Khrom Capital Management LLC

Khrom Capital was founded in 2008 and is owned 25% or more by Eric Khrom. Khrom Capital GP, LLC serves as the general partner of the Company and is owned 25% or more by Eric Khrom. As of December 31, 2025, the Company managed approximately $981 million of regulatory assets under management on a discretionary basis on behalf of one client. Khrom Capital provides discretionary investment advice and management services to a private investment fund (“private fund”) each a “client” and collectively the “clients”, which may be organized as onshore limited partnership (“Partnership”) or offshore company or other types of vehicles. Khrom Capital’s private fund conducts trading activities through a mini-master structure. In a mini-mater structure, a Cayman Islands based fund contributes its investible assets into Khrom Investments Fund, LP and participates on a pro rata basis in the profits and losses of Khrom Investments Fund, LP and bears a pro rata portion of the expenses of Khrom Investments Fund, LP, based on the respective capital account balances of all parties investing in Khrom Investments Fund, LP.

An affiliate of Khrom Capital serves as the general partner to Khrom Investments Fund, LP and affiliates of Khrom Capital serve as directors of the offshore feeder fund. The private fund is managed only in accordance with its own investment objectives and is not tailored to any particular private fund investor (each an “investor”). Khrom Capital currently manages one private fund. The Fund employs a fundamental value strategy, in which Khrom Capital seeks to invest as much as possible in stocks (or other instruments) of companies that Khrom Capital knows well and whose shares it believes offer above average rates of return for investors. To a lesser extent and primarily during periods in which the research does not turn up favorable investment candidates, Khrom Capital may invest in investment grade bonds, U.S. government securities, or money market instruments. Khrom Capital will not invest in securities under its fundamental value strategy merely for the sake of investing. If the Khrom Capital feels that the market does not offer significant attractive opportunities, then a large portion of the Partnership's funds may be invested in the aforementioned low‐risk or risk‐free assets until Khrom Capital sees an opportunity to invest in securities with higher potential returns. Since Khrom Capital does not provide individualized advice to the investors in the private fund, investors must consider whether a particular private fund meets their investment objectives and risk tolerance prior to investing. Information about the private fund can be found in its offering documents, including its Private Placement Memorandum (“PPM”). However, the private fund relies on certain registration exclusions available under the Investment Company Act of 1940, as amended (“IC Act”) and exemptions available under the Securities Act of 1933, as amended (“Securities Act”). Therefore, this brochure is designed solely to provide information about Khrom Capital and should not be considered an offer of interest in any Khrom Capital private fund. Any such offer may only be made by delivery to the prospective investor of the PPM for the private fund under consideration. Khrom Capital currently provides advice to a private fund but reserves the right to provide advice to other types of clients.

Khrom Capital and/or the applicable general partner of the clients have the authority to (1) deduct management and performance-based fees from the assets of the clients, and (2) authorize the payment or reimbursement of other fees or expenses to third parties from the assets of the clients. Management Fees Khrom Capital’s clients and consequently the underlying investors, incur an annual management fee of 1.0%. The management fee is charged monthly, in advance. If the applicable general partner allows an investor in a private fund to withdraw capital from the private fund prior to the end of a quarter, the investor incurs a pro-rated management fee for the period in which the withdrawn assets remained invested in the private fund. Finally, Khrom Capital charges reduced or no management and/or performance-based fees to Khrom Capital, its affiliates, current and former employees and their family members, and current and former consultants. Khrom Capital has no obligation to disclose the specific details of such

arrangements or to offer such additional rights, terms, or conditions to all investors. Performance-Based Fees Please see the “Performance-Based Fees and Side-by-Side Management” section. Expenses Khrom Capital and/or the applicable general partner of the clients are authorized to incur expenses on behalf of the clients; when this occurs, the appropriate client reimburses Khrom Capital and/or the applicable general partner in the amount of such expenses. The applicable general partner or Khrom Capital will be responsible for certain ordinarily recurring and other reasonable expenses of the clients such as rent, travel (except for travel related to the Private Fund Investments 1), supplies, secretarial expenses, charges for furniture and fixtures, telephone, stationery, employee insurance, payroll taxes, compensation of the general partner’s professional and administrative personnel. The clients shall be responsible for all their expenses, other than Overhead Expenses, including expenses for investments specific to the relevant client. The Company shall be authorized to incur and pay all expenses on behalf of the clients in connection with the client’s business which it deems necessary or desirable, and to charge or to be reimbursed by the clients for those expenses. The clients may share certain expenses. The Fund and the Offshore Fund bear their own expenses including, but not limited to, transaction and trading-related expenses (e.g., commissions and brokerage charges, other prime brokerage fees, clearing and settlement charges, interest expenses, expenses relating to short sales, stock borrow fees, financing expenses, data services, investment bankers, appraisers, bank service fees and related transactional expenses) 2; order management systems, as well as other analytical systems; compensation payable to research consultants engaged to evaluate or appraise particular investments; all research-related expenses with respect to potential and actual investments; all travel-related expenses (including first-class or business-class travel) incurred in connection with Private Portfolio Investments only; appraisals for Private Portfolio Investments and any other difficult to value investments; news and quotation equipment and services (including Bloomberg and similar subscriptions); systems and software used in connection with the operation of the private fund and investment related activities; costs associated with shareholder engagement of portfolio companies, such as expenses related to event hosting and production, public presentations, websites, public relations and public affairs, government relations, consultants, forensic and other analyses, investigations, litigation, proxy contests, solicitations, tender offers, and any expenses of director or executive nominees proposed by the Company; defending the private fund (or the Company, the applicable general partner or any other indemnified party) against any threatened or actual litigation associated with any potential or actual investments; any other legal fees related to the investment activities of the private fund, including potential or actual investments of the private fund; legal expenses related to potential or actual government or regulatory actions with respect to A private fund investment is an entity created to pool money from multiple investors—often referred to as limited partners. Each investor makes an investment in the fund by purchasing an interest in the fund entity, and the adviser uses that money to make investments on behalf of the fund. Please see the “Brokerage Practices” section below for further information about Khrom Capital’s brokerage practices and other trading-related matters.

the private fund (including but not limited to expenses relating to regulatory or similar investigations, inquiries, “sweeps,” and any resulting fines and any litigation or threatened litigation); expenses related to the Fund and Khrom Capital’s regulatory filings (e.g., expenses related to the Company’s or any of its affiliates’ registration with the Securities and Exchange Commission or any international regulatory body or regime, such as expenses incurred in connection with preparing and updating Form ADV, Form PF, blue sky, Hart-Scott-Rodino, Sections 13 and 16 of the Securities Exchange Act of 1934, as amended, the Financial Instruments and Exchange Act , the Foreign Exchange and Foreign Trade Act, as amended, and other applicable law, non-U.S. and other corporate filing fees and expenses) made in connection with the private fund’s business and other regulatory expenses; taxes (including but not limited to partnership taxes); organizational expenses and initial and ongoing offering expenses (including legal fees); governmentally imposed expenses; administrative expenses; custodians, and any other applicable regulations and any ongoing costs associated with such filings, expenses of and relating to any Alternative Investment Fund Managers; any expenses incurred through investments in partnerships or other entities (including registered investment companies) engaged in investment activities; directors expenses and other similar expenses; accounting expenses (including third party accounting services, if any), audit (including custody audit, if any) and tax preparation expenses (including preparation costs of financial statements, tax returns and reports to private fund investors); any and all fees and expenses relating to representation by the tax matters partner or the partnership representative, as applicable, of the relevant private fund and the private fund investors; expenses to which the indemnification provisions of the relevant governing document apply; the general partner’s Directors & Officers and Errors & Omissions insurance and Cyber Security Insurance policies; the costs of such insurance as may be obtained to provide for the protection of the clients and indemnified parties against claims covered by the indemnification provisions of the relevant governing document (except as otherwise provided in such agreement); the cost of the Investment Managers’ compliance program management fee; other ordinary and extraordinary expenses associated with the operation of the private fund; and any other similar expenses to those described above. For the avoidance of doubt, “similar expenses” refers to any expenses that are similar in type and nature to the expenses described above. Further information with respect to the fees and other expenses incurred by the client, and ultimately the underlying investors, can be found in each client’s governing document. Private Fund Withdrawal Rights and Associated Fees Khrom Capital and/or the applicable general partner of the private fund have the authority to allow withdrawals other than at the time periods specified in each private fund’s PPM. If Khrom Capital and/or the applicable general partner of the private fund allow an investor in a private fund to withdraw capital from the private fund prior to the end of a quarter, the investor, in the case of any private fund subject to a management fee, incurs a pro-rated management fee for the period in which the withdrawn assets remained invested in the Fund as applicable. The applicable private fund’s general partner reserves the right to waive the applicable notice period and/or allow other than annual withdrawals for certain current and former Khrom Capital employees and their family members. Additionally, the applicable general partner is not subject to lockup periods with respect to its interests in the private fund. Any investor that makes a withdrawal from a private fund will not be able to withdraw that portion of

its capital account that is in Private Portfolio Investments (please see definition below under “Types of Investments”) until such Private Portfolio Investments are liquidated, determined by the applicable general partner to no longer be Private Portfolio Investments, or otherwise allowed at the discretion of the applicable general partner. In addition, the applicable general partner may, in its sole discretion, reserve and withhold from distribution a reasonable estimate of expenses due with respect to such withdrawing investor’s capital account. Side Letters Khrom Capital has entered into side letter agreements with certain investors granting them, among other things, greater portfolio transparency, additional rights to reports, reductions in fees, and more favorable redemption rights in comparison to the standard investment terms applicable to other investors per the disclosures in each private fund’s PPM. Side letter agreements may also include key person provisions, restrictions with respect to permitted investment sectors and limit certain investment activities as well as the allocations of Private Portfolio Investments. In addition to the foregoing, the General Partner shall be authorized to enter into one or more side letter agreements with any Limited Partner (without notice to or consent of any other Limited Partner) in order to implement or document the exercise of the General Partner's discretionary authority under any provision of the Partnership Agreement, or to modify the terms of the Partnership Documents with respect to such affected Limited Partner. Such side letter agreements may result in certain Limited Partners receiving preferred terms regarding fees, liquidity, reporting or access to information, notices of certain events, or other investment terms in comparison to the terms governing the investment of other Limited Partners. Accordingly, Limited Partners who have side letter agreements may be deemed to hold a different class of Interests than other Limited Partners. In particular, the General Partner may, in its sole discretion, waive or reduce the Incentive Allocation charged to any Limited Partner, or otherwise agree with such Limited Partner to vary the terms of such fee or allocation. The General Partner has entered into side letter agreements with certain Limited Partners. Khrom Capital has no obligation to disclose the specific details of such arrangements or to offer such additional rights, terms, or conditions to all investors.

Investment Strategy The Partnership will be structured as a long‐biased portfolio, consisting mostly of domestic and international common stock, although it will also invest in other equity securities or securities convertible into equity securities (e.g., preferred stocks, convertible bonds, convertible preferred stocks, options, warrants, etc.). The Partnership will take short positions, from time to time, on an opportunistic basis as part of a tax strategy, however the Partnership's investment portfolio is expected to be composed primarily of long positions. The primary strategy of the Partnership consists of its fundamental value strategy, in which the Partnership seeks to invest as much as possible in stocks (or other instruments) of companies that Khrom Capital knows well and whose shares it believes offer above average rates of return for investors. To a lesser extent and primarily during periods in which Khrom Capital's research does not turn up favorable investment candidates, Khrom Capital may invest in investment grade bonds, U.S. government securities, or money market instruments. Khrom Capital will not invest in securities under its fundamental value strategy merely for the sake of investing. If Khrom Capital feels that the market does not offer significant attractive opportunities, then a large portion of the Partnership's funds will be invested in the aforementioned low‐risk or risk‐free assets until Khrom Capital sees an opportunity to invest in securities with higher potential returns. In selecting equity securities for this strategy, Khrom Capital seeks to identify companies that it understands well and that possess certain characteristics. Essentially, Khrom Capital attempts to identify companies whose stocks, in its analysis, are trading at a substantial discount to the company's intrinsic value. Khrom Capital determines a company's intrinsic value by examining various characteristics including durable and sustainable competitive advantages of the business, its cash flow generation potential, the growth of those cash flows, the potential return on capital the company can achieve when it reinvests earnings, and executive management's track record and incentive structure, amongst other variables. Khrom Capital assesses these and other important metrics by analyzing companies from the "bottom‐up" – scouring available regulatory filings, financial statements, and industry journals. In implementing this strategy, the Partnership usually invests in stocks or bonds, but will also invest in derivative securities, such as options and convertible debt, if those investments are trading at substantial discounts to Khrom Capital's opinion of intrinsic value and/or are a better way, in Khrom Capital's opinion, to take advantage of underpriced underlying securities. In this strategy, the Partnership has no particular market capitalization requirements and purchases securities with a long‐term investment horizon (typically 1–5 years), seeking to achieve long term capital appreciation as the markets realize the value of the investments over time. Securities acquired in the context of this strategy are typically sold when Khrom Capital believes they are no longer undervalued; there has been a fundamental change in the company or industry affecting Khrom Capital's estimate of intrinsic value; or Khrom Capital believes that there exist more undervalued securities with higher return potential in which to invest. Short sales by the Partnership will take place within the context of this strategy. Khrom Capital will utilize short sales (including the use of options) to hedge against risk.

Khrom Capital’s investment strategy is described in greater detail in each client’s PPM (or governing document, as applicable). Types of Investments Short Selling. From time to time, Khrom Capital will sell short individual stocks and/or stock indices as a means of attempting to reduce risk and increase performance. Stocks are shorted by investors for a variety of reasons including: (i) high multiples of market to book value; (ii) temporary overvaluation due to short‐term market euphoria for a sector; (iii) faulty business model; (iv) poor earnings; (v) questionable accounting practices; (vi) deteriorating fundamentals; and (vii) weak management unable to adapt to changes in technology, regulation or the competitive environment. The shorting of stocks or indices is not expected to be a significant component of the Partnership's investment program. Options. Khrom Capital believes in the use of derivative securities, including options. Khrom Capital will purchase and write put and call options that are traded on national securities exchanges or over‐the‐counter markets, as well as on electronic communications networks. Khrom Capital believes that the possible use of options and other derivatives should help reduce risk and enhance investment performance. Fixed Income Securities. Khrom Capital will invest in corporate, and government issued fixed income securities as part of the strategic operations of the Partnership. Khrom Capital will take advantage of special investment opportunities in the high yield and convertible segments of the fixed income market. Khrom Capital considers these investments to be equity substitutes, with the expectation of providing both current income and capital appreciation. Khrom Capital will also seek opportunities in government issued fixed‐income securities as deemed appropriate. Futures Contracts. Khrom Capital does not intend at this time to invest in commodity futures contracts. If the Partnership determines to trade commodity interests or futures contracts, Khrom Capital will first register with the CFTC as a commodity pool operator under the CEA or seek an exemption from such registration in accordance with applicable CFTC rules and regulations. Event‐Driven Investments. When the opportunity arises, the Partnership will invest in companies based upon certain situations or events, a corporate restructuring, a merger or an acquisition. Leverage. The Partnership may increase the number and extent of its "long" positions by borrowing (e.g., by purchasing securities on margin). Entering into short sales also increases the Partnership's use of leverage. The amount of any borrowing by the Partnership will be limited by regulations imposed by the Federal Reserve Board and by the availability and cost of credit. Khrom Capital intends to employ leverage sparingly, and only to the limited extent necessary to achieve the Partnership's investment objectives. Private Placements. In addition to investing in publicly traded equity securities, the Partnership will in certain cases invest in privately placed unregistered securities that do not have a readily ascertainable market value, or in other types of illiquid assets. Investments in Illiquid Assets may be held in a separate Side Pocket Account, at the discretion of the General Partner, and only those

Limited Partners who are Limited Partners at the time the investment is made may participate in the investment. Other Investments. Khrom Capital will from time to time invest some of the Partnership's assets in short‐term obligations of the United States Government or other governments, certificates of deposit, commercial paper and other money market instruments, including repurchase agreements with respect to such obligations, to enable the Partnership to make investments quickly and to serve as collateral with respect to certain of its investments. If Khrom Capital believes that a defensive position is appropriate because of expected economic or business conditions or the outlook for security prices, or where Khrom Capital determines that opportunities for investing are unattractive, a greater percentage of Partnership assets will be invested in such obligations. The Partnership will also engage in securities lending activities. From time to time, at the sole discretion of Khrom Capital, cash balances in the Partnership's brokerage account may be retained in cash or placed in a money market fund. Sources of Information Khrom Capital's investment ideas may be generated from a wide variety of sources including industry contacts, trade and financial publications, trade shows, investment conferences and stock screens. Company analyses will begin with review of public filings (10‐Ks, 10‐Qs, 8‐Ks, DEF‐ 14As, etc.) and other available information. Particular attention will be paid to a company's balance sheet, including such ratios as cash per share, gross and net working capital per share, and tangible book value per share. Stock price valuation will be assessed from a variety of standpoints in addition to the criteria noted above, including sales and earnings history and outlook, historical and expected cash flows, and comparison with competing and related companies. Material Risks All investment involves a risk of loss and the clients, and their underlying investors could lose money over short or long periods. An investment in the clients may be deemed a speculative investment and is not intended as a complete investment program. It is designed for sophisticated investors who fully understand and can bear the risk of an investment in the clients. No guarantee or representation is made that the clients will achieve their investment objective or that investors will receive a return of their capital. The descriptions contained below are an overview of different risks related to the clients but are not intended to serve as an exhaustive list or comprehensive description of all risks and conflicts that may arise regarding the management and operations of the clients. Investors should review the risks listed in the clients’ PPMs (or governing document, as applicable) prior to investing. Prospective investors should consult their own legal, tax, and financial advisors as to all these risks, and as to an investment in a client generally. Past Performance – There can be no assurance that the clients will achieve their investment objectives. The past investment performance of the clients cannot be construed as an indication of the future results of an investment in the clients. Even though the clients have commenced operations, past performance of the clients should not be construed as an indication of the future results of an investment in the clients. Furthermore, the past performance of the clients does not necessarily indicate that the client will be successful in the future. The client’s results of operations will depend on the availability of suitable investment opportunities for the client and the

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Khrom Capital provides investment advisory services to private funds, which are generally organized as limited partnerships under the laws of the State of Delaware or another appropriate jurisdiction or, in the case of offshore private fund, a company under the laws of the Cayman Islands. Khrom Capital expects each private fund to qualify for an exclusion from having to register as an investment company under the IC Act pursuant to Section 3(c)(1) thereunder, and to offer interests to investors pursuant to Regulation D or Regulation S under the Securities Act. Thus, this disclosure brochure may discuss information relevant to such investors, as necessary or appropriate. Nonetheless, this brochure is designed solely to provide information about Khrom Capital and should not be considered as an offer of interest in any Khrom Capital private fund. Any such offer may be made only by delivery to the prospective investor of the PPM for the private fund under consideration. Client investors may include high net worth individuals and a variety of institutional investors (e.g., trusts, employee benefit plans, endowments, foundations, public pension plans, sovereign wealth funds, corporations, private fund of funds, and other types of entities). Certain clients or investors in the private fund may expose Khrom Capital to potential conflicts of interest. Investments by such parties may expose Khrom Capital to potential conflicts of interest with respect to proxy voting decisions and investment decisions and could expose Khrom Capital to risks relating to the receipt of material non-public information or other confidential information relating to the company in question. In addition, Khrom Capital employees have made, or may make, contributions to charitable organizations that have invested in the clients. Khrom Capital may have a conflict between acting in the best interest of the clients and making decisions that build goodwill with the aforementioned types of investors so they will maintain or increase their investments in the private fund. Please see the “Code of Ethics, Insider Trading Policies and Procedures and Personal Trading Policies and Procedures” sections for additional information about Khrom Capital’s insider trading policy and the “Proxy Voting” section for additional information about Khrom Capital’s proxy voting policies and procedures. When accepting new investors, the clients generally require a minimum investment of $1 million but may accept lesser amounts at the discretion of Khrom Capital and/or the general partner of the relevant clients.

The Fund charges a “performance allocation” or “incentive allocation” generally equal to 20-25% of the net profits or the net profits above the benchmark (as defined in the Fund’s governing documents), in certain cases after a performance hurdle or preferred return, attributable to each investor, which is paid to Khrom Capital, or the general partner of the private fund, either at the end of the year, upon withdrawal of capital, or upon transfer by an investor from one tranche to another. Performance-based fees are charged in compliance with Rule 205-3 under the Investment Advisers Act of 1940 (the “Advisers Act”). Performance-based fees may create an incentive for Khrom Capital to make riskier or more speculative investments on behalf of the private fund than would be the case in the absence of such fees. In addition, the performance-based fees received by the general partners of the Fund reflect both realized and unrealized gains and losses. Accordingly, members of the general partners of the Fund could earn performance-based fees on unrealized gains that the Fund might ultimately never

realize. Finally, Khrom Capital charges reduced or no management and performance-based fees to Khrom Capital, its affiliates, current and former employees and their family members, and current and former consultants. Khrom Capital has no obligation to disclose the specific details of such arrangements or to offer such additional rights, terms, or conditions to all investors.

Khrom Capital or its affiliates serve as the General Partner to the Fund. Khrom Capital does not recommend or select other investment advisers for clients. However, Khrom Capital will recommend that clients invest in the Fund. As the sponsor/investment manager of the Fund, Khrom Capital receives management and performance fees or allocations from the Fund which creates a

conflict of interest. All fees will be disclosed to the clients in advance of their investment in a Fund. Khrom Capital’s employees, affiliates or their related persons from time to time will also invest directly in some or all of the Fund. To address potential conflicts of interests in its material relationships, Khrom Capital has adopted policies and procedures, including a Code of Ethics (the “Code”) (as described in Item 11). Under the Code, in general, all personnel of Khrom Capital, including directors, officers, and employees, must put the interests of the Khrom Capital’s Clients first and must act honestly and fairly in all respects in dealings with Clients. For a more detailed discussion of the Code and conflicts of interest policies, please see Item 11.

Personal Trading Khrom Capital has adopted a code of ethics (see “Code of Ethics” section below) and implemented procedures relating to personal securities transactions and insider trading that are designed to detect and prevent (or otherwise mitigate) conflicts of interest. Khrom Capital access persons are not permitted to transact in the securities of individual public companies in their personal brokerage accounts (except pre-cleared sales, as noted below), nor are they permitted to invest in third-party private investment funds that primarily invest in equity securities of individual public companies (unless pre-cleared by the Chief Compliance Officer or their designee). The Chief Compliance Officer (“CCO”) or their designee, among other things, monitors employee brokerage accounts in an attempt to prevent employees and the clients from engaging in improper personal securities transactions and to otherwise detect and prevent potential conflicts of interest. Khrom Capital has adopted the Code of Ethics (“the Code”). The Code has several goals. First, the Code is designed to assist Khrom Capital in complying with applicable laws and regulations governing its investment advisory business. Under the Advisers Act, Khrom Capital owes fiduciary duties to its Client. Pursuant to these fiduciary duties, the Code requires Khrom Capital associated persons to act with honesty, good faith, and fair dealing in working with Client. In addition, the Code prohibits associated persons from trading or otherwise acting on insider information. Next, the Code sets forth guidelines for professional standards for Khrom Capital’s associated persons (managers, officers, and employees). Under the Code’s Professional Standards, Khrom Capital expects its associated persons to put the interests of its Clients first, ahead of personal interests. In this regard, Khrom Capital’s associated persons are not to take inappropriate advantage of their positions in relation to Khrom Capital’s Clients. Third, the Code sets forth policies and procedures to monitor and review the personal trading activities of associated persons. Khrom Capital’s associated persons may not invest in the same securities recommended to Clients, except as provided below. The Code’s personal trading policies include procedures for limitations on personal securities transactions of associated persons, including generally disallowing trading by an associated person in any security any Client account trades or considers trading and the creation of a restricted securities list, reporting and review of personal trading activities and pre-clearance of certain types of personal trading activities. These policies are designed to discourage and prohibit personal trading that would disadvantage Clients. Statement on Insider Trading Khrom Capital and/or its employees may come into possession of material non-public or other

confidential information which, if disclosed, might affect an investor’s decision to buy, sell, or hold a security. Under applicable law, Khrom Capital and its employees are prohibited from improperly disclosing or using such information for their personal benefit or for the benefit of any other third party. Accordingly, should Khrom Capital and/or its employees come into possession of material non-public or other confidential information with respect to any company, they may be prohibited from communicating such information to, or using such information for the benefit of, Khrom Capital’s clients and their underlying investors. Khrom Capital has adopted a Statement on Insider Trading (“insider trading policy”) in accordance with Section 204A under the Advisers Act, which establishes procedures to prevent the misuse of material non-public information by Khrom Capital and its employees. Participation by Khrom Capital Personnel in Private Fund Profits Certain employees of Khrom Capital are permitted to invest directly in the private fund and will participate in the private fund’s investments, pro rata, in accordance with their capital account balances. In addition, certain of Khrom Capital’s employees hold interests indirectly in the general partners and/or management companies of the clients and in this manner, share in revenue generated by clients (e.g., performance allocation and/or management fee revenue). Finally, investments by Khrom Capital current and former employees and consultants, their family members are generally subject to no or reduced management fees and/or performance fees.

Outsourced Trading Khrom Capital uses one or more unaffiliated broker-dealers to trade securities on behalf of its clients. Khrom Capital has negotiated execution costs for outsourced trading in addition to standard trading costs. Khrom Capital’s clients incur the costs associated with one or more outsourced trading solutions, which Khrom Capital believes are reasonable considering the value of the trading services. Prime Broker The Prime Broker will clear (on the basis of payment against delivery) the securities transactions of the Partnership which are affected through other brokerage firms. Khrom Capital will also utilize the Prime Broker, its affiliates and other brokers and dealers for the purpose of executing transactions for the Partnership. Accordingly, the Prime Broker will receive substantial brokerage commissions and/or margin interest related to the securities transactions of the Partnership. The Partnership's securities will be held at the Prime Broker. Khrom Capital is not committed to continue its prime brokerage and custodial relationships with the Prime Broker for any minimum period and will enter into prime broker or custodial relationships with one or more other brokers or financial institutions from time to time at its discretion. Khrom Capital is deemed to have custody of client funds and securities because it has the authority to obtain client funds or securities, for example, by deducting advisory fees from a client's account or otherwise withdrawing funds from a client's account. Khrom Capital will be subject to Rule 206(4)‐2 under the Advisers Act (the "Custody Rule").

However, it will not be required to comply (or will be deemed to have complied) with certain requirements of the Custody Rule with respect to the Partnership because it will comply with the provisions of the so‐called "Pooled Vehicle Annual Audit Exception," which, among other things, requires that the Partnership be subject to audit at least annually by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, and requires that the Partnership distribute its audited financial statements to all investors within 120 days of the end of its Fiscal Year. The Prime Broker is a "qualified custodian" as such term is defined in the Custody Rule. Khrom Capital will maintain client assets in compliance with the Custody Rule. General Khrom Capital will be responsible for the placement of the portfolio transactions of the Partnership and the negotiation of any commissions or spreads paid on such transactions. Portfolio investments normally will be purchased through brokers on securities exchanges or directly from the issuer or from an underwriter or market maker for the investments. Purchases of portfolio investments through brokers may involve a commission to the broker. Purchases of portfolio investments from dealers serving as market makers include the spread between the bid and the asked price. Execution of Transactions In placing portfolio transactions and negotiating commission rates, Khrom Capital will seek to obtain the best execution for the Partnership, taking into account the following factors: (i) the ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any); (ii) the operational efficiency with which transactions are effected, taking into account the size of order and difficulty of execution; (iii) the financial strength, integrity and stability of the broker; (iv) the reputation of the broker; (v) the firm's risk in positioning a block of securities; (vi) efficiency of execution and error resolution; (vii) the quality, comprehensiveness and frequency of available research services considered to be of value; and (viii) the competitiveness of commission rates in comparison with other brokers satisfying Khrom Capital's other selection criteria. Khrom Capital is authorized to pay higher prices for the purchase of securities from or accept lower prices for the sale of securities to brokerage firms that provide it with such investment and research information or to pay higher commissions to such firms if Khrom Capital determines such prices or commissions are reasonable in relation to the overall services provided. Research services furnished by brokers will include written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; statistics and pricing or appraisal services; discussions with research personnel; and invitations to attend conferences or meetings with management or industry consultants. Khrom Capital is not required to weigh any of these factors equally. Information so received is in addition to and not in lieu of services required to be performed by Khrom Capital, and neither the Incentive Allocation nor the Management Fee are reduced as a consequence of the receipt of such supplemental research information. Research services provided by broker/dealers used by the Partnership will be utilized by Khrom Capital or its affiliates (including other investment funds managed by such persons) in connection with their other investment activities. Since commission rates in the United States are negotiable, Khrom Capital's selection of brokers on the basis of considerations which are not limited to applicable commission rates may at times result in the Partnership being charged higher transaction costs than

it could otherwise obtain. The Partnership is not required to allocate either a stated dollar or stated percentage of its brokerage business to any broker for any minimum time period and will review such relationships from time to time. Directed Brokerage Khrom Capital may also direct some Partnership brokerage business to brokers who refer prospective investors to the Partnership. Because such referrals, if any, are likely to benefit Khrom Capital but will provide an insignificant (if any) benefit to Limited Partners, Khrom Capital will have a conflict of interest with the Partnership when allocating Partnership brokerage business to a broker who has referred investors to the Partnership. To prevent Partnership brokerage commissions from being used to pay investor referral fees, Khrom Capital will not allocate Partnership brokerage business to a referring broker unless Khrom Capital determines in good faith that the commissions payable to such broker are not materially higher than those available from non‐referring brokers offering services of substantially equal value to the Partnership. Trade Aggregation and Allocation Khrom Capital does not aggregate trades because we manage only one pooled investment vehicle. “New Issues” Khrom Capital allocates new issues of equity securities registered under the Securities Act (“new issues”) in accordance with FINRA Rules 5130 and 5131. This may, in certain circumstances, limit or restrict certain clients or investors from participating in any profits and losses from new issues. Trade Error Policy As a general practice, Khrom Capital attempts to cause any broker or other service provider responsible for a trade error to reimburse affected clients for any losses resulting from the trade error. If Khrom Capital causes a trade error, the identification and resolution will be on a case- bycase basis, taking into account the particular circumstances of the situation. Such resolution will include a determination of what party, or parties will bear the costs of resolving the trade errors (i.e., the firm, the account, or a responsible third-party, such as the broker-dealer), including whether the Client should be reimbursed and if so, by whom. The particular standards for resolving trade errors will also be provided for in a private placement memorandum or an investment advisory agreement, as applicable. In all cases, Khrom Capital will be guided by its fiduciary duty. Finally, if a trade error results in a gain, the gain will accrue to the benefit of the affected client accounts. The limitation on Khrom Capital’s liability to clients for losses is described in the offering documents. The self-assessment by Khrom Capital as to whether a trade error loss resulted from bad faith, gross negligence, or willful misconduct may expose Khrom Capital to a potential conflict of interest. Khrom Capital may have an incentive to determine that it does not have to reimburse its clients for trade error losses. To mitigate this conflict, Khrom Capital’s trade error procedures require Khrom Capital to resolve any trade error in a reasonable, practicable, timely and efficient manner. Khrom Capital will maintain a log to detail any trade errors, if any, and the action taken. Additionally, the CCO will review the Trade Error Log and a record of trades on a periodic basis as they determine appropriate

under the circumstances.

If Khrom Capital compensates a third party to obtain investors for its private fund, the referral agreement, disclosures, and all related activities must comply with Rule 206(4)-1 under the Advisers Act. Management fees charged by Khrom Capital to clients or private fund investors introduced by such third party will not be any higher than those charged to similar clients or investors not introduced by a third party. Client Service/Marketing Agreements Khrom Capital has an agreement with a third-party solicitor to provide overseas marketing support to the Fund. The general partner of the relevant private fund will compensate this third-party solicitor with (i) a percentage of the performance fee and (ii) a percentage of the management fee. The applicable general partner will also reimburse this third-party solicitor for certain expenses. The applicable general partner retains discretion to compensate this third-party solicitor based upon any other compensation structure. Such third-party solicitors will receive fees from the applicable general partner that will be based on the subscription amounts of investors, ongoing fees based upon the performance of investors’ interests in the private fund or based on other compensation structures as determined by the applicable general partner in its discretion.

There are no legal or disciplinary events that are material to the evaluation of our advisory business or the integrity of our management.

Each client account is reviewed by certain partners and employees of Khrom Capital generally on a daily basis. Periodic account reviews consist of an analysis of the account’s performance to date considering its investment objectives and an evaluation of any appropriate changes which should be made to its portfolio in light of its current positions, the exposure of the portfolio to various forms of risk, and Khrom Capital’s ongoing assessment of the overall market and alternative investment opportunities. Investors receive written reports as described in the applicable PPM or governing document. Khrom Capital generally supplies monthly capital account balance statements with periodic reports to investors that will include investment and market summaries as well as the performance of the applicable client versus that of a benchmark selected based on applicable governing documents or for comparison to broad market performance. Each investor in an onshore private fund also receives a Schedule K-1 for tax purposes. To comply with Rule 206(4)-2 (the “Custody Rule”) of the Advisers Act, annual audit reports are generally provided within 120 days following a client’s fiscal year end, or earlier as required by the Custody Rule. Certain investors may receive additional information and reporting from Khrom Capital and/or the general partners of the Client, upon verbal request, through written side letter agreements, or consulting agreements, and such information may affect an investor’s decision to request a withdrawal of its interests or make additional subscriptions. Khrom Capital’s CCO, CFO, and/or Head of Investor Relations and Marketing, as relevant, internally reviews the information provided to investors in order to detect and prevent potential concerns with respect to information flow, such as a combination of enhanced transparency and liquidity that could benefit particular investors to the detriment of other investors.

As Khrom Capital and/or general partner of the clients, Khrom Capital and/or its affiliates have the authority to directly access the funds or securities of such clients. Khrom Capital and/or its affiliates have the authority to automatically deduct fees and expenses payable to Khrom Capital, the general partners of the clients, and/or third-party service providers with respect to each client by sending instructions directly to the custodian (or the prime broker, as relevant). In each such case, Khrom Capital will be deemed to have custody of the client’s assets under the Custody Rule. Khrom Capital will comply with the requirements of the Custody Rule regarding such custody. Investors in onshore and offshore private fund will receive audited financial statements annually, prepared in accordance with generally accepted accounting principles, within 120 days after the end of the fiscal year of each such private fund. Additional disclosure regarding custody of client assets can be found in the Company’s Form ADV Part 1 filing with the SEC.

Khrom Capital is retained with respect to its clients on a discretionary basis and is authorized to make the following determinations in accordance with a client’s specified investment objectives without investor consultation or consent before a transaction is effected (unless consultation is required with respect to principal trades, which Khrom Capital does not intend to employ as part of its standard investment strategy): • • • • • •

the security selection; the total quantity or amount of securities; the type and timing of the transaction; the broker-dealer through which securities are transacted; the commission rates and/or financing terms at which securities transactions are effected; and the transaction price of securities, which may include dealer spreads, mark-ups or markdowns, and transaction costs.

Investors cannot place restrictions on Khrom Capital’s investment discretion with respect to the private fund. However, Khrom Capital will enter into side letter agreements with certain large or strategic investors granting, among other things, requested restrictions with respect to permitted investment sectors.

Khrom Capital has written proxy voting policies and procedures as required by Rule 206(4)-6 under the Advisers Act. Khrom Capital’s policy is to vote proxies with the aim of furthering the best interests of its clients, generally by promoting high levels of corporate governance and adequate disclosure of company policies and practices. Khrom Capital will generally vote proxies as directed by the applicable portfolio manager(s), or their designee, and investment team, as necessary. Investors cannot direct Khrom Capital as to how to vote in a specific ballot. Khrom Capital reserves the right, on occasion, to abstain from voting a proxy or a specific proxy item when it concludes that the cost of voting outweighs the potential benefit or when Khrom Capital otherwise does not

believe voting serves its clients’ best interests. Material conflicts of interest could arise in certain circumstances, such as, for example, where a client or investor is associated with the company soliciting the proxy or actively supporting or opposing a proxy proposal, or where a partner or executive officer of Khrom Capital has personal or other business relationships with participants in a proxy contest (such as a company director or a proponent of the proxy proposal). Khrom Capital takes steps to identify the existence of any material conflicts of interest relating to the securities to be voted and/or the issues at hand. For example, Khrom Capital’s employees must disclose to the CCO any potential personal conflicts known to them and potential conflicts based on business relationships or dealings. In considering whether a material conflict of interest exists, the CCO from time to time will consult with other persons in Khrom Management that they deem relevant in making a determination. In the absence of a finding of a material conflict of interest relating to the proxy vote at hand, the recommendation to vote the proxy as directed by the applicable portfolio manager(s), or their designee, with assistance from the investment team, as necessary, or to abstain from voting the proxy, shall be deemed to have been made in the best interests of Khrom Capital’s clients. Investors can obtain a copy of Khrom Capital’s written proxy voting policies and procedures as well as information on how Khrom Capital voted proxies for the clients by requesting such information. Please contact Khrom Capital at info@khromcapital.com.

Khrom Capital has never filed for bankruptcy and is not aware of any financial condition that is expected to affect its ability to manage client accounts.