Lighthouse Investment Partners, LLC

Firm Overview

Lighthouse is an alternative asset management firm that provides investment advisory services primarily to privately offered investment funds, and, in certain cases to separately managed accounts (“SMAs”). Our investor base mainly consists of institutional investors and high net worth individuals located globally. Lighthouse, a Delaware limited liability company, began managing capital in 1999 (through a predecessor) and operates through Lighthouse and certain Relying Advisers listed in Item 10 of this Brochure and on Schedule R of Form ADV Part 1A.

Ownership Lighthouse is an indirect wholly owned subsidiary of Navigator Global Investments Limited (ASX:NGI), a publicly traded Australian Securities Exchange listed company. NGI owns Lighthouse through intermediate holding companies. Blue Owl Capital, Inc. (NYSE:OWL), a publicly traded New York Stock Exchange listed company, indirectly controls approximately 37% of NGI’s voting securities. A detailed description of Lighthouse’s ownership is provided in Schedule A and Schedule B of Form ADV Part 1A.

What We Do

We organize and manage investment strategies through privately offered funds, including single-manager and multi‑portfolio manager strategies. In most cases, we allocate capital among internal portfolio managers (our employees) and third‑party portfolio managers under contracts that set investment guidelines and risk limits. We oversee risk, set mandates, and may add or remove portfolio managers.

Business Lines

Platform Hedge Funds – Proprietary, single manager or multi‑manager strategies we operate through Lighthouse and our Relying Advisers.

Hedge Fund Solutions – Multi‑manager solutions that allocate to our Platform Hedge Funds and to external managers.

Platform Services – Global investment support offerings for institutional investors and certain Funds. These services include risk management and analysis, data processing, and assistance with direct hedge fund and long-only investments, along with related reporting and operational support. Lighthouse may also provide Platform Services for investments not held through its managed Funds in the future.

Types of Clients and Vehicles Our clients are primarily private funds organized in the United States and outside the United States (“Funds”). Some Funds are structured for multiple investors; others are customized for a single investor or a related group of investors (a “Custom Fund”). Funds may invest through master-feeder structures or through "Fund Accounts.” A Fund Account is the portfolio within a Fund that is managed by one or more Portfolio Managers. Where more than one Portfolio Manager manages a Fund Account, it is divided into ”Sub-Accounts,” with each Portfolio Manager generally exercising discretion over its own Sub-Account. Investors do not invest in a Fund Account directly; they invest in the Fund that holds it. Some Funds that hold Fund Accounts accept only other Lighthouse Funds as investors and operate as internal allocation vehicles. Others also accept investment from outside investors. In either case, Lighthouse's client is the Fund, not the Fund Account or the Portfolio Managers who manage it. Lighthouse's marketing and investor materials commonly refer to Fund Accounts as “managed accounts” and to the Funds that hold them as the “managed account platform.” Depending on strategy, regulatory requirements, or mandate, certain Funds may invest a substantial portion of assets in unaffiliated funds managed by third‑party portfolio managers (“Unaffiliated Funds”). We also manage customized portfolios for certain investors

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through SMAs held with independent custodians. For ease of reference, unless otherwise indicated or the context otherwise requires, references to “Funds” in this Brochure include SMAs.

Fund Level Terms and Classes Within Funds

Our Funds vary by investment objectives and guidelines, liquidity (including redemption rights), minimum investment amounts, and other fund‑level terms. Many Funds issue multiple series or share classes that differ by fees, base currency, or hedging/portfolio exposure. Some Funds also offer series or classes that correspond to distinct portfolios; in some cases, a class holds a customized portfolio for a single investor or a related investor group (for example, where investors are advised by the same consultant or wealth manager). See the Cross‑Class and Cross‑Fund Liability Risk factor in Item 8 of this Brochure for additional information.

Our Role and Legal Structures

We typically serve as an investment manager, manager, general partner, or in a similar capacity to our Funds. For Fund Accounts, we typically enter into an investment advisory agreement (also referred to as a “Subadvisory Agreement”) with a portfolio manager for each legal structure or segregated cell within a structure that limits liability among its cells (for example, Cayman Islands segregated portfolio companies, Ireland unit trusts, Delaware series limited liability companies, and Irish Collective Asset‑management Vehicles). For purposes of this Brochure, the term ‘Subadvisory Agreement’ also includes any employment agreement, compliance requirement, or other governing arrangement that establishes the portfolio manager’s discretionary authority and applicable investment restrictions. In some cases, a single fund structure or segregated cell is further divided into separate accounts (or Sub‑Accounts), each managed by a different portfolio manager. See the Fund Legal Structures Untested risk factor in Item 8 of this Brochure for additional information.

Co‑Advisory and Limited‑Scope Advisory Relationships

We may serve as a co‑investment adviser, co‑manager, or provide limited‑scope advisory services (such as platform services) for certain private funds. In these arrangements, we may share responsibility for investment decisions and portfolio management or provide advisory input without full discretionary authority. These relationships can create conflicts of interest in allocating investment opportunities and resources. See Item 10 for additional information regarding co-advisory relationships and related risks.

Fund Objectives and Customization

Most Funds are designed for multiple investors, and we set each Fund’s investment objectives and guidelines. Custom Funds are tailored for a single investor or a related group of investors (for example, where investors are advised by the same consultant or wealth manager). A Fund’s investment objectives—and any applicable investment limitations, restrictions, or guidelines—are described in its governing and offering documents (e.g., private placement memorandum, partnership or limited liability company agreement, subscription documents, investor side letters, or similar constitutional documents). Investment guidelines for Fund Accounts are generally established in the applicable Subadvisory Agreement between Lighthouse and the portfolio manager.

Portfolio Managers In this Brochure, “Portfolio Manager” means a group, typically comprised of one to five individuals but sometimes many more, operating as a single team to manage a Fund’s or Fund Account’s assets or a portion thereof. A Portfolio Manager team may include portfolio managers, traders, analysts, risk and research personnel, technologists, data scientists, information technology staff, operations and accounting staff, and other professionals. Teams may consist of:

employees of Lighthouse or its affiliates,

independent third‑party managers engaged under Subadvisory agreements,

independent third‑party managers whose vehicles our Funds invest in directly; or 5|P a g e

individuals seconded to Lighthouse under contract.

Third-party Portfolio Managers operate their trading groups and are responsible for trading decisions, staffing, and day‑to‑day operations, subject to our risk management, investment guidelines, and oversight. We retain authority to approve mandates, set risk limits, and terminate or reassign trading authority for the Funds and Fund Accounts they manage. We may also provide certain administrative and operational support to third-party Portfolio Managers. Certain third-party Portfolio Managers also manage capital for unaffiliated clients. Portfolio Managers who are Lighthouse employees are subject to Lighthouse’s supervision and control.

Regulatory Status of Funds

All private funds we manage are exempt from registration as investment companies in reliance on Section 3(c)(7) of the U.S. Investment Company Act of 1940, as amended (the “Investment Company Act”).

Assets Under Management (“AUM”) As of June 30, 2026, Lighthouse’s total AUM was approximately $19.8 billion. Approximately $14.1 billion were discretionary assets. Approximately $5.7 billion were non-discretionary assets, based on certain investment restrictions imposed in relation to certain Funds. See Item 16 of this Brochure for further information on how “discretionary” and “non-discretionary” AUM are determined.

Wrap Fee Programs We do not participate in any wrap fee programs.

We do not have a single standardized management fee or performance fee schedule for our services. Depending on the offering document or constitutional document of our Funds, we receive (i) a management fee (“Management Fee”), (ii) a performance fee (“Performance Fee”), or a combination thereof. In certain cases, we may be entitled to receive both a Management Fee and a Performance Fee. The Management Fee may vary among our Funds, share classes, or series of interests within each Fund. Management Fees are typically paid monthly or quarterly in arrears following the calculation of the net asset value of each Fund. Please see each Fund’s offering or other disclosure documents for more information about the specific fees charged with respect to such Funds. The Performance Fee is typically subject to a loss carryforward or “high water mark” and, if applicable, a “hurdle rate” as set forth in the offering documents or constitutional document of our Funds. Certain share classes within the Funds place additional limitations on the calculation or payment of the Performance Fee related to such share classes, series of interests, and/or Funds. If an investor in a Fund that is subject to a Performance Fee redeems all or part of its shares or interests in the fund other than as of the date that a Performance Fee is calculated, a Performance Fee is paid with respect to the redeemed amount at the time of redemption. We may waive, reduce, or rebate the Management Fee or Performance Fee with respect to any investor, either in whole, or in part. In addition, we may enter into side letters with certain investors granting them preferential fee terms. Our determination to offer lower fees may be based on the relevant investor’s investment size or the aggregation of accounts for investors sourced from a certain investment advisor, consultant, or other third party, although we also may consider other factors. Employees who are permitted to invest in our Funds are not subject to a Management Fee or Performance Fee. In certain circumstances, we invest directly in Funds that hold Fund Accounts and will not bear the costs and expenses of other Funds. Where we engage third parties to assist in the placement of interests or shares in our Funds, we pay part, or all, of our Management Fees and/or Performance Fees to such third parties.

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Fees for Platform Services (“Platform Services Fees”) are independently negotiated based on the type of service and size of the relationship. Platform Services Fees typically constitute a percentage of notional asset value of a Fund and will be paid in arrears, either monthly or quarterly. Generally, the administrator of the Funds calculates the Management Fee, Performance Fee, and Platform Services Fee and communicates the net asset value and fee calculation to us. We confirm the calculations, and then the administrator directs the bank of the applicable Fund to make payment to us. Fees are customarily deducted from investors’ assets. In certain limited circumstances, an investor may pay fees to Lighthouse in a manner outside those described above whereby Lighthouse submits a bill to the client and such client pays Lighthouse directly rather than having the fees deducted from their assets. In addition to the Management Fees, Performance Fees, or Platform Services Fees deducted from an investor’s assets, each investor also pays a portion of the ongoing investment and operating expenses of such Fund, most commonly on a pro rata basis. Such expenses include, without limitation, administrator fees; professional fees relating to investments; liability insurance premiums; legal and regulatory expenses; tax-related expenses; audit and accounting expenses; research; and software and technology expenses. All these are described more fully in the applicable offering document or relevant constitutional document of our Funds. Investors in our Funds also bear, directly or indirectly, the management, performance-based, advisory, sponsorship, administrative and other fees and expenses charged by Portfolio Managers and by Unaffiliated Funds and other investment vehicles in which our Funds invest. These fees and expenses are in addition to the fees payable to Lighthouse, are payable irrespective of a Fund's profitability and may be substantial even during losing periods. Because a Portfolio Manager's performance-based compensation is generally calculated on that Portfolio Manager's own results, a Fund may pay performance-based compensation to one or more Portfolio Managers in a period in which the Fund as a whole has not realized a profit. The expenses borne by our Funds vary based on the applicable Fund's governing documents. Certain Funds employ a broad pass-through expense model (“Pass-Through Funds”), under which a range of investment-related, operational, administrative and other expenses may be borne by the Fund as described below. Other Funds permit only certain categories of expenses to be borne by the Fund. For these Funds, expenses that are not permitted under the applicable governing documents are borne by Lighthouse rather than reallocated to other Funds. The particular expenses borne by each Fund are governed by its applicable offering and constitutional documents. Pass-Through Funds incur various expenses in connection with or otherwise related to the operations and activities at various levels of (i) the Pass-Through Fund, (ii) Lighthouse or one of its subsidiaries that manages such Pass-Through Fund (“Pass-Through Fund Manager”), (iii) a co-investment adviser, where applicable, and (iv) Portfolio Managers (collectively, “Pass-Through Expenses”). Each Fund that invests in a Pass-Through Fund will also be responsible for its share of such expenses. In addition, Lighthouse may elect and has elected in the past not to pass through certain expenses that otherwise could be borne by investors. Any such determination is made in Lighthouse’s sole discretion. Pass-Through Expenses include, but are not limited to:

Investment-Related Expenses. Investment expenses (e.g., expenses that the Pass-Through Fund Manager determines to be related to the investment of the Pass-Through Fund’s assets, such as brokerage commissions, expenses relating to short sales, financing charges, dividend expense, exchange fees, clearing and settlement charges, custodial fees, bank service fees, and interest and financing expenses); currency hedging expenses; costs associated with establishing and maintaining exchange memberships; legal expenses and professional fees (including, without limitation, expenses of third-party consultants, compliance consultants, expert networks, risk service providers, and portfolio finance and treasury service providers); proxy voting services, class action recovery and monitoring or tax reclamation service providers; valuation expenses, including the cost of valuation agents; performance-based compensation of Portfolio Managers (if any); asset-based compensation 7|P a g e

of Portfolio Managers (if applicable); and management fees, performance fees, and other costs and expenses payable in respect to any investment by the Pass-Through Fund in another investment vehicle (whether affiliated with Lighthouse or not).

Organizational and Operating Expenses. Administrator fees, administrative expenses, legal expenses, auditing and tax preparation expenses (including in connection with tax returns, tax estimates, Schedule K-1s, Schedule K-3s or similar forms or other communications with investors), expenses for tax or accounting services performed by any third parties; costs of preparing, printing, and mailing reports and notices, including customized reporting requested by investors; bonding costs required by Employee Retirement Income Security Act of 1974, as amended (“ERISA”), if applicable; taxes, including withholding tax, and similar amounts and other related interest, penalties, or other expenses; “Fund representative” fees and expenses; corporate licensing; costs of effecting and maintaining registrations and licenses in U.S. and non-U.S. jurisdictions; costs and expenses related to regulatory reporting of whatever nature and in whatever jurisdiction (including the costs and expenses incurred in the preparation and filing of Form ADV, Form PF, Form CPO-PQR, Schedules 13D, 13G, 13H, Form SHO, Form N-PX, blue sky filings, and other Fund-specific regulatory filings and Fund-specific costs and expenses related to AIFMD and other jurisdiction-specific filings); the fees and expenses of the Pass-Through Fund’s board of directors; advisory committee fees; the fees and expenses of the Fund’s anti-money laundering officers; the fees and expenses of the paying agent (if any); organizational expenses; costs and expenses incurred in connection with establishing and maintaining entities through which the Funds will conduct their investment activities; publicrelations consultants; expenses incurred in connection with the offering and sale of interests in the Funds (including the preparation and revision of disclosure documents and other constitutional documents, marketing materials, due diligence questionnaires, subscription agreements, negotiation and administration of side letters, negotiation and documentation of agreements with placement agents or marketers and travel expenses to meet prospective and existing investors and to attend industry events and conferences such as capital introduction events (including first or business class air or rail travel, private car services, car rentals, lodging, meals and similar expenses)); the cost of the Pass-Through Fund Manager’s and the Pass-Through Fund’s liability insurance premiums (including, without limitation, costs related to Errors & Omissions, Directors & Officers, commercial property insurance, employment practices liability insurance, cyber insurance, and general liability insurance, including those for the Portfolio Managers, the board of the directors of the Pass-Through Fund, and Investment Adviser Personnel); expenses related to the maintenance of the Pass-Through Fund’s registered office or future offices and other similar expenses; fees and expenses related to the Pass-Through Fund’s wind down and liquidation; costs and expenses associated with litigation and arbitration; costs of indemnification or contribution pursuant to a Fund’s constitutional document, any agreement with a Portfolio Manager or a service provider to the Funds or other agreements; and extraordinary expenses. “Investment Adviser Personnel” means the principals, members, officers, employees and consultants of the Pass-Through Fund Manager and the principals, members, officers, employees and consultants of its affiliates who devote any portion of their time to any aspect of the operation (including legal, compliance, accounting, operations, human resources, marketing, investor relations and reporting, tax, risk management, portfolio management or trade execution) of a Pass-Through Fund on behalf of the Pass-Through Fund Manager, as well as certain other personnel of the Pass-Through Fund Manager and its affiliates that the Pass-Through Fund Manager has designated as performing Corporate Service Functions on behalf of the Pass-Through Fund Manager and its affiliates. “Corporate Service Functions” include functions such as legal, compliance, finance, accounting, operations, tax and similar corporate services. The costs and expenses associated with Investment Adviser Personnel (including those performing Corporate Service Functions) will be charged to the Pass-Through Funds as a Fund Expense in accordance with the principles set out below under the heading “Determination of Allocation of Expenses”.

Research and Risk Related Expenses. Research-related expenses, including expenses related to Bloomberg and other similar subscription-based services; independent research reports or publications; periodicals; software, quotation, and related financial and market data services (including services providing alternative data, news data, and certain valuation, pricing and economic data); expenses related to various risk software and systems used by Portfolio Managers and the 8|P a g e

Pass-Through Fund Manager; corporate access charges; investment/research-related travel expenses of Portfolio Managers and the Pass-Through Fund Manager (including first or business class air or rail travel, private car services, car rentals, lodging, meals and similar expenses); consulting services regarding products, technologies, issuers or industries; and “Employee Costs” (as described below) related to risk and research personnel used by the Portfolio Managers and the Pass-Through Fund Manager.

Portfolio Manager and Fund Initial and Ongoing Investment Diligence and Onboarding. Costs and expenses associated with all Portfolio Manager relationships considered (whether or not consummated), evaluated or consummated by the Pass-Through Funds, including all fees and expenses associated with sourcing, negotiating, establishing investigating, researching, financing, structuring, acquiring and performing due diligence of all Portfolio Managers (including costs of third party consultants and service providers engaged to conduct diligence, as well as the costs of background checks, and costs in connection with traveling to and attending industry conferences and other activities in connection with sourcing potential new Portfolio Managers and ongoing monitoring of existing Portfolio Managers, including first or business class air or rail travel, private car services, car rentals, lodging, meals and similar expenses), whether or not such relationships are ultimately consummated (including third-party research, data, analytics, modeling, structuring, pricing, execution and other third-party information systems and software and service fees (including data feeds, subscriptions, reports and similar items)), in each case related to the Fund’s investment activities.

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Credit

This strategy seeks to profit from inefficiencies in the markets for distressed, stressed, and performing debt securities. Portfolio Managers generally will use a fundamental and rigorous credit-intensive approach to identify and capture these inefficiencies. They will attempt to control risk through diversification of holdings across individual issuers, industries, sectors, and geography, as well as through hedged and direct short positions. Sub-strategies may include capital structure arbitrage, event-driven credit, credit long/short, long distressed, and fixed income lending, among others.

Event-Driven

Event-driven strategies involve investing in opportunities created by significant transactions and/or events, such as spin-offs, mergers and acquisitions, bankruptcy reorganizations, recapitalizations, and share buybacks.

Fixed Income

Fixed income strategies attempt to profit from movements in bond prices. Fixed income strategies, such as relative value arbitrage, involve the pairing of one instrument believed to be of higher value with another closely related instrument believed to be of lower value. Fixed income arbitrage can involve corporate, government, or mortgage assets.

Global Macro

Global macro strategies seek to identify investment opportunities arising from macroeconomic, market and geopolitical developments and trends. These strategies may take long or short positions in global interest rate, fixed income, equity, currency and commodity markets through securities, futures, swaps, options and other instruments. Global macro strategies may employ discretionary, systematic or a combination of approaches.

Long/Short Equity

Long/short equity strategies involve the purchase of a long basket of stocks hedged by a short basket of stocks. Unlike market neutral equity, there are no constraints on the percentage of long securities versus short securities. For example, a Portfolio Manager might be 80% long and 20% short or 60% long and 40% short, thus exposing the net portfolio balance to broader market risk factors. Long/short equity can be broad in terms of security selection or very focused on a particular sector or geography.

Market Neutral Equity

Market neutral equity strategies attempt to profit from discrepancies between a basket of long and short positions in similar proportions. The decision to purchase or sell a security can be driven by computer models or by fundamental research. Typically, the long equity portion of the portfolio will include stocks with solid balance sheets, improving earnings, and strong financial ratios. The short equity positions will include stocks with weak balance sheets, declining earnings, outdated products, and poor financial ratios. Some market neutral equity strategies concentrate on specific sectors or geographies.

Quantitative and Systematic

Quantitative and systematic strategies use quantitative analysis, statistical techniques, algorithms, models and other technology to identify investment opportunities, construct portfolios and/or generate trading signals. These strategies may incorporate a variety of data sources and may be implemented with varying degrees of human judgment or intervention. Certain strategies may also use artificial intelligence (“AI”) and machine learning technologies as part of the investment process.

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Multi-Strategy

This strategy generally involves Portfolio Managers exercising discretion in allocating capital among several types of investment strategies. Capital is allocated to each strategy based on the possibility of an opportunity set changing with market conditions.

Relative Value

Relative value is an investment strategy that involves taking positions based on the pairing of one instrument that is believed to be overpriced with another closely related instrument that is believed to be underpriced. Examples include merger, credit, and convertible bond arbitrage. Merger arbitrage generally involves buying the common stock of a company involved in a takeover or merger attempt where the current market price is less than the offered price on the transaction’s expected closing date. Credit arbitrage seeks to take advantage of price discrepancies between common stocks, bonds, options, and credit derivatives of the same issuer or another related company or companies. Convertible bond arbitrage involves the purchase of a convertible bond while a short position is taken in the underlying company’s common stock. This allows for trading of both the convertible bond and common stock against each other as one instrument becomes overvalued or undervalued relative to the other.

Opportunistic Strategies

To implement the opportunistic strategy, Lighthouse focuses on Portfolio Managers that attempt to take advantage of investment opportunities in the medium term (i.e., three to seven years) liquidity market that Lighthouse believes presents an attractive risk/return profile. Portfolio Managers that Lighthouse selects for the opportunistic strategy may implement event-driven, credit, or any other investment strategy. Lighthouse has found investment opportunities with Portfolio Managers who focus on asset-backed securities, collateralized loan obligations, collateralized debt obligations, long/short credit, bank loans, distressed debt, secondary loans, whole mortgages, and other products with exposure to the credit markets both in the U.S. and internationally. For the opportunistic portfolio, Lighthouse may also invest assets in non-credit focused opportunities, including, but not limited to, investments in distressed hedge fund interests trading at a discount in the secondary market and co-investment opportunities in individual securities alongside the Funds. Certain Funds implementing opportunistic strategies can have exposure to publicly and privately traded securities. Generally, our Portfolio Managers are neither limited in the markets (either by location or type, such as large capitalization, small capitalization, or non-U.S. markets) in which they invest nor the investment discipline that they may employ (such as value or growth or bottom-up or top-down analysis). The investment guidelines are set forth in the Subadvisory Agreements, each of which specify restrictions and investment strategies of the applicable Fund. However, the offering documents of Unaffiliated Funds may not subject the Portfolio Managers to any formal limitations as to the investments permitted or strategies in effect.

Risk of Loss Investing in securities involves a substantial risk of loss that investors in our Funds should be prepared to bear. Further, past performance of a Fund is not indicative of future performance. There are material risks associated with the structures of our Funds and with the investment strategies employed directly or through Portfolio Managers and Unaffiliated Funds, as summarized below. This summary does not attempt to describe all of the risks associated with an investment in our Funds or all the risks associated with the strategies employed by our Funds. Although no summary can fully describe all of the risks associated with an investment in our Funds, investors should also review the risk factors stated in the offering documents or relevant constitutional document for each of our Funds, which are tailored to the specific strategies and investment structures employed, and consult with their own financial advisors prior to making an investment.

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The risks described below may arise from investments made directly by Lighthouse, through Portfolio Managers, or through investments in other pooled investment vehicles, as applicable. Not every risk described below applies to every Fund or investment strategy.

Investment Management and Strategy Risks Investment Strategies and Risk Generally

The success of our Funds depends on Lighthouse’s and the applicable Portfolio Managers’ ability to identify and select investments, interpret market information and otherwise successfully implement the applicable investment strategies. For multi-Portfolio Manager strategies, success also depends on Lighthouse’s ability to select Portfolio Managers and allocate and reallocate capital among them. Portfolio Managers may deviate from expected investment strategies or guidelines, whether intentionally or inadvertently, and may engage in excessive concentration, directional investing, leverage or other activities that result in losses, or engage in fraud or other misconduct. There can be no assurance that Lighthouse or any Portfolio Manager will successfully implement an investment strategy or that a Fund will be able to obtain or maintain desired investments or exposures.

Multiple Portfolio Managers

For Funds that use multiple Portfolio Managers, each Portfolio Manager generally trades independently of the others. As a result, losses generated by certain Portfolio Managers may offset profits generated by others. Portfolio Managers may also compete for the same investment opportunities, potentially affecting the availability or value of positions in a manner adverse to a Fund. Conversely, Portfolio Managers may establish economically offsetting positions, causing a Fund to incur expenses without achieving a corresponding net investment exposure. Portfolio Managers may also establish similar or overlapping positions, resulting in greater concentration or correlation than intended.

Other Clients of Portfolio Managers

The Portfolio Managers may also manage other accounts (including other funds and accounts in which the Portfolio Managers have an interest) that may employ different or similar trading strategies and that, together with accounts already being managed, could increase the level of competition for the same trades our Funds might otherwise make, including the priorities of order entry. This could make it difficult or impossible to take or liquidate a position in a particular security or futures contract at a price or on the terms sought by a Portfolio Manager.

Portfolio Managers with Limited or No Performance Track Record

Certain Portfolio Managers may be newly formed businesses or otherwise have limited operating histories or performance track records. Such Portfolio Managers may still be developing their operational processes and refining their approaches to portfolio construction and risk management and may have fewer personnel or other resources than more established Portfolio Managers. Although Lighthouse may seek to evaluate the prior performance and experience of key personnel at previous firms, such information may be limited or unavailable and may not be indicative of the Portfolio Manager's future performance. These factors may increase the investment and operational risks associated with allocating capital to such Portfolio Managers.

Portfolio Managers Consisting of a Single Principal

Certain Portfolio Managers may consist of only one principal or otherwise depend substantially on a single individual. The death, incapacity, departure or other unavailability of such individual could adversely affect the implementation of the applicable investment strategy and result in losses to a Fund.

Regulatory Hosting Platforms

Lighthouse or an affiliate may provide regulatory hosting arrangements to certain Portfolio Managers, including arrangements under which a Portfolio Manager becomes affiliated with Lighthouse or an affiliate for purposes of obtaining regulatory authorization necessary to trade on behalf of a Fund. Lighthouse may also use third parties to provide such arrangements. Regulatory requirements and the availability or 18 | P a g e

permissibility of regulatory hosting arrangements vary by jurisdiction and may change. Changes in applicable requirements or regulatory practices could delay the onboarding of Portfolio Managers, interrupt or restrict the activities of existing Portfolio Managers, or require alternative regulatory arrangements, which could adversely affect a Fund or Lighthouse’s ability to source, attract and onboard Portfolio Managers.

Reliance on Management and Key Employees

The success of our Funds depends substantially on the services and skills of Lighthouse and its personnel and, depending on the applicable strategy, Portfolio Managers and their key personnel. The loss or unavailability of one or more key individuals, or an inability to attract and retain qualified investment and other personnel, could adversely affect the implementation of a Fund’s investment strategy and its performance.

Assets May Not Be Diversified

Our Funds are not necessarily required to diversify their investments and may have significant exposure to a limited number of positions, issuers, industries, sectors, geographic regions, asset classes, investment strategies or Portfolio Managers. In Funds that allocate capital among multiple Portfolio Managers, Portfolio Managers make investment decisions independently and may establish similar or overlapping positions, resulting in greater concentration or correlation than intended. Concentrated exposures may increase a Fund’s risk of loss because adverse developments affecting one or a limited number of investments or exposures could have a material adverse effect on the Fund.

Sector Risks

Certain Funds or investment strategies may have significant exposure to particular industries, sectors or market segments. Such concentrations may cause a Fund to be more significantly affected by economic, regulatory, technological or other developments affecting the applicable industry, sector or market segment and may result in greater volatility or losses than would occur in a more diversified portfolio.

Increased Competition for Investment Opportunities

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Lighthouse clients are primarily the Funds managed by Lighthouse. Lighthouse also provides investment advisory services to certain institutional investors through SMAs, as described in Item 4. These Funds are offered consistent with private offering requirements applicable to the jurisdiction where both the Fund is domiciled along with where the underlying investors are domiciled. The investors of these Funds include institutional investors and high net worth individuals. Institutional investors include, but are not limited to, sovereign wealth funds, governmental and corporate pension plans, insurance companies, banks, corporations, government entities, healthcare organizations, charitable organizations, foundations, endowments (including those benefiting universities and colleges), religious entities, and other business entities. Lighthouse also provides limited-scope advisory services, including Platform Services, to certain private funds managed by unaffiliated investment advisers, as described in Items 4 and 10. Each investor in a Fund must generally be (a) an “accredited investor” as defined in Regulation D under the Securities Act of 1933, as amended (the “Securities Act”) and (b) either a “qualified purchaser” as defined in the Investment Company Act or a “knowledgeable employee” as defined in the regulations thereunder. In the case of certain offshore Funds, non-U.S. investors generally need not be “accredited investors” or “qualified purchasers” so long as each such non-U.S. investor is not a “U.S. person” as defined in Regulation S under the Securities Act, as amended. Minimum investment requirements for investors vary by Fund and are set forth in the applicable Fund’s offering documents. Lighthouse may waive or modify such minimum investment requirements in its discretion, subject to applicable legal and regulatory requirements.

Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis As described in Item 4, Lighthouse offers Platform Hedge Funds and Hedge Fund Solutions designed to meet a variety of investment objectives, as described more fully in the offering documents of the applicable Fund or other documents governing the applicable mandate. Depending on the strategy, Lighthouse and its Portfolio Managers may use fundamental, quantitative, systematic, macroeconomic, relative value and other forms of analysis in identifying investment opportunities, constructing portfolios and managing risk. Investment strategies implemented across Lighthouse include, but are not limited to, equity, credit, event-driven, fixed income, global macro, quantitative and systematic, relative value, opportunistic and multi-strategy approaches. There can be no assurance that a Fund will achieve its investment objective. For strategies implemented through Portfolio Managers, Lighthouse also evaluates Portfolio Managers through quantitative and qualitative analysis of factors that may include performance history, strategy differentiation, portfolio construction, risk management, personnel, systems and internal controls. Lighthouse's overall portfolio construction may also take into account current economic and market conditions, liquidity, diversification of strategy exposures, capacity constraints and other factors. The main strategies implemented by our Portfolio Managers include:

Credit Event-Driven Fixed Income Global Macro Long/Short Equity Market Neutral Equity Quantitative and Systematic Multi-Strategy Relative Value Opportunistic 15 | P a g e

The strategies described below may employ a variety of investment techniques, including taking both long and short positions, the use of leverage and derivatives, and other techniques described elsewhere in this

Lighthouse charges some Funds a Performance Fee (in lieu of or in addition to a Management Fee) on terms described more fully in the applicable offering document or relevant constitutional document of our Funds. This Performance Fee is in addition to the fees and performance-based compensation charged by Portfolio Managers and Unaffiliated Funds (as applicable). Performance-based compensation may create an incentive for Lighthouse, a co-adviser or Portfolio Managers to cause our Funds to make investments that are riskier or more speculative than would be the case in the absence of performance-based compensation. In addition, because performance-based compensation is generally based on realized and unrealized gains and losses, Lighthouse, a co-adviser or a Portfolio Manager could earn performance-based compensation on gains that investors in certain Funds never realize. In some cases, a Fund issues more than one class or series of shares or interests where some classes or series are subject to a Performance Fee, while other classes or series are not. Similarly, a Fund that is subject to a Performance Fee and another Fund that is not subject to a Performance Fee may both invest through the same Fund. In those instances, all investors in the investing Funds are subject to the risks discussed in the preceding paragraph (not just the investors that are subject to the Performance Fee) because Lighthouse manages each such Fund as a single pool of assets. Moreover, the side-by-side management of some Funds that pay performance-based compensation and other Funds that do not pay performance-based compensation could create an incentive for Lighthouse to favor accounts from which Lighthouse receives performance-based compensation because Lighthouse stands to gain greater compensation from those accounts. Lighthouse addresses these conflicts through policies and procedures reasonably designed to provide fair and equitable treatment over time in the allocation of investment opportunities and transactions among our Funds. Allocations are not necessarily made on a pro rata basis among our Funds. Rather, Lighthouse allocates investment opportunities among our Funds on the basis of numerous considerations, such as: (i) different liquidity needs (e.g., investor inflows, investor outflows, foreign currency trading settlements, credit facility guidelines/limits, fund liquidity profile, or other reasons); (ii) the investment timeframe; (iii) the investment capacity of the investment opportunity; (iv) different strategy or investment needs (due to differing performance, changes in investment guidelines, differing capital bases, or other reasons); (v) the percentage of assets that the Fund has previously allocated to the same strategy as the investment opportunity; (vi) tax status and client type (onshore, offshore, and/or ERISA); (vii) intent to avoid our Funds having to pay withdrawal fees to Unaffiliated Funds; (viii) Funds not having sufficient cash or unfunded commitments on hand to make an allocation within the required timeframe; (ix) legal considerations; and (x) other considerations that Lighthouse deems appropriate in Lighthouse’s discretion. Lighthouse does not consider fees paid by an investor or a Fund when making allocation and redemption decisions. Certain Funds are treated as “plan assets” for the purposes of the fiduciary responsibility standards and prohibited transaction restrictions of the ERISA, and the parallel prohibited transaction excise tax provisions of Section 4975 of the Internal Revenue Code of 1986. For compliance and other reasons, certain investment funds or their investment managers limit the amount of the investment made by a plan assets fund or may prohibit such investments altogether. As a result, allocations of investments for “plan assets” and “non-plan assets” Funds are different due to the ability or inability of different investment funds or their investment managers to accept assets subject to ERISA.

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Neither Lighthouse nor any Lighthouse management persons are registered or have an application pending to register as a broker-dealer or a registered representative of a broker-dealer. Lighthouse is registered with the CFTC as a commodity pool operator (“CPO”) and commodity trading adviser (“CTA”) and is a member of the National Futures Association (“NFA”). Lighthouse’s NFA identification number is 0406075. In addition, certain of Lighthouse’s Relying Advisers have similar capacities with the CFTC and NFA: • •

North Rock Capital Management, LLC (“North Rock”) is registered with the CFTC as a CPO and is a NFA member. North Rock’s NFA identification number is 0483385. Mission Crest Capital Management, LLC (“Mission Crest”) is registered with the CFTC as a CPO and CTA and is a member of the NFA. Mission Crest’s NFA identification number is 0538437.

Lighthouse has entered into and may from time to time enter into co-advisory arrangements with unaffiliated investment advisers to jointly manage certain Funds or to provide limited scope advisory services. In some cases, these arrangements involve shared responsibility for investment management and related services; in others, Lighthouse’s role may be to primarily provide Platform Services. These relationships create potential conflicts of interest, including allocation of investment opportunities, resources, and expenses between the co-advisers’ respective clients. There is no guarantee that such arrangements will be successful or that the roles of the co-advisers will result in achieving the Fund’s investment objectives. Additional risks include: • •

Resource Allocation Risk: Each co-adviser may be unable to devote sufficient time and resources to the Fund. Delegation Risk: Investment and trading responsibilities may be delegated to an Investment Committee or other body, which may not successfully execute the overall strategy. 33 | P a g e

•

Termination Risk: If the co-advisers terminate their arrangement, the Fund may experience significant operational and strategic consequences, including potential cessation of operations, which could result in material losses to investors.

Lighthouse employees may constitute significant investors in certain Funds. Additionally, certain Funds are majority or wholly owned by Lighthouse and Lighthouse employees. Lighthouse may be viewed as having an incentive to favor those Funds in which Lighthouse employees invest. Lighthouse has adopted procedures and controls that are intended to ensure that no investors or Funds are favored over others. Lighthouse and its subsidiaries serve as the general partner or manager of the U.S.-domiciled Funds. Lighthouse and its subsidiaries serve as investment manager of the non-U.S. Funds. We do not receive any compensation from Portfolio Managers in connection with our Funds’ investments, and in the event we engage in any seeding transactions, the proceeds of any such transaction shall inure solely to the benefit of the Lighthouse Funds (i.e., Lighthouse Funds may receive a profit allocation from a Portfolio Manager’s investment management business). Certain personnel of Lighthouse serve as directors of Funds. These personnel do not receive compensation for their service as directors. Certain personnel of Lighthouse also serve as directors to MSW Director Services Limited, a wholly owned subsidiary of Lighthouse and a Cayman Islands exempted company that serves as corporate director to certain Funds. These personnel do not receive compensation for their services as directors of MSW. NGI, OWL or their affiliates own passive minority ownership stakes in certain alternative asset managers. Lighthouse may cause our Funds to invest with managers or their funds that are sponsored by NGI, OWL or their affiliates. In such case, the Funds will bear the fees and expenses incurred by investing with such managers, including asset- and/or performance-based compensation payable to NGI and/or OWL or their affiliates. Lighthouse will be subject to a conflict of interest in causing the Funds to make such investments given its affiliation with OWL and NGI. Longreach Alternatives Ltd. (“LRA”) is an Australia-based alternative asset management firm that is an affiliate of Lighthouse as a result of NGI being a greater than 25% shareholder of LRA. LRA maintains an Australian financial services license and provides investor distribution and client servicing support to Lighthouse. Lighthouse may compensate LRA in the future by paying an ongoing fee that comprises a portion of Lighthouse’s Management and/or Performance Fees. Lighthouse’s compensation to LRA would not increase the compensation earned by Lighthouse in respect of any investor solicited by LRA. Prospective investors introduced by LRA are informed of the affiliation between Lighthouse and LRA. LRA may sponsor and/or serve as a distributor to unaffiliated investment vehicles established by LRA or third parties for Australian and New Zealand investors to access certain of our Funds. Lighthouse is also affiliated with Ashmere Limited; LH PAMLI Partners GP LLC; and LH PAMLI Partners GP Ltd. These entities serve as general partners to Funds structured as Cayman Islands and Delaware limited partnerships. Lighthouse has two wholly owned affiliates which provide investment management or research services directly to Lighthouse: Lighthouse Partners UK, LLC, headquartered in London, and Lighthouse Partners HK Limited, headquartered in Hong Kong. Lighthouse’s Relying Advisers are listed below, together with any applicable foreign licenses or registrations:

North Rock, a Delaware limited liability company that manages a multi-portfolio manager long/short equity focused strategy.

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North Rock Capital Management (UK) LLP (“NR UK”), a United Kingdom limited liability partnership that serves as a sub-investment manager of the North Rock strategy. NR UK is authorized by the United Kingdom Financial Conduct Authority as a MiFIDPRU investment firm. North Rock Capital Management (HK) Limited (“NR HK”), a Hong Kong limited company that serves as a sub-investment manager of the North Rock strategy. NR HK is licensed by the Hong Kong Securities and Futures Commission to conduct regulated activities in Dealing in Securities and Asset Management. North Rock Capital Management (SG) Pte. Ltd (“NR SG”), a Singapore private limited company that serves as a sub-investment manager of the North Rock strategy. NR SG is licensed by the Monetary Authority of Singapore as a Capital Markets Services Licensee for Fund Management. North Rock Capital Management (DIFC) Limited (“NR DIFC”) is a private limited company incorporated in the Dubai International Financial Centre that serves as a sub-investment manager of the North Rock strategy. NR DIFC is authorized by the Dubai Financial Services Authority as a Category 3C Firm. Mission Crest, a Delaware limited liability company that manages a multi-portfolio manager global macro-focused strategy. Pier61 Partners, LLC, a Delaware limited liability company that manages a multi-portfolio manager strategy focused on opportunities influenced by climate, energy, and global public policy. LHP Ireland Fund Management Limited (“LHP Ireland”), an Irish private limited company that manages the assets of certain Ireland-domiciled Funds. LHP Ireland is authorized by the Central Bank of Ireland as an alternative investment fund manager. Lighthouse Partners (DIFC) Limited (“Lighthouse Dubai”) is a private limited company incorporated in the Dubai International Financial Centre. Lighthouse Dubai is authorized by the Dubai Financial Services Authority as a Category 4 Firm. Penglai Peak Capital Management, LLC, a Delaware limited liability company that manages a multiportfolio manager long/short strategy focused on Japan. LH Penglai Peak Ltd. (“Penglai Peak Japan”), a Japanese company registered with the Kanto Local Finance Bureau as an Investment Management Business Operator under the Financial Instruments and Exchange Act of Japan. Penglai Peak Japan serves as a sub-investment manager of the Penglai Peak strategy. LH Credit Partners LLC (“LH Credit”), a Delaware limited liability company that operates a consumer credit focused strategy. See LH Credit below. LH PAMLI Partners LLC, a Delaware limited liability company that manages a credit convexity focused strategy. Lighthouse Omphalos Partners, LLC (“LH Omphalos”), a Delaware limited liability company that manages an AI-powered long/short strategy. See LH Omphalos below.

LH Credit operates as a Relying Adviser under Lighthouse and manages a strategy focused on consumer-credit through dedicated Funds. The strategy is intended to concentrate on consumer receivables generated through lending platforms that have bank partner arrangements with DR Bank, a state-chartered non-member bank regulated by the State of Connecticut Department of Banking and the Federal Deposit Insurance Corporation, but may diversify its holdings across lending platforms over time. While Lighthouse and DR Bank are not affiliated, certain personnel involved in the management of the strategy have outside relationships with DR Bank. In particular, certain personnel employed or affiliated with DR Bank, including the Chairman of the Board of DR Bank and the largest shareholder of DR Bank’s holding company, have been seconded to LH Credit and have day-to-day portfolio management responsibilities. The portfolio management personnel will devote such reasonable time and efforts to the business, purposes and activities of LH Credit as determined to be necessary for the dedicated Funds to achieve their business objectives. However, such personnel currently conduct, and may in the future conduct, other business, including any business within the asset management and/or consumer lending industry, including, but not limited to, continuing to provide services to DR Bank, in an employment, board member and/or advisory capacity and, in such capacities, will have ongoing responsibilities and obligations (including fiduciary obligations) to DR Bank. Further, certain personnel of Lighthouse, including Lighthouse’s Founder and Chief Executive Officer, are shareholders in DR Bank and its affiliates. These relationships and ownership interests could influence the decision-making process of 35 | P a g e

such personnel, including decisions related to investments, counterparties, allocation of certain costs incurred by DR Bank in connection with the issuance of consumer receivables purchased by the dedicated Funds, or other transactions involving DR Bank. Lighthouse believes that the conflicts relating to existing and future DR Bank relationships are mitigated, in part, by the incentive compensation structure of the dedicated Funds which can serve to align the interest of LH Credit personnel with the overall performance of the dedicated Funds, rather than with any specific external entity. LH Omphalos operates as a Relying Adviser under Lighthouse and manages the Omphalos Funds. LH Omphalos is jointly owned by Lighthouse, which holds a majority interest; an unaffiliated technology provider that provides AI-related services to LH Omphalos; and a vehicle owned by certain Lighthouse executive officers and other management personnel. These ownership interests present conflicts because certain Lighthouse personnel may benefit economically from the activities of LH Omphalos and the technology provider is both an owner of and service provider to LH Omphalos. Lighthouse addresses these conflicts under the policies described in Items 6 and 11.

Transactions and Personal Trading Code of Ethics Lighthouse has adopted a Code of Ethics and Statement on Insider Trading (“Code”) that sets forth the ethical standards of business conduct and personal securities trading policies that Lighthouse requires of Lighthouse employees. A copy of the Code is available upon request by any investor or potential investor by contacting us at +1-561-741-0820 or investor.relations@lighthousepartners.com. Under the Code, Lighthouse states its commitment to upholding the highest level of professionalism in the investment community. Lighthouse policies and prohibitions are primarily focused on avoiding conflicts of interest with investors and our Funds while acting consistently with Lighthouse’s fiduciary duties. Through regular reporting and/or obtaining pre-approval from the Lighthouse Chief Compliance Officer (“CCO”), employees are subject to various policies that govern, among other things, employee securities transactions, gifts, and entertainment, outside business activities, confidentiality of information, and charitable and political contributions. The Code strictly prohibits the misuse of material non-public information. At the beginning of employment and annually thereafter, each Lighthouse employee must acknowledge the terms of the Code and receive training on the various obligations under it. Any employee who violates the Code will be subject to disciplinary action up to and including termination. All employees are obligated to report any violations of the Code to the CCO. The CCO and compliance staff conduct testing and monitoring of various procedures under the Code and provide an annual report to Lighthouse’s senior management on the effectiveness of these policies and procedures.

Participation or Interest in Client Transactions Lighthouse and Lighthouse-qualified employees (subject to pre-approval requirements) may invest in certain Funds and in certain underlying securities in which investors also invest indirectly through the Funds, and certain Lighthouse employees hold ownership interests in Lighthouse affiliates, as described in Item 10. In addition, Lighthouse serves as the general partner and manager of the U.S. Funds. The investments and interests of Lighthouse employees and Lighthouse's status as the general partner and manager of the U.S. Funds could be viewed as creating a conflict of interest because Lighthouse and its employees may have an incentive to act in its interest or their own self-interest as opposed to that of the applicable Fund. However, the Code, as described above, and various other compliance policies and procedures, such as our allocation policy, are intended to ensure the mitigation of the risk that any Fund is favored over another.

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Lighthouse may cause a Fund to purchase, sell, or transfer interests in a Fund or Unaffiliated Funds from or to another Fund when Lighthouse believes that those transactions are appropriate and in the best interest of those Funds. Any such purchase, sale, or transfer will take place at the stated net asset value of the interests being purchased, sold, or transferred. In addition, Lighthouse may recommend that a Fund purchase or sell an investment that is being sold or purchased, respectively, at the same time by Lighthouse, Lighthouse’s affiliates, officers, employees, or another advisory client. In addition, under certain circumstances, employees may hold personal investments in the same portfolio securities that Lighthouse clients hold. These personal investments could be in the same security or in different parts or issues of the same issuer’s capital structure. Lighthouse, as a fiduciary, endeavors to always make decisions in the best interest of clients if a conflict of interest arises. If any such investment(s) poses a conflict of interest, Lighthouse will seek to act in a way that favors the interest of clients. There could also be various reasons such as investment or risk guidelines, trading restrictions, entry point, investment time horizon, estate planning, or tax consequences that may cause Lighthouse personnel to transact contrary to Lighthouse clients in common investments. In relation to cross trades and those simultaneous purchases and sales, Lighthouse may have a conflict of interest between acting in the best interest of that Fund and assisting another Fund by selling or purchasing a particular Fund investment or Unaffiliated Fund interest. Lighthouse does not typically engage in principal transactions with our Funds; however, on occasions when such transactions occur, Lighthouse obtains any required client consents in accordance with applicable law. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker‐dealer, buys from or sells any security to any advisory client. A principal transaction also may be deemed to occur if Lighthouse and Lighthouse subsidiaries own a substantial portion of a Fund, and that Fund participates in a purchase or sale transaction with another Fund. Any principal or cross trade will be effected in accordance with applicable law and Lighthouse's policies and procedures, including applicable approval, pricing and consent requirements. Lighthouse also has adopted compliance policies and procedures designed to ensure that, over time, all our Funds are treated fairly in allocation and redemption opportunities (see Item 6). Certain officers of Lighthouse serve as directors of the non-U.S. Funds, and these officers are not compensated for their service as directors. Under certain circumstances, we may determine that Lighthouse or one of our employees or certain affiliates has obtained, or may have obtained, material non-public information. Lighthouse maintains a “restricted list” that is designed to prevent our clients, officers, and employees from engaging in insider trading. Lighthouse and its affiliates’ use of a restricted list and caution in connection with potential exposure to material non-public information may limit clients’ investment opportunities. Lighthouse employees may benefit from educational events sponsored by industry service providers such as prime brokers, administrators, law firms, audit firms, and such other professional service firms.

In certain Platform Hedge Funds, we have discretion in deciding which securities are bought and sold, the amount and price of those securities, the broker-dealers to be used for a particular transaction, and commissions or markups and markdowns paid. In selecting broker-dealers to effect transactions, the factors Lighthouse considers include, but are not limited to, listed bids and asks, the opportunity for price improvement, transaction costs, anonymity, liquidity, the ability to effect prompt and reliable executions at favorable prices, the operational efficiency with which transactions are effected, taking into account the size of order and difficulty of execution; speed of execution, expertise with difficult securities, the financial strength, integrity and stability of the broker-dealer; the quality, comprehensiveness, and frequency of related services considered to be of value; the competitiveness of commission rates in comparison with other broker-dealers satisfying our selection criteria, responsiveness, and frequency of errors. Accordingly, if we determine that the amount of commissions charged by a broker-dealer is reasonable in relation to the value of the brokerage and products or services provided by such broker-dealer, the Fund may pay commissions to such broker-dealer in an amount greater than the amount another broker-dealer 37 | P a g e

might charge for effecting the same transaction. We may benefit indirectly from payments made by a client (including payments by way of “soft dollars”) as described further below. With respect to our North Rock Platform Hedge Fund, we receive research, brokerage, or other products or services other than executions from a broker-dealer and/or a third party in connection with securities transactions. This is known as a soft dollar relationship. We have also established commission sharing arrangements (“CSAs”) with various broker-dealers and use a commission management service to assist in administering soft dollar payments to third-party research providers that are paid with soft dollars. We have entered into such arrangements where we believe that it is administratively or operationally expedient to do so or where such an arrangement is more favorable to the client than an arrangement under which the client pays for the products or services in question with hard dollars. However, such arrangements may present conflicts in allocating expenses and make it more difficult for investors to evaluate the cost structure of a client because the costs of such products or services are not broken out separately. Lighthouse limits the use of soft dollars to obtain services that constitute research and brokerage within the meaning of Section 28(e) of the Securities Exchange Act of 1934, as amended. Research and brokerage services Lighthouse receives include but are not limited to research reports on particular industries and companies, economic and industry surveys and analyses, recommendations as to specific securities, certain financial newsletters and trade journals, software providing analysis of securities portfolios, attendance at certain seminars and conferences, discussions with research analysts, meetings with corporate executives, data services (including services providing market and alternative data, news data, company financial data, and certain valuation, pricing, and economic data), consulting services regarding products, technologies, issuers, or industries, market risk data, advice on portfolio strategy, financial database software and services, advice from brokers on order execution, as well as other products and services that provide assistance in the performance of investment and trading decision-making responsibilities, services related to trade execution, including effecting securities transactions, messaging and connectivity services used to transmit orders, commission management services, including trade recordkeeping and reporting, and clearing and settlement of securities and functions incidental thereto. Where a product or service provided has both “eligible” uses under Section 28(e) (i.e., uses related to Lighthouse’s investment decision-making process) but also has other uses, Lighthouse will make a reasonable allocation between the eligible and “non-eligible” uses and will use soft dollars only for the eligible portion. Lighthouse and Portfolio Managers also receive products or services that may have multiple uses or that benefit more than one Sub-Account, and in some instances all or a portion of the products or services received are eligible under the Section 28(e) safe harbor. Lighthouse allocates the cost of any mixed-use products or services between hard dollars and soft dollars and among Sub-Accounts in good faith. In making good faith allocations of costs between non-eligible administrative benefits and eligible research and brokerage services, a conflict of interest exists by reason of Lighthouse’s allocation of the costs of such benefits and services between those that primarily benefit Lighthouse and those that primarily benefit the client. Our use of soft dollars presents a potential conflict of interest because Lighthouse is effectively using client assets to pay for research that we might be able to generate internally or would otherwise have to purchase. Soft dollar arrangements also provide an incentive to select or recommend a broker-dealer based on an interest in receiving research or other products or services, rather than on receiving the most favorable execution. Soft dollar arrangements may cause the Fund to pay commissions (markups or markdowns) higher than those charged by other broker-dealers in return for soft dollar benefits (known as “paying-up”). As previously mentioned, Lighthouse considers the amount and nature of research services provided by broker-dealers, as well as the extent to which such services are relied upon and attempts to allocate a portion of the brokerage business of clients on the basis of that consideration. In addition, broker-dealers sometimes may suggest a level of business that they would like to receive in return for the various services provided. Actual brokerage business received by any broker-dealer may be less than the suggested allocations but can (and often does) exceed the suggestions because total brokerage is allocated on the basis of all the considerations described above. A broker-dealer is not excluded from receiving business because it has not been identified as providing research services. Periodically, we consider the amount and nature of research and brokerage services provided by broker-dealers, as well as the extent to which such services are relied upon, and we attempt to allocate a portion of the brokerage business of the clients on the basis of that consideration. Research and brokerage services 38 | P a g e

obtained by the use of commissions arising from a client’s portfolio transactions may be used by Lighthouse in its other investment activities. Research and brokerage services obtained by the use of commissions arising from a client’s portfolio transactions generally benefit the respective client though they typically benefit Lighthouse and certain third-party Portfolio Managers as well. In some cases, such as at the end of a calendar year or when an account closes, certain brokers may provide a cash refund of unused soft dollar credits. In such case, Lighthouse intends to credit the refund to the corresponding client. Lighthouse maintains policies and procedures to review the quality of executions, including periodic reviews by our trading and investment professionals of our brokerage and counterparty relationships. A “trade error” is generally considered to include an error that (i) prevents portfolio trading instructions given by a Portfolio Manager on behalf of a client from being substantially effectuated in the manner intended by the Portfolio Manager; (ii) results in the execution of a trade on behalf of a client that was not intended for that client; or (iii) causes a violation of any applicable investment guideline or restriction. Depending on the relevant facts and circumstances, other events might also be considered trade errors. Lighthouse seeks to detect trade errors prior to settlement and to correct and/or mitigate them in an expeditious manner. Generally, gains and losses attributable to trade errors will be borne by clients. However, if the error was caused by Lighthouse’s willful misconduct, recklessness, or gross negligence, then Lighthouse will bear the costs of the error. Lighthouse has a conflict of interest in determining whether an error has occurred or was caused as a result of willful misconduct, recklessness, or gross negligence. To the extent an error is caused by a third party, such as a broker, Lighthouse will seek to recover any losses associated with the error from that third party. However, there is no guarantee that Lighthouse will be able to do so. Lighthouse will not use soft dollars or commitments of future brokerage business to compensate any broker-dealer for absorbing the cost of a trade error. Lighthouse or our subsidiaries may receive introductions to Fund investors through broker-dealers that are prime brokers or who execute trades on behalf of Lighthouse. Lighthouse does not believe that it pays any additional fees or higher commissions as a result of these introductions. Lighthouse seeks the best execution on all transactions. However, Lighthouse may have an incentive to select or use an executing or prime broker based on Lighthouse or an affiliate receiving Fund investor referrals from that counterparty. Lighthouse does not consider client or Fund investor referrals from broker-dealers when making brokerage allocation decisions. Where a Relying Adviser manages more than one Fund or account pursuing the same or a similar investment strategy, Lighthouse may aggregate orders and determine an allocation method for the aggregated orders, subject to treating the participating Funds and accounts fairly. Lighthouse is not obligated to aggregate orders, and where orders are not aggregated, participating Funds and accounts may receive different prices for the same security and bear higher transaction costs than if orders had been combined. As it relates to our Platform Hedge Funds, third-party Portfolio Managers generally do engage in brokerage activities (e.g., direct brokerage transactions or have soft dollar arrangements). As part of the Lighthouse due diligence process on Portfolio Managers, Lighthouse reviews the brokerage practices and soft dollar arrangements of the third-party Portfolio Managers. Lighthouse selects the prime brokers and swap counterparties of our Funds in consultation with the Portfolio Manager, based on such factors as the prime broker or counterparty’s overall performance, pricing, operational capabilities, and financial stability. Lighthouse negotiates the terms of the fees and commissions each Fund will pay to each applicable prime broker. Under the terms of each Subadvisory Agreement between a third-party Portfolio Manager and a Fund, each Portfolio Manager is responsible for arranging for the execution of all orders for the purchase and sale of securities and other investments with respect to the applicable Fund. The Portfolio Manager is required to seek the best execution for that Fund. The Portfolio Manager, to the extent permitted by applicable laws and regulations, may aggregate the investments to be purchased or sold on behalf of its clients to attempt to obtain a more favorable price, lower brokerage commissions, or most efficient execution. Portfolio Managers may engage in soft dollar practices whether or not such practices fall within the soft dollar safe harbor established by Section 28(e) of the Securities Exchange Act of 1934, as 39 | P a g e

amended. For instance, a Portfolio Manager could receive “brokerage and related services” covered by such safe harbor as well as office space, overhead expense reimbursement, and similar benefits not covered by such safe harbor. Lighthouse conducts hedging in relation to certain of our Fund share classes that are denominated in a foreign currency. Lighthouse may also deem it advisable for a Fund to take a direct position in a security, currency, over-the-counter derivative, or futures product for hedging or portfolio reallocation purposes. If Lighthouse terminates a Portfolio Manager’s investment authority over a Fund, Lighthouse may cause such Fund to trade securities, futures, or other financial instruments it holds, typically by liquidating them as promptly as Lighthouse deems advisable under the circumstances or by hiring a third party to do so. Finally, Funds may buy or sell interests in Unaffiliated Funds through secondary market transactions. Lighthouse does not request, require, or recommend an investor to direct brokerage transactions to specific brokers or dealers. Lighthouse does not select or recommend brokers or dealers based on whether they refer investors to Funds.

Lighthouse does not receive an economic benefit for providing investment adviser or other advisory services to any Funds from any person who is not an investor. Lighthouse engages third-party placement agents to solicit investors for certain Funds. In such instances, the placement agent is typically compensated by way of a retrocession that is specified in the applicable solicitation, placement, or other applicable agreement. Retrocession is a term used to describe an on‐ going fee payable by Lighthouse – and not a Fund – to the third-party placement agent so long as such assets placed by the placement agent remain invested in the Fund. Lighthouse may pay a retrocession fee in an amount equal to all or part of the management fee and/or performance‐based compensation to third-party placement agents for assisting in the placement of interests in a Fund. The payment of the retrocession fee by Lighthouse to a third-party placement agent does not increase the compensation earned by Lighthouse in respect of any investor solicited by a third-party placement agent. However, in certain circumstances, placement agents have an agreement with an investor to be compensated by receiving an upfront selling commission from the investor’s subscription amount. Any solicitation agreement with placement agents is in writing and in compliance with applicable securities laws. The payment of retrocessions may cause a placement agent to recommend one Fund over another adviser that does not pay such compensation. In any case in which a placement agent receives payment from Lighthouse, the placement agent will have a conflict in advising investors with respect to subscriptions and withdrawals. Further, placement agents may receive different amounts of compensation with respect to different Funds and therefore could have incentives to favor one or more products over others. The Funds also use placement agents some of which may be affiliated with Fund investors or brokerdealers or prime brokers that service the Funds. Placement agents receive compensation from Lighthouse in connection with investors referred by them. Placement agents that solicit or refer potential investors to Funds are subject to a conflict of interest because they will be compensated in connection with their solicitation activities. Investor referrals or an investment from an entity or affiliate that serves as an executing or prime broker may also create a conflict of interest in that such may create an incentive for Lighthouse to direct additional brokerage to these entities or an affiliate. As mentioned in the Brokerage Practices section above, Lighthouse does not consider client or investor referrals when selecting trading counterparties. Lighthouse also has policies and procedures designed to seek the best execution on all transactions and periodically monitors and evaluates service providers.

Other Compensation Lighthouse does not permit Lighthouse employees to receive any form of compensation, including cash, sales awards, or other prizes, from non-clients for providing advisory services to our Funds. Lighthouse maintains written policies and procedures with respect to the giving and receipt of gifts and entertainment and the giving of donations and contributions, which are reasonably designed to comply with applicable law, including pay-to-play restrictions. Those policies and procedures may prohibit giving or receiving gifts, entertainment, donations, and contributions under certain circumstances (e.g., lavish or excessive). Lighthouse also receives investor referrals from unaffiliated consultants and wealth advisers that are retained by investors. Lighthouse does not compensate these parties for such referrals but may enter into

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agreements with them to reduce management and performance fees paid by their clients based on their clients’ aggregate investments in our Funds.

Lighthouse and management personnel have not been involved in any legal or disciplinary events in the past 10 years that Lighthouse believes would be material to an investor or client’s evaluation of Lighthouse or its personnel.

Review of Accounts Lighthouse monitors compliance with the investment objectives of its clients on an ongoing basis, and this is done at least monthly. In general, Lighthouse has daily (and in many cases real-time or intraday) information regarding its managed portfolios. Additionally, investment personnel of the Lighthouse Group are organized into formal committee/team structures that provide a framework for the management of its portfolios.

Reports to Investors Each investor in a Fund receives monthly account statements, depending on the terms specific to that Fund, which provide beginning and ending balances as well as a description of account activity. Statements are either delivered by mail or as elected by an investor, by an email notification that the statements are available on the administrator’s website. In limited circumstances where onshore investors have opted to receive their statements in hardcopy format via mail, statements are distributed monthly. Certain investors or their advisors receive performance estimates and monthly risk reports of various Funds via email monthly. Similarly, Lighthouse also distributes weekly performance estimates for certain Funds via email. On a monthly and/or quarterly basis, Lighthouse also prepares commentary on overall investment performance that is sent to various investors or their advisors. On a quarterly basis, senior investment staff conduct conference calls providing investment commentary on certain of our products and hedge fund strategies, providing general investment commentary to various investors and their advisors. The reporting that is in addition to the monthly account statements described above is also made available to investors or their advisors upon request. Each investor in a Fund also receives audited financial statements on an annual basis. In the case of Funds that are organized as partnerships for U.S. tax purposes, as soon as reasonably practicable after the end of each calendar year, Lighthouse delivers to each person who was an investor in the Fund at any time during such calendar year such tax information and schedules relating to the Fund as are necessary for the preparation by the investor of its federal income tax returns. However, Lighthouse does not assume responsibility for tax reporting errors or delays on the part of the Unaffiliated Funds. Further, a Fund that is organized as a partnership for U.S. tax purposes may not be able to complete and file its partnership income tax return for any year or deliver a Schedule K-1 for such year to each of its investors until the Fund has received tax information for that year from the Unaffiliated Funds in which it invests. Because certain Unaffiliated Funds in which a Fund may invest are calendar-year taxpayers, and due to the time needed for the preparation of income tax returns, Lighthouse is ordinarily not able to send a Schedule K-1 to each investor in time to file the investor’s income tax returns by the original due date. In such cases, Lighthouse can provide investors with tax estimates prior to issuing a 40 | P a g e

Schedule K-1, and it is usually necessary for each investor to obtain an extension of the filing date for its return for such year.

Under the “custody rule” under the Investment Advisers Act of 1940, as amended – which imposes certain requirements on SEC-registered investment advisers that have custody of client funds or securities – Lighthouse is deemed to have custody of the assets of its private Funds even though neither Lighthouse nor its affiliates has actual physical custody of such assets. Although Lighthouse is deemed under the custody rule to have custody of the assets of its private Funds, Lighthouse is exempt from many of the provisions of that rule because it undertakes to deliver to investors in such Funds, on an annual basis, financial statements of such Funds that are (i) prepared in accordance with U.S. generally accepted accounting principles; and (ii) audited by an independent public accountant that is registered with and subject to regular inspection by the Public Company Accounting Oversight Board.

Generally, Lighthouse has discretionary authority over each Fund pursuant to a limited partnership agreement, limited liability company agreement, investment management agreement, or other constitutional documents. Such discretion is exercised in a manner consistent with the stated investment objectives and strategies of the particular Fund and may include selecting investments or investment vehicles, allocating capital among Portfolio Managers, and conducting direct investment trading. In certain Funds, Lighthouse’s discretion is limited by further restrictions, such as approval by the investor, investor representatives, board of directors, or other body designated under the governing documents of the Fund. For the majority of such assets, however, Lighthouse maintains authority to terminate a Portfolio Manager’s investment authority on behalf of the Fund. With respect to a portion of the assets of a Custom Fund and certain Funds managed under Lighthouse Platform Services offerings, Lighthouse does not have the authority to terminate a Portfolio Manager's investment authority without requisite approval, or acts subject to the direction of the Fund's unaffiliated investment manager, and therefore treats such arrangements as non-discretionary for this purpose. For Fund Accounts, Lighthouse maintains discretionary authority but delegates the day-to-day investment activity to Portfolio Managers who are subject to investment guidelines set forth in the respective Subadvisory Agreement.

Lighthouse has adopted a policy for exercising proxy voting rights as required under Rule 206(4)-6 of the Investment Advisers Act of 1940, as amended. The Lighthouse proxy voting policy is reasonably designed to ensure that Lighthouse votes proxies in the best interest of our Funds and their investors. The exercise of proxy voting rights typically involves votes with respect to (i) circumstances where Lighthouse trades equities directly on behalf of Funds and (ii) terms and structure changes governing the Unaffiliated Funds in which certain Funds invest. With respect to circumstances where Lighthouse trades equities directly, Lighthouse would vote in a manner that it believes reasonably furthers the best interest of the Funds and is consistent with the investment objectives as set forth in the relevant investment management documents. Lighthouse may abstain from voting if it deems that abstaining is in a Fund’s best interest. For example, Lighthouse may abstain from voting proxies where (i) clients no longer hold the securities at the time of the vote (whether or not they held them on the record date of the vote), (ii) Lighthouse, on behalf of clients, has a net short position in such issuer, or (iii) the proxy involves “share blocking,” or similar measures that could limit Lighthouse’s ability to sell the affected security during a blocking period. There may also be times when 42 | P a g e

refraining from voting is in the best interest of clients, such as when analysis of a proxy reveals that the cost of voting the proxy may exceed the expected benefit to clients. For example, Lighthouse may elect not to vote all proxies or acknowledge a Portfolio Manager’s policy of not voting all proxies, for certain portfolios when it determines that the success of the portfolios’ investment strategy is not dependent on the outcome of proxy contests, such as with certain quantitative strategies with short-term holding periods. Because Lighthouse does not feel it is in our clients’ best economic interest, Lighthouse also does not anticipate attempting to recall shares that have been lent or rehypothecated in order to participate in proxy voting. We will reasonably try to assess whether Lighthouse is subject to any material conflict of interest in connection with proxies. If it is determined that a conflict of interest is material, one or more methods may be used to resolve the conflict. These include disclosing the conflict to the relevant client and obtaining its consent before voting; suggesting to the relevant client that it engages another party to vote the proxy on its behalf; consulting with an unaffiliated third party (e.g., a proxy voting service) to recommend a vote with respect to the proxy, based on application of the policies set forth herein; or such other method as is deemed appropriate by Lighthouse under the circumstances given the nature of the conflict. Portfolio Managers typically have authority to vote proxies in the best interest of their Sub-Account; therefore, at times, a Lighthouse client may vote the same proxy differently when multiple Portfolio Managers vote the respective proxy. For certain Platform Hedge Funds, Lighthouse has engaged a third-party proxy voting service to assist in the administration of its proxy voting responsibilities and provide proxy voting recommendations. A review and agreement of general voting guidelines and policies has been established between Lighthouse and the proxy voting service provider. Lighthouse also periodically reviews the proxy voting service provider’s voting guidelines and processes. The proxy voting firm pre-populates each client’s votes with the proxy voting service’s recommendations and automatically submits the Fund’s votes. Pre-population and automated voting generally occur prior to the submission deadline for proxies to be voted on at the shareholder meetings and Lighthouse relies on the proxy voting service to ensure soliciting materials that are received close to the submission deadline are incorporated into voting recommendations and Lighthouse’s votes. Lighthouse will generally vote in line with the recommendations of the proxy voting service in accordance with their voting guidelines and recommendations. Should a situation arise where Lighthouse or a Portfolio Manager believes voting in a manner other than agreed upon in the guidelines, or abstaining from a vote, is in the best interest of its clients, Lighthouse will exercise its discretion to vote or abstain accordingly. With respect to voting regarding Unaffiliated Funds, in evaluating these proxies, Lighthouse considers numerous factors relating to each investment and makes an independent determination whether to support or oppose a proposal from a third-party Portfolio Manager. Lighthouse also has procedures to ensure a proxy is voted in our Funds’ best interest in the event a proxy vote creates a material conflict between the interests of Lighthouse and our Funds. Third-party Portfolio Managers of our Funds are required to have a proxy voting policy and vote proxies pursuant to the applicable Subadvisory Agreement. Lighthouse has also adopted procedures and retained the services of a third-party service provider to facilitate the submission of claims in class actions involving securities held by Lighthouse clients. When Lighthouse participates in a class action lawsuit and later receives any recovery amounts, those amounts will generally be credited to the participating clients at the time the recovery amounts are received. A copy of the Lighthouse proxy voting policies and procedures is available to investors upon request.

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Lighthouse has never filed for bankruptcy and is not aware of any financial condition that is expected to affect Lighthouse’s ability to manage client accounts.

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