Hillsdale Investment Management Inc.

P. Information Technology Security As the use of technology has become more prevalent in the course of business, the Funds have become potentially more susceptible to operational risks through breaches in information technology security (“IT security”). A breach in IT security refers to both intentional and unintentional events that may cause a Fund to lose proprietary information or other information subject to privacy laws, suffer data corruption, or lose operational capacity. This in turn could cause a Fund to incur regulatory penalties, reputational damage, additional compliance costs associated with corrective measures, and/or financial loss. IT security breaches may involve unauthorized access to a Fund’s digital information systems (e.g., through “hacking” or malicious software coding), but may also result from outside attacks such as denial-of-service attacks (i.e., efforts to make network services unavailable to

intended users). In addition, IT security breaches of a Fund’s third-party service providers (e.g., trustee or manager, administrators, transfer agents, custodians and sub-advisors) or of issuers in which a Fund invests can also subject a Fund to many of the same risks associated with direct IT security breaches. As with operational risk in general, the Funds, through Hillsdale as trustee and manager, have established risk management systems designed to reduce the risks associated with IT security. However, there is no guarantee that such efforts will succeed, especially since the Funds do not directly control the IT security systems of issuers or third-party service providers. Q. Modeling Risk Hillsdale’s investment processes rely on quantitative models and historical and current data to generate forecasts, rankings, risk estimates, and other analytical outputs. Differences between expected and actual model performance may lead to undesirable outcomes for clients. Historical relationships reflected in the data may not be representative of future market conditions and models may fail to predict future returns, volatilities, correlations, liquidity conditions, or other market behavior. Unexpected market events, changes in market structure, and conditions outside of the historical test environment may cause model outputs and portfolio outcomes to vary materially from expectations. Hillsdale’s quantitative processes depend on software, code, and systems developed internally and by third parties. Programming, model, or implementation errors can occur and may go unidentified or unaddressed for extended periods. If an error affects inputs, assumptions, or implementation, model outputs and related portfolio actions may vary materially from expectations and could adversely affect trading decisions and portfolio outcomes. Hillsdale employs strategy specific risk parameters (including risk budgets) that are monitored through separate processes, which are intended to limit the extent of unintended exposures; however, these measures may not be effective in all circumstances. Even when coded as intended, certain numerical estimation and optimization methods may produce sub optimal or incorrect outputs under certain conditions. Certain investment strategies may also rely on the gathering, cleaning, mapping, and analyzing of large amounts of data from third‑party sources. It is not possible or practicable to incorporate all potentially relevant data into forecasts or trading decisions at all times. Hillsdale uses its judgment to determine which data to acquire and which subsets of data are used within a strategy, subject to legal, regulatory, risk, and operational constraints. Third‑party data providers may adjust, degrade, limit, delay, or suspend the provision of data for a variety of reasons. Due to the automated nature of data pipelines and the reliance on third‑party sources, it is possible that not all desired data will be available to, or processed by, Hillsdale at all times, including due to coding errors, system failures, or upstream vendor issues. In such circumstances, forecasts and investment and trading decisions may be generated based on the data available at the relevant time. Data errors or limitations, including errors in pricing or corporate action data, could adversely affect trading decisions and portfolio outcomes. There can be no assurance that Hillsdale’s models will perform as expected. Clients should consider modeling, data, and implementation risks as inherent risks of a quantitative investment process.

R. Use of Machine Learning and Artificial Intelligence Hillsdale’s investment and research processes are quantitative and rely on data, models, software, and analytical methods. Certain quantitative techniques that may be used in these processes can include machine learning, natural language processing, large language models, or other implementations of artificial intelligence (collectively, “AI Tools”). AI Tools rely in whole or in part on computer-driven analysis and may be more complex than other quantitative techniques. They may require additional data, more complex code, greater processing capacity, and different expertise to develop, operate, supervise, and validate. AI Tools and their inputs are expected to continue to evolve and increase in complexity over time. The use of AI Tools can heighten certain modeling and operational risks, including the risk of errors, defects, or limitations that may be difficult to identify, explain, replicate, or correct in a timely manner, or at all. Certain AI Tools may produce outputs that appear reasonable but are incomplete, inaccurate, biased, outdated, or otherwise unreliable, including “hallucinations.” AI Tools are highly dependent on the data and other inputs used to train them and produce results and may be susceptible to errors arising from flawed, incomplete, or biased data or processing. AI Tools may also fail to integrate as intended with other systems or components used in Hillsdale’s quantitative processes, potentially causing errors or unintended outcomes. Hillsdale may use AI-enabled tools and third-party providers of AI-enabled software, data, or research tools, in connection with aspects of research, portfolio support, trading support, or operational workflows. Many AI Tools are relatively recent and evolving developments and may be subject to undetected errors, defects, limitations, or security vulnerabilities. Where AI Tools are developed, hosted, or provided by third parties, Hillsdale may have limited or no visibility into the data used to train the AI Tool, the technology used to create it, or the accuracy, completeness, or robustness of the tool and its outputs. In addition, the processes by which some AI Tools produce particular outputs may be difficult (or impossible) to understand, to explain, or to replicate, and there is a risk that outputs may be unreliable, including where outputs appear to be accurate but are not. Some errors, defects, or security vulnerabilities may be discovered only after a tool has been used in production or after substantial usage. The use of AI-enabled tools can also introduce or increase risks related to confidentiality, privacy, information security, record retention, and third-party risk management. For example, information submitted to an AI-enabled tool could be retained, processed, or used in a manner inconsistent with Hillsdale’s expectations or contractual arrangements. The effectiveness and availability of AI-enabled tools may depend on third-party providers and their controls, including controls relating to data security, confidentiality, and system integrity. These risks could result in operational errors, reporting inaccuracies, or other unintended outcomes and could adversely affect client accounts or the Funds. Laws and regulatory expectations relating to AI Tools, including those relating to data use, recordkeeping, and intellectual property, are evolving and may lead to restrictions, increased compliance costs, disputes, or potential liability. Hillsdale maintains policies and procedures designed to govern the use of third-party applications, including those that incorporate AI-enabled

components, including restrictions on the use of sensitive and proprietary information and the application of access controls and human oversight. However, there can be no assurance that these measures will be effective in all circumstances or that all risks associated with the use of AI-enabled tools can be prevented. S. Potential Conflicts of Interest Hillsdale is required to meet its fiduciary duty and to satisfy its standard of care in exercising its duties with respect to the Funds and separately managed accounts. Hillsdale and its affiliates may also engage in the promotion, management or investment management of any other fund or trust or engage in other activities. Directors and officers of Hillsdale may act as directors or officers of other entities that provide services to funds. In doing so situations may arise where: (i) the interests of Hillsdale, including individuals employed by it, and its clients diverge; (ii) the interests of different clients, including the Funds, diverge; (iii) Hillsdale could be influenced to put its interests ahead of its clients’ interests; or (iv) monetary or non-monetary benefits available to Hillsdale may compromise the trust that a reasonable client has in Hillsdale. Such situations are referred to as “conflicts of interest” or “conflicts”. Hillsdale is required to have policies and procedures in place designed to ensure that material conflicts are resolved in the best interest of its clients, including the Funds. A conflict is considered to be material if it could be reasonably expected to affect either or both of: (i) decisions of a client; and (ii) recommendations or decisions of Hillsdale. If a material conflict is not managed in the best interest of a Fund, the Fund may be negatively impacted. For example, the Fund’s investment results achieved could be negatively impacted if the interests of the Fund are not managed in its best interests or if management of the Fund is adversely affected. In addition, the Fund and Hillsdale may be adversely impacted as a result of reputational damage or regulatory action. Hillsdale may invest a portion of the Fund’s assets in other investment funds that are managed or advised by Hillsdale in accordance with applicable law (“Underlying Funds”). There will be no duplication of performance fees, management fees or any other fees in connection with any such investments. Investors should refer to the offering document for their specific investment for a discussion of conflicts of interest. For additional discussion with respect to potential conflicts of interest also refer to the following sections: (i) Item 6 – Performance Based Fees and Side-by-Side Management; (ii) Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading; (iii) Item 12 – Brokerage Practices; (iv) Item 14 – Client Referrals and Other Compensation; and (v) Item 17 – Voting Client Securities. T. Series Risk The management and performance fees determined with respect to a particular series, as well as certain other operating expenses, are charged against the asset value of that series. However, all

other expenses generally will be allocated among the various series of a Fund, and a creditor of a Fund may seek to satisfy its claims from the assets of a Fund as a whole, even though its claims relate only to a particular series of a Fund. U. Performance Fees Performance-based fees may create an incentive for Hillsdale to engage in investment strategies and make investments that are more speculative than would be the case in the absence of such fees. Please also refer to Item 6 – Performance Based Fees and Side-by-Side Management. V. Indebtedness A Fund may incur indebtedness, secured by the assets of the Fund, to facilitate redemption requests and for other short-term liquidity requirements, which may subject the Fund to higher current expenses. W. Fees and Expenses A Fund is obligated to pay management fees and other expenses regardless of whether a Fund realizes a profit. Under certain circumstances, a Fund may be subject to significant indemnification obligations in respect of Hillsdale and certain other parties. Investors should refer to the offering document for their specific investment for more detail. X. Potential Liability of Unitholders The Declaration of Trust or Trust Agreement, as applicable, of each of the Hillsdale Funds provides that no Unitholder shall be subject to any personal liability whatsoever in tort, contract or otherwise to any person in connection with the Trust Property or the obligations or affairs of the Fund and all such persons will look solely to the Trust Property for the satisfaction of claims of any nature arising out of or in connection therewith and the Trust Property only will be subject to levy or execution. There is a risk, that is considered by Hillsdale to be remote, in the circumstances that a Unitholder could be held personally liable, notwithstanding the statement in the Declaration of Trust or Trust Agreement, for obligations of a Fund (to the extent that claims are not satisfied by the Fund). It is intended that each Fund’s operations be conducted in such a way as to minimize any such risk. It is considered that the risk of any personal liability of Unitholders is minimal in view of the anticipated equity of the Funds. In the event that a Unitholder should be required to satisfy any obligation of the Funds, such Unitholder will be entitled to reimbursement from any available assets of the applicable Fund. Y. Changes in Applicable Law Legal, tax and regulatory changes may occur that can adversely affect a Fund and its investors. Z. Lack of Certain Registration and Regulatory Protections

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