KENNEDY LEWIS MANAGEMENT LP

Kennedy Lewis Management LP (“Kennedy Lewis” or the “Firm”) was formed on September 15, 2017. The Firm’s headquarters are located in New York, NY. David Chene and Darren Richman control Kennedy Lewis. Mr. Chene and Mr. Richman are the Managing Partners of the Firm. Together Messrs. Richman and Chene manage the Firm with the assistance of their staff. Kennedy Lewis is the investment adviser to the Kennedy Lewis Capital Partners Master Fund LP; Kennedy Lewis Capital Partners Master Fund II LP; Kennedy Lewis Capital Partners Master Fund III LP, Kennedy Lewis Capital Partners Master Fund IV LP, their Delaware onshore feeders, and their Cayman Islands offshore feeder and intermediate funds, as well as certain parallel and co-investment and “funds of one” (collectively, the “Credit Opportunity Funds”). Kennedy Lewis is also the investment adviser to “funds of one” that invest in and/or alongside (i) Kennedy Lewis Senior Loan Fund (the “Senior Loan Fund”), and (ii) Kennedy Lewis Capital Company, an externally-managed, diversified, closed-end investment company that has elected to be regulated as a business development company (the “BDC”). The Senior Loan Fund, the BDC and various funds of one to whom Kennedy Lewis serves as investment adviser are collectively referred to as the “Core Lending Funds.” In addition, Kennedy Lewis, through Kennedy Lewis Land and Residential Advisors LLC (“KLLARA”), its wholly-owned subsidiary, advises Millrose Properties, Inc. (“Millrose Properties”) a publicly traded real estate investment trust (“REIT”) that was created by way of a spin-off from Lennar Corporation in February 2025. As discussed in Item 10 below, Kennedy Lewis is affiliated with (i) investment advisers (the “Affiliated Advisers”), including, without limitation, Kennedy Lewis Capital Holdings LLC, which serves as investment adviser to the BDC, Kennedy Lewis Residential Property Income Advisors LLC, which is the investment adviser to Kennedy Lewis Residential Property Income Company LP (the “KLRES Fund” and, collectively together with the Credit Opportunities Funds and the Core Lending Funds, the “Funds”) and Kennedy Lewis Loan Management LLC (“KLLM”), which is the investment advisor for Kennedy Lewis’ collateralized loan obligation platform (the “KLLM CLOs”) and Kennedy Lewis Advisors (Switzerland) SARL, a relying investment adviser of Kennedy Lewis, which is based in Geneva, Switzerland, and is under common control with Kennedy Lewis and shares certain supervised persons, and (ii) Kennedy Lewis Capital Markets LLC (the “Kennedy Lewis Broker-Dealer”). For information about the investment strategy of Kennedy Lewis, see the discussion under Item 8 below. Further, details regarding the Funds can be found in the respective offering memoranda, limited partnership agreements and other governing documents (the “Governing Documents”). Kennedy Lewis generally manages each Fund pursuant to the objectives specified in the Governing Documents. The Funds’ investors generally do not have the right to restrict the Funds’ investing in certain securities or types of securities. Kennedy Lewis may tailor the advisory services it provides to certain Funds to the extent that certain investments cannot be held by certain Funds for legal, regulatory and/or tax reasons and pursuant to its general investment discretion, with respect to the investment activity of the Funds. Information regarding Kennedy Lewis Capital Holdings LLC and the BDC is provided in the Form ADV for Kennedy Lewis Capital Holdings LLC. Information regarding Kennedy Lewis Loan Management LP and the KLLM CLOs is provided in the Form ADV for Kennedy Lewis Loan Management LLC. Information regarding KLLARA is provided in the Form S-11 for Millrose Properties. As of December 31, 2025, Kennedy Lewis had approximately $11,536,179,487 in regulatory assets under management.1 As of that date, the Firm managed $11,536,179,487 on a discretionary basis and $0 on a non-discretionary basis.

This amount includes unfunded commitments for certain funds that do not currently own any assets.

Advisory Fees and Compensation. Kennedy Lewis charges a management fee and is entitled to performance-based compensation in accordance with the respective Funds’ Governing Documents. The information provided in this brochure regarding fees and expenses is not intended to be complete or final and is qualified in its entirety by the Governing Documents. Limited partners and prospective investors should read and review the Governing Documents of the respective Fund to fully understand the types of fees and expenses that are borne by the Fund. Except as noted below and with respect to the KLRES Fund and the Senior Loan Fund, the Funds, as to each limited partner, pay Kennedy Lewis either (i) a quarterly management fee calculated at an annual rate of 1.0%-2.0% based on the Commitments (as defined in the Governing Documents), and in some cases an additional 0.50%-2.0% on Actively Invested Capital (as defined in the Governing Documents) as of the first day of each calendar quarter, or (ii) a monthly management fee calculated at an annual rate of 0.9% on Net Asset Value (as defined in the Governing Document) as of the first day of each calendar quarter. With respect to the Credit Opportunity Funds, the terms of the specific tranche of limited partner interests determines whether the management fee is calculated based on Commitments or Actively Invested Capital and after the investment period, the management fee will be calculated based on Actively Invested Capital. The management fee payable by the Credit Opportunity Funds and the Core Lending Funds in any quarterly or monthly period, as applicable, is reduced by the sum of any transaction, management, investment banking, monitoring, closing, topping, break-up or other similar fees received by Kennedy Lewis, the general partner of the applicable Fund, or their affiliates (net of unrecouped partnership expenses that such person has elected to pay on behalf of the applicable Fund). The quarterly management fee is also reduced in an amount equal to the sum of all fees and expenses paid or reimbursed by the applicable Credit Opportunity Fund to placement agents in connection with the offering and sale of limited partnership interests in such Credit Opportunity Fund during the immediately preceding calendar quarter. The KLRES Fund, as to each limited partner, pays Kennedy Lewis a monthly management fee calculated at an annual rate of 1.25% based on the Net Asset Value (as defined in the Governing Documents of the KLRES Fund) of such limited partner’s Interests on such date. The Senior Loan Fund, as to each limited partner, pays Kennedy Lewis a monthly management fee calculated at an annual rate generally of 1.0% based on the Net Asset Value (as defined in the Governing Documents of the Senior Loan Fund) of such limited partner’s Interests on such date. Except as noted below, the general partners of the Funds or their affiliates are also entitled to receive carried interest or similar profit distributions (“Carried Interest”) from the Funds or an allocation equal to 10%12.5% of profits above the set hurdle amount (“Incentive Allocation”). Carried Interest is a performancebased profit allocation based on a share of the income and gains of the assets in each applicable Fund. Carried Interest distributions for the Credit Opportunity Funds are typically 20.0% of distributions after investors have received a return of their capital contributions plus a preferred return. Carried Interest for the Credit Opportunity Funds is not calculated on the basis of unrealized gains and losses while the calculation of Incentive Allocation includes unrealized gains and losses. The calculation of Incentive Allocation for the Senior Loan Fund is based on increases in net asset value. Any loss incurred by a limited partner in the Senior Loan Fund is carried forward so that no Incentive Allocation is owed unless and until losses incurred during a prior period or periods have been recouped, subject to certain adjustments (also referred to as a “High Water Mark”). Carried Interest distributions for the KLRES Fund are typically 12.5-15% of distributions above the set hurdle amount. The specific tranche of limited partner interests determines the Carried Interest percentage for such limited partner in the KLRES Fund. Carried Interest in the KLRES Fund is calculated on the basis

of unrealized gains and losses. The Senior Loan Fund receives an annual Incentive Allocation that is typically 12.5% of each limited partner’s share of profits, provided that at the time of calculation the limited partner’s net asset value exceeds the High Water Mark and is above the set hurdle amount. The Funds have multiple categories of interests or tranches, including a tranche for initial limited partners, which may bear lower fees than those described above. Kennedy Lewis also reserves the right to vary the fees as to particular limited partners by separate agreement and to reduce or waive any fees at any time. Kennedy Lewis waives or reduces the management fees and Carried Interest for its own capital and that of its constituent partners, affiliates, and employees, and family members of the foregoing. Expenses. In addition to paying management fees and Carried Interest or Incentive Allocation, the limited partners of the Funds will also indirectly bear certain expenses charged to the Funds. The Funds were subject to certain costs in connection with their organization, as more particularly described in the Governing Documents. The Funds generally bear their own operating costs. Such fees and expenses will vary but generally include fees, costs, and expenses incurred in connection with the following: (i) the developing, sourcing, investigation, negotiation, structuring, evaluation, acquisition, or disposition of investments and prospective investments, whether or not consummated, including without limitation private placement fees, sales commissions, appraisal fees, taxes, travel expenses, litigation expenses, brokerage fees, underwriting commissions and discounts, fees and expenses related to loan servicers (whether affiliated or not) and other related services, any filing or similar fees, and legal, accounting, investment banking, financial, consulting, information services, professional fees, and expenses related to research products and services (including without limitation, expert consultants and third party consultants/advisors); (ii) the retention of placement agents; (iii) the termination, cancelation, or abandonment of a potential investment that is not consummated (including expenses from any legal, financial, accounting, consulting, or other advisors or any lenders, investment banks, or other financial sources); (iv) the carrying of investments, including without limitation custodial, trustee, record keeping, and other administrative fees; (v) the retention of independent appraisers or other valuation experts; (vi) the maintenance of the books and records of the Funds, their reports, tax returns, Schedules K-1 (or similar schedules) and non-U.S. tax forms, and any communications with the limited partners; (vii) the retention of attorneys and accountants and other service providers relating to Fund matters, including, without limitation, expenses incurred in connection with compliance with the Funds’ Governing Documents, including without limitation, costs of outside legal counsel and any third-party provider of a contract automation and intelligence platform to support compliance with such Governing Documents); (viii) any and all taxes (including interest and penalties) and other governmental charges that may be incurred or payable by the Funds without regard to the status of any limited partner; (ix) any and all insurance policies purchased by the Funds in connection with their activities, including errors, omissions, fidelity, crime, general partner liability, directors’ and officers’ liability, and similar coverage for any person acting on behalf of the Funds; (x) compliance with any law or regulation related to the activities of the Funds; (xi) regulatory filings and reporting requirements, including, without limitation, any preparation and filings in connection with non-U.S. marketing and fundraising, including as related to AIFMD and non-AIFMD investors which seek information about the Funds, Form PF and filings related to, among others, Section 13 and Section 16, Hart Scott Rodino and other antitrust-related matters, and CFIUS to the extent they are in connection with, relate to or derive from a Fund or its investment activities, and expenses associated with certain reporting to existing and prospective investors; (xii) the dissolution, winding up or termination of the Funds; (xiii) the formation and operation of alternative investment vehicles and any special purpose entities, including, without limitation, costs of outside legal counsel and any third-party provider of a contract automation and intelligence platform; (xiv) any amendments, modifications, revisions, or restatements to the constituent documents of the Funds or related entities; (xv) any valuation of the assets of the Funds; (xvi) distributions to the partners or any meeting of the partners (including reasonable transportation, lodging, meals and other expenses of the general partner or Kennedy Lewis in connection therewith); (xvii) any annual or other meetings of the applicable Fund’s limited partner advisory committee, including all reasonable out-of-pocket expenses incurred by members

of such committee; (xviii) the Fund’s indemnification obligations; (xix) the management fees payable to Kennedy Lewis; (xx) administrative proceedings relating to the determination of Fund items at the Fund level undertaken in connection with certain tax matters, including tax audits, including any related administrative settlement and judicial review; and (xxi) solely in respect of the KLRES Fund, fees and expenses incurred in connection with satisfying any REIT Shareholder Requirement (as defined in the Governing Documents of the KLRES Fund). From time to time, Kennedy Lewis has and will engage individuals as third-party advisors, “consultants,” “contractors,” “advisers” and other consultants (collectively, “Advisors”) who are not employees of Kennedy Lewis, but are paid fees for services provided to one or more clients managed by Kennedy Lewis, including services related to Kennedy Lewis’ investment process. Additionally, certain research providers and consultants (“Research Providers”) are engaged with respect to the clients. The terms of these engagements, including compensation arrangements for Advisors and Research Providers, are generally agreed upon between the Firm or Research Provider (or one of their respective affiliates) and Kennedy Lewis at the time of engagement and will vary depending upon the nature of the services provided. These fees and expenses (including travel and lodging expenses) are generally allocated to the client(s) that benefit from the services and are not borne by Kennedy Lewis even if the services of such Advisor or Research Provider are not utilized during the entire term of the engagement. Kennedy Lewis offers investment support services to the portfolio investments certain of the Funds, including members of Kennedy Lewis’ Operational Resource Center (the “ORC”). The terms of engagement, including the compensation arrangements for members of the ORC are generally agreed between the ORC member and Kennedy Lewis (or one of its affiliates or portfolio investments) at the time of engagement and vary depending on the nature of the services provided. In addition to retainers, periodic fees and the reimbursement expenses, members may receive compensation arrangements from portfolio investments composed of a discretionary performance-related bonus, grants of equity and/or co-investment opportunities in the portfolio investments in which such member serves directly as a consultant or adviser and may receive directors’ fees, consulting fees and other compensation from portfolio investments. These fees and expenses are not paid by Kennedy Lewis out of management fees and do not reduce or be offset against the management fee or any other compensation paid to Kennedy Lewis. A member of the Operational Resource Center (an “ORC Member”) shall not be paid a retainer during any period when such member is also receiving a cash salary from a portfolio investment. Furthermore, the Fund shall only pay its pro rata amount of a retainer to an ORC Member relative to any successor or predecessor pooled investment vehicles advised by Kennedy Lewis that benefit from the services of such member. On an annual basis, the Funds’ expenses attributable to the fees of the ORC Members are capped in accordance with the Governing Documents of the applicable Funds. For the avoidance of doubt, ORC Members shall only be compensated in cash by the Fund (i.e., they shall not receive any equity, options or any other portion of any of the Funds’ ownership interests in a portfolio investment). The Funds will bear any extraordinary expenses they may incur, including any litigation, arbitration or settlement expenses involving any such Fund, any investment or entities in which it has an investment or otherwise relating to such investment, and the amount of any judgments or settlements paid in connection therewith. The Funds will also pay or reimburse Kennedy Lewis, the respective Fund general partner, and their affiliates for all expenses incurred in pursuit of an investment that upon initial review appeared to meet a Fund’s investment guidelines and that the Fund undertook efforts in furtherance of investing in, but which

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METHODS OF ANALYSIS Credit Opportunity Funds. The Credit Opportunity Fund portfolios may consist of, but are not necessarily limited to, privately originated debt, leveraged loans, investment grade and high yield bonds and notes, equity and equity-linked securities, mortgages, liquidation claims, advances, credit derivatives and real assets. Investments may also include other assets or businesses that present an appropriate event-driven or value opportunity. From time to time, the Credit Opportunity Fund portfolios may invest in highly structured investments that are used to fund corporate growth or recapitalize a company. Investments are likely to be in private and public securities or loans of non-investment grade and potentially non-rated companies. The Credit Opportunity Funds seek to generate superior risk-adjusted returns by investing in primarily debt or other debt-like securities across the capital structure. The Credit Opportunity Funds generally seek investments with a focus on opportunities primarily in North America and Western Europe with the ability to consider investments focused on other geographic markets. In particular, the Credit Opportunity Funds will predominantly target a non-sponsor lending strategy to capitalize on the needs of middle market companies for alternative sources of funding. Kennedy Lewis engages in non-sponsor-backed lending situations which require rigorous fundamental bottoms-up independent credit analysis, sector expertise and creative structuring. In addition, the Credit Opportunity Funds will dynamically allocate across privately originated asset-backed credit opportunities that are backed by large and diversified pools of financial and hard assets, and will seek to provide highly structured capital solutions to U.S. homebuilders for financing the acquisition of entitled land and the completion of land development. Kennedy Lewis has generally had limited participation in traditional sponsor-backed situations. The Firm believes its direct non-sponsor focused origination approach can provide a combination of: (i) proactive portfolio construction through Kennedy Lewis’ proprietary sourcing channels; (ii) enhanced return given the less competitive lending landscape in non-sponsored companies in complex and evolving industries; (iii) and loans with stricter covenants and terms resulting in greater downside protection. Furthermore, Kennedy Lewis is often the sole-lender in its transactions, or the Firm involves a small cohort of lenders, which significantly reduces the probability that a single credit exposure spans multiple third-party portfolios. This provides investors with greater diversification across industries and companies. Core Lending Funds. The Core Lending Funds seek to invest primarily in debt or other debt-like securities across the capital structure of middle market companies located in the United States and, selectively, in other North American countries and in Europe, with the ability to consider investments focused on other geographic markets. The Core Lending Funds employ a strategy to primarily provide capital to middle market companies, with a focus on direct originations of private loans that are generally first lien, senior secured instruments in performing companies, with return characteristics that Kennedy Lewis believes are appropriate for the Fund to meet its investment objectives. To a lesser extent, the Core Lending Funds expect to invest a portion of its assets in more liquid credit investments such as high yield and/or investment grade bonds, broadly syndicated loans, collateralized loan obligations and other liquid securities, including, cash, cash equivalents, U.S. government securities or high-quality debt securities maturing in one year or less from the time of investment, to, among other things, maintain liquidity before investing in a private loan, while also seeking attractive investment returns. The loans in which the Fund invests will generally pay floating interest rates based on a variable base rate.

In particular, the Core Lending Funds will predominantly target a non-sponsor, senior secured lending strategy to capitalize on the needs of middle market companies for alternative sources of funding; Kennedy Lewis engages in non-sponsor backed lending situations which require rigorous fundamental bottoms-up independent credit analysis, sector expertise and creative structuring. Kennedy Lewis defines non-sponsor deals as debt financings arranged by the credit provider to fund corporate objectives. As a result of Kennedy Lewis’ preference for non-sponsor situations, ownership of the Funds’ target companies generally will include publicly listed companies, founders, management teams, minority equity sponsors and families, but not necessarily “control” oriented private equity managers. Kennedy Lewis has generally had limited participation in traditional sponsor-backed situations. The Firm believes its direct non-sponsor focused origination approach can provide a combination of: (i) proactive portfolio construction through Kennedy Lewis’ proprietary sourcing channels; (ii) enhanced return given the less competitive lending landscape in non-sponsored companies in complex and evolving industries; (iii) and loans with stricter covenants and terms resulting in greater downside protection; these might include financial maintenance covenants, which require the borrower to meet certain financial ratios and other governance rights such as board observation rights or formal board representation. When coupled with Kennedy Lewis’ restructuring and workout expertise, the Firm believes tighter covenants and stronger governance can generally lead to earlier hard defaults which can allow Kennedy Lewis to preserve value. Furthermore, Kennedy Lewis is often the sole-lender in its transactions, or the Firm involves a small cohort of lenders, which significantly reduces the probability that a single credit exposure spans multiple third-party portfolios. This provides investors with greater diversification across industries and companies. Kennedy Lewis expects the Core Lending Funds to generally self-originate senior secured loans and other private debt investments, including broadly syndicated loans, sourced through its network of relationships, including founders, management teams, corporate boards, minority equity owners, portfolio companies, banks and prior financing relationships. These loans flow from Kennedy Lewis’ expansive, existing deal origination efforts across a range of industries and corners of the market that exhibit uncorrelated or counter-cyclical characteristics. The Firm’s experienced team has originated and structured private investments in a variety of macro-economic environments to create diverse portfolios of loans that span multiple industries. Investment Strategy Overviews. With respect to the Funds’ investments, Kennedy Lewis is focused on corners of the market that have been overlooked or displaced by traditional sources of capital and which exhibit uncorrelated or countercyclical properties. Kennedy Lewis seeks to source and gain access to proprietary deal flow through its scalable “verticals” (i.e., Life Sciences, Homebuilder Finance, Build-to-Rent, TMT, Power, Tactical Opportunities and Opportunistic Cyclicals) which have allowed the Firm to repeatedly exploit identified themes in sectors that are contending with or causing some form of industry disruption; Kennedy Lewis will also consider adding new verticals as the team identifies new corners of the market in which Kennedy Lewis can build scalable and differentiated platforms. These verticals are intended to be largely uncorrelated to macroeconomic factors. The Firm believes that orienting around verticals allows Kennedy Lewis to scale resources and create a “moat” around its best ideas and deliver attractive absolute returns. Each vertical is led by a senior investment professional, either at the Partner or Managing Director level, who is responsible for sourcing and underwriting opportunities that are consistent with the Firm’s macroeconomic themes and are in need of creativity and flexible capital; for example, companies that suffer from unsustainable capital structures or that lack access to bank or direct-lending sources of capital. Sourcing deal flow that Kennedy Lewis views as proprietary is critical to its success, and the Firm believes that organizing Kennedy Lewis by vertical brings into focus more attractive private investment opportunities. Furthermore, targeting complex situations has allowed the Firm to capitalize on its in-depth sector knowledge, structuring expertise and problem-solving capabilities. The Firm’s asset selection process emanates from a thorough sector analysis as seen through the lens of

broader macro-economic trends. Kennedy Lewis’ strategy is to first identify sectors that are facing transition or disruption, and the Firm then drills down to understand the forces causing the disruption – regulatory, cyclical, secular related or sparked by innovation. The Firm then evaluate which companies within the affected sector may have an acute need for a capital solution. Lastly, Kennedy Lewis consider the securities and relevant structured capital solution that may best capture the upside through experts analysis and execution. These forces of disruption are not mutually exclusive; often multiple catalysts for disruption are associated with the Firm’s investments. Once Kennedy Lewis identifies a sector in transition, it assesses the cause of that disruption and evaluates the expected duration of those industrial and/or economic forces at the heart of the disturbance. This helps to inform if and to what extent the Firm wants to be invested in the space. It also helps to calibrate what type of risk Kennedy Lewis may be willing to tolerate. Once Kennedy Lewis has thoroughly evaluated the sector, it will seek to identify the contemporary opportunity set that exists within the investable universe of the affected sector. The investment team will then distill its analysis down to finding the best way to exploit its sector view, which includes identifying specific sub-industries and companies. The Firm has found that understanding the causes of the disruption and the expected duration of the transition period, will inform what part of the capital structure the Firm will target for investment. The Credit Opportunity Fund portfolios may consist of, but are not necessarily limited to, leveraged loans, high yield bonds, notes, equity and equity-linked securities, mortgages, liquidation claims, advances, credit derivatives and real assets. Investments may also include other assets or businesses that present an appropriate event-driven or value opportunity. From time to time, the Credit Opportunity Fund portfolios may invest in highly structured investments that are used to fund corporate growth or recapitalize a company. Investments are likely to be in public and private securities or loans of non-investment grade and potentially non-rated issuers. Further, the Funds may make investments in “build-to-rent” investment opportunities. Such “build-to-rent” investments involve the Funds acquiring interests in developments which are constructed for the specific purpose of serving as new single-unit rental properties for tenants. This Item 8 applies to the Credit Opportunity Funds and the KLRES Fund. The Core Lending Funds have a substantially similar strategy to the BDC, which is provided in Item 8 of the Form ADV Part 2A for Kennedy Lewis Capital Holdings LLC. The KLRES Fund portfolio may consist of, but is not necessarily limited to, homebuilder finance investments in the United States, securities issued by the United States Government, cash-flowing real properties located in the United States, mortgage loans and securities backed by commercial or residential real properties, derivative instruments, ISDA agreements and other instruments for hedging or similar purposes. The credit strategy involves substantial risks that should be considered carefully. Certain risk factors that may be considered applicable to the strategy are outlined below. Additional risk factors are outlined in the Governing Documents for the Funds. It should be noted, however, that there may be other risk factors applicable that are not identified but that might still result in material losses. Although Kennedy Lewis may attempt to manage these risks through careful research, ongoing monitoring of investments, and appropriate hedging techniques, there can be no assurance that the securities and other instruments purchased which are the focus of its strategies will increase in value or that the Funds will not incur significant losses. MATERIAL RISKS (INCLUDING SIGNIFICANT OR UNUSUAL RISKS) RELATING TO INVESTMENT STRATEGIES Investment Strategy. The evaluation models and trading techniques used by Kennedy Lewis in implementing the credit strategy may not be successful and may thereby cause the Funds to incur losses on the positions that the Firm initiates. There can be no assurance that transactions will be successful, since their success depends, in part, upon the ability of Kennedy Lewis to predict future changes in market conditions, interest rates and prices of specific securities or assets. In addition, Kennedy Lewis will have broad authority to expand, contract or otherwise change the Funds’ activities. Over time, the strategies

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As previously described, Kennedy Lewis provides investment advice to the Funds, which are pooled investment vehicles, including “funds of one”. Underlying investors in the Funds may include, but are not limited to, institutional investors such as trusts, endowments, foundations, corporates, sovereign wealth funds, pension and profit-sharing plans, as well as high net worth investors. The Firm may also choose to advise separately managed accounts, but is not managing any at this time. The Funds impose minimum investment limits upon investors that can be waived in certain circumstances, as set forth in the Governing Documents.

As disclosed above, in addition to the management fee, Kennedy Lewis or its affiliates are also entitled to receive Carried Interest distributions or the Incentive Allocation from the Funds. The fact that Kennedy Lewis will be compensated, in certain circumstances, based on realized profits may create an incentive for Kennedy Lewis to delay the realization of certain investments or to make investments on behalf of clients that are riskier or more speculative than would be the case in the absence of performance compensation arrangements such as Carried Interest and Incentive Allocation. In addition, certain Kennedy Lewis personnel are compensated on a basis that includes a performance-based component. Kennedy Lewis manages multiple Funds and the Affiliated Advisers manage Affiliated Adviser clients, which creates a conflict of interest because Kennedy Lewis and the Affiliated Advisers may have incentive to allocate potentially more favorable investment opportunities to one Fund or account over another, including without limitation an incentive to favor one Fund or account over another based upon a potentially greater management fee, Carried Interest or Incentive Allocation. To address that risk, Kennedy Lewis has adopted and implemented policies and procedures intended to address conflicts of interest that may arise relating to the management of multiple accounts. These procedures, which are described in more detail in Item 16 below, require that Kennedy Lewis allocate investment opportunities in a fair and equitable manner over time.

The general partner of each Fund is a related entity of Kennedy Lewis. Kennedy Lewis and certain of the general partner entities currently rely on exemptions from registration as commodity pool operators pursuant to U.S. Commodity Futures Trading Commission Regulation 4.13(a)(3). The advisers listed below are affiliated advisers (“Affiliated Advisers”) of Kennedy Lewis: 

KLLM, an investment adviser that manages CLO assets. KLLM and Kennedy Lewis are under common control and share the same physical location and certain supervised persons. Employees of Kennedy Lewis provide services to KLLM pursuant to an intercompany services agreement.

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Kennedy Lewis Advisors (Switzerland) SARL, a relying investment adviser of Kennedy Lewis which is based in Geneva, Switzerland. Kennedy Lewis Advisors (Switzerland) SARL and Kennedy Lewis are under common control and share certain supervised persons.

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Kennedy Lewis Residential Property Income Advisors LLC, which serves as investment adviser to Kennedy Lewis Residential Property Income Company LP, is a relying investment adviser of Kennedy Lewis. Kennedy Lewis Residential Property Income Advisors LLC and Kennedy Lewis are under common control and share the same physical location and certain supervised persons.

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Kennedy Lewis Capital Holdings LLC, which serves as investment adviser to the BDC. Kennedy Lewis Capital Holdings LLC and Kennedy Lewis are under common control and share the same physical location and certain supervised persons. Kennedy Lewis has entered into a resource sharing agreement (“Resource Sharing Agreement”) with Kennedy Lewis Capital Holdings LLC, pursuant to which Kennedy Lewis makes certain personnel and resources available to Kennedy Lewis Capital Holdings LLC to provide certain investment advisory services to the BDC.

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Kennedy Lewis Land and Residential Advisors (“KLLARA”) is an affiliate of Kennedy Lewis that is the external manager to Millrose Properties, Inc. (“Millrose Properties”), which invests in homebuilder finance opportunities. Homebuilder finance opportunities are the focus of the strategy of the KLRES Fund and a component of the strategy of the Credit Opportunity Funds. Please see Item 16 below regarding Kennedy Lewis’ allocation policy.

Kennedy Lewis Broker-Dealer is a SEC and FINRA-registered broker-dealer. Kennedy Lewis BrokerDealer and Kennedy Lewis are under common control and share the same physical location. Certain supervised persons of Kennedy Lewis also hold positions at Kennedy Lewis Broker-Dealer. Pooled investment vehicles managed by Petershill at Goldman Sachs Asset Management hold a minority passive interest in Kennedy Lewis and certain affiliated entities. Conflicts of Interest. There are numerous perceived and actual conflicts of interest among and between Kennedy Lewis, the Affiliated Advisers, its affiliates, the Funds, Affiliated Adviser clients and the Kennedy Lewis BrokerDealer. The conflicts of interest that may be relevant to the Funds include those discussed below, although such discussion does not describe all of the conflicts that may be faced by Kennedy Lewis. Dealing with conflicts is complex and difficult, and new and different types of conflicts are likely to subsequently arise. If any matter arises that Kennedy Lewis determines in its good faith judgment constitutes an actual conflict of interest, Kennedy Lewis may take such actions as it determines in good faith may be necessary or appropriate to ameliorate the conflict. These actions may include, by way of example and without

limitation, (i) disposing of the security giving rise to the conflict of interest, (ii) appointing an independent fiduciary to act with respect to the matter giving rise to the conflict of interest, (iii) consulting with the relevant LP advisory committee regarding the conflict of interest and either obtaining a waiver from the LP advisory committee of such conflict of interest or acting in a manner, or pursuant to standards or procedures, approved by the LP advisory committee with respect to such conflict of interest, (iv) creating groups of personnel within Kennedy Lewis and the Affiliated Advisers separated by information barriers (which may be temporary and limited purpose in nature), each of which would advise or represent one of the advisory clients of the Firm and relevant Affiliated Advisers that has a conflicting position with other advisory clients of the Firm and relevant Affiliated Advisers, and (v) implementing other policies and procedures (which may be specific to one or more investments) reasonably designed to mitigate the conflict of interest. In most cases, however, the resolution of the conflict will depend entirely on the exercise of the discretion of the Firm, in light of relevant facts and circumstances at the time, including the immediate and longerterm interests of the relevant advisory clients. The specific weight ascribed to each of the relevant factors is a subjective judgment about which reasonable people may differ, and, with respect to the advisory clients of the Kennedy Lewis such judgments will remain in the complete discretion of Kennedy Lewis. Investments in the Same Portfolio Company. One Fund or Affiliated Adviser client may, from time to time, make an investment in a portfolio company in which another Fund has previously invested, or subsequently invests, in a different part of the portfolio company capital structure and vice versa. For example, one Fund could make a loan to a portfolio company, or otherwise invest in a senior security of a portfolio company, where another Fund has already invested in the equity of the portfolio company or subsequently does so. In making an investment from a Fund in a portfolio company in which another Fund already holds an investment, Kennedy Lewis may be subject to a conflict of interest as the terms of the investment may have an impact on the value of the portfolio company and therefore the value of the existing investment. In addition, there may be instances where such a portfolio company may become insolvent or bankrupt and where one Fund’s interest in the portfolio company conflicts with another’s interest. If one Fund holds an interest in a portfolio company with rights, preferences and privileges that are different than those held by another Fund in the same portfolio company, Kennedy Lewis could be presented with decisions when the interests of the Funds are in conflict. It is possible that, in a bankruptcy proceeding, out-of-court restructuring or other corporate action, one Fund’s interest ends up subordinated or otherwise adversely affected by virtue of another Fund’s investment and actions relating to its investment. Similar conflicts can arise in determining the terms of investments or if or when to exercise rights associated with investments. Decisions about what action should be taken in a troubled situation, including whether or not to enforce claims, whether or not to advocate or initiate a restructuring or liquidation inside or outside of bankruptcy, and the terms of any work-out or restructuring raise conflicts of interest. If additional capital is necessary as a result of financial or other difficulties, or to finance growth or other opportunities, a Fund that invested in the portfolio company may not be in a position to make a further investment due to where it is in its life cycle or for some other reason. Another Fund may or may not provide the additional capital, and if provided such Fund will supply the additional capital in such amounts, if any, as determined by Kennedy Lewis. Kennedy Lewis’ incentives with respect to the Funds in those cases may differ and even conflict. Use of Consultants. Kennedy Lewis may use individuals as consultants or advisors who are not employees of the Firm, but are compensated for services provided to the Fund, other advisory clients of Kennedy Lewis or Affiliated Advisers and/or portfolio investments, including, without limitation, persons who provide are investment advisers not affiliated with Kennedy Lewis or provide similar services (“Consultants”). There is an incentive for Kennedy Lewis to engage or employ such persons and persons performing activities that might otherwise be performed by Kennedy Lewis-employed investment professionals (rather than Kennedy Lewis-employed investment professionals) so that any compensation paid to such persons (as described more fully below) is an expense of the Funds, other advisory client of the Kennedy Lewis or Affiliated Advisers or a portfolio investments, as applicable, and not Kennedy Lewis. The terms of engagement, including the compensation arrangements for Consultants are generally

agreed between the Consultant and Kennedy Lewis (or one of its affiliates or portfolio investments) at the time of engagement and vary depending on the nature of the services provided. In addition to retainers, periodic fees and the reimbursement of expenses, Consultants may receive compensation arrangements from portfolio investments composed of a discretionary performance-related bonus, grants of equity and/or co-investment opportunities in the portfolio investments in which such individual serves directly as a consultant or adviser and may receive directors’ fees, consulting fees and other compensation from portfolio investments determined by Kennedy Lewis and/or the portfolio company. These fees and expenses may be allocated to the Fund (or other advisory clients of Kennedy Lewis or Affiliated Advisers) or portfolio companies that benefit from the service. Further, consultants may be eligible to invest in the Funds on a no fee, no carry basis. Although Kennedy Lewis seeks to retain Consultants with a view to reducing costs to portfolio companies (and ultimately, the Funds and/or other advisory clients of the Firm or Affiliated Advisers) and/or improving portfolio investment performance, a number of factors may result in limited or no cost savings from such retention. Unconsummated Transaction Expenses. As discussed above in Item V (Fees and Expenses), the Funds will bear expenses incurred in connection with transactions intended for the Funds. This applies if the investment is closed, as well as if the investment is not ultimately consummated, including, without limitation all expenses incurred in pursuit of an investment that upon initial review appeared to meet a Fund’s investment guidelines and that the Fund undertook efforts in furtherance of investing in, but which did not become an investment of the Fund. Examples of such unconsummated transaction expenses include, but are not limited to, due diligence expenses, commitment fees that become payable in connection with a proposed investment that is not ultimately made; legal, tax, accounting, financing, advisory, and consulting fees and expenses; travel, accommodation and related expenses; transaction fees; brokerage commissions; litigation expenses; printing expenses; any liquidated damages; reverse termination fees and similar payments. In instances where co-investors or joint venture partners have not yet committed to a proposed co-investment or joint venture, a Fund may bear all of the unconsummated transaction expenses. The financial position of the Funds and other relevant advisory clients of Kennedy Lewis or Affiliated Advisers may give Kennedy Lewis or its affiliates an incentive to allocate such fees and expenses to the Funds over another advisory client of the Firm or vice versa. For example, it would be advantageous to allocate expenses from unconsummated expenses to an advisory client that is not expected to pay carried interest to its general partner, as the fees and expenses would not affect the amount of carried interest paid—it would be zero in any case; a similar incentive could arise where an advisory client of Kennedy Lewis is paying carried interest at a lower rate than other advisory clients of the Firm. Conversely, it typically would be disadvantageous as an economic matter to allocate transaction expenses from unconsummated transactions to an advisory client of Kennedy Lewis that is paying carried interest, as doing so would delay and reduce the amount of carried interest paid to the relevant general partner. Co-Investments. As discussed above in Item 16 (Investment Discretion), co-investment vehicle may be established to make parallel investments with the Funds and other advisory clients of Kennedy Lewis in certain investment opportunities, provided that the general partner or managing member of such Funds has determined it is not prudent for the Funds to make the portion of the investment being offered to the coo-investment vehicles. For example, Kennedy Lewis may determine that the size of an available investment opportunity being considered by the Funds meaningfully exceeds the amount that is appropriate for the Funds. Kennedy Lewis may, but is not obligated to, provide co-investment opportunities to other parties other than the co-investment vehicle and parallel accounts on such terms and conditions as determined by the Firm in its sole discretion. Certain advisory clients of Kennedy Lewis and investors in other pooled vehicles advised by Kennedy Lewis or an Affiliated Adviser have also been granted rights to coinvestment opportunities in accordance with their governing documents. Kennedy Lewis will determine the person(s) to whom it offers any such opportunity, and the relative amounts offered to each such person, taking into account such factors as Kennedy Lewis determines appropriate based on the relevant facts and circumstances, which may include one or more of the

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Code of Ethics. Kennedy Lewis has adopted and implemented a code of ethics (the “Code of Ethics”) pursuant to Rule 204A-1 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), which requires Kennedy Lewis and its employees to put the interests of the Funds and any other Firm clients before their own interests and to act honestly and fairly in all respects in the Funds and any other dealings with its clients. The Code of Ethics also requires all employees to comply with applicable federal securities laws. The Code of Ethics describes rules surrounding personal securities transactions and applies to all Kennedy Lewis’ employees and to any other person who is deemed to be an “access person” (all such employees and other persons are referred to as “access persons”). Access persons are required to report certain personal securities transactions and holdings. Those personal securities transactions may raise potential conflicts with the interests of Kennedy Lewis’ clients. To mitigate potential conflicts of interest, Kennedy Lewis requires its access persons to pre-clear their personal transactions in any investments involving initial public offerings, private placements, as well as other “reportable securities” as defined in Rule 204A-1 under the Advisers Act. The Firm, however, allows its access persons to trade exchange traded funds and exchange traded notes, as well as other securities that are not “reportable securities” without a prior written approval. The Code of Ethics also provides guidance for Kennedy Lewis employees regarding (i) engaging in activities outside of Kennedy Lewis’ business; (ii) documenting close personal or family relationships; and (iii) giving and receiving business related gifts and providing and receiving entertainment. A copy of the Code of Ethics may be obtained by contacting the Chief Compliance Officer whose contact information is set forth on the cover of this Brochure. Investing in Securities Recommended to Clients. Kennedy Lewis and its affiliates, as well as certain of Kennedy Lewis’ employees may, and currently do, invest in the Funds, and, accordingly, will share any profits and losses generated by the Funds’ investments. Furthermore, in certain situations, related persons of Kennedy Lewis may purchase interests in the same investments held by the Funds, subject to pre-clearance and other Code of Ethics requirements. Conflicts of interest may arise if Kennedy Lewis or its employees recommend a particular transaction because of a financial interest held by any such person in such securities or interests. Such investments pose a risk that Kennedy Lewis will favor one or more Funds in which an investment is maintained. Transaction in Securities where Kennedy Lewis has a Material Financial Interest. As described above, Funds advised by Kennedy Lewis from time to time, invest in the equity of CLOs managed by KLLM or the BDC. Such investments do pose conflicts of interest. The Funds shall invest in CLOs managed by KLLM if and only when the investment committee has concluded that such investment is superior opportunity to other opportunities in the market and that it is the Fund’s interest to invest in such CLO. The Funds will not be charged a management fee in connection with any investment in KLLM-managed CLOs. As described above in Item 5, there is no management fee or performance compensation paid at the Core Lending Fund-level with respect to amounts invested in the BDC. See the discussion above in Item 10 for information on the anticipated activities of the Kennedy Lewis Broker-Dealer, including activities which would result in the Kennedy Lewis Broker-Dealer receiving Broker-Dealer Fees from a portfolio company or borrower of a Fund.

Insider Trading Policy. Kennedy Lewis, its Affiliate Advisers or their respective related persons, in the course of their investment management and other activities, may come into possession of confidential or material nonpublic information about issuers, including issuers in which Kennedy Lewis, its affiliates or their respective related persons have invested or seek to invest on behalf of the Funds or other clients. Kennedy Lewis is prohibited from improperly disclosing or using such information for its own benefit or for the benefit of any other person, regardless of whether such other person is a Fund. Kennedy Lewis maintains and enforces written policies and procedures that prohibit the communication of such information to persons who do not have a legitimate need to know such information and to assure that Kennedy Lewis is meeting its obligations to the Funds and remains in compliance with applicable law. In certain circumstances, Kennedy Lewis may possess certain confidential or material, nonpublic information that, if disclosed, might be material to a decision to buy, sell or hold a security or financial instrument, but Kennedy Lewis will be prohibited from communicating such information to the Funds or using such information for the Funds’ benefit. In such circumstances, Kennedy Lewis will have no responsibility or liability to the Funds for not disclosing such information to the Funds (or the fact that Kennedy Lewis possesses such information), or not using such information for the Funds’ benefit, as a result of following its policies and procedures designed to provide reasonable assurances that it is complying with applicable law.

As investment adviser to the Funds, Kennedy Lewis has been granted the discretionary authority in the relevant Governing Documents and/or investment management agreements to determine which securities and what quantities of such securities are to be bought or sold. For transactions in which the services of a broker-dealer are deemed to be necessary or beneficial, Kennedy Lewis is also authorized to select the broker-dealer to be used and the commission rates to be paid, provided that where the Governing Documents permit the Fund to retain the Kennedy Lewis Broker-Dealer, the LP advisory committee of the Fund or the Fund is required to approve the direct payment of Broker-Dealer Fees by the Fund. Subject to the Governing Documents, Kennedy Lewis may execute trades with other unaffiliated brokers and dealers with whom the Fund has other business relationships, including prime brokerage and credit relationships or with broker-dealers that have invested, either directly or through affiliates, in a Feeder Fund or its affiliates or as described above in Item 10. Broker Selection and Best Execution. Kennedy Lewis is authorized to determine the broker-dealer to be used for each applicable securities transaction for the Funds. In selecting broker-dealers to execute transactions, Kennedy Lewis is not required to solicit competitive bids and does not have an obligation to seek the lowest available pricing. Kennedy Lewis may not always select a broker-dealer based on the best price, but will take into account a number of qualitative and quantitative factors. In selecting broker-dealers and negotiating compensation arrangements, Kennedy Lewis will typically take into account a range of factors, including, without limitation: transacting parties’ ability to source investments in a responsible and efficient manner, historical net prices (after markups, markdowns and other transaction-related compensation); transacting parties’ execution, clearance, and settlement and error correction capabilities generally and in connection with instruments of the type and in the amounts to be bought or sold; their willingness to commit capital; their reliability and financial stability; the size of the transaction; the availability of securities to borrow for short sales; the market for the instrument in question; and the nature, quantity, and quality of research and other services and products the transacting party provides. Kennedy Lewis may place transactions with a brokerdealer that (i) provides the Firm with the opportunity to participate in capital introduction events sponsored by the broker-dealer or (ii) refers clients or limited partners to other products advised by Kennedy Lewis, if otherwise consistent with seeking best execution, provided Kennedy Lewis is not selecting the brokerdealer in remuneration of the opportunity to participate in such capital introduction events or the referral of clients or prospective limited partners. Clients may at times pay more than the lowest transaction cost available in order to obtain services and products other than the execution of securities transactions. Soft Dollars. Kennedy Lewis has not entered into, and currently does not intend to enter into, any formal soft dollar arrangements but may receive products or services from broker-dealers and other counterparties that to the best of Kennedy Lewis’ knowledge are generally made available to all institutional clients doing business with these counterparties. These products and services are made available to Kennedy Lewis on an unsolicited basis and without regard to transaction costs paid by the Funds or the volume of business Kennedy Lewis directs to these counterparties.

Kennedy Lewis compensates third-party solicitors or other promoters for referrals of private fund investors. Kennedy Lewis’ arrangements with third-party solicitors or other promoters may vary. Any compensation paid pursuant to these arrangements creates an incentive for the third-party solicitor or other promoter to recommend Kennedy Lewis, resulting in a material conflict of interest. An affiliate of a Fund portfolio company has been retained by Kennedy Lewis to place interests in one or more Kennedy Lewis-managed private funds. Affiliates of the Fund portfolio company may also place investors in a fund managed by a Kennedy Lewis Affiliate Advisor and may receive a profits interest in a Kennedy Lewis Affiliated Advisor.

This Item is not applicable.

Positions held by Kennedy Lewis’ Funds will be continuously monitored and reviewed by the investment advisory personnel of Kennedy Lewis. Accounts will also be subject to regular reviews in the context of the Funds’ stated investment objectives and guidelines. Additional reviews may be triggered by material changes in variables such as the Funds’ or individual circumstances, or the market, political or economic environment. Limited partners will be provided a quarterly performance report by Kennedy Lewis and a quarterly capital statement by the Funds’ administrator.

Kennedy Lewis and its affiliated general partners are deemed to have custody of the assets of the Funds and intend to comply with Rule 206(4)-2 under the Advisers Act by meeting the conditions of the pooled vehicle annual audit provision.

Kennedy Lewis has discretionary authority to manage securities accounts on behalf of the Funds. As investment adviser to the Funds, Kennedy Lewis has generally been granted discretionary authority in the relevant Governing Documents to determine which securities, and what quantities of such securities, are to be bought or sold, as well as the broker-dealer to be used and the commission rates to be paid, if any. Kennedy Lewis has adopted and implemented policies and procedures relating to the allocation of investment opportunities (including but not limited to land banking investments) between and among the Funds and other clients. As mentioned above, Kennedy Lewis is required to provide fair and equitable treatment to the Funds and any other client account which shares similar investment mandates and guidelines. However, because of differences in account size, account ramp-up or liquidation status, cash considerations, tax restrictions, regulatory restrictions, specific investment guidelines, liquidity and other considerations, it is expected that the Funds may not necessarily participate in, or will receive, a pro rata share of every investment opportunity. To the extent that Kennedy Lewis, its Affiliated Advisers or certain of the Funds are presented with land banking investment opportunities, such investments are required to be allocated in accordance with certain policies and procedures as described in Millrose Properties’s Form S-11. Securities and other investment opportunities acquired through a limited offering and illiquid securities will be allocated in accordance with the procedures set forth in Kennedy Lewis’ allocation policy. To the extent that the Funds are investing alongside the BDC, the arrangements will be required to be in accordance with the exemptive relief granted by the SEC which applies to the BDC and the Funds. The exemptive relief enumerates various conditions that need to be followed by the Funds, the BDC and Kennedy Lewis. Co-Investment Kennedy Lewis may determine that the size of an available investment opportunity being considered by one or more of the Funds meaningfully exceeds the amount that is appropriate for the Fund (taking into consideration the relevant provision of the Fund’s Governing Documents). Kennedy Lewis may form one or more co-investment vehicles specifically to take up such excess opportunity and may offer one or more persons (including, but not limited to, investors in the relevant Fund or consultants) the opportunity to participate in such co-investment vehicles. In this regard, Kennedy Lewis manages KLCP Co-Investment Opportunities III LP (“Co-Invest”), which was established to make co-investments in parallel with Fund III. Certain Funds also have been granted rights to co-investment opportunities in accordance with their Governing Documents. Kennedy Lewis will determine the person(s) to whom it offers any such opportunity, and the relative amounts offered to each such person, taking into account such factors as Kennedy Lewis determines appropriate based on the relevant facts and circumstances, which may include one or more of the following: (i) the ability of an investor to commit to invest in a short period of time, in light of the timing constraints applicable to such investment; (ii) the ability of an investor to commit to a significant portion of such opportunity; (iii) whether an investor provides strategic value in respect of such investment, such as by having relevant experience in the sector or existing relationships with management or other relevant parties; (iv) the size of an investor’s commitment to the Fund; (v) whether and to what extent an investor has accepted prior co-investment opportunities offered to it; or (vi) such other factors as Kennedy Lewis deems relevant, which may include subjective determinations such as working relationships and strategic benefits

to Kennedy Lewis or to the Funds. In all cases, allocation of co-investment opportunities will be subject to the provisions of the Governing Documents of the relevant Fund. The management of Co-Invest, and other Funds with co-investment rights, by Kennedy Lewis creates a conflict of interest in that Co-Invest and such other Funds may benefit from due diligence conducted by Fund(s) without co-investment rights and transaction cost that is allocated to the Fund(s). In addition, CoInvest, and other Funds with co-investment rights, will not necessarily be allocated Unconsummated Transaction Expenses. From time to time, Kennedy Lewis may form special purpose vehicles (“SPVs”) to acquire illiquid investments on behalf of multiple Clients where direct ownership is impracticable. No fees or material costs are incurred by use of these SPVs, except as otherwise disclosed in the Governing Documents of the KLRES Fund. Cross Transactions. Kennedy Lewis may effect cross transactions between the Funds and Affiliated Adviser clients accounts, except as otherwise noted below. Cross transactions enable Kennedy Lewis to effect a trade between two Funds for the same security at a set price, thereby possibly avoiding an unfavorable price movement that may be created through entrance into the market and saving commission costs for both accounts. Kennedy Lewis has a potentially conflicting division of loyalties and responsibilities regarding both parties to cross transactions, including with respect to a decision to enter into such transactions and with respect to valuation, pricing and other terms. Because Kennedy Lewis represents the interests of both the seller and the buyer in a cross transaction, the Funds or other clients for which Kennedy Lewis executes cross transactions bear the risk that other Funds or clients in the cross transaction will be treated more favorably, especially where the other party pays a higher investment management or performance compensation. The Funds also bear the risk that the price of a security bought or sold through a cross transaction may be less favorable than it might have been had the transaction been executed in the open market, the risk that they receive a security that is difficult to dispose of in a market transaction. Kennedy Lewis will only engage in a cross transaction between the Funds or other clients when Kennedy Lewis has determined that the cross transaction is in the best interest of each client. Cross transactions between the Fund or other client accounts are not permitted if they would constitute principal trades unless consent has been obtained or trades for which the Firm or its affiliates are compensated as a broker. In certain circumstances Kennedy Lewis is required to obtain a consent from the Funds’ investment advisory committee. In addition to the cross transactions described above, subject to the Governing Documents, Kennedy Lewis may also engage in agency cross transactions between Funds and an unaffiliated third party in a manner consistent with the Advisers Act and the rules promulgated thereunder. In an agency cross transaction, the Kennedy Lewis Broker-Dealer execute securities trades for brokerage customers in which advisory client securities are sold to or bought from the brokerage customer. As noted above in Item 12, where the Governing Documents permit the Fund to retain the Kennedy Lewis Broker-Dealer, the LP advisory committee of the Fund or the Fund is required to approve the direct payment of Broker-Dealer Fees by the Fund Trade Errors. Kennedy Lewis has adopted and implemented trade processes and procedures designed to reduce the likelihood of errors. If it appears that a trade error has occurred, Kennedy Lewis will review the relevant facts and circumstances to determine an appropriate course of action. To the extent that trade errors occur, the Kennedy Lewis’ error correction procedure is to ensure that clients are treated fairly. Kennedy Lewis

has discretion to resolve a particular error in any manner that it deems appropriate and consistent with the above stated policy. Kennedy Lewis’ general policy will seek to identify and correct any trade errors promptly and in a way that mitigates any losses. Trade errors in a Fund will be borne by the Fund unless an error is the result of gross negligence, willful misconduct or violation of applicable laws by Kennedy Lewis. To the extent that the ERISA fiduciary standard applies to trading in a Fund’s accounts, in the event of a trade error, such Fund will not bear any losses, and will keep any gains.

In accordance with its fiduciary duty to clients and Rule 206(4)-6 under the Advisers Act, Kennedy Lewis has adopted and implemented written policies and procedures governing the voting of client securities. All proxies that Kennedy Lewis receives will be treated in accordance with these policies and procedures. Proxies must be voted with diligence, care, and loyalty. Kennedy Lewis votes each proxy in accordance with its fiduciary duty to its clients and Affiliated Adviser clients. Kennedy Lewis seeks to vote proxies in a way that maximizes the value of Fund assets. Each proxy vote is ultimately cast on a case-by-case basis, as Kennedy Lewis considers the contractual obligations under Governing Documents and investment management agreements, and all other relevant facts and circumstances at the time of the vote. Kennedy Lewis will abstain from voting or affirmatively decide not to vote if Kennedy Lewis determines that abstention or not voting is in the best interests of the client. In making this determination, Kennedy Lewis will consider various factors, including, but not limited to, (i) the costs associated with exercising the proxy (e.g., translation or travel costs); and (ii) any legal restrictions on trading resulting from the exercise of a proxy. If a material conflict of interest between Kennedy Lewis and a Fund exists, Kennedy Lewis will determine whether voting in accordance with the guidelines set forth in its proxy voting policies and procedures is in the best interests of a Fund or take some other appropriate action. Clients may obtain a copy of Kennedy Lewis’ proxy voting policies and procedures and information about how Kennedy Lewis voted a client’s proxies by contacting submitting a request to the Chief Compliance Officer, whose contact information can be found on the cover page of this brochure.

This Item is not applicable.