Nitor Capital Management LLC

The Adviser is an investment advisory firm with its principal place of business in Englewood Cliffs, New Jersey. The Adviser commenced operations as an investment adviser in 2011. David Spier is the managing member (the “Managing Member”) and owner of the Adviser. The Adviser provides investment advisory services to its clients, which are a private pooled investment vehicle, including sleeves thereof, (collectively, the “Funds” or each a “Fund”) and separately managed accounts (the “Accounts”, and together with the Funds, the “Clients”). The Adviser generally has broad and flexible investment authority with respect to the Clients’ investment portfolios based on specific investment objectives and strategies consistent with the Client’s governing documents. It provides investment advisory services to the Clients based upon each Client’s specific investment objective and strategy. The Adviser’s primary investment objective is to focus on long-term, concentrated investments in publicly traded equities. We tailor our advisory services to the specified investment mandates of our Clients, consistent with the Client’s governing documents, which may include a private placement memorandum, operating agreement, management agreement, and/or subscription agreement (individually and collectively, the “Governing Documents”). The Adviser does not tailor its advisory services to the individual needs of investors in the Fund. As of March 31, 2026, the Adviser had approximately $158,608,573 in client regulatory assets under management, all of which were managed on a discretionary basis.

The Adviser charges the Clients an asset-based investment management fee (the “Management Fee”). The Funds pays a Management Fee up to 1.5% annually. The Accounts pay a Management Fee up to 2% annually. Depending on the Client, the Management Fee is generally payable either monthly in arrears, quarterly in advance, or quarterly in arrears. Generally, the Adviser instructs the Client’s custodian to deduct the Management Fee from the Client’s account or bills the Client for fees incurred. The Management Fee will be prorated for any period that is less than a full fiscal quarter. In addition to the Management Fee, the Adviser is also eligible to receive from the Clients either an incentive fee (the “Incentive Fee”) or an incentive allocation (the “Incentive Allocation”), which is compensation based on a share of realized and unrealized appreciation of the Clients’ account. The Incentive Fee or Incentive Allocation is up to 20% of the Clients net capital appreciation and is subject to a highwater mark or a hurdle rate the details of which are set forth in the Clients Governing Documents. The Incentive Fee or Incentive Allocation, if any, will be billed or allocated at the end of each fiscal year. In addition to paying the Management Fee and allocating or paying the Incentive Fee, Clients may be subject to other investment expenses including but not limited to, Client’s brokerage commissions (see Item 12), due diligence costs, legal and auditing expenses, operating expenses, fund administration, and investment related expenses incurred in connection with the fund’s activities. Depending on the Client, the Adviser, in its sole discretion, has and in the future may waive or reduce the Management Fee and/or Incentive Fee for Clients or members that are principals, employees or affiliates of the Adviser, relatives of such persons, and for certain large or strategic investors.

Nitor creates a diversified portfolio of investments for its Clients. Nitor’s investment philosophy and strategy is to achieve capital appreciation by investing long-term in public equities. Nitor seeks to achieve successful long-term value investing conducted through the identification of companies that have the ability to generate high and sustainable returns on invested capital. METHODS OF ANALYSIS Nitor’s investment approach focuses on the analysis, purchase, and long-term ownership of equity securities. Other than as set forth in the Governing Documents, the Adviser is not subject to any limitations on the amount of capital which may be committed to any one asset class, industry or investment and the Adviser prefers a portfolio of concentrated positions. Accordingly, the Clients may be heavily concentrated. An investment in the Fund or through Accounts is speculative and will be subject to substantial risks, including, without limitation, the Adviser’s investment strategies, the use by the Adviser of certain investment techniques, and the illiquid nature of investments. There is no assurance that the Adviser will achieve its investment objective or will not incur losses, or that it will be profitable. RISK FACTORS The following summary identifies the material risks related to the Adviser’s investment strategy and should be carefully evaluated before making an investment with the Adviser. The following does not intend to identify all possible risks of an investment with the Adviser or provide a full description of the identified risks:

INVESTMENT ACTIVITIES. The Adviser’s investment activities involve a significant degree of risk. The performance of any investment is subject to numerous factors which are neither within the control of nor predictable by the Adviser. Such factors include a wide range of economic, political, technological, competitive and other conditions (including acts of terrorism or war) that may affect investments in general or specific industries or companies. The securities markets may be volatile, which may adversely affect the ability of the Clients to realize profits. As a result of the nature of the investing activities of the Clients, it is possible that the Clients financial performance may fluctuate substantially over time and from period to period. CONCENTRATION OF INVESTMENTS. The concentration of the Clients investments may subject the Client’s to a greater degree of risk with respect to the failure of one or a few investments. At any given time, the assets within the Clients may become highly concentrated within a particular company, industry, asset category, trading style or financial or economic market. In that event, the Client will be more susceptible to fluctuations in value resulting from adverse economic conditions affecting the performance of that particular company, industry, asset category, trading style or financial or economic market, that a less concentrated portfolio would be. As a result, if the Client becomes concentrated, its aggregate return may be volatile and may be affected substantially by the performance of only one or a few holdings. BROKERAGE COMMISSIONS/TRANSACTION COSTS. During some periods, the Client’s activities may involve a high level of trading, and the movement of its portfolio may generate considerable transaction costs. These costs will be borne by the Client regardless of its profitability. LIMITED LIQUIDITY OF INTERESTS. An investment in the Fund involves substantial restrictions on liquidity and its interests are not freely transferable. There is no market for the interests in the Fund, and no market is expected to develop. Additionally, transfers are subject to the consent of the Adviser, which consent may be granted or withheld in the Adviser’s sole discretion. Consequently, investors will be unable to liquidate their interests, except by withdrawing in accordance with the Governing Documents. Investors may be unable to liquidate their investment promptly in the event of an emergency or for any other reason. Although an investor may attempt to increase its liquidity by borrowing from a bank or other institution, interests may not readily be accepted as collateral for a loan. In addition, the transfer of an interest as collateral or otherwise to achieve liquidity may result in adverse tax consequences to the transferor, and in no event shall the Adviser be responsible for any such adverse tax consequences. EQUITY SECURITIES. The Adviser generally expects to primarily invest in equity securities on a long and short basis. The value of equity securities are directly affected by issuer-specific events, as well as general market conditions that can adversely affect the prices of equity securities within a particular industry, market sector or in general. As a result, the Clients may suffer losses if it invests in equity instruments of issuers whose performance diverges from the Adviser’s expectations or if equity markets generally move in an unfavorable direction with respect to the various equity security positions. The Clients also may be exposed to risks that issuers will not fulfill contractual obligations, such as, in the case of convertible securities or private placements, delivering marketable common stock upon conversions of convertible securities and registering restricted securities for public resale. SHORT SELLING. Short selling involves selling securities which are not owned and borrowing them for delivery to the purchaser, with an obligation to replace the borrowed securities at a later date. The extent to which the Client may engage in short sales depends upon the Adviser’s investment strategy and opportunities. A short sale creates the risk of a tentatively unlimited loss, in that the price of the underlying security could theoretically increase without limit, thus increasing the cost to the Clients of buying those securities to cover the short position. There can be no assurance that the Clients will be able to maintain the ability to borrow securities sold short. There also can be no assurance that the securities necessary to cover a short position are available for purchase at or near prices quoted in the market. Purchasing securities to

close out the short position can itself cause the price of the securities to rise further, thereby exacerbating the loss. RISK OF DEFAULT OR BANKRUPTCY OF THIRD PARTIES. Clients may engage in transactions in securities, commodities, other financial instruments and other assets that involve counterparties. Under certain conditions, a Client could suffer losses if a counterparty to a transaction were to default or if the market for certain securities, commodities, other financial instruments and/or other assets were to become illiquid. In addition, a Client could suffer losses if there were a default or bankruptcy by certain other third parties, including brokerage firms and banks with which the Client does business, or to which securities, commodities, other financial instruments and/or other assets have been entrusted for custodial purposes. For example, if the Client’s prime broker and custodian were to become insolvent or file for bankruptcy, the Client could suffer significant losses with respect to any securities held by such firm. DEPENDENCE UPON THE ADVISER AND THE PRINCIPAL. The success of the Clients will depend on the management of the Adviser, and on the skill and acumen of its sole principal. If the principal should cease to participate in the Clients’ business for any period of time, the Clients’ ability to select attractive investments, manage its portfolio and generate trading profits could be severely impaired. Investors should be aware that they will have no right to participate in the management of the Clients, and they will have no opportunity to select or evaluate any of the investments or strategies utilized by the Adviser. OVERALL INVESTMENT RISK. All securities investments risk the loss of total capital. The nature of the securities, instruments, derivatives, and investments to be purchased and traded by the Adviser and the investment techniques and strategies employed may increase this risk. Many unforeseeable events, may result in sharp market fluctuations, which could adversely affect the strategies. There can be no assurance that the investments or investment techniques employed by the Adviser will achieve its investment objectives or that the strategies will be profitable. There can be no assurance that Client accounts will not incur losses.

As described in Item 4, the Adviser’s Clients are a Fund suitable for accredited, institutional and other sophisticated investors and Accounts. In addition, the Adviser is a sub-advisor to a private pooled investment vehicle. Generally, the minimum capital contribution for an investment in the Adviser’s Fund is $500,000. In each case, however, the Adviser and/or its affiliates have sole discretion to accept lesser amounts. Any investment minimums for the Accounts are individually negotiated.

As discussed in Item 5, the Adviser is paid or allocated performance-based compensation by its Clients in the form of an Incentive Allocation or Incentive Fee. Performance-based fee arrangements may create an incentive for the Adviser to recommend investments which may be riskier or more speculative than those which would be recommended under a different fee arrangement. Such fee arrangements may also create an incentive to favor higher fee paying accounts over other accounts in the allocation of investment opportunities. The Adviser has implemented procedures designed to ensure that all clients are treated fairly, and to prevent this conflict from influencing the allocation of investment opportunities among clients. To mitigate such conflicts of interest or potential conflicts of interest, the Adviser has established policies and procedures further described in this in Item 11. Any such incentive fees will comply with the applicable requirements of the Advisers Act and specifically Section 205-3 thereof (otherwise referred to as the “Performance Fee Rule”).

There are no other financial industry activities and/or affiliations to disclose.

The Adviser has adopted a Code of Ethics (the “Code”) that obligates the Adviser and its related persons to put the interests of the Clients before their own interests and to act honestly and fairly in all dealings with Clients. To request a copy of the Code or for additional information, please contact David Spier at dspier@nitorcapital.com. The Adviser, in the course of its investment management and other activities, may come into possession of confidential or material nonpublic information about issuers of securities, including issuers in which the Adviser or its related persons have invested or seek to invest on behalf of its Clients. The Adviser is prohibited from improperly disclosing or using such information for its own benefit or for the benefit of any other person, including its Clients. The Adviser maintains written policies and procedures reasonably designed to prohibit the communication of such information to persons who do not have a legitimate need

to know such information and to otherwise ensure that the Adviser is acting in compliance with applicable law. In certain circumstances, the Adviser may possess certain confidential or material nonpublic information that, if disclosed, might be material to a decision to buy, sell or hold a security. The Adviser and any of its personnel are prohibited from communicating such information with respect to its Clients or using such information for a Client’s benefit. The Adviser and/or its employees could have an investment position or interest in the same securities recommended to or owned by the Clients. As such, the Adviser could purchase or sell for its Clients securities of an issuer in which the Adviser and/or its employees also have an investment position or interest. To the extent the Adviser buys or sells securities for a Client, at or about the same time that the Adviser or related person buys or sells the same securities for its own account the Adviser and the related person, if applicable, will do so in accordance with policies and procedures to minimize conflicts stemming from situations where the contemporaneous trading would result in an economic benefit for the Adviser or its related person to the detriment of a Client. The Adviser recognizes the fiduciary responsibilities it owes to its Clients, which require the Adviser to always act in the Clients best interest. The Adviser has established procedures intended to limit conflicts of interest in cases where the Adviser or a related person buys, sells or otherwise has an interest in securities recommended by the Adviser to its Clients. If a principal transaction or agency cross transaction arises, the Adviser will execute such transaction with the consent of the applicable Client or as otherwise permitted by applicable law. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of a related person, buys from or sells any security to any advisory Client. An agency cross transaction is generally defined as a transaction where a person acts as investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory Client and for another person on the other side of the transaction.

The Adviser may in the future receive brokerage services from a broker-dealer and/or a third party in connection with Client securities transactions. This is known as a “soft dollar” relationship. The Adviser has not entered, and does not anticipate entering, into any formal soft dollar arrangements. To the extent the Adviser does enter into any soft dollar arrangements, the Adviser will limit the use of “soft dollars” to obtain services that constitute research and brokerage within the meaning of Section 28(e) of the Securities Exchange Act of 1934. 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; 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, and services related to the execution, clearing and settlement of securities transactions and functions incidental thereto (i.e., connectivity services between and 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 to the SEC or a self-regulatory organization such as comparison services, electronic confirms or trade affirmations. The Adviser generally executes a Client’s trades with a specified broker-dealer. Given this arrangement, the Adviser typically does not select other broker-dealers to effect transactions and negotiate commissions for

a Client’s account. Other Adviser’s may not require clients to direct a specified broker-dealer. Although the Adviser attempts to affect such transactions in a manner consistent with its policy of seeking best execution, there may be occasions where it is unable to do so. By using a particular broker-dealer to effect transactions such direction may result in certain costs or disadvantages to the Client. Such costs may include but are not limited to higher brokerage commissions (as an example, the Adviser may not be able to aggregate orders to reduce transaction costs) and/or less favorable execution of transactions. By requiring a Client to direct the Adviser to execute the Client’s trades through a specified broker-dealer, the Adviser will make no attempt to negotiate commissions on behalf of the Client and, as a result, in some transactions such Clients may pay materially disparate commissions depending on their commission arrangement with the specified broker-dealer and other factors. The commissions charged to Clients that direct the Adviser to execute the Client’s trades through a specified broker-dealer may in some transactions be materially different than those of Clients who do not direct the execution of their trades or who have directed the Adviser to use a different broker-dealer. Pursuant to the Adviser’s allocation policy, the Adviser may aggregate orders for accounts of multiple Clients in a single transaction. Thereafter, each participating Client receives the average of the prices obtained for the group. If the order is not completely filled, it is the Adviser’s policy that the securities are distributed among participating clients based upon client investment agreements as well as risk tolerance and investment objectives. The Adviser may use the aggregation in its duty to seek best execution for all its Clients. Block trades are used when the Adviser believes that the combination of transactions will provide for better prices or faster execution of its investment actions.

The Adviser does not receive economic benefit from non-Clients in connection with Client transactions and does not compensate any person for Client referrals.

There is no disciplinary information to disclose.

Accounts are reviewed on an ongoing basis by the Adviser’s Managing Member and sole employee, David Spier. More frequent reviews may be triggered by security purchase or sale decisions, account rebalancing, actual or anticipated significant cash flows into or out of an account, and/or changes in investment objectives. Investors receive written reports as described in the Governing Documents.

The Adviser complies, and will continue to comply, with the requirements of the Rule 206(4)-2 of the Advisers Act (“Custody Rule”) with regards to custody of its Fund assets. An investment adviser is deemed to have custody or possession of client funds or securities if the adviser directly or indirectly holds client funds or securities or has the authority to obtain possession of them (regardless of whether the exercise of that authority or ability would be lawful). An investment adviser is deemed to have custody if it or its affiliate serves as a manager to a client of the Adviser. If the Adviser has custody of client assets and securities, it is required to maintain such assets and securities (except for securities that meet the privately offered securities exemption in the Custody Rule) over which it has custody with a “qualified custodian.” Qualified custodians include banks, broker-dealers, futures commission merchants and certain foreign financial institutions.

Rule 206(4)-2 generally imposes on advisers with custody of clients’ funds or securities certain requirements concerning reports to such clients (including underlying investors in certain circumstances) and surprise examinations relating to such clients’ funds or securities. Clients that receive account statements directly from a custodian should carefully review these account statements. However, the Adviser need not comply with such requirements with respect to pooled investment vehicles if the pooled investment vehicle: (i) is audited at least annually by an independent public accountant, and (ii) distributes its audited financial statements prepared in accordance with generally accepted accounting principles to the client, or, in certain circumstances, all limited partners, members or other beneficial owners, within 120 days of its fiscal year end. The Adviser intends to rely upon this exception, and therefore will be exempt from the Rule 206(4)-2 reporting and examination requirements, with respect to the Fund. The assets of the Accounts are held by a custodian as disclosed in the applicable Governing Documents. The Adviser is not authorized to open accounts in the name of a Client. At times, the Adviser will debit certain fees from its Client’s accounts. Each Client is urged to carefully review the statements it receives from the broker-dealer, bank, or custodian and compare such statements to any statements received from the Adviser.

The Adviser provides investment advisory services on a discretionary basis to Clients. Please see Item 4 for a description of any limitations Clients may place on the Adviser’s discretionary authority. Prior to assuming full discretion in managing a Client’s assets, the Adviser enters into an agreement that sets forth the scope of the Adviser’s discretion. Unless otherwise instructed or directed by a discretionary Client, the Adviser has the authority to determine: (1) which securities or instruments to buy or sell; (2) total amount of securities or instruments to buy or sell and (3) the executing broker or dealer for any transaction. Because of the differences in Client investment objectives and strategies, risk tolerances, tax status and other criteria, there may be differences among Clients in invested positions and securities held, and it is possible that different Clients will hold opposing positions.

The Adviser complies with its proxy voting policies and procedures that are designed to ensure that in cases where the Adviser votes proxies with respect to a Client’s securities, such proxies are voted in the best interests of the Client. If a material conflict of interest between the Adviser and a Client exists, the Adviser will determine whether voting in accordance with the guidelines set forth in the proxy voting policies and procedures is in the best interests of the Clients or take some other appropriate action. For additional information about the Adviser’s proxy voting policies and procedures and information about how the Adviser voted the Clients’ proxies, please contact David Spier at dspier@nitorcapital.com.

Nitor does not require or solicit the payment of fees six months or more in advance.

Nitor has no financial condition that is reasonably likely to impair its ability to meet contractual and fiduciary commitments to its clients. Nitor has never been the subject of a bankruptcy petition.