KING STREET CAPITAL MANAGEMENT, L.P.

King Street is a leading global alternative asset manager founded in 1995 that manages capital across an institutional platform spanning multiple segments of the public and private markets. King Street was co-founded in 1995 by Brian J. Higgins, the Managing Member of King Street’s general partner, King Street Capital Management GP, L.L.C. (the “Investment Manager GP”). King Street is owned by the members of the Investment Manager GP. King Street provides services to private investment funds, which include: •

open-ended hedge funds that focus on distressed debt, special situations, long/short credit and event driven strategies (the “Hedge Funds”)

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closed-ended real estate funds that employ an opportunistic strategy focused on special situations investments and select high conviction themes (the “Real Estate Funds”)

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closed-end global drawdown funds which employ a special situations credit strategy focused on idiosyncratic opportunities across corporates, structured products and asset-backed transactions, as well as claim-related investments. (the “Drawdown Funds”)

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closed-end and evergreen opportunistic credit funds that focus on performing credit with lending and income focus (the “OCS Funds”)

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liquid and semi-liquid funds offered solely to offshore investors under arrangements with unaffiliated investment managers that pursue strategies (or components of strategies) similar to those outlined above (the “Offshore Investor Funds”)

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sub-advised Collective Investment of Transferrable Interest funds which are European-based collective investment vehicles that comply with EU regulations and focus on highly liquid investments in stocks, bonds, short-term treasury and cash (the “UCITS Funds”)

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other funds that pursue a combination or variation of the strategies described above, or other strategies that King Street may determine to pursue in the future.

Each of the foregoing are referred to as a “Fund” and collectively, the “Funds”. A related person of King Street generally acts as general partner or special shareholder of each Fund, and King Street acts as investment manager to each Fund. King Street’s affiliate, Rockford Tower Capital Management, L.L.C. (“RTCM”) acts as the collateral manager to collateralized loan obligation vehicles that invest primarily in broadly syndicated loans and collateralized bond obligation vehicles that invest in bonds and broadly syndicated loans (collectively, the “Rockford Tower CDOs”). If required, RTCM also acts as “risk retention provider” (as described below) with respect to the Rockford Tower CDOs. In its role as risk retention provider, RTCM holds Rockford Tower CDO securities to the extent required by applicable risk retention rules (“Risk Retention Interests”) and, through their investment in RTCM, certain Funds will be indirectly exposed to the Risk Retention Interests. King Street provides certain services to RTCM relating to management of the Rockford Tower CDOs. King Street manages, or expects to manage, assets for one or more advisory clients through separately managed accounts (“SMAs”) or similar arrangements employing an investment strategy investing in parallel

with, or similar to, the strategy of the Funds. The investment objectives of such SMAs, including any restrictions on King Street’s authority to invest in specific securities or types of securities, may be determined in consultation with such client and memorialized in each such client’s investment management agreement. The Funds, the Rockford Tower CDOs, and SMAs are collectively referred to herein as “Advisory Clients.” References to King Street in this Brochure include, as the context requires, affiliates through which King Street provides investment advisory services or that act in any capacity. Each general partner, manager and special shareholder that is a related person of King Street is subject to the Investment Advisers Act of 1940, as amended (the “Advisers Act”), pursuant to King Street’s registration and in accordance with SEC guidance, and such persons collectively operate as a single advisory business. King Street’s management of each Advisory Client is subject to, and the terms of any investor’s investment in an Advisory Client and all other terms of each Advisory Client, are governed exclusively by, the terms of that Advisory Client’s organizational documents, offering memorandum (if any), limited partnership agreement (if any), memorandum and articles of association (if any), investment management agreement (if any), and subscription agreement (if any), each as amended, supplemented or modified from time to time (collectively, the “Governing Documents”) and Side Letters (as defined below) (if any). All discussions in this Brochure regarding the Advisory Clients, including their investments, the strategies King Street pursues in managing them, the fees and expenses borne by them and their investors (as applicable), and all other terms of each Advisory Client, are qualified in their entirety by reference to the relevant Governing Documents and are further described below under “Methods of Analysis, Investment Strategies and Risk of Loss.” Investors in the Funds participate in the overall investment program for the applicable Fund, but in certain circumstances are excused from a particular investment due to legal, regulatory or other agreed-upon circumstances pursuant to the Governing Documents and/or Side Letters; for the avoidance of doubt, such arrangements generally do not and will not create an adviser-client relationship between King Street and any investor in a Fund. The Funds or King Street have entered into, and expect in the future to enter into, side letters or other similar agreements (“Side Letters”) with certain investors that have the effect of establishing rights under, or altering or supplementing the terms (including economic or other terms) of, the Governing Documents with respect to such investors. Investors in a Fund should review the relevant Governing Documents to determine whether such an investment is appropriate for their individual circumstances, as King Street manages each Advisory Client pursuant to its investment objectives and restrictions as set forth in the applicable Governing Documents. From time to time, where investments of the Funds consist of portfolio companies or include intermediate holding vehicles through which the Funds invest, personnel of King Street or its affiliates serve on such portfolio companies’ or holding vehicles’ respective boards of directors or otherwise act to influence control over such entities. As of December 31, 2025, King Street had approximately $34,568,100,000 in regulatory assets under management, all managed on a discretionary basis. King Street currently does not provide investment advisory services to clients apart from its management of the Advisory Clients, although it may do so in the future. Except in limited circumstances, investors in the Funds have no opportunity to select or evaluate any investments or strategies. King Street selects each Fund’s investments and determines its investment strategies.

With respect to each type of Advisory Client, King Street and certain of its affiliates receive management fee and performance compensation, as described below. King Street complies with Rule 205-3 of the Advisers Act, to the extent required by applicable law. Subject to the relevant Governing Documents, King Street has waived, and may in the future in its sole discretion waive, all or any portion of the management fee and/or performance compensation with respect to an Advisory Client or any investor in a Fund including, but not limited to, King Street, its affiliates and any of their respective current or former principals, members, directors, officers, partners, employees, the family members of any of the foregoing and any trusts or other vehicles for the benefit of such persons and any charitable trust, foundation or similar entity established by any such persons. Additionally, King Street and its affiliates have in the past waived, and may in the future in its sole discretion waive or modify all or a portion of the management fees, incentive compensation or other remuneration in respect of Other Persons (as defined in Item 8). Management fees and performance reallocations are calculated based on the terms set forth in each Advisory Client’s Governing Documents. Investors should review carefully the specific terms set forth in the relevant Advisory Client’s Governing Documents. In the event that transaction, advisory, asset servicing, and/or similar fees (including, as applicable, fees from Rockford Tower CDOs) are received by King Street in connection with a Fund’s investments, King Street generally intends to offset the portion of those fees received by King Street allocable to the Fund against the management fees and/or otherwise credit such fees to the Fund’s investors, on a pro rata basis; however, King Street or other King Street entities or affiliates reserve the right, in certain circumstances, to retain such fees without offset to management fees or credit to a Fund’s investors, to the extent permitted under the relevant Governing Documents. The Funds Management Fees. The Funds generally pay King Street a management fee that ranges from 1.00% to 1.875%. •

Management Fees for the Hedge Funds range from 1.00% to 1.5% and management fees for Offshore Investor Funds range from 1.10% to 1.875%, each of which is annually payable in advance on a quarterly basis.

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Management Fees for Real Estate Funds, Drawdown Funds, and OCS Funds are paid quarterly in advance, equal to a percentage up to 1.50% of the undrawn and/or drawn capital commitments for a specified period of time, and thereafter a percentage up to 1.50% of certain invested capital, in each case subject to reductions and/or adjustments as set forth in the relevant Governing Documents. From time to time, these Funds expect to offset and reduce amounts otherwise distributable to investors in order to pay the management fee to King Street (or an affiliate thereof). As a general matter, the management fees will be payable until all assets of the Fund are distributed, including during any term extensions, unless otherwise agreed with investors or explicitly prohibited by the relevant Governing Documents.

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Evergreen OCS Funds generally pay a management fee equal to 1.375% of an investor’s opening capital account balance (before such balance is adjusted for the effect of management fees and the accrual of any performance compensation), calculated each calendar quarter and paid each calendar quarter in arrears. The management fee will typically be adjusted for any capital accounts established after the first business day of a calendar quarter, but is generally not otherwise adjusted for events occurring after the commencement of any calendar quarter.

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The King Street Long/Short Credit UCITS Fund charges a management fee at the Fund level, as disclosed in the Fund’s governing documents and offering materials. King Street serves as subinvestment manager and is compensated by the investment manager from the management fee charged to the Fund. Pursuant to the sub-investment management agreement, King Street’s portion of the management fee ranges from 0.20% to 1.125% per annum of the Fund’s net asset value, depending on share class. King Street does not receive additional compensation from the Fund beyond its agreed share of the management fee.

Performance Compensation. An affiliate of King Street generally receives carried interest distributions between 10-25% of net profits of the applicable Fund subject to a preferred return, as more fully described in the Governing Documents of each Fund. •

For Hedge Funds, an affiliate of King Street generally receives performance reallocations equal to 20% or 25% of the net profits (including realized and unrealized gains) of the applicable Fund. The performance reallocation does not take into consideration gains and losses applicable to Special Investments (as defined in Item 8) that continue to be held in Special Investment accounts (if any) as of the performance reallocation date.

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For Real Estate Funds, Drawdown Funds and OCS Funds, an affiliate of King Street generally receives carried interest distributions of between 10-20% of the net profits of the applicable Fund subject to a preferred return, as more fully described in the Governing Documents of each Fund. The carried interest is subject to a potential giveback at the end of life of the Fund if King Street has received excess cumulative distributions as set forth in the relevant Governing Documents.

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For OCS Funds, an affiliate of King Street generally receives performance equal to 15% of the net increase in value (including realized and unrealized gains) of the applicable Fund, subject to a highwater adjustment and preferred return, each as described in greater detail in the relevant Governing Documents.

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For Offshore Investor Funds, the Offshore Investor Closed-End Fund is typically expected to bear an incentive fee equal to 15% of the net increase in value (including realized and unrealized gains) of the Fund, subject to a high-water adjustment and preferred return, each as described in greater detail in the relevant Governing Documents. The Offshore Investor Open-End Fund is typically expected to bear an incentive fee equal to 15% of the net investment income, subject to a 5% preferred return with catch up paid quarterly, and 15% on realized capital gains (net of realized and unrealized losses) paid on the calendar year end.

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The King Street Long/Short Credit UCITS Fund charges a performance fee of 15% to 20% of net profits, depending on share class, subject to the terms set forth in the Fund’s governing documents. King Street receives a portion of the performance fee allocated by the investment manager pursuant to the sub-investment management agreement. King Street does not receive performance compensation directly from investors.

SMAs Management Fee. King Street expects to charge a monthly or quarterly management fee for SMAs, equal to a mutually agreed annual rate applied to the account’s value at each month- or quarter-end (before fee deduction), pro-rated for partial periods, calculated and accrued monthly, and typically payable quarterly in arrears, subject to the relevant SMA Advisory Client’s Governing Documents. Fee levels are expected

to be negotiated on an individual basis with an SMA Advisory Client based on services, account size, and relationship, and may be fixed or variable, based on a percentage of an account’s value, generally below 1% and subject to negotiation. Rockford Tower CDOs Management Fees. RTCM generally receives management fees from the Rockford Tower CDOs of approximately 0.45% of the par value of the collateral and cash held in the Rockford Tower CDOs. Management fees will generally be payable only if there are funds available in accordance with the priority of payments provisions of the respective Rockford Tower CDO’s Governing Documents. Performance Compensation. RTCM also receives incentive fees, typically 20% of the excess cash flows due to the holders of the subordinated notes, subject to a stated hurdle rate.

Advisory Client Expenses In addition to the management fee and carried interest payable to King Street, each Advisory Client bears certain expenses. As set forth more fully in the Governing Documents, an Advisory Client generally bears all fees, costs, expenses, liabilities and obligations relating to the Advisory Client’s (and its subsidiaries’ and intermediate entities’) activities, investments and business to the extent not applied to reduce management fees. For example, such expenses typically include administrative costs, including the fees and expenses paid to the administrator, accounting and valuation (including, without limitation, the costs of accounting, portfolio management, asset services, advisory council, risk management and trade order management systems and software), tax (including tax preparation, consulting, entity-level taxes and governmental charges), auditing (including auditor review of and reporting on controls, procedures, custody and valuation such as in an Agreed Upon Procedures review), legal and compliance, regulatory requirements (including the costs of preparing and distributing investor reporting, investor notices or consents, and any legal fees or expenses, costs of monitoring, consulting or other third-party service providers engaged at King Street’s discretion related thereto), filings and expenses including in connection with filings pertaining to investments (including, without limitation, blue sky, U.S. FATCA, CRS, Form D, Section 13, Form PF, etc. and comparable non-U.S. filings, including those contemplated by AIFMD or any similar law, rule or regulation, including secondary legislation, regulations, rules and/or associated guidance, and any related requirements), consulting (including with respect to sourcing and due diligence of potential investments, operational improvements or monitoring of existing investments, and compliance costs incurred by King Street related to any of the foregoing) and other professional fees and expenses (including with respect to research, investment banking, deal sourcing, lobbying or any of the other expense categories referenced in this paragraph), U.S. and non-U.S. custodial, depositary, local paying agent, trustee, recordkeeping, registered office, clearing and transfer agency fees and expenses (including any depositary appointed pursuant to the AIFMD and any Swiss representative or paying agent appointed pursuant to the Swiss Collective Investment Schemes Act (as amended), including any law, rule or regulation relating to the implementation thereof), printing and mailing expenses (including the expenses incurred for the printing of the offering documents, subscription agreements, notices, reports and sales literature and the delivery of such materials to existing and potential investors), other promotional expenses (including fees and costs associated with satisfying local regulatory requirements in non-U.S. jurisdictions), organizational expenses (including organization of trading or special purpose vehicles), the cost of maintaining an Advisory Client’s corporate existence and registered office, the cost of obtaining and maintaining operational, credit or other ratings, the costs and expenses of products and services relating to research concerning investments or potential investments (except to the extent that such costs or expenses

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Primary Investment Strategies and Methods of Analysis King Street seeks to produce attractive, risk-adjusted returns throughout diverse market environments by capitalizing on what it perceives as mispriced investment opportunities. King Street takes a fundamental and research-intensive approach to investing, where downside risk assessment plays a key role in the investment process. King Street generally has broad discretionary authority to determine the investments to be traded and the strategy and approaches used to meet the overall investment objectives of each Advisory Client. Except as otherwise noted, the Funds generally seek to achieve their investment objectives by investing in instruments related to any level of an issuer’s capital structure (including, without limitation, bank debt, corporate bonds, trade claims, convertible securities, equities, credit default swaps, options and other derivatives, as well as the debt or equity of structured credit products) and across a broad spectrum of companies, industries and asset classes. The Funds invest directly in these instruments or indirectly through intermediate pooled entities, including special purpose vehicles, which are also managed by King Street for, among other things, pooling investments of multiple Funds. The Funds from time to time establish

both long and short positions and invest in initial public offerings of securities. More detailed information regarding King Street’s investment strategies and activities described below is set forth in the Governing Documents for the relevant Advisory Client. Long/Short Credit, Event-Driven and Real Estate Strategies King Street is a global alternatives firm with a robust platform encompassing multiple segments of the public and private markets. Since its founding in 1995, King Street has been evolving its skill set and has been tested by many economic cycles. Rigorous fundamental research married with tactical trading and exceptional sourcing is core to King Street’s investment process. King Street seeks to identify misunderstood investment opportunities. On the long side, this strategy focuses on companies, assets and instruments that King Street perceives are trading below their inherent value. These investments include companies King Street believes have fundamentally sound businesses that are experiencing financial distress or difficulty due to a challenging operating environment and/or inappropriate capital structures, including companies that are reorganizing under applicable bankruptcy laws, restructuring debt obligations outside of court, liquidating assets to pay off creditors or emerging from a recent financial restructuring. In addition, this strategy also involves investing in structured credit products, such as collateralized debt obligations, collateralized loan obligations and other asset-backed securities, when King Street believes they can be purchased at a discount to expected realizable cash flows. On the short side, this strategy involves implementing short positions in the securities of companies that King Street believes may deteriorate in credit quality due to operating or financial challenges, become subject to a leveraging event (such as a leveraged buyout or recapitalization) or have a negative catalyst in the future. In addition to directional long or short investments, intercapital trades comprised of both a long and short component are opportunistically implemented. Examples of such trades include basis trades between bonds and credit default swaps, trades that take a view on the steepness of an issuer’s credit curve, intercapital trades that are long a senior security and short a more junior security and pair trades between different issuers in related businesses. The real estate strategy involves investing in equity and debt interests in real estate and real estate-related assets through a global investment strategy across all major property types, focusing on situations that are out-of-favor, complex, misunderstood or in markets undergoing a transition. Investments are generally expected to exhibit one or more of the following characteristics: (i) located in a market with a supply/demand imbalance; (ii) owned by a motivated seller; (iii) situated in a dislocated market; and/or (iv) under-managed or under-invested. In particular, King Street invests in a variety of property types including development, retail, office, industrial, residential (including both single and multi-family units), hotel/lodging, multi-use and land, subject to the terms of the relevant Governing Documents. In addition to direct real estate investments, this strategy also includes investments in certain private instruments and public securities, such as equity interests, debt interests, debt- or equity-related interests, participations, leasehold interests, or other direct or indirect interests in or relating to single or multiple real estate properties or assets (including land, buildings and other improvements and related personal or intangible property), pools or portfolios of real estate properties or assets, partial interests or rights in real estate properties or assets, options, swaps, derivative instruments, futures contracts, forward commitments, rights of refusal, rights of offer and similar rights in respect of real estate properties or assets or portions thereof, and debt or equity securities and other interests in real estate or real estate-related companies (listed or non-listed).

Rockford Tower CDOs The Rockford Tower CDOs managed by RTCM will invest primarily in broadly syndicated loans and other similar obligations. Certain Funds have exposure to the Rockford Tower CDOs by virtue of direct investments and, indirectly, through their investment in RTCM, which retains Risk Retention Interests in the Rockford Tower CDOs. Co-Investments alongside Other Persons In connection with the foregoing strategies, Advisory Clients from time to time participate in coinvestments through partnerships, joint ventures, pooled investment vehicles, other Advisory Clients, other entities, or participations or other syndication arrangements alongside one or more third parties that act as co-venturer, partner, participant or sub-participant (including other Advisory Clients or investors of the Advisory Clients or parties with whom King Street otherwise has a relationship such as service providers, sponsors, market participants, finders, consultants, King Street personnel and/or certain other persons associated with King Street and/or its affiliates) (collectively, “Other Persons”) if King Street determines that such an arrangement represents a preferred way to access a particular investment opportunity or otherwise expand the investment expertise available to the Advisory Clients. To facilitate such investments, an Advisory Client from time-to-time pre-funds amounts on behalf of such Other Persons by way of a shortterm loan, interim purchase or otherwise (including where an Advisory Client purchases an investment with the intention of later syndicating a portion thereof to Other Persons). Summary of Certain Risk Factors Investing in securities and other instruments involves risk of loss that investors should be prepared to bear. The management style offered by King Street may be deemed speculative and is not intended as a complete investment program. It is designed for sophisticated investors who fully understand and are capable of bearing the risk of such an investment. No guarantee or representation is made that the Advisory Clients will achieve their investment objectives or avoid losses. The following is a brief summary of certain risks associated with King Street’s investment strategies. Please see the Governing Documents of each Advisory Client, including relevant sections on risk factors and conflicts of interest, for more detailed and specific information regarding the principal risks applicable to individual Advisory Clients. General – The investments of Advisory Clients are speculative and entail a significant degree of risk and, therefore, should be undertaken only by investors capable of evaluating the merits and risks of the Advisory Clients and bearing the risks they represent, including the potential loss of their entire investment. There can be no assurance that the Advisory Clients will be able to achieve their investment objectives or that significant losses will not be incurred. Market Risk – The Advisory Clients invest in and actively trade securities and other financial instruments or assets (including derivative instruments) utilizing strategies and investment techniques with significant risk characteristics, including risks arising from the volatility of the debt and equity markets. The prices of the financial instruments in which the Advisory Clients invest can be highly volatile. Price movements of equity, debt and other securities, instruments and assets in which the Advisory Clients are invested are influenced by, among other things, credit spreads, interest rates, foreign exchange rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments and national and international political and economic events and policies. Moreover, war, political or economic crisis, financial fraud, or other events may occur which can be highly disruptive to the markets, regardless of the strategies being employed. In addition, governments from time to time

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King Street provides investment advice to the Advisory Clients disclosed above and may provide investment advisory services to other types of clients in the future. Please see Item 4 (Advisory Business).

As described in Item 5 (Fees and Compensation) above, the Advisory Clients pay King Street or its affiliates performance-based compensation. Additionally, RTCM’s ownership of the Risk Retention Interests of a Rockford Tower CDO gives King Street a material pecuniary interest in the performance of such Rockford Tower CDO. The fact that affiliates of King Street are compensated based on trading profits creates an incentive to make investments on behalf of the Advisory Clients that are riskier or more speculative than would be the case in the absence of such compensation. Additionally, to the extent that King Street affiliates are entitled to varying percentages of carried interest terms (including amount, timing, waterfall conditions or other terms) or performance reallocations from the Advisory Clients, King Street is subject to conflicts of interest to the extent it identifies investment opportunities as appropriate for the Advisory Clients from which the affiliates are entitled to receive a higher carried interest percentage. For example, King Street’s ability to receive management fees and performance-based compensation creates an incentive to allocate investments to certain Advisory Clients and not others. King Street has other policies and procedures in place designed to mitigate this conflict, including an allocation policy. Except with respect to Rockford Tower CDOs, the performance-based compensation received by the affiliates of King Street is based primarily on realized and unrealized gains and losses. As a result, some performance-based compensation may be based on unrealized gains that investors do not realize.

Certain of King Street’s affiliates serve as general partners or special shareholders to the Advisory Clients, which are recipients of the performance reallocation from each applicable Advisory Client. See Item 5 (Fees and Compensation). Certain King Street affiliates also serve as “relying advisers” that are registered under the Advisers Act pursuant to King Street’s registration. These affiliated entities operate as a single advisory business together with King Street and serve as general partners, special shareholders or investment advisers to the Advisory Clients and/or other pooled vehicles and generally share common owners, officers, partners, employees and/or persons occupying similar positions.

CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Code of Ethics and Personal Trading King Street has adopted a Code of Ethics and Policies Governing Personal Securities Transactions (“Code of Ethics”). The Code of Ethics states that each of King Street’s employees shall place the interests of the Advisory Clients first. Employees are permitted to invest in securities and other investment products for their own accounts consistent with Rule 204A-1 under the Advisers Act, and in such a manner so as to avoid any actual or potential conflict of interest, or any abuse of an individual’s position of trust and responsibility. These transactions have been, and may in the future be, the same as or different from the transactions that King Street executes for the Advisory Clients. Employees’ personal securities transactions generally must be approved in advance, subject to certain limited exceptions such as accounts for which the employee does not maintain investment control or participate in the investment decisions. The Code of Ethics requires employees to disclose all reportable securities upon hire and at least annually thereafter, disclose all reportable securities transactions at least quarterly, and disclose all personal investment accounts. Employees generally must provide or arrange for their brokers to send King Street account statements and must separately report on a quarterly basis any reportable security transactions that do not appear on an account statement. Gifts and Entertainment The Code of Ethics contains policies and procedures intended to prevent employees from being unduly influenced or unduly influencing others in their decisions by the receipt or provision of gifts or other inducements from or to third parties, such as trading counterparties, vendors and investors. Political Contributions From time to time, King Street and/or its supervised persons make political contributions to persons who serve or seek to serve in elected capacities with certain public entities. These political contributions are permitted only in compliance with Rule 206(4)-5 under the Advisers Act (relating to pay-to-play activities) and corresponding local laws and regulations. Outside Activities

The Code of Ethics requires employees to obtain prior approval to engage in certain outside business activities. From time to time, a principal or employee of King Street or its affiliates or related persons serve as a director (or equivalent) of one or more companies in which one or more of the Advisory Clients invests. Unless restricted by the Governing Documents, King Street personnel are also permitted to serve on boards or act in other roles unaffiliated with King Street, the Advisory Clients or their portfolio companies, including boards of charitable and educational institutions, public companies and former portfolio companies, and receive compensation in connection with such services and roles. Moreover, King Street personnel reserve the right to manage their own personal investments, whether or not through a formal family office or estate planning structure, to establish trusts, endowments, charitable programs, foundations or similar arrangements, and to pay or receive compensation relating to the foregoing. Such personal investment activities, including those conducted through family offices or similar arrangements, can require time, attention and resources and can give rise to conflicts of interest between the personal financial interests of such personnel and the interests of the Advisory Clients. Although King Street has adopted policies and procedures designed to mitigate certain of these conflicts, there can be no assurance that such measures will be effective in eliminating all such conflicts. To the extent an investment opportunity is received that is unsuitable for an Advisory Client, in King Street’s sole discretion, King Street and its personnel reserve the right to refer such opportunity to third parties or to make personal investments in the relevant opportunity, but will not in such circumstances be required to share in or reimburse the relevant Advisory Client for due diligence or other expenses (including broken deal expenses) incurred by the Advisory Client in connection with the Advisory Client’s consideration of the relevant investment opportunity. King Street’s principals, employees, affiliates and related persons will use their best efforts in connection with the purposes and objectives of the Advisory Clients and will devote so much of their time and effort to the affairs of the Advisory Clients as is, in their judgment, necessary to accomplish the purposes of the Advisory Clients and as it deems appropriate to perform its duties in accordance with the Governing Documents of each Advisory Client. However, there is no obligation that they devote any specific amount or percentage of their time to the affairs of the Advisory Clients. A copy of King Street’s Code of Ethics may be obtained upon written request directed to: Chief Compliance Officer, King Street Capital Management, L.P., 299 Park Avenue, 40th Floor, New York, NY 10171 or by calling (212) 812-3130. Material Non-Public or Confidential Information; Other Regulatory Restrictions As a result of King Street’s extensive operations, King Street frequently comes into possession of confidential or material non-public information concerning an entity in which certain Advisory Clients have invested, or propose to invest, and the possession of such information may restrict, by law, internal policies or otherwise, King Street’s ability to buy or sell particular securities or instruments of the issuer on behalf of its Advisory Clients (or to take other actions relating to such securities or instruments), thereby limiting the investment opportunities or exit strategies available to the Advisory Clients. On the other hand, at times, King Street, in an effort to avoid restrictions for its Advisory Clients, elects not to receive, or actively avoids exposure to, information relating to a particular investment that other market participants or counterparties are eligible to receive or have received. As a result, King Street may not possess all of the information relating to the investment that other investors (or prospective investors), including without limitation, lenders, portfolio managers or other market participants, may have, and consequently may from time to time take actions (including, without limitation, purchasing, selling or making other decisions) or refrain from taking actions with respect to investments that it would not take or refrain from taking were it in possession of material non-public information known to other market participants. In addition, the general partner, King Street and/or certain investors in a Fund may be required by law or otherwise to disclose confidential information relating to a Fund, its investors or actual or potential portfolio

investments, including as a result of public records, the Freedom of Information Act or similar laws applicable to certain investors. Any such disclosure could adversely affect an Advisory Client by, among other things, diminishing competitive advantages, limiting exit alternatives or adversely affecting realized prices, and while the general partner reserves the right to seek to limit or resist such disclosure to the extent permitted by law, there can be no assurance that such efforts will be successful, and any related costs may be borne by the Fund. Similarly, anti-money laundering, anti-boycott and economic and trade sanction laws and regulations in the U.S. and other jurisdictions may prevent King Street or an Advisory Client from entering into transactions with certain individuals or jurisdictions. The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and other governmental bodies administer and enforce laws, regulations and other pronouncements that establish economic and trade sanctions on behalf of the U.S. Among other things, these sanctions may prohibit transactions with or the provision of services to, certain individuals or portfolio companies owned or operated by such persons, or located in jurisdictions identified from time to time by OFAC. Additionally, antitrust laws in the U.S. and other jurisdictions give broad discretion to the U.S. Federal Trade Commission, the U.S. Department of Justice and other U.S. and non-U.S. regulators and governmental bodies to challenge, impose conditions on, or reject certain transactions. In certain circumstances, securities regulation, antitrust or other restrictions relating to one Advisory Client’s acquisition of an investment may preclude other Advisory Clients from making an attractive acquisition or require one or more other Advisory Clients to sell all or a portion of certain portfolio companies owned by them. As a result of any of the foregoing, an Advisory Client may be adversely affected because of King Street’s inability or unwillingness to participate in transactions that may violate such laws or regulations, or by remedies imposed by any regulators or governmental bodies. Any such laws or regulations may make it difficult or may prevent an Advisory Client from pursuing investment opportunities, require the sale of part or all of certain portfolio companies on a timeline or in a manner deemed undesirable by King Street or limit the ability of one or more portfolio companies from conducting their intended business in whole or in part. Consequently, there can be no assurance that any Advisory Client will be able to participate in all potential investment opportunities that fall within its investment objectives. Participation or Interest in Advisory Client Transactions King Street does not generally buy or sell securities for its own account except in connection with the Risk Retention Rules as discussed above. However, King Street or its affiliates have an interest, as general partner or otherwise, in one or more of the Advisory Clients. In addition, certain members, directors, officers and employees of King Street and its affiliates own, buy and/or sell interests in the Advisory Clients. Accordingly, King Street and/or its affiliates and employees have a substantial interest in certain of the Advisory Clients managed by King Street. If King Street’s or its affiliates’ interests in an Advisory Client are substantial, the Advisory Client is treated as a principal account of King Street for certain purposes, to the extent required by law. Additionally, an Advisory Client has invested, and under certain circumstances, may in the future invest, in securities of an issuer in which a King Street control person or other affiliate has a control or material beneficial ownership position. To the extent any principal account participates in transactions in securities or other instruments in which other Advisory Clients participate, King Street will ensure that such principal account participates in accordance with King Street’s policies and procedures on allocation of investments and applicable legal and regulatory requirements, if any, and that relevant conflicts of interest are addressed consistent with any applicable fiduciary duty, as further described in Item 8 (Methods of Analysis, Investment Strategies and Risk of loss) above. In certain cases, King Street has determined, and may in the future determine, that it would be in the best interest of a Fund to provide an opportunity for investors to obtain liquidity for all or a portion of their

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General King Street has sole discretion to determine, subject to each Advisory Client’s investment objectives, policies and strategies, the securities to be purchased or sold and in what amounts, the exchanges, broker-dealers and other financial intermediaries to use in effecting transactions for the Advisory Clients, and the commission rates to be paid for such transactions. A more detailed discussion of how King Street makes use of this authority follows. King Street is authorized to determine the broker or dealer to be used for each securities transaction for the Advisory Clients. In selecting brokers or dealers to effect portfolio transactions, King Street will seek “best execution” taking into account such factors as King Street determines to be relevant, which may include price (including the applicable brokerage commission or mark-up or mark-down), size of the order, difficulty of execution, the operational facilities and reliability of the firm involved, the firm’s promptness of execution, adequacy of the firm’s trading infrastructure, technology and capital, the quality of service rendered to King Street or its affiliates in other transactions, confidentiality considerations, the firm’s financial stability and reputation, special execution capabilities, access to underwritten offerings, secondary markets and over-the-counter investment opportunities, the availability of bonds or stocks to borrow for short trades, the firm’s ability to accommodate any special execution or order handling requirements that may surround a particular transaction, any research or brokerage products or services provided by such brokers or dealers, and such other factors as King Street deems appropriate. King Street need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost or spread available. Broker-dealers sometimes suggest a level of business they would like to receive in return for the various services they provide. Actual business received by a broker-dealer may be less than the suggested allocations, but can (and often does) exceed the suggestions because transactions are allocated on the basis of all the considerations described above. Each Advisory Client’s securities transactions can be expected to generate a substantial amount of brokerage commissions and other compensation, all of which the Advisory Clients, not King Street, are obligated to pay. King Street has sole discretion in deciding which brokers and dealers each Advisory Client uses and in negotiating the rates of compensation each Advisory Client pays. In addition to using brokers as agents and paying commissions, each Advisory Client is permitted to buy or sell securities directly from or to dealers acting as principals at prices that include mark-ups or mark-downs, and is

permitted to buy securities from underwriters or dealers in public offerings at prices that include compensation to the underwriters or dealers. In addition, from time to time, King Street executes over-the-counter trades on an agency basis rather than on a principal basis. In these situations, the brokerdealer used by each Advisory Client may acquire or dispose of a security through a market-maker (a practice known as interpositioning). The transaction may thus be subject to both a commission and a mark-up or mark-down. King Street believes that the use of a broker-dealer in such instances can provide anonymity in connection with a transaction. In addition, a broker-dealer may, in certain cases, have greater expertise or ability in accessing the markets and executing a transaction. In light of the fact that certain Advisory Clients’ investment programs include trading as well as investments, short-term market considerations will frequently be involved. King Street believes that the turnover of the portfolios of such Advisory Clients (and, therefore, brokerage related expenses) is substantially greater than the turnover rates of certain other types of investment vehicles. Soft Dollars From time to time, the Advisory Clients pay a broker or dealer commissions (or mark-ups or mark-downs with respect to certain types of riskless principal transactions) at a higher rate than that which another broker or dealer might have charged for effecting the same transaction in recognition of the value of the brokerage and research services provided by the broker or dealer. The use of any commissions or soft dollars to pay for research or brokerage products or services will fall within the safe harbor created by Section 28(e) of the Securities Exchange Act of 1934, as amended (“Section 28(e)”). Products or services furnished or paid for by brokers or dealers may include, without limitation, research products and services, such as research reports on particular industries and companies, economic surveys and analyses, recommendations as to specific securities, performance measurement data, consultations, economic and market recommendations, general reports, quotation services, as well as other brokerage products and services, such as special execution capabilities, clearance, settlement, net pricing, online pricing, block trading and block positioning capabilities, willingness to execute related or unrelated difficult transactions in the future, financial strength and stability, efficiency of execution and error resolution, availability of stocks to borrow for short sales, custody, recordkeeping and similar services. Research obtained by the use of commissions arising from an Advisory Client’s portfolio transactions from time to time is used by King Street in its other investment activities and to service other Advisory Clients, and therefore the Advisory Clients that generated the commissions used to obtain the research are not necessarily, in any particular instance, the direct or indirect beneficiary of the research provided. Under Section 28(e), research or brokerage services obtained with soft dollars generated by an Advisory Client may be used by King Street to service other Advisory Clients, or clients other than that Advisory Client, if any. Where a product or service obtained with soft dollars provides assistance both within the safe harbor created by Section 28(e) and outside of the safe harbor, each Advisory Client will make a reasonable allocation of the cost that are paid for with soft dollars and pay the remaining portion using King Street’s own hard dollars. The portion of the cost of such products and services that King Street allocates to be paid for with soft dollars generated by an Advisory Client will be borne indirectly by the Advisory Client, rather than directly by King Street. Neither the management fees nor the performance-based compensation will be reduced as a result of the use of soft dollars. While soft dollars have been, and may in the future be, used as described above, third-party research-related products or services and brokerage services generally will be paid for directly by the Advisory Clients as an expense. King Street may derive substantial direct or indirect benefits from the use of soft dollars, as they may not otherwise have to produce, develop or acquire such research, products or services. Accordingly, the relationships with brokerage firms that provide soft dollar services present conflicts due to the ability to influence the judgment of King Street in allocating brokerage business of the Advisory Clients and create a conflict of interest in using the services of those brokers or dealers to execute the Advisory Clients’ brokerage transactions.

Aggregation of Trades King Street will typically aggregate sale and purchase orders of securities on behalf of the Advisory Clients if King Street believes that such aggregation is reasonably likely to result in an overall benefit to the Advisory Clients based on an evaluation of factors in King Street’s sole discretion. In many instances, the purchase or sale of securities for the Advisory Clients will be effected simultaneously. In certain instances, such transactions are made at slightly different prices, due to the volume of securities purchased or sold. Each Advisory Client that participates in an aggregated order generally will participate at the average price for all of King Street’s transactions in that investment on a given business day (provided, that this policy is subject to the sole discretion of King Street, and with respect to certain instruments such as option contracts, determining the average price may not be possible), with transaction costs shared pro rata based on each Advisory Client’s participation in the transaction. King Street will receive no additional compensation of any kind as a result of an aggregated order. For certain over-the-counter transactions (e.g., bank debt, derivatives), for administrative and operational reasons, King Street in certain instances executes a transaction in an Advisory Client’s name and enters into a participation agreement granting an interest in the relevant investment to other Advisory Clients or vice versa, rather than having each participant purchase its allocable share directly. Furthermore, King Street has established, and may in the future establish, one or more special purpose vehicles in which one or more of the Advisory Clients have invested, and may in the future invest, for tax, legal, operational or other reasons when deemed to be in the interest of the relevant Advisory Clients. In such circumstances, the Advisory Clients have guaranteed, and may in the future guarantee, the obligations of each other and/or any such special purpose vehicles. Allocation of Investment Opportunities King Street and its affiliates and their respective members, directors, officers and employees (“Affiliated Parties”) have conflicts of interest in allocating investments among, and in effecting transactions and taking actions for, the Advisory Clients, including as a result of having differing economic interests in different Advisory Clients. In order to mitigate these conflicts, King Street has adopted policies and procedures pursuant to which investment opportunities are required to be allocated by King Street and its Affiliated Parties on a fair and equitable basis among the Advisory Clients for which participation in the respective opportunity is considered appropriate, taking into account, among other considerations (a) whether the riskreturn profile of the proposed investment is consistent with the objectives of the Advisory Clients, which objectives may be considered (i) solely in light of the specific investment under consideration or (ii) in the context of the portfolio’s overall holdings and available capital; (b) the potential for the proposed investment to create an imbalance in the portfolio of the Advisory Clients; (c) liquidity requirements of the Advisory Clients; (d) potential tax consequences; (e) legal, contractual or regulatory restrictions; (f) the desire to adjust the risk profile of one or more of the Advisory Clients; (g) there being Advisory Clients with a substantial amount of investable cash (e.g., during a “ramp-up” period) or a substantial reduction in available cash; (h) whether such allocation would create de minimis exposure with respect to such Advisory Clients; and (i) other relevant factors as determined by King Street. In certain instances, such considerations result in allocations among the Advisory Clients on other than a pari passu basis. In addition, the Affiliated Parties generally allocate to Advisory Clients that specialize in investments in a limited set of asset classes, sectors, geographic regions, industries or markets greater than their pari passu share of any investments in such asset classes, sectors, geographic regions, industries or markets. Notwithstanding the foregoing, the Affiliated Parties are generally not under any obligation to share any investment opportunity, idea or strategy with a particular Advisory Client. From the standpoint of the Advisory Clients, simultaneous identical portfolio transactions for each individual Advisory Client tend to decrease the prices received, and increase the prices required to be paid, by each Advisory Client for their portfolio sales and purchases. Further, it may not always be possible or consistent with the investment objectives of each Advisory Client for the same investment positions to be taken or liquidated at the same time or at the same price.

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King Street does not currently provide investment advice to any clients other than the Advisory Clients, and from time-to-time utilizes solicitation arrangements in connection with soliciting investors for Funds. King Street will in the future enter into additional arrangements to provide investment advice to other clients. Broker-dealers (including, without limitation, prime brokers) and other counterparties provide a variety of services, including underwriting and capital introduction services. King Street is not required to direct any volume of business in return for these services. However, it has an incentive to maintain relationships with these firms based on their prior and continued services.

Not Applicable

Depending on the type of Advisory Client, King Street performs various daily, monthly and/or quarterly reviews of their portfolios. These reviews are conducted by various groups within King Street, including: (i) the managing member; (ii) portfolio managers, (iii) investment committee members, traders and research analysts who monitor and review positions and risk; (iv) certain back office personnel who are responsible for valuation, confirmations, settlements, position reconciliation and allocating profits and losses of the Advisory Clients; and (v) certain risk management personnel.

Investors in the Funds generally receive (i) periodic reports containing information regarding the Fund, (ii) annual GAAP audited financial information, and (ii) annual tax information necessary for each investor’s tax return. For Rockford Tower CDOs, an independent trustee is responsible for preparing periodic reports and distributing them to investors. In addition, King Street provides to certain investors, prospective investors and certain other parties, upon request, on such terms as King Street determines, in its sole discretion, certain information relating to the relevant Advisory Client’s portfolio investments.

King Street is deemed to have custody over the assets of the Funds under the Advisers Act because of the authority of King Street and its affiliates over the accounts and assets of these Funds. Although investors in the Funds do not receive statements directly from their respective qualified custodians, they do receive the applicable Fund’s annual financial statements audited by an independent public accounting firm. See Item 13 (Review of Accounts). The audited financial statements are prepared in accordance with generally accepted accounting principles and distributed within 120 days of the applicable Fund’s fiscal year end as required by the Advisers Act. Investors in the Funds are urged to carefully review such statements.

Except in certain limited circumstances, King Street exercises sole discretion in managing the investments of each Advisory Client, based on each Advisory Client’s particular investment objectives, policies and strategies and in accordance with each Advisory Client’s Governing Documents. For more information, please see Item 4 (Advisory Business). Investment guidelines and restrictions are set forth in the respective Governing Documents for each Advisory Client. When selecting securities and determining amounts, King Street observes the investment policies, limitations and restrictions of the relevant Advisory Client for which it advises pursuant to its Governing Documents. For SMAs, King Street enters into an investment management agreement with each client pursuant to which it is authorized to supervise and direct the investment of the account and to execute transactions and related documentation on the client’s behalf in accordance with that agreement. Each such agreement generally sets forth the applicable investment guidelines, restrictions and scope of King Street’s authority.

Purchase and sale transactions (including derivatives transactions and loan participations) have been and may in the future be “crossed” (i.e., effected between Advisory Clients, including Advisory Clients deemed

to be principal accounts for this purpose) if the holdings are independently considered appropriate for purchase and sale by different Advisory Clients, or to adjust the exposure of certain portfolio securities holdings among the Advisory Clients. Such transactions are subject to the following guidelines: (i) they will be effected at a price determined in accordance with each Advisory Client’s valuation policies for the particular securities or assets; and (ii) no extraordinary brokerage commissions or fees (i.e., except for customary transfer fees or commissions paid to a third party for effecting the transfer) or other remuneration will be paid in connection with any such transaction. In addition, subject to any limitations set forth in the applicable Governing Documents, King Street reserves the right to have one Advisory Client invest, directly or indirectly, in the interests of other Advisory Clients. Such ownership creates conflicts of interest, and in certain instances could provide an incentive for King Street to take actions that benefit one or more Advisory Clients over another. In determining how to resolve any such conflicts, King Street seeks to act in a manner that it believes is fair and reasonable under the circumstances. In some circumstances a cross trade will be viewed as a “principal transaction” due to the ownership interest in one or more of the Advisory Clients by King Street, its affiliates or their personnel. To the extent that such a transaction constitutes a principal transaction under the Advisers Act, appropriate consent to the trade will be obtained from the relevant Advisory Clients, as applicable, in accordance with the requirements of the Advisers Act and their Governing Documents, which, in the case of the Funds, generally include approval by a board of directors, advisory committee or independent reviewer. Any decision of a board of directors, advisory committee and/or independent reviewer to approve or disapprove a transaction will be binding on all investors in the relevant Fund. Cross Transactions – King Street has in the past, and is expected to in the future, determine in certain circumstances that it is in the best interests of a particular Advisory Client and of another Advisory Client that the particular Advisory Client should invest in an existing portfolio company of another Advisory Client, or to cause a particular Advisory Client to (i) acquire all or a portion of the interests in one or more portfolio companies from another Advisory Client (including situations where a new Advisory Client is organized by King Street solely for this purpose), or (ii) make a primary investment in such other Advisory Client’s portfolio company. This may be done for various reasons, including but not limited to, to reduce transaction costs, increase execution efficiency, and/or capitalize on opportunities for liquidity and risk management. Such transactions create conflicts of interest because, by not exposing such buy and sell transactions to market forces, an Advisory Client may not receive the best price otherwise possible, or King Street might have an incentive to improve the performance of one Advisory Client by selling underperforming assets to another Advisory Client or by selling attractive assets to another Advisory Client that is seeking to raise capital, in each case in order, for example, to earn fees. These conflicts are heightened to the extent the relevant securities are illiquid or do not have a readily ascertainable value, and there generally can be no assurance that the price at which such transactions are entered into represent what may ultimately be the underlying investment’s fair value. Depending on the transaction structure, such transaction may disproportionately benefit the purchasing or selling Advisory Client (or King Street as a result of its interests in the Advisory Client), and the other Advisory Client may incur expenses or forgo gains that would have been obtained had it not exited such company or companies. The acquisition by an affiliated Advisory Client may also lead to the other Advisory Client holding the remaining portion of the company, if any, longer than it otherwise would have if it had instead disposed of the entire asset, which will increase the risk for loss. Additionally, in connection with such transactions, King Street, its affiliates, and/or their personnel (i) generally have significant investments, or intentions to invest, in the Advisory Client that is selling and/or purchasing such an investment; or (ii) otherwise have a direct or indirect interest in the investment (such as through certain other participations in the investment). King Street and its affiliates receive management fees or other fees in connection with their management of the relevant

Advisory Clients involved in such a transaction, and generally are entitled to share in the investment profits of the relevant Advisory Clients. Any incremental costs and expenses associated with any such investment generally will be borne by such Advisory Clients on a pro rata basis. To address these conflicts of interest, in connection with effecting such transactions, King Street will follow any applicable investment allocation requirements of the relevant Advisory Clients (e.g., the Governing Documents of certain Advisory Clients may provide for the rebalancing of investments at certain times and at a cost set forth in those Governing Documents so that these Advisory Clients’ resulting ownership of investments are generally proportionate to the relative capital commitments or investable assets, as applicable under the relevant Governing Documents, and King Street’s written policies and procedures regarding investment allocation. King Street’s General Counsel or Chief Compliance Officer will be responsible for confirming that King Street (i) considers its respective duties to each Advisory Client; (ii) determines whether the purchase or sale and price or other terms are comparable to what could be obtained through an arm’s length transaction with a third party on commercially reasonable terms; and (iii) obtains any required approvals of the transaction’s terms and conditions. In addition, the relevant Advisory Client general partners (each, a “General Partner”) reserve the right to seek to mitigate such conflicts by seeking the opinion of an unaffiliated third party (including the use of a consultant or investment banker to opine as to the fairness of a purchase or sale price). However, the General Partner does not always expect to obtain such an opinion or consent. While King Street may (but is not required to) engage an independent valuation firm selected by King Street that would either value such investments or review King Street’s valuations, there can be no assurance that such valuations will be accurate. The General Partner also may determine that the willingness of a third-party to make an investment on substantially the same economic terms demonstrates the fairness of the relevant transaction to the Advisory Client under then-current market conditions. Further, Advisory Clients nearing the end of their term are expected from time to time to sell their interest in commonly held investments to other Advisory Clients with more time remaining in their term, which gives rise to the conflicts of interest discussed herein. Conflicts of interest are also heightened in the foregoing transactions to the extent the partners of the General Partner are assigned varying percentages of carried interest from Advisory Clients in the same investment, or if economic terms, performance and/or the potential for carried interest vary between Advisory Clients, particularly when one Advisory Client sells its portion of such investment to another Advisory Client, which could cause a portion of such carried interest to become “crystallized.” The General Partner intends to conduct such transactions in a manner that the General Partner believes to be fair and equitable to each Advisory Client under the circumstances, including a consideration of the potential present and future benefits with respect to each Advisory Client. From time to time, for strategic and other reasons, a co-investor or co-invest vehicle (including a coinvesting or companion Fund) purchases a portion of an investment from one or more Advisory Clients after such Advisory Clients have consummated their investment in the portfolio company (also known as a post-closing sell-down or transfer), which generally will have been funded through Advisory Client investor capital contributions and/or use of an Advisory Client credit facility. Any such purchase from an Advisory Client by a co-investor or co-invest vehicle generally occurs relatively soon after the Advisory Client’s completion of the investment to avoid any changes in valuation of the investment, but in certain instances could occur well after the Advisory Client’s initial purchase. Where appropriate, and in King Street’s sole discretion, in accordance with the relevant Advisory Clients’ Governing Documents and King Street’s written policies and procedures, King Street reserves the right to charge interest on the purchase to the coinvestor or co-invest vehicle (or otherwise equitably to adjust the purchase price under certain conditions), and to seek reimbursement to the relevant Advisory Client for related costs. However, to the extent such amounts are not so charged or reimbursed, they generally will be borne by such relevant Advisory Client.

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King Street has adopted written proxy voting policies and procedures intended to satisfy the requirements of Rule 206(4)-6 under the Advisers Act. King Street will vote proxies in the best interest of the applicable Advisory Client and in accordance with its proxy voting policies and procedures. The proxy voting policy provides, among other things, that in general, if there is a conflict of interest or potential conflict of interest between the applicable Advisory Client, on the one hand, and King Street, on the other, the proxy will be voted in the best interest of the applicable Advisory Client. If King Street determines that any such conflict of interest exists or may be perceived to exist when voting a proxy, King Street, in accordance with its proxy voting policy, may seek to resolve such conflict by: (i) delegating the voting decision for such proxy proposal to an independent third party; (ii) delegating the voting decision to an independent committee of partners, members, directors or other representatives of the Advisory Clients, as applicable; (iii) informing an investing SMA Advisory Client or the investors in the investing Funds, as applicable, of the conflict of interest and obtaining consent to vote the proxy as recommended by King Street; or (iv) obtaining approval of the decision from a King Street legal officer and/or the King Street Conflicts Committee. In general, King Street’s proxy voting policy is to vote in accordance with the recommendation of the company’s management, unless, in King Street’s sole discretion, such recommendation is not in the best interests of the investing Advisory Clients. The Advisory Clients do not have the right to direct King Street on how to vote on a particular matter. There have been, and may in the future be, circumstances when refraining from voting a proxy is in an Advisory Client’s best interest including, without limitation, when and if King Street determines that the cost of voting the proxy exceeds the expected benefit to the Advisory Client. Furthermore, the Advisory Clients invest in non-U.S. securities. The laws and regulations governing shareholder rights and voting procedures differ around the world, and in certain countries, the requirements, restrictions or costs involved with voting may outweigh any benefit that the Advisory Clients would receive by voting the proxies involved. In such cases, King Street may decide, in its sole discretion, it is in the best interests of the Advisory Clients not to vote the applicable proxies. A copy of King Street’s Proxy Voting Policies and Procedures and information on how an Advisory Client’s securities have been voted may be obtained by submitting a written request directed to: Chief Compliance Officer, King Street Capital Management, L.P., 299 Park Avenue, 40th Floor, New York, NY 10171 or by calling (212) 812-3130.

There is no current financial condition that is reasonably likely to impair King Street’s ability to meet its contractual commitments to the Advisory Clients.