm will follow the below policies. In such cases, Soft Dollar credits, generated by the Fund’s trading activities, would be used to purchase brokerage and research services or products that would otherwise have been Fund expense. We intend to keep any such arrangements within the parameters of the safe harbor of Section 28(e) of the Exchange Act. To date, the firm has not utilized such arrangements. Neither Harraden Circle nor any related person receives client referrals from any brokerdealer or third party. However, subject to best execution, we may consider, among other things, capital introduction and marketing assistance with respect to Investors in the Funds in selecting or recommending broker-dealers for the Funds. The provision by a broker of research and other services and property to us creates an incentive for us to select such broker since we would not have to pay for such research and other services and property as opposed to solely seeking the most favorable execution for a client. Any research, services or property provided by a broker may benefit any client and such benefits may not be proportionate to commission dollars related to the provision of such research, services or property.

-29-

We do not receive economic benefits from non-clients for providing investment advice and other advisory services. Neither we nor any of our related persons, directly or indirectly, compensate any person who is not a supervised person for client referrals.

-24-

To the best of our knowledge, there are no legal or disciplinary events that are material to an Investor's or prospective investor's evaluation of our advisory business or the integrity of our management.

Our Portfolio Manager and investment professionals continuously monitor and analyze the transactions, positions, and investment levels of the Fund to ensure that they conform with the investment objectives and guidelines that are stated in a Fund’s Offering Documents or SMA documents, as applicable. In these reviews, the Firm pays particular attention to any changes in the investment’s fundamentals, overall risk management and changes in the markets that may affect price levels. Account Reporting We perform various periodic reviews of each Client’s portfolio. Such reviews are conducted by our officers. We distribute audited financial statements with respect to the previous fiscal year to all Fund Investors within 120 days of fiscal year end. We may also distribute monthly unaudited net asset value statements and a quarterly investor letter to all Fund Investors.

Harraden Circle and its affiliates are deemed to have custody of the Funds’ assets (except with respect to the separately managed accounts) because we have the authority to deduct advisory fees from the Funds or otherwise withdraw assets from the Funds. Such Funds’ assets are held by qualified custodians and are subject to an annual audit by an independent accounting firm. Investors in such Funds are provided audited financial statements within 120 days of their respective fiscal year ends. Investors should carefully review such statements. We will comply with Rule 206(4)-2 of the Investment Advisers Act of 1940, as amended (the “Advisers Act”) (i.e., the “custody rule”) by meeting the conditions of the pooled vehicle annual audit approach. Upon completion of the relevant Fund’s annual audit by an independent auditor that is registered with, and subject to inspection by, the Public Company Accounting Oversight Board (PCAOB), we will distribute the Fund’s audited financials to Investors within 120 days of such Fund’s fiscal year end. Harraden Circle does not maintain custody over the SMAs.

We have full discretionary investment authority with respect to the Clients, including authority to make decisions with respect to which securities to be bought and sold, as well as the amount and price of those securities.

In compliance with Rule 206(4)-6 of the Advisers Act (i.e., the “proxy voting rule”), we have adopted proxy voting policies and procedures. The general policy is to vote all proxy proposals, amendments, consents or resolutions (collectively, “Proxies”) in a prudent and diligent manner that will serve the applicable Client’s best interests and is in line with such Client’s investment objectives. We may take into account all relevant factors, as determined by us in our discretion, including, without limitation:

the impact on the value of the securities or instruments owned by the relevant Client and the returns on those securities; the anticipated associated costs and benefits; any contractual restrictions on voting securities of a particular company; the continued or increased availability of portfolio information; and industry and business practices.

Generally, clients may not direct our vote in a particular solicitation. Clients may obtain a copy of our proxy voting policies and our proxy voting record upon request.

-30-

We are not required to include a balance sheet for our most recent fiscal year, are not aware of any financial condition reasonably likely to impair our ability to meet contractual commitments to Clients, and have not been the subject of a bankruptcy petition at any time during the past ten years.

-31-