MONTANOVA CAPITAL, LLC

Montanova Capital, LLC (f/k/a Suvretta Capital Management, LLC) (the “Adviser” or “Montanova”), a Delaware limited liability company, is a New York-based investment management firm founded by Aaron Cowen (the “Managing Member”) in 2011. The owner of the Adviser is Montanova Capital, LP. (f/k/a Suvretta Capital, LP), a Delaware limited partnership, and its general partner is Montanova Capital GP, LLC (f/k/a Suvretta Capital GP, LLC), a Delaware limited liability company. As of December 31, 2025, Montanova’s regulatory assets under management were approximately $7,866,700,000. As of the date of this filing, Montanova does not manage any assets on a non-discretionary basis. Montanova provides discretionary investment management services to private pooled investment vehicles (each a “Fund” and collectively the “Funds”) intended for sophisticated investors and institutional investors (“Fund Investors”). The Funds Montanova manages include:

Suvretta Partners, LP (the “Onshore Fund”) and Suvretta Offshore Fund, Ltd. (the “Offshore Fund”), which invest substantially all of their assets in Suvretta Master Fund, Ltd. (the “Suvretta Fund,” and collectively with the Onshore Fund and the Offshore Fund, the “Long-Short Funds”);

Averill Partners, LP (“Averill Onshore”) and Averill Fund, Ltd. (“Averill Offshore”), which invest substantially all of their assets in Averill Master Fund, Ltd. (“Averill Master,” collectively with Averill Onshore and Averill Offshore, the “Averill Funds”);

Averill Madison Partners, LP (“Madison Onshore”) and Averill Madison Fund, Ltd. (“Madison Offshore”), which invest substantially all of their assets in Averill Madison Master Fund, Ltd. (“Madison Master,” collectively with Madison Onshore and Madison Offshore, the “Madison Funds”); and

Suvretta GP, LLC (the “GP”) serves as the general partner to the Onshore Fund and a holder of certain allocation class shares in the Master Fund. Averill GP, LLC (“Averill GP”) serves as the general partner to Averill Onshore and a holder of certain allocation class shares in Averill Master. Averill Madison GP, LLC (“Madison GP”) serves as the general partner to Madison Onshore and a holder of certain allocation class shares in Madison Master. The GP, Averill GP and Madison GP (collectively, the “General Partners”) are related entities of Montanova. The Onshore Fund, Averill Onshore and Madison Onshore are Delaware limited partnerships (altogether the “US Funds”). Interests in the US Funds are offered on a private placement basis, and in reliance on Section 3(c)(7) of the IC Act, to persons who are “accredited investors” as defined under Regulation D of the Securities Act and “qualified purchasers” as

defined under the IC Act, subject to certain other conditions, which are set forth in each US Fund’s offering documents. The Offshore Fund, Averill Offshore and Madison Offshore are exempted companies incorporated under the laws of the Cayman Islands (altogether the “Cayman Funds”). Shares or interests in the Cayman Funds are generally offered to persons on a private placement basis who (1) are not “U.S. persons,” as defined under Regulation S of the Securities Act, or such U.S. persons that may be offered interests in the US Funds, as described above, but are tax-exempt (or entities substantially comprised of tax-exempt U.S. persons), and (2) are subject to certain other conditions, which are set forth in each Cayman Fund’s offering documents. Each Master Fund is an exempted company incorporated under the laws of the Cayman Islands. The purpose of each Master Fund is to achieve trading and administrative efficiencies. Each of the US Funds and the Offshore Funds (together, the “Feeder Funds”) invests all of its Investment Assets in its complex’s applicable Master Fund. “Investment Assets” means all assets other than cash, money market securities and other liquid assets held for pending contribution to the Master Fund, distribution to investors, or payment of feeder-level expenses. Thus, an investment in the Feeder Funds is the functional and economic equivalent of an investment in a Master Fund. With regards to the Long-Short Funds, Montanova seeks to achieve positive absolute returns, regardless of market conditions, on behalf of the Funds by investing primarily in equity securities (both long and short), with an emphasis on large- to mega-capitalization companies. Montanova, through the Long-Short Funds, may invest in privately placed unregistered securities that do not have a readily ascertainable market value or other illiquid securities which may be valued but are not freely transferable (which are defined and designated as “Designated Investments”), subject to a 10% limitation as defined in the Onshore Fund’s and the Offshore Fund’s confidential private placement memorandums. With regards to the Averill and Madison Funds, Montanova seeks to achieve risk-adjusted capital appreciation through a range of investment instruments in the healthcare industry, by adhering to its investment philosophy of generating returns through fundamental, bottom-up stock selection. With respect to the Averill Funds, Montanova seeks to invest in companies in therapeutics-related companies, namely within the biotechnology and pharmaceuticals sectors, but may also invest in medical technology, healthcare services and other related subsectors. With respect to the Madison Funds, Montanova seeks to invest primarily in companies in the healthcare sector, mostly defined as healthcare equipment and services, pharmaceuticals, biotechnology and life sciences, and other related sub-sectors. Montanova, through each of the Averill Funds and Madison Funds, may invest in Designated Investments, subject to a 25% limitation as defined in Averill Onshore’s, Averill Offshore’s, Madison Onshore’s and Madison Offshore’s confidential private placement memorandums. Montanova manages the assets of the Funds in accordance with the investment strategy set forth in each Feeder Fund’s confidential private placement memorandum and, subject to certain investment restrictions, does not tailor its investment management services to the individual needs of Fund Investors.

Montanova also serves as sub-manager to a portion of an unaffiliated SICAV established under the laws of Luxembourg 1 (“SICAV Sub-account”). Montanova manages the SICAV Subaccount based on the investment advisory agreement between Montanova and the SICAV’s investment manager and the investment guidelines in the SICAV’s prospectus and operating memorandum. Montanova currently does not manage separate accounts for particular Clients (as defined herein). If Montanova were to manage separate accounts, the accounts would be subject to investment objectives, guidelines, restrictions, fee arrangements and other terms that would be individually negotiated with each such Client pursuant to an investment advisory agreement. Separate accounts would generally involve significant account minimums. Montanova has in the past, and may in the future serve as investment manager to additional co-investment vehicles (“Co-Investment Vehicles”) that co-invest in certain investments along with one or more Funds. In this document, any reference to “Client” means the Funds, the Co-Investment Vehicles and their investors and any other advisory client of the Adviser. One or more affiliates of Montanova previously sponsored, and may do so again in the future, special purpose acquisition vehicles (“Affiliated SPACs”) that were generally formed for the purpose of effecting a merger, share exchange, asset acquisition, share purchase, reorganization or similar business combination with one or more businesses. Montanova does not participate in Wrap Fee Programs.

The fees applicable to each Fund are set forth in detail in their respective confidential private placement memorandums. A summary of the fees is provided below. Montanova and the General Partners typically receive compensation from the Funds in the form of fees based on a percentage of assets under management and performance-based incentive allocations.

The Long-Short Funds pay Montanova a quarterly management fee in advance ranging from 0% to 1.5% (per annum) of the net assets of the Long-Short Funds. For LongShort Fund assets that are Designated Investments, the quarterly management fee is based upon the lower of (i) initial cost, as adjusted for partial realizations of such Designated Investment and (ii) fair value (which may be at cost).

The Averill Funds pay Montanova a quarterly management fee in advance ranging from 1% to 2% (per annum) of the net assets of the Averill Funds. For Averill Fund assets that are Designated Investments, the quarterly management fee is based upon the

A “SICAV,” which stands for Société d’investissement à capital variable, is a type of open-ended investment fund with variable share capital that may invest in transferable securities, money market instruments, units of investment funds, deposits and financial derivative instruments.

lower of (i) initial cost, as adjusted for partial realizations of such Designated Investment and (ii) fair value (which may be at cost).

The Madison Funds pay Montanova a quarterly management fee in advance ranging from 1.5% to 2% (per annum) of the net assets of the Madison Funds. For Madison Fund assets that are Designated Investments, the quarterly management fee is based upon the lower of (i) initial cost, as adjusted for partial realizations of such Designated Investment and (ii) fair value (which may be at cost).

The Funds will also allocate an annual performance allocation to the General Partners as described below: The Long-Short Funds Performance Allocation The GP will receive an annual performance allocation ranging from 0% to 20% of the net profits (including net unrealized gains) as of the end of each fiscal year (after deducting all expenses) allocated to an investor, subject to a loss carryforward provision that is described in the Onshore Fund’s and Offshore Fund’s confidential private placement memorandums. Net unrealized profits attributable to Designated Investments are not included in calculating the performance allocation until a Designated Investment is realized or deemed realized. The Averill Funds Performance Allocation The Averill GP will receive an annual performance allocation ranging from 10% to 20% of the net profits (including net unrealized gains) as of the end of each fiscal year (after deducting all expenses) allocated to an investor, subject to a loss carryforward provision that is described in Averill Onshore’s and Averill Offshore’s confidential private placement memorandums. Net unrealized profits attributable to Designated Investments are not included in calculating the performance allocation until a Designated Investment is realized or deemed realized. The Madison Funds Performance Allocation The Madison GP will receive an annual performance allocation ranging from 20% of the net profits generated above the returns of a benchmark return (described below); to 20% of the net profits (including net unrealized gains) as of the end of each fiscal year (after deducting all expenses) allocated to an investor, subject to a loss carryforward provision that is described in Madison Onshore’s and Madison Offshore’s confidential private placement memorandums. Net unrealized profits attributable to Designated Investments are not included in calculating the performance allocation until a Designated Investment is realized or deemed realized. The benchmark return is calculated as the amount that a capital account or series of shares (collectively “Capital Accounts”) would have appreciated or declined during a performance period if it had achieved a rate of return for such period equal to that of the benchmark specified in the Madison Onshore Fund’s and Madison Offshore Fund’s confidential offering memorandums.

Because for certain limited partners and/or shareholders the annual performance allocation is determined based upon a Capital Account outperforming the benchmark return for any fiscal year, it is possible the Madison GP will be entitled to receive a performance allocation for a fiscal year even if the Capital Account had depreciated in value during the year. In addition, it is also possible that the performance allocation earned by the Madison GP will exceed the Capital Account’s allocable share of net profits at the Master Fund level in a fiscal year. Under such circumstances, the performance allocation will be reallocated to the Madison GP for a fiscal year only to the extent of the Master Fund’s net profits allocated to such Capital Account for such fiscal year. The remaining portion of the performance allocation that was not reallocated to the Madison GP (“Deferred Performance Allocation”) will not be allocated to the Madison GP until the next fiscal year that there is sufficient amount of Master Fund net profits allocated to the Capital Account even if no performance allocation is otherwise due in such subsequent fiscal year. Unallocated Deferred Performance Allocation will not reduce the value of a Capital Account for purposes of determining the annual performance allocation in a subsequent fiscal year. If a shareholder or limited partner subject to a Performance Allocation based on outperformance of the benchmark return, as described above, redeems or withdraws from the Madison Funds with unallocated Deferred Performance Allocation in their Capital Account, the unallocated Deferred Performance Allocation will be debited from such shareholder’s or limited partner’s Capital Account upon withdrawal or redemption, provided, however that if there are insufficient Master Fund net profits to cover the unallocated Deferred Incentive Allocation, the amount of the unallocated Deferred Incentive Allocation will be deducted from the amount otherwise payable to the redeeming shareholder or withdrawing limited partner, as applicable, and will be placed in a “Suspension Account.” The Madison GP’s allocation class shares of the Master Fund will be reallocated the Deferred Performance Allocation from the Suspension Account once there are net profits in the Capital Accounts of the remaining shareholders or limited partners in that year or subsequent fiscal years. Until such time, the Suspension Account will be invested in the Madison Funds (or as otherwise directed by the Madison GP), and any net profits earned from the Suspension Account will be credited to all of the remaining shareholders or limited partners on a pro rata basis at the end of the fiscal year based on the values of the Capital Accounts as of the beginning of the last fiscal period of such fiscal year. If the Madison Funds dissolve, the amount allocated to the Suspension Account will be distributed to the remaining shareholders or limited partners in accordance with each fund’s winding up procedures. The Madison Funds will maintain an “Underperformance Recovery Account” for each Capital Account of a shareholder or limited partner subject to a Performance Allocation based on outperformance of the benchmark return, as described above. In the event a Capital Account underperforms the benchmark return in a fiscal year, the Underperformance Recovery Account will be debited an amount equal to the underperformance. For each fiscal year a Capital Account outperforms the benchmark return, the Underperformance Recovery Account will be credited an amount equal to the outperformance. To the extent that there is a negative balance in a Capital

Account’s Underperformance Recovery Account at the end of a fiscal year or at such other date as the calculation of the performance allocation is required to be made, an annual performance allocation will not be made; however, any outstanding Deferred Performance Allocation from prior fiscal years attributable to the Capital Account shall be made to the extent of the amount of net profits allocated to the Capital Account. Montanova has (and reserves the right to) waived or reduced fees for certain Fund Investors, including employees, family members, initial investors and others as may be determined in Montanova’s sole discretion. For the Cayman Funds, such waivers or reduction of fees must be approved by the Cayman Funds’ Board of Directors or General Partner, as applicable. As sub-manager to the SICAV, Montanova is currently paid 1.15% (per annum) of the net assets of the SICAV Sub-account. The management fee is calculated on the daily net asset value of the SICAV Sub-account and payable to Montanova monthly in arrears. Fees are subject to negotiation for any future accounts Montanova manages. Expenses In addition to paying management fees and incurring the annual performance allocation (if applicable), the Funds will also be subject to other investment expenses which include:

commissions, research and proxy solicitation fees and expenses (including researchrelated travel and third-party research provider expenses) (please refer to Item 12 of this Brochure for a discussion of Montanova’s brokerage practices); costs of independent appraisals, broken-deal and/or unconsummated expenses associated with an investment (including any portion of expenses that could have been borne by any other co-investment vehicle or account); expenses in connection with conducting due diligence and negotiating terms of investments, regardless of whether such investments are consummated; interest on margin accounts and other indebtedness; borrowing charges on securities sold short; proxies, custodial fees and bank service fees; taxes, duties and other government charges; other portfolio expenses; and any other expenses reasonably related to the Funds’ operations and the purchase, sale or transmittal of Fund assets (including, proxy solicitation fees and expenses, fees and performance compensation paid to unaffiliated third-party managers with respect to the management of certain assets of the Fund and trading systems and order management systems).

In addition, the Funds bear relevant operating expenses including those listed above and: Fund legal, compliance, regulatory, administrator, audit and accounting expenses (including third party accounting services); fees and expenses related to an advisory board, if any; consultant fees, including healthcare-related expert fees and/or lobbyist fees; and fees and expenses related to various fund related filings (or portions thereof) including those made in connection with managing the Fund’s portfolio (including, but not limited to, Section 13 filings

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The Long-Short Funds Montanova employs a global equity strategy, both long and short positions, that aggregates all of the disparate skillsets Aaron Cowen, the Funds’ Chief Investment Officer and Portfolio Manager, learned at his previous work experiences. This includes deep fundamental analysis, “industry before company” investing, trading, options, strong risk control management and an appreciation for macro influences on equities. Montanova generally uses (1) equities; (2) futures; (3) exchange-traded funds (“ETFs”); and (4) equity options to express its investment opinion. Montanova prefers to express an investment opinion in the equity security and use options to hedge unexpected risk in the security or to enhance its view in a cost efficient manner. Montanova may use ETFs and futures to hedge unwanted industry or market exposure.

While the Long-Short Funds invest primarily in equities and equity-related securities globally, each have broad and flexible investment authority. Accordingly, the Long-Short Fund investments may at any time include, without limitation, long or short positions in U.S. or nonU.S. publicly traded or privately issued or negotiated common stocks, including private investments in public equity (“PIPEs”), special purpose acquisition companies (“SPACs”), preferred stocks, stock warrants and rights, corporate debt, bonds, notes or other debentures or debt participations, convertible securities, fixed income securities, swaps, options (purchased or written), futures contracts, commodities, forward contracts and other derivative instruments, partnership interests and other securities or financial instruments including those of investment companies. Further, the Long-Short Funds have complete flexibility to create or organize (alone or in conjunction with others including the Funds’ affiliates) or otherwise utilize special purpose subsidiaries, affiliates, feeders or other special purpose investment or financing vehicles (including to access investment opportunities), swaps or other derivatives or structured products to access investments, particularly in instances where the Long-Short Fund, in its sole discretion, determines that there is a potential tax, regulatory, finance, confidentiality or other advantage to such structured product, instrument or entity. The investment strategy starts with investing in industries which benefit from secular growth or shorting industries in secular decline. Montanova strives to own great companies in solid industries and short companies which are in weak industries and/or are losing market share. Montanova conducts due diligence on both businesses and industry fundamentals, focusing on competitive strengths and weaknesses, revenue growth, profitability, liquidity, and free cash flow. Then, Montanova develops fundamental bottoms-up research for each company in which it may invest to determine earnings potential and underlying intrinsic value. The focus tends to be on industries experience secular growth and furthermore, those companies that would benefit from such growth. Montanova also actively engages management and seeks to gain perspective from competitors, customers, and suppliers. The investment philosophy emphasizes companies which have management teams that are either good or bad stewards of capital for long and short ideas, respectively. Investing in something “cheap” is not a sufficient thesis as a stock can always get cheaper, especially in volatile markets. Montanova prefers management teams who have an appreciation for their cost of capital and improving their balance sheets. The team also looks for opportunities with hard or soft catalysts on both the long and short side. Additionally, the team generally invests in larger or highly liquid companies. Montanova’s investment philosophy for the Long-Short Funds focuses on investing in largeand mega-capitalization companies where the investment personnel have the ability to generate a differentiated investment view that can generally be expressed in equities that are liquid. These are also generalist portfolios, without any one focus on a particular industry or sector. The sectors that the Long-Short Funds invest in include, but are not limited to, consumer/retail; technology, media and telecommunications; healthcare services; industrials; financials; and energy. Areas that Montanova is generally not keen to invest in are industries and companies in which the equity performance is driven by binary events or “data point” investing. Positions that enter the portfolios will be sized based on an array of factors. Sizing of positions will take into account liquidity, upside/downside risk and return characteristics, timeframe to

an expected catalyst, changes in information, changes to the thesis, and scaling up and down opportunistically in relation to the underlying performance of the stock. Montanova also seeks to hedge within sectors to limit the amount of basis risk within the portfolios. For the Long-Short Funds, Montanova believes that short positions should generate alpha and seeks to have the majority of the short portfolio in single stock positions. If there is an inability to find single stock shorts, the first option will be to create a basket of shorts, and if that is suboptimal, to use ETFs. The investment process is iterative, relying on the experience of the entire team. The portfolios are generally focused on North America and Western Europe. The Averill Funds and the Madison Funds The Averill Funds and the Madison Funds (the “Healthcare Funds”), managed by Kishen Mehta, the Healthcare Funds’ Chief Investment Officer and Portfolio Manager, and his team (the “Averill Team”), employ a thorough, structured research process that strives to identify key aspects of a successful healthcare investment. These aspects may include the likelihood of development success, regulatory hurdles and expected commercial dynamics, including competitive positioning, among others. The Averill Team believes this reproducible process allows it to generate investment views on a broad set of healthcare companies, increasing its potential to find mispriced companies. Finally, through the use of a range of financial instruments, the Averill Team looks to maximize the value of each investment while working to control risk. The Averill Funds’ investment strategy seeks to achieve risk-adjusted capital appreciation through investment in a range of instruments in the healthcare industry, by adhering to the Averill Team’s investment philosophy of generating returns through fundamental, bottom-up stock selection. The Averill Team employs an approach that focuses on capturing dislocations between market pricing of a security and the perceived riskiness of its underlying asset(s), potentially caused by data updates or drug commercialization milestones, etc. The Averill Team believes that it is important to understand the fundamentals of companies as well as the overall products’ competitive profile along with the level of risk in the clinical development plan. Therefore, the Averill Team focuses as much on the addressable market of diseases/conditions, competitive landscape, the pre-clinical and clinical development program and the implied market success of those products, as it does on individual company financials. With respect to the Averill Funds, the Averill Team prefers to invest in companies that it perceives to have a key product that could disrupt or threaten current methods of managing or treating various diseases or conditions. On the short side, the Averill Team looks for companies that it believes fail to react to large changes in paradigm or are in secular decline. Regardless of direction, the Averill Team seeks to construct a portfolio of companies where the “Street” does not appropriately price the value of its comprising products. The Averill Team will also take into account industry dynamics, such as secular growth, events/catalysts, data releases, etc. that could impact potential investments.

The Averill Team conducts due diligence on industry and business fundamentals. At the industry level, the Averill Team will monitor new methodologies for treating various diseases, changes in treatment paradigms, regulatory changes and industry news/data in an attempt to recognize and appreciate positive and negative transformation. The Averill Team will then conduct in-depth fundamental and strategic analysis on product opportunities, including developing a model to determine future revenue, earnings, cash flow, etc., to assess the development and commercial feasibility of therapies and products. The Averill Team will also actively engage management and seek to gain perspective from medical and research professionals, the scientific community, competitors, customers and suppliers. As such, the Averill Team seeks to achieve the investment objective of the Averill Funds by investing primarily in equity securities (both long and short) of public and private issuers primarily in the healthcare sector. Specifically, the Averill Team seeks to invest in companies in biotech and pharmaceuticals, as well as medical technology and supplies, healthcare services and other related sub-sectors. Notwithstanding the foregoing, the Averill Team has broad and flexible investment authority to invest the Averill Funds’ assets. Accordingly, the Averill Funds’ investments may at any time include, without limitation, long or short positions in U.S. or non-U.S. publicly traded or privately issued or negotiated common stocks, including PIPEs, SPACs, preferred stocks, stock warrants and rights, corporate debt, bonds, notes or other debentures or debt participations, convertible securities, fixed income securities, swaps, options (purchased or written), futures contracts, commodities, forward contracts and other derivative instruments, partnership interests and other securities or financial instruments including those of investment companies. The Madison Funds’ investment strategy seeks to achieve risk-adjusted capital appreciation through investment in a range of instruments in the healthcare industry, by adhering to the Averill Team’s investment philosophy of generating returns through fundamental, bottom-up stock selection. The Averill Team employs an approach that focuses on capturing dislocations between the market pricing of a security and the perceived riskiness of its underlying asset(s). The Averill Team believes that it is important to understand the fundamentals of companies as well as the overall products’ competitive profile in order to ascertain if the company is overor under-valued. Therefore, the Averill Team focuses as much on the addressable market of diseases/conditions/services and the competitive landscape, among other things, as it does on individual company financials. With respect to the Madison Funds, the Averill Team prefers to invest in companies that it perceives to have a key product that could disrupt the healthcare industry. On the short side, the Averill Team looks for companies that it believes fail to react to large changes in paradigm or are in secular decline. Regardless of direction, the Averill Team seeks to construct a portfolio of companies where the “Street” does not appropriately price the value of its comprising products. The Averill Team will also take into account industry dynamics, such as secular growth, events/catalysts, data releases, etc. that could impact potential investments. The Averill Team conducts due diligence on industry and business fundamentals. At the industry level, the Averill Team will monitor new methodologies for treating various diseases, changes in treatment paradigms, regulatory changes and industry news/data in an attempt to recognize and appreciate positive and negative transformation. The Averill Team will then conduct in-depth fundamental and strategic analysis on product opportunities, including

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As of the date of this Brochure, Montanova’s Clients consist of private pooled investment vehicles and foreign pooled investment vehicles. Fund Investors may include, but are not limited to; high net worth individuals; pension plans (corporate, state or foreign); sovereign wealth funds; endowments; foundations; banks; pooled investment vehicles (e.g., funds-offunds); trusts; estates or charitable organizations and corporate or business entities. Each Feeder Fund generally requires a minimum investment of $1 million; however, Montanova (or a Fund’s board of directors if applicable) maintains discretion to accept less than the minimum investment threshold. Montanova requires that all Fund Investors read the confidential private placement memorandum, accompanying documentation and complete a Fund’s respective subscription documents.

The General Partners are entitled to receive performance-based compensation in the form of an annual incentive fee as described in Item 5 above. All Fund Investors are charged performance-based fees unless such fee is reduced or waived as determined in Montanova’s sole discretion. For the Cayman Funds, such waiver or reduction of fees must be approved by the Cayman Funds’ Board of Directors or General Partner, as applicable. In addition, Montanova’s investment personnel are typically compensated on a basis that includes a performance-based component. The fact that a significant portion of Montanova’s compensation is directly computed on the basis of profits generated by the trading activities of the Funds may create an incentive to make investments on behalf of the Funds that are riskier or more speculative than would be the case in the absence of such compensation. Montanova mitigates this risk associated with this conflict of interest through written policies and procedures. In addition, the performance based compensation received by Montanova is based primarily on realized and unrealized gains and losses. As a result, Montanova may receive a performance allocation reflecting unrealized gains at the end of a year that is not subsequently recognized by the Funds. Montanova is involved with the valuation of securities held by the Funds, which in turn determines the calculation of the management fee and the performance allocation it receives. This creates an incentive for Montanova to increase the value of the assets during the valuation process. Montanova addresses this conflict of interest by using readily available market quotations and other commonly used and recognized valuation methods to value

securities and by delegating all valuation responsibilities to the Funds’ third-party administrator. Additionally, Montanova believes that through the Managing Member’s and other Montanova personnel’s investments in the Funds, its interests are aligned with Fund Investors. In addition, certain Clients are eligible to be charged performance-based fees while other Clients are not. This leads to a potential risk for one Client to be favored over another Client, whereas Montanova has a greater incentive to favor Clients that are charged performancebased fees. Accordingly, Montanova has adopted and implemented policies and procedures intended to address conflicts of interest relating to the management of multiple accounts, including accounts with different fee arrangements, as well as any Affiliated SPACs, and the allocation of investment opportunities. Montanova’s procedures relating to the allocation of investment opportunities require that Clients with similar investment mandates participate in investment opportunities pro rata based on asset size and require that, to the extent orders are aggregated, orders are price-averaged. Also, Montanova’s procedures require the objective allocation for limited opportunities (such as initial and secondary public offerings and private placements) to ensure fair allocation among Clients. These areas are monitored by the CCO. For further descriptions of these policies and procedures, please see the “Trade Aggregation, Allocation and IPO Procedures” under Item 12 below.

Neither Montanova, the principal nor any of its officers are registered as a broker-dealer or a representative of a broker-dealer or have an application pending to register as a broker-dealer or a registered representative of a broker-dealer. Montanova is also an exempt commodity pool operator. Montanova sponsored the formation of the private pooled investment vehicles it manages. The General Partners of the US Funds are related entities of Montanova. Montanova also selected the three directors for the Cayman Funds, two of whom are independent. Although this arrangement may give Montanova more control and discretion over the Funds, Montanova manages any potential conflicts of interest by adhering to the investment strategy and investment allocation policies written in the Feeder Funds’ confidential private placement memorandums. The Adviser does not recommend or select other investment advisers for its clients.

Trading Code of Ethics Montanova has adopted a Code of Ethics pursuant to Rule 204A-1 of the Investment Advisers Act of 1940, as amended (the “Advisers Act”) which sets forth standards of ethical and business conduct expected of its personnel and addresses conflicts that may arise from personal trading by its personnel. Montanova’s Code of Ethics, among other things, requires compliance with the U.S. federal securities laws; reflects Montanova’s fiduciary responsibilities and those of its personnel; prohibits certain personal securities transactions; requires Montanova’s personnel to periodically report their personal securities transactions and to pre-clear certain securities transactions; and addresses prevention of the misuse of material non-public information. Montanova’s personnel are required to certify their compliance with the Code of Ethics upon the commencement of their employment and at least annually thereafter. All Montanova personnel are also required to comply with applicable securities laws, and to report any violation or suspected violation of the Code of Ethics to the CCO. The Code of Ethics will be provided to any investor or potential investor upon request. Montanova may trade and invest for its own account in securities and other financial instruments that are similar to or different from those in which its Clients invest. The Adviser will seek to resolve such conflicts of interest in a fair and equitable manner in accordance with its Code of Ethics. On a daily basis, Montanova’s Compliance Department reviews all trades from the same day and may request immediate action from the investment team in case of any irregularity. Any irregularity is reported to the Chief Operating Officer. Montanova’s personnel (“Adviser Personnel”) may buy and sell certain securities for their own accounts that Montanova buys and sells for its Clients so long as same day pre-clearance is obtained before executing any personal trade, subject to certain limited exceptions. For example, Adviser Personnel may personally trade shares of open-ended mutual fund companies (not including exchange traded funds), direct obligations of the U.S. government, commercial paper, certificates of deposit and other money market instruments without preapproval. Generally, Adviser Personnel are generally prohibited from buying and selling securities for their own accounts that are in the Funds’ portfolios and/or are placed on Montanova’s restricted list unless an exemption applies. Montanova’s CCO may permit such personal trading on a case by case basis. Montanova has established internal policies, including the adoption of a Code of Ethics, designed to ensure that Adviser Personnel do not unfairly benefit from personal trading at the expense of any of Montanova’s Clients. Adviser Personnel are required to disclose their personal securities holdings and transactions to Montanova on a periodic basis. The Code of Ethics’ personal trading policy applies to accounts held by Adviser Personnel, their immediate family members and any other family member sharing such employee’s household. Montanova also has adopted policies and procedures that are designed to prevent the misuse of material nonpublic information (“MNPI”). Such policies and procedures strictly forbid Montanova and its personnel from trading or recommending trading in securities of a

company while in possession of MNPI about such company in violation of applicable securities laws. Montanova utilizes certain procedures to mitigate the risk of trading on the basis of MNPI, which include but are not limited to periodic monitoring of the information flow to and between Montanova Personnel and employee training. In addition to the policies, procedures and restrictions described above, Montanova also maintains policies and procedures that address and place limits on Montanova personnel giving and receiving gifts and entertainment, making of political contributions, serving on outside boards of directors and other outside business activities that could give rise to potential conflicts of interest. Participation or Interest in Client Transactions Montanova, its affiliates and personnel (“Montanova Affiliates”) may invest in the same securities (or related securities) that Montanova or an affiliate recommends to Clients, including private securities. Such practices present a conflict if, because of the information an employee has, the employee is in a position to trade in a manner that could adversely affect Clients (e.g., place his or her own trades before or after Client trades are executed in order to benefit from any price movements due to the Clients’ trades). Montanova Affiliates may make co-investments together with the Funds. As a result of these co-investments, Clients may not be able to invest as much in a particular limited capacity investment as would be the case if such persons were not permitted to co-invest in these opportunities. In addition to affecting the individual’s objectivity, these situations may give rise to scenarios in which Montanova personnel invest in securities of an issuer in which a Fund has an existing investment or makes a future investment, giving rise to potential conflicts. Cross Trades and Principal Trades A “cross trade” is a pre-arranged transaction not involving a broker-dealer or brokerage commission between two or more Client accounts that are managed by the same investment adviser. An investment adviser that proposes to engage in cross trading must make full disclosure of the practice in its Form ADV and to clients. The investment adviser must also ensure that the cross trade achieves best execution for any clients involved and that no client is disfavored by the cross trading. Compliance with the requirements of Section 206(3) of the Advisers Act is not required for cross trades between Clients; however, where a cross trade involves a Client account in which the adviser or an affiliate directly or indirectly holds an ownership interest (including through a performance fee), the SEC may deem such trade to be a principal transaction subject to Section 206(3), depending on the percentage of such ownership interest. Montanova has a potentially conflicting division of loyalties and responsibilities regarding both parties to cross transactions, including with respect to a decision to enter into such transactions and with respect to valuation, pricing and other terms. Because Montanova represents the interests of both the seller and the buyer in a cross transaction, Clients for which Montanova executes cross transactions bear the risk that other Clients in the cross transaction will be treated more favorably, especially where the other Clients pay a higher investment management or performance-based fee or incentive allocation. Clients also bear the risk that the price of a security bought or sold through a cross transaction may be less

favorable than it might have been had the transaction been executed in the open market, and the risk that they receive a security that is difficult to dispose of in a market transaction. Section 206(3) of the Advisers Act prohibits Montanova and any employee or other affiliate from trading with any Client on a principal basis, or from recommending an agency cross trade to both participants, unless Montanova discloses the capacity in which it is acting to each participating Client in writing before completion of the transaction, and obtains each participating Client’s consent to the transaction. Montanova may effect a cross trade between certain Clients only when such trade is consistent with applicable law and this policy and Montanova has determined that such trade is in the best interest of each Client. Prior to engaging in the type of transaction described above, the responsible Montanova portfolio manager must notify the CCO. The CCO will determine, with the advice of outside counsel as necessary, whether the cross transaction is a principal transaction. For purposes of determining whether a transaction is a principal transaction, accounts of Montanova and its affiliates or other accounts controlled by Montanova or its affiliates (within the meaning of the Advisers Act) may be treated as accounts of Montanova. Additionally, an account of which Montanova and/or its controlling persons, in the aggregate, own more that 25% will be deemed an account of Montanova. The CCO will seek to ensure that the required notice is given and consent is obtained in accordance with Section 206(3) for principal transactions. Co-Investments Montanova has in the past and expects, from time to time in the future, to offer one or more Fund investors (including, without limitation, Montanova Affiliates) or other third-party investors the opportunity co-invest with the Funds in particular investments. Montanova Affiliates may, for example, offer such co-investment opportunities when the size of the opportunity exceeds the amount of capital that Montanova believes should be invested by the Funds for which the investment is appropriate. Montanova may also offer co-investment opportunities based on factors such as, but not limited to, the nature of the opportunity, speed of execution required, tax considerations, such persons' familiarity with, capability and history of making similar investments, such person' s prior expressions of interest in making similar investments, the ability of such persons to generate future investment opportunities or provide other benefits to Montanova and/or the Funds and/or to provide analytical and market advice or other expertise that may be valuable to Montanova and/or the Funds, and other factors deemed by Montanova to be relevant. In addition, Montanova Affiliates may coinvest with the Funds whether or not the particular co-investment opportunity is offered to Fund Investors or other third-party investors. Montanova is not required to offer co-investment opportunities to any investor, and no investor will be entitled (or obligated) to participate in such an opportunity by reason of being a Fund Investor. The decision of Montanova to offer (or not offer) co-investment opportunities to any investor will be made in the sole discretion of Montanova. If it is determined to offer any co-investment opportunity to an investor, Montanova will provide the details of such opportunity at the time the offer is communicated to such investor. If Montanova advises a committed co-investment vehicle in the future, such vehicle may be offered a co-investment opportunity before such opportunity is offered to any Fund investor, and no Fund investor will

be entitled (or obligated) to participate in such an opportunity by reason of being an investor in a Fund. Montanova receives fees and/or allocations from co-investors, which may differ among coinvestors, and which also may differ from the fees and/or allocations borne by Fund Investors. Additionally, co-investors may not bear certain expenses (e.g., broken deal expenses) that are borne by Fund Investors in connection with their investments in the Funds. Co-investors may have rights in addition to, and be subject to different terms as compared to, the rights and terms applicable to Fund Investors. For example, co-investors may receive minority protections, board seats or other control rights and may have different or advantageous rights with respect to their ability to exit the co-investment. If Montanova advises a committed coinvestment vehicle in the future, the fees, allocations and other terms and rights applicable to such investors in such vehicle may differ from the fees, allocations and other terms and rights applicable to Fund Investors.

In selecting broker-dealers to effect transactions for the Funds, Montanova, subject to its written policies and overall duty to obtain “best execution” of transactions, has authority to consider the full range and quality of the services and products provided by various brokers. Montanova will take into account such relevant factors as:

Listed bid and ask prices; The opportunity for price improvement; Transaction costs; Anonymity; Liquidity; Speed of execution; Quality of research; Expertise with difficult securities; Trading style and strategy; Geographic location; Frequency of errors; and Access to new issues.

Montanova is not required to solicit competitive bids and will not have an obligation to seek the lowest available commission cost. Accordingly, Montanova may cause a Client to pay a broker-dealer that provides brokerage or research services (either directly or through thirdparty relationships) an amount of commission or transaction cost in excess of that which another broker-dealer would have charged, if Montanova determines in good faith that such commission or transaction cost is reasonable in relation to the value of brokerage, research or other services provided. Montanova does not consider investor referrals from brokerdealers when making brokerage allocation decisions.

Research, Other Soft Dollar Benefits and Directed Brokerage Montanova may pay higher commission prices for the purchase or sale of securities to receive research or other products or services other than execution from a broker-dealer and/or a third-party in connection with Client securities transactions. This is known as a “soft dollar” relationship. Montanova limits the use of “soft dollars” to obtain research and brokerage services to services that constitute research and brokerage within the meaning of Section 28(e) of the Securities Exchange Act of 1934, as amended (“Section 28(e)”). Research services within Section 28(e) may include, but are not limited to, research reports (including market research); certain financial newsletters and trade journals; software providing analysis of securities portfolios; corporate governance research and rating services; attendance at certain seminars and conferences; discussions with research analysts; corporate access (including, but not limited to, meetings with corporate executives); consultants’ advice on portfolio strategy; data services (including services providing market data, company financial data and economic data); advice from brokers on order execution; and certain proxy services. Brokerage services within Section 28(e) may include, but are not limited to, services related to the execution, clearing and settlement of securities transactions and functions incidental thereto (i.e., connectivity services between an adviser and a broker-dealer and other relevant parties such as custodians); trading software operated by a broker-dealer to route orders; software that provides trade analytics and trading strategies; software used to transmit orders; clearance and settlement in connection with a trade; electronic communication of allocation instructions; routing settlement instructions; post trade matching of trade information; and services required by the SEC or a self-regulatory organization such as comparison services, electronic confirms or trade affirmations. When Montanova uses Client commissions to obtain Section 28(e) eligible research and brokerage products and services, Montanova’s Best Execution Committee meets periodically to review and evaluate its soft dollar practices and to determine in good faith whether, with respect to any research or other products or services received from a broker-dealer, the commissions used to obtain those products and services were reasonable in relation to the value of the research, brokerage or other products or services provided by the broker-dealer. This determination will be viewed in terms of either the specific transaction or Montanova’s overall responsibilities to the accounts or portfolios over which Montanova exercises investment discretion. The use of Client commissions (or markups or markdowns) to obtain research and brokerage products and services raises conflicts of interest. For example, Montanova will not have to pay for the products and services itself. This creates an incentive for Montanova to select or recommend a broker-dealer based on its interest in receiving those products and services. Montanova may cause Clients to pay commissions (or markups or markdowns) higher than those charged by other broker-dealers in return for soft dollar benefits (known as paying-up), resulting in higher transaction costs for Clients. In some instances, Montanova may obtain a product or service that is used, in part, by Montanova for Section 28(e) eligible purposes and, in part, for other purposes. In such instances, Montanova will make a good faith effort to determine the relative proportion of the product or service used to assist Montanova in carrying out its investment decision-making responsibilities and the relative proportion used for administrative or other purposes outside

Section 28(e). Such determination will be based on the actual use of the product or service by Montanova’s personnel. The proportion of the product or service attributable to assisting Montanova in carrying out its investment decision-making responsibilities will be paid through brokerage commissions generated by Client transactions and the proportion attributable to administrative or other purposes outside Section 28(e) will be paid for by Montanova from its own resources. The determination of the appropriate allocation of “mixed use” products and services creates a potential conflict of interest between Montanova and its Clients. Montanova may participate in “commission sharing arrangements” pursuant to which Montanova may execute transactions through a broker-dealer and request that the brokerdealer allocate a portion of the commissions or commission credits to another firm that provides research and other products to Montanova. Montanova excludes from use under these arrangements those products and services that are not eligible under Section 28(e) and applicable regulatory interpretations. In selecting brokers to execute transactions on behalf of the accounts of certain of its Clients, Montanova may place transactions with a broker or dealer that (1) provides Montanova with the opportunity to participate in capital introduction events sponsored by the broker-dealer; or (2) refers investors to a Fund, if otherwise consistent with seeking best execution. While Montanova recognizes that it may have an incentive to favor broker-dealers that provide capital introduction services to Montanova or otherwise refer prospective Clients or Fund Investors, Montanova does not select broker-dealers in recognition of the opportunity to participate in such capital introduction events or the referral of investors. Trade Aggregation, Allocation and IPO Procedures Montanova has established policies and procedures for (i) bunching orders for purchases of securities and (ii) allocating securities purchased and sold among Clients. These procedures incorporate (1) the applicable restrictions of the federal securities laws, including the Advisers Act and (2) general principles of fiduciary duty relating to the bunching of transactions and the allocation of purchases and sales of securities among Client accounts. Notwithstanding the foregoing, Montanova recognizes that in certain circumstances, strict compliance with these procedures may not be feasible and that unusual or extraordinary conditions may on occasion warrant deviation from the standard practices and procedures set forth herein. In such circumstances, the CCO, in consultation with outside counsel (if appropriate) shall determine the appropriate action which, in his reasonable judgment, will serve the best interests of, and will be fair and equitable to, all Clients. General Policies Montanova purchases or sells securities on behalf of its Clients based on their respective investment objectives and policies. Each transaction should be suitable for each Client in light of the characteristics of the specific security and the overall portfolio composition of such Client. Montanova has a fiduciary obligation to use its best efforts to ensure that no Client is treated unfairly in relation to any other Client in the allocation of securities or the order of the execution of transactions. Montanova will periodically monitor and evaluate the trade

allocations made during the preceding period, including whether allocations are made in accordance with the policies described herein. Allocations of securities will be made first by determining the Client(s) for which a particular security is appropriate. Because of the differences in Client investment objectives, strategies, guidelines, restrictions, risk tolerances, tax statuses and other criteria, there will be differences among Clients in invested positions and investment opportunities held. If the security is appropriate for more than one Client, generally, an allocation between or among such Clients will be made pro rata based on the net asset value of such Clients, giving appropriate consideration to the current capital exposure (as well as leverage) to the applicable strategy utilized by the Clients. Under certain circumstances, other criteria will be used in the allocation process. These criteria include those set forth below. Based on the foregoing, Montanova generally will designate the amount of securities to be purchased or sold for each account participating in a bunched order at the time the order is communicated to the trading desk. Such pre-determined allocation will be based upon the risk parameters of each Client. If a bunched order is not completely filled, it will typically be allocated on a pro rata basis to all Clients participating in the order promptly following execution. Where a combined order is executed at more than one price over the course of a day, the executed transactions will be allocated so that each account receives the average unit price and bears its pro rata share of the transaction costs, to the extent reasonably practicable. To the extent that any of those orders remains unfilled following that allocation, the unfilled amount will be combined with subsequent orders in that security, if any, for allocation of subsequent transactions. In certain cases, when Montanova determines that pro rata allocation is not appropriate under the particular circumstances, the allocation will be made based on other factors that Montanova deems appropriate, including, without limitation, the avoidance of a Client holding odd lots or similar de minimis number of shares or the factors set forth below. In such cases, Montanova will increase or decrease the amount of securities that would otherwise be allocated to each Client by reallocating the securities in a manner which Montanova deems fair and equitable to Clients over time. Criteria for Allocations among Montanova Clients

Client already having sufficient exposure to the securities, issuer or market in question; The different liquidity positions and requirements of the participating Clients; Tax considerations; Regulatory considerations; The relative capitalization and cash availability of the participating Clients; The relative risk and value-at-risk profiles of the participating Clients; Different strategies; Portfolio concentration considerations; Informal diversification requirements; Borrowing base considerations; Different historical and anticipated subscription and redemption patterns; Minimum investment criteria; and/or Investment time horizon.

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As stated in Item 12, Montanova may allocate portfolio transactions to brokers or dealers who provide research and/or related services. Montanova has entered into referral or distribution agreements with broker-dealers and other third-party solicitors as placement agents (altogether “Third Party Solicitors”) to introduce the Funds to prospective investors. Pursuant to these agreements, Montanova pays a percentage of the management and/or performance based fee collected from the Client to the Third Party Solicitor. Montanova requires Third Party Solicitors to provide written disclosure to the prospective investor of any such arrangement, including payment arrangements to such parties, if any. Referred investors should ensure that they receive and read the disclosure document from the Third Party Solicitor.

There are no legal or disciplinary events that are material to a Client’s or prospective client’s evaluation of the Adviser’s business or the integrity of the Adviser’s management.

Aaron Cowen, Managing Member and the chief investment officer and portfolio manager of the Long-Short Funds and the SICAV Sub-account, Kishen Mehta, the chief investment officer

and portfolio manager of the Healthcare Funds, and Montanova’s team of investment professionals will be primarily responsible for ensuring that the Funds’ portfolio holdings are consistent with the terms of the management or advisory agreements and the Funds’ disclosures set forth in a Fund’s confidential private placement memorandum. Montanova’s operations team reconciles and reviews all portfolio activity and portfolio reports on a daily basis to ensure accuracy of all securities, quantities and prices contained therein. In addition, Montanova’s operations team performs legal and compliance reviews of each Fund on a daily basis to ensure adherence with compliance requirements. Montanova and/or the Funds’ administrator will generally send Fund Investors unaudited monthly net asset value statements and quarterly letters regarding the performance of the Funds. Fund Investors will also receive annual financial statements produced by an independent public accounting firm within 120 days of the fiscal year end and, if applicable, information necessary for a Fund Investor to complete its annual income tax return.

Even though Montanova does not accept or maintain physical possession of any of its Clients’ assets, Montanova is deemed to have custody of the Funds’ assets under Rule 206(4)-2 of the Advisers Act (the “Custody Rule”) because it has the authority to access the Funds’ assets to deduct fees and expenses. In compliance with the Custody Rule, Montanova maintains all of the Funds’ assets at prime brokers or ISDA counterparties, all of whom are qualified custodians. Montanova also (1) engages an independent public accounting firm, that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, to audit the Clients’ accounts at the end of each fiscal year and (2) distributes the results of the audit in audited financial statements that are prepared in accordance with United States generally accepted accounting principles to all Fund Investors within 120 days after the end of the fiscal year.

Montanova accepts discretionary authority to manage its Clients’ assets through an investment management agreement with its Clients.

Additionally, with respect to the Feeder Funds, before accepting their subscriptions for interests or shares in the Feeder Funds, as applicable, Montanova provides all potential investors in the Feeder Funds with a confidential private placement memorandum, which sets forth in detail the investment strategy and program. By completing the subscription documents to acquire an interest or shares in one of the Feeder Funds, investors give Montanova complete authority to manage the capital contributed in accordance with the offering document received.

Montanova has the authority to vote the proxies of companies on behalf of its Clients. In voting proxies, Montanova is guided by general fiduciary principles. Montanova’s goal is to act prudently, solely in the best interests of its Clients and consistent with efforts to achieve a Client's stated objectives, including maximizing portfolio value. Because Montanova provides investment advice to commingled investment entities, individual investors in the Funds will not be able to direct Montanova on how to cast a proxy vote. It is Montanova’s policy to exercise voting rights on behalf of its Clients in the interest of maximizing the value of the Clients’ assets. Consistent with its fiduciary duty, Montanova will vote in a way that it believes will cause the value of the investment to increase the most or decline the least over time. Consideration will be given to both the short and long term implications of the proposal to be voted on when considering the optimal vote. Montanova has in place voting procedures designed to enable it to resolve material conflicts of interest that may arise between Montanova and its Clients before exercising voting rights. Further, to satisfy any disclosure requirements under Rule 14Ad-1 under the Exchange Act, Montanova has in place recordkeeping policies with respect to votes where Montanova exercised voting power under the SEC’s formulation, relating to shareholder votes approving compensation for “named” executive officers, including “golden parachute” compensation arrangements, as well as how frequently shareholders may approve these compensation arrangements. Montanova is not required to vote every Client proxy and abstaining from voting Client proxies should not necessarily be construed as a violation of Montanova’s fiduciary obligations. Montanova shall at no time ignore or neglect its proxy voting responsibilities. However, there may be times when refraining from voting is in the Clients’ best interest, such as when Montanova’s analysis of a particular Client proxy reveals that the cost of voting the proxy may exceed the expected benefit to the Client. Montanova’s CCO will reasonably try to assess whether Montanova is subject to any material conflict of interest in connection with each proxy vote. So long as there are no material conflicts of interest identified, Montanova will vote proxies according to the policy set forth above. Montanova may also elect to abstain from voting if it deems such abstinence in its Clients’ best interests. It is impossible to anticipate all material conflicts of interest that could arise in connection with proxy voting. Clients may contact the CCO in order to obtain a copy of Montanova's Proxy Voting Policies and Procedures as well as information about how Montanova voted a client's proxies by contacting Andrew Nathanson by email at anathanson@montanova.com or by telephone at (212) 702-5200.

Not Applicable.