Lexington Partners

Overview The Lexington Partners organization was founded in 1994 and is one of the largest managers of secondary private equity and co-investment funds. Lexington Partners L.P., a Delaware limited partnership, is a registered investment adviser which has been in business since March 19, 2008. For purposes of this brochure, “Lexington” includes (where the context permits) affiliated general partners of the Lexington Funds (as defined below) and other Lexington affiliates that provide or may provide advisory services to the Lexington Funds but, for the avoidance of doubt, does not include Franklin Templeton (as defined below). Effective April 1, 2022, Franklin Resources, Inc. (together with its affiliates (but excluding Lexington), “Franklin Templeton”) acquired 100% of the equity in Lexington Partners L.P. (the “FT Transaction”). Franklin Resources, Inc.’s common stock is traded on the New York Stock Exchange under the ticker symbol “BEN.” In addition, Lexington partners and employees hold a 25% profit interest in Lexington Partners L.P. indirectly through Lexington Partners MIP L.P., which is a limited partner of Lexington Partners L.P. Franklin Templeton has agreed to irrevocably delegate the authority to manage the day-to-day business and affairs of Lexington to the Lexington Operating Committee, currently composed of Lexington’s President and Chief Financial Officer, until March 31, 2033, subject to limited exceptions. However, Franklin Templeton has sole ultimate control of Lexington Partners L.P. (including Lexington and the Lexington Funds) and may, under certain circumstances, terminate the employment of any or all of the current personnel of Lexington. Lexington and/or its affiliates provide financial, investment and portfolio analysis services as required for the benefit of Lexington’s “secondary” private equity funds (including, for the avoidance of doubt, funds pursuing a “continuation vehicle” strategy), co-investment funds and managed accounts (collectively, the “Lexington Funds”) whose securities are not registered under the Securities Act of 1933, as amended, and the rules and regulations promulgated thereunder (the “Securities Act”). Lexington’s affiliate Lexington Advisors LLC (“Lexington Advisors”) (which is also an SEC-registered investment adviser) serves as a sub-adviser to a Delaware statutory trust registered under the Investment Company Act of 1940, as amended, and the rules and regulations promulgated thereunder (the “Investment Company Act”), as a non-diversified, closed-end management investment company (the “U.S. Registered Fund”) and a Luxembourg-domiciled Part II UCI (the “Offshore Registered Fund,” and, together with the U.S. Registered Fund, the “Registered Funds”). Certain sections of this brochure contain limited references to the Registered Funds, and additional information about the Registered Funds, including descriptions of certain relevant risks and conflicts, is included in Lexington Advisors’ Form ADV brochure. Detailed information about the Registered Funds can be found in their prospectuses and related offering documents, which are publicly available on the Franklin Templeton website. Lexington’s primary investment focus on behalf of the Lexington Funds is to seek capital appreciation by acquiring diversified portfolios of private investment fund interests (generally through secondary market purchases) and, in certain circumstances, directly or indirectly, privately held portfolio company interests, and holding and realizing upon such interests. Lexington also advises the Lexington Funds with respect to making “primary market” commitments to private

investment funds that have recently been formed or are otherwise still fundraising, and participating in co-investment and other transactions, including “continuation vehicle” transactions, that are sponsored by managers or general partners of private investment funds and/or other associated management teams. The Lexington Funds generally seek capital appreciation through investments in private investment funds and privately held portfolio companies, but also make investments in publicly traded securities. The investments made by Lexington for the Lexington Funds are subject to compliance with such Lexington Funds’ investment strategies and restrictions and applicable law. Lexington tailors its advisory services to the specific investment objectives and restrictions of each Lexington Fund pursuant to the investment guidelines and restrictions set forth in such Lexington Fund’s confidential private placement memorandum, limited partnership agreement, advisory agreement and other governing documents, as applicable (collectively, the “Governing Documents”). Investors of each Lexington Fund (generally referred to herein as “investors,” “partners” or “limited partners”) should refer to the Governing Documents of such Lexington Fund for complete information on the investment objectives and investment restrictions with respect to such Lexington Fund. Investment advice is provided directly to the Lexington Funds, subject to the discretion and control of the general partner of the relevant Lexington Fund, and not individually to the investors in the Lexington Funds. There can be no assurance that any of the Lexington Funds’ investment objectives will be achieved. The Lexington Funds generally are offered exclusively to “accredited investors,” as such term is defined in Section 501(a) of Regulation D under the Securities Act, and/or “qualified purchasers,” as such term is defined in Section 2(a)(51)(A) of the Investment Company Act of 1940, as amended, and the rules and regulations promulgated thereunder (the “Investment Company Act”), and are eligible to rely on Section 3(c)(1) or Section 3(c)(7) of the Investment Company Act. Therefore, the Lexington Funds are not required to register as investment companies under the Investment Company Act in reliance upon certain exceptions applicable to private investment funds whose securities are not publicly offered. A related entity of Lexington generally acts as general partner of each Lexington Fund, and Lexington or its affiliate Lexington Advisors is the investment adviser of each Lexington Fund. Investment advisory services are provided to the Lexington Funds in accordance with the Governing Documents of the applicable Lexington Fund. Lexington expects to provide specific portfolio management services to certain private investment funds that are managed by an alternative investment fund manager (whether affiliated or unaffiliated with Lexington) for the purposes of the Alternative Investment Fund Managers Directive (the “Directive”). In accordance with common industry practice, one or more of the Lexington Funds’ general partners have entered (and/or expect to enter) into “side letters” or similar agreements with certain investors pursuant to which the general partner grants the investor specific rights, benefits, or privileges that are not made available or disclosed to investors generally except as required under the Governing Documents of the applicable Lexington Fund. Additional details regarding the types of side letters that may be entered into with certain investors generally are described in the Governing Documents with respect to a Lexington Fund. To the extent Lexington or a Lexington Fund incurs third-party expenses in connection with compliance with a side letter provision, such

expenses may be, in the sole discretion of Lexington, borne either by the investors that have the benefit of such provision or by all investors in the relevant Lexington Fund. In addition to providing advisory services to the Lexington Funds, Lexington provides nondiscretionary sub-advisory services to StepStone Group LLC (“StepStone”) with respect to a portfolio of private investment funds managed by StepStone in which certain Lexington Funds are invested. Lexington does not participate in any wrap fee programs. Lexington manages all assets of the Lexington Funds on a discretionary basis in accordance with the terms and conditions of each Lexington Fund’s Governing Documents. As of September 30, 2025, the amount of assets Lexington manages on a discretionary basis is $79,274,402,408. 1

Compensation and Fee Schedules All investors and prospective investors in a Lexington Fund should review the Governing Documents of the applicable Lexington Fund in conjunction with this brochure for complete information on the fees and compensation payable with respect to such Lexington Fund. Different Lexington Funds are subject to different advisory fees as compensation for the investment advisory services rendered to the applicable Lexington Fund (each, an “Advisory Fee”), typically calculated based on committed capital or the sum of the fair market value of portfolio investments and reserves for portfolio investments, or capital contributions (including outstanding borrowings by such Lexington Fund) for unrealized portfolio investments, with respect to such Lexington Fund, in each case as set forth in the Lexington Funds’ Governing Documents. Lexington also receives performance-based compensation from the Lexington Funds as described further in the section titled “Performance-Based Fees and Side-by-Side Management”. The precise amount, and the manner and calculation, of the Advisory Fees for each Lexington Fund are established by Lexington and are set forth in such Lexington Fund’s Governing Documents, which are received by each investor prior to making an investment in such Lexington Fund. In certain circumstances, the Advisory Fees payable to Lexington by individual investors in a Lexington Fund will vary among such investors (e.g., based on size and aggregation of commitment, timing of admission or otherwise) and may be negotiable. Lexington also has discretion in determining whether size-based commitments will be aggregated for purposes of determining certain Advisory Fee rates, and treatment among investors is expected to vary. Moreover, personnel and certain business associates and “friends and family” of Lexington or its personnel (collectively, “Adviser Investors”) typically will not pay or bear any Advisory Fees with respect to their direct or indirect investments in the Lexington Funds. Notwithstanding that Adviser Investors will generally not pay or bear Advisory Fees, Adviser Investors will bear their pro rata share of certain Lexington Fund expenses or such Adviser Investors’ pro rata portion of such expenses will be allocated to Lexington. Discretionary assets under management include the Lexington Funds’ asset values and uncalled commitments as of September 30, 2025, and additional investor commitments closed between October 1, 2025 and November 30, 2025.

Advisory Fees paid by a Lexington Fund are indirectly borne by investors in such Lexington Fund. Investors and prospective investors in each Lexington Fund should note that similar advisory services may (or may not) be available from other investment advisers for similar or lower fees and that fees may differ among investors in the same Lexington Fund. All clients of Lexington (and all Lexington Fund limited partners) are “qualified purchasers” as defined in Section 2(a)(51) of the Investment Company Act and, therefore, Lexington has not included specific fee information in this brochure. Deduction of Fees; Timing of Payments; Termination Lexington is authorized under the Governing Documents to charge and deduct Advisory Fees directly from the Lexington Funds. Payments of Advisory Fees are generally made quarterly in advance and in accordance with the terms of the Governing Documents of the applicable Lexington Fund. As a general matter, Advisory Fees will be payable during term extensions unless otherwise agreed with investors. Please refer to the Governing Documents of each of the Lexington Funds for complete information on the timing of Advisory Fee payments. Upon termination of any Lexington Fund’s advisory relationship with Lexington, any prepaid, unearned fees will be promptly refunded to such Lexington Fund, and any earned, unpaid fees will be due and payable. Other Fees and Expenses Consistent with the Governing Documents of the Lexington Funds, in addition to the Advisory Fees and performance-based compensation payable to Lexington, each Lexington Fund (and indirectly, the investors thereof) will incur and/or bear certain charges including, but not limited to: fees, costs and expenses of any administrators (including administrators that perform antimoney laundering or “know your customer” diligence and investor verification services in connection with the ongoing participation of investors in the Lexington Funds), independent appraisers, custodians, depositaries, attorneys, accountants, auditors, tax advisors, “tax matters partners” or “partnership representatives,” consultants, brokers, agents, research-related data providers, independent appraiser and valuation firms or experts or other professionals (including advisors to Lexington); costs associated with preparing, printing, and distributing communications and reports to investors and monitoring investor portfolio activity (including, without limitation, accounting or financial management software and other expenses (including third party expenses) incurred in connection with secure communications to the limited partners, the preparation of financial statements, tax returns, Schedules K-1 and other accounting or similar administrative functions); out-of-pocket costs and expenses, if any, incurred in connection with developing, negotiating, structuring, monitoring, custodying, or, to the extent applicable, disposing of, portfolio investments of the Lexington Fund (whether or not consummated), including, without limitation, any financing, legal, tax, accounting, advisory, consulting, software or other professional expenses in connection therewith, any liquidated damages, reverse termination fees or similar payments, and expenses incurred in connection with organizing the Lexington Fund and its related entities (including, for example, any entities used to acquire, hold, or dispose of any one or more investments or otherwise to facilitate investment activities), and the offering of interests in the Lexington Fund (including expenses relating to organizational and governing documents,

prospectuses, diligence responses, disclosure documents, legal opinions, side letters and similar agreements, printing fees, filing fees, meetings with prospective investors and travel related thereto), as well as attending meetings related to portfolio investments and portfolio companies, including, without limitation, any related legal, tax and accounting fees and expenses, travel expenses, costs and expenses of meetings with representatives thereof, maintenance and formation and/or filing fees; the costs and expenses (including travel, set-up, room and board, honorarium, dining, entertainment and related expenses) of holding meetings or conferences with one or more of the Lexington Fund’s investors and/or advisory board(s) (including observers); out-of-pocket costs and expenses, if any, incurred by or on behalf of the Lexington Fund in developing, negotiating and structuring prospective or potential portfolio investments which are not ultimately made, including, without limitation, any legal, accounting, advisory, financing, broken-deal, travel, consulting and other professional costs, fees and expenses in connection therewith (to the extent not otherwise reimbursed); investment banking, brokerage commissions, prime brokerage fees, registration fees and expenses, custodial expenses, other bank service fees and other investment costs, fees and expenses actually incurred in connection with actual portfolio investments; expenses incurred in connection with compiling and complying with provisions in side letter agreements (including the process of distributing and implementing applicable elections pursuant to any “most-favored-nations” clauses in side letters) or in connection with any amendments to any partnership agreement of such Lexington Fund or certain related entities; extraordinary expenses of the Lexington Fund, including, without limitation, the costs of any pending or threatened litigation, audit, investigation, administrative or other proceedings (including out-of-pocket costs and expenses, if any, associated with any third-party examination or audits (including similar services) of the Lexington Fund or Lexington that are attributable to the operation of such Lexington Fund or requested by one or more investors in the Lexington Fund (but, for the avoidance of doubt, excluding any SEC or similar regulatory examination)), settlement or review of the business or activities of the Lexington Fund, D&O liability, fidelity bonding or other insurance and any indemnification or extraordinary expense (including judgments, fines, other awards and settlements paid in connection therewith) or liability relating to the affairs of the Lexington Fund; all out-of-pocket fees, costs and expenses, if any, incurred in connection with the Lexington Fund’s legal and regulatory compliance with U.S. federal, state, local, non-U.S. or other law, rule or regulation (including, for example and without limitation, Form PF, filings with CFIUS or other matters related to the U.S. Defense Protection Act or CFIUS or similar U.S. or non-U.S. regulations, FATCA and related foreign account reporting regimes (including, without limitation, the OECD Standard for Automatic Exchange of Financial Account Information in Tax Matters – the Common Reporting Standard and any associated guidance), the Directive and related European Economic Area national private placement laws or other similar non-U.S. laws, rules or regulations relating to the foregoing or the implementation thereof in any relevant jurisdiction, including any registrations, licenses, notices, reports and/or filings required in accordance with the AIFM Directive or the European Union Sustainable Finance Disclosure Regulation and any other applicable legislation or regulations related to the European Commission’s Action Plan on Financing Sustainable Growth, similar filings required in other jurisdictions, all costs incurred in complying with the Directive or other local rules and regulations, including the engagement, organization or maintenance of any entity used in connection with compliance by the Lexington Fund with the Directive or other local rules and regulations (including any entity engaged or established to be the “alternative investment fund manager” of the Lexington Fund within the meaning of the Directive as well as any travel and accommodation

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Investments and potential investments are analyzed by Lexington based on (i) with respect to investments in private investment funds, the investment strategy and focus of the underlying private investment funds, the relevant experience of the underlying private investment funds’ managers, the past performance of related private investment funds, if any, and any other methods deemed appropriate, and (ii) with respect to investments in equity and quasi-equity securities and

securities distributed in kind to the Lexington Funds, the “fundamental” analysis of the issuers of such securities. Lexington’s principal sources of information (i) with respect to investments in private investment funds, include private offering memoranda, quarterly and annual reports of the underlying private investment funds, personal interviews with the underlying private investment funds’ managers, and reference checks on the underlying private investment funds’ managers, and (ii) with respect to investments in equity and quasi-equity securities of an entity, include private offering memoranda, quarterly and annual reports, personal interviews with directors and officers of such entities and visits to such entities, SEC filings (if available) and general industry knowledge. Lexington provides investment advice on various types of private investments. As described above, Lexington’s primary investment strategy is to seek capital appreciation by acquiring diversified portfolios of private investment fund interests (generally through secondary market purchases) and, in certain circumstances, privately held portfolio companies, and holding and realizing on such interests. Lexington also provides advice with respect to making “primary market” commitments to private investment funds that have recently been formed or are otherwise still fundraising and participating in co-investment and other transactions, including continuation vehicle transactions, that are sponsored by managers or general partners of private investment funds and/or other associated management teams. The task of identifying investment opportunities and managing private equity investments is difficult. There can be no assurance that a Lexington Fund will be able to make and/or realize any particular investment or that the Lexington Funds will be able to generate returns for their investors. The marketability and value of any such investments will depend upon many factors beyond the control of Lexington and the Lexington Funds. In addition, there can be no assurance that any investor will receive any distribution from a Lexington Fund. Investing in the Lexington Funds involves a risk of loss that investors should be prepared to bear. Investors in the Lexington Funds should carefully consider, among other factors, the following material risks involved with Lexington’s investment strategies. Investors in the Lexington Funds are requested to refer to the Governing Documents of the applicable Lexington Fund for complete information on investment strategies employed by such Lexington Fund and the corresponding risks associated with such investment strategies. Risks Inherent in Investments in the Lexington Funds A successful program of investing is subject to risks related to (i) the quality of the management of the respective private investment funds in which the Lexington Funds invest (the “Investment Funds”); (ii) the ability of the management of the Investment Funds to select successful investment opportunities; (iii) general economic conditions; and (iv) the ability of the Lexington Funds and the Investment Funds to liquidate their investments. There can be no assurance that the investments made by the Investment Funds will result in rates of return to the Lexington Funds that are equal to or better than the average rate of return on investments in other partnerships, or that the performance of any Investment Fund will equal or exceed the performance of past investments made by Lexington. Historically, private equity returns have varied greatly over time, depending on the conditions at the time investments were made and when the private equity partnerships exited such investments. In addition, each private equity subclass may exhibit

considerable volatility of returns. The Lexington Funds may not be successful in meeting their respective performance objectives. Investors should not subscribe to a Lexington Fund unless they can bear the risk of a complete loss of their committed capital. Market Risks Recent volatility in the global financial markets and political systems of certain countries may have adverse spill-over effects into the global financial markets generally. Moreover, a recession, slowdown and/or sustained downturn in the global economies (or any particular segment thereof) or weakening of credit markets will adversely affect the Lexington Funds’ profitability, impede the ability of the Lexington Funds’ portfolio investments (or their underlying portfolio companies) to perform under or refinance their existing obligations, and impair the Lexington Funds’ ability to effectively exit portfolio investments on favorable terms. The extent and duration of such environment, to the private equity industry and global markets as a whole, is currently unknown. Any of the foregoing events could result in substantial or total losses to the Lexington Funds in respect of certain portfolio investments, which losses will likely be exacerbated by the presence of leverage in the capital structure of a particular portfolio company of an Investment Fund. For this reason, valuations are generally subject to heightened uncertainty and numerous subjective judgments, any or all of which could turn out to be incorrect with the benefit of hindsight. Furthermore, traditional valuation approaches that have been used historically may need to be modified in order to effectively capture fair value of private investments in the midst of significant volatility or market dislocation. Undervalued Investments The investment strategy of the Lexington Funds is based, in part, upon the premise that certain potential investments will be available for purchase by a Lexington Fund at “undervalued” prices. However, purchasing interests at what may appear to be “undervalued” or “discounted” levels is no guarantee that these investments will generate attractive risk-adjusted returns to such Lexington Fund, and it is possible that such investments will be subject to further reductions in value. No assurance can be given that any Lexington Fund will be able to acquire investments at favorable prices or that the market for such interests will continue to improve. Highly Competitive Market for Investment Opportunities The activity of identifying, completing, and realizing private equity investments is highly competitive and involves a high degree of uncertainty. In addition, developing and maintaining relationships with sponsors of private funds, joint venture partners or management teams, on which some of the Lexington Funds’ strategies depend, is highly competitive. The Lexington Funds and the Investment Funds will be competing for investments with other private equity investment vehicles, as well as individual third-party investors, including, without limitation, other investment partnerships and corporations, business development companies, sovereign wealth funds, domestic and international public pension plans, individuals, financial institutions and other investors investing directly or through affiliates. Some of these competitors may have more relevant experience, greater financial and other resources and more personnel than Lexington. Furthermore, over the past several years, an increasing number of private equity funds, including secondary, coinvestment funds and sponsor solutions funds and other capital pools targeted at the secondary,

co-investment and sponsor solutions sectors, have been formed (and certain of such existing funds have grown substantially in size), and additional capital will likely be directed at these sectors in the future. Additional funds with similar investment objectives may be formed in the future by other unrelated parties. The supply and consequently the pricing of secondary investments (including continuation vehicle investments) is dependent on a number of factors that may be adversely impacted by general conditions in the global financial markets, including the rate at which such underlying sponsors are able to deploy capital, the performance and value of investments held by funds managed by such underlying sponsors and the ability for such investment funds to realize, recapitalize and/or refinance their own investments in order to return capital to their investors. Higher valuations and increased liquidity and return of capital in the private equity investment market may result in fewer attractive investment opportunities. No assurance can be given that the Lexington Funds will be able to identify investment opportunities that satisfy their investment objectives and desired diversification goals, or if the Lexington Funds are successful in identifying such investment opportunities, that they will be permitted to invest, or invest in the amounts desired, in such opportunities. Additionally, there is a significant amount of capital available in the industry for secondary investments. Accordingly, it is possible that a Lexington Fund’s capital commitments will not be fully utilized if sufficient attractive investments are not identified and consummated by such Lexington Fund during its investment period. Certain Risks Particular to Secondary Investments The market for secondary investments has been evolving and is likely to continue to evolve. It is possible that competition for appropriate investment opportunities will increase, thus reducing the number of investment opportunities available to the Lexington Funds and adversely affecting the terms upon which investments can be made by such Lexington Funds. Accordingly, there can be no assurance that the Lexington Funds will be able to identify sufficient investment opportunities or that they will be able to acquire sufficient secondary investments on attractive terms. In addition, in the cases where a Lexington Fund acquires an interest in an Investment Fund or directly held security in a secondary transaction, including a “tender offer” transaction, such Lexington Fund typically will acquire certain contingent liabilities of the seller of such interest. More specifically, where the seller has received distributions from the relevant Investment Fund, and subsequently, such Investment Fund recalls one or more of these distributions, such Lexington Fund (as the purchaser of the interest to which such distributions are attributable), and not the seller, likely will be obligated to return monies equivalent to such distributions to the Investment Fund. While such Lexington Fund may, in turn, be able to make a claim against the seller for any such monies so paid to the Investment Fund, there can be no assurances that such Lexington Fund would have the ability to make such a claim or, if such a claim were made, that such Lexington Fund would prevail. Finally, in some instances, the Lexington Funds have the opportunity to acquire a portfolio of Investment Fund interests or directly held securities from a seller on an “all or nothing” basis. Certain of the Investment Funds or directly held securities in such a portfolio are often less attractive than others, and certain of the sponsors of such Investment Funds or directly held securities are often more familiar to Lexington than others, or are more experienced or highly regarded than others. In addition, the Lexington Funds sometimes have the opportunity to participate in “linked secondaries” (e.g., a secondary market purchase of an existing interest and corresponding portfolio investment in a separate vehicle sponsored by the same investment manager). In certain instances, the corresponding portfolio investment may be less attractive than the secondary market purchase of an existing interest. In such cases, it may not be possible for the

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Types of Clients and Investment Vehicles Lexington generally provides advice to pooled investment vehicles. Lexington also provides advice to managed accounts (i.e., investment vehicles in which only Lexington and one or more affiliates of a single third party invest). Investors in the Lexington Funds include, without limitation, corporations, endowments, foundations, trusts, estates, sovereign wealth funds, banks and other financial institutions, insurance companies, family offices, high net worth individuals and public and private retirement and pension plans and profit sharing plans. As noted above, Lexington also provides non-discretionary sub-advisory services to StepStone, an investment adviser registered with the SEC. In connection with the formation and management of certain Lexington Funds, Lexington or its related entities establish certain vehicles (“Feeder Funds”) to address tax, legal, regulatory, and/or other similar issues or requirements of certain investors in the Lexington Funds. Each Feeder Fund is a limited partner (or equivalent) of a Lexington Fund and interests in such Feeder Fund are held by the investors who participate in the Lexington Fund through such Feeder Fund. In addition, Lexington forms other parallel funds, alternative investment vehicles and/or similar investment vehicles to address tax, legal, regulatory, and/or other business considerations. Investors are requested to refer to the Governing Documents of the applicable Lexington Fund for complete details on any Feeder Funds or other investment vehicles established in connection with such Lexington Fund and such Lexington Fund’s ability to make investments through any such vehicles. Minimum Investment Requirements Lexington and its related entities generally require that each investor in the Lexington Funds be an “accredited investor” as defined in Regulation D promulgated under the Securities Act. In addition, Lexington and its related entities generally require that each investor in the Lexington Funds be a “qualified purchaser” as defined in the Investment Company Act. In general, the minimum investment commitment required of an investor to participate in a Lexington Fund is $5,000,000; however, the general partner of each Lexington Fund has discretion to increase or reduce the minimum investment commitment and such minimum investment requirement does not apply to all Lexington Funds. Investors are requested to refer to the Governing Documents of the applicable Lexington Fund for complete information on minimum investment requirements for participation in such Lexington Fund.

Performance-Based Fees A related entity of Lexington, as general partner of a Lexington Fund, will typically receive certain allocations calculated and charged based on a share of capital gains on or capital appreciation of the assets of such Lexington Fund. Such “carried interest” allocation arrangements are intended to comply with Rule 205-3 under the Investment Advisers Act of 1940, as amended, and the rules and regulations promulgated thereunder (the “Advisers Act”). Any share of profits paid to the general partners of the Lexington Funds are separate and distinct from the Advisory Fees charged by Lexington for advisory services. Arrangements regarding performance-based fees received by Lexington, or related persons of Lexington, can create an incentive for Lexington to cause a Lexington Fund to make investments that are riskier or more speculative than those that Lexington would have caused such fund to make, or to time purchases or sales differently than Lexington would have caused such fund to do, under a different fee or compensation arrangement. However, Lexington generally considers performance-based compensation to better align its interests with those of investors, and Lexington’s commitments to the Lexington Funds and the existence of a general partner clawback, each where applicable, should somewhat reduce these incentives. Side-by-Side Management Each Lexington Fund is subject to its own performance-based compensation arrangements, and, in certain cases, Lexington or an affiliate may not be permitted to take a performance-based allocation or may only be permitted to take a performance-based allocation from a Lexington Fund after the investors in such Lexington Fund have received a preferred return on their contributed capital or realized capital (subject to clawback). The potential for Lexington and its affiliates to receive different fees or allocations from performance-based accounts creates a potential conflict of interest with respect to the allocation of investment opportunities and Lexington’s time and resources because Lexington has an incentive to direct the best investment ideas and/or resources to, or to allocate investments and/or resources in favor of, the account that pays a more favorable performance fee or allocation. In addition, where a Lexington Fund has a clawback, the clawback should reduce the incentives to make more speculative investments but potentially creates other misalignments of interests between Lexington and investors, such as an incentive for Lexington to defer disposition of an investment that would result in a realized loss, or delay the dissolution and liquidation of a Lexington Fund if doing so would trigger a clawback obligation. Please refer to the Governing Documents of each Lexington Fund for complete information on the specific performance-based compensation arrangements of such Lexington Fund.

Registered Broker-Dealers Neither Lexington nor any of its management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. Registered Futures Commission Merchants, Commodity Pool Operators and Commodity Trading Advisors Neither Lexington nor any of its management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of any of the foregoing. Relationships with Related Persons Lexington is the sole owner of Lexington Advisors LLC (“Lexington Advisors”), an investment adviser registered with the SEC. Lexington provides sub-advisory, back-office, administrative and/or other services to Lexington Advisors and may receive advisory fee revenue from Lexington Advisors in connection with the investment advisory services provided by Lexington Advisors to its managed private investment funds. Moreover, Lexington is affiliated with Administradora Lexington Partners, S.C., Lexington Partners UK LLP, Lexington Partners Asia Limited, Lexington Partners Chile SPA, Lexington Partners Luxembourg S.a.r.l., and Lexington Partners ME Limited (collectively, the “Lexington Foreign Affiliates”), each of which provides certain consulting, advisory and/or sub-advisory services to Lexington and its affiliates. Lexington, Lexington Advisors, and the Lexington Foreign Affiliates share compliance personnel, and the personnel of the Lexington Foreign Affiliates are subject to the same compliance policies and procedures and Code of Ethics requirements as the personnel of Lexington and Lexington Advisors (in addition to any other compliance requirements of applicable regulatory authorities in the Lexington Foreign Affiliates’ respective jurisdictions). Furthermore, various related entities of Lexington serve as general partners of the Lexington Funds. Lexington and its Lexington affiliates manage a number of Lexington Funds (including, for purposes of this paragraph, the Registered Funds) that have investment objectives similar to each other. Lexington also expects that it, Lexington Advisors, or their personnel, will in the future establish one or more additional investment funds and/or managed accounts with investment objectives substantially similar to, or different from, those of the current Lexington Funds. Allocation of available investment opportunities between and among the Lexington Funds and any “successor” investment funds and/or managed accounts of the type described in the preceding sentence can, and in many cases does, give rise to conflicts of interest. Lexington expects in certain circumstances for it, or its affiliates, to give advice or take actions with respect to the investments of one or more Lexington Funds that Lexington and its affiliates do not, or might not, give or take with respect to other Lexington Funds with similar investment programs, objectives, or strategies. For this and other reasons, Lexington Funds with similar strategies generally do not hold the same securities or achieve the same performance. In addition, it is expected that personnel of Lexington responsible for managing a particular Lexington Fund will have responsibilities with respect to

other Lexington Funds, including “successor” funds and other managed accounts. Potential conflicts of interest arise in allocating time, services or functions of these officers and personnel. Lexington will, in certain circumstances, consider and reject an investment opportunity on behalf of one Lexington Fund and subsequently determine to have another Lexington Fund make an investment in the same opportunity. A potential conflict of interest arises in such circumstances because one or more Lexington Funds generally will benefit from the initial evaluation, investigation, and due diligence undertaken by Lexington on behalf of the original Lexington Fund considering the investment. In such circumstances, the benefitting Lexington Fund(s) will not be required to reimburse the original Lexington Fund for expenses incurred, directly or indirectly, in connection with reviewing such investment. In addition, in connection with Lexington’s services to the Lexington Funds, Lexington and Lexington Personnel expect to receive certain tangible and intangible benefits. For example, in the course of Lexington’s operations, including research, due diligence, investment monitoring and investment activities, Lexington and Lexington Personnel expect to receive and benefit from various kinds of information, “know-how,” experience, analysis and data relating to financial, industry, market, business operations, trends, budgets, customers, suppliers, competitors, and other metrics (collectively, “Lexington Information”). In many cases, Lexington Information will include tools, procedures, and resources developed by Lexington to organize or systematize data for ongoing or future use. In addition, Lexington Information is expected, in certain instances, to include information received or generated in connection with efforts on behalf of one Lexington Fund’s investment (or prospective investment) in a portfolio investment. As a result of receiving Lexington Information, Lexington believes it is generally better able to anticipate macroeconomic and other trends, and otherwise develop investment strategies. Lexington has in the past, and is likely in the future, to enter into information sharing and confidentiality arrangements with respect to the Lexington Funds’ portfolio investments and other sources of information that may limit the internal distribution and use of such information. Lexington has already used, and is likely in the future, in certain instances to use Lexington Information in a manner that may provide a material benefit to Lexington, its affiliates, or to certain other Lexington Funds without compensating or otherwise benefitting the Lexington Fund or Lexington Funds from whose investments such information was derived. In addition, Lexington may have an incentive to pursue investments based on the Lexington Information expected to be received or generated. Lexington has in the past, and is likely in the future, to utilize Lexington Information to benefit Lexington, its affiliates or certain Lexington Funds in a manner that otherwise has the potential to create a conflict of interest, it but does not intend to specifically disclose such conflicts to the relevant Lexington Funds. Additionally, as discussed in the section titled “Participation or Interest in Client Transactions; Personal Trading,” Lexington and its related entities are, directly or indirectly, the general partners, limited partners and/or managing members of the general partner of each of the Lexington Funds, including the private investment funds managed by Lexington Advisors. Certain principals and related persons of Lexington spend substantially all of their business time on one or more of the Lexington Funds as required pursuant to the terms of each Lexington Fund’s Governing Documents. On the other hand, the time, dedication and scope of work of a professional varies considerably. For example, it is expected that certain personnel will devote substantial time and

efforts to multiple Lexington Funds, to leadership roles across multiple investment strategies, and/or to projects related to Franklin Templeton. This has the potential to create conflicts in the allocation of time, resources and investment opportunities to and among the Lexington Funds. Investors are requested to refer to the Governing Documents of each Lexington Fund for complete information on the requisite time commitments of Lexington, Lexington Personnel, and Lexington’s related persons to such Lexington Fund. As discussed above, Lexington is owned by Franklin Resources, Inc., which has various subsidiaries that provide financial services, including investment advisory and portfolio management services. See “Franklin Templeton” above. Selection or Recommendation of Other Advisers As a secondary private equity manager, Lexington selects Investment Funds for its clients. Principals or related persons of the Investment Funds are often permitted to invest in the Lexington Funds. Lexington does not, however, receive compensation from the advisers of such Investment Funds in a manner that would create a material conflict of interest and does not have other business relationships with other advisers that create a material conflict of interest. Certain of Lexington’s principals and/or related persons are invited to serve on the advisory boards of the Investment Funds in which the Lexington Funds invest to provide advice on certain conflicts of interest and other matters pertaining to such Investment Funds. There may be instances where such persons are asked to vote on issues taking the needs of all investors in such Investment Funds into account. In limited circumstances, an investment by a Lexington Fund (or diligence with respect to a potential investment by such Lexington Fund) will cause Lexington and its related persons to become subject to legal or contractual restrictions on their ability to effect transactions for other Lexington Funds, for example due to the receipt of material non-public information. Lexington has engaged consultants (including specialized consultants, external executives and industry roundtable members) and senior advisors located in key areas of interest. Lexington’s advisors work in an advisory capacity with Lexington’s professionals to leverage their strong local connections regarding market intelligence and investment-related resources. The nature of the relationship with each such advisor and the time devotion requirements of each such advisor may vary significantly. The Lexington Funds shall, in Lexington’s discretion, bear their allocable share of the fees, costs, and expenses of such advisors. Such advisors are not personnel of Lexington or the Lexington Funds, and therefore, their compensation is in addition to advisory fees paid by the Lexington Funds. To the extent any such fees are paid by a Lexington Fund, they generally will not be offset against or otherwise reduce the Advisory Fee. Subject to applicable law, advisors engaged by Lexington may invest, participate, or engage in (for their own accounts or for the accounts of others), or may possess an interest in, other financial ventures and investment and professional activities of every kind, nature and description, independently or with others, including but not limited to: management of other investment partnerships; investment in, financing, acquisition or disposition of securities; investment and management counseling; providing brokerage and investment banking services; or serving as officers, directors, managers, consultants, advisors or agents of other companies, partners of any partnership, members of any

limited liability company or trustees of any trust (and may receive fees, commissions, remuneration or reimbursement of expenses in connection with these activities), whether or not such activities conflict with any interest of Lexington, the Lexington Funds, or their respective investors.

Trading Code of Ethics Lexington has adopted a Code of Ethics under Rule 204A-1 of the Advisers Act and Rule 17j- 1 under the Investment Company Act that is applicable to all of its members, partners, officers, directors (or other person occupying a similar status or performing similar functions), employees, and other persons who provide investment advice on behalf of Lexington and are subject to its supervision and control (collectively, “Lexington Personnel”) expressing Lexington’s commitment to ethical conduct. Lexington’s Code of Ethics describes its fiduciary duties and responsibilities to its clients, and sets forth, among other things, Lexington’s policies on (i) receipt of gifts by personnel, (ii) political contributions, and (iii) reporting and monitoring of the personal securities transactions of Lexington Personnel with access to client investment recommendations. The Code of Ethics helps Lexington detect and prevent potential conflicts of interest. Under Lexington’s Code of Ethics, all Lexington Personnel have a duty to act only in the best interests of the Lexington Funds and all potential conflicts and violations of the Code of Ethics must be promptly reported to Lexington’s Chief Compliance Officer (“CCO”). All Lexington Personnel must acknowledge and adhere to the terms of the Code of Ethics. It is the expressed policy of Lexington that no person employed by Lexington shall prefer his or her own interest to that of an advisory client. To supervise compliance with its Code of Ethics, Lexington requires that certain restricted persons provide annual securities holdings reports and quarterly transaction reports (or equivalent reports or acknowledgments) to the firm’s Legal and Compliance group (“Compliance”), which includes the CCO. Lexington requires such “access persons” to also receive approval from Compliance prior to investing in any initial public offerings or private placements. In an effort to prevent inappropriate securities transactions by Lexington’s personnel, Compliance maintains and makes available a list of restricted securities. Access persons are strictly prohibited from trading on their own behalf in restricted securities without obtaining the prior written approval of Compliance. Lexington requires that all individuals act in accordance with all applicable federal and state regulations governing investment advisory practices. Lexington’s Code of Ethics also includes the firm’s policy prohibiting the misuse of material non-public information. Any individual not in observance of the above may be subject to discipline or termination. Lexington Personnel who violate the Code of Ethics may be subject to remedial actions including, but not limited to, profit disgorgement, fines, censure, demotion, suspension or dismissal. Lexington Personnel are also required to promptly report any violation of the Code of Ethics of

which they become aware. Lexington Personnel are required to annually certify compliance with the Code of Ethics. Lexington reserves the right to refine and modify the Code of Ethics and its other policies and procedures over time. Lexington will provide a complete copy of its Code of Ethics to any client or prospective client upon request. Participation or Interest in Client Transactions; Personal Trading As general partners, limited partners and/or managing members of the general partners of each of the Lexington Funds, Lexington and its related persons have indirect beneficial interests in the securities owned by the Lexington Funds and will share in any profits and losses generated by the Lexington Funds’ investments. Before Lexington makes a recommendation that a Lexington Fund buy or sell a security, all related persons that have direct ownership of such security at the time of such recommendation and would otherwise be expected to participate in the discussions or authorizations concerning such recommendation, are required to disclose such ownership interest to Lexington and may not be permitted to participate in the discussions or authorizations to recommend that a Lexington Fund buy or sell such security. A related person shall not be so restricted if such person’s only interest in a security is (i) held indirectly through one of the Lexington general partner entities, the Lexington Funds or otherwise, or (ii) related to such person’s service as a director or advisor of a portfolio investment entity to facilitate Lexington’s ability to monitor the investment. Lexington and/or certain related persons of Lexington in certain circumstances are permitted, directly or through one or more entities, to sell securities in which they have a direct or indirect ownership interest to certain Lexington Funds in connection with certain “warehousing” or other principal transactions, provided that the sale is consistent with Lexington’s fiduciary obligations to such Lexington Funds. Such transactions will be fully disclosed and the written consent of the applicable Lexington Fund (which, in certain circumstances, may be provided by the applicable Lexington Fund’s advisory board) will be obtained prior to the consummation of any such transactions in accordance with Section 206(3) of the Advisers Act (to the extent such transactions constitute “principal transactions”) and all other applicable state and federal securities laws. In certain situations, related persons of Lexington will be permitted to purchase interests in the same portfolio investments held by one or more Lexington Funds. All such transactions are subject to compliance with Lexington’s Code of Ethics as described above. Lexington reserves the right to cause a Lexington Fund to engage in a “cross transaction” via the purchase or acquisition of a limited partner (or equivalent) interest from or sale or transfer of a limited partner (or equivalent) interest to another Lexington Fund, provided that the transfer is consistent with Lexington’s fiduciary obligations to each Lexington Fund participating in the cross transaction. These transactions can arise when, for example, parallel Lexington Funds and/or committed co-investment vehicles or managed accounts rebalance their portfolios at their final closing, or when a Lexington Fund has warehoused an investment prior to the initial closing of a separate Lexington Fund.

Lexington Funds also are permitted to acquire interests in other Lexington Funds from a Lexington Fund investor to the extent consistent with Lexington’s fiduciary obligations and the applicable Governing Documents. These transactions can arise when, for example, a limited partner interest in a Lexington Fund is included in a larger secondary transaction pursued by a separate Lexington Fund. Lexington reserves the right to also guarantee certain credit facilities entered into by a Lexington Fund or SPV to enable such Lexington Fund or SPV to acquire a portfolio of investments prior to holding an initial closing. In connection with such warehousing arrangements, Lexington will generally be reimbursed for its out-of-pocket costs and receive a backstop guaranty payment from the applicable Lexington Fund or SPV equal to a percentage of the principal amount of the credit facility. Investors are requested to refer to the Governing Documents of the applicable Lexington Fund for additional information on any such loan and warehousing arrangements applicable to such Lexington Fund. While Lexington endeavors at all times to act in the best interests of the Lexington Funds, investors should be aware that Lexington’s receipt of compensation from the Lexington Funds creates inherent potential conflicts of interest. Conflicts of Interest Lexington and its related entities engage in a broad range of investment-related activities. In the ordinary course of conducting its activities, the interests of a Lexington Fund are expected, in certain instances, to conflict with the interests of Lexington, other Lexington Funds and/or their respective affiliates. For example, the buyers and sellers, directly or indirectly, of any Lexington Fund’s investments will often be investors in Lexington Funds, and a Lexington Fund’s investments in some cases include limited partnership interests in other Lexington Funds. For the avoidance of doubt, Advisory Fees paid by the Lexington Funds with respect to other Lexington Funds are not subject to any offsets. Additionally, underlying funds in which Lexington Funds are investors sometimes sell their assets to other Lexington Funds. While Lexington will seek to negotiate transactions in good faith and on an arm’s length basis, the foregoing presents inherent conflicts of interest and there can be no assurance that there will not be an adverse impact on the Lexington Funds. For example, there can be no assurance that any Investment Fund interest or other asset acquired by a Lexington Fund from such a seller will not be valued or allocated a sale price that is higher than might otherwise have been the case if such asset were acquired from a third party (or lower than might otherwise have been the case if the Lexington Fund is selling to such a buyer). Lexington will not be required to solicit third-party bids or obtain a third-party valuation prior to causing a Lexington Fund to participate in such a transaction. These activities could give rise to potential conflicts of interest and there can be no assurance that such activities will not have a material adverse effect on the Lexington Funds. Resolution of Conflicts In the case of all conflicts of interest, Lexington’s determination as to which factors are relevant, and the resolution of such conflicts, will be made using Lexington’s best judgment, but in its sole discretion. In resolving conflicts, Lexington will consider various factors, including, without

limitation, the interests of the applicable Lexington Funds with respect to the immediate issue and/or with respect to their longer-term courses of dealing. Certain procedures for resolving specific conflicts of interest are set forth below. When conflicts arise, the following factors generally mitigate, but will not eliminate, conflicts of interest: •

Many important conflicts of interest will generally be resolved by set procedures, restrictions or other provisions contained in the Governing Documents for the Lexington Funds;

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Lexington has adopted and implemented certain policies and procedures designed to reduce certain conflicts of interest;

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Many of the Lexington Funds have established an advisory board, consisting of representatives of investors not affiliated with Lexington. Lexington is required to obtain advisory board approval with respect to certain conflicts of interest pursuant to the relevant Lexington Funds’ Governing Documents;

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Where Lexington deems appropriate, it can use unaffiliated third parties to help resolve conflicts or to provide input as to the fairness or “arm’s-length” nature of a purchase or sale price (whether or not part of a formal fairness opinion, “request for proposal” process, or proposal or quotation provided exclusively for the benefit of Lexington); and

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Prior to subscribing for interests in a Lexington Fund, each investor receives information relating to significant potential conflicts of interest arising from the proposed activities of the Lexington Fund.

In certain instances, some conflicts of interest may be resolved in a manner adverse to a Lexington Fund and its ability to achieve its investment objectives. Diverse Membership The investors in the Lexington Funds generally include U.S. taxable and tax-exempt entities, and institutions from jurisdictions outside of the United States. Such investors often have conflicting investment, tax, and other interests with respect to their investments in a Lexington Fund. The conflicting interests among the investors generally relate to, or arise from, among other things, the nature of investments made by a Lexington Fund, the structuring of the acquisition of investments, and the timing of the disposition of investments. As a consequence, conflicts of interest arise in connection with decisions made by Lexington or its affiliates, including with respect to the nature or structuring of investments, that are more beneficial for one investor than for another investor, especially with respect to investors’ individual tax situations. In selecting and structuring investments appropriate for a Lexington Fund, Lexington and its affiliates will consider the investment and tax objectives of the applicable Lexington Fund as a whole, not the investment, tax, or other objectives of any investor in such Lexington Fund individually. Possibility of Different Information Rights; Outside Statements

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Although Lexington typically does not utilize broker-dealers to effect portfolio investments, the Lexington Funds do receive shares of certain companies as part of general distributions in kind. Subject to the investment objectives, policies and restrictions of each Lexington Fund, as set forth in such Lexington Fund’s Governing Documents, Lexington will generally have discretionary authority to select the broker or dealer to be used to execute transactions in securities on behalf of the Lexington Funds and negotiate the commission cost to be paid. In selecting brokers, Lexington’s primary consideration will be to obtain the most favorable net result for the applicable Lexington Fund under the circumstances, which will not always involve the lowest possible commission cost. In selecting broker-dealers to effect securities transactions, Lexington seeks to obtain best execution by considering factors including, but not limited to: the nature of the transaction, the size of the transaction, execution capability, execution costs, the level of service offered, responsiveness, financial responsibility and reliability, resources, experience in liquidating distributions from private equity funds, research services (such as reports and analyses of markets, industries, companies and economic trends), and such other factors as Lexington considers relevant and beneficial to the Lexington Funds. The applicability of specific criteria will vary depending upon the nature of the transaction, the market in which it is executed, and the extent to which it is possible to select from among multiple brokers or dealers. Research and Soft Dollar Benefits Lexington does not engage in any formal soft dollar arrangements with respect to securities transactions for the Lexington Funds.

Any research services and/or other products or services that are provided to Lexington by brokers or dealers may be used for the benefit of all clients of Lexington and do not necessarily benefit solely the Lexington Fund from which the commissions were generated. Lexington has no commitment or arrangement to provide any specific level of commissions or transactions with respect to any proprietary research received. The receipt of research and/or other products or services is not directly connected to the recommendation of brokerage services to the Lexington Funds, but does create a potential conflict of interest of which investors should be aware in assessing Lexington’s choice of broker-dealers. Service Providers and Client Referrals Subject to Lexington’s obligation to seek best execution of all transactions for its clients, Lexington is permitted to consider referrals of investors in determining its selection of third-party service providers. Accordingly, in some cases Lexington has an incentive to select or recommend a service provider based on its interest in receiving investor referrals. Any such determinations will be made in accordance with Lexington’s fiduciary obligations to the Lexington Funds and Lexington’s compliance policies and procedures. Directed Brokerage Lexington has discretionary authority to select the brokers or dealers in connection with securities transactions of the Lexington Funds, and investors are not permitted to direct Lexington to use a particular broker or dealer to execute portfolio transactions on behalf of a Lexington Fund. Trade Aggregation Lexington generally will, to the extent possible, place a combined order for two or more Lexington Funds it manages that are engaged in the purchase or sale of the same security if, in its good faith determination, joint execution would be consistent with its duty to seek best execution, consistent with the terms of the participating Lexington Funds’ Governing Documents, and otherwise in the best interest of the participating Lexington Funds.

Economic Benefits Received from Third Parties In certain circumstances, in connection with investments made by certain Lexington Funds, Lexington or its affiliates or supervised persons expect to receive transaction fees, directors fees, investment banking fees, advisory fees, closing fees, topping fees, break-up fees, and/or other similar fees. To mitigate potential conflicts of interest, Lexington will offset all or a portion of such benefits against advisory fees payable by the applicable Lexington Fund to the extent required under such Lexington Fund’s Governing Documents. Investors are requested to refer to the Governing Documents of the applicable Lexington Fund for complete information on the additional compensation received by Lexington or its affiliates or supervised persons in connection with such Lexington Fund’s investments. Third Party Compensation for Client Referrals and Investor Referrals Lexington and related entities of Lexington enter into compensation arrangements with placement agents or other parties for introducing investors to (and/or otherwise assisting in the fundraising of) a Lexington Fund. These arrangements generally are disclosed in the relevant Lexington Fund’s Form D. Any compensation associated therewith will ultimately be payable by Lexington and/or its related entities, either directly or through an offset of the Advisory Fee payable by the relevant Lexington Fund to Lexington. Moreover, as described above, Lexington is permitted to consider referrals of investors to the Lexington Funds in determining its selection of third-party service providers. Lexington endeavors at all times to put the interests of the Lexington Funds first as part of Lexington’s fiduciary duty to the Lexington Funds. Nevertheless, the receipt of compensation by the placement agents creates a potential conflict of interest and may affect the judgment of placement agents when making referrals to Lexington and the Lexington Funds.

Lexington and its principals have not been the subject of any material legal proceeding required to be disclosed in response to this item.

Review of Client Accounts The investments of the Lexington Funds are generally private, illiquid and long-term in nature, and accordingly Lexington’s review of them is not directed toward a short-term decision to dispose of securities. However, Lexington will regularly monitor portfolio investments on behalf of the Lexington Funds. Investments are reviewed in the context of each Lexington Fund’s stated investment objectives and guidelines as set forth in the Governing Documents of each Lexington Fund. Members of Lexington’s investment committee meet regularly to determine and review overall investment objectives, risk tolerance, and other information relevant to the Lexington Funds.

Reports to Investors The general partners of each Lexington Fund distribute quarterly and annual written reports to their respective investors. Annual reports generally contain an individual capital account statement as of the end of such fiscal year, a listing of investments held by the Lexington Fund, and the audited financial statements of the Lexington Fund. The quarterly reports generally contain unaudited financial statements of the Lexington Fund for the fiscal quarter. Investors are requested to refer to the Governing Documents of the applicable Lexington Fund for further information on the reports provided by such Lexington Fund to its investors.

Lexington will not have physical custody of any client assets (other than certain privately offered securities to the extent permitted by the Advisers Act). Nevertheless, Lexington will generally be deemed to have custody of the assets of the Lexington Funds as a result of its position as an affiliate of the general partner of each Lexington Fund.

It is Lexington’s policy to cause each Lexington Fund with assets over which Lexington is deemed to have “custody” to be audited annually and distribute audited financial statements, prepared in accordance with U.S. generally accepted accounting principles (“GAAP”), to investors no later than 180 days after the end of each fiscal year (or as otherwise may be required under the Advisers Act). In addition, upon the final liquidation of any such Lexington Fund, Lexington will obtain a final audit and distribute audited financial statements prepared in accordance with GAAP with respect to such Lexington Fund to all investors promptly after completion of the audit. Investors will generally not receive account statements directly from the bank or other qualified custodian holding physical custody of the Lexington Funds’ securities.

Subject to the investment objectives, policies, and restrictions of each Lexington Fund as set forth in the Governing Documents of such Lexington Fund, Lexington has discretionary authority to determine the type, amount, and price of securities and investments to be bought and sold on behalf of each Lexington Fund, including the selection of, and commissions paid to, broker-dealers.

Because Lexington has, or will accept, authority to vote securities held by a Lexington Fund, it has adopted policies and procedures (the “Proxy Voting Policies and Procedures”) that have been designed to ensure that Lexington complies with the requirements of the Advisers Act, and reflect Lexington’s commitment to vote all client securities for which it exercises voting authority in a manner consistent with the best interest of the Lexington Funds. When exercising its voting authority over client securities, Lexington considers all relevant information, evaluates other issues that could have an impact on the value of the security, and votes with a view toward maximizing overall value. Lexington votes all proxies in a prudent manner, considering the prevailing circumstances at such time, and in a manner consistent with the Proxy Voting Policies and Procedures and Lexington’s fiduciary duties to the Lexington Funds. Lexington reviews each proposal submitted for a vote on a case-by-case basis to determine whether it is in the best interest of the applicable Lexington Fund. As a result, depending on the Lexington Fund’s particular circumstances, Lexington may vote one Lexington Fund’s securities differently than it votes those of another Lexington Fund, or may vote differently on various proposals, even though the securities or proposals are similar (or identical). In some instances, Lexington may determine that it is in a Lexington Fund’s best interest for Lexington to “abstain” from voting or not to vote at all, and will do so accordingly. Notwithstanding the foregoing, because proxy proposals and individual company facts and circumstances may vary, Lexington may not always vote proxies in accordance with the Proxy Voting Policies and Procedures. In addition, many possible proxy matters are not covered in the Proxy Voting Policies and Procedures. Generally, Lexington will vote proxies (i) in favor of management’s recommendation for the election of the board of directors and (ii) to approve the financial statements as presented by management. Prior to exercising its voting authority, Lexington, in consultation with Compliance and/or outside counsel, as appropriate, reviews the relevant facts and determines whether a material conflict of

interest may exist or arise due to business, personal or family relationships of Lexington, its owners, its personnel or its related persons, with persons having an interest in the outcome of the vote. If it is determined that a material conflict exists, Lexington takes steps to ensure that its voting decision is based on the best interests of the applicable Lexington Fund and is not a product of the conflict. Lexington may, at its discretion, (i) seek the advice of the applicable Lexington Fund’s advisory board in voting such security; (ii) disclose the conflict of interest to the investors in the Lexington Fund (or its advisory board) and either ask for such Lexington Fund’s (or advisory board’s) consent to Lexington’s proposed vote or defer to such Lexington Fund’s (or advisory board’s) voting recommendation; (iii) defer to the voting recommendation of an independent thirdparty provider of proxy voting services; and/or (iv) take such other action in good faith (in consultation with Lexington’s outside counsel, if appropriate) as would serve the best interest of the Lexington Fund. Depending on the particular circumstances involved, the appropriate resolution of one conflict of interest may differ from the resolution of another conflict of interest, even though the general facts underlying both conflicts may be similar (or identical). Lexington will deliver to each investor in a Lexington Fund, upon written request, a complete copy of its Proxy Voting Policies and Procedures and/or information on how it voted proxies for the applicable Lexington Fund.

Lexington has no financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients, and has not been the subject of a bankruptcy proceeding.