Lingotto Investment Management LLP

Lingotto was formed in July 2016 as a limited liability partnership with its principal place of business in London, England, United Kingdom. Lingotto is authorized and regulated by the Financial Conduct Authority (FCA) in the United Kingdom. Lingotto is indirectly owned by Exor N.V., a publicly listed company incorporated in the Netherlands (Amsterdam Stock Exchange ticker: EXO). As described further in Item 7, Lingotto provides investment advisory services on a discretionary basis to the following pooled investment vehicles, each of which is offered as a private fund to U.S. investors. Lingotto Intersection Offshore Long/Short Master Fund LP and its feeder funds Lingotto Intersection Offshore Long/Short US Fund LP and Lingotto Intersection Offshore Long/Short Fund Ltd (referred to collectively as “Intersection Long/Short Strategy”). Lingotto Intersection Offshore Concentrated Long Master Fund LP and its feeder funds Lingotto Intersection Offshore Concentrated Long US Fund LP and Lingotto Intersection Offshore Concentrated Long Fund Ltd (referred to collectively as “Intersection Concentrated Long Strategy”). The Intersection Long/Short Strategy and the Intersection Concentrated Long Strategy shall be collectively referred to herein after as the “Intersection Strategy”. Lingotto Alternative Investments Master Fund ICAV – Lingotto Innovation Master Fund and its feeder funds Lingotto Alternative Investments Feeder Fund ICAV – Lingotto Innovation Feeder Fund and Lingotto Innovation Fund LP (referred to collectively as the “Innovation Funds”). Lingotto acts as a sub-advisor to its affiliate Lingotto (US) LLC in respect of Lingotto Innovation Ventures Fund I, LP, a proprietary investment vehicle that is not offered to outside investors. Lingotto also acts as an investment adviser to separately managed accounts (each an “SMA”, together the “SMAs”, and collectively with the Innovation Funds and Lingotto Innovation Ventures Fund I, LP, the “Innovation Strategy”) that follow a similar strategy as the Innovation Funds. Each of the Innovation Funds and the Intersection Strategy referred to herein as a “Fund”. The Funds, along with the SMAs, are the Firm’s “Advisory Clients”. Lingotto generally invests on behalf of Advisory Clients in strategies which invest in equity and equityrelated securities, unlisted companies, new issues, specialty credit opportunities, and to a lesser extent corporate fixed income securities. Please see Item 8 for more information about the investment strategy for each Fund. Each Advisory Client is managed in accordance with investment objectives, strategies, fees, risks, and restrictions, which are set forth in more detail in either the Fund’s private offering memoranda and governing documents or in the investment management agreement for separately managed accounts. These offering materials are available to prospective investors or clients of the Funds. Lingotto does not tailor its advisory services to the individual needs of investors in the Funds and generally does not accept investor-imposed investment restrictions. The terms and any investment restrictions of the SMAs are individually negotiated and documented in their investment management agreements.

As of December 31, 2025, Lingotto, including its affiliates, had approximately $10.6bn of assets under management on a discretionary basis. The Firm does not manage any assets on a non-discretionary basis.

The Funds

Investment Management Fee Each investor in a Fund pays a management fee generally ranging from 1% to 1.5% of the net asset value attributable to their capital account depending on the particular fund share class selected for investment. For certain Funds management fees are payable monthly and for other Funds management fees are payable quarterly. The specific terms of the management fee and share classes are outlined in the relevant Fund’s offering memoranda. Performance-Based Fee The Funds pay a performance-based fee as described below in Item 6. depending on the terms of the relevant Fund’s offering memoranda. Waiver of Fees The management fee and/or performance-based fee may be and have been waived, reduced, or calculated differently with respect to certain investors, including, without limitation, investors that are members, shareholders, partners, affiliates or employees of the Firm or its affiliates. The governing documents of the Funds allow fees to be waived for such individuals and for different fees to be negotiated with investors in the Funds. Expenses In addition to the management fee and the performance-based fee outlined in Item 6 below, investors in a Fund also pay formation and preliminary expenses of the fund; the costs and expenses incurred in the course of fund operation which may include without limitation, taxes, expenses for legal, auditing and consulting services, research, registration fees and other expenses due to supervisory authorities, insurance, interest, brokerage costs, all fees and expenses of transactional, risk, market data and traderelated services; fees of the relevant Fund’s (or its general partner’s, if applicable) directors which shall include reasonable travelling, hotel accommodation and other out-of-pocket expenses incurred by them while executing their duties as directors; fund administrator fees; custodian fees; prime broker fees; fund secretary fees; auditor fees and expenses; and other service provider fees. Fund investors may also be subject to subscription and/or redemption charges as specified in the relevant fund’s offering documents. For more specific disclosure regarding the expenses paid by a Fund, investors should consult the relevant Fund’s offering documents. The SMAs Management Fee In connection with the advisory services provided to the SMAs, Lingotto will receive an management fee that is negotiated on an account-by-account basis and which is typically based on a percentage of each account’s assets under management. The management fees are paid quarterly or semi-annually in arrears, and paid by the underlying client of each SMA either directly or deducted from the SMA.

Performance-Based Fees Lingotto will receive a performance based fee in respect of each SMA as described below in Item 6. depending on the terms of each investment management agreement in place with each client. Expenses As set forth in the relevant investment management agreement for each SMA, each SMA client bears certain expenses relating to the operations of its SMA, which generally include (without limitation): trading expenses, brokerage commissions and other transaction charges. Please refer to Item 12 – Brokerage Practices for additional information.

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Methods of Analysis, Investment Strategies and Risk of

Descriptions set forth in this Brochure of specific advisory services that the Firm offers to Advisory Clients, investment strategies pursued, and investments made by the Firm on behalf of its Advisory Clients, should not be understood to limit in any way the Firm’s investment activities. The Firm may offer any advisory services, engage in any investment strategy, and make any investment, including any not described in this Brochure, that the Firm considers appropriate, subject to each Advisory Client’s investment objectives and guidelines. The investment strategies that the Firm pursues are speculative and entail substantial risks. Advisory Clients should be prepared to lose some or all of their investment. There can be no assurance that the investment objectives of any Advisory Client will be achieved or that the Firm’s attempts to manage risk will be successful. Please see the relevant Advisory Client’s governing documents for a full description of risks. Investment Strategy Innovation Strategy The Innovation Strategy comprises concentrated portfolios of public and private company positions in businesses driving exponential innovation, with the objective of achieving attractive returns and capital appreciation over the long-term. The Innovation Strategy’s expected sources of return arise from a rigorous, theme-based research process with flexibility to invest across both public and private markets globally. By anchoring investment decisions in long-term thematics and maintaining the freedom to pursue the most compelling opportunities regardless of asset class, sector and geography, the Strategy is designed to capture value from the transformative shifts in technology, society and industries. The Innovation Strategy will invest a proportion of the relevant assets in unlisted companies. Where the Firm considers it appropriate, a proportion of the relevant assets may be invested in debt and convertible securities issued by companies that the Firm believes align with the Innovation Strategy’s investment objectives. The Innovation Strategy will not take short positions other than for hedging purposes (including currency hedging). Although the Firm does not typically expect to do so, the Innovation Strategy may invest in derivative instruments traded on exchanges or over the counter including, but not limited to, forwards, futures (including index futures), options, warrants and swaps (including total return swaps) on equities, other equity related instruments, and other asset classes as may be deemed appropriate. Intersection Strategy The Intersection Strategy will invest principally in equity and equity-related securities and to a lesser extent corporate fixed income securities, primarily on a long and short basis. The portfolio will be comprised principally of shares in listed companies. The Firm is neutral as to the market capitalization of the companies in which it may invest and will look to invest on a global basis. Save as provided in the Funds’ information memoranda, the geographical focus of strategy’s portfolio may be concentrated dependent on the Firm’s view of the investment opportunities available. The strategy may invest directly or through undertakings for collective investment (principally regulated UCI). The strategy may also invest in other assets, including, but not limited to, private or unlisted securities, bonds and financial

derivatives instruments of any kind. There are no restrictions with respect to the types of underlying assets of such financial derivatives instruments in which the strategy may invest. In case of market deficiency or market volatility, or for other reasons where determined by the Firm, the strategy may invest up to 100 per cent. of its assets in money market instruments and equivalents, including cash. Methods of Analysis In pursuing an investment strategy, Lingotto, through analysis of industry dynamics, competitive positioning, managerial skill, profitability, opportunities for growth, and reinvestment requirements, seeks to identify and qualify investment opportunities. The Firm utilises proprietary forecasts for profitability, cash flow and balance sheet development, and a range of valuation models to help identify investment opportunities where the economic fundamentals discerned are, in its opinion, different to those reflected by the market price of the relevant securities. Beyond the insights offered by individual companies themselves (including by reference to market and/or accounting data), for certain strategies, the Firm believes that the understanding offered by renowned academics is a valuable input to the investment process, and one that can provide differentiation and reinforce a long-term perspective. Accordingly, the Firm seeks to develop relationships with, and build access to, individuals and institutions of global distinction. The Firm seeks to ensure that each investment is consistent with the relevant Advisory Client’s requirements for prudent risk management which are set out in the relevant governing documents of the Advisory Client. Risks The descriptions contained below provide a brief overview of certain risks related to the Firm’s investment strategies. They are not intended to serve as an exhaustive list, or a comprehensive description of all risks associated with the investment strategies or specific types of securities described herein. Investors should refer to the relevant governing documents for a more complete understanding of the investment objectives and strategies applicable to their investments. General Investment and Trading Risks; Risk of Loss. All investments present a risk of loss of capital. Supply and demand for securities and other financial instruments can change rapidly and are affected by a variety of factors. Such factors include investment-specific price fluctuations as well as macroeconomic, market and industry-specific conditions, including, but not limited to, national and international economic conditions, domestic and international financial policies and performance, conditions affecting particular investments (such as the results of operations, financial condition, sales and product lines of corporate issuers), national and international politics, governmental events and changes in interest rates and income tax laws. In addition, events such as political instability, terrorism, natural disasters, and regional and global health epidemics may occur. The Firm may have only limited ability to vary its investment portfolio in response to changing economic, financial, investment and other conditions. No guarantee or representation can be made that the Firm's investment program will be successful. The market price of securities and other financial instruments owned by the Advisory Clients may go up or down, sometimes unpredictably, and investment results may vary substantially.

Business Dependent Upon Key Individuals. The success of the Firm’s investing is significantly dependent upon the expertise of members of the Firm’s investment management team and any future unavailability of their services could have an adverse impact on the performance of an investment strategy. Inability to Transact as a Result of Exposure to Material Non-Public Information. From time to time, the Firm may receive material non-public information with respect to an issuer of publicly-traded securities, including in situations where the Firm may have secured the appointment of persons selected by the Firm or other members of the Firm to a portfolio company’s board of directors. This could prohibit the Firm from transacting in the securities of the issuer. This can result in substantial risk of loss or loss of opportunity if the Firm is not able to purchase or sell such securities. Concentration of Investments/Lack of Asset Diversification. The Firm’s investment strategies are subject to certain diversification requirements but may invest a significant portion of its assets in a small number of investments. As a result, an investment strategy may be more susceptible to risks associated with a single economic, political or regulatory occurrence than would be the case with a more diversified portfolio and such investment strategy may be subject to significant losses in the event that it holds a large position in a particular investment that declines in value or is otherwise adversely affected, including by default of the issuer. Investments in Non-listed Securities. The Firm expects to make investments in non-listed enterprises. Comparatively to large public companies, investments in small and middle market companies may be subject to additional risks, including: (i) limited financial resources leading to unmet obligations and missed guarantees in respect of the any investment; (ii) increased vulnerability to competitors and market conditions; (iii) reliance on investment professionals to obtain information about potential returns; (iv) companies’ reliance on key management persons; (v) reduced predictability with regards to operating results; and (vi) companies’ problems in accessing further funding. Non-listed companies may not benefit from the same protections offered to listed companies, and regulations relating to corporate governance and disclosure. Investing in Private Companies. Investments in unlisted companies can be riskier than investments in listed companies as unlisted companies may be smaller, more vulnerable to changes in markets, competition and technology and dependent on the skills of a small investment team. Investments in unlisted companies can be difficult and sometimes impossible to realise. Illiquid Investments. Although investments may generate current income, the return of capital and the realisation of gains, if any, from an investment will most likely occur only upon partial or complete disposal. While an investment may be sold at any time, it is generally expected that the disposal of some of the investments will not occur for several years from the date of first investment by an Advisory Client. Accordingly, the pool of purchasers to whom an Advisory Client may seek to sell its investments may be limited, and the proceeds from such investments may be adversely affected. This may have a knock on impact on an Advisory Client being able to meet any distribution or redemption request. Equity Investments Risk. The prices of equity securities can be more volatile than those of fixed income securities. The prices of equity securities can rise and fall in response to a number of different factors. In particular, equity securities can respond to events that affect entire financial markets or industries (such as changes in inflation or consumer demand) and to events that affect particular issuers (such as news flow and financial reporting). Equity securities also are subject to “stock market risk,” meaning that stock prices in general may decline over short or extended periods of time. When the value of the stocks held

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As described in Item 4, Lingotto provides investment advisory services on a discretionary basis to the Advisory Clients. The Funds are each offered as a private fund to U.S. investors in reliance on the exemption from registration contained in Section 3(c)(1) and/or Section 3(c)(7) of the Investment Company Act of 1940. Each investor in the Funds must meet certain eligibility provisions. U.S. investors in a Fund are typically limited to persons who are “qualified purchasers” as that term is defined in the Investment Company Act of 1940, and “accredited investors” as that term is defined in SEC Rule 501(a) under the Securities Act of 1933. Investors in a Fund may include, but are not limited to, high net worth individuals, family offices, companies, pension funds, life assurance companies, other regulated investment advisers, and state-sponsored funds.

The minimum initial or additional subscription or investment amounts are set forth in the governing documents of the relevant Fund. SMA clients are subject to different terms and fees from the Funds. Such fee arrangements and terms are individually negotiated. SMA relationships are generally subject to significant account minimums, although Lingotto can vary this in its sole discretion. In addition, Lingotto provides investment advisory services on a discretionary basis to pooled investment vehicles that are not offered to U.S. investors. These pooled investment vehicles are not discussed in this Brochure.

As described in Item 5 above, the Firm and its affiliates are entitled to receive performance-based fees in the form of a performance fee or carried interest based on the performance of Advisory Client accounts. Performance Fees/Carried Interest In general, performance fees or carried interest are payable in arrears and subject to the performance of the relevant Fund exceeding a performance hurdle and/or a “high water mark”. Not all classes of a Fund are subject to performance fees/carried interest. The specific terms of the performance fees/carried interest and the classes of a Fund that they relate to are outlined in the relevant Fund’s offering memoranda. The amount of performance fees or carried interest charged, if any, is 20% depending on profits in Fund accounts and depending on the terms of the relevant Fund’s offering memoranda. It should be noted that performance-based fees may create an incentive for the Firm to make investments on behalf of Advisory Clients that are riskier or more speculative than would be the case in the absence of such an arrangement. All current Advisory Clients of Lingotto are, and future advisory clients will be, charged a performance-based fee.

Lingotto is affiliated with Lingotto (US) LLC, a Registered Investment Adviser with the SEC, which is wholly owned by Lingotto. Amongst other activities, Lingotto (US) LLC provides non-discretionary investment services as a sub-adviser to the Innovation Strategy. Please refer to Lingotto (US) LLC Form ADV Brochure for additional details. Delegating services to affiliates presents a conflict of interest between Lingotto and our clients. The Firm has a documented Conflicts of Interest policy to outline the process for mitigating the risk of delegation to both affiliated and non-affiliated entities.

Transactions and Personal Trading Lingotto has adopted a Code of Ethics (“Code”) which, among other things, contains provisions designed to (i) prevent improper personal trading by employees; (ii) prevent improper use of material,

non-public information about securities recommendations made by Lingotto or securities holdings of Advisory Clients and (iii) identify conflicts of interest, including monitoring of gifts and pay-to-play issues that could arise due to political donations by Lingotto or its personnel. The Code sets forth a standard of business conduct that takes into account Lingotto’s status as a fiduciary and requires staff to place the interests of clients above their own interests and the interests of Lingotto. The Code requires staff to comply with applicable federal securities laws. Further, staff are required to promptly bring violations of the Code to the attention of Lingotto’s chief compliance officer. The Code also sets forth certain reporting and pre-clearance requirements with respect to personal trading by staff. All staff are provided with a copy of the Code and are required to acknowledge receipt of the Code upon hire and on at least an annual basis thereafter. A copy of Lingotto’s Code of Ethics will be provided to any investor or client, prospective investor or client, upon request. Additionally, employees of Lingotto and affiliates of Lingotto, including other entities owned by Exor N.V., invest in Funds. Such investments may represent all of or a significant percentage of a Fund’s assets. This creates a potential for conflicts between the interests of Lingotto employees and affiliates on the one hand, and other investors in a relevant Fund and other Advisory Clients on the other hand. To address conflicts of interest, it is Lingotto’s policy that such Funds should receive neither special advantages nor disadvantages. Funds are managed in a manner consistent with Lingotto’s duty to all Fund investors and all of its Advisory Clients. Furthermore, Lingotto provides investment advice to investment accounts in which the primary investor is Exor N.V. These “proprietary” accounts invest in certain investments that other Advisory Client accounts also invest in. This creates a potential for conflicts between the interests of the Advisory Clients and the interests of the proprietary accounts when Lingotto personnel make decisions on allocating investment opportunities between the accounts of Advisory Clients and the proprietary accounts. Lingotto’s policy is that the proprietary accounts should receive neither special advantages nor disadvantages. Additionally, the Firm has implemented policy for allocating investment opportunities as summarized in the Aggregated Trades section of Item 12, below. Client Transactions Certain Lingotto personnel may from time-to-time invest in the same investments that Lingotto directs an Advisory Client to invest in. In addition, certain of such personnel have ownership in and serve as a member of the board of directors (or equivalent) of an investment adviser that is unaffiliated with Lingotto, and where such investment adviser may from time-to-time invest in the same investments that Lingotto directs an Advisory Client to invest in and in which Lingotto personnel may also invest. This investment activity of the unaffiliated investment adviser and of the relevant Lingotto personnel gives rise to the potential for conflicts between the interests of such parties and the interests of Advisory Clients. To mitigate potential conflicts of interest, Lingotto regularly reviews accounts under management to ensure that such accounts are invested consistently with Advisory Clients’ mandates and the Firm’s disclosures. Moreover, as summarized in the Aggregated Trades section of Item 12, below, Lingotto’s policy is to allocate investment opportunities in a manner that is fair to all Advisory Clients. Additionally, the personal investment activity and outside business activity of Lingotto personnel is governed by a policy in the Firm’s Code of Ethics. With respect to the activities of Lingotto personnel in connection with the unaffiliated investment adviser, Lingotto carefully monitors for potential conflicts of interest,

including potential overlapping investment positions, in order to identify any transactions that may give rise to a potential conflict of interest. Lingotto will conduct further diligence and implement further measures where appropriate, including discussion of potential conflicts with such unaffiliated investment adviser and recusal of investment personnel in certain situations to ensure that no Advisory Client is adversely impacted in connection with any such transaction in which the unaffiliated investment adviser may invest or decline to invest on behalf of its clients.

Lingotto has complete discretion in deciding which financial instruments are bought and sold, the amount and price of those financial instruments, the brokers or dealers to be used for a particular transaction, and commissions or markups and markdowns paid. Soft Dollar Benefits The Firm does not have any formal or informal soft-dollar arrangements and does not receive any soft dollar benefits from any broker, dealer, or other counterparty. To the extent that the Firm purchases investment research, it does so consistent with guidance issued by the SEC. Best Execution Reviews Portfolio transactions will be allocated to brokers and dealers on the basis of numerous factors and not necessarily the lowest pricing. The Firm has adopted an order execution policy and arrangements with a view to obtaining the best possible result for its clients taking into consideration the relevant “execution factors”, including price, costs, speed, likelihood of execution and settlement, order size, nature of transaction, venue, or other considerations relevant to the execution of a particular transaction. Brokers and dealers may provide other services that are beneficial to the Firm and/or certain Advisory Clients, but not beneficial to all Advisory Clients. Subject to its best execution obligations in selecting brokers and dealers (including prime brokers) to execute transactions, provide financing and securities on loan, hold cash and short balances and provide other services, the Firm may consider, among other factors that are deemed appropriate under the circumstances, the following: the ability of the brokers and dealers to effect the transaction; the brokers’ or dealers’ facilities, reliability and financial responsibility; the provision by the brokers of capital introduction, talent introduction, marketing assistance, consulting with respect to technology, operations, equipment and commitment of capital and access to company management and access to deal flow. Lingotto maintains policies and procedures to review the quality of executions, including quarterly reviews by the Firm’s management. Some investment transactions will be privately negotiated by the Firm and, in such instances, this policy will not be relevant. Brokerage for Client Referrals Lingotto may from time to time receive client referrals from a broker dealer or third party. As a result, and subject to best execution, the Firm may consider, among other things, capital introduction and marketing assistance with respect to investors in the Funds in selecting or recommending broker-dealers for the Funds. Directed Brokerage

Lingotto does not recommend, request or require that a client direct the Firm to execute transactions through a specified broker-dealer. Aggregated Trades Lingotto will only aggregate a client order with an order of another client where it can be reasonably expected that the aggregation of orders will not work overall to the disadvantage of any client, and it has been disclosed to each client involved that the effect of the aggregation may work to their disadvantage. The Firm’s portfolio managers will consider the applicability of the transaction to each of the Firm’s clients. The factors to be considered by the portfolio managers are the investment objectives, policy and investment restrictions applicable to each client including: liquidity of the investment, funding facilities and liquidity facilities available to the client, diversification requirements, size of the client, size of investment, risk profile of funding and portfolio building strategy for any Account. The Firm recognizes that by aggregating orders an Advisory Client may be able to benefit from a better trade price, lower transaction costs or overall better transaction terms achieved through larger, bulk transactions. Aggregation of Advisory Client orders generally only occurs when initiated with the same set of execution instructions, through the same order execution venue at the same time and on the same day. In such instances where it is the same venue, the broker would be informed, and any order that is aggregated for execution will be allocated according to the Firm’s allocation policy. However, trades may not be aggregated if an Advisory Client mandate restrictions prevent the Firm from doing so. Aggregated trades will be allocated on a basis believed to be fair and equitable, and in accordance with the Firm’s allocation policy; it is Firm policy that no participating Advisory Client will receive preferential treatment over any other. The Firm will strive to ensure that no participating Advisory Client will be systematically disadvantaged by the aggregation, placement or allocation of trades. When placing aggregated orders, the Firm will ensure that each execution is allocated across the identified group of Advisory Clients at the time the order is placed and in accordance with the Firm’s allocation policy. When an aggregated order is filled through multiple trades at different prices on the same day, each participating Advisory Client will receive the average price, with transaction costs generally allocated pro rata based on the size of each Advisory Client’s participation in the order (or allocation in the event of a partial fill) as determined by the Firm. There may be occasions when it is not suitable for one or more Advisory Clients to participate on the same basis or to participate at all in aggregated transactions. In such circumstances, the portfolio manager will consider the applicability of the transaction to each of the Advisory Clients. The factors to be considered by the Firm as to whether or not to aggregate an order, in addition to the investment objectives, policy and investment restrictions applicable to each Advisory Client include: liquidity of the investment, funding facilities and liquidity facilities available to the Advisory Client, diversification requirements, size of the Advisory Client, size of investment, risk profile of funding and portfolio building strategy for any new Advisory Client account. Trade Errors In the event that the Firm experiences an error with respect to trades made on behalf of the Advisory Clients, the Firm will correct such error in accordance with its policies and procedures. Trade errors are unintentional mistakes which occur during the execution phase of trading and result in the placing of a different trade to one that was instructed. Any gains resulting from trade errors will be retained by the

Advisory Clients. Any losses resulting from trade errors will be paid by Advisory Clients, unless in cases of gross negligence, in which case, Lingotto will be responsible for the loss associated. To the extent that a trade error is caused by a counterparty of the Advisory Clients, such as a broker or agent, the Firm will seek to recover any related trade error losses from such counterparty.

Lingotto has not engaged any third parties to solicit clients or investors into the Fund. Similarly, Lingotto does not receive any compensation from any third parties for referrals of clients or investors, or any other business activities.

Lingotto does not have any reportable legal or disciplinary events.

Lingotto reviews the Advisory Clients’ investments on an ongoing basis. Such reviews are conducted in the ordinary course by the members of Lingotto’s investment and compliance teams. A review of an Advisory Client account may also be triggered by any unusual activity or special circumstances.

The cash and securities of the Advisory Clients are held by third party custodians and Lingotto does not have direct custody of such cash or securities. However, Lingotto is deemed to have constructive custody of certain of the Funds because an affiliate acts as general partner of the Fund. Accordingly, where applicable, the Firm will comply with the “audit exception” to the SEC’s custody rule and deliver audited financial statements to investors within 120 days of the funds’ fiscal year end.

Lingotto has discretionary authority to manage the investment activities of the Advisory Clients, as set forth in the governing documents and/or investment management agreement of each Advisory Client. Investment advisory services are provided directly to the Advisory Clients, and, in the case of the Funds, not to the Funds’ underlying investors. Investors in the Funds do not have the ability to impose limitations on Lingotto’s discretionary authority.

Lingotto has adopted Proxy Voting Policies and Procedures (the “Proxy Policy”) to address how it will vote proxies, as applicable, for the Advisory Clients’ portfolio investments. The Proxy Policy seeks to ensure that Lingotto votes proxies in the best interest of the Advisory Clients, including where there may be material conflicts of interest in voting proxies. In the event a conflict of interest is identified and deemed to be material, Lingotto will generally seek to mitigate the conflict by voting in accordance with

the recommendation of another independent third party, disclosing the conflict to affected Investors, or abstain from voting. Lingotto’s proxy voting procedures and voting records are available upon request to Lingotto’s Chief Compliance Officer. Contact information has been provided on the cover page of this Brochure.

Lingotto has never filed for bankruptcy and is not aware of any financial condition that is expected to impact clients or investors.