JW Asset Management, LLC

JW Asset Management, LLC (“JW Asset” or the “Investment Manager”), a Delaware limited liability company, was founded in November 2003 and provides discretionary investment management services to certain private funds as discussed below. Jason Wild owns a 99% interest in JW Asset, with Tamar Katzburg Wild, his spouse, controlling the remaining 1%. Mr. Wild is the managing member of the Investment Manager and is responsible for all the securities selections on behalf of the Investment Manager. Mr. Wild is the president and managing member of each of JW Asset and JW GP, LLC (“JW GP” or the “General Partner”). JW Asset serves as the investment manager for JW Growth Fund, LLC, JW Opportunities Fund, LLC, and JW Partners, LP, (each a “Fund” and collectively, the “Funds”). JW Asset also provides investment management services to Insight Wellness Fund, LLC, which is managed by an unaffiliated managing member (not JW GP) and, except as noted or as the context otherwise requires, is also deemed a “Fund” for purposes of this brochure. Mr. Wild is responsible for all of the Funds’ investment decisions on behalf of JW Asset. Mr. Wild has over 25 years of experience as a portfolio manager and a fund manager. Over the course of his career he has focused on the healthcare industry including specialty pharmaceuticals, generic drugs, and cannabis. He is the executive chairman of TerrAscend Corp. (“TerrAscend”) and serves as a member of the board of Vitruvias Therapeutics, Inc. (“Vitruvias”), Allumia, Inc. (“Allumia”) and Tyson 2.0 Inc. (“Tyson”). Prior to the launch of JW Partners, LP in 1998, Mr. Wild was a practicing pharmacist. He graduated from Long Island University in 1996 with a Bachelor of Science in Pharmacy. Please see Item 8 herein for a brief discussion of JW Asset’s investment strategies (collectively, the “Strategies”). The Strategies generally focus on healthcare, consumer and retail sectors and are tailored to each specific Fund. Important information regarding an investment in a Fund, including the specific investment strategies and policies, fees and expenses, risk factors and other material terms, are set forth in each Fund’s Offering Documents. As of December 31, 2025 JW Asset’s discretionary regulatory assets under management were approximately $477 million.

JW Asset does not have a standardized fee schedule. JW Asset generally receives a management fee of up to 2% per annum of assets under management (a) based on beginning of period or end of period assets or capital commitments (as applicable), (b) generally charged quarterly, and (c) payable either in advance or in arrears. JW Asset as the investment manager, in its sole discretion, may waive, reduce or calculate differently the management fee with respect to certain investors in the Funds, including, without limitation, investors who are affiliates or employees of the General Partner or the Investment Manager, members of the immediate families of such persons, trusts or other entities for their benefit (“Related Partners”). The Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and current Internal Revenue Service (“IRS”) regulations prohibit fee payments to oneself and/or an affiliate from one's IRA or other self-directed retirement account. Accordingly, such an account of an officer of the General Partner or his or her spouse will be deemed to be a Related Partner and will not be subject to management fees or Performance Profit (as defined below) allocations. Except as otherwise provided in the relevant Fund’s Offering Documents, JW Asset and/or the General Partner (as applicable) shall bear and pay (without reimbursement by the relevant Fund) all reasonable and normal overhead expenses incurred in the operation of its business, including, among other things, office expenses, rent, employee salaries, telephone, postage and clerical costs (but not accounting, legal or other professional service costs). The respective Fund will pay or reimburse JW Asset and/or the General Partner (as applicable) for all other costs and expenses incurred by or on behalf of the respective Fund or for its benefit, including, without limitation, all costs and expenses associated with the organization of the Fund, all respective Fund trading costs and expenses (such as, for example, expenses related to short sales, option premiums, brokerage commissions and fees, clearing and settlement charges, custodial fees and expenses and service fees, securities transaction costs and research costs), taxes, all interest on Fund borrowings (on margin or otherwise), all accounting and legal fees, as well as extraordinary or nonrecurring expenses (such as litigation expenses), which expenses may be paid directly by the respective Fund or reimbursed to JW Asset and/or the General Partner (as applicable).

All such fees and expenses and other important information regarding an investment in a Fund, are more fully set forth in each Fund’s Offering Documents. Clients (i.e., Funds) may terminate JW Asset’s investment management services in accordance with the terms of their agreements with JW Asset. Withdrawals or redemptions by investors in a Fund are subject to the terms described in the applicable Fund’s Offering Documents. Upon termination of any Client account, or a withdrawal or redemption made by an investor in a Fund, any prepaid, unearned fees will be promptly refunded and any earned, unpaid fees will be due and payable. JW Asset deducts its management fee from the Funds’ assets (other than Insight Wellness). See Item 12 which describes the factors that JW Asset considers in selecting broker-dealers for Client transactions and determining the reasonableness of their compensation (e.g., commissions).

Methods of Analysis JW Asset believes that it can identify value and opportunities without undue risks by applying informed decision making and skilled management and by attention to the details of each Fund’s investments. As part of its research process, JW Asset will analyze many factors including, but not limited to:

a detailed review of a company’s regulatory filings and financial statements;

information received as a result of face-to-face meetings with a company’s senior management as well as meetings and site visits with management teams, suppliers, customers and industry participants;

utilization of the Investment Manager’s proprietary network of industry experts and contacts in the relevant industry; and

insights from public and private markets to inform its view of valuation and industry trends.

Further, JW Asset’s analysis depends on:

extensive, bottom-up, due diligence of companies;

daily news surveillance and evaluation of all positions;

frequent management interaction in and onsite company visits when productive;

together with trusted partners, evaluation of clinical data and regulatory developments and analysis of therapeutic products and pricing power;

attendance at industry meetings and conferences throughout the year;

review of SEC and FDA filings as they become public;

analysis and review of portfolio companies, relying heavily on Mr. Wild’s background having previously worked as a pharmacist and 25+ years as a dedicated healthcare portfolio manager;

concentrated portfolios of best ideas with top 10 positions usually accounting for over 50% of the portfolio (initial positions usually kept below 15% of the public equity portfolio);

mitigated risk with respect to regulatory, political, and potential patent litigation whenever possible;

event driven trading, covered calls and strategic short positions to reduce overall volatility when opportunities present themselves.

Investment Strategies JW Asset’s Strategies are described briefly below: JW Partners, LP (“JW Partners”) The investment objective of JW Partners is to seek capital appreciation by investing primarily, but not exclusively, in growth companies in the healthcare (including companies which operate in the medical and adult-use cannabis markets), consumer and retail sectors. JW Partners invests in both public and private companies without restrictions or limits on the percentage allocations to specific investments. JW Asset seeks to capitalize on the absence of research coverage for many small and mid-sized companies by conducting its own proprietary investment research. The investment policies of JW Partners are based upon the belief that significant profit can be realized from a sophisticated and aggressive investment strategy, often independent of general market factors. JW Partners has had and intends to continue to have a relatively concentrated portfolio by focusing its investment activities on a relatively small number and limited variety of companies, with the expectation that such a concentrated investment strategy may lead to greater returns. JW Partners has made substantial investments in companies in the business of cultivating and selling medical and adult-use cannabis, such as TerrAscend. JW Partners is not limited to investing in any specific sector and may, within the limits established from time to time by JW Asset, pursue other investment opportunities as JW Asset may, in its sole discretion, determine. JW Asset will generally effect portfolio transactions for JW Partners without regard to holding periods and, as a result, the Fund’s portfolio turnover may be high. JW Partners may, from time to time, utilize certain investment techniques, including hedging, short-selling, margining its positions in the securities markets, securities lending, leveraging techniques, and other securities investment strategies. In certain other situations, JW Partners also may purchase or sell put or call options in connection with its positions in securities. JW Partners will invest, hold, sell, trade (on margin or otherwise), and otherwise deal in public and private securities and other intangible investment instruments. Investment instruments utilized may include publicly traded stocks, bonds, notes, options, warrants, rights, derivatives and other securities and instruments. JW Partners also may trade in publicly traded and over the counter options and invest in debt instruments.

JW Opportunities Fund, LLC (“JW Opportunities Fund”) The investment objective of JW Opportunities Fund is to seek capital appreciation by investing primarily, but not exclusively, in growth companies in the healthcare (including companies which operate in the medical and adult-use cannabis markets), consumer and retail sectors. JW Opportunities Fund invests in both public and private companies without restrictions or limits on the percentage allocations to specific investments. JW Asset seeks to capitalize on the absence of research coverage for many small and mid-sized companies by conducting its own proprietary investment research. The investment policies of JW Opportunities Fund are based upon the belief that significant profit can be realized from a sophisticated and aggressive investment strategy, often independent of general market factors. JW Opportunities Fund has had and intends to continue to have a relatively concentrated portfolio by focusing its investment activities on a relatively small number and variety of companies, with the expectation that such a concentrated investment strategy may lead to greater returns. JW Opportunities Fund has made substantial investments in companies in the business of cultivating and selling medical and adult-use cannabis, such as TerrAscend. JW Opportunities Fund is not limited to investing in any specific sector and may, within the limits established from time to time by JW Asset, pursue other investment opportunities as JW Asset may, in its sole discretion, determine. JW Opportunities Fund may trade, buy, sell (including sell short), and otherwise acquire, hold, dispose of (using margin and other forms of leverage) and deal in financial instruments and other rights and interests including, without limitation, listed and unlisted, registered and unregistered securities of various U.S. and international issuers, including, but not limited to, equity and equity-related securities (e.g., common stock, preferred stock, stock warrants and rights, convertible securities, “new issues” and indices related to any of the foregoing), exchange-traded funds, and other derivative instruments, currencies, interest rates, notes, bonds, warrants, debt instruments and other fixed income securities (corporate, derivative and governmental, rated and unrated, interestonly and principal-only), listed and over-the-counter derivative instruments (including credit derivatives) on all of the above instruments, rights to acquire the same of public and private issuers throughout the world, and such other instruments or interests as JW Asset deems appropriate. JW Asset will generally effect portfolio transactions for the Fund without regard to holding periods; as a result, at times the Fund’s portfolio turnover rate may be high.

JW Opportunities Fund may, from time to time, utilize certain investment techniques, including hedging, short-selling, margining its positions in the securities markets, securities lending, leveraging techniques, and other securities investment strategies. In certain other situations, the Fund also may purchase or sell put or call options in connection with its positions in securities. JW Growth Fund, LLC (“JW Growth”) The investment objective of JW Growth is to seek capital appreciation by investing in the growth opportunity presented by the expansion of the legalization of medical and adult-use cannabis. In pursuing this investment objective, JW Asset uses fundamental analysis to select investments in equity and debt securities of companies in the cannabis industry, but may opportunistically invest in other financial instruments. JW Growth invests in both public and private companies without restrictions or limits on the percentage allocations to specific investments. JW Asset implements its own investment process, which includes generating ideas, sourcing deals, conducting proprietary investment research, considering investment structures, optimizing portfolio management without compromising effective risk management measures, and consistently monitoring and re-evaluating investments. JW Asset seeks to invest JW Growth’s portfolio vertically across the following cannabis subsectors: dispensaries/retail, cultivation/production, AgTech, compliance/testing, banking, and pharmaceuticals, or as otherwise provided in JW Growth’s private placement memorandum. The primary geographic focus of JW Growth’s investments is North America (U.S. and Canada) but as the growth of the legal cannabis industry continues, JW Asset may invest opportunistically across the expanded accessible market. The investment policies of JW Growth are based upon the belief that significant profit can be realized from a sophisticated and aggressive investment strategy, often independent of general market factors. JW Asset seeks a long-term investment approach for the Fund, based on an event-driven trading strategy. JW Growth has and intends to continue to have a relatively concentrated portfolio by focusing its investment activities on a relatively small number and variety of companies, a significant portion of which may be privately-held entities, with the expectation that such a concentrated investment strategy may lead to greater returns. JW Asset generally intends to target investments of twenty (20) to thirty (30) long positions and up to five (5) short positions at any

one time. Notwithstanding the foregoing, the numbers and techniques described in this paragraph are guidelines only and in no way restrict JW Asset from exceeding such guidelines and numbers or employing other guidelines, as it deems appropriate, in its sole discretion, particularly when JW Asset believes it would be in the best interests of JW Growth to take advantage of specific opportunities. The assets of JW Growth may be invested and traded in a broad variety of securities and other instruments, whether traded on exchanges, over-the counter or negotiated on electronic markets. JW Growth will invest primarily in Canadian and other North American equity and debt securities, whether long or short, however, investments may include global securities and take a broad variety of forms. JW Growth may trade, buy, sell (including sell short), and otherwise acquire, hold, dispose of (using margin and other forms of leverage) and deal in financial instruments and other rights and interests including, without limitation, listed and unlisted, registered and unregistered securities of various U.S. and international issuers, including, but not limited to, equity and equity-related securities (e.g., common stock, preferred stock, stock warrants and rights, convertible securities, “new issues” and indices related to any of the foregoing), exchange traded funds, and other derivative instruments, currencies, interest rates, notes, bonds, warrants, debt instruments and other fixed income securities (corporate, derivative and governmental, rated and unrated, interest-only and principal-only), listed and over-the-counter derivative instruments (including credit derivatives) on all of the above instruments, rights to acquire the same of public and private issuers throughout the world, and such other instruments or interests as JW Asset deems appropriate. JW Asset will generally effect portfolio transactions for JW Growth without regard to holding periods; as a result, at times the Fund’s portfolio turnover rate may be high. JW Growth may, from time to time, utilize certain investment techniques, including hedging, short-selling, margining its positions in the securities markets, securities lending, leveraging techniques, and other securities investment strategies. In certain other situations, the Fund also may purchase or sell put or call options in connection with its positions in securities.

Insight Wellness Fund, LLC (“Insight Wellness Fund”) The investment objective of Insight Wellness Fund is to seek capital appreciation by investing in the substantial growth opportunity presented by the expansion of the legalization of medicinal and/or adult-use cannabis. In pursuing this investment objective, JW Asset uses fundamental analysis to select investments in equity and debt securities of companies in the cannabis industry, but may opportunistically invest in other financial instruments. The Fund will invest in both public and private companies without restrictions or limits on the percentage allocations to specific investments. JW Asset implements its own investment process, which includes generating ideas, sourcing deals, conducting proprietary investment research, considering

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compromising effective risk management measures, and consistently monitoring and reevaluating investments. The Insight Wellness Fund intends to have a relatively concentrated portfolio by focusing its investments on a relatively small number and variety of companies, a significant portion of which may be privately-held entities, with the goal that such a concentrated investment strategy may lead to greater returns.

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JW Asset provides discretionary investment management services to four (4) Funds. Each Fund has a minimum investment requirement for investors as set forth in such Fund’s Offering Documents. Investors also are required to meet certain eligibility standards as set forth in each Fund’s Offering Documents. In its discretion, JW Asset may enter into side letter arrangements with certain investors in a Fund (“Side Letter Investors”) whereby JW Asset and a Side Letter Investor have agreed (or may agree in the future) to vary the Side Letter Investor’s investment terms from those made available to other investors in the Fund, including but not limited to reduced fees to be charged to a Side Letter Investor (management and/or incentive). A Fund also may issue additional classes that are subject to such different terms and conditions which are similar or the same as a side letter arrangement.

An amount equal to 20% of each investor's share of net profits, if any, during any fiscal year, in excess of the sum of (i) the management fees paid in respect of such investor and (ii) any cumulative unrecovered net losses experienced by each investor over all prior years (subject to adjustment on withdrawal as described below) (“Performance Profits”) will be allocated to the capital accounts of the General Partner (an affiliate of JW Asset), from the capital accounts of each investor in the Funds (other than Insight Wellness). Performance Profit allocations will be based on realized and unrealized gains for all Fund investments. In the event that an investor withdraws, is required to withdraw or makes a substantial withdrawal from a Fund at any time other than at the end of a fiscal year, a Performance Profit allocation is made from that investor's account at the time of its withdrawal or substantial withdrawal as though it were being made at the end of a fiscal year. Performance Profit allocations do not apply to Related Partners except as directed by the General Partner. The General Partner of the Funds and/or JW Asset may be subject to conflicts of interest with respect to the Funds. JW Asset currently manages and makes investment decisions for several Funds with similar investment objectives and policies. The Funds, therefore, may compete with each other with respect to investment transactions. Furthermore, one or more of the Funds currently invests in private entities and/or start-ups in which JW Asset, its principals and/or

affiliates are also invested and which are partially or wholly controlled by JW Asset, its principals and/or affiliates. Certain Funds may have higher Performance Profit allocations than other Funds. Such arrangements may create an incentive for JW Asset to favor those accounts with a higher Performance Profit allocation over other accounts with a lower (or no) Performance Profit allocation in the allocation of investment opportunities. JW Asset has designed and implemented policies and procedures to prevent these potential conflicts from influencing the allocation of investment opportunities among Clients. See also Item 8. All fees and expenses and other important information regarding an investment in a Fund, are more fully set forth in each Fund’s Offering Documents.

JW GP, LLC, a Delaware limited liability company formed in November 2003 serves as the general partner or managing member (as applicable) of the Funds (except Insight Wellness) for which JW Asset serves as the Investment Manager. Mr. Wild and Tamar Katzburg Wild, his spouse, control JW GP. JW Asset does not refer clients or investors to other investment advisers and it does not receive any compensation from other financial industry participants. The right of the General Partner to receipt of the Performance Profit allocation may create an incentive for JW Asset, an affiliate of the General Partner, to cause the relevant Fund to make investments that are riskier or more speculative than would be the case if the General Partner was allocated only a fixed amount.

and Personal Trading JW Asset has a fiduciary responsibility to treat Clients fairly and seek to avoid actual or potential conflicts of interest. In performing their duties, JW Asset’s employees have an obligation to act solely in the best interests of Clients, and to make full and fair disclosure of all material facts, particularly where the Clients' interests may conflict with the interests of JW Asset or its employees.

Code of Ethics JW Asset strives to adhere to the highest industry standards of conduct based on principles of professionalism, integrity, honesty and trust and, therefore, has adopted a code of ethics (“Code of Ethics”) which describes the general standards of conduct that it expects of all its employees and focuses on specific areas where employee conduct has the potential to adversely affect the Clients, namely: misuse of confidential information, personal securities trading and outside business activities. Failure of an employee to uphold the Code of Ethics may result in disciplinary sanctions, including termination of employment by JW Asset. All employees must acknowledge the terms of the Code of Ethics annually, or when amended. Any Client or prospective Client and any investor in a Fund may request a copy of the Code of Ethics. Under the Code of Ethics, JW Asset’s employees are permitted to maintain personal trading accounts provided that such accounts are disclosed to JW Asset and any personal trading by Employees must be consistent with applicable law and with the Code of Ethics. Employees may buy, sell or hold for their own personal trading accounts securities that JW Asset also buys, sells or holds for the Funds subject to compliance with applicable laws, rules and regulations, the Code of Ethics, pre-approval, and a determination that no conflict of interest exists. See also “Personal Securities Trading” below.

Misuse of Nonpublic Information JW Asset’s Code of Ethics also addresses misappropriation of material nonpublic or proprietary information (e.g., insider trading). JW Asset’s insider trading prohibitions (i) apply to all its employees, (ii) extend to activities within and outside their duties as employees of JW Asset, and (iii) apply to investment interest-related information that is internal to JW Asset.

Participation or Interest in Client Transactions JW Asset may invest Client assets in securities where one or more principals of JW Asset has a vested interest or serves as director for the issuer. This presents a potential conflict of interest because JW Asset may have an incentive to make and/or maintain such investments even if they are not performing well and there will not be any independent oversight with respect to such investments, as set forth in Item 8. However, such relationships and potential conflicts of interest are fully disclosed to Clients and investors. See also Items 4, 5 and 8 above. JW Asset does not cross trade among Client accounts and does not plan to do so. To the extent necessary in the future, JW Asset has the discretion, as permitted under applicable law, to effect client cross-transactions. JW Asset may also engage an independent representative to satisfy the disclosure and consent requirements of Section 206(3) of the Advisers Act with respect to transactions entered into by Clients.

Personal Securities Trading Subject to compliance with applicable laws, rules and regulations and the limitations set forth in its Code of Ethics, employees may buy, sell or hold for their own personal trading accounts securities, including the same securities as Client accounts. JW Asset has adopted personal trading policies and procedures, which prohibit employees from benefitting personally from the trading activities of JW Asset Clients, to prevent conflicts of interest with its Clients. JW Asset at times may maintain a restricted list of securities that it and its employees may not trade in order to avoid the misuse of material non-public information or confidential Client information. Also, though JW Asset and its employees may invest in or hold the same securities that it recommends or previously recommended for its clients, JW Asset has adopted a policy in its Compliance Manual restricting the ability of JW Asset or its employees to benefit from Client trades in those securities, including by providing a no-trade window before an anticipated or pending Client trade and after a Client trade. JW Asset’s chief compliance officer periodically reviews the personal accounts of its employees for compliance with these policies and procedures.

Outside Business Activities Employees are permitted to engage in limited outside business activities provided these activities are pre-cleared by the chief compliance officer (and, with respect to any outside

business activities of the chief compliance officer, pre-cleared by Mr. Wild) and more importantly, do not create an actual or potential conflict of interest due to the amount of time spent on such activities and the investment-related nature of certain activities. If any activities are deemed to be in conflict with the Clients, such conflicts will be fully disclosed.

As a fiduciary, the Investment Manager has a duty to seek the best execution for all transactions it executes on behalf of a Fund and for other accounts managed by the Investment Manager (“Other Accounts”). The Investment Manager need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost. In selecting brokers for execution of a Fund’s trades, the Investment Manager will consider the full range of brokerage services provided, which may include a broker’s execution, clearance and settlement capabilities; its capital strength, stability, responsibility, reputation and reliability; the reasonableness of the broker’s commission rates (and other transactional charges); the nature and frequency of the broker’s sales coverage; its responsiveness to the Investment Manager; the broker’s depth of available services, arbitrage operations, bond capability and option operations; the availability of stocks to borrow for short trades; the broker’s willingness to execute related or unrelated difficult transactions in the future; and the broker’s back office, processing and special execution capabilities, and error resolution capabilities. In addition, the Investment Manager may consider in selecting brokers the nature and character of the particular security or instrument being traded and the activity existing and expected in the markets, including the size of the trade, the markets on which it is purchased or sold, the desired timing of the transaction and the pricing of the transaction. The Investment Manager also may consider the quality of the brokerage and research services, within the meaning of Section 28(e) of the U.S. Securities Exchange Act of 1934, as amended (the “Securities Exchange Act”), that are provided to the Investment Manager by the broker (“Brokerage and Research”). The Investment Manager will not adhere to any rigid formulas in selecting brokers but will weigh the factors described above. Recognizing the value of one or more of these factors, the Investment Manager may pay a brokerage commission in excess of that which another broker might have charged for effecting the same transaction. The Investment Manager periodically will evaluate the placement of brokerage and the reasonableness of commissions paid.

To the extent the Investment Manager receives Brokerage and Research, it will be receiving a benefit by reason of the direction of such commissions because it will not need to produce or pay for the Brokerage and Research (or charge such expenses to clients). Thus, to the extent the Investment Manager uses commissions to obtain Brokerage and Research that would otherwise be an expense of the Investment Manager, such Brokerage and Research in effect will constitute additional compensation to the Investment Manager. As a result, the Investment Manager may have an incentive to select brokers based on such benefits. Brokerage and Research may be used by the Investment Manager in managing both a Fund’s assets as well as those of some or all of the Other Accounts. Some Brokerage and Research may not necessarily be used by the Investment Manager in managing the assets of the Fund even though the Fund’s commission dollars are provided for the Brokerage and Research. The Fund may not, in any particular instance, be the direct or indirect beneficiary of the Brokerage and Research provided. Brokerage and Research may include, among other things, proprietary research from brokers. Brokers may also provide the Investment Manager with third party research services. Research may be in oral or written form and may include, among other things research concerning market, economic and financial data, a particular aspect of economics or on the economy in general, statistical information, database information, data on pricing and availability of securities, non-mass-marketed financial publications, electronic market quotations, trading analytics, analyses concerning specific securities, companies, industries or sectors and market, economic and financial studies and forecasts. All soft dollar arrangements that the Investment Manager enters into will be within the safe harbor provided by Section 28(e) of the Securities Exchange Act. Pursuant to such safe harbor, Brokerage and Research services must provide lawful and appropriate assistance to the Investment Manager in the performance of its investment decision-making responsibilities. Further, the amount of commissions paid by a Fund must be reasonable in light of the value of the Brokerage and Research services offered, taking into account various factors, including commission rates, financial responsibility and strength and ability of the broker to efficiently execute transactions. Accordingly, if the Investment Manager determines in good faith that the amount of commissions charged by a broker are reasonable in relation to the value of the Brokerage and Research services provided by such broker, a Fund may pay commissions to such broker in an amount greater than the amount another broker might charge.

The Investment Manager may aggregate sale and purchase orders of securities held or purchased by a Fund with similar orders being made simultaneously for Other Accounts if, in the Investment Manager’s judgment, such aggregation is reasonably likely to result in an overall economic benefit to the Fund and the Other Accounts, in the aggregate, based on an evaluation that the Fund and the Other Accounts are benefited by relatively better purchase or sale prices, lower commission expenses or beneficial timing of transactions, or a combination of these and other factors. In many instances, the purchase or sale of securities for the Fund will be effected contemporaneously with the purchase or sale of like securities for Other Accounts. Such transactions may be made at slightly different prices, due to the volume of securities purchased or sold. In such event, the average price of all securities purchased or sold in such transactions may be determined, and in the Investment Manager’s exclusive discretion, a Fund may be charged or credited, as the case may be, the average transaction price. As a result, however, the price may be less favorable to the Fund than it would be if similar transactions were not being concurrently executed for Other Accounts.

JW Asset may pay referral fees or any other benefits to third parties for referring investors. Investors in the Funds do not pay higher advisory fees based on these relationships.

There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of JW Asset’s advisory business or the integrity of its management.

All Client accounts are monitored on a daily basis by the principals of JW Asset for performance, composition and market movement. JW Asset negotiates custom reporting schedules and content, but these typically include real time execution reports, monthly performance reports, monthly AUM reports, and monthly trade allocation percentages. Investors in the Funds receive audited financial statements on an annual basis.

JW Asset does not have actual physical custody of Client’s assets. Nonetheless, JW Asset is deemed to have custody of the assets of the Funds (other than Insight Wellness) under Rule 206(4)-2 of the Advisers Act because JW Asset has the ability to deduct fees from the Funds and its affiliated entity (JW GP) serves as general partner/managing member for the Funds (other than Insight Wellness). In order to comply with its obligations under Rule 206(4)-2 of the Advisers Act for those Funds for which it is deemed to have custody (i.e., the Funds other than Insight Wellness), JW Asset maintains the assets of such Funds with qualified custodians and audited

financial statements are furnished annually to all investors in such Funds.

JW Asset has investment discretion for all Client accounts. In all cases, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular Client.

To the extent JW Asset receives proxies on behalf of Clients, it votes all such proxies in a prudent and timely manner or abstains from voting such proxies in accordance with its Proxy Voting Policy outlined in its Compliance Manual. A copy of the Proxy Voting Policy is available to any client or prospective client upon request. Information on how votes were cast is also available to any Client and any investor in a Fund.

JW Asset does not have any financial condition that would be likely to impair its ability to meet its commitments to its Clients.