Medalist Partners LP

Medalist is an alternative investment management firm headquartered in New York City focused on asset-based private credit and structured credit. Prior to the formation of Medalist in May 2018, certain senior members of the Medalist investment team have worked together dating back to 2000, initially for certain wholly-owned subsidiaries of Credit Suisse Group AG and thereafter with Candlewood Investment Group, LP. Medalist was formed as a Delaware limited liability company in 2017 and converted to a Delaware limited partnership in 2018. The principal owners and partners of Medalist are Gregory Richter, Michael Ardisson, James Buccola and John Slonieski. Gregory Richter is also the managing member of Medalist Partners General LLC, the general partner of Medalist. Medalist commenced operations on May 1, 2018. Medalist provides investment management services to private pooled investment vehicles, including private funds and real estate investment trusts (“REITs”)(collectively, the “Medalist Funds”) that are offered to investors on a private placement basis, to regulated investment vehicles, including investment companies registered under the Investment Company Act of 1940 (“Investment Company Act”) (each a “RIC”), and to other institutional managed account clients, including pension funds (each an “SMA” and, together with the RIC clients, collectively, the “Institutional Clients”) . The RICs advised by Medalist include Medalist Partners MBS Total Return Fund and Medalist Partners Short Duration Fund (both a series of Advisers Series Trust). The private investment vehicles Medalist advises generally are structured as Delaware limited partnerships, Delaware limited liability companies, Maryland statutory trusts, Cayman Islands exempted limited partnerships and Cayman Islands exempted companies. Generally, Medalist is appointed as an investment manager with discretionary trading authorization in connection with the investment management services it provides to the Medalist Funds. Medalist generally provides discretionary investment management services. Medalist Partners Opportunity II, LLC, Medalist Partners Private Credit III GP LLC, and Medalist Partners Private Credit IV GP, LLC (collectively, the “Relying Advisers”) are each a related adviser of Medalist under Rule 203A-2(b) and, furthermore, are disclosed as relying advisers of Medalist on Schedule R of Part 1A of this Form ADV. The Relying Advisers each serves as a general partner and trustee to certain Medalist Funds (including certain REITs). The Relying Advisers have each delegated day-to-day management of the Medalist Funds for which it serves as a general partner or trustee to Medalist. Accordingly, the operational disclosures and risks set forth herein with respect to Medalist also generally apply to the Relying Advisers. Medalist employs multiple strategies on behalf of its clients, including, but not limited to, structured credit, asset finance, current income, opportunistic credit, and specialty lending strategies. Such strategies involve various liquidity profiles, including liquidity only upon realization events or semi-annual, quarterly or daily liquidity. Medalist has also sponsored coinvestment vehicles to make specific investments. The Medalist Funds maintain certain individual position and industry limits, calculated at the time investments are made, based on aggregate net asset value.

Investors and prospective investors in each Medalist Fund or RIC fund (collectively, the “Client Funds”) should refer to the confidential private placement memorandum, offering documents, limited partnership agreement and/or memorandum and articles of association and other governing documents for the respective Medalist Fund -or RIC fund (the “Governing Documents”) for more complete information on the investment objectives and investment restrictions with respect to a particular Client Fund. There is no assurance that any of the Client Funds’ investment objectives will be achieved. As of December 31, 2025, Medalist managed regulatory assets under management of approximately $2,442,898,897 on a discretionary basis and $0 on a non-discretionary basis.

Compensation and Fee Schedules The fees applicable to each Client Fund are set forth in detail in each Client Fund’s Governing Documents. The fees applicable to an SMA client are set forth in the investment management agreement for that client. A brief summary of those fees is provided below. Investors in the Medalist Funds and Institutional Clients generally pay a management fee to Medalist (the “Management Fee”) on a monthly or quarterly basis, either in arrears or advance, equal to an annual rate of up to 1.75% of net assets or drawn capital, depending on the particular Institutional Client. Generally, at the end of each fiscal year, each investor in any Medalist Fund (but not RIC) that is an open-end vehicle also pays an annual performance allocation to an affiliate of Medalist, equal to 10% to 20% of the amount by which the net value of each account as of the end of each calendar year exceeds the net value of the account as of the beginning of the year, subject to a “high water mark” (the “Incentive Allocation”). In addition, under the Governing Documents of each Medalist Fund that is a closed-end vehicle, generally an affiliate of Medalist will receive a performance based allocation calculated and charged based on a percentage of such Medalist Fund’s realized capital gains (the “Carried Interest”). Generally, with respect to the Medalist closed-end vehicles, the Carried Interest payable to Medalist is 20% of profits subject to a specified preferred return. Medalist (or its affiliates) may, in its sole discretion, reduce, waive or calculate differently the Management Fee, the Incentive Allocation or the Carried Interest with respect to certain clients or investors, including members, partners, directors, officers, affiliates or employees of Medalist, its affiliates or the Medalist Funds, or such person’s family members and trusts or other entities established for the benefit of such person or his or her family. Medalist has agreed to waive and/or reimburse management fees of Medalist Partners MBS Total Return Fund and Medalist Partners Short Duration Fund to limit total annual operating expenses. Such waivers or reimbursements may be terminated or modified with approval of the Board of Trustees, Advisers Series Trust. Each fund may be obligated to repay to Medalist such fees waived or reimbursed in following years should such fund’s expense ratio fall below agreed upon maximums.

Medalist may enter into “side letters” or similar agreements with certain investors in the Medalist Funds, granting such investors specific rights, benefits, or privileges that are not made available to investors generally. Certain Medalist Funds have, on a limited basis, entered into side letters related to certain regulatory and social responsibility obligations affecting such investors or providing certain other rights related to such investor’s investment, including but not limited to, more favorable terms relating to fees and liquidity. Deduction of Fees Medalist is authorized under the Governing Documents to charge and deduct advisory fees directly from the assets of the Medalist Funds, at the times and in the amounts described above. Medalist also receives advisory fees from certain clients, as specified in the relevant investment management agreement governing such relationship.

Other Fees and Expenses In addition to the fees payable to Medalist, the Medalist Funds pay for all costs and expenses incurred in connection with the investments in their accounts, including (but not limited to) brokerage commissions, clearing and settlement charges, custodial fees, interest expenses, expenses relating to consultants, attorneys, brokers or other professionals or advisers who provide research, advice, proxy voting services or due diligence services with regard to investments, research related expenses, appraisal fees and expenses, investment banking expenses, costs related to transactions that are not completed, portfolio valuation and pricing services, other legal expenses, costs of preparing required regulatory filings directly related to the Medalist Fund, the offering of the interests and other offering and solicitation regulatory regimes, including any fees and expenses relating to anti-money laundering and Cayman Islands economic substance requirements, and Regulation D under the Securities Act of 1933, as amended (the “Securities Act”)) and/or specific portfolio investments (including, without limitation, offering and regulatory expenses related to compliance with the Alternative Investment Fund Managers Directive, Form D and Form BE-13, and other offering and solicitation regulatory regimes, including any fees and expenses relating to implementing and monitoring of anti-money laundering requirements, antibribery, environment, social justice and corporate governance (ESG), cybersecurity and privacy policies), fees and expenses of any advisory committee, costs and expenses of forming and operating any holding company or alternative vehicle (including administration costs), costs associated with compliance with the General Data Protection Regulation and the California Consumer Privacy Act of 2018, any expenses associated with FATCA registration and compliance, including with any intergovernmental agreements relating to automatic tax information exchange, accounting, audit, tax preparation and other tax related expenses, entitylevel taxes and registration fees, expenses related to obtaining insurance for the directors and officers of the relevant Medalist Fund or its general partner, organizational and offering expenses, administration fees and related costs (including the fees of any third party provider of middle office functions), and the costs and expenses of any services provided by Medalist or an affiliate that would otherwise be performed by third parties and are permitted to be charged as expenses under the Governing Documents of such Medalist Fund, as described in greater detail in the Governing Documents for each Medalist Fund.

The section below titled “Brokerage Practices” describes the factors Medalist considers in selecting or recommending broker-dealers and determining the reasonableness of their compensation. Transaction-Based Compensation Neither Medalist nor its supervised persons receives any compensation with respect to the purchase or sale of securities or other investment products by any client, including any Medalist Fund that is not otherwise set off against the Management Fee or otherwise disclosed in the Governing Documents for a particular Medalist Fund. The foregoing compensation could create an incentive for Medalist to manage client investments in a manner that could increase the risk of loss.

Methods of Analysis Investments and potential investments are typically analyzed by Medalist using fundamental, cyclical and technical analysis, among other methods. The investment strategies employed by Medalist include, but are not limited to, investing in distressed asset-backed securities and structured credit strategies, as described below: Structured Credit: Medalist, on behalf of one or more of the Medalist Funds or Institutional Clients, conducts an in-depth credit review process, to understand the timing and probability of a security’s cash flows coupled with the unique characteristics of each credit structure. Medalist may invest in a broad range of instruments, including securities backed by residential mortgages, credit card loans, automobile loans, transportation finance loans, collateralized debt obligations, structured investment vehicles, derivative instruments, small balance commercial loans, aircraft operating leases, consumer receivables (e.g., student loans and small balance personal loans), insurance-linked products, tax liens and other asset-backed securities. Asset Based Loans and Leases: Medalist, on behalf of one or more Medalist Funds or Institutional Clients, may invest in and/or originate loan and debt positions in asset classes such as commercial and residential mortgage bridge lending, small ticket equipment, aircraft, auto and consumer finance, small balance commercial mortgages, Small Business Administration (SBA) lending, and other niche asset-based lending markets. Distressed Asset-Backed Securities: Medalist, on behalf of one or more of the Medalist Funds or Institutional Clients, may invest in the debt of collateralized debt obligations and structured

investment vehicles trading at a discount to their underlying collateral value. In select situations, Medalist may take an active role in facilitating the liquidation of the underlying collateral. Medalist, on behalf of one or more of the Medalist Funds or Institutional Clients, may also selectively invest directly in the securitized debt of small business loans, equipment leasing receivables, automobile loans, residential mortgages, commercial mortgages, student loans and other asset-backed securities. These descriptions of specific strategies that are or may be engaged in by Medalist on behalf of its clients are a summary only. Under the Governing Documents of each Client Fund (and the investment management agreements with respect to other clients, including the SMAs), Medalist has broad discretion to employ investment strategies not described above that Medalist may, from time to time, consider appropriate. Medalist’s principal sources of information regarding specific investments include quarterly and annual reports, offering materials, personal interviews with directors and officers of such entities, visits to such entities, SEC filings (if available), general industry knowledge, and research materials prepared by others. The investment programs of the Client Funds and other clients of Medalist are speculative and entail substantial risks. There can be no assurance that Medalist’s investment objectives will be achieved. Accordingly, Medalist’s investment strategies could result in substantial losses to its clients under certain circumstances. Material Risks Although investments in the Client Funds may result in significant returns to the clients of Medalist, they also involve a substantial degree of risk. Medalist generally accepts only clients that are able to bear the financial risk of the investment strategy for an indefinite period of time and are able to sustain the loss of all or a significant part of their investment. Prospective investors in the Client Funds should carefully review the risks described in the Governing Documents for the relevant fund, and should evaluate the merits and risks of an investment in the context of their overall financial circumstances. The risk factors below are not intended to be exhaustive and should be considered carefully by prospective investors together with the full text of the applicable Governing Document or client agreement. Illiquid Investments. Medalist, on behalf of one or more of the Medalist Funds or Institutional Clients, may invest in securities and other assets that are subject to legal or other restrictions on transfer or for which no liquid market exists. The market prices, if any, for such investments tend to be volatile and may not be readily ascertainable, and Medalist, on behalf of such Medalist Fund or Institutional Client , may not be able to sell them when it desires to do so or to realize what it perceives to be their fair value in the event of a sale. The sale of restricted and illiquid assets often requires more time and results in higher brokerage charges or dealer discounts and other selling expenses than does the sale of assets eligible for trading on national securities exchanges or in the over-the-counter markets. Such Medalist Fund Institutional Client may not be able to readily dispose of such illiquid investments and, in some cases, may be contractually prohibited from disposing of such investments for a specified period of time. Thus, there can be no assurance as to

the timing and amount of distributions from certain Medalist Funds or Institutional Clients and any distribution that would require either an in kind distribution or a forced sale of illiquid investments at a price deemed unattractive by Medalist may occur. Restricted assets may sell at a price lower than similar assets that are not subject to restrictions on resale. Competition and Supply for Investments. Medalist’s success in investing will depend, in part, on its ability to obtain investments on advantageous terms. In purchasing investments, the Medalist Funds and Institutional Clients will compete with a broad spectrum of investors and institutions. Increased competition for, or a diminution in the available supply of, investments which meet a Medalist Fund’s or Institutional Client’s investment objectives could result in lower yields on such investments, which could reduce returns to investors. In addition, there can be no assurance that a Medalist Fund or Institutional Client will be able to fully invest its available capital. Uncertain Exit Strategies. Due to the illiquid nature of some or all of the positions which the Medalist Funds or Institutional Client may acquire, Medalist is unable to predict with confidence what the exit strategy will ultimately be for any given position, or that one will definitely be available. Exit strategies which appear to be viable when an investment is initiated may be precluded by the time the investment is ready to be realized, due to economic, legal, political or other factors. Public Health Risk. The operations of Medalist, its clients (including the Medalist Funds and Institutional Clients), and their portfolio investments may be adversely affected by outbreaks of infectious diseases, pandemics or other public health emergencies. Such events may lead to supply chain disruptions, labor shortages, inflationary pressures, changes in consumer behavior, and volatility in financial markets. Governmental responses, including travel restrictions, quarantines, vaccination mandates or other public health measures, may further impact economic activity and the operations of portfolio companies, counterparties and service providers. The timing, severity and duration of any such events are inherently uncertain, and their effects may be material and adverse to the performance and liquidity of investments. In addition, the risks associated with a widespread outbreak of a high-risk contagious disease, may make it more likely that limited partners and shareholders of the Medalist Funds /Institutional Clients fail to fund their subscription obligations or other payments when due, in which case Medalist’s ability to complete its investment strategy or otherwise continue operations may be impaired. Geopolitical Conflict Risk. Ongoing and potential future geopolitical conflicts, including the conflict between Russia and Ukraine and tensions and hostilities in the Middle East (including those involving Israel, Hamas, Iran and other regional actors), have contributed to, and may continue to contribute to, global economic and market instability. Such conflicts may result in increased volatility in financial markets, disruptions to global energy supplies and trade routes (including key maritime shipping lanes), supply chain interruptions, inflationary pressures and reduced investor confidence.

In addition, governments and international bodies have imposed, and may in the future impose, economic sanctions, export controls, trade restrictions and other measures in response to geopolitical developments. These actions may adversely affect issuers, counterparties and financial institutions globally, including those in which Medalist’s clients invest or with which

Medalist transacts, and may limit investment opportunities or require the modification or liquidation of existing investments. The scope, duration and potential escalation of geopolitical conflicts are inherently uncertain and may include the expansion of hostilities to additional countries or regions, as well as retaliatory or asymmetric actions (including cyberattacks). Any such developments could have a material adverse effect on global financial markets and the performance and liquidity of certain investments. Market Disruptions and Government Intervention. The global financial markets have gone through a series of disruptions in recent years, including inflationary pressures, the collapse of cryptocurrency market participants, and the failure or near-failure of a number of banking institutions. Such disruptions may lead to government intervention, including intervention implemented on an emergency basis. Sudden or substantial government intervention in the financial markets could affect Medalist’s ability to continue to implement certain strategies or manage the risk of its outstanding positions. In addition, prior government interventions in the financial markets have at times been unclear in scope and application, resulting in confusion and uncertainty which in itself has been materially detrimental to the efficient functioning of the markets as well as previously successful investment strategies. The Medalist Funds/Institutional Clients may incur major losses in the event of disrupted markets and other extraordinary events in which historical pricing relationships become materially distorted. The risk of loss from pricing distortions is compounded by the fact that in disrupted markets many positions become illiquid, making it difficult or impossible to close out positions against which the markets are moving. Financing available to the Medalist from its banks, dealers and other counterparties is typically reduced in disrupted markets. Such a reduction may result in substantial losses. Market disruptions may from time to time cause dramatic losses for the Medalist /Institutional Clients, and such events can result in otherwise historically low-risk strategies performing with unprecedented volatility and risk. Moreover, continued market disruptions could magnify other risks set forth herein. Global Investments and Investments in Emerging Markets. Medalist, on behalf of one or more of the Medalist Funds /Institutional Clients, may invest in securities and obligations denominated in foreign currencies and/or traded outside the United States. Investing in the securities and obligations in non-U.S. countries involves certain considerations not usually associated with investing in securities and obligations in U.S. markets, including: political and economic considerations, such as greater risks of expropriation and nationalization, confiscatory taxation, the potential difficulty of repatriating funds, general social, political and economic instability and adverse diplomatic developments; the possibility of imposition of withholding or other taxes on dividends, interest, capital gains or other income; the small size of the securities markets in such countries and the low volume of trading, resulting in potential lack of liquidity and in price volatility; fluctuations in the rate of exchange between currencies and costs associated with currency conversion; and certain government policies that may restrict Medalist’s investment opportunities. In addition, accounting and financial reporting standards in such countries may not be equivalent to U.S. standards and, consequently, less information may be available to investors in securities and obligations issued in such countries than is available to investors located in the United States.

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Types of Clients Medalist provides advice to pooled investment vehicles, including the Clients Funds, and managed account clients, including the SMAs. The limited partners and shareholders of the Client Funds may include corporations, endowments, foundations, trusts, estates, individuals and pension and profit sharing plans. The Medalist Funds are offered in the United States to accredited investors as defined under Regulation D under the Securities Act, and to qualified purchasers as defined under Section 2(a)(51) of the Investment Company Act of 1940, as amended (the “Investment Company Act”), and are therefore not required to register as investment companies under the Investment Company Act in reliance upon the exception under Section 3(c)(7) for funds whose securities are not publicly offered. Certain Medalist Funds, such as those structured as REITs, may rely on other exceptions under the Investment Company Act. Medalist advises the SMAs and may in the future provide investment management and supervisory services to other separate account clients from time to time. Certain of Medalist’s separate account clients may invest in existing or future Client Funds.

Minimum Investment Requirements As noted above, Medalist and its related persons generally require that each investor in each of the Medalist Funds be an “accredited investor” as defined in Regulation D under the Securities Act and a “qualified purchaser” as defined in Section 2(a)(51) of the Investment Company Act. Investors in the Medalist Funds are generally required to make a minimum initial investment of $5 million or such other amount as may be set forth in the Governing Documents of such Medalist Fund, although Medalist may accept lower amounts in its (or the relevant general partner’s) discretion. Certain of the Medalist Funds have a defined term, but investors in the open-ended Medalist Funds are also generally subject to a soft lock-up period of one year after investment, which lock-up may be waived or reduced by Medalist, the relevant board of directors or the relevant general partner in its discretion. Medalist Partners MBS Total Return Fund and Medalist Partners Short Duration Fund are openend mutual funds available for investment by all investors. Minimum investment amounts are set forth in the relevant fund offering materials. Minimum portfolio amounts for individualized account services are negotiated with the Client and depend on investment strategy, investment guidelines, account size, services provided, among other factors.

Performance-Based Fees A related person of Medalist (generally acting as general partner or managing member of certain Medalist Funds), may receive either an annual special allocation of profits as of the end of each calendar year calculated and charged based on a share of the net appreciation of the assets of such Medalist Funds during such year or an allocation of a percentage of profits attributable to realized capital gains. Please refer to the Governing Documents of each Medalist Fund for more complete information on the performance-based compensation arrangements of each Medalist Fund. Different client accounts may be subject to different performance-based compensation arrangements. The performance-based allocation arrangements discussed above comply with Rule 205-3 under the Investment Advisers Act of 1940 (the “Advisers Act”). Performance-based allocation arrangements received may create an incentive for Medalist to recommend investments that may be riskier or more speculative than those that would be recommended under a different fee arrangement. Side-by-Side Management Medalist may provide concurrent advisory services to clients that are not charged a performancebased fee or allocation, or are charged a lower fee, at the same time as it provides services to clients that are charged a higher performance-based fee or allocation. The potential for Medalist to receive greater fees or allocations from performance-based accounts, or accounts paying higher fees, may create a potential conflict of interest with respect to the allocation of investment opportunities, as Medalist may have an incentive to direct the best investment ideas to, or to allocate investments in favor of, the account that pays a higher performance fee or allocation. To alleviate potential conflicts of interest, the allocation of commitments and investment decisions with respect to each Medalist Fund are made by Medalist in accordance with Medalist’s investment allocation policy, considering all factors potentially applicable to each client. Among the factors that may be considered by Medalist in allocating trades among client accounts are: investment policies, guidelines or

restrictions applicable to each specific client; tax considerations; cash availability; liquidity requirements for payment of redemptions or other purposes; risk tolerances; restrictions under the Employee Retirement Income Security Act of 1974 or other applicable laws or regulations; available credit lines; counterparty exposure; account size; industry and security weightings; and hedging objectives and activity. In the event investment opportunities are suitable for more than one Medalist client, Medalist will allocate such investment opportunities in accordance with its allocation policy in effect from time to time, which provides that such allocation be fair and equitable to each account over time, taking into account all relevant facts and circumstances. Medalist’s allocation policy is reviewed periodically and subject to change. Medalist allocates expenses among participating accounts in proportion to their respective net asset values or in such other manner that it determines to be equitable. Medalist or its affiliates manage the SMAs and may in the future manage other separate managed accounts or dedicated investment vehicles for institutional investors that pursue strategies similar to, or that overlap with, those of other Client Funds. These clients may have access to detailed information about their accounts, including current portfolio holdings, which Medalist does not customarily make available to investors in the Client Funds or other pooled investment vehicles. Such clients may be able to take action, including more timely action, with respect to their accounts that investors in pooled vehicles with similar or parallel strategies cannot take. Medalist and its affiliates may purchase on behalf of clients, different classes of debt and/or equity of the same borrower or issuer. These and other investments may be deemed to create a conflict of interest. Medalist may be required to take certain actions for some clients with respect to one class of debt or equity that may be adverse to other clients who hold other classes of debt or equity of the same borrower or issuer.

Registered Broker-Dealers None of Medalist or its principals or employees are registered as a broker-dealer or a registered representative of a broker-dealer. Registered Futures Commission Merchants, Commodity Pool Operators and Commodity Trading Advisors None of Medalist or any of its principals or employees are registered as or affiliated with a registered futures commission merchant, commodity pool operator or commodity trading advisor. Relationships with Related Persons As discussed in the section titled “Participation or Interest in Client Transactions; Personal Trading,” Medalist and its related persons are, directly or indirectly, the general partner, trustee, limited partners and/or managing members of the general partner of each of the Medalist Funds. Medalist and its related persons may spend substantially all of their business time on one or more of the Medalist Funds or the Institutional Clients. Employees of Medalist and its affiliates may serve as officers, advisors, directors or in comparable management functions for portfolio companies in which clients of Medalist may invest. Employees or partners of Medalist may also from time to time serve on the board of directors or a creditors committee of a portfolio company, or be given access for other reasons to confidential information relating to companies in which clients of Medalist may invest. As a result, Medalist and the clients of Medalist may, under certain circumstances, be prohibited for a period of time from engaging in transactions with respect to the debt or securities of such a portfolio company, which prohibition may have an adverse effect on clients of Medalist. Selection or Recommendation of Other Advisers Medalist does not recommend or select other investment advisers for its clients or receive compensation from such advisers in a manner that would create a material conflict of interest. Medalist does not have other business relationships with other advisers that create a material conflict of interest.

Trading Code of Ethics Medalist strives to adhere to the highest industry standards of conduct based on principles of professionalism, integrity, honesty and trust. In seeking to meet these standards, Medalist has adopted a Code of Ethics (the “Code”), which is reviewed and updated (if necessary) at least annually. The Code incorporates the following general principles that all employees are expected

to uphold: employees must at all times place the interests of clients first; all personal securities transactions must be conducted in a manner consistent with the Code and any actual or potential conflicts of interest or any abuse of an employee’s position of trust and responsibility must be avoided; employees must not take any inappropriate advantage of their positions; and information concerning the identity of securities and financial circumstances of clients and the Medalist Funds, including investors in the Medalist Funds, must be kept confidential. The Code also places restrictions on personal trades by employees, including requiring that they disclose their personal securities holdings and transactions to Medalist on a periodic basis, and requires that employees pre-clear certain types of personal securities transactions. As part of the Code, Medalist maintains insider trading policies and procedures (the “Insider Trading Policies”) that are designed to prevent the misuse of material, nonpublic information. Medalist’s personnel are required to certify to their compliance with the Code, including the Insider Trading Policies, on at least an annual basis. The Insider Trading Policies prohibit generally Medalist and its personnel from trading for the Medalist Funds or themselves, or recommend trading, in public securities of a company while in possession of material, non-public information (“Inside Information”) about the company, and from disclosing such information to any person not entitled to receive it. By reason of its various activities, Medalist may have access to Inside Information or be restricted from effecting transactions in certain investments that might otherwise have been initiated. Medalist has designed and implemented policies and procedures reasonably designed to closely monitor the access of its investment professionals to Inside Information. Among other things, such policies seek to control and monitor the flow of Inside Information to and within Medalist, as well as to prevent trading public securities based on Inside Information. Notwithstanding such policies and procedures, there may be certain cases where Medalist either may receive Inside Information due to its various activities on behalf of itself or the Medalist Funds or may be restricted in acting for the Medalist Funds. As a result, Medalist may, under certain circumstances, be prohibited for a period of time from engaging in transactions with respect to the debt or securities of such a portfolio company, which prohibition may have an adverse effect on a client or the Medalist Funds. Medalist seeks to minimize those cases whenever possible, consistent with applicable law and our Insider Trading Policies, but there can be no assurance that such efforts will be successful and that such restrictions will not occur. Investors may request the opportunity to review a copy of the Code by contacting Medalist at the address or telephone number listed on the first page of this document. Participation or Interest in Client Transactions; Personal Trading Medalist may cause one or more of its clients to buy securities from, or sell securities to, other clients of Medalist at current market prices, including accounts in which Medalist, its principals or employees are investors or in which such persons may have a financial interest, either directly or indirectly, due to the payment of a performance allocation to Medalist (or an affiliate) by such client. Medalist will only engage in “cross trades” if the sale or purchase is consistent with Medalist’s fiduciary obligations to each client. Cross transactions may include rebalancing transactions that are undertaken so that, after withdrawals or contributions have occurred, the

portfolio compositions of similarly managed accounts remain substantially similar. Medalist has a potentially conflicting division of loyalties and responsibilities regarding both parties to any cross transactions. Where required by applicable law, any such transaction will be approved in advance by the client in accordance with Section 206(3) of the Advisers Act. On occasion, Medalist and its principals and employees may buy and sell securities for themselves that they also recommend to clients. Medalist and its principals and employees are investors in some of the investment funds managed by Medalist. The Code of Ethics contains policies and procedures designed to prevent improper practices with respect to such transactions, and compliance with the Code of Ethics by Medalist, its principals and employees is the primary method employed by Medalist to address the conflicts of interest that arise with respect to these transactions. For example, the principals and employees of Medalist are generally not permitted to execute a personal securities transaction if any client of Medalist has a position in the same security. From time to time, a Medalist Fund or other entity controlled by Medalist may offer to other Medalist Funds or clients participations in and/or assignments or sales of loans (or interests in loans) that such Medalist Fund has originated or purchased. In the event of such an offer, the price for such instrument will be established based on third-party quotations or valuations. The decision by a client of Medalist to accept or reject the offer may be made by a party independent of Medalist, such as the independent directors of such client. In certain situations, related persons of Medalist may purchase interests in portfolio investments held by one or more Medalist Funds. All such purchases are subject to compliance with Medalist’s Code of Ethics as described above. In addition, Medalist and/or certain members or employees of Medalist may, directly or through one or more entities, sell securities in which they have a direct or indirect ownership interest to certain Medalist Funds, provided that the sale is consistent with Medalist’s fiduciary obligations to the Medalist Funds. Such transactions will be fully disclosed in writing, and where required by applicable law, the written consent of the appropriate client will be obtained in accordance with Section 206(3) of the Advisers Act.

Subject to the investment objectives, policies and restrictions of each Client Fund as set forth in such Client Fund’s Governing Documents, Medalist has discretionary authority to determine the type, amount, and price of securities and investments to be bought and sold on behalf of most Client Funds, including the selection of, and commissions paid to, brokers. In selecting broker-dealers to effect securities transactions, Medalist seeks to obtain best execution by considering such factors as price, transaction costs, a broker’s or dealer’s ability to effect the transactions, its facilities, reliability and financial responsibility, commitment of capital and the provision or payment by the broker of the costs of research and research-related services which are of benefit to Medalist or the Client Funds, as well such other factors as Medalist considers relevant and beneficial to the Client Funds. Medalist may consider referrals of Medalist Fund investors in determining its selection of brokers. Accordingly, the commission rates (or dealer markups and markdowns arising in connection with riskless principal transactions) charged to the

Medalist Funds by brokers or dealers in the foregoing circumstances may be higher than those charged by other brokers or dealers that may not offer such services. Research and Other Soft Dollar Benefits Section 28(e) of the Securities Exchange Act of 1934 (the “Exchange Act”) provides a safe harbor that permits advisers, when selecting brokers to execute transactions for client accounts, to take into account certain research products and services provided to the adviser by brokers. Clients may pay higher commissions than are obtainable from other brokers as a result of the consideration of research services as a factor in selecting brokers in addition to commission cost and best execution, provided that Medalist determines in good faith that the amount of commissions charged is reasonable in relation to the value of the brokerage and research services provided by such broker. Research services provided to Medalist by brokers may include written information and analyses concerning specific securities, companies or sectors; market, financial and economic studies and forecasts; statistics and pricing services; and discussions with research personnel. Medalist does not currently engage in any soft dollar arrangements in which Medalist receives third-party services. However, consistent with obtaining best execution for clients, Medalist may in the future engage in such soft dollar arrangements, provided that such arrangements are of the type described in Section 28(e) of the Exchange Act and are designed to augment Medalist’s own internal research and investment strategy capabilities. Receipt of research services from brokers may provide Medalist with a benefit because it will not have to produce or pay for the research, products or services. Medalist may have an incentive to select a broker-dealer based on its interest in receiving the research or other products or services, rather than on a client’s interest in receiving most favorable execution. Research services obtained with the use of commissions arising from portfolio transactions may be used by Medalist in its investment activities for all of its clients, and, therefore, any particular client may or may not, in any particular instance, be the direct or indirect beneficiary of the research or services provided. Subject to the considerations described above, the selection of a broker, including a prime broker, to execute transactions, provide financing and securities on loan, hold cash and short balances and provide other services may be influenced by, among other things, the provision by the broker of the following: capital introduction, marketing assistance and consulting services with respect to technology, operations, commitment of capital, access to company management, and access to deal flow. Generally, neither Medalist nor any client of Medalist (including the Medalist Funds) separately compensates any broker for any of these other services. In view of the fact that the investment programs of Medalist clients include trading as well as investments, short-term market considerations will frequently be involved, and the turnover rate of the portfolios of the Medalist Funds in certain circumstances may be substantially greater than the turnover rates of other types of investment vehicles. Directed Brokerage Medalist does not have any arrangements with any clients that require Medalist to execute transactions through a specified broker-dealer, except that certain sub-advisory clients may from

time to time direct Medalist not to use a particular executing broker-dealer to execute transactions for such client. In the event that Medalist is prohibited from using a specific broker-dealer, the client may pay higher brokerage commissions because Medalist may not be able to aggregate orders to reduce transaction costs, and the client may receive less favorable prices. Trade Aggregation When it is determined that it would be appropriate for any Client Funds to participate in an investment opportunity, Medalist will seek to execute orders for all of the participating investment accounts on an equitable basis, taking into account such factors as the relative amounts of capital available for new investments, relative exposure to short-term market trends and the investment programs and portfolio positions of the applicable Client Funds for which participation is appropriate. However, Medalist has no obligation to obtain any particular investment opportunity for any particular Client Fund, and Medalist may be precluded from offering to certain Medalist Funds particular securities in certain situations, including where Medalist or its affiliates have a prior contractual commitment with other accounts or clients. Orders may be combined for all such accounts, and if any order is not filled at the same price, they may be allocated on an average price basis. Similarly, if an order on behalf of more than one account cannot be fully executed under prevailing market conditions, securities may be allocated among the different accounts on a basis which Medalist or its affiliates considers equitable. There is no assurance that the Client Funds will hold the same investments or perform in a substantially similar manner as other Client Funds with similar strategies.

Economic Benefits Received from Third Parties Medalist is compensated exclusively by its clients and investors for providing investment advice. Third Party Compensation for Client Referrals Medalist or its affiliates have and may enter into arrangements with unaffiliated placement agents or third parties whereby Medalist or its affiliates will pay to third parties who introduce clients or investors in the Medalist Funds to Medalist or its affiliates a portion of the Management Fee received by Medalist or its affiliate from such clients or with respect to such investors’ investment in a Medalist Fund. Any sales charge associated therewith will ultimately be payable by Medalist or its related persons, either directly or through an offset of the Management Fee payable by the relevant client or Medalist Fund to Medalist. Such arrangements will be disclosed to Medalist’s clients in accordance with, and otherwise comply with, Rule 206(4)-3 under the Advisers Act to the extent applicable. Certain third parties may be affiliates of Medalist.

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

Review of Client Accounts Medalist performs various daily, weekly, monthly, quarterly and periodic reviews of the Medalist Funds’ portfolios. Such reviews are conducted by Medalist’s investment professionals. Among other criteria, the portfolios are reviewed in the context of each Medalist Fund’s adherence to the investment objectives and guidelines as set forth in the Governing Documents of each Medalist Fund. Each review is conducted by one or more of the following supervised persons: For all Medalist Funds and Institutional Client accounts:

Supervised Person

Title

Gregory Richter

Chief Executive Officer, Portfolio Manager – Liquid Alternatives and Investment Committee Co-Chair for the Medalist Partners Opportunity Funds / Asset-Based Private Credit Funds

James Buccola

Chief Investment Officer, Portfolio Manager – Liquid Alternatives and Investment Committee Co-Chair for the Medalist Partners Opportunity Funds / Asset-Based Private Credit Funds

John Slonieski

Director of Private Credit and Investment Committee Co-Chair for the Medalist Partners Opportunity Funds / Asset-Based Private Credit Funds

For Institutional Client Accounts:

Supervised Person

Title

Thomas Mandel

Portfolio Manager – Liquid Alternatives

Other Medalist investment or operational professionals may participate in client account reviews from time to time. Reports to Clients Investors in the Medalist Funds receive either monthly or quarterly written reports, although Medalist may provide certain investors with information on a more frequent and detailed basis if agreed to by Medalist. In addition, each Medalist Fund issues tax reports and audited financial statements to investors within 120 days of its fiscal year-end. Investors should refer to the Governing Documents of each Medalist Fund for further information on the reports provided by a particular Medalist Fund to its investors.

Medalist will not have physical custody of any client assets. Medalist may be deemed to have custody of the assets of the Medalist Funds and their subsidiaries as a result of its authority over the Medalist Funds and their subsidiaries.

It is Medalist’s policy to cause each Medalist Fund with assets over which Medalist is deemed to have “custody” to be audited annually and distribute audited financial statements, prepared in accordance with U.S. generally accepted accounting principles, to investors no later than 120 days after the end of each fiscal year. All assets in the accounts of Medalist clients, including the Institutional Clients, will be held by a qualified custodian, except that certain privately offered, uncertificated securities may be recorded on the books of the issuer or its transfer agent in the name of the relevant Medalist Fund or client and are not required to be maintained with a qualified custodian.

Subject to the investment objectives, policies and restrictions of each Client Fund as set forth in the Governing Documents of such fund, or, in the case of a managed account client, the relevant investment management agreement, Medalist generally has discretionary authority to determine the type, amount and price of securities and investments to be bought and sold on behalf of each Medalist Fund or Institutional Client for which it serves as discretionary investment manager, including the selection of, and commissions paid to, broker-dealers. Medalist generally enters into a written investment management agreement with each client granting such discretionary authority.

Because Medalist has, or will accept, authority to vote securities held by a Medalist Fund, it has adopted policies and procedures that have been designed to ensure that Medalist complies with the requirements of Rule 206(4)-6 and Rule 204-2(c)(2) under the Advisers Act, and reflect Medalist’s commitment to vote all client securities for which it exercises voting authority in a manner consistent with the best interest of the client. Medalist’s general policy is to vote proxy proposals, amendments, consents or resolutions relating to client securities (collectively, “proxies”), in a manner that serves the best interests of the Medalist Funds, as determined by Medalist in its discretion, taking into account the following factors: (i) the impact on the value of the investments; (ii) the anticipated associated costs and benefits; (iii) the continued or increased availability of portfolio information; and (iv) industry and business practices. In limited circumstances, Medalist may refrain from voting proxies where Medalist believes that voting would be inappropriate taking into consideration the cost of voting the proxy and the anticipated benefit to the Medalist Funds. Prior to exercising its voting authority, if any, Medalist reviews the relevant facts and determines whether or not a material conflict of interest may arise due to business, personal or family relationships of Medalist, its owners, its employees or its related persons, with persons having an interest in the outcome of the vote. If a material conflict exists, Medalist takes steps to ensure that its voting decision is based on the best interests of the client and is not a product of the conflict. Medalist may, at its discretion, disclose the conflict of interest to the client and defer to the client’s voting recommendation, defer to the voting recommendation of an independent third party provider of proxy voting services, or take any other action which would serve the best interest of the client. Depending on the particular circumstances involved, the appropriate resolution of one conflict of interest may differ from the resolution of another conflict of interest, even though the

general facts underlying both conflicts may be similar or identical. Medalist will deliver to each client upon written request a complete copy of its proxy voting policies and/or information on how it voted proxies for the applicable Medalist Fund.

Not Applicable.