J.P. MORGAN ALTERNATIVE ASSET MANAGEMENT, INC.

Advisory Business A. General Description of Advisory Firm This Brochure relates to the investment advisory services offered by J.P. Morgan Alternative Asset Management, Inc. (“JPMAAM” or the “Adviser”). JPMAAM is registered with the U.S. Securities and Exchange Commission (“SEC”) as an investment adviser pursuant to the Investment Advisers Act of 1940, as amended (the “Advisers Act”). JPMAAM, together with Bear Stearns Asset Management Inc., Campbell Global, LLC, 55I, LLC, Highbridge Capital Management, LLC, J.P. Morgan Investment Management, Inc., JPMorgan Asset Management (Asia Pacific) Limited, JPMorgan Asset Management (UK) Limited, JPMorgan Funds Limited, Security Capital Research & Management Inc., each an SEC registered investment adviser, various affiliated foreign investment advisers and the asset management division of JPMorgan Chase Bank, N.A. comprise the Asset Management ("AM"), business of J.P. Morgan Asset & Wealth Management ("JPMAWM"). J.P. Morgan Asset Management (“JPMAM”) is the marketing name for the AM businesses of JPMorgan Chase & Co. and its affiliates worldwide (“JPMC”). JPMC is a publicly traded global financial services firm. JPMorgan Asset Management Holdings Inc., which is a subsidiary of JPMC, owns all the common stock of JPMAAM. JPMAAM was incorporated in Delaware on July 2, 1987. B. Description of Advisory Services JPMAAM and its "Affiliates" (as defined in Key Terms) in JPMAM provide a broad range of investment strategies to meet the diverse requirements of their clients' investment needs. JPMAAM provides discretionary and non-discretionary investment management services to institutional and individual investors. JPMAAM acts as investment manager to various domestic and foreign private pooled investment vehicles as well as investment manager to foreign registered funds, including, but not limited to, Collective Investment in Transferable Securities (“UCITS”) funds(each, a “Fund”), and to certain separately managed accounts (each, a “Managed Account”). It also acts as sub-adviser to certain accounts.

In its capacity as investment manager or sub-adviser, JPMAAM’s principal services consist of providing investment advice regarding the investment of the assets of each Fund or Managed Account among professionally selected investment vehicles or accounts (the “Investment Vehicles”) that are managed by portfolio managers (the “Portfolio Managers”) which are selected through a due diligence process. These Portfolio Managers employ, as a group, a variety of investment techniques and strategies. JPMAAM also may provide investment advice regarding JPM Affiliated Funds as described in Item 5E. To a limited extent, JPMAAM, on behalf of certain Funds and Managed Accounts, makes, or, with respect to its non-discretionary clients, may recommend direct investments (“Direct Investments”) in a broad range of securities, markets and instruments other than through Investment Vehicles, including without limitation, for portfolio hedging and to temporarily adjust a Fund’s or Managed Account’s overall market exposure. C. Availability of Customized Services for Individual Clients JPMAAM typically makes or recommends investments for clients in accordance with written investment guidelines or other investment specific documentation agreed with clients for each advisory mandate. Investment services may be tailored for each client’s specific needs and objectives, including restrictions on investing in certain securities or types of securities, strategies, industries or regions of the world, and client accounts have varying business terms, including but not limited to fees charged, investment minimums, redemption rights, information rights and reporting requirements. JPMAAM has procedures and controls to monitor compliance with each client’s specific investment guidelines. JPMAAM also provides investment advice related to the liquidation of assets of Managed Accounts in accordance with written guidelines agreed with clients for each liquidation mandate. Liquidation services may be provided with respect to new or existing client relationships. Where JPMAAM is the investment adviser to a Fund, investment objectives, guidelines and any investment restrictions of the Fund generally are not tailored to the needs of individual investors in those vehicles, but rather are described in the prospectus or other relevant offering document for the vehicle. D. Wrap Fee Programs

Not applicable. E. Assets Under Management As of December 31, 2025, JPMAAM had assets under management in the amounts set forth below: Assets Under Management Assets Managed on a Discretionary Basis Assets Managed on a Non-Discretionary Basis Total Assets Under Management

U.S. Dollar Amount $ 18,235,504,961 $ 11,495,823,000 $ 29,731,327,961

Fees and Compensation A. Advisory Fees and Compensation Separately Managed Accounts Clients generally pay an investment advisory fee based on a percentage of the market value of the assets managed by the Adviser. Such fee is referred to as an “asset-based fee.” To the extent permitted under the Advisers Act, the Adviser also charges performance-based compensation with respect to certain strategies and products or as otherwise agreed with specific clients. For an additional discussion of performance-based compensation, please refer to Item 6. Fees vary as a result of negotiations, discussions and/or factors that may include the particular circumstances of the client, account size, investment strategy, account servicing requirements, the size and scope of the overall relationship with the Adviser and its Affiliates or certain consultants, or as may be otherwise agreed with specific clients on a case by case basis. The Adviser may not disclose to a client the terms of another client’s agreement (without that client’s permission). Clients will indirectly pay fees to Investment Vehicles in which such clients are invested. (See Item 5.C below for greater detail.) Registered Funds JPMorgan Funds and Other Registered Funds Sub-Advised by the Adviser The prospectus of each foreign registered fund (including UCITS) advised or sub-advised by the Adviser (the “Foreign Funds”) sets forth the applicable fees and expenses. Unregistered Funds With respect to unregistered private funds managed by the Adviser, the applicable fees and expenses are set forth in the relevant offering or governing documents, or in certain cases, in separate fee agreements between the Adviser and the private fund’s investors. The Adviser's fees vary depending on the type of fund, investment strategy, share class or series within a Fund. The private funds managed by the Adviser are generally subject to an asset-based fee ranging up to 1.6% annually and performance-based compensation ranging up to 12.5% of the appreciation of the fund’s assets or performance in excess of a specified benchmark or preferred return threshold. (Additionally, investors in a fund will

indirectly pay fees to Investment Vehicles in which such fund is invested. (See Item 5.C below for greater detail.) From time to time, a private fund may enter into “side letter” agreements with certain investors which provide for investment terms that may differ from the terms described in its offering documents. Such terms may include waivers reducing or rebating management fees and/or performance fees. JPMAAM typically will not disclose to other private fund investors the terms of any such side letter agreements. Investors should refer to the offering documents of the relevant private fund or applicable fee agreement for further information with respect to fees. B. Payment of Fees Separately Managed Accounts For Managed Accounts, the fees are either paid out of the assets of the account or from the client’s other assets by the client’s custodian, or as provided in the investment management agreement with the client and the Adviser or its Affiliate. The Adviser typically charges fees after services have been rendered, including with respect to posttermination or liquidation - related services; (i) the management fee is typically payable at the end of each calendar quarter, and (ii) the performance compensation is typically payable at the end of each calendar year, or, in each case as otherwise provided in the investment management agreement with the client. Registered and Unregistered Funds A description of the calculation and payment of fees payable to the Adviser is set forth in the applicable prospectus, offering or governing document or fee agreement for the relevant fund. Investors should refer to such documents for further information with respect to fees. C. Additional Fees and Expenses General In addition to the advisory fees described above, clients may be subject to other fees and expenses in connection with JPMAAM's advisory services. Transaction Charges

Certain clients, typically the Liquid Alts Funds, pay brokerage commissions, taxes, charges and other costs related to the purchase and sale of securities for such client’s account. See Item 12 for additional information regarding the Adviser’s brokerage practices. Custody and Other Fees Clients may establish a custody account under a separate agreement with a custodian bank, and the client will incur a separate custody fee for the custodian’s services. The custodian may be an Affiliate of the Adviser. If an investor's account is invested in pooled investment funds, including private funds, the investor’s account generally will bear its pro-rata share of the expenses of the fund, including custody fees. Common Types of Expenses Related to Advisory Services Clients, including funds, may either directly or through allocations by the Adviser or its Affiliates bear the following expenses related to the offering, administration and operation of a client account: (i)

All organizational and offering expenses of a fund;

(ii)

The costs, fees and expenses associated with the formation of any joint venture, special purpose vehicle, co-investment or any syndication in relation to any investment;

(iii)

The costs related to the marketing of a fund to potential investors, including, the costs, fees and expenses associated with registering a fund in certain jurisdictions, distribution fees or expenses or translations of fund documents;

(iv)

Fees paid and out-of-pocket expenses reimbursed to service providers selected to provide administrative services, registration and transfer agency services, operational services, treasury oversight services and all other recordkeeping expenses;

(v)

Fees paid and out-of-pocket expenses reimbursed to a client’s custodian;

(vi)

Fees and disbursements arising from the Adviser’s use of legal counsel in connection with the Adviser’s performance of its activities on behalf of a client, including, without limitation, preparing and updating agreements between a

client and its service providers, governing documents for funds or subscription and other fund-related documents; (vii)

Expenses (including attorneys’ fees and disbursements) relating to litigation, proceedings, examinations, audits or requests brought in state, federal or other courts and/or by regulatory bodies, including by any taxing authority or other governmental bodies or self-regulatory organizations;

(viii)

The costs, fees or expenses incurred in threatening, making, defending, investigating or settling any claim, counterclaim, demand, action, suit or proceedings of any kind or nature (including legal and accounting fees and expenses, costs of investigation incurred in making, defending or settling any of the same), including in connection with the enforcement of clients’ rights in respect of investments made;

(ix)

Fees arising from the Adviser’s use of independent accountants and other professional advisors in connection with the Adviser’s performance of its activities on behalf of a client, including without limitation, the costs, fees and expenses associated with any independent valuation agent, the auditors and professional appraisers or other advisers in the preparation of the annual audit of the fund, the valuation of its assets and other persons associated with the preparation, printing and communication of valuations and reports to investors and any financial statements or tax returns for the fund or its investors;

(x)

The costs of directors’ and officers’ errors and omissions insurance and any fidelity bond;

(xi)

Fees and expenses of directors, general partners or managing members not affiliated with the Adviser;

(xii)

The costs of organizing and conducting director and investor meetings with respect to a fund and the preparation and distribution of all investor reports and other communications with the fund’s investors;

(xiii)

The expenses of a conflicts review board (or similar oversight governance), if established

(xiv)

Fees and expenses of a fund’s secretary and the costs of maintaining a fund’s registered office;

(xv)

Payment of taxes and other governmental charges, including without limitation, annual regulatory registration fees,

(xvi)

U.S. or non-U.S. tax preparation expenses related to a fund or intermediary entity or to a client’s direct or indirect investment;

(xvii) All reporting and filing expenses, including costs of compliance-related matters and regulatory filings together with the costs incurred in preparing any such submission; (xviii) The costs of maintaining all of a fund’s corporate records and books of account, including, accounting and auditing fees and disbursements; (xix)

Any stock exchange listing fees;

(xx)

Costs and expenses of borrowing, including interest expenses;

(xxi)

Costs and expenses of issuing, transferring and redeeming shares or interests of any class of shares or interests of a fund and paying dividends or making other distributions thereon;

(xxii) All fees paid and expenses incurred directly or indirectly related to a client’s investment program, either with respect to direct investments or allocations to Investment Vehicles, (including, for the avoidance of doubt, the ongoing operating and administrative expenses of any intermediary vehicles or other funds managed by the Adviser in which a fund invests); including, without limitation: a. asset-based fees, performance-based or incentive fees or allocations and redemption or withdrawal fees, however titled or structured; b. all costs and expenses related to portfolio transactions and positions in Investment Vehicles for a client’s account; c. third-party (such as attorneys or other professional advisers or agents) costs, fees and expenses incurred in connection with structuring, negotiating, financing, and documenting of the acquisition, ownership or realization of investments on behalf of clients, including, with respect to investments in less liquid, private equity-like funds, seed/revenue share arrangements, co-investments and other uniquely structured investments; d. Taxes related to direct or indirect investments on behalf of a client, including without limitation, transfer taxes and premiums, taxes withheld on non-U.S. dividends;

e. Costs, fees and expenses incurred in connection with conversion from one currency into another and any hedging or currency transactions, including such transactions hedging any foreign exchange or other risks associated with any investments or any fund; f. Any other expenses related to a client’s investment program, including without limitation, fees for data and software providers, third-party research expenses, expenses in connection with its temporary or cash management investments, brokerage commissions, interest and commitment fees on loans and debit balances, borrowing charges on securities sold short, dividends on securities sold but not yet purchased and margin fees; (xxiii) Costs and expenses incurred in connection with the liquidation of a fund or intermediary entity; (xxiv) Any costs, fees and expenses incurred to alter or modify the structure of a fund (including in order to comply with any anticipated or applicable regulation or law or to enable the fund to operate in a more efficient manner); and (xxv) Any extraordinary expenses of a client, including indemnification expenses. The foregoing examples of expenses are not exhaustive and should not be taken to be inclusive of all costs, fees and expenses. For details on fund expenses of the funds advised by an Adviser, please refer to the offering documents for the funds. The Adviser may, in its discretion, invoice a client directly for certain out-of-pocket expenses. Expense Allocation From time to time, expenses will be incurred by multiple client accounts and funds. In such cases, the Adviser will allocate aggregate costs among the applicable client accounts (and, in certain cases, among the Adviser and applicable client accounts and funds) in accordance with allocation policies and procedures which are reasonably designed to allocate expenses in a fair and equitable manner. However, expense allocation decisions can involve potential conflicts of interest (e.g., an incentive to favor advisory clients that pay higher incentive fees or conflicts relating to different expense arrangements with certain advisory clients). In general, the Adviser allocates expenses related to investments made on behalf of more than one client among such clients in proportion to their respective capital invested or proposed to be invested in such

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JPMAAM’s selection or recommendation of an Investment Vehicle is based on a defined due diligence process that generally includes both qualitative and quantitative analysis of each of the Investment Vehicles and on-site visits. The qualitative evaluation includes an examination of the Investment Vehicle’s investment strategy, philosophy, background of the Investment Vehicle’s key personnel, and many other investment and operational considerations. The quantitative evaluation, if applicable, includes a review of the rate of return, profit/loss, and volatility of the Investment Vehicle’s assets under management and a statistical analysis of the Investment Vehicle’s portfolio correlation with market indices and with portfolios of existing and other prospective Investment Vehicles. To this end, JPMAAM has developed a proprietary database, and proprietary analytical programs and asset allocation models to enhance its performance evaluation capabilities. JPMAAM subscribes to databases and evaluation services to supplement its proprietary programs. JPMAAM also makes use of trade publications, industry conferences, and its knowledge of the alternative asset management industry to identify and analyze new funds. Portfolio Managers invest Investment Vehicles’ and clients’ assets in a wide range of instruments and markets across certain major strategies. Such instruments and markets may include, but are not limited to, U.S. and non-U.S. equities and equity-related instruments, fixed income and other debt-related instruments, currencies, commodities and derivative instruments. Direct Investments are primarily sourced through JPMAAM’s

relationships with the Portfolio Managers and may include, without limitation, U.S. and non-U.S. equities and equity-related instruments, restricted securities, special purpose acquisition companies, currencies, commodities, and derivative instruments and any other investments that JPMAAM may make or recommend indirectly through the Investment Vehicles. Additionally, the Adviser considers ESG factors as part of the investment decision process for certain strategies. JPMAAM’s risk management approach is focused on identifying, monitoring and managing both investment and operational risks. JPMAAM’s investment risk management framework is coordinated across its platform and supported by rigorous but flexible risk management tools and fluid communication. Information flowing through the risk monitoring processes is compiled in a timely manner. The insights that are formulated based on the information facilitate informed decisions in manager selection, portfolio construction and on-going risk management across JPMAAM’s portfolios. At the portfolio level, JPMAAM’s risk management policy is focused on understanding and managing liquidity, exposures, cross correlations, value at risk and leverage; and monitoring such risks of JPMAAM’s portfolios during both normal and stressed market environments. The strategies and sub-strategies employed by Portfolio Managers and Investment Vehicles are analyzed to ensure that with the embedded risks across the portfolios are satisfactory. Generally, a multi-manager, multi-strategy framework overlays the investment process and helps to further mitigate risk. JPMAAM makes recommendations for all clients with respect to which it acts as investment manager, adviser or sub-adviser in accordance with the investment objectives and strategies agreed with each client. Generally, JPMAAM seeks to allocate a client’s holdings among broad categories of investment strategies. The strategies currently include the six broad categories that are described generally below. JPMAAM may add, delete or modify such categories of investment strategies at its discretion. Long/Short Equities: Portfolio Managers utilizing this strategy make long and short investments in equity securities that are deemed to be undervalued or overvalued. The Portfolio Managers may specialize in a particular industry or geography, or may allocate holdings across industries or geographies. The Portfolio Managers typically do not attempt to neutralize the amount of long and short positions (i.e., they will be net long or net short). Portfolio Managers in this strategy may employ leverage and may utilize derivatives and credit instruments. Relative Value: Portfolio Managers utilizing this strategy attempt to capture pricing inefficiencies/differentials between related securities while trying to minimize the impact

of general market movements. Different relative value strategies include convertible bond arbitrage, statistical arbitrage, pairs trading, yield curve arbitrage, volatility arbitrage, commodity relative value, and basis trading. The types of instruments traded vary considerably depending on the Portfolio Manager’s particular relative value strategy. Since the typical implementation of relative value strategies attempts to capture comparatively small mispricings between securities, moderate to substantial leverage may be employed to produce attractive rates of return. In practice, the magnitude and precision of Portfolio Managers’ hedging can vary substantially, generally introducing some degree of directionality and/or basis risk. Opportunistic/Macro: Portfolio Managers utilizing this strategy invest in a wide variety of instruments using a broad range of primarily directional strategies. It is common for Portfolio Managers in this strategy to assume an aggressive risk posture relying on a combination of macro-economic models, fundamental research, and quantitative algorithms. Portfolio Managers invest across countries, markets, sectors and companies, and have the flexibility to invest in numerous financial instruments. Futures and options are often used for hedging and speculation in order to quickly position a portfolio to profit from changing markets. The use of leverage varies considerably. Credit: Portfolio Managers utilizing this strategy may take long or short positions in public or private corporate bonds, loans, credit derivatives, convertible bonds, asset-backed securities, equities and equity derivatives. In most cases, Portfolio Managers will take long or short positions that reflect fundamental views on underlying credits. In some instances, Portfolio Managers may take long or short positions in instruments that reflect credit exposure to the same entity. Credit Portfolio Managers may invest in both investment grade and non-investment grade credit issuers, while also very often holding positions where the underlying exposures are to debt and equity securities of companies in financial difficulty, reorganization or bankruptcy. Merger Arbitrage/Event Driven: Portfolio Managers utilizing this strategy invest in securities of companies involved in mergers, acquisitions, restructurings, liquidations, spin-offs, or other special situations that alter a company’s financial structure or operating strategy. Portfolio Managers will have long or short positions in equities, equity derivatives, corporate bonds, loans and credit derivatives. Risk management and hedging techniques are typically employed to protect the portfolio if an anticipated event does not occur as expected or is extended. Portfolio Managers will typically employ leverage. Portfolio Hedge: Portfolio Managers utilizing this strategy can make use of one of any number of strategies which JPMAAM views as offsetting risks inherent in other parts of

the portfolio. The Adviser also intends to manage a portion of certain clients’ portfolios assets directly utilizing portfolio hedge strategies. Specifically, by way of example, substrategies such as short selling or long volatility may be employed to hedge equity beta (profiting from declining security prices) or a short credit allocation may be used to offset long credit risk (profiting from credit spread widening). It is also conceivable that JPMAAM may utilize the Portfolio Hedge strategy to offset risks to macroeconomic factors, such as inflation, sovereign default, etc. In general, JPMAAM would seek out Portfolio Managers that add alpha over a simple benchmark return, or the inverse return of the benchmark in many cases. It is expected that the allocation to this strategy will produce returns that are negatively correlated to the rest of the portfolio and/or the broader markets, and therefore one could reasonably expect negative returns for the Portfolio Hedge strategy in periods of low volatility and/or upwardly trending markets. It should also be noted that the allocations to this strategy are generally indirect portfolio hedges and therefore may introduce some degree of basis risk to the broader portfolio. ESG Integration Strategies: JPMAAM believes that ESG considerations can play an important role in long-term investment strategies and performance. While the precise methodology is tailored to each investment strategy, the Adviser generally takes a holistic, research-driven approach to sustainable investing including supplementing proprietary research with a variety of third-party industry specialists and engaging directly with Portfolio Managers on a variety of ESG issues. The Adviser offers an array of investment solutions to meet clients’ financial goals and non-financial objectives including ESG objectives. Some of the Adviser’s core investment capabilities incorporate ESG factors into the Adviser's analysis consistent with the Adviser's goal of delivering investment returns to its clients and the Adviser’s duty to act in the best interests of the accounts it manages. The Adviser also accommodates client specific goals and offers ESG strategies that include the strategies described below. The following are some of the Adviser’s ESG strategies: • ESG integration strategies include systematic and explicit consideration of ESG factors in the investment decision-making process. • Values/norms based strategies, including screening for or avoiding certain companies or industries as specified by the client that do not align with client values or meet other norms or standards. • Best in class strategies include making investments in Investment Vehicles that use ESG themes to try to generate positive performance versus industry peers.

Clients should understand that investments in the Investment Vehicles, securities and other assets involve the risk of loss. Past performance of any investment strategy is not a guarantee of future results. Clients should be prepared to bear the risk of investment losses. See Item 8.B, below, for additional information regarding investment risks.

B. Material, Significant, or Unusual Risks Relating to Investment Strategies The investment strategies utilized by the Adviser depend on the requirements of the client and the investment guidelines associated with the client’s account. Each strategy is subject to material risks. A client’s account may not achieve its objective if the Adviser’s expectations regarding particular securities or markets are not met. Set forth below are some of the material risk factors that are often associated with the investment strategies and types of investments relevant to many of the Adviser’s clients. This is a summary only. The information included in this Brochure does not include every potential risk associated with each investment strategy or applicable to a particular client account. Clients should not rely solely on the descriptions provided below. Clients are urged to ask questions regarding risk factors applicable to a particular strategy or investment product, read all product-specific risk disclosures and determine whether a particular investment strategy or type of security is suitable for their account in light of their specific circumstances, investment objectives and financial situation. In the case of Funds, the risk factors associated with the relevant Fund’s investment strategy are disclosed in the prospectus, offering memorandum or other materials of such Fund. Prospective investors should carefully read the relevant offering documents and consult with their own counsel and advisers as to all matters concerning an investment in such Fund. Certain Structural Risks Related to Portfolio Managers and Investment Vehicles None of the Adviser’s private investment funds or Investment Vehicles generally will be registered as investment companies under the ICA. Neither clients, investors nor a private investment fund (as an investor in these Investment Vehicles) will have the benefit of the protections afforded by the ICA to investors in registered investment companies. A Portfolio Manager may use proprietary investment strategies that are not fully disclosed to the Adviser, which may involve risks under some market conditions that are not anticipated by the Adviser. The performance of a private investment fund and other clients largely depends on the success of the Adviser in selecting Portfolio Managers for clients

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Type of Clients The Adviser primarily provides investment advisory services to both U.S. and non-U.S. clients, including: •

Charitable and/or religious organizations

•

Closed-end funds

•

Corporations

•

Defined contribution and defined benefit pension plans

•

Endowments and foundations

•

Financial Institutions

•

High Net Worth Individuals

•

Insurance companies

•

Investment companies (including mutual funds, closed-end funds and ETFs)

•

Pooled investment vehicles (private funds)

•

Sovereigns and central banks

•

State and local governments

•

Supranational organizations

•

Taft-Hartley plans

•

Trusts

The Adviser also provides investment advisory services to the Wealth Management division of JPMAWM and to J.P. Morgan Investment Management Inc. (“JPMIM”). Account Requirements The Adviser has established minimum account requirements for certain client accounts, which vary based on the investment vehicle (separate account or fund), investment strategy and asset class. In addition, a larger minimum account balance may be required for certain types of accounts that require extensive administrative effort. Minimums are subject to waiver in the Adviser's discretion and are waived for client accounts from time to time. To open or maintain an account, clients are required to sign an investment advisory agreement with JPMAAM that stipulates the terms under which JPMAAM is authorized to act on behalf of the client to manage the assets listed in the agreement. In certain instances, JPMAAM also manages the assets of its Affiliate’s clients and will receive from the Affiliate a portion of the fee or other compensation paid by the end client for such services. Under these circumstances, the client enters into an investment advisory agreement with the Affiliate and, in turn, the Affiliate appoints or delegates authority to JPMAAM. For private investment funds offered or managed by the Adviser, U.S. investors must generally satisfy certain investor sophistication requirements, including that the client qualifies as an “accredited investor” under Rule 501(a) of Regulation D under the Securities Act of 1933, as amended, a “qualified purchaser” within the meaning of section 2(a)(51) of the Investment Company Act of 1940, as amended (the “ICA”), and a “qualified eligible person” under Rule 4.7 of the Commodity Exchange Act.

ITEM 8 Methods of Analysis, Investment Strategies and Risk of Loss

A. Methods of Analysis and Investment Strategies The Adviser utilizes different methods of analysis that are tailored for each of the investment strategies it offers its clients. Set forth below are the primary methods of analysis and investment strategies that the Adviser utilizes in formulating investment advice or managing assets. This Item 8 includes a discussion of the primary risks associated with these investment strategies. However, it is impossible to identify all the risks associated with investing and the particular risks applicable to a client account will depend on the nature of the account, its investment strategy or strategies and the types of securities held. While the Adviser seeks to manage accounts so that risks are appropriate to the strategy, it is often impossible or not desirable to fully mitigate risks. Any investment includes the risk of loss, and there can be no guarantee that a particular level of return will be achieved. Clients should understand that they could lose some or all of their investment and should be prepared to bear the risk of such potential losses. Clients should carefully read all applicable informational materials and offering or governing documents prior to retaining the Adviser to manage an account or investing in any JPMorgan Affiliated Funds. See

Performance-Based Fees and Side-by-Side Management A. Performance-Based Fees Clients of JPMAAM pay various types of fees for investment advisory services. For example, Managed Account fees may be determined on a fixed rate, sliding scale or performance basis. Most client accounts are charged fees based on a percentage of assets under management. Certain accounts are charged an incentive or performancebased compensation together with an asset-based fee. Generally, performance-based compensation is calculated on the appreciation of a client’s assets or performance in excess of a specified benchmark or preferred return threshold. B. Side-by-Side Management and Potential Conflicts of Interest The Adviser simultaneously manages accounts that are charged performance-based fees and accounts that are charged asset-based fees. Frequently, the Adviser utilizes substantially similar investment strategies and invests in substantially similar assets for both account types. This portfolio management relationship is often referred to as “sideby-side management.” Accounts that pay performance-based fees reward the Adviser based on the performance in those accounts. As a result, performance-based fee arrangements likely provide a heightened incentive for the Adviser to make investments that present a greater potential for return but also a greater risk of loss and that may be more speculative than if only asset-based fees were applied. On the other hand, compared to a performance-based fee account, the Adviser will likely have an interest in engaging in relatively safer investments when managing accounts that pay asset-based fees. The side-by-side management of accounts that pay performance-based fees and accounts that only pay an asset-based fee creates a conflict of interest because there is

an inherent incentive for the Adviser to favor accounts with the potential to receive greater fees. For example, the Adviser will be faced with a conflict of interest when allocating scarce investment opportunities given the possibility of greater fees from accounts that pay performance-based fees as opposed to accounts that do not pay performance-based fees. Areas in which scarce investment opportunities may exist include investments in Investment Vehicles and direct or indirect investments in and co-investments alongside alternative investment funds. To address these types of conflicts, JPMAAM has adopted policies and procedures pursuant to which investment opportunities will be allocated among similarly situated clients in a manner that JPMAAM believes is fair and equitable. For a detailed discussion of how JPMAAM addresses allocation conflicts, please see Item 11.B: Conflicts Related to Allocation. For additional information regarding the Adviser’s review process please see Item 13.A.

A. Broker-Dealer Registration Status JPMAAM is not a registered broker-dealer; however, certain of JPMAAM’s management persons are registered with the U.S. Financial Industry Regulatory Authority (“FINRA”) as representatives of J.P. Morgan Institutional Investments Inc. (“JPMII”), an affiliated brokerdealer, if necessary, or appropriate to perform their responsibilities. B. Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor Registration Status JPMAAM is registered with the U.S. Commodity Futures Trading Commission (the “CFTC”) as a Commodity Trading Adviser (“CTA”) and Commodity Pool Operator (“CPO”). JPMAAM is also a member of the National Futures Association (the "NFA"). JPMAAM filed a notice of claim for exemption pursuant to CFTC Rule 4.7 in March 2015. Rule 4.7 exempts a CTA and a CPO that files a notice of claim for exemption from having to provide a CFTC-mandated Disclosure Document to certain highly accredited clients known as Qualified Eligible Persons (“QEPs”) who consent to their accounts being Rule 4.7-exempt QEP accounts. Accordingly, the Adviser is exempt from the requirement to provide a CFTC Disclosure Document with respect to its Rule 4.7-exempt QEP accounts. In addition, certain of JPMAAM’s management persons are registered with the NFA as "associated persons" of JPMAAM, if necessary or appropriate to perform their responsibilities. C. Related Persons The Adviser has certain relationships or arrangements with related persons that are material to its advisory business or its clients. Below is a description of such relationships and some of the conflicts of interest that arise from them. JPMC has adopted policies and procedures reasonably designed to appropriately prevent, limit or mitigate conflicts of interest that may arise between the Adviser and its Affiliates. These policies and procedures include information barriers designed to prevent the flow of information between the Adviser and certain other Affiliates, as more fully described below. For a more complete discussion of the conflicts of interest and corresponding controls designed to prevent, limit or mitigate conflicts of interest, please see Item 11.B - Participation or Interest in Client Transactions and Other Conflicts of Interest. Broker-Dealers

J.P. Morgan Institutional Investments Inc. (“JPMII”) JPMII, an Affiliate, serves as placement agent for certain private investment funds managed by the Adviser. Typically, JPMII does not receive any placement fees directly from a private Fund or its investors. A description of the placement agent services and compensation, if any, payable to JPMII by the private Funds is set forth in the offering documents for the relevant Fund. The Adviser benefits from the distribution and placement agency services provided by JPMII as it increases the assets upon which the Adviser’s fees are based. The Adviser also engages certain other non-U.S. Affiliates (either directly or through JPMII) to act as placement agents outside of the U.S. for certain private Funds managed by the Adviser. Typically, JPMII and such other Affiliates do not receive placement fees from such Funds but receive fees directly from the Adviser and/or from certain investors subscribing for interests in such Funds. J.P.Morgan Securities LLC (“JPMS”) JPMS, an Affiliate, is a FINRA member and is dually registered as a broker-dealer and an investment adviser with the SEC. JPMS is also registered as a Futures Commission Merchant (“FCM”) with the CFTC. JPMS also serves as a distributor of certain private Funds. Typically, JPMS does not receive placement fees from such Funds but receives fees directly from the Adviser and from certain investors subscribing for interests in such funds. These fees are typically in addition to the cost of the investors' subscription amounts. The Adviser may enter into placement or distribution agreements with certain other affiliated and non-affiliated entities. (Please see Section 7.B.(1) of Schedule D of Part 1A of JPMAAM’s Form ADV for a complete list.) JPMC, by virtue of its indirect interest in the Adviser, indirectly benefits from the services of placement agents when placement agents place interests which lead to an increase in assets upon which the Adviser receives fees from Funds. In addition, the potential for placement agents affiliated with JPMC, and for JPMC itself, to receive (directly or indirectly) compensation in connection with certain investors’ subscriptions for Funds creates a conflict of interest in recommending investments in such Funds. The remuneration relating to sales of interests in Funds managed by the Adviser from time to time will be greater than that of other products that placement agents might offer on behalf of JPMC. In such circumstances, the placement agents will have an incentive to recommend and offer interests in Funds managed by the Adviser to their clients. Investment Companies or Other Pooled Investment Vehicles

The Adviser is the investment adviser or sub-adviser for various JPMorgan Affiliated Funds (the Liquid Alts Funds), including Funds organized under the laws of other countries and jurisdictions. Please refer to Item 11.B - Participation or Interest in Client Transactions and Other Conflicts of Interest - Conflicts Relating to the Adviser's Recommendations or Allocations of Client Assets to JPMorgan Affiliated Funds for a more complete discussion regarding conflicts of interest. Other Investment Advisers, Commodity Pool Operators, and Commodity Trading Advisors The Adviser has relationships that are material to its investment management business with the following affiliated investment advisers that are registered with the SEC: J.P. Morgan Investment Management Inc. and JPMorgan Asset Management (UK) Limited. J.P. Morgan Investment Management Inc. is also registered as a Commodity Pool Operator and Commodity Trading Advisor with the CFTC. JP Morgan Asset Management (UK) Limited is an SEC registered investment adviser and an Exempt Commodity Trading Adviser with the CFTC. Security Capital Research & Management Incorporated, also an SEC registered affiliated investment adviser, has a sub-advisory relationship with the Adviser for the AISS Funds. The relationship with such entities and other Affiliates that are not registered as investment advisers with the SEC is described below. The Adviser serves as adviser or sub-adviser for various client accounts and funds managed by its Affiliates. The Adviser provides investment advisory services to JPMC and certain foreign Affiliates under the wealth management and solutions division of J.P. Morgan Asset & Wealth Management umbrella. The Adviser also serves as adviser or sub-adviser for various client accounts managed by JPMIM and J.P. Morgan (Suisse) S.A. In this regard, JPMAAM may recommend investments in Investment Vehicles in which an Affiliate or Affiliates have a position or interest. In addition, clients may invest in certain intermediary vehicles sponsored by JPMAAM or Affiliates. In addition, as described above, the Adviser serves as sub-adviser to Liquid Alts Funds organized as UCITS by its Affiliate JPMorgan Asset Management (Europe) S.à r.l. J.P. Morgan SE serves as depositary for the UCITS.

Conversely, with respect to certain client accounts and funds, the Adviser delegates some or all of its responsibilities as adviser to other affiliated advisers as described below. This creates conflicts of interest related to the Adviser’s determination to use, suggest, or recommend the services of such entities because the Adviser and/or its Affiliates may benefit from increased allocations to their businesses. The particular services involved will depend on the types of services offered by the relevant Affiliate. Please refer to Item 11.B – Participation or Interest in Client Transactions and Other Conflicts of InterestConflicts Relating to the Adviser’s Recommendation of Client Assets to JPMorgan Affiliated Funds and Sub-Advisory Relationships for a more complete discussion regarding conflicts of interest. The Adviser either may compensate other affiliated advisers out of the advisory fees it receives from the relevant client account or the relevant client may compensate each adviser directly. Please refer to the respective client’s offering documents or investment management agreement, as applicable, for a complete discussion of fees and expenses. The Adviser delegates a portion (but may delegate more in the future) of its responsibilities as adviser or sub-adviser to the Foreign Funds to Affiliates. Additionally, as described in Item 4, to a limited extent, the Adviser may recommend Direct Investments for portfolio hedging and to temporarily adjust a Fund’s or managed account’s overall market exposure. The Adviser also intends to route orders for such Direct Investments or to the extent applicable, certain direct trading for client accounts through JPMIM for execution. The Adviser also delegates a portion of its responsibility as adviser or sub-adviser in relation to currency hedging for certain client accounts to its advisory affiliate JPMorgan Asset Management (UK) Limited. Banking or Thrift Institution JPMorgan Chase & Co., the Adviser’s parent company is a public company that is a bank holding company registered with the Federal Reserve (the “Federal Reserve”). JPMorgan Chase & Co. is subject to supervision and regulation by the Federal Reserve and is subject to certain restrictions imposed by the BHCA and related regulations. For a more complete discussion of the BHCA's restrictions that may apply to the Adviser’s activities please see the disclosure describing Regulatory Risk within Item 8.B. JPMorgan Chase Bank, N.A. (“JPMCB”) is a national banking association affiliated with the Adviser. JPMCB is subject to supervision and regulation by the U.S. Department of Treasury's Office of the Comptroller of the Currency. JPMCB is also an Exempt

Commodity Pool Operator and Exempt Commodity Trading Adviser with the CFTC. JPMCB provides investment management, trustee, custody, and other services to institutional clients. Certain functions, such as human resources, legal, compliance, IT, and risk management, are provided through JPMAM and/or JPMC as shared functions across all of its geographical entities. Sponsor or Syndicator of Limited Partnerships From time to time, the Adviser or its related persons act as a special limited partner of a limited partnership or may act as a general partner of a limited partnership or managing member or special member of a limited liability company to which the Adviser serves as an adviser, sub-adviser or provides other services. The Adviser and related persons may solicit the Adviser’s clients to invest in such limited partnerships or limited liability companies, for which the Adviser or a related person may receive compensation. Related persons of the Adviser may serve as a director of a U.S. or non-U.S. pooled investment vehicle or other corporate entity for which the Adviser may solicit clients to invest. For a list of private Funds, please refer to Section 7.B of Schedule D in Form ADV Part 1A. Pricing and Trading Platforms PricingDirect Inc. ("PricingDirect") is an approved pricing vendor and an Affiliate of the Adviser. PricingDirect is used as a primary pricing source for emerging market debt securities or secondary pricing source for certain OTC derivatives and fixed income securities. PricingDirect has an evaluation methodology for certain fixed income securities and OTC derivatives that is widely relied upon within the financial services industry. Valuations received by the Adviser from PricingDirect are the same as those provided to other affiliated and unaffiliated entities. The Adviser or Affiliates utilize established controls to oversee all pricing services, including those provided by affiliated and unaffiliated entities. Controls include ongoing and routine due diligence reviews of prices received from affiliated and unaffiliated sources. Considerations Relating to Information Held by the Adviser and Its Affiliates

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Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics and Personal Trading JPMAAM and its registered investment adviser Affiliates have adopted the JPMAM Code of Ethics (the “Code of Ethics”) pursuant to Rule 204A-1 under the Advisers Act. The Code of Ethics is designed to ensure that JPMAAM employees comply with applicable federal securities laws and place the interests of its clients before their own personal interests at all times. The Code of Ethics imposes certain restrictions on securities transactions in the personal accounts of covered persons to help avoid or mitigate conflicts of interest, as described more fully below. A copy of the Code of Ethics is available free of charge to any client upon request by contacting your client service representative or financial adviser. The Code of Ethics contains policies and procedures relating to:

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Account holding reports, personal trading, including reporting and pre-clearance requirements for all employees of the Adviser;

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Confidentiality obligations to clients set forth in the JPMC privacy notices;

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Employee conflicts of interest, which includes guidance relating to restrictions on trading on MNPI, gifts and business hospitality, political and charitable contributions and outside interests; and

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Escalation guidelines for reporting Code of Ethics violations.

In general, the personal trading rules under the Code of Ethics require that accounts of employees and associated persons be maintained with an approved broker and that all trades in reportable securities for such accounts be pre-cleared and monitored by compliance personnel. The Code of Ethics also prohibits certain types of trading activity, such as short-term and speculative trades. Employees of the Adviser must obtain approval prior to engaging in all covered security transactions, including those issued in private placements. In addition, certain employees of the Adviser are not permitted to buy or sell securities issued by JPMC during certain periods throughout the year. Certain “Access Persons” (defined as persons with access to non-public information regarding the Adviser’s recommendations to clients, purchases, or sales of securities for client accounts and advised funds) are prohibited from executing personal trades in a security or similar instrument five business days before and after a client or fund managed by that Access Person transacts in that security or similar instrument. In addition, Access Persons are required to disclose household members, personal security transactions and holdings information. These disclosure obligations and restrictions are designed to mitigate conflicts of interest that may arise if Access Persons transact in the same securities as advisory clients. Additionally, all JPMAAM employees are subject to the JPMC firm-wide policies and procedures including those found in the JPMC Code of Conduct (the “Code of Conduct”). The Code of Conduct sets forth restrictions regarding confidential and proprietary information, information barriers, private investments, outside interests and personal trading. All JPMC employees, including JPMAAM employees, are required to familiarize themselves, comply, and attest annually to their compliance with provisions of the Code of Conduct’s terms as a condition of continued employment. B. Participation or Interest in Client Transactions and Other Conflicts of Interest JPMC Acting in Multiple Commercial Capacities

JPMC is a diversified financial services firm that provides a broad range of services and products to its clients and is a major participant in the global currency, equity, commodity, fixed-income and other markets in which the Adviser's client accounts, directly or through Investment Vehicles, invest or may invest. JPMC is typically entitled to compensation in connection with these activities and the Adviser's clients will not be entitled to any such compensation. In providing services and products to clients other than the Adviser’s clients, JPMC, from time to time, faces conflicts of interest with respect to activities recommended to or performed for the Adviser's client on one hand and for JPMC’s other clients on the other hand. For example, JPMC has, and continues to seek to develop banking and other financial and advisory relationships with numerous U.S. and non-U.S. persons and governments. JPMC also advises and represents potential buyers and sellers of businesses worldwide. The Adviser’s client accounts have directly or through Investment Vehicles, invested in, or may wish to invest in, such entities represented by JPMC or with which JPMC has a banking, advisory or other financial relationship. In addition, certain clients of JPMC, including the Adviser's clients, directly or through Investment Vehicles may invest in entities in which JPMC holds an interest, including a JPMorgan Affiliated Fund. In providing services to its clients and as a participant in global markets, JPMC from time to time recommends or engages in activities that compete with or otherwise adversely affect an Adviser’s client account or its investments. It should be recognized that such relationships can preclude the Adviser's clients or Investment Vehicles from engaging in certain transactions and can also restrict investment opportunities that may be otherwise available to the Adviser's clients or to Investment Vehicles in which such clients invest. For example, JPMC is often engaged by companies as a financial adviser, or to provide financing or other services, in connection with commercial transactions that are potential investment opportunities for the Adviser's clients or the Investment Vehicles in which such clients may invest. There are circumstances in which advisory accounts are precluded from participating in such transactions as a result of JPMC’s engagement by such companies. JPMC reserves the right to act for these companies in such circumstances, notwithstanding the potential adverse effect on the Adviser's clients. In addition, JPMC derives ancillary benefits from providing investment advisory, custody, administration, prime brokerage, transfer agency, treasury oversight services, fund accounting and shareholder servicing and other services to the Adviser's clients and/or the Investment Vehicles in which such clients invest. For example, allocating client assets to an unaffiliated Portfolio Manager may help JPMorgan or the Adviser enhance its relationships with the unaffiliated Portfolio Manager or its affiliates, facilitate additional business development and enable JPMorgan or the Adviser to obtain additional business and generate additional revenue. For example, allocating a client account’s or a certain JPMorgan Affiliated Fund's assets to a third-party private

investment fund or product enhances JPMC’s relationship with such third-party investment fund or product and their affiliates and could facilitate additional business development or enable JPMC or the Adviser to obtain additional business and generate additional revenue. The following are descriptions of certain additional conflicts of interest and potential conflicts of interest that may be associated with the financial or other interests that the Adviser and JPMC may have in transactions effected by, with, or on behalf of its clients. In addition to the specific mitigants described further below, JPMAM and the Adviser has adopted policies and procedures reasonably designed to appropriately prevent, limit or mitigate conflicts of interest. In addition, many of the activities that create these conflicts of interest are limited and/or prohibited by law, unless an exception is available. JPMC Service Providers and Its Relationships with Issuers of Debt or Equity Instruments in Client Portfolios JPMC or the Adviser’s related persons provide financing, consulting, investment banking, management, custodial, transfer agency, shareholder servicing, treasury oversight, administration, distribution, underwriting, including participating in underwriting syndicates, brokerage (including prime brokerage) or other services to, and receive customary compensation from, an issuer of equity or debt securities held by client accounts or JPMorgan Affiliated Funds managed by the Adviser or the portfolio companies in which such accounts or funds invest. These relationships generate revenue to JPMC and could influence the Adviser in deciding whether to select or recommend such investment funds, products or companies for investments by client accounts or JPMorgan Affiliated Funds, in deciding how to manage such investments, and in deciding when to realize such investments. For example, JPMC earns compensation from private investment funds or their sponsors or investment products for providing certain services. The Adviser has an incentive to favor such funds or products over other funds or products with which JPMC has no relationship when investing on behalf of, or recommending investments to, client accounts or JPMorgan Affiliated Funds because such investments potentially increase JPMC’s overall revenue. In providing these services, JPMC could also act in a manner that is detrimental to a client account or JPMorgan Affiliated Fund, such as when JPMC is providing financing services and it determines to close a line of credit to, to not extend credit to, or to foreclose on the assets of, an investment vehicle or a portfolio company in which a client account or JPMorgan Affiliated Fund invests, or when JPMC advises a client and such advice is adverse to a client account or JPMorgan Affiliated Fund. Any fees or other compensation received by JPMC in connection with such activities will not be shared with the Adviser’s clients. Such compensation could include financial advisory fees, monitoring fees, adviser fees or fees in connection with restructurings or mergers and acquisitions, as well as underwriting or placement fees, financing or commitment fees, trustee fees and brokerage fees.

Client Participation in Offerings where JPMC acts as Underwriter or Placement Agent When permitted by a client’s investment guidelines, objectives, restrictions, conditions, limitations, directions and cash needs, and subject to compliance with applicable law, regulations and exemptions, the Adviser from time to time purchases securities for client accounts during an underwriting or other offering of such securities in which a brokerdealer Affiliate of the Adviser acts as a manager, co-manager, underwriter or placement agent. The Adviser’s Affiliate typically receives a benefit in the form of management, underwriting or other fees. When a JPMC broker-dealer serves as underwriter in connection with an initial or secondary public offering of securities held in client accounts or certain JPMorgan Affiliated Funds managed by the Adviser, JPMC typically requires certain equity holders, including such client account or such JPMorgan Affiliated Fund, to be subject to a lockup period following the offering during which time such equity holders’ ability to sell any securities is restricted. In addition, JPMC internal policies or identified actual or potential conflicts arising from the role of such broker-dealer Affiliate could preclude a client account or a JPMorgan Affiliated Fund from selling into such an offering. These factors could restrict the Adviser’s ability to dispose of such securities at an opportune time and thereby adversely affect the relevant account or JPMorgan Affiliated Fund and its performance. Affiliates of the Adviser also act in other capacities in such offerings and such Affiliates will receive fees, compensation, or other benefit for such services. The commercial relationships and activities of the Adviser’s Affiliate may at times indirectly preclude the Adviser or an Investment Vehicle from engaging in certain transactions on behalf of its clients and constrain the investment flexibility of client portfolios or Investment Vehicles in which such clients invest. Client Participation in Structured Fixed Income Offerings in which an Affiliate is a Service Provider In addition subject to applicable law, the Adviser expects that clients will, directly or through its investment in an Investment Vehicle participate in structured fixed income offerings of securities in which an Affiliate acting on behalf of an issuer serves as trustee, depositor, originator, service agent or other service provider, and receives fees for such service. For example, from time to time, JPMC acts as the originator or agent of loans or receivables for the structured fixed income offerings in which an Investment Vehicle may invest. In transactions where the Affiliate has agreed to hold or acquire unsold securities in an offering, direct or indirect participations by clients will relieve the Affiliate of such obligation.

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Brokerage Practices A. Factors Considered in Selecting or Recommending Broker-Dealers for Client Transactions In general, JPMAAM’s investment management agreements with the Funds and other clients with respect to which it acts as manager, adviser or sub-adviser may give JPMAAM the authority to open brokerage accounts in the name of the Funds or other clients (in the case of certain Funds, subject to the approval of the board of directors of the relevant Fund). However, since JPMAAM is primarily in the business of selecting Investment Vehicles, the Portfolio Managers, rather than JPMAAM, generally select the brokers and arrange for the execution of transactions. JPMAAM may consider the broker selection process employed by a Portfolio Manager as a factor in determining whether to invest in that Investment Vehicle. However, on occasion, JPMAAM may be responsible for selecting a broker to execute transactions. On such occasions, JPMAAM will seek best price and execution on a competitive basis for both purchases and sales of securities as well as considering the broker's execution capabilities and the commissions charged. In selecting a broker,

JPMAAM’s primary objective is to be consistent with its fiduciary duty to its clients. Because JPMAAM generally relies on its own research, the value of any research provided by brokers is not typically a factor in selecting a broker. As such JPMAAM does not presently utilize any “soft dollar” benefits or programs. JPMAAM may pay a broker a commission in excess of that which another broker might have charged for effecting the same transaction, in recognition of the value of the brokerage services provided by the broker. Since commission rates in the United States and in many other jurisdictions are negotiable, selecting brokers on the basis of considerations which are not limited to applicable commission rates may at times result in higher transaction costs than would otherwise be attainable. As indicated in Section 10C., the Adviser intends to route orders for certain Direct Investments through an Affiliate to brokers and counterparties for execution. Any fees payable to such Affiliate in relation to the service it provides to a Fund will be paid by the Adviser. To the extent that the Adviser (or an affiliate on its behalf) utilizes brokerage services, including, without limitation, in connection with any foreign exchange trading or Direct Investments made by a Fund, the Adviser or its Affiliate, as the case may be, will adopt practices substantially as described above. To the extent permitted by applicable law, the Adviser (or an Affiliate on its behalf) may effect transactions on behalf of a Fund with affiliated brokers and such affiliates may receive fees or commissions in connection with such transactions so long as any such payments by the Fund are on terms at least as favorable to the Fund as terms generally available in arm’s-length transactions with independent third parties. Account Errors and Resolutions Account errors, trade errors, and other operational risk events occasionally occur in connection with the Adviser’s management of funds and client accounts. The Adviser has developed policies and procedures that address the identification and correction of errors and generally require that errors caused by the Adviser and affecting a client's account be resolved promptly and fairly subject to the considerations set forth below. Errors can result from a variety of situations, including portfolio management (e.g., violation of investment restrictions), trading, processing or other functions (e.g., miscommunication of information, such as wrong number of shares, wrong price, wrong account, raising the order as a buy rather than a sell and vice versa, etc.). Determining whether an operational risk event is an error is done on a case-by-case basis and highly dependent on the unique facts and circumstances.

The intent of the policies and procedures is to restore a client account to the appropriate financial position as determined in good faith by the Adviser based on what it considers reasonable in light of all relevant facts and circumstances surrounding the error. The Adviser makes its determinations pursuant to its error policies and procedures on a caseby-case basis, in its discretion, based on factors it considers reasonable. Relevant facts and circumstances the Adviser may consider include, among others, the nature of the service being provided at the time of the incident, whether intervening causes, including the action or inaction of third parties, caused or contributed to the incident, specific applicable contractual and legal restrictions and standards of care, whether a client’s investment objective was contravened, the nature of a client’s investment program, whether a contractual guideline was violated, the nature and materiality of the relevant circumstances, and the materiality of any resulting losses. The determination by the Adviser to treat (or not to treat) an incident as an error, and any calculation of compensation in respect thereof for any one client account may differ from the determination and calculation made by the Adviser in respect of one or more other accounts. Additional information about the resolution of and compensation for errors is available upon request. Consistent with the applicable standard of care, the Adviser’s policies and procedures and client agreements generally do not require perfect implementation of investment management decisions, trading, processing or other functions performed by the Adviser. Operational risk events such as imperfections in the implementation of investment decisions, cash movements, portfolio rebalancing, processing instructions or facilitation of redemptions and subscriptions, settlement, imperfection in processing corporate actions, or imperfection in the generation of cash or holdings reports resulting in trade decisions may not constitute compensable errors, depending on the materiality and other facts and circumstances. For example, the Adviser’s investment professionals are typically expected to exercise discretion to generally effect the portfolio management team’s investment intent in the best interests of the client including, without limitation, with respect to the execution of trade requests or the implementation of quantitative strategies or methods (as applicable). Regardless of whether the portfolio management team specifies a fixed quantity of a particular security or Investment Vehicle to be purchased or sold, or provides a date by which a trade is to be completed, instances in which an investment professional executes a trade that results in a portfolio position that is different from the exposure intended by the portfolio management team (whether specified or not) may not be considered errors unless the trade or transaction results in a portfolio position that violates investment guidelines of the client or is substantially inconsistent with the portfolio management

team’s investment intent. Similarly, imperfections in the implementation of investment strategies that do not result in material departures from the intent of the portfolio management team may not be considered errors. In managing accounts, the Adviser may make allocation changes to accounts participating in a trade made post execution on T+1 or pre-settlement and making such allocation changes will not be considered an error. With respect to an account’s investment guidelines, an account drifting out of compliance due to market conditions or cash flows, is generally not considered an error by the Adviser. In addition, in managing accounts, the Adviser may establish non-public, formal or informal internal targets, or other parameters that may be used to manage risk, manage sub-advisers or otherwise guide decision-making, and a failure to adhere to such internal parameters will not be considered an error. Finally, delays in the performance of a process, may not be considered errors depending on the surrounding facts and circumstances. A failure on the Adviser’s part to recognize a client cash flow will generally not be considered an error unless the Adviser fails to recognize the cash flow within a reasonable period of time from the delivery date specified in the client’s notification to the Adviser. The purchase of a security for which the client is ineligible under the issuer’s prospectus, offering documents or other issuer-related rules or documentation generally will not be considered an error to the extent that the purchase does not also violate a client guideline, regardless of whether the Adviser maintains or exits the position after becoming aware of the ineligibility. Operational risk events may also occur in connection with other activities that may be undertaken by the Adviser and its affiliates, such as net asset value calculation, transfer agent activities (i.e., processing subscriptions and redemptions), fund accounting, trade recording and settlement and other matters that are non-advisory in nature and may not be compensable unless they deviate from the applicable standards of care. Incidents resulting from the actions of third parties, including agents of the Adviser and its affiliates, are generally not compensable from the Adviser to a client. When the Adviser determines that compensation by the Adviser is appropriate, the client will be compensated as determined in good faith by the Adviser. The Adviser will determine the amount to be reimbursed, if any, based on what it considers reasonable guidelines regarding these matters in light of all of the facts and circumstances related to the error. Generally, losses are reimbursed to the client, and gains accrue to the benefit of the client. In calculating any reimbursement amount, the Adviser generally does not consider tax implications for, or the tax status of, any affected client. The Adviser expects that in certain situations, subject to its discretion, losses will be netted with an account’s gains arising from a single incident or incidents stemming from the same root cause. Furthermore, the Adviser expects to follow a materiality policy with respect to client

accounts. Therefore, in certain circumstances, operational risk events that result in losses below a threshold will not be compensable. In general it is the Adviser’s policy to notify clients of incidents corrected post-settlement that violate a client guideline and certain errors that result in a loss to the client. Generally, the Adviser will not notify clients of non-compensable operational risk events. Investors in a pooled investment vehicle will generally not be notified of the occurrence of an incident or the resolution thereof. Additional information about resolution of and compensation for incidents is available upon request and may be set forth in the prospectuses or other relevant offering documents of Adviser-managed pooled investment vehicles. The Adviser may at any time, in its sole discretion and without notice to investors, amend or supplement its policies with respect to account errors and error resolution.

B. Order Aggregation Not Applicable - JPMAAM does not aggregate trades.

Client Referrals and Other Compensation A. Economic Benefits Received from Third-Parties for Providing Services to Clients The Adviser does not receive economic benefits from someone who is not a client for providing investment advisory services to its clients. As discussed in Item 11B., however, the Adviser derives ancillary benefits from providing investment advisory services to clients. For example, allocating client assets to an unaffiliated investment adviser or Portfolio Manager may help the Adviser or its Affiliates enhance their relationships with the unaffiliated investment adviser or its affiliates, facilitate additional business development and enable the Adviser and its Affiliates to obtain additional business and generate additional revenue. Please see Item 11B. Participation or Interest in Client Transactions and Other Conflicts of Interest - JPMC Acting in Multiple Commercial Capacities. The Code of Ethics, the Code of Conduct and other related policies and procedures adopted by the Adviser restrict the receipt of personal benefits by employees of the Adviser or its Affiliates in connection with the Adviser's business. For more information, please see Item 11A. Code of Ethics and Personal Trading. B. Compensation to Non-Supervised Persons for Client Referrals

March 31, 2022

The Adviser directly or indirectly compensates affiliated and unaffiliated agents for client or investor referrals in accordance with applicable laws, including Rule 206(4)-1 under the Advisers Act, if and when applicable. The compensation generally consists of a cash payment, computed as a percentage of the Adviser's fees. Such compensation is paid entirely out of amounts payable to the Adviser and therefore, does not result in any additional charges to the clients.

Disciplinary Information A. Criminal or Civil Proceedings The Adviser has no material civil or criminal actions to report. B. Administrative Proceedings Before Regulatory Authorities JPMAAM has no material administrative proceedings before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority to report. C. Self-Regulatory Organization (“SRO”) Proceedings The Adviser has no material SRO disciplinary proceedings to report.

Review of Accounts A. Frequency and Nature of Review of Client Accounts or Financial Plans Accounts are periodically reviewed by members of the Adviser’s investment committee. Accounts are reviewed based on the guidelines of each account to ensure there is compliance with those guidelines. In addition, the allocations of portfolios will be reviewed and discussed to contemplate proposed portfolio changes based on strategy views and manager convictions. In addition, the Portfolio Managers are periodically reviewed for, among other things, management stability, asset growth and/or shrinkage, style drift, employee turnover and changes in strategy, approach, or administrative procedures. B. Factors Prompting Review of Client Accounts Other than a Periodic Review In addition to periodic reviews, JPMAAM may perform reviews as it deems appropriate or otherwise required. Additional reviews of client accounts may be triggered by client request, compliance monitoring, industry factors, market developments, statutory or

regulatory changes and any issues that may have been identified with respect to a client account. C. Content and Frequency of Account Reports to Clients The administrator for each Fund provides each investor in the Fund with a monthly statement showing the Fund’s performance. Additionally, JPMAAM provides a monthly unaudited performance update to investors. JPMAAM also prepares monthly reports that generally highlight a Fund’s performance, investment strategy and the impact of major positions on a Fund's return. Audited financials are provided annually to Fund investors. Reports on customized portfolios are provided to Managed Account clients as agreed with each such client.

Custody JPMAAM generally does not maintain physical custody of its clients’ assets. Client assets are typically held by a qualified custodian pursuant to a separate custody agreement. However, pursuant to Rule 206(4)-2 under the Advisers Act, in certain circumstances the Adviser may be deemed to have custody of client assets. JPMAAM is deemed to have custody of client assets in the following circumstances: •

When JPMAAM or a related person acts in any capacity that gives it legal ownership of, or access to, client assets, (e.g., when JPMAAM serves as a general partner, managing member, or comparable position for certain private Funds.) Investors in private Funds will receive such Funds’ annual audited financial statements. Such investors should review these statements carefully. If investors in the private Funds do not receive audited financial statements in a timely manner, they should contact JPMAAM immediately.

•

When, with respect to certain separately managed accounts, JPMAAM or a related person directly or indirectly holds client funds or securities or has authority to obtain possession of them. Clients will receive account statements at least quarterly directly from their brokerdealer, bank or other qualified custodian. Separately managed account clients may also receive a statement of assets from JPMAAM. Clients are encouraged to compare the account statements that they receive from their qualified custodian with those they receive from JPMAAM.

File No. 801-38319 March 31, 2022

Investment Discretion As described in Item 4B., the Adviser provides both discretionary and non-discretionary investment management services. For discretionary mandates, the Adviser and client execute an investment advisory agreement authorizing the Adviser to act on behalf of the account. Execution of such agreement authorizes the Adviser to supervise and direct the investment and reinvestment of assets in the client’s account on the client’s behalf and at the client’s risk. The Adviser’s discretionary authority may be limited by the terms of its written agreement with each client. These limitations might include objective and investment guidelines that the client establishes for the account. For registered investment companies, the Adviser’s investment discretion may be limited by certain federal securities laws and tax laws that require diversification of investments and impose other limitations. For an additional discussion of risks related to the Adviser’s discretionary authority, please refer to Item 6.

Voting Client Securities A. Policies and Procedures Relating to Voting Client Securities Objective If the Adviser has been appointed as an investment manager, the client may give the Adviser the authority to vote the proxies of the securities held in the client’s portfolio. As a fiduciary, the Adviser must act in the best interest of the client with respect to proxy voting activities. To ensure that the proxies are voted in the best interests of its clients and to prevent material conflicts of interest, as described in Item 11, from affecting the manner in which proxies are voted, JPMAAM has adopted a Proxy Voting Policy (the

"Proxy Voting Policy") within the Adviser Compliance Program and detailed written proxy voting procedures (“Procedures”) pursuant to Rule 206(4)-6 of the Advisers Act. These Procedures apply to consents and other solicitations that may be made by various Investment Vehicles and other “alternative investments” in which JPMAAM’s clients may be invested. Because solicited votes with respect to alternative investments most often raise unique questions, such solicitations will generally be analyzed and voted by JPMAAM on a case-by-case basis. Where consent or other solicited vote or a proxy relates to a routine matter, JPMAAM will generally vote in accordance with specific guidelines developed with the objective of encouraging action that enhances investor value. The Procedures also require JPMAAM to identify and address conflicts of interest between JPMAAM and its clients. If a material conflict of interest exists, JPMAAM will determine whether any additional steps must be taken to ensure that the proxies are voted, and that the consents and other solicitations are acted on, in the best interests of its clients. In regards to any registered investment company JPMAAM may manage, please see the Prospectus and Statement of Additional Information for that registered product for information on voting client securities. Clients may obtain a copy of JPMAAM’s Procedures and information about how JPMAAM voted a client’s proxies by contacting the Investment Specialists’ Team by telephone at (212) 648-1728. B. No Authority to Vote Client Securities and Client Receipt of Proxies If a client chooses not to delegate proxy voting authority to the Adviser, the right to vote proxies is retained by the client or other designated person. In such situations, the client will generally receive proxies or other solicitations directly from the custodian or transfer agent. Clients may contact the Adviser if they have a question on a particular proxy voting matter or solicitation; however, the Adviser will not recommend how to vote where the Adviser lacks authority to do so.

Financial Information A. Balance Sheet Pursuant to SEC instructions, the Adviser is not required to include its balance sheet as part of this Brochure. B. Financial Conditions Likely to Impair Ability to Meet Contractual Commitments to Clients The Adviser is not subject to any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. C. Bankruptcy Filings The Adviser has not been the subject of a bankruptcy petition at any time during the past ten years.

Access Persons

Adviser

Advisers Act

Key Terms means persons with access to non-public information regarding the Adviser's recommendations to clients, purchases, or sales of securities for client accounts and advised funds. means J.P. Morgan Alternative Asset Management, Inc., which is a U.S. investment advisory branch of J.P. Morgan Asset Management. means the Investment Advisers Act of 1940, as amended.

Affiliate

means, with respect to any Person, any other Person that, directly or indirectly, controls, is under common control with, or is controlled by that Person. For purposes of this definition, “control” (including the terms “controlled by” and “under common control with”), as used with respect to any Person, means the possession, directly or indirectly, of the power to direct and cause the direction of the management and policies of such Person, whether through the ownership of voting securities, by contract, or otherwise.

AIFMD

means the European Commission Directive on Alternative Investment Fund Managers.

AM

means the Asset Management business of JPMAWM

BHCA Brochure CFTC

Code of Conduct

means the Bank Holding Company Act of 1956. means JPMAAM’s Form ADV, Part 2A. means the U.S. Commodity Futures Trading Commission means the JPMC firm-wide policies and procedures that sets forth restrictions regarding confidential and proprietary information, information barriers, private investments. outside business activities and personal trading.

Code of Ethics

CPO CTA

Direct Investments

means JPMAM Code of the Ethics, which is designed to ensure that JPMAAM employees comply with applicable federal securities laws and place the interests of clients first in conducting personal securities transactions. means Commodity Pool Operator. means Commodity Trading Advisor. means JPMAAM on behalf of certain Funds and Managed Accounts may make, or, with respect to its non-discretionary clients, may recommend direct investments in a broad range of securities, markets and instruments other than through Investment Vehicles, including without limitation, for portfolio hedging and to temporarily adjust a Fund’s or Managed Account’s overall market exposure.

Dodd-Frank

ERISA

FCM

Exchange Act

FINRA

Fund

ICA

IHS Markit

Investment Vehicle IRS

means the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, as amended. means the U.S. Employee Retirement Income Security Act of 1974, as amended. means Futures Commission Merchant. means the U.S. Securities Exchange Act of 1934, as amended. means the U.S. Financial Industry Regulatory Authority. means various domestic and foreign private pooled investment vehicles as well as a UCITS fund and registered investment company managed by the Adviser means the Investment Company Act of 1940, as amended. IHS Markit Ltd., formerly, Markit Group Ltd., an approved pricing vendor and an Affiliate of the Adviser. means professionally selected investment vehicles that are managed by Portfolio Managers means the U.S. Internal Revenue Service means J.P. Morgan Alternative Asset Management, Inc. or the Adviser means JPMorgan Asset Management, which is the marketing name for the investment management businesses of JPMorgan Chase & Co. means JPMorgan Chase & Co., a publicly traded company, and its Affiliates worldwide. means JPMorgan Chase Bank, N.A. means J.P. Morgan Institutional Investments Inc., an affiliated broker-dealer of JPMAAM used to facilitate the distribution of certain pooled investment funds. means J.P. Morgan Investment Management Inc., which is the primary U.S. investment advisory branch of JPMorgan Asset Management.

JPMAAM

JPMAM

JPMC

JPMCB

JPMII

JPMIM

JPMC Seed Capital

means when the Adviser or related persons provide initial funding necessary to establish a new fund.

JPMorgan Affiliated Funds

means mutual funds and other pooled investment vehicles managed by JPMAAM and its Affiliates.

JPMorgan Funds JPMS

means mutual funds or ETFs advised by JPMAAM or its affiliates. means J.P. Morgan Securities LLC.

Liquid Alts Funds

Managed Account

MNPI OTC

Person

Portfolio Manager

PricingDirect

Procedures

Proxy Voting Policy

means the detailed written proxy voting policy adopted by JPMAAM pursuant to Rule 206(4)-6 of the Advisers Act.

QEPs

means certain highly accredited clients who participate in commodity pools or open managed accounts known as Qualified Eligible Participants. The categories of persons who qualify as QEPs are listed in CFTC Regulation 4.7(a).

SEC

means the U.S. Securities and Exchange Commission.

Section 16 SRO

Volcker Rule

means Section 16 of the Securities Exchange Act of 1934. means self-regulatory organization. refers to § 619 (12 U.S.C. § 1851) of the Dodd–Frank Wall Street Reform and Consumer Protection Act.

means U.S. or foreign registered funds (including UCITS) advised or sub-advised by the Adviser. means certain separately managed accounts for institutional clients including other investment advisers and financial institutions. means material non-public information. means over-the-counter. means, with respect to any Person, any other Person that, directly or indirectly, controls, is under common control with, or is controlled by that Person. For purposes of this definition, “control” (including, with correlative meaning, the terms “controlled by” and “under common control with”), as used with respect to any Person, shall mean the possession, directly or indirectly, of the power to direct and cause the direction of the management and policies of such Person, whether through the ownership of voting securities, by contract, or otherwise. means portfolio managers which are selected by JPMAAM through a due diligence process and to which client assets are allocated. means PricingDirect Inc., an approved pricing vendor and an Affiliate of the Adviser. means the detailed written proxy voting procedures adopted by JPMAAM pursuant to Rule 206(4)-6 of the Advisers Act.