Hellman & Friedman

Hellman & Friedman LLC, a Delaware limited liability company (“H&F LLC”), and Hellman & Friedman LP, a Delaware limited partnership (“H&F LP”), together establish and, with various of their affiliates, provide investment advisory services to pooled investment vehicles that are exempt from registration under the Investment Company Act of 1940, as amended (the “1940 Act”) and whose securities are not registered under the Securities Act of 1933, as amended (the “Securities Act”) (such entities that are advisory clients of H&F LLC or H&F LP under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), being the “Funds” and each, a “Fund”). H&F LP is the manager of such Funds and has engaged H&F LLC, through a subadvisory agreement, to assist H&F LP with certain of such advisory services. The affiliates through which such advisory services are provided include the general partners of the Funds (each, a “General Partner”). Certain of these affiliates are formed for tax, regulatory or other purposes in connection with the organization of the Funds. H&F LP and H&F LLC, together (where the context permits) with the General Partners, their affiliated management companies and other affiliates that provide advisory services to the Funds, are referred to in this brochure collectively as “H&F.” H&F was formed in 1984 and raised its first institutionally sponsored private equity partnership in 1987. H&F has offices in San Francisco, New York and London. H&F LP is owned indirectly through holding companies by its partners and H&F LLC is owned by its members. H&F is focused on making large-scale private equity-related investments in the developed markets. Across sectors, H&F generally seeks high quality businesses with defensible competitive positions, strong economic profiles and an orientation towards higher growth. H&F generally seeks to build a concentrated portfolio of scale investments in its core sectors of expertise, including technology; healthcare; consumer services & retail; financial services; and information, content & business services. H&F continually seeks to identify new industries or sub-sectors that meet its investment criteria. Although the primary focus of each Fund is on private equity-related investments, H&F also may from time to time recommend other types of investments consistent with the respective Fund’s investment strategy and objectives. H&F’s advisory services consist of investigating, identifying and evaluating investment opportunities, structuring, negotiating and making investments on behalf of the Funds, managing, overseeing and monitoring the performance of such investments and disposing of such investments. H&F serves as the investment adviser, sub-adviser, general partner and/or ultimate general partner, or equivalent, to the Funds to provide such services. H&F provides investment advisory services to each Fund in accordance with various investment management or advisory or sub-advisory agreements, as applicable (each, a “Management Agreement”), the limited partnership agreement (or analogous organizational document) of such Fund (each, an “Organizational Document”) and/or side letters with limited partners of the Funds (the “Limited Partners” and, together with the General Partners, the “Partners”) (“Side Letters” and together with the Management Agreements and the Organizational Documents, the “Governing Documents”). Investment advice is provided directly to the Funds and not individually to the Limited Partners. Investment restrictions for the Funds, if any, are generally established in the Governing Documents or offering documents of the applicable Fund.

For purposes of this brochure, a “Fund Family” means a group of Funds that is raised simultaneously and contractually required to invest together, such as Hellman & Friedman Capital Partners VII, L.P., and its affiliated parallel funds, Hellman & Friedman Capital Partners VIII, L.P. and its affiliated parallel funds, Hellman & Friedman Capital Partners IX, L.P. and its affiliated parallel funds, Hellman & Friedman Capital Partners X, L.P. and its affiliated parallel funds or Hellman & Friedman Capital Partners XI, L.P. and its affiliated parallel funds. The Fund entities that comprise a “Fund Family” are referred to herein as “Main Fund” entities. H&F from time to time also establishes other investment vehicles, including dedicated or “standing” vehicles, through which one or more Limited Partners and/or third parties may invest alongside one or more Fund Family(ies) in a single transaction or in multiple transactions (any co-investment vehicles established by H&F, “Co-Investment Vehicles”). The term “Co-Investment Vehicles” includes deal specific entities for one or more investors formed to invest alongside one or more Fund Families in a specifically identified portfolio company or companies; and co-investment Funds formed for one or more investors to invest together with one or more Fund Families. In addition, from time to time, H&F also establishes certain investment vehicles for the purpose of purchasing one or more investments from one or more Fund Families (often where the selling Fund Family(ies) is approaching the end of its term) in connection with or alongside other Fund Family(ies) making an investment (such transactions, “Continuation Transactions” and such other vehicle a “Continuation Vehicle”). As part of a Continuation Transaction, the selling Fund’s Partners from time to time may be, and have in the past been, given an election to rollover their existing Fund investment into a new investment vehicle through which they continue to invest in the underlying portfolio company or companies together with the purchasing Continuation Vehicle and, where applicable, Funds (an “Extended Duration Vehicle”). For purposes of this brochure, Co-Investment Vehicles, Continuation Vehicles, Extended Duration Vehicles as well as other investment vehicles established for the purpose of purchasing one or more interests in one or more of these vehicles on the secondary market or otherwise in connection with providing liquidity to Limited Partners are collectively referred to as “Other Investment Vehicles”. For purposes of this brochure, certain Other Investment Vehicles are deemed to be “Funds” because they are advisory clients of H&F under the Advisers Act and certain Other Investment Vehicles are not “Funds” for these purposes. Certain of the Fund entities are comprised primarily of current and former employees and/or friends or family of H&F and are referred to herein as “Associates Funds”. As of December 31, 2025, H&F managed a total of $110,419,300,000 of client assets (calculated as “Regulatory Assets Under Management” as defined in the Form ADV General Instructions), $103,385,200,000 of such client assets were managed on a discretionary basis and $7,034,100,000 of such client assets were managed on a non-discretionary basis.

H&F charges certain Funds (including, without limitation, certain Other Investment Vehicles) various fees and compensation, including management fees, carried interest (as described in Item 6 below), administrative fees and/or profits interests, in each case as set forth in the applicable Governing Documents. For the Main Funds, management fees are either calculated based on Limited Partner commitments to the applicable Fund, costs of investments or capital contributions in respect of investments then held.

Receipt of profits interests varies from Fund to Fund subject to the applicable Governing Documents. For certain Funds (including, without limitation, certain Other Investment Vehicles) H&F has, or may in the future have, the ability to receive a profits interest as the result of waiving all or a portion of the management fee otherwise payable by a Fund (on a voluntary basis pursuant to H&F’s election). Such profits interest entitles H&F to share in net profits, if any, of the applicable Funds. In addition, for certain Funds (including, without limitation, certain Other Investment Vehicles), H&F has been, or may in the future be, entitled to a profits interest to share in net profits, if any, of the applicable Funds up to a fixed percentage of the capital commitments of the Fund’s Limited Partners. For certain Funds, H&F receives both types of profits interests. Please see Item 6 below regarding “carried interest” that certain Funds pay. Certain Funds and certain other vehicles are not required to pay management fees, administrative fees, profits interests and/or carried interest, or pay reduced management fees, administrative fees, profits interests and/or carried interest, including certain of the Associates Funds and certain Other Investment Vehicles. In addition to the management fee, administrative fee, carried interest (as described in Item 6 below) and profits interests, break-up (or other similar fees), consulting, merger and acquisition, financial advisory, investment banking, commitment, transaction, monitoring, directors’ or other similar fees (including secondment fees), whether paid in cash, in-kind or other equity, are from time to time charged by H&F and/or its senior advisors, which, for the avoidance of doubt, include Senior Operating Advisors and Operating Partners of H&F (collectively, “Senior Advisors”), with respect to an investment or proposed investment by a Fund (such fees net of all related expenses, collectively, “Other Fees”). The amount and timing of Other Fees received by H&F, its personnel and/or its Senior Advisors are generally specified in the agreement or other documentation governing the applicable transaction or other agreement between H&F or its Senior Advisors and the applicable portfolio company. Notwithstanding the foregoing and other than as set forth in the applicable Governing Documents, Other Fees do not include (i) amounts paid to any individual partner or member of H&F LLC and/or H&F LP, or their direct or indirect general partners or managers (collectively, “H&F Executives”) or other H&F personnel, including Senior Advisors (collectively, such H&F Executives, Senior Advisors and other H&F personnel being “H&F Personnel”) in their capacity as director (including advisory boards or similar positions) or trustee of any concern that is not a portfolio company of the applicable Fund, (ii) the value of any stock options or other similar rights received by any H&F Personnel prior to an investment by such Fund or acquired by any such H&F Personnel after the disposition of an investment by such Fund, (iii) any amounts paid by a former portfolio company, such as directors’ fees a former portfolio company pays to H&F Personnel who remain on the company’s board of directors following the Fund’s disposition of its investment in the portfolio company and (iv) any fees and other amounts paid to any consultants, operating advisors, operating executives (which, for the avoidance of doubt, exclude any Senior Advisors) and other individuals or service providers retained by or on behalf of such Fund or and/or its portfolio companies to provide services (which, among other things, may include operational and industry expertise and serving on the board of directors of one or more portfolio companies or relating to deal-sourcing and investment opportunities), in each case, who are not then current H&F Personnel (provided, that they may be former H&F Personnel or current or former employees, directors, executives, chairpersons or similar positions with

current or former portfolio companies of such Fund, prior Funds or successor funds) and are not bound to provide services on an exclusive basis to H&F (collectively, “External Advisors”) (which may include profits interest, equity or equity-related interests in the Funds and/or portfolio company or other incentive-based compensation). These Other Fees may be substantial and may be paid in cash, in securities of portfolio companies or investment vehicles (or rights thereto) or otherwise. In the event of an initial public offering or other partial disposition, monitoring fees may continue to be paid so long as the applicable Fund continues to hold an other than de minimis position in such portfolio company and H&F continues to provide the monitoring services. In the event H&F receives Other Fees, unless otherwise set forth in the applicable Governing Documents, H&F will reduce the amount of management fees paid by, or in some cases the carried interest paid by, the applicable Fund in an amount equal to 100% of Other Fees attributable to each such Fund or in some cases instead of an offset such Fund will distribute such amount to its Limited Partners. The manner of such reduction or distribution, if any, is set forth in the Governing Documents of the applicable Fund (“Other Fee Offset”). To the extent any Other Fee is attributable to a portfolio company held by more than one Fund and/or Other Investment Vehicle, for purposes of calculating the Other Fee Offset, such Other Fee is allocated among the applicable Fund(s) and Other Investment Vehicle(s) in proportion to their interest (or prospective interest) in the portfolio company. As described above, certain Funds (e.g., Associates Funds) or certain Other Investment Vehicles pay reduced or no management fees or carried interest. If a Fund or Other Investment Vehicle does not pay management fees and/or carried interest, subject to the applicable Governing Documents, any reduction in management fees or carried interest, if applicable, in respect of Other Fees does not benefit such Fund or Other Investment Vehicle. The portion of Other Fees allocable to Other Investment Vehicles where there is no Other Fee Offset is typically retained by H&F. For the avoidance of doubt, any fees accrued and paid to H&F or H&F Personnel after a Fund has exited an investment are not considered “Other Fees” and do not reduce management fees. Any fees that accrue to the benefit of former H&F Personnel, including without limitation to the extent former H&F Personnel remain on a portfolio company board of directors after they depart H&F or to the extent they provide services to a portfolio company, are not considered “Other Fees” and are not subject to the Other Fee Offset or otherwise benefit the Funds or Limited Partners. Similarly, any fees that accrue to the benefit of current H&F Personnel prior to their association with H&F (even if any fee received in-kind is realized or otherwise converted to cash during their tenure with H&F) are not considered “Other Fees” and are not subject to the Other Fee Offset or otherwise benefit the Funds or Limited Partners. From time to time, H&F will maintain the amounts associated with Other Fees in accounts that bear interest before such amounts are offset. Any such interest is not considered “Other Fees”, is not subject to the Other Fee Offset and does not otherwise benefit the Funds or Limited Partners. From time to time, H&F will disclose to certain Limited Partners the amount of Other Fees allocated to the Fund in which such Limited Partner has invested in account statements or other similar periodic reports delivered to such Limited Partners.

In many cases with respect to the implementation of the arrangements described above, there is not an independent third party involved on behalf of the relevant portfolio company and therefore such fees are not subject to a market check. In such circumstances, a conflict of interest exists in the determination of any such fees and other related terms in the applicable agreement with the portfolio company by virtue of H&F acting on behalf of both parties. Consistent with the Funds’ Governing Documents, a portfolio company generally will reimburse H&F for out of pocket expenses (including without limitation, expenses for certain entertainment, meals, travel, deals, data, search firms, legal expenses (including without limitation, legal costs associated with reviewing financing documents and agreements, whether on behalf of a portfolio company borrower or a lender), transaction expenses, accounting / tax expenses, registered or local office expenses, government fees, public relations services, expert network fees, sustainability services or advisory fees, other consultancy or advisory expenses and/or other miscellaneous expenses like shipping, postage and reprographics) incurred by H&F in connection with its monitoring of, or performance of services for, such portfolio company, including, without limitation, services as a board member or observer of such portfolio company or services of H&F Personnel. In addition, the terms of the applicable Governing Documents generally provide that the Funds will reimburse H&F for out-of-pocket costs and expenses (excluding unreimbursed travel and entertainment) incurred by H&F in connection with consummated or unconsummated transactions. All such reimbursements are different from Other Fees and thus are not subject to the Other Fee Offset arrangements described above. As used throughout this brochure, “travel” and “travel-related” expenses shall be deemed to include, without limitation, commercial and noncommercial transportation costs (including first class or business class travel, chartered or private planes; provided, that any air travel paid for by the Funds shall not exceed commercial first-class equivalent rates, and private car travel), lodging and accommodations. H&F also, from time to time, engages and retains External Advisors who include, among other persons, former H&F Personnel or current or former employees, directors, chairpersons, executives or similar persons of portfolio companies, and who, from time to time, receive fees, allocations, reimbursements of expenses and other amounts (which may include a profits interest, equity or equity-related interests in the Funds and/or portfolio company or other incentive-based compensation) for providing services to or on behalf of the Funds and/or their portfolio companies (which, among other things, may include operational and industry expertise and/or serving on the board of directors of one or more portfolio companies or relating to deal-sourcing and investment opportunities). Such fees, expense allocations and other amounts are generally paid and/or reimbursed by the applicable portfolio company and/or the applicable Fund (although in certain limited circumstances, H&F may elect to pay the fees and compensation of such External Advisors, provided that H&F paying such fees does not preclude a Fund or portfolio company from paying such fees to such External Advisor going forward). Such amounts, fees, allocations, reimbursement of expenses or other compensation received by External Advisors are generally retained by such External Advisors and are not deemed paid to or received by H&F and such amounts will not be subject to the Other Fee Offset arrangements described above or otherwise reduce management fees. The nature of the relationship with each such External Advisor and the time devotion requirements of each such External Advisor may vary significantly. These arrangements are negotiated individually, depending on the anticipated services to be provided. In

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Methods of Analysis and Investment Strategies H&F has developed a focused strategy that seeks to align both the organization and its investment philosophy and investment process around the objectives described in Item 4 above. The foundation of H&F’s investment philosophy stems from a rigorous focus on the fundamental quality of the underlying business as the primary driver of investment results. Across sectors, H&F generally seeks high quality businesses with defensible competitive positions, strong economic profiles and an orientation towards higher growth. H&F generally seeks to build a concentrated portfolio of scale investments in its core sectors of expertise, including technology; healthcare; consumer services & retail; financial services; and information, content & business services. H&F continually seeks to identify new industries or sub-sectors that meet its investment criteria. Since its inception, H&F has developed and continually refined its internal processes to help apply its investment philosophy. Importantly, these processes are incorporated into the evaluation of new investment opportunities, the value creation at existing investments and the management of the overall portfolio. H&F believes that there are a limited number of businesses and opportunities that fit within its investment parameters and has therefore designed its investment process to concentrate and dedicate resources when it identifies a situation that may be attractive. H&F considers material sustainability-related risks and opportunities among many other material factors as part of its investment selection, portfolio management and monitoring and reporting processes. While H&F may consider material sustainability-related factors when making an investment decision, the Funds do not pursue a sustainability-based investment strategy or limit their investments to those that meet specific sustainability-related criteria or standards. Risks Material risks relating to the investment strategies and methods of analysis described above, and to the types of securities typically purchased by or for the Funds, include (but are not limited to) the following: No Assurance of Investment Return. H&F cannot provide assurance that it will be able to make or realize investments in any particular company or portfolio of companies. There is no assurance that H&F will be able to generate returns for its Funds or that the returns will be commensurate with the risks of investing in the type of companies and transactions described herein. There can be no assurance that expected returns for the Funds will be achieved, that a Fund will receive a return of its capital or that H&F will otherwise be able to carry out its investment program. There can be no assurance that H&F’s assessment of the short-term, intermediate-term or long-term

prospects of investments will prove accurate or that the Funds will achieve their investment objective or avoid loss of capital. Competition for Investments. The activity of identifying, managing, completing, monitoring, and realizing on attractive investments that fall within a Fund’s objective is highly competitive, involves a high degree of uncertainty and will be subject to market conditions. The Funds encounter competition from other entities having similar investment objectives. To the extent that Funds encounter increased competition for investments, returns to the Limited Partners are likely to be negatively impacted. Potential competitors include other investment partnerships and corporations, merchant banks, industrial groups, strategic industry acquirers, Limited Partners, financial institutions and other institutional investors, including hedge funds, private investment funds, registered investment companies and sovereign wealth funds, investing directly or through affiliates. New competitors continually enter the market, and in some cases existing competitors combine in a way that increases their strength in the market. Further, over the past several years, an ever-increasing number of private equity funds have been formed and many existing funds have grown considerably in size. Many recently formed and existing funds are able to call substantial amounts of remaining capital commitments, resulting in a significant amount of capital available for investment in such opportunities. Additional funds with similar investment objectives can be expected to be formed in the future by other unrelated parties. Additionally, competition for investment opportunities from other investment vehicles has increased on a global scale. Private equity and other alternative asset management vehicles, whether located in the U.S., Europe, Asia, or other emerging market regions, are making global competition increasingly intense. Such competitors may have more relevant experience, greater financial resources, a greater willingness to take on risk, lower return thresholds and more personnel than H&F. H&F expects that competition for appropriate investment opportunities could increase further, which may also require the Funds to participate in more auctions, the outcome of which cannot be guaranteed, thus reducing the number of investment opportunities available to the Funds and/or adversely affecting the terms upon which investments can be made. Participation in competitive processes such as auctions also increases the pressure on the Funds with respect to the pricing of a transaction, which could result in the Funds overpaying relative to what the Funds otherwise may have. For example, given the increasingly more competitive environment, H&F has found it more difficult to obtain buyer-favorable terms in a transaction which, at times, has resulted in H&F agreeing to more seller-favorable terms in a transaction, such as agreeing to a “hell or high water” agreement in an antitrust context, not being able to limit carveouts on interim operating covenants or being forced to provide equity backstop commitments. Moreover, in a competitive process, the Funds will incur bid, legal, due diligence and other costs (including deposits that may not be refundable) on investments that are not consummated or are otherwise not successful. As a result, the Funds will not recover from such potential investments all of its costs, which will detract from the Funds’ returns. In the event that a financing-related closing condition is not available to a Fund or if a Fund is required to provide a reverse break-up fee or guarantee in connection with a potential investment, a Fund may become obligated to consummate a transaction on less favorable terms or may be required to fund the reverse break-up or similar fee in connection with a potential investment that

is not made. As a result of this competitive environment, there can be no assurance that a Fund will be able to identify or consummate investments satisfying its investment criteria or that if such investments are made, that such investments will be realized upon at favorable valuations or that the objectives of the Fund will be achieved. Likewise, there can be no assurance that a Fund will be able to locate, complete and exit investments that satisfy a Fund’s rate of return objectives or realize upon the values of its investments or that it will be able to fully invest its committed capital. In addition, H&F’s investment strategies in certain cases may depend on its ability to enter into satisfactory relationships with joint venture partners or operating executives. There can be no assurance that H&F’s current relationship with any such partner or operating executive will continue (whether on currently applicable terms or otherwise) with respect to a Fund or that any relationship with other such persons will be able to be established in the future as desired with respect to any sector or geographic market and on terms favorable to such Fund. Risk of Investment Concentration. Concentration of investments may involve risks greater than those generally associated with more diversified funds, including significant fluctuations in returns. The Funds participate in a limited number of investments and, in addition, certain of these investments may require equity investments that are larger than were required in H&F’s historical transactions. A significant portion of the portfolio companies may be concentrated in a few industries, regions or types of investment and such concentration may change over time, including, for example, due to there being only a limited number of investments when the Fund initially commences its investing activities. Consequently, the aggregate return of a Fund may be adversely affected by the unfavorable performance of any single investment or industry. To the extent a Fund concentrates investments in a particular issuer, industry, asset, security, geographic region, asset type, sector, location in the capital structures of the issuers in which a Fund invests, transaction type or other measures, such Fund’s investments will be subject to higher concentration levels in such areas, which concentration would result in such Fund’s being more susceptible to fluctuations in value resulting from adverse economic, geopolitical, business, market or other conditions. Certain geographic regions, industries, sectors, transaction types or capital structures in which a Fund may more heavily invest may be more adversely affected from economic pressures when compared to others. As a consequence, the aggregate return of the Funds may be adversely affected by the unfavorable performance of one or a limited number of investments. Moreover, there are no assurances that any or all of a Fund’s investments will perform well or avoid loss, and if certain investments perform unfavorably, for a Fund to achieve above average returns, one or a few of its investments must perform very well. There are no assurances that this will be the case. In addition, in circumstances where H&F intends to refinance, restructure or dispose of all or a portion of the capital invested in a transaction, there will be a risk that such refinancing, restructuring or disposition may not be completed, which could lead to increased risk as a result of a Fund having an unintended long-term investment as to a portion of the amount invested and/or reduced diversification. Broad Investment Mandate. Except as described in the Governing Documents, there are no material limitations on the instruments, markets, geographic regions, asset types, transaction types or sectors in which the Funds may invest or the specific investment strategies that may be employed on behalf of the Funds. Considering the Funds’ broad investment mandate, the Funds may opportunistically make equity and/or debt investments that do not involve control or influence

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H&F currently provides investment advisory services to the Funds, and the Funds are H&F’s only clients. Investment advice is provided directly to the Funds and not individually to Limited Partners in such Funds.

Interests in the Funds are offered pursuant to applicable exemptions from registration under the Securities Act and the 1940 Act. H&F does not have a minimum size for a Fund, but minimum investment commitments are established for Limited Partners in certain Funds, subject to waiver by H&F in its sole discretion.

With respect to the Funds (including certain Other Investment Vehicles), a portion of the profits of such Fund is allocated to its General Partner as “carried interest.” Each General Partner is a Related Person (as defined in the 1940 Act) of H&F LP and H&F LLC. Certain Funds and other vehicles are not required to pay carried interest, management fees, administrative fees and/or profits interests or pay reduced carried interest, management fees, administrative fees and/or profits interests, including certain Associates Funds and certain Other Investment Vehicles. In addition, certain Funds may not pay carried interest due to the underperformance of such Funds’ underlying portfolio investments. The payment by some, but not all, Funds or Other Investment Vehicles of carried interest or payment of different carried interest rates may create an incentive for H&F to disproportionately allocate time, services or functions to Funds or Other Investment Vehicles paying carried interest or higher carried interest rates. Generally, and except as may be otherwise set forth in the Governing Documents of the Funds, this conflict is mitigated, at least in part, by (i) certain limitations on the ability of H&F to establish new investment funds, (ii) contractual provisions generally requiring Funds within the same Fund Family and related Other Investment Vehicles to purchase and sell investments contemporaneously or otherwise setting forth any agreement regarding priority with respect to existing opportunities, (iii) each investing Fund within the same Fund Family generally being required to invest pro-rata based on commitments and/or (iv) contractual provisions and procedures setting forth investment allocation requirements. Please also see Item 11 below for additional information relating to how conflicts of interests are generally addressed by H&F.

Affiliated Adviser H&F includes one foreign affiliated adviser, Hellman & Friedman LLP, a limited liability partnership organized under the laws of England (“H&F LLP”). H&F LLP is authorized to act as an arranger and an advisor by the UK Financial Conduct Authority. H&F LLP provides subadvisory services to H&F LLC pursuant to a sub-advisory agreement in respect of investments by the Funds in companies with principal operations outside the United States. H&F LLP has not registered with the SEC under the Advisers Act, in reliance on SEC no-action positions and the foreign private adviser exemption. To the extent H&F LLP is involved (directly or indirectly) in advising H&F with respect to the Funds, it is considered a “Participating Affiliate” and complies with the required record keeping and inspection provisions of the Advisers Act set forth in the Uniao de Bancos de Brazilieros S.A. (July 28, 1992) no-action letter and similar SEC staff no-action positions. Personnel of H&F LLP who are involved in providing advice (directly or indirectly) to H&F with respect to the Funds are considered “associated persons” of H&F LP and H&F LLC. In addition, consistent with SEC guidance, H&F LLP has entered into a “Participating Affiliate Agreement” that governs the relationship between H&F LLP and H&F LLC.

Trading Code of Ethics H&F LLC has adopted a written Compliance Manual and Code of Ethics (collectively the “Code of Ethics”) that is applicable to all H&F Personnel and any other person who the H&F Chief Compliance Officer determines provides advice on behalf of H&F and is subject to H&F’s supervision and control (collectively, “Adviser Personnel”). 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. Adviser Personnel and certain family and household members are generally precluded from purchasing publicly traded securities or trading in securities of the portfolio companies, subject to certain limited exceptions set forth in the Governing Documents of the Funds (including with respect to securities received as a distribution-in-kind from the Funds) or as set forth in the Code of Ethics. In addition, the Code of Ethics generally permits other transactions if (i) the transaction is “pre-cleared” by a compliance officer or (ii) the transaction is exempt from pre-clearance under the Code of Ethics. Under the Code of Ethics, Adviser Personnel are also required to file certain periodic reports with H&F’s compliance personnel as required by Rule 204A-1 under the Advisers Act. The Code of Ethics helps H&F detect and prevent potential conflicts of interest. Adviser Personnel who violate the Code of Ethics may be subject to remedial actions, including, but not limited to, censure, retraining, profit disgorgement, fines, demotion, suspension or dismissal. Adviser Personnel are also required to promptly report any violation of the Code of

Ethics of which they become aware. Adviser Personnel are required to annually certify compliance with the Code of Ethics. H&F reserves the right to refine, modify and amend the Code of Ethics and its other policies and procedures over time. A copy of the Code of Ethics is available to any client or prospective client upon written request to: Hellman & Friedman LLC, 415 Mission Street, Suite 5700, San Francisco, CA 94105, Attention: Chief Compliance Officer. Participation or Interest in Client Transactions Certain Adviser Personnel invest in and alongside the Funds, either through H&F (including through a General Partner), as direct Partners in the Funds or otherwise. In particular, Associates Funds are comprised primarily of current and former H&F Personnel and/or other friends and family of H&F. All or a portion of the management fee and carried interest related to investments held by such Funds are in certain cases reduced or eliminated. For further details regarding these arrangements, as well as conflicts of interest presented by them, please see “Conflicts of Interest” immediately below. Due in part to the fact that Limited Partners and potential Limited Partners in a Fund request different information, H&F provides certain information to one or more Limited Partners or prospective Limited Partners that it does not provide to all Limited Partners or prospective Limited Partners. Some Limited Partners are also executives of portfolio companies, and thus inherently have different (and greater) information regarding a Fund’s investments as well. In addition, the Governing Documents of certain Funds permit each such Fund’s General Partner to withhold information from certain Limited Partners in such Fund in certain circumstances. H&F may elect to withhold certain information to such Limited Partners for reasons including relating to H&F’s public reputation or overall business strategy, protection of its intellectual property or certain confidentiality concerns despite the potential benefits to such Limited Partners of receiving such information. Conflicts of Interest H&F and its related entities engage in a broad range of activities, including investment activities for their own account and for the account of multiple Funds, and providing transaction-related, investment advisory, management and other services to Funds and portfolio companies. In the ordinary course of conducting its activities, the interests of a Fund from time to time conflict with the interests of H&F, other Funds or their respective affiliates. Certain of these conflicts of interest, as well a description of how H&F addresses such conflicts of interest, can be found below. In general, H&F invests in one Fund Family at a time except with respect to follow-on investments (which are typically made by Funds that invested in the original investment (except as described below)), reserved investments and in connection with the activation of a successor Fund Family. In addition, H&F from time to time establishes Other Investment Vehicles, including on a transaction-by-transaction basis or for the purpose of investing in multiple portfolio companies

and/or multiple transactions, to enable the investing Fund Family to satisfy any shortfall in the required equity commitment necessary for an investment that exceeds the amount that H&F determines, in its sole discretion, is prudent for such Fund Family. Subject to the applicable Governing Documents, such Other Investment Vehicles generally are contractually required, as a condition to investment, to purchase and sell each investment opportunity at substantially the same time and on substantially the same terms as the applicable Fund Family that is invested in that investment opportunity. Certain Other Investment Vehicles pay management fees, administrative fees, profits interests and/or carried interest as determined by H&F in its sole discretion and certain Other Investment Vehicles pay reduced or no management fees, administrative fees, profits interests and/or carried interest. Resolution of Conflicts Prior to subscribing for interests in a Fund, each prospective Limited Partner receives information relating to significant potential conflicts of interest arising from the proposed activities of the Fund. In the case of all such conflicts of interest, H&F’s determination as to which factors are relevant, and the resolution of such conflicts, will be made using H&F’s best judgment and in H&F’s good faith discretion. In resolving conflicts, H&F considers various factors, including the interests of the applicable Funds with respect to the immediate issue and/or with respect to their longer-term courses of dealing. Certain procedures for resolving specific conflicts of interest are set forth below. When conflicts arise, the following factors may mitigate, but will not eliminate, conflicts of interest: •

H&F has adopted and implemented certain policies and procedures designed to reduce certain conflicts of interest;

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A Fund will not make an investment unless H&F believes that such investment is an appropriate investment considered from the viewpoint of such Fund;

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Many important conflicts of interest will generally be resolved by set procedures, restrictions or other provisions contained in the relevant offering documents and/or Governing Documents for the applicable Funds; and

•

Each Fund Family, as well as certain Other Investment Vehicles, has an Advisory Board, consisting of representatives of Limited Partners not affiliated with H&F. The Advisory Boards meet as set forth in the applicable Governing Documents to consult with H&F as to certain potential conflicts of interest. H&F seeks Advisory Board approval with respect to issues involving actual conflicts of interest as required pursuant to the Governing Documents of the applicable Fund (or, in the case of certain Other Investment Vehicles that do not have their own Advisory Board, the Advisory Board of another Fund will provide approval with respect to certain conflicts, as provided by the Governing Documents of the relevant Other Investment Vehicle). If no Advisory Board or Limited Partner approval is required, H&F will be guided by its good faith discretion.

As discussed above, certain provisions of a Fund’s Governing Documents are designed to protect the interests of Limited Partners in situations where conflicts may exist. However, these provisions

do not eliminate such conflicts. In addition, even when such Governing Document provisions are followed, some of such conflicts of interest may be resolved in a manner adverse to a Fund and its ability to achieve its investment objectives. There can be no assurance that H&F will identify or resolve all conflicts in a manner that is favorable to the Funds and Limited Partners generally are not entitled to receive notice or disclosure of the actual occurrence of conflicts or have any right to consent to them as they arise. Conflicts The material conflicts of interest encountered by a Fund include those discussed below, although the discussion below does not necessarily describe all the conflicts that are faced by a Fund. Other conflicts are also disclosed throughout this brochure and the brochure should be read in its entirety for other conflicts. In addition, other conflicts of interest may also be disclosed in the offering documents and/or Governing Documents of a particular Fund. Allocation of Investment Opportunities Among Funds and Allocation of Co-Investment Opportunities In connection with its investment activities, H&F encounters situations in which it must determine how to allocate investment opportunities among various Funds and other persons, which include, but are not limited to, the following: •

One or more Funds Families;

•

One or more Other Investment Vehicles;

•

One or more co-investors that wish to make direct investments (i.e., not through an Other Investment Vehicle) side-by-side with a Fund in a specific portfolio company investment, which from time to time include persons that are also Limited Partners in one or more Funds and/or persons that are not Limited Partners in any Funds; and

•

One or more co-investors acting as “co-sponsors” with H&F with respect to a specific transaction, which from time to time include persons that are also Limited Partners in one more Funds and/or persons that are not Limited Partners in any Funds.

H&F must first determine which Fund Family or Families or Other Investment Vehicle(s) are eligible to participate in an investment opportunity, including follow-on investments. H&F assesses whether a particular Fund Family or Other Investment Vehicle are eligible to participate in an investment opportunity based on factors such as the applicable Fund Family or Other Investment Vehicle’s Governing Documents, investment objectives, strategies, remaining commitments, investment period and structure and for follow-on investments, whether such Fund Family or Other Investment Vehicle are already invested in that portfolio company. H&F expects that from time to time investments will be appropriate for more than one Fund Family or for a Fund Family and Other Investment Vehicle(s) and H&F from time to time expects that it will allocate investment opportunities between more than one Fund Family or between a Fund Family and Other Investment Vehicle(s). With respect to follow-on investments, where more than one Fund Family and/or more than one Fund Family and one or more Other Investment Vehicle are

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While the Funds primarily generally invest in private or privately-placed securities, the Funds from time to time also transact in public open market transactions of publicly-traded securities. To meet its fiduciary duties to the Funds, H&F has adopted the following policies to address issues that might arise with respect to transacting in publicly-traded securities on the open market. Selection of Brokers and Dealers In the event it chooses to use a broker-dealer, H&F seeks to obtain best price and execution of transactions as set forth below. For each of the Funds, H&F has sole discretion over the purchase and sale of investments (including the size of such transactions) and the broker or dealer, if any, to be used to effect transactions. In placing each transaction for a Fund involving a broker-dealer, H&F will seek “best execution” of the transaction except to the extent it may be permitted to pay higher brokerage commissions in exchange for brokerage and research services (as discussed below). “Best execution” means obtaining for a Fund account the lowest total cost (in purchasing a security) or highest total proceeds (whether through a sale or distribution of securities), taking into account the circumstances of the transaction and the reputation and reliability of the executing broker or dealer. Best execution is not limited solely to the considerations of the best available commission rate.

In selecting brokers or dealers, H&F takes into account all factors that it deems relevant, including, by way of illustration, the reputation, experience and financial stability of the broker-dealer; the ability to provide competitive pricing; the size and timing of the transaction taking into account market prices and trends; the nature of the market for the security and the difficulty of execution; the amount of the commission; the ability and willingness to commit capital or financing and provide prompt and accurate execution and settlement; whether the broker-dealer makes a market in a security and/or finds sources of liquidity; the deemed appropriate monetization strategy taking into account the current and, if applicable, any contemplated later transaction; the ability to maintain H&F’s anonymity; the broker-dealer’s trading expertise, including its ability to minimize total trading costs and to trade without unduly impacting the market; the belief that the brokerdealer charges a fair and reasonable fee for each trade and that the Funds have been treated fairly and honestly in prior trades; the quality of execution, quality of broker-dealer relationship and quality of service rendered by the broker-dealer in other transactions; the broker-dealer’s expertise in a particular industry or prior experience and familiarity with the issuer; and the quality of any proprietary research and investment ideas. In addition, H&F may consider the use of Electronic Communications Networks (“ECNs”) when placing trades on behalf of the Funds. To the extent consistent with achieving best execution, H&F may also consider other business a particular broker or dealer may have done with H&F, such as identifying investment opportunities, performing investment banking services and the ability and willingness to commit capital or financing to other H&F transactions. When purchasing or selling over-the-counter securities with market makers, H&F generally seeks to select market makers it believes to be actively and effectively trading the security being purchased or sold. H&F has no formal arrangements with specific brokers or dealers to receive research or other services beyond transaction execution in exchange for brokerage commissions from client transactions (so called “soft dollar” arrangements). However, brokers or dealers are from time to time selected who provide research reports and services to H&F, including: proprietary brokerdealer company research and analysis; oral and written reports, statistics and advice about the economy, industries and individual securities or company investment opportunities; and reports on underwriting activity, bank rates, loan defaults, loan new issuance volumes and other capital markets statistics, all of which may be attractive for one or more Funds or to H&F; and opportunities to confer with management. In accordance with Section 28(e) of the Exchange Act, broker-dealers providing such services may be paid commissions on transactions for Funds in excess of those that other broker-dealers not providing such services might charge so long as H&F determines in good faith the amount of commissions is reasonable in relation to the value of the brokerage and research services provided, taking into account all of the accounts over which H&F exercises investment discretion. Recognizing the value of the brokerage and research services provided, H&F may allow a brokerage commission or negotiated term more than that which another broker-dealer might have charged for effecting the same transaction. H&F will periodically evaluate the overall reasonableness of the brokerage commissions and negotiated terms paid to or made with broker-dealers with respect to client transactions by, among other things, seeking to compare such commissions and terms with the commission rates and negotiated terms being charged by and entered into with other comparable broker-dealers. H&F will also periodically review the past performance of the broker-dealers with whom H&F has placed orders to execute Fund transactions considering the factors discussed above.

Aggregation of Trades H&F from time to time aggregates (or bunches) the orders of more than one Fund for the purchase or sale of the same publicly traded security. Portfolio managers and traders often employ this practice because larger transactions may enable them to obtain better overall prices, including lower commission costs or mark-ups or mark-downs. H&F may combine orders on behalf of one Fund with orders for other Funds for which it or its affiliates have trading authority, or in which it or its affiliates have an economic interest. To the extent H&F aggregates such orders, it will aggregate such orders as it deems appropriate and in accordance with each Fund’s Governing Documents and in the best interest of each Fund. If an order for more than one Fund for a publicly traded security cannot be fully executed, allocation shall be made based upon a pro rata basis among the participating Funds.

For details regarding economic benefits provided to H&F by non-clients, including a description of related material conflicts of interest and how they are addressed, please see Item 11 above. In addition, and as further described in Item 11 above, H&F and its affiliates as well as H&F Personnel, in certain instances, receive gifts from, or discounts on products and services provided by, portfolio companies of Funds, the customers and suppliers of such portfolio companies and/or service providers of Funds. H&F has in place a gift policy to address conflicts related to such gifts. H&F may from time to time in the future engage one or more third parties to establish feeder vehicles in connection with the offer and sale of interests in the Funds to certain potential investors.

Such persons are generally compensated by the feeder vehicle and investors therein for creating such vehicle, and may also be compensated by H&F, but are not generally compensated by the Funds. In addition, H&F may from time to time in the future, engage one or more third parties to act as a placement agent for a Fund in connection with the offer and sale of interests to certain potential investors or may, as described above, enter into an arrangement with a person to establish a pooled investment vehicle to act as a feeder into such Fund. In each such case, such persons generally will receive a fee in an amount equal to a percentage of the capital commitments for interests made by such potential investors to such Fund that are subsequently accepted or the relevant feeder fund. Subject to the applicable Governing Documents, such fees would generally be paid by the applicable Fund, and treated similar to an Other Fee Offset.

Not applicable.

Oversight and Monitoring The investment portfolios of the Funds are generally private, illiquid and/or long-term in nature, and accordingly H&F’s review of them is generally not directed toward a short-term decision to dispose of securities. However, H&F closely monitors the portfolio companies of the Funds. In addition, each portfolio company is formally reviewed by its team of investment professionals on a periodic basis and presented to H&F’s investment staff. The portfolio company’s deal team generally includes H&F Executives and other investment professionals of H&F. Reporting Limited Partners in the Funds typically receive, among other things, a copy of audited financial statements of the relevant Fund within 120 days after the fiscal year end of such Fund, as well as unaudited financial statements of the Fund, including statements of operations, cash flow and changes in capital account balances within 45 days after the close of each of the first three calendar quarters of each year. H&F from time to time, in its sole discretion, provides additional information relating to such Fund to one or more Limited Partners in such Fund as it deems appropriate.

As H&F relies on the “audit exemption” under the Advisers Act custody rule (i.e., Rule 206(4)2(b)(4)), Limited Partners in the Funds will not receive account statements from the Funds’ custodians.

Investment advice is provided directly to the Funds and not individually to the Limited Partners in the Funds. Services are provided to the Funds in accordance with the Governing Documents of the applicable Fund. Investment restrictions for the Funds, if any, are generally established in the Governing Documents or offering documents of the applicable Fund.

H&F has adopted policies and procedures setting forth the principles and procedures by which H&F votes or gives consent with respect to securities owned by the Funds. H&F may, from time to time, determine that it is in the best interest of a Fund to depart from the specific policies described below. H&F’s general policy is to vote proxy proposals, amendments, consents or resolutions, including a vote of a private company that does not involve a proxy relating to the Funds (each, a “proxy” and, collectively, “proxies”) in a manner that serves the best interest of the Fund, as determined by H&F in its discretion, taking into account relevant factors, including: (i) the impact on the value of the returns of the Fund; (ii) alignment of portfolio company management’s interest with the Fund’s interest, including establishing appropriate incentives for management; (iii) the ongoing relationship between the Fund and the portfolio companies in which it invests including the continued or increased availability of portfolio information; and (iv) industry and business practices. Subject to the foregoing, H&F will generally vote in accordance with the recommendation of a portfolio company’s management, as applicable, unless, in H&F’s opinion, such recommendation is not in the best interests of the applicable Fund. Unless the matter is reserved for the Board of Directors of the ultimate general partner of the applicable Fund, such votes must be approved by

an H&F Executive on the investment team for the relevant deal or may be approved by a Partner in the H&F legal department or tax department where the vote relates to administrative or nontransactional matters. H&F will abstain from voting or affirmatively decide not to vote if H&F determines that abstaining or not voting is in the best interest of the Fund. In making such a determination, H&F will consider various factors, including, but not limited to: (i) the costs associated with exercising the proxy (e.g., translation or travel costs); (ii) any legal restrictions on trading resulting from the exercise of a proxy; and (iii) any actual or perceived conflicts of interest in the proposed action to be voted upon. Conflicts may arise between the interest of the Fund, on the one hand, and the interest of H&F on the other hand. H&F will use its best judgment to address any such conflict of interest and ensure that it is resolved in accordance with the best interests of the Funds and consistent with the Governing Documents. See also “Conflicts of Interest” in Item 11 above. Copies of relevant proxy logs and copies of proxy voting policies are available to any client or prospective client upon written request to: Hellman & Friedman LLC, 415 Mission Street, Suite 5700, San Francisco, CA 94105, Attention: Chief Compliance Officer.

Not applicable.