KRYGER CAPITAL Ltd

Kryger Capital LLC (“KCLLC” or the “Investment Manager”) provides investment management and portfolio management services to opened-ended Alternative Investment Funds (“AIFs”) and three separately managed accounts, all of which are domiciled in the Cayman Islands. In this brochure, the Private Funds and Managed Accounts together are referred to as the "Clients" or the “Kryger Event Strategy”. All investment advisory services are based on client needs, stated objectives, guidelines and investment restrictions. KCLLC is a Bermuda exempted Limited Liability Company incorporated in June 2021 with Bermuda company registration number 202100012. KCLLC has its registered office at Clarendon House, 2 Church Street, Hamilton, HM11, Bermuda and operates from 3rd Floor, 141 Front Street, Hamilton, HM19 Bermuda. KCLLC is the 100% owner of Kryger Capital Limited (“KC”), a limited company incorporated in May 2020 in England and Wales, whose registered and operational office is at 8th Floor, 35 Dover Street, London, W1S 4NQ, United Kingdom. KCLLC and KC are collectively referred to as the “Firm” or “Kryger Capital”. The Investment Manager is owned by John Melsom, the sole member. Rahul Patel, Portfolio Manager / Head of Research and Trading and Stephen Hill, Chief Operating Officer and Compliance Officer sit on the Management Committee of the Investment Manager alongside John. KC has a Board of Directors. Please see Kryger Capital Corporate Structure below for ownership. KCLLC is licenced to conduct investment business by the Bermuda Monetary Authority (BMA) and has been reporting to the United State Securities Exchange Commission (“SEC”) as an Exempt Reporting Adviser (“ERA”) since February 2022. KC became authorised and regulated in December 2020 by the United Kingdom Financial Conduct Authority (“FCA”) as a full scope Alternative Investment Fund Manager (“AIFM”) and Collective Portfolio Management Investment Firm and has been reporting to the SEC as an ERA since 2021. KCLLC is an Exempt Commodity Trading Adviser (“CTA”) with the National Futures Association (“NFA”) and KC is an Exempt CTA and Exempt Commodity Pool Operator (“CPO”) with the NFA. KCLLC’ s licence under Section 17 of the BMA Investment Business Act 2003 permits KCLLC to manage investments, provide investment advice, dealing in investments, arranging deals in investments and the promotion of investments to funds affiliated with the Kryger Event Strategy. The AIFs managed are registered Overseas Funds pursuant to Section 5A(7) of the Investment Business Act 2003 in Bermuda. Under an Investment Manager Agreement, KCLLC has been appointed to manage the assets of the AIFs in the Kryger Event Strategy. Under a Management Agreement KCLLC relies on KC as AIFM and for risk management, and support services including compliance, operations and risk, fund accounting, finance, marketing and investor relations. KC has also been appointed to market the shares of the AIFs. Please see Kryger Capital Fund Structure for governance and structure. The Kryger Event Strategy follows an actively managed, global event-driven strategy, which John Melsom as the Chief Investment Officer (“CIO”) has refined with over 20 years of investing experience. The Kryger Event Strategy has a long-term track record of over 12 years with the Kryger Event Fund being incorporated in 2013. Senior personnel at the Firm have been actively working together for over 15 years. As Investment Manager, KCLLC subject to the supervision of the Board of Directors of the Kryger Event Strategy AIFs, makes decisions with respect to all purchases and sales of securities and other investment assets and related liabilities on behalf of the Funds and managed accounts and consistent with investment objectives, policies, and restrictions and in accordance with the Offering Memorandums and Management Agreements in place. The Firm does not, and will not, process client money transactions or otherwise handle client money or assets. Wrap Fee Programs The Firm does not participate in wrap fee programs.

Regulatory Assets Under Management As of 31 December 2025, the Firm managed approximately $1,425,976,421 in Regulatory Assets Under Management (RAUM) on a discretionary basis across its relevant Clients in the Kryger Event Strategy.

Fees and Expenses The Investment Manager receives Investment Management, Advisory Management and Performance Fees from the Kryger Event Strategy Funds. All fees are agreed in advance with Clients and clearly stated in the Offering Documents for the AIFs and the Investment Management Agreements / Investment Advisory Agreements with the managed accounts. Clients do not pay any fees in advance. Investment Management Fee The AIFs pay in respect of each Share, an Investment Management Fee equal to an agreed percentage per month of the Net Asset Value per Share (before deduction of that month’s Investment Management Fee and before deduction for any accrued Performance Fees) as at the last Valuation Day in each month, payable monthly in arrears. The Management Fees differ depending on the Share Class and the full details can be found in the Offering Memorandums for each Fund. Performance Fee The Investment Manager is also entitled to receive a Performance Fee from the AIFs calculated on a Shareby-Share basis so that each Share is charged a Performance Fee which equates precisely with that Share’s performance. This method of calculation ensures that (i) any Performance Fee paid to the Investment Manager is charged only to those Shares which have appreciated in value, (ii) all holders of Shares of the same Class have the same amount of capital per Share at risk in the Fund, and (iii) all Shares of the same Class have the same Net Asset Value per Share. The Performance Fee in respect of each Share is calculated in respect of each period of twelve months ending on 31 December in each year (a “Calculation Period”). The Performance Fee is deemed to accrue monthly as at each Valuation Day. For each Calculation Period the Performance Fee in respect of each share class is equal to an agreed percentage of the appreciation in the Net Asset Value per share during that Calculation Period above the Base Net Asset Value per share. The Base New Asset Value per share is the greater of the Net Asset Value per share of the relevant share class at the time of issue of that share and the highest Net Asset Value per share of that share class achieved as at the end of any previous Calculation Period (if any) during which such share was in issue. The Performance Fee in respect of each Calculation Period is calculated by reference to the Net Asset Value before deduction for any accrued Performance Fee. The Performance Fee is normally payable to the Investment Manager in arrears within 14 Business Days after the determination of the Net Asset Value of the Shares following the end of each Calculation Period. However, in the case of Shares redeemed during a Calculation Period, the accrued Performance Fee in respect of those Shares is payable within 14 Business Days following the determination of the Net Asset Value of the Shares with respect to the relevant Redemption Day. In the event of a partial redemption, Shares are treated as redeemed on a first in, first out basis. The Investment Manager may from time to time and at its sole discretion and out of its own resources decide to rebate to intermediaries and/or Shareholders part or all of the Investment Management Fee and/or Performance Fees. Any such rebates may be applied in paying up additional Shares to be issued to the Shareholder or may (at the discretion of the Investment Manager) be paid in cash. If the Investment Management Agreement is terminated before the end of any Calculation Period, the Performance Fee in respect of the then current Calculation Period will be calculated and paid as though the date of termination were the end of such Calculation Period. The Performance Fees differ depending on the Share Class and the full details can be found in the Offering Memorandums for each Fund.

The following table shows the standard management fee and performance fees of the AIFs within the Kryger Event Strategy: Alternative Investment Funds (“AIF”)

Fee Structure

Kryger Event Fund

Kryger Enhanced Fund

Class B Shares Management Fee 1.5% Performance Fee 20%, with high water mark

Class B Shares Management Fee 2.5% Performance Fee 20%, with high water mark

Manager Kryger Capital Limited acts as the “Manager” to the AIFs as detailed in the Fund Structure diagram and Item 4. KC is paid a fee for its services under the Management Agreement out of the fees and expenses payable to the Investment Manager under the Investment Management Agreement. The amount of the fee is agreed between the Investment Manager and the Investment Manager from time to time in accordance with the terms of the Management Agreement. Managed Accounts – Advisory Fees and Performance Fees The Investment Manager charges Advisory Fees and Performance Fees to Managed Accounts in much the same way it does to the AIFs. These fees may, however, be negotiated depending on the account size, the total investment by any individual investor across multiple products, the aggregate investment by related accounts, the complexity of any additional guidelines provided by the Client and other discretionary factors. Other Fees and Expenses The Master Fund pays the fees of the Administrator and the Prime Brokers and Custodians. The Fund pays the costs and expenses of (i) all transactions carried out by it or on its behalf and (ii) the administration of the Fund and indirectly bears its proportional share of the Master Fund’s operating and other expenses, including: (a) the charges and expenses of legal advisors and auditors, (b) brokers’ commissions (if any), borrowing charges on securities sold short and any issue or transfer taxes chargeable in connection with any securities transactions, (c) all taxes and corporate fees payable to governments or agencies, (d) Directors’ fees and expenses, (e) interest on borrowings, including borrowings from the Prime Brokers and Custodians, (f) fees and expenses incurred by the Manager or the Investment Manager in connection with the provision of their respective services pursuant to the Management Agreement and the Investment Management Agreement (as applicable, and including but not limited to software costs associated with portfolio systems, deal related legal costs, fund related legal costs, costs relating to trading, borrowing of cash and securities and other direct costs of trading), (g) communication expenses with respect to investor services and all expenses of meetings of Shareholders and of preparing, printing and distributing financial and other reports, proxy forms, prospectuses and similar documents, (h) the cost of insurance (if any) for the benefit of the Directors, (i) litigation and indemnification expenses and extraordinary expenses not incurred in the ordinary course of business, (j) the cost of obtaining and maintaining a listing of the Shares on any stock exchange, (k) the charges and expenses of the AIF Depositary and (l) other organisational and operating expenses. The Fund and the Master Fund will also meet their respective winding-up and liquidation costs. Other Expenses Aside from the Management, Advisory and Performance Fees, Clients will incur other fees or expenses. These expenses typically include, but not limited to, custodian fees, brokerage services, administration and other transaction fees. Research Fees The Firm has established, and controls, a Research Payment Account (“RPA”) to facilitate compliance with applicable regulatory requirements. The RPA is used to pay for investment research provided by research service providers as selected and pre-approved by the Firm. The methodology for the RPA is consistently applied to all Clients. The RPA is only funded by a specific research charge to the Firm’s Clients which is based on a research budget set by the Firm for the purpose of establishing the amount needed for third party

research in respect of investment services rendered to its Clients and is not linked to the volume or value of transactions executed on behalf of its Clients. Kryger Capital agrees with its Clients, in the investment management agreement or general terms of business the budgeted research charge and the frequency with which specific research charges will apply. Other Compensation Neither KCLLC, KC nor any of its officers, directors or employees accept additional compensation for the sale of securities or other services or other investment services or products.

Method of Analysis

The methods of analysis and investment strategies Kryger Capital employs for a given Client will be as agreed with the Client in the relevant investment management agreement or investment advisory agreement governing that account. Kryger Capital employs the same investment strategy for the AIFs and the Managed Accounts, subject to any agreed limitations. Global event-driven approach – Investment Strategies The Fund employs a global event-driven investment strategy. The Fund invests primarily in the equity and equity related securities of companies that are undergoing significant corporate events. The Fund's mandate is event-driven in the truest sense – it invests predominantly in announced transactions and does not seek to predict corporate activity. The Chief Investment Officer does not follow a pre-defined geographic or industry exposure requirements and targets events that he believes have a high degree of certainty of completion. The Fund’s exposure to these events is increased as their outcomes become clearer; as such, the portfolio will typically be highly concentrated, with the majority of risk in the top ten strategies. Within the eventdriven universe, the Fund does not allocate capital in a fixed ratio across the sub-strategies, but rather allocates capital based on the best risk/reward opportunities.

Risks The descriptions contained below provide a brief overview of certain risks related to the Firm’s investment strategies. They are not intended to serve as an exhaustive list, or a comprehensive description of all risks associated with the investment strategies or specific types of securities described herein. Investing in securities involves the risk of loss that clients should be prepared to bear. Past performance does not guarantee future results and there is no guarantee that the client’s investment objectives will be achieved. For more information about the risks of each of the Private Funds, please see their relevant Private Placement Memorandums and associated offering documents which should be requested from Kryger Capital. Such governing documents provide for a more complete understanding of the investment objectives and strategies applicable to their investments. The strategy is managed within certain risk guidelines including Deal Break Risk and Portfolio liquidity. In tandem with these guidelines various risk management concepts and performance statistics are monitored at a portfolio level as part of the investment management and risk monitoring process, and they include but are not limited to: Concentrations; Exposure analysis; Leverage; Correlations; Periodic stress testing and scenario analysis; Beta; Return P&L analysis/attribution; Volatility; Sharpe Ratio; and Sortino Ratio. Together this allows the total risk of the portfolio using this strategy to be measured and assessed. Margin and counterparty risk also form part of risk monitoring, measurement and assessment. RISK FACTORS Investment in the Kryger Event Strategy carries substantial risk and is suitable only for persons who can assume the risk of losing their entire investment. There can be no assurance that the Fund’s or the Master Fund’s investment objective will be achieved, and investment results may vary substantially over time. Investment in the Fund is not intended to be a complete investment programme for any investor. Prospective investors should carefully consider whether an investment in Shares is suitable for them in light of their circumstances and financial resources. The Feeder Funds invests all of their assets (to the extent not retained in cash) in the ordinary shares of the Master Funds and accordingly are not diversified. For the purpose of these RISK FACTORS the “Feeder Funds” and “Master Funds” can be seen on the following diagram as taken from the Fund Structure diagram above.

The nature of the Master Fund’s investments involves certain risks, and the Master Fund utilises investment techniques (such as leverage, short selling and the use of derivatives) which may carry additional risks. An investment in Shares therefore carries substantial risk and is suitable only for persons which can assume the risk of losing their entire investment. The Manager maintains a risk management policy agreed with the Directors of the Fund which is available on request. Prospective investors should consider, among others, the following factors before subscribing for Shares. Amortisation of Organisational Costs The Fund’s and the Master Fund’s financial statements are prepared in accordance with US Generally Accepted Accounting Principles. US GAAP only permits the amortisation of certain costs relating to the establishment of the Fund and the Master Fund. Notwithstanding this, the Directors may, at their absolute discretion resolve to amortise the organisational costs of the Fund and the Master Fund over a period of time and, this may result in a qualification in the auditor’s report. Availability of Investment Strategies The success of the Master Fund’s investment activities depends on the Investment Manager’s ability to identify overvalued and undervalued investment opportunities and to exploit price discrepancies in the financial markets, as well as to assess the import of news and events that may affect the financial markets. Identification and exploitation of the investment strategies to be pursued by the Master Fund involves a high degree of uncertainty. No assurance can be given that the Investment Manager will be able to locate suitable investment opportunities in which to deploy all of the Master Fund’s assets or to exploit discrepancies in the securities and derivatives markets. A reduction in money market liquidity or the pricing inefficiency of the markets in which the Master Fund seeks to invest, as well as other market factors, will reduce the scope for the Master Fund’s investment strategies. The Master Fund may be adversely affected by unforeseen events involving such matters as changes in interest rates or the credit status of an issuer, forced redemptions of securities or acquisition proposals, break-up of planned mergers, unexpected changes in relative value, short squeezes, inability to short stock or changes in tax treatment. Use of Estimates In calculating the Net Asset Value of the Fund and the Master Fund, and each Class Account, reliance may be placed on the use of estimates and assumptions. There is a risk that the Net Asset Value finalised using these estimations or assumptions may differ from actual values and accordingly that Net Asset Value may be overstated or understated, as the case may be. There is a risk that an investor may redeem on the basis of the Net Asset Value that is lower than the actual Net Asset Value. Similarly, an investor may overpay if the actual

value of the investment is lower than the Net Asset Value as calculated and at which they subscribed for Shares. Borrowing The Master Fund uses borrowings for the purpose of making investments and/or meeting redemptions. The use of borrowing creates special risks and may significantly increase the Fund’s or the Master Fund’s investment risk. Borrowing creates an opportunity for greater yield and total return but, at the same time, will increase the Fund’s and the Master Fund’s exposure to capital risk and interest costs. Any investment income and gains earned on investments made through the use of borrowings that are in excess of the interest costs associated therewith may cause the Net Asset Value of the Shares to increase more rapidly than would otherwise be the case. Conversely, where the associated interest costs are greater than such income and gains, the Net Asset Value of the Shares may decrease more rapidly than would otherwise be the case. Business Risk There can be no assurance that the Fund or the Master Fund will achieve their investment objective. Past performance should not be regarded as an indication of future performance. The investment results of the Fund and the Master Fund are reliant upon the success of the Investment Manager, whose historical performance should not be regarded as an indication of its likely future performance. Concentration of Investments The Fund invests all of its assets in ordinary shares of the Master Fund and is accordingly not diversified. Although it is the policy of the Master Fund to diversify its investment portfolio, the Master Fund may at certain times hold relatively few investments. The Master Fund could be subject to significant losses if it holds a large position in a particular investment that declines in value or is otherwise adversely affected, including default of the issuer. Counterparty Risk – Prime Brokers and Custodians In relation to the Master Fund's right to the return of assets equivalent to those of the Master Fund's investments and other assets all rights, title and interest in and to which has been transferred to a Prime Broker and Custodian or which a Prime Broker or Custodian borrows, lends, pledges, charges, rehypothecates, disposes of or otherwise uses for its own purposes, the Master Fund will rank as one of each Prime Broker and Custodian’s unsecured creditors and, in the event of the insolvency of the applicable Prime Broker and Custodian, the Master Fund might not be able to recover such equivalent assets in full. In addition, the Master Fund’s cash held with a Prime Broker and Custodian is not segregated from that Prime Broker and Custodian’s own cash and may be used by that Prime Broker and Custodian in the course of its business and the Master Fund ranks as an unsecured creditor in relation thereto. Counterparty Risk – Other Counterparties The Fund and the Master Fund are also subject to the risk of the inability of any counterparty other than the Prime Brokers and Custodians to perform with respect to transactions, whether due to insolvency, bankruptcy or other causes. Cross Class Liabilities The Fund has the power to issue Shares in classes. The Articles provide for the manner in which the liabilities are to be attributed across the various classes (liabilities are to be attributed to the specific class in respect of which the liability was incurred). However, the Fund is a single legal entity and there is no limited recourse protection for any class. Accordingly, all of the assets of the Fund will be available to meet all of its liabilities regardless of the class to which such assets or liabilities are attributable. In practice, cross-class liability is only expected to arise where liabilities referable to one class are in excess of the assets referable to such class and it is unable to meet all liabilities attributed to it. In such a case, the assets of the Fund attributable to other classes may be applied to cover such liability excess and the value of the contributing classes will be reduced as a result. Currency Exposure The Shares other than the EUR Shares, the GBP Shares and the JPY Shares are denominated US Dollars and the EUR Shares, the GBP Shares and the JPY Shares are denominated in Euros, Sterling and Japanese Yen, respectively. The Shares are issued and redeemed in those currencies. However, the Fund is denominated in

Read the rest in the brochure

Kryger Capital provides discretionary investment services to Private Funds and separately managed accounts, all of which are exempt from the definition of an investment company under the Investment Company Act of 1940. Kryger Capital will only engage with private funds and separately managed accounts that are classified as professional clients, eligible counterparties, qualified purchasers or accredited investors. Kryger Capital also provides Managed Account services to certain investors.

As stated above, Performance Fees are charged to Clients based on the capital appreciation of each Client’s assets under management. All Performance Fees charged to US persons will comply with Rule 205-3 under the Investment Advisers Act of 1940 (“Advisers Act”). While the Investment Manager believes that performance-based fee arrangements align the adviser's interests with the interests of its Clients, performance-based compensation may create an incentive to make investments that are riskier or more speculative than would be the case in the absence of the performancebased compensation. In addition, the performance on which performance-based compensation is calculated may include unrealised appreciation and depreciation of investments that may not ultimately be realised. Such fee arrangements also create an incentive to favour higher fee-paying Clients over others. The Firm has adopted policies and procedures that seek to: mitigate any such conflicts presented by its performance-based fee arrangements; to ensure that all Clients are treated fairly; and to prevent fee-related conflicts from influencing the allocation of investment opportunities among its Clients. The Firm’s Allocation Policy is designed to ensure that Clients’ accounts are treated equitably under all circumstances. The Investment Manager does not favour any Client or subset of Clients when it engages in side-by-side trading of the Managed Accounts and / or Private Funds.

As noted above, Kryger Capital LLC is 100% owner of Kryger Capital Limited. KCLLC performs portfolio management services whilst KC performs risk management and operational services. The Investment Manager does not believe that any of its, or its subsidiary, activities and/or affiliations create any material conflicts of interest.

Trading High ethical standards are essential for success and to maintain the confidence of clients. The Investment Manager’s long-term business interests are best served by adherence to the principle that the interests of its Clients come first; the Investment Manager has a fiduciary duty to its Clients to always act for their benefit. All personnel of the Investment Manager must put the interests of its Clients before their own personal interests and must act honestly and fairly in all respects in dealings with clients. All personnel must also comply with all federal securities laws. The Investment Manager has established procedures intended to limit conflicts of interest in cases where the Investment Manager, a related person or any of its employees, buys or sells securities recommended by the Investment Manager to its Clients. Generally accepted principles are that employees may invest their money but should avoid “trading”. The policy is that employees must avoid investments in any positions that may lead to the accusation of front running Clients or improperly gaining from a Clients’ activities. The generally accepted principles are that specific stocks traded by the Investment Manager on behalf of its Clients should be avoided by all staff, whereas positions in instruments such as indices would be considered reasonable. As discussed, Kryger Capital has adopted a Code of Ethics governing personal trading by its personnel. Among other requirements, the Code of Ethics requires personnel who have access to Clients’ portfolio information or Kryger Capital’s non-public recommendations to report their personal securities transactions and holdings to Kryger Capital. Statements of investment holdings must be disclosed by all individuals upon joining the Firm, and thereafter on an annual basis. These statements must come directly to the Compliance Team from the brokerage firm or equivalent and not via the individual. Only brokerage firms that will provide

a copy of all transactions and statements in this way may be used and these are reconciled by the Compliance Team. All transactions must be pre-approved by the Compliance Team. Generally, the approval will be good for 24 hours only and will then lapse and fresh approval required. Employees are required to avoid transactions in any asset where there may be a perception of impropriety, typically where transacting in any position held by the Private Funds or other Clients, though exceptions for certain positions (e.g. indices) may be granted with approval by the Compliance Team. Principal Transactions To the extent that Cross Trades may be viewed as principal transactions (as such term is used under the Advisers Act) due to the ownership interest in a fund by the general partner or otherwise, the Firm or its personnel, will comply with the requirements of Section 206(3) of the Advisers Act for any principal transactions. Please refer to the offering documents for the Funds for further information regarding consent mechanisms for principal transactions. Conflicts of Interest Created by Contemporaneous Trading Investment advisers that manage accounts for multiple clients have a number of obligations governing their allocation of orders and their ability to aggregate trades across clients. The Firm has multiple Clients that are investing in the same securities, therefore KC will allocate investment opportunities to those Clients on a fair and equitable basis, to the extent that is practical and in accordance with Clients’ applicable investment strategies, over a period of time. As mentioned in Item 12, the Firm has an “Allocation and Aggregation” policy designed to allocate investment opportunities among Clients in a fair and equitable manner.

The Firm has no obligation to deal with any specific broker-dealer in the execution of transactions in portfolio securities. Consistent with the interests of its clients, the Firm is committed to achieving best execution on trades. The Firm acts in accordance with the best interests of the Firm’s client when placing orders through brokers, and when executing orders directly with the market. The Firm looks at several factors when reviewing best execution and in selecting broker-dealers with whom to place orders for purchases and sales of securities on behalf of Clients including: Price; Cost; Speed; Research; Access to companies; Liquidity; Likelihood of execution and settlement; Client Objectives; Order size / nature; and Venue. The Firm will also consider the quality of broker-dealer firms with which it seeks to execute Clients’ orders, the adequacy of lines of communication, timelines of reports of order execution, the capacity to accommodate unusual trading volume and the preservation of client anonymity, among other factors. All broker-dealers must be pre-approved by the Compliance Team before engaging. As per Item 5, the Firm engages with certain, approved, research service providers. The Firm does not engage in soft-dollar arrangements.

The Firm does not accept clients who require it to execute transactions through a specified broker-dealer. Securities transactions in investment advisory accounts are normally implemented on a consistent basis across accounts. To accomplish this, subject to the Firm's duty of best execution, orders are aggregated (bunched) and allocated fairly. In addition to considerations of equity, bunching avoids placing competing orders, improves order management, and may, because of larger order size, permit some degree of price improvement relative to a series of individually placed orders. Trade Errors Kryger Capital makes and implements investment decisions for its Clients consistent with its fiduciary duty. However, trades may occasionally be incorrectly executed due to technical issues or due to keystroke, typographic or inadvertent drafting errors, or other human error at the time of entry or execution of a trade. Any trading errors that occur will be reviewed on a case-by-case basis and allocated accordingly between the relevant Client account(s) or the investment manager dependent upon and in accordance with the applicable investment management agreement or offering memorandum. Cross Trading Cross trading gives rise for potential conflicts of interest between Kryger Capital’s Clients. However, Kryger Capital considers it to be in the best interest of its Clients to engage when it is beneficial for both Clients that take part. Accordingly, Kryger Capital may engage in cross trades provided that such trades are conducted in accordance with its cross trading policy which sets out that: • the cross trade is in the best interest of each Client; • the cross trade must be consistent with the investment policies of each Client participating in the transaction; and • the cross trade may only be undertaken in securities that are actively traded in agency or dealer markets. Aggregation and Allocation When the Firm determines that an investment opportunity is appropriate for more than one Client account, the Firm may aggregate (“bunch”) orders to purchase or sell the same security. Aggregation is used when the Firm believes it will be advantageous to Clients to trade as a block rather than as separate, individual orders. Block trades are allocated on a fair and equitable basis over time, taking into account factors such as account size, available cash, investment objectives or restrictions, existing positions, and risk tolerances. The Firm maintains written trade allocation and aggregation procedures designed to ensure that no Client is systematically advantaged or disadvantaged over another. Research As per Item 5, the Firm controls a Research Payment Account for its Clients. The allocation of a Firm’s research budget must be subject to appropriate controls and senior management oversight to ensure it is managed and used in the best interests of the Firm’s Clients. The Firm’s procedures for using third party research addresses the extent to which research purchased through an RPA may benefit clients’ portfolios, including, where relevant, by taking into account investment strategies applicable to various types of portfolios, and the approach the Firm will take to allocate such costs fairly to its Clients.

Kryger Capital does not engage in client referrals or compensate in any other manner directly or indirectly to any person who is not an Kryger Capital supervised person for client referrals.

None of Kryger Capital LLC, Kryger Capital Limited or their supervised persons have been involved in any legal or disciplinary events that are material to a Client’s or a potential client’s evaluation of the advisory business or to the integrity of Kryger Capital LLC, Kryger Capital Limited and/or their management.

Kryger Capital's Operations and Compliance Teams perform a regular review of portfolio holdings to ensure that transactions are within the parameters of Client objectives. The Clients that Kryger Capital advises and the investors in the Private Funds receive regular monthly reporting. Such reports provide information on account balances, monthly performance, and other information designed to provide a comprehensive assessment of their portfolios. Investor Statements are produced independently by the Private Fund Administrators.

Kryger Capital does not hold Client assets, and an independent custodian has been engaged for such purposes. The Private Funds are independently audited by a firm registered with the Public Company Accounting Oversight Board (“PCAOB”). Private Fund investors receive account statements directly from a qualified custodian and are encouraged to review those account statements received from the custodian. The Private Funds are (1) audited at least annually and (2) independently distribute their audited financial statements prepared in accordance with generally accepted accounting principles (GAAP) to investors. The Private Funds are required to do this within 120 days of the end of their fiscal year end, excluding its first year.

Kryger Capital has been appointed by Clients to provide them with portfolio management services on the terms set out in the respective investment management agreements. These agreements provide Kryger Capital with the authority to manage Clients’ assets on a discretionary basis, including determining what investments are made, as well as when and how they are made, subject to reasonable restrictions, limitations or other requirements imposed with respect to each Client’s accounts.

From time to time, companies in which Kryger Capital invests may submit certain matters to a vote of its security holders. The right to vote is usually available to equity holders and not to holders of company debt. As a fiduciary and investment adviser, Kryger Capital is obligated to vote proxies in the best interests of its clients. Kryger has developed and implemented a process that is designed to ensure that proxy voting is conducted in an appropriate manner, consistent with clients’ best interests and within the framework of its Proxy Voting Policy.

Kryger Capital has adopted Proxy Voting Policies and procedures pursuant to Rule 206(4)-6 of the Advisers Act designed to ensure that proxies are voted prudently and solely in the best interest of its Clients. Kryger Capital operates a policy of exercising proxy votes for clients as permitted within Client agreements. Voting is undertaken at all times in the best interests of Clients and for their benefit.

No financial events or conditions have occurred to or with Kryger Capital LLC nor Kryger Capital Limited that would negatively affect its financial viability or impair its ability to meet contractual commitments to Clients. A balance sheet is not required to be provided as Kryger (i) does not solicit fees more than six months in advance, (ii) does not have a financial condition that is likely to impair its ability to meet contractual commitments to clients and (iii) has not been subject to any bankruptcy proceeding during the past 10 years.