Millstreet Capital Management LLC

Millstreet Capital Management LLC (“Millstreet”, “Investment Manager”, “we”, or “our”) is a Delaware limited liability company formed on March 16, 2010. Millstreet is principally owned by Craig M. Kelleher and Brian D. Connolly, who together control 100% of the voting rights. Jeffrey T. Growney and David T. Danforth are also shareholders of Millstreet. Millstreet provides investment management services to private pooled investment vehicles and separately managed accounts (“SMAs”) for institutional qualified purchasers. Millstreet currently serves as investment manager to Millstreet Credit Fund LP, a Delaware limited partnership organized to operate as a private investment partnership primarily for the benefit of taxable U.S. investors (the “Fund” or the “Partnership”), and Millstreet Credit Offshore Fund Ltd., a Cayman Islands exempted company that operates as a feeder fund for non-U.S. investors and qualified U.S. tax-exempt investors (the “Offshore Fund” and together with Millstreet Credit Fund LP, the “Funds”). The Funds are structured and operate in a “mini-master-feeder” structure, pursuant to which substantially all of the assets of the affiliated feeder fund are invested in the Fund. Millstreet also serves as sub-investment manager to one SMA. Millstreet employs a long/short, fundamental, and value-driven investment strategy with an emphasis on catalysts, as described in the Funds’ respective private placement memorandum. SMA services may be tailored to client-specific objectives and restrictions, which are set forth in applicable investment management agreements and may result in differences from the Funds’ portfolios. SMA clients generally follow the same strategy as the Fund’s core credit portfolio but certain restrictions and other factors may result in differences in investments compared to the Fund (see discussion in “Brokerage Practices” below). Millstreet does not currently participate in any Wrap Fee Programs. As of December 31, 2025, Millstreet had regulatory assets under management of approximately $5,821,270,000. Millstreet does not manage any client assets on a non-discretionary basis.

Millstreet charges its Funds and SMAs a management fee based on the value of client assets under management and may also charge a performance-based fee. Performance-based fees generally consist of a percentage of net profits or increases in net asset value and may be subject to a high-water mark, hurdle rate, and participation rate, as applicable. Investors in the Funds are subject to a management fee and a performance allocation, with only the performance allocation subject to a high-water mark. Investors in the Funds and SMA clients are required to be "qualified purchasers" as defined in Section 2(a)(51)(A) under the Investment Company Act of 1940. Accordingly, Millstreet’s compensation arrangements and specific fee schedules are not disclosed herein. The applicable management fees and performance allocation terms for each Fund and SMA are set forth in the relevant private placement memorandum (“PPM”) or investment management agreement. With respect to the Fund, Millstreet currently receives a management fee paid quarterly in advance based on net assets as of the last business day of the preceding quarter. Management fees are prorated for any period that is less than a full period. Millstreet’s affiliate, Millstreet Capital Partners LLC, the Fund’s general partner (“General Partner”), is allocated a performance allocation annually in arrears for each fiscal year the Fund generates a net profit above the high-water mark. Management fees and any performance allocation are deducted from the Fund’s assets. The Offshore Fund’s investment as a limited partner in the Fund is subject to both a management fee and a performance allocation.

As disclosed in the Funds’ PPM provided to investors prior to investment, the General Partner may, in its sole discretion, waive, reduce or modify management fees or performance allocations for certain investors, provided, that no arrangement results in any other investor bearing a greater share of fees or performance allocation than would otherwise apply. Millstreet does not receive management fees or performance allocations with respect to the General Partner, its affiliates, employees, or their respective relatives. Subject to applicable withdrawal restrictions, investors may generally withdraw capital on a quarterly basis, however, withdrawals attributable to a capital contribution made within the preceding twelve (12) months are subject to a three percent (3%) withdrawal charge. Any such withdrawal charge is allocated pro rata to remaining investors through the Fund’s net asset value, is not retained by the Adviser, applies on a first-in, first-out basis to separate capital contributions, and may be waived by the General Partner in its sole discretion. SMA clients pay Millstreet a management fee quarterly in arrears, calculated based on a daily accrual applied to the daily net asset value of the portfolio, adjusted for any contributions or withdrawals. SMA clients may also pay Millstreet an incentive fee annually in arrears, based on an increase in net asset value or performance accrued daily. Incentive fees for SMAs may be subject to a high-water mark, hurdle rate, and a participation rate, as agreed upon in the applicable investment advisory agreement. SMA fees are agreed upon contractually and are generally invoiced and payable upon receipt. Director’s fees or similar compensation as a result of any of the officers, directors or employees of Millstreet serving as Directors on the board (or similar governing positions) of companies that are in the portfolios of the Fund will either be paid to the Fund or be used to offset any Management Fees payable to the Investment Manager from the Fund on a dollar-for-dollar basis. Such payment or offset shall be determined pro rata based on all advisory clients of the Investment Manager and its affiliates that are invested in such related companies. The Fund pays its expenses, including but not limited to, the management fee; investment expenses (e.g., expenses that the Investment Manager reasonably determines to be related to the investment of the Fund’s assets, such as brokerage commissions, interest and expenses relating to short sales, clearing and settlement charges, custodial fees, bank service fees, interest on margin accounts and other indebtedness, any other expenses related to the purchase and sale of less liquid securities); legal expenses, professional fees (including, without limitation, expenses of consultants, experts and valuation agents) relating to investments; travel expenses, including transportation costs and expenses related to air travel that shall not exceed commercial rates available for first class travel (unless otherwise unavoidable), related to initial due diligence on prospective investments and ongoing due diligence on the Fund’s assets; expenses of agents and other persons providing services to or on behalf of the Fund, including performance reporting and data analytics expenses; governmental and registration fees and taxes; portfolio management system expenses (provided, however, to the extent the Investment Manager uses any such portfolio management system to manage the accounts of clients other than the Fund, the Fund shall be allocated and shall bear only its pro rata share of the associated expenses based on the net assets of all the accounts for which the Investment Manager uses the portfolio management system); fees and expenses for risk management services; insurance expenses, including costs of any liability insurance obtained on behalf of the Fund (including, without limitation, directors and officers insurance); administration fees and expenses (including fees and expenses of the Fund’s Administrator); accounting expenses (including the cost of accounting software packages); auditing and tax preparation expenses; costs of printing and mailing reports and notices; research fees and expenses; taxes; corporate licensing; regulatory expenses (including filing fees and costs related to Form PF); setup expenses for a portfolio accounting system; expenses incurred in connection with the offering and sale of the limited partnership interests (including changes to the offering memorandum and drafting and negotiating supplementary agreements) and other similar expenses related to the Fund; indemnification expenses; fees and expenses relating to services provided in connection with the daily

pricing of investments of the Fund; and extraordinary expenses. Such expenses will be shared on a pro rata basis by all limited partners. The Offshore Fund pays its pro rata portion of the Fund’s expenses allocated to it as a limited partner and also has certain specific costs allocated directly to it, such as audit and taxpreparation fees, director expenses, organizational fees, administration fees, and registered office and other recurring legal fees. Regarding the expenses of the SMAs, all brokerage commissions and fees and clearing and regulatory fees arising from trading or other transactions of each SMA, any margin financing fees, and management fees, in addition to other direct costs, which may include certain legal expenses, associated with the activities of each SMA, are borne by each SMA respectively. The allocation of SMA expenses is stipulated in each investment advisory agreement. All SMA expenses, aside from transaction and brokerage costs, are approved and allocated to each SMA investor and charged by the SMA’s administrator and/or custodian as appropriate. Clients, including the Funds, will incur broker and other transaction costs. Please refer to “Brokerage Practices” for a discussion of brokerage. The Fund has a one-year soft lock-up provision and a twenty-five percent (25%) investor-level gate. Due to the above described provisions, subscriptions in the Fund may not be terminated before the end of a billing period. Each SMA may be terminated by either party upon the required notice established in the investment advisory agreement, and Millstreet will refund any prepaid but unearned fees, calculated based on the number of days that the SMA was in effect for that quarter or month, as applicable.

Millstreet’s strategy seeks to generate attractive absolute returns that are uncorrelated to traditional asset classes over a full market cycle. In order to achieve this objective, we employ a long/short, fundamentally driven, and value-oriented investment strategy with an emphasis on catalysts. We look to opportunistically invest in a diversified portfolio of long and short investments in the more inefficient small-to-mid capitalization segment of the corporate fixed-income market and specifically securities with higher yield characteristics. The emphasis is on out-of-favor and/or overlooked small-to-mid cap U.S. corporate bonds and leveraged loans and securities often characterized by identifiable catalysts/transformational events that we believe provide opportunities to capture excess returns. We attempt to achieve our investment objective by employing our strategy across the entire capital structure of an entity, including but not limited to, bank debt, second lien loans, senior and subordinated bonds, mezzanine debt, convertible bonds, and preferred and common stock. In order to seek to capitalize on perceived fundamental misvaluations and technical dislocations, the strategies employed by Millstreet may include, without limitation, long-only, short-only (including purchases of credit default swaps), relative value, inter- and intra-capital arbitrage, and portfolio hedging strategies. The Fund may purchase securities on margin. Millstreet’s research process is based on top-down and bottom-up fundamental analysis of both long and short investments and an evaluation of the relative merits of each investment. We analyze the many issues that can affect an investment’s relative attractiveness, with a particular focus on the overall quality of a security relative to its perceived value. Investment opportunities are subject to in-depth analysis of company, industry, management, structural, and market factors. Millstreet intends to pursue the methods of analysis and investment strategies described above, although we may also formulate new approaches to carry out our investment objectives. Millstreet and its affiliates generally have broad and flexible investment authority over our portfolios, but investments in client accounts may be subject to restrictions or limitations as to the types or specific characteristics of securities that may be purchased or the types of trades that may be effected for each account. Material Risks for Investment Strategies and Types of Securities: The portfolios managed by Millstreet should be considered speculative investments and are not intended to be complete investment programs. The portfolios are designed only for sophisticated clients who are able to bear the risk of loss of their entire investments. Investors should be aware that they may be required to

bear the financial risks of an investment for an indefinite period of time. The list of risk factors below is not exhaustive, and a more comprehensive list of risks is detailed in the offering materials. Investment and Trading Risks: An investment in the Partnership involves a high degree of risk, including the risk that the entire amount invested may be lost. No guarantee or representation is made that the Partnership’s investment program will be successful. The Investment Manager will be investing substantially all of the Partnership’s assets in securities, some of which may be particularly sensitive to economic, market, industry, regulatory and other variable conditions. The markets in which the Partnership expects to invest have experienced and continue to experience significant volatility and losses. No assurance can be given as to when or whether adverse events might occur that could cause immediate and significant losses to the Partnership. Investments in High Yield and Distressed Securities: The Partnership may invest in high-yield and distressed securities. Such securities are generally not exchange traded and, as a result, these instruments trade in a smaller secondary market than exchangetraded bonds. In addition, the Partnership may invest in credit instruments of issuers that do not have publicly traded equity securities, making it more difficult to hedge the risks associated with such investments. High-yield securities that are below investment grade or unrated face ongoing uncertainties and exposure to adverse business, financial or economic conditions which could lead to the issuer’s inability to meet timely interest and principal payments. The market values of certain of these lower-rated and unrated debt securities tend to reflect individual corporate developments to a greater extent than do higherrated securities, which react primarily to fluctuations in the general level of interest rates and tend to be more sensitive to economic conditions than are higher-rated securities. Companies that issue such securities are often highly leveraged and may not have available to them more traditional methods of financing. It is possible that an economic recession could severely disrupt the market for such securities and may have an adverse impact on the value of such securities. In addition, it is possible that any such economic downturn could adversely affect the ability of the issuers of such securities to repay principal and pay interest thereon and increase the incidence of default of such securities. Such investments involve a substantial degree of risk and could result in substantial losses to the Partnership. The terms and conditions associated with credit instruments, particularly high yield and distressed securities, are often complex and require a sophisticated level of evaluation of financial, operational and legal matters. There is no assurance that the Investment Manager will correctly evaluate the value of a company’s assets, the terms of its debt instruments or the prospects for a successful reorganization or similar action. Investments in these securities require active monitoring and may, at times, require participation in business strategy or reorganization proceedings by the Investment Manager. The involvement by the Investment Manager in an issuer’s reorganization proceedings could result in the imposition of restrictions limiting the Partnership’s ability to liquidate its respective position in the issuer. Undervalued and Overvalued Securities: The Partnership’s investment strategy will focus on investing in companies that the Investment Manager believes are undervalued and overvalued. Opportunities in undervalued equity securities arise from market inefficiencies or due to a lack of wide recognition of the potential impact (positive or negative) that earnings events or trends may have on the value of a security. Opportunities in overvalued securities may arise when a stock’s earnings will be less than analysts’ published consensus, and, therefore, the stock price is expected to drop. Overvaluation may result from an emotional buying spurt, which inflates the stock’s market price, or from a deterioration in a company’s financial strength. The identification of investment opportunities in undervalued and overvalued securities is a difficult task, and there is no assurance that such

opportunities will be successfully recognized or acquired. While investing long in undervalued securities and investing short in overvalued securities present opportunities for above-average capital appreciation, these investments involve a high degree of financial risk and can result in substantial losses. Furthermore, investing in these securities carries additional risk as other managers with similar positions could be forced to unwind and drive security pricing in a manner adverse to the Partnership. General Market and Risks of Credit Obligations: Credit portfolios are subject to credit risk and interest rate risk. “Credit risk” refers to the likelihood that an issuer will default in the payment of principal and/or interest on an instrument. Financial strength and solvency of an issuer are the primary factors influencing credit risk. In addition, inadequacy of collateral or credit enhancement for a debt instrument may affect its credit risk. Credit risk may change over the life of an instrument, and debt obligations which are rated by rating agencies are often reviewed and may be subject to downgrade. “Interest rate risk” refers to the risks associated with market changes in interest rates. Interest rate changes may affect the value of a debt instrument indirectly (especially in the case of fixed rate securities) and directly (especially in the case of instruments whose rates are adjustable). In general, rising interest rates will negatively impact the price of a fixed rate debt instrument and falling interest rates will have a positive effect on price. Adjustable rate instruments also react to interest rate changes in a similar manner although generally to a lesser degree (depending, however, on the characteristics of the reset terms, including the index chosen, frequency of reset and reset caps or floors, among other factors). Interest rate sensitivity is generally more pronounced and less predictable in instruments with uncertain payment or prepayment schedules. Fixed Income and Corporate Debt Securities: The Partnership may invest in investment grade and below investment grade bonds or other fixed income securities of U.S. and non-U.S. issuers, including, without limitation, bonds, notes and debentures issued by corporations, limited partnerships and other similar entities. The Partnership may also invest in debt securities issued or guaranteed by the U.S. government or one of its agencies or instrumentalities, commercial paper and “higher yielding” (and, therefore, higher risk) debt securities of the former categories. These securities may pay fixed, variable or floating rates of interest and may include zero coupon obligations. The value of fixed income securities in which the Partnership invests will change in response to fluctuations in interest rates. In addition, the value of certain fixed-income securities can fluctuate in response to perceptions of creditworthiness, political stability or soundness of economic policies. Fixed income securities are subject to the risk of the issuer’s inability to meet principal and interest payments on its obligations (i.e., credit risk) and are subject to price volatility due to such factors as interest rate sensitivity, market perception of the creditworthiness of the issuer and general market liquidity (i.e., market risk). A major economic recession could disrupt severely the market for such securities and may have an adverse impact on the value of such securities. In addition, any such economic downturn could adversely affect the ability of the issuers of such securities to repay principal and pay interest thereon and increase the incidence of default for such securities. Investments in Bankrupt or Restructured Companies: Certain of the issuers of securities which may be purchased by the Partnership, may be involved in bankruptcy or other reorganization proceedings which involve a substantial degree of risk. Many of the events within a bankruptcy case are adversarial and often beyond the control of the creditors. Accordingly, a bankruptcy court may approve actions that are adverse to the Partnership. Generally, the duration of a bankruptcy case can only be roughly estimated. The process can involve substantial legal, professional and administrative costs to the company and the Partnership; it is subject to

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Millstreet currently provides investment management and administrative services to private pooled investment vehicles and SMAs for institutional investors, which are all qualified purchasers. The minimum investment in the Fund and the Offshore Fund is $1,000,000. Lesser amounts may be accepted at the sole discretion of the General Partner. All investors in the Fund and Offshore Fund must be “qualified purchasers” as defined in Section 2(a)(51) of the Investment Company Act and “accredited investor” as defined under Rule 501 of Regulation D of the Securities Act or “knowledgeable employees” within the meaning of Rule 3c-5 of the Investment Company Act. The minimum amount for an SMA will be at the discretion of Millstreet and will depend on client guidelines regarding strategy and investment restrictions.

Certain clients managed by Millstreet pay both a management fee and a performance allocation or incentive fee to Millstreet or its affiliate, Millstreet Capital Partners LLC (the “General Partner”). Any performance allocation or incentive fee is based on a percentage of the net profits, new trading profits, or increase in net asset value as defined in the offering memorandum or investment advisory agreement and may be subject to parameters, such as a hurdle rate and a high-water mark. The General Partner, in its sole discretion, may waive or reduce or calculate differently the performance allocation and/or management fee for certain limited partners or shareholders of the Funds. No management fee or performance allocation is paid to Millstreet or the General Partner with respect to the account of the General Partner including any limited partnership or shareholder interest owned beneficially by a member or employee of Millstreet or the General Partner, and their respective relatives. The incentive allocation or “performance-based fee” may create an incentive for Millstreet to make investments that are more speculative or riskier than would be the case if there were no performance- based fees. In addition, because the incentive allocation may be based on unrealized gains, Millstreet may have an incentive to value investments in a manner that increases reported performance. Capital appreciation, both realized and unrealized, is a factor in calculating performance-based fees. Millstreet manages accounts and funds that may charge performance-based fees at different rates and which may be subject to different parameters. Any differences in the fee structures of the private pooled investment vehicles and other accounts we manage could create an incentive for Millstreet to favor those clients that pay higher performance-based fees. We have established procedures that seek to ensure that clients paying higher fees do not receive preferential treatment over clients paying lower fees. As a fiduciary, Millstreet recognizes its duty to act in good faith with fairness in all of its dealings with all clients, regardless of fee arrangements. Millstreet generally has discretion to waive or modify the application of any provision of the investment

terms applicable to an investor in the Funds in a "side letter" or in any other manner, without obtaining the consent of any other investor in the Funds. In all cases, any modified provisions are subject always to Millstreet’s fiduciary duty to treat all investors fairly and equitably.

Certain principals and employees of Millstreet serve on the board of directors of portfolio or other companies. Millstreet Co-Founder and Co-Chief Investment Officer Brian Connolly is an independent director of Aware, Inc. and is a member of its Audit Committee and Nominating and Corporate Governance Committee. This directorship is unrelated to Millstreet’s investments and operations, and Mr. Connolly personally receives shares and/or options for this position. Mr. Connolly also serves on the board of directors of Jervois Global. Millstreet Co-Founder and Co-Chief Investment Officer Craig Kelleher currently serves on the boards of Trailblazer Energy Resources, LLC and Jervois Global. In addition, certain members of Millstreet’s investment team serve on the boards of Jervois Global and Tacora Resources Inc. As a result of these board seats, the Fund and SMAs may be restricted from transacting in securities of such issuers. Director’s fees or similar compensation as a result of any of the officers, directors or employees of Millstreet serving as Directors on the board (or similar governing positions) of companies that are in the portfolios of the Fund will either be paid to the Fund or be used to offset any Management Fees payable to the Investment

Manager from the Fund on a dollar-for-dollar basis. Such payment or offset shall be determined pro rata based on all advisory clients of the Investment Manager and its affiliates that are invested in such related companies. The General Partner of the Fund has claimed an exemption from registration as a commodity pool operator under Rule 4.13(a)(3) of the Commodity Exchange Act, and the Adviser has claimed an exemption from registration as a commodity trading advisor under Rule 4.14(a)(8). The General Partner or Adviser may register with the Commodity Futures Trading Commission in the future if required or deemed appropriate. The General Partner is an affiliate of the firm and under common control.

Millstreet has adopted a Code of Ethics (the “Code”) pursuant to Rule 204A-1 under the Advisers Act for its members and employees (collectively, “employees”). In recognition of its fiduciary duty to its clients and the desire to maintain high ethical standards, Millstreet has adopted this Code containing rules for business conduct to help employees avoid potential conflicts of interest that may arise from their actions and their personal investments. Under the Code, Millstreet’s employees must seek pre-approval from the Chief Compliance Officer prior to trading in many types of securities for accounts they, or their immediate family members with whom they share a household, beneficially own or control. In addition to pre-approval, Millstreet’s policies prohibit trading in corporate taxable fixed-income securities (the majority of the assets in client accounts), securities held in accounts managed by Millstreet, and securities which are under consideration for client accounts, among other restrictions. Personal trades are examined for potential conflicts of interest, among other things. Millstreet reviews all transactions submitted and executed by employees in order to identify any possible violations or any pattern of conduct that may evidence a conflict or potential conflict with the principles and objectives of Millstreet’s Code or other inappropriate behavior. Millstreet’s Code is available for review by clients and prospective clients upon request. An affiliate of Millstreet, Millstreet Capital Partners LLC, a Delaware limited liability company, is the General Partner of the Fund, to which Millstreet provides investment management and administrative services. The General Partner maintains capital in the Funds (which may include amounts invested in limited partnership and shareholder interests beneficially owned by Class A members of the General Partner) in an amount equal to at least $1,000,000.

Millstreet has the authority to determine, without specific client consent, the securities to be bought or sold, the amount of securities to be bought or sold, and the broker or brokers with whom to execute each transaction. In choosing the broker-dealer to use for each securities transaction, Millstreet seeks best execution. We are not required to select the broker that charges the lowest transaction cost. We consider several factors in selecting brokers including the financial stability and reputation of the broker-dealer and the execution services provided by such broker-dealer. The majority of client account assets are invested in corporate fixed-income securities which trade over-the-counter and not on an exchange. Some of the securities selected by Millstreet may be thinly traded and there may be only one broker-dealer who can execute the desired trade. The General Partner selects the prime brokers (or introducing brokers) that will handle all clearing, settlement, and custody of the Fund. The clients in the SMAs select the custodians and/or prime brokers for their accounts managed by Millstreet, but Millstreet may make a suggestion in the selection process.

In choosing a broker-dealer for bond loan transactions, Millstreet generally does not consider the value of various services or products that the broker-dealer provides client accounts beyond transaction execution. Some of our bond positions are in securities for which there is very limited research available. Millstreet may receive, on an unsolicited basis, various research and other products and services from brokers or dealers. Millstreet affords no consideration, however, to the receipt of such products and services when determining through which brokers or dealers it executes client securities transactions. Millstreet does not use soft dollar benefits to service client accounts. Transaction fees are built into the price of a bond transaction and an OTC credit default swap, whereas a commission per share, per contract, or per trade is paid for equities, options, and cleared CDS transactions, respectively. The Co-Chief Investment Officers of the Fund may bid for and purchase (and sell) the same securities as purchased and sold for Millstreet’s SMA clients. Differing investment portfolios can be expected to result from several factors, including, without limitation, differences in investment strategy, potential regulatory constraints, client-imposed investment restrictions, and the amount of cash available for investment. For these reasons, such purchase and sale orders for the Fund may be made separately from purchases and sales for the SMA strategies. On occasion, Millstreet may purchase a security for the Fund or an SMA while at the same time it sells the same security for an SMA or the Fund. Such a transaction may occur if an SMA investor requests a change to its portfolio or in order to rebalance positions. Any transfer must be consistent with Millstreet’s fiduciary obligations to its investors and must be effected through one or more brokerdealers. If Millstreet believes that the purchase or sale of a security is in the best interest of more than one of its clients, Millstreet will generally aggregate orders of various accounts which are under the management of Millstreet and the General Partner for execution in order to seek to get the benefit of best prices or commission rates from a larger overall transaction size. Millstreet has established allocation and aggregation procedures that are designed to ensure that each client is treated fairly and that transactions are allocated in a manner that is fair and equitable to each client relative to other clients, taking into account all material relevant facts and circumstances. In certain cases, the aggregate order may be executed in a series of transactions at various prices and the trades are allocated to client accounts as to amount and price in a manner considered equitable to each account so that each typically receives the average price of such transactions. Exceptions may be made due to the size of the account and the size of the trade. In the event the Co-Chief Investment Officers determine to aggregate offers to buy or sell the same bonds across the Fund and SMAs, the aggregation policies described above will be in effect.

From time to time in certain circumstances, Millstreet may accept introductions to prospective investors by way of its prime broker capital introduction teams. However, Millstreet does not pay such capital introduction team for any investments Millstreet may receive from prospective investors.

Millstreet and its employees have not been involved in any legal or disciplinary events that would be material to a client’s or prospective client’s evaluation of Millstreet’s advisory business or the integrity of its management and personnel.

Craig Kelleher, Managing Member of Millstreet and the General Partner and Co-Chief Investment Officer, and Brian Connolly, Managing Member of Millstreet and the General Partner and Co-Chief Investment Officer, review investments in each client account on each trading day and regularly reassess valuations, theses, and the risk/reward profile of each existing investment on a stand-alone basis and within the context of the overall client account. The daily evaluation also facilitates adherence to the investment strategy. Internal portfolio profit and loss estimates are maintained on a real-time basis. Conditions that may trigger a review aside from regular reviews are changes in applicable laws, new investment information, changes in the market, a change in the thesis related to any of our positions, and changes in a particular client’s circumstances or investment mandate. Millstreet’s operations team also maintains portfolio profit and loss estimates for each client account. The estimate for the Fund is compared on a monthly basis to the accounting calculated by Stone Coast Fund Services LLC (“Stone Coast”), the administrator of the Funds, in order to confirm and approve the final net asset value and investor capital balances each month. Millstreet also reviews and approves the monthly

NAV/share and ending net assets for each investor in the Offshore Fund. Millstreet’s estimate of each SMA’s profit and loss is compared monthly to the SMA investor’s own accounting and/or that of the respective administrator or custodian of that account. The investor and Millstreet agree upon the profit and loss for the period and any associated fees. The Fund’s auditor, KPMG LLP, audits the books and records of the Fund and the Offshore Fund at the end of each fiscal year, and we annually provide investors in the Funds within 120 days of the Funds’ fiscal year end with audited year-end financial statements prepared in accordance with GAAP. Regarding the Fund, investor statements with capital balances and net performance for the month and yearto-date are provided to investors on a monthly basis by Stone Coast. Investors in the Offshore Fund receive investor statements from Stone Coast that include the NAV per share, ending net assets, and net performance for the month and year-to-date. Investors in the Fund and Offshore Fund are also provided a commentary and a portfolio snapshot of the Fund on a monthly basis that includes details such as fund characteristics (AUM, number of total positions, exposures), fixed income distribution (weighted average coupon, yield, maturity, duration,), and net performance (attribution, monthly, year-to-date, inception-todate). On a quarterly basis, investors are provided a quarterly letter that includes portfolio and market commentary. Audited financial statements and K-1s are sent to investors in the Funds annually. Clients in the SMAs receive monthly statements from their respective custodians and administrators, where applicable. The SMA clients also receive from Millstreet the same general commentary provided to investors in the Funds and may receive consultation or reports as requested.

Fund assets are generally held in custody by third party qualified custodians, including the Fund’s prime brokers and other unaffiliated broker/dealers or banks; however, Millstreet Capital Partners LLC is deemed to have custody of the Fund’s assets since it serves as the General Partner of the Fund and has the ability to deduct advisory fees from the Fund’s account. Limited partners in the Fund and shareholders in the Offshore Fund do not receive statements from the prime brokers. The Funds are subject to an annual audit and audited financial statements, which are prepared in accordance with generally accepted accounting principles by a PCAOB Accountant, are distributed annually to each limited partner or shareholder, as the case may be, within 120 days of the end of each fiscal year. Millstreet is not deemed to have custody over any SMA client accounts and is expressly prohibited from taking or receiving possession of any of the assets in the current SMAs.

Millstreet has discretionary authority to manage investment accounts on behalf of its clients. Under these arrangements, Millstreet has the authority to determine, without obtaining specific client consent, the securities to be bought or sold and the amount of the securities to be bought or sold on behalf of clients. Millstreet’s discretionary authority with respect to its SMA clients may be limited by specific mandates outlined and agreed upon in each client’s individual investment advisory agreement with Millstreet. There are no specific limitations on Millstreet’s authority with respect to the Funds other than as set forth in the offering memorandum.

All investors in the Funds agree to grant Millstreet an irrevocable power of attorney to sign necessary documents related to the business and management of the Funds on behalf of each such investor. Each investor grants this power upon execution and acceptance of the subscription documents for the Fund or Offshore Fund, as applicable. Regarding the SMAs, each investor has authorized and appointed Millstreet the attorney-in-fact with respect to trading for the investor’s SMA.

Millstreet’s overall policy is to vote proxies and voluntary corporate action events and to evaluate class actions in the best interest of its clients. A material conflict of interest may arise if Millstreet, one of its principals, or one of its employees has a substantial business or personal relationship with the company that is the subject of a proxy or voluntary corporate action event or a proponent of a proxy proposal and the failure to vote in favor of management or the proponent could harm Millstreet’s relationship with such persons or company. Janet Kastrud is Millstreet’s designated Proxy Voting Administrator. She serves as the arbiter in determining whether specific proxies or corporate actions pose a material conflict of interest with Millstreet members or employees. The Proxy Voting Administrator helps resolve material conflicts of interest related to proxies or corporate actions on a case-by-case basis. Resolution may involve recusing a Co-Chief Investment Officer from the voting decision or securing a third party to exercise the vote in the best interest of our clients. In general, Millstreet has minimal proxies to vote since the majority of its positions are in fixed income. However, voluntary corporate events for which Millstreet needs to make elections occur fairly frequently related to bond positions in Millstreet’s portfolios. The SMA investors may reserve the authority to vote proxies on behalf of their accounts and receive proxy information directly. In these cases, Millstreet may make suggestions to the investors regarding how certain proxies should be voted. Regarding voluntary corporate actions for bonds in the SMA portfolios, Millstreet has the authority to make the relevant elections. In terms of participating in class actions, Millstreet will evaluate each class action to determine if it would be in the best interest of the Fund to participate. Regarding the SMAs, Millstreet will forward along information for the SMA investors to decide whether to file or not. Millstreet will not file a class action claim on behalf of any SMA investor unless requested to but may recommend what action the SMA investors should take. Millstreet will deliver to each Fund and SMA upon written request a complete copy of its Proxy Voting and Election Policies and Procedures and/or information on how it voted proxies or made elections for the Funds or SMAs.

Millstreet is not aware of any financial condition that is reasonably likely to impair Millstreet’s ability to meet its contractual commitments to its clients.