Owl Creek Asset Management, L.P.

The Investment Manager is a Delaware limited partnership founded in 2001. It is located in New York, NY, but certain services provided by the Investment Manager may be performed from Miami Beach, with certain employees working remotely from their home offices. Owl Creek Advisors, an affiliated Delaware limited liability company, serves as the general partner of several funds advised by the Investment Manager and also serves as a managing member of several general partners as described below. Owl Creek primarily provides investment management services to private pooled investment vehicles. These private investment vehicles are structured as Delaware limited partnerships and Cayman Islands exempted companies or limited partnerships.

In connection with providing investment management services to its clients, Owl Creek has been appointed as investment manager with discretionary trading authority. Additional detailed information about Owl Creek is provided below, including information about Owl Creek's advisory services, investment approach, personnel, affiliations and brokerage practices. The Investment Manager serves as the investment manager to six investment partnerships organized under the laws of the State of Delaware: Owl Creek I, L.P. ("Owl Creek I"), Owl Creek II, L.P. ("Owl Creek II"), Owl Creek Credit Opportunities Fund, L.P. (the “Credit Domestic Fund,”), the Owl Creek Special Situations Fund, L.P, (the “OCSS Fund”), the Owl Creek Credit Solutions Fund, L.P. (the “OC Solutions Fund”), and the Owl Creek Aviation Opportunities Fund, L.P. (the “Owl Creek Aviation Fund”, and collectively with Owl Creek I, Owl Creek II, Credit Domestic Fund, OCSS Fund and the OC Solutions Fund, the "U.S. Funds"). Owl Creek Advisors, a limited liability company organized under the laws of the State of Delaware (“OCA”) affiliated with the Investment Manager, serves as the general partner of Owl Creek I, Owl Creek II, and the OCSS Fund. Owl Creek Credit Opportunities Advisors, LLC, a limited liability company organized under the laws of the State of Delaware (“OCCOA”) affiliated with the Investment Manager, serves as the general partner of the OC Solutions Fund. Owl Creek Aviation GP, LLC, a limited liability company organized under the laws of the State of Delaware affiliated with the Investment Manager, serves as the general partner of the serves as the general partner of the Owl Creek Aviation Fund (“OCAGP” together with OCA and OCCOA, the "General Partner"). OCA is the managing member of both OCCOA and OCAGP. Interests in Owl Creek I, (collectively the “3(c)(1) Funds”) are offered on a private placement basis, and in reliance on Section 3(c)(1) of the Investment Company Act of 1940, as amended (the "Company Act"), to persons who generally are "accredited investors" as defined under the Securities Act of 1933, as amended (the "Securities Act"), and subject to certain other conditions, which are set forth in the offering documents for the applicable 3(c)(1) Funds. The interests in Owl Creek II, Credit Domestic Fund, the OCSS Fund, the OC Solutions Fund, and the Owl Creek Aviation Fund are offered on a private placement basis, and in reliance on Section 3(c)(7) of the Company Act, to persons who generally are "accredited investors" as defined under the Securities Act and "qualified purchasers" as defined under the Company Act, and who are subject to certain other conditions, which are set forth in the offering documents for the applicable Funds. The Investment Manager is also the investment manager to the following investment funds organized under the laws of the Cayman Islands: Owl Creek Overseas Fund, Ltd. ("Owl Creek Overseas"), Owl Creek Credit Opportunities Fund, Ltd. (“Credit Offshore Fund,” and together with Owl Creek Overseas, the "Offshore Funds"). The Offshore Funds together with the U.S. Funds, the Credit Intermediate Fund (as defined below) and the Master Funds (as defined below) are each referred to as a “Fund” and collectively, as the "Funds". Shares in the Offshore Funds are generally offered to persons (x) who are not "U.S. Persons," as defined under Regulation S of the Securities Act, or who are tax-exempt U.S. Persons (or entities substantially comprised of tax-exempt U.S. Persons) on a private placement basis, and (y) who are subject to certain other conditions, which are fully set forth in the offering documents for the Offshore Funds.

To effect their respective investment objectives, Owl Creek Overseas invests its assets in Owl Creek Overseas Master Fund, Ltd. ("Owl Creek Overseas Master Fund"), and the Domestic Credit Fund invests its assets in Owl Creek Credit Opportunities Master Fund, L.P. (the “Owl Creek Credit Master Fund”) and the Offshore Credit Fund invests its assets in Owl Creek Credit Opportunities Intermediate Fund, L.P. (the “Credit Intermediate Fund”), a Cayman Islands limited partnership, which in turn invests in the Owl Creek Credit Master Fund (Owl Creek Overseas Master Fund, and Owl Creek Credit Master Fund, each, a "Master Fund" and collectively, the "Master Funds"). Each of the Master Funds is a Cayman Islands exempted company, except Owl Creek Credit Master Fund which is organized as a Cayman Islands limited partnership. The Investment Manager also serves as the investment manager to each Master Fund and the Intermediate Fund. Owl Creek Advisors serves as the management company to Owl Creek Overseas Master Fund and in that capacity has the overall responsibility for the investment strategy of such Master Fund, subject to the policies and control of the board of directors of such Master Fund. In such capacity, Owl Creek Advisors is referred to herein as the "Manager." Owl Creek Advisors also serves as the general partner of the Owl Creek Credit Master Fund and the Intermediate Fund. The Investment Manager may advise managed accounts and other Clients in the future. Owl Creek I, Owl Creek II, Owl Creek Overseas, and Owl Creek Overseas Master Fund, are referred to herein as the "Flagship Funds." The Domestic Credit Fund, Offshore Credit Fund, Credit Intermediate Fund, and Owl Creek Credit Master Fund are referred to herein as the “Credit Funds.” The Flagship Funds, Credit Funds, the OCSS Fund, the OC Solutions Fund and the Owl Creek Aviation Fund are collectively referred to herein as the “Clients” (and each such Fund shall be referred to as a “Client”). OCSS is presently not seeking additional investment as its full capital has been drawn and certain investments realized. The OC Solutions Fund is seeking additional capital, and the Owl Creek Aviation Fund is closed to additional investors. Owl Creek has full discretionary authority with respect to investment decisions on behalf of each Client. Owl Creek’s advice with respect to each Client is tailored according to each Client’s investment objectives, guidelines, and requirements as set forth in each Client’s respective offering memoranda, investment management agreement, sub-advisory agreements, or investment guidelines, as the case may be. Owl Creek does not participate in any Wrap Fee Programs. New Classes/Side Letter Agreements Owl Creek and the Funds may establish new classes of shares/interests and has issued other classes of shares/interests to, and may and has entered into "side letter" agreements with, certain investors which terms differ from the shares/interests generally offered to investors with respect to, among other things, the Incentive Allocation (as defined below) and Management Fee (as defined below), redemption and withdrawal rights (including more frequent redemption or withdrawal dates), informational rights and other rights. Owl Creek and/or a Fund may establish new classes of shares/interests or enter into "side letter" arrangements without providing prior notice to, or receiving consent from, existing investors. The terms of such classes and "side letters" will be determined by Owl Creek and/or such Fund in their sole discretion. Ownership and AUM

Owl Creek was founded in 2001 and is primarily owned by Jeffrey Altman (“Altman”). As of December 31, 2025, Owl Creek managed approximately $1.66 billion (including all withdrawals and redemptions effective as of such date) on a discretionary basis, on behalf of 11 clients. Assets under management (“AUM”) 1 reflect net assets invested by external investors and our related parties in our Funds, plus any unfunded commitments. “Regulatory Assets Under Management” as of the same date was $2.46 billion (including withdrawals effective as of such date). Regulatory Assets Under Management (as defined by the SEC, “Reg. AUM”) reflect the Balance Sheet value of Gross Assets plus any unfunded commitments. Gross exposure (being the market value of long and short positions) may exceed Regulatory Assets under Management. Unfunded commitments included in AUM and Reg. AUM were $92 million at December 31, 2025.

The fees and expenses applicable to each Fund are set forth in detail in each of the Fund's respective offering documents. A brief summary of those fees and expenses is provided below. U.S. Funds—Management Fees With respect to Owl Creek I and Owl Creek II, each Fund generally pays Owl Creek at the beginning of each quarter, an amount ("Management Fee") equal to 0.375% (1.5% annualized) of a limited partner's beginning capital account for such quarter (prorated for partial periods). With respect to the Credit Domestic Fund, the Fund generally pays Owl Creek at the beginning of each quarter a Management Fee equal to 0.375% (1.5% annualized) of a limited partner’s beginning capital account for such quarter (prorated for partial periods). The OCSS Fund is not currently being offered to investors, but the management fee terms applicable in respect of the existing investors in the OCSS Fund are set forth in that Fund’s limited partnership agreement. The OC Solutions Fund is currently being offered to investors and generally pays Owl Creek at the beginning of each quarter a Management Fee equal to 0.3125% (1.25% annualized) of a limited partner's invested capital for such quarter (prorated for partial periods and subject to change in the event of certain dispositions and write-downs). The Owl Creek Aviation Fund is not currently being offered to investors and generally pays Owl Creek at the beginning of each quarter a Management Fee equal to 0.175% (0.70% annualized) of a limited partner's invested capital for such quarter (prorated for partial periods and subject to change in the event of certain dispositions and write-downs). With respect to all of the U.S. Funds, a pro rata portion of any Management Fee paid in advance will be repaid by Owl Creek to the relevant Fund and distributed to any limited partner that is permitted to withdraw prior to the end of a quarter. For the purpose of calculating the Management Fee, a limited partner's capital account shall include the fair value, as determined by Owl Creek, of certain investments which Owl Creek believes either lack a readily assessable market value or should be held until the resolution of a special event or circumstance ("Special Investments") in which such limited partner has an interest. For the Flagship Funds and the Credit Funds if, after giving effect to a withdrawal, a capital account would be completely withdrawn from a U.S. Fund except for its interest in one or more Special

We are using a definition here consistent with “Net assets under management” per the Form PF Glossary of Terms

Investments, the General Partner may determine to reserve or hold back a portion of the proceeds with respect to such withdrawal that is required, in its reasonable discretion, to pay for the Management Fees expected to be earned over the life of the Special Investments in which such capital account has an interest (the "Management Fee Reserve"). The Management Fee Reserve is not segregated from the applicable Fund’s assets and does not earn interest. Any remaining amount of the Management Fee Reserve will be distributed to the holder of such capital account together with the withdrawal proceeds upon the realization of such Special Investments. If the Management Fee Reserve is insufficient, the relevant U.S. Fund will bill the holder of such capital account quarterly for Management Fees attributable to the Special Investments in which such capital account has an interest. If the full amount of an invoice is not paid by the date provided on such invoice, the General Partner may, in its sole discretion, reduce the amount of any proceeds paid with respect to such Special Investments by an amount equal to the unpaid invoice, together with interest thereon at a market rate, as determined by the General Partner. Owl Creek may, in its discretion, elect to reduce or waive the Management Fee with respect to any limited partner of the U.S. Funds. Owl Creek typically waives the Management Fee with respect to Owl Creek affiliates. Management fees are deducted from investors' accounts. U.S. Funds—Incentive Allocation The General Partner is generally entitled to an amount (the "Incentive Allocation") equal to 20% of the net capital appreciation of each U.S. Fund (excluding the OCOPP Funds’, the OC Solutions and the Owl Creek Aviation Fund Incentive Allocation – as described below). Except as provided below with respect to Special Investments, net capital appreciation includes both realized gains and losses and unrealized gains and losses of securities held in each U.S. Fund's portfolio. Generally, any net capital depreciation in a fiscal year allocated to any limited partner is carried forward so that no Incentive Allocation is borne by such limited partner unless the losses have been recouped, subject to certain adjustments. A portion of each applicable U.S. Fund's assets may be invested in Special Investments that may be maintained in special situation sub-accounts, in which case they are generally not subject to any Incentive Allocations until a gain is realized (or deemed realized). Such Special Investments generally are subject to the Management Fees described above and will be carried at fair value, as determined by the General Partner, for the period that they are maintained in such special sub-accounts. The Incentive Allocation in respect of the OC Solutions Fund will generally be equal to 15% of net profits after an 8% hurdle is achieved and investor capital is returned. The Incentive Allocation in respect of the Owl Creek Aviation Fund will generally be equal to 10% of net profits after a 6% hurdle is achieved and investor capital is returned. The General Partner may, in its discretion, elect to reduce or waive the Incentive Allocation with respect to any limited partner of the U.S. Funds, including, but not limited to, any affiliate of the General Partner. The General Partner reserves the right to waive or impose different fees or allocations or otherwise modify the fee or allocation arrangements of an existing investor in a U.S. Fund with the consent of such investor. In addition, each U.S. Fund reserves the right to impose different fees or allocations on future investors. In exchange for increased fees or allocations, such investors may receive more frequent withdrawal dates and less notice required upon withdrawal than other investors in such Fund. Owl Creek has provided certain investors in the U.S. Funds other significant rights, such as

reduced fees, more frequent liquidity terms, access to information and capacity rights, which are not offered generally to other investors in the U.S. Funds. See "New Classes/Side Letter Agreements" in Item 4. Offshore Funds—Management Fees With respect to Owl Creek Overseas, the Fund generally pays Owl Creek a Management Fee, payable quarterly (prorated for partial periods), in advance, equal to 0.375% (1.5% annualized) for Owl Creek Overseas of the NAV of each series of shares as of the beginning of the quarter prior to any accrual for Incentive Allocation. With respect to the Offshore Credit Fund, the Credit Offshore Fund generally pays Owl Creek a Management Fee, payable quarterly (prorated for partial periods), in advance, equal to 0.375% (1.5% annualized) of the NAV of each series of shares of the Fund as of the beginning of the quarter. With respect to all of the Offshore Funds, a pro rata portion of any Management Fee paid in advance will be repaid by Owl Creek to the relevant Fund and distributed to any shareholder that is permitted to redeem prior to the end of a quarter. Owl Creek may designate an investment made by Owl Creek Overseas and / or the Offshore Credit Fund as a Special Investment, in which case, a pro rata portion of each series of shares will be automatically exchanged by way of redemption and issuance of a new class of shares (generally Class C Shares). In calculating the Management Fees paid, these shares are valued at fair value. If, after giving effect to a redemption, a shareholder only owns shares relating to Special Investments, the relevant Fund may determine to reserve or hold back a portion of the proceeds with respect to such redemption in order to establish a Management Fee Reserve to pay for the Management Fees expected to be earned over the life of such Special Investments. The Management Fee Reserve is not segregated from the applicable Fund’s assets and does not earn interest. Any remaining amount of the Management Fee Reserve will be distributed to the Fund, and in turn, to the shareholder together with the redemption proceeds upon the realization of such Special Investments. If the Management Fee Reserve is insufficient, the relevant Offshore Fund will bill the shareholder quarterly for Management Fees attributable to the Special Investments attributable to such shareholder. If the full amount of an invoice is not paid by the date provided on such invoice, such Offshore Fund may, in its sole discretion, reduce the amount of any proceeds paid with respect to such Special Investments by an amount equal to the unpaid invoice, together with interest thereon at a market rate, as determined by such Offshore Fund. In the sole discretion of Owl Creek, the Management Fee may be reduced or waived with respect to any shareholder of the Offshore Funds. Owl Creek typically waives the Management Fee with respect to Owl Creek affiliates. Management fees are deducted from investors' accounts. Offshore Funds—Incentive Allocation Generally, at the end of the fiscal year of each of the Offshore Funds an Incentive Allocation equal to 20% of the net realized and unrealized appreciation (taking into account gains and losses with respect to realized or deemed realized Special Investments allocated during such year) in the NAV of each series of shares of the relevant Master Fund corresponding to a series of shares of the

corresponding Offshore Fund during each fiscal year (after adjustments for any redemption of shares in such series and accruals for the Incentive Allocation made with respect to redemptions made during such year (if any) and after taking into account the Management Fee and any net expenses that are charged at the Offshore Fund level and are not otherwise reflected in such Master Fund's NAV) will be reallocated from the NAV of such Master Fund series to the NAV of the Class M Shares of such Offshore Fund (which are held by the Manager); provided, however, that an Incentive Allocation will only be made with respect to the net realized and unrealized appreciation in the NAV of a series of shares of such Master Fund in excess of its Prior High Net Asset Value. The "Prior High Net Asset Value" of a series of shares of a Master Fund is the NAV of that series immediately following, and after reduction for, the most recent calculation of the Incentive Allocation with respect to such series (or if no Incentive Allocation has yet been determined with respect to such series, the NAV of the series immediately following its initial offering). The Prior High Net Asset Value of a series will be adjusted for redemptions (including redemptions of any shares of a series exchanged for Class C Shares) and distributions (excluding any distributions relating to the Management Fee) and for expenses charged at the corresponding Offshore Fund level (with respect to Owl Creek Overseas Master Fund only) made subsequent to the date on which the last Incentive Allocation with respect to such series was determined. Special Investments, represented by Class C Shares, generally are not subject to Incentive Allocation until a gain is realized (or deemed realized). With respect to the Offshore Credit Fund, at the end of each fiscal year of the Intermediate Fund (December 31), the General Partner will generally allocate to the General Partner an Incentive Allocation equal to 20% of the net realized and unrealized appreciation (taking into account gains and losses realized or deemed realized by Owl Creek with respect to Special Investments) allocated to the Intermediate Fund capital account corresponding to each series of shares of the Offshore Credit Fund (each, a “Series Capital Account”) for such fiscal year (after adjustments for any redemption of shares in such series and accruals for the Incentive Allocation made with respect to redemptions made during such year (if any) and after taking into account the Management Fee and any net expenses that are incurred at the Offshore Credit Fund level that are not otherwise reflected in the Intermediate Fund’s net asset value). The Intermediate Fund maintains a memorandum loss recovery account (a “Loss Recovery Account”), sometimes called a “high water mark,” for each Series Capital Account. For each fiscal year, each Loss Recovery Account is debited with the aggregate net capital depreciation, if any, allocated to such Series Capital Account for such fiscal year (taking into account gains and losses realized or deemed realized from Special Investments, Special Investment Income and expenses of the Offshore Credit Fund) and credited, but not beyond zero, with the aggregate net capital appreciation, if any, allocated to such Series Capital Account for such fiscal year (taking into account gains and losses realized or deemed realized from Special Investments, Special Investment Income and Feeder Expenses). The General Partner will not be allocated any Incentive Allocation with respect to a Series Capital Account until such Series Capital Account has recovered any negative balance in its Loss Recovery Account. The amount which must be recovered will be adjusted for withdrawals of capital. The aggregate incentive allocation allocated to Owl Creek (“Incentive Allocation”) is deducted from investors' series of shares.

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The investment strategies, methods of analysis, and (material) risks applicable to each Fund are set forth in detail in each of the Fund's respective offering documents. A brief summary of those investment strategies, methods of analysis, and (material) risks is provided below.

The descriptions set forth in this Brochure of specific advisory services that Owl Creek offers to Clients, and investment strategies pursued, and investments made by Owl Creek on behalf of its Clients, should not be understood to limit Owl Creek’s investment activities in any way. Owl Creek may offer any advisory services, engage in any investment strategy, and make any investment, including any not described in this Brochure, that Owl Creek considers appropriate, subject to each Client's investment objectives and guidelines. The investment strategies Owl Creek pursues are speculative and entail substantial risks. Clients should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any Client will be achieved. Investment Strategies and Methods of Analysis The investment objective of the Flagship Funds is to seek above average returns through an opportunistic event-driven value strategy. Owl Creek generally employs an investment strategy for the Flagship Funds, which includes, among other strategies, (i) event-driven investing, (ii) fundamental, value driven long/short equities, and (iii) long/short credit incorporating long distressed investments. Owl Creek analyzes each potential investment using a “bottom-up” analysis. The conclusions reached from this “bottom-up” approach are used to purchase or sell short a variety of financial instruments including, but not limited to, listed and unlisted common stocks, preferred stocks, convertible securities, American Depository Receipts, SPACS, public and private debt issues (including bank loans and trade claims), rights, warrants, put and call options, swaps, forward contracts, when-issued securities and other derivatives, including futures contracts. In addition to investing directly, the Funds may invest indirectly from time to time through special purpose vehicles. Owl Creek may use leverage in connection with the Clients' investment program. Generally, leverage is utilized as determined by Owl Creek, subject to applicable investment guidelines and legal and regulatory limitations. Owl Creek may invest a portion of the Clients' assets in registered investment companies, including, but not limited to, exchange-traded funds and closed-end funds, subject to Company Act limitations and applicable investment guidelines. Advisers to such funds charge a management fee and performance compensation in addition to fees charged by Owl Creek. The investment objective of the Credit Funds is to generate positive absolute returns, while minimizing the risk of loss of principal. The Credit Funds seek to achieve this investment objective through opportunistic investments across the credit spectrum. Owl Creek generally employs a fundamental, value investment approach in selecting investments on behalf of the Credit Funds. Owl Creek generally utilizes a fundamental, “bottom-up” investment process. The Credit Funds focus on various credit-related investment strategies, including distressed, eventdriven and long-short investment strategies. The Credit Funds seek to exploit the mispricing of securities and other instruments via both long and short positions. The Credit Funds invest primarily in bank debt, including revolving credit facilities, bridge financings, debtor-in-possession financings, corporate bonds, including high-yield debt, receivables and trade claims, sovereign debt, and credit default swaps and other credit-related derivatives. The Credit Funds may also invest in aviation leasing opportunities, futures and forward contracts, options, and convertible securities, preferred stock and equities of private and public issuers, SPACS, litigation financings, as well as asset-backed securities, mortgages, loans, and real estate and real-estate related securities.

A material portion of the Credit Funds’ portfolio is comprised of illiquid investments that are not designated as Special Investments and are classified as Level 3 assets (i.e., assets whose fair value is determined using significant unobservable inputs). Of these, many relate to aviation-related leasing opportunities in aircraft engine leasing to a broad range of international airlines and limited U.S. airlines. Other Level 3 assets may also include litigation claims, certain private investments that arose from historic restructurings (but incorporate a broad range of debt or equity instruments listed above), or other Credit Fund investments. A large proportion of Level 3 assets are subject to periodic external independent third party valuations. The investment program of the OCSS Fund is to invest in investments that are also made by the Flagship Funds and/or Credit Funds if Owl Creek determines, in its sole discretion, that (a) such other funds have acquired, in the aggregate, an allocation of such investments that is appropriate for such other funds at such time and (b) such investments can be acquired at attractive prices relative to Owl Creek’s assessment of the applicable investment’s potential for long-term appreciation prior to the end of the OCSS Fund’s investment period, provided that Owl Creek may also determine, in its discretion, to allocate investments to other Clients, to the extent that it determines in its sole discretion, that such other Clients have additional capacity for such investments. The investment objective of the OC Solutions Fund is to create value by employing a global, valueoriented approach to event-driven and opportunistic credit investments with a focus on distressed opportunities, event-driven credit, litigation, liquidations, and hard-asset leasing opportunities. The investment objective of the OC Solutions Fund may have some overlap with other funds managed by Owl Creek, in particular the Credit Funds. The Owl Creek Aviation Fund seeks to generate attractive risk-adjusted returns through the acquisition and leasing of commercial aviation engines and related hard assets. The Fund focuses primarily on acquiring engines that are already on lease, or can be promptly leased, to creditworthy counterparties. Such counterparties are usually international airlines. The strategy emphasizes engines with remaining greentime, enabling the Fund to generate recurring contractual lease payments and maintenance reserve income while targeting asset disposition prior to major maintenance events. Investments may be structured through special purpose vehicles and may utilize asset-level leverage, subscription facilities, and other financing arrangements. The investment objective of the Owl Creek Aviation Fund has overlap with other funds managed by Owl Creek, in particular the Credit Funds and the OC Solutions Fund. Event Driven Transactions: Across both distressed debt and equities, both long and short, Owl Creek will pursue opportunities that are event driven in nature. It is the belief of Owl Creek that mispriced securities are most abundant in situations where a company or industry is undergoing a large, material change. Furthermore, securities which have a risk/reward profile which is dependent on the outcome of a certain situation will have some lesser amount of overall market exposure as a result, which we consider important to generate above average returns. Some examples of event driven situations include restructurings, mergers, asset injections, recapitalizations, rights offerings, divestitures and spin-offs, post-bankruptcy equities, litigation plays, potential changes in laws and regulations, and situations where an activist investor is trying to unlock value buried in a company. Owl Creek may also play an activist role if in doing so it believes it will help a particular security realize its full

value, but this will be a secondary alternative as the primary objective is to be a passive long-term investor. Long/Short Equities: Owl Creek typically takes positions in equity securities of companies that Owl Creek has identified as undervalued (long equity positions) and overvalued (short equity positions). Owl Creek generally will purchase equity securities of companies with strong long-term fundamentals when the securities can be purchased at a discount to the perceived present value of a future stream of cash flows to the stockholder, or which in other ways represent assets with an attractive risk/reward profile. As Owl Creek focuses on the long-term cash generating potential of companies, it will seek to take advantage of price volatility caused by shorter-term concerns, such as temporarily disappointing financial performance, and purchase equity securities at attractive levels. Alternatively, Owl Creek usually will short equity securities of overvalued companies when an identifiable catalyst exists for eliminating the spread between price and fair value. Research, Analysis, Sources of Information: To determine whether a specific investment meets the Clients' investment guidelines, the Investment Manager typically performs extensive financial analysis of the company's underlying business fundamentals. The Investment Manager does research which may include making a determination of the company's competitive position, financial needs, liquidity, industry prospects as well as a liquidation value analysis. The Investment Manager may do an analysis of the company's financial statements, including a comparative analysis of margins and changes in balance sheet items in comparison with the company's competitors. The analysis of both equity and debt may include discounted cash flow analysis and centers on absolute (not relative) value. The Investment Manager also considers low cash flow multiples with solid long-term fundamentals. The Investment Manager looks for drivers or catalysts that will serve to close the value gap within the investment time horizon, which will usually be within a range of nine to twenty-four months. Owl Creek utilizes many sources of information in its analyses of investments. These sources include, but are not limited to, financial filings; business, economic, financial and other publications; trade journals; third-party data services; outside research; and one-on-one conversations with company management teams, suppliers, customers, end users and sector specialists, as well as lawyers, lobbyists and academic specialists. In addition, Owl Creek may employ third-party consultants, other investment managers and other third parties to provide it with fundamental and technical research, including, but not limited to, information regarding various markets, industries, assets and companies. Risk of Loss The following risk factors do not purport to be a complete list or explanation of the risks involved in an investment in the Funds. These risk factors include only those risks Owl Creek believes to be material, significant or unusual and relate to particular significant investment strategies or methods of analysis employed by Owl Creek. All investing involves a risk of loss that clients should be prepared to bear. The investment strategies offered by Owl Creek could lose money over short or long periods of time. Identifying undervalued securities and other assets is difficult, and there are no assurances that Owl Creek's

investment strategies will succeed. Furthermore, Clients may be forced to hold such investments for a substantial period of time (e.g., Special Investments in the case of certain Funds) before realizing any anticipated value. Owl Creek cannot give any guarantee that it will achieve a Client’s investment objectives or that any Client will receive a return of its investment. Investors should ultimately refer to the Funds’ respective offering documents for which Owl Creek provides sub-advisory services for detailed risk disclosures that specifically address risks of each Client's investment strategies, methods of analysis, and/or particular types of securities recommended. Below is a summary of potentially material risks for each significant Owl Creek investment strategy used, the methods of analysis used, and/or the particular type of security recommended. Please note that Owl Creek's use of the term "investor" in this section may refer to either a limited partner in a U.S. Fund or a shareholder in an Offshore Fund.

Risk of Loss. No guarantee or representation is made that the Funds’ investment programs, including the investment objective, diversification strategies or risk monitoring goals, will be successful. Investment results may vary substantially over time. No assurance can be made that profits will be achieved or that substantial or complete losses will not be incurred. Past investment results of the Investment Manager (or investments otherwise made by the investment professionals of the Investment Manager) are not necessarily indicative of their future performance.

General Investment and Trading Risks - Clients invest in equity securities and other financial instruments using investment techniques with significant risk characteristics. The Clients’ investment programs utilize such investment techniques as short sales, leverage, options, swaps and other derivatives investments, including futures contracts, which practices can, in certain circumstances, maximize the adverse impact to which the Clients may be subject.

Dependence on Key Individuals. The success of the Funds depends upon the ability of Mr. Altman and Mr. Daniel Krueger to develop and implement investment strategies that achieve the Partnership's investment objectives. If Mr. Altman and/or Mr. Krueger were to become unable to participate in the management of the Funds, the consequences to the Funds would be material and adverse.

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Owl Creek provides advice to the U.S. Funds and the Offshore Funds, which are private investment funds, as described above. Investors in the Funds may include some or all of the following: individuals, banks or thrift institutions, investment companies, pension and profit-sharing plans, trusts, estates or charitable organizations, or corporations or business entities other than those listed previously, private investment funds or other entities. Investors in the Funds are generally required to make minimum initial investments of at least $5 million. The Board of Directors (for the Offshore Funds) or the General Partner (for the U.S. Funds) may waive the minimum initial investment amount. Additional investments in the Funds by existing investors generally must be in the minimum amount of $100,000. Investors in the Funds are persons who generally are (x) "accredited investors" as defined under the Securities Act or (y) not U.S. Persons (as defined under Regulation S of the Securities Act). In addition, investors in Owl Creek II, Owl Creek Overseas, the Domestic Credit Fund Offshore Credit Fund, OCSS Fund, OC Solutions Fund and the Owl Creek Aviation Fund who are U.S. Persons (as defined under Regulation S of the Securities Act) must generally be "qualified purchasers" as defined under the Investment Company Act or have an exemption under that Act making them eligible to invest.

Owl Creek and its affiliates may receive performance-based fees or allocations in respect of the Funds as described in Item 5 above. In allocating investment opportunities between accounts,

performance-based fee/allocation arrangements may also create an incentive to favor accounts from which an adviser will receive a greater performance fee/allocation over accounts from which an adviser will receive a lesser performance fee/allocation (e.g., if a Fund is below its “high water mark” and another Fund is not). Performance-based compensation arrangements may also create an incentive for an investment adviser to recommend investment opportunities that may be riskier or more speculative given the adviser’s potentially greater participation in upside performance than would be the case in fixed asset-based fee arrangements. However, Owl Creek has adopted investment allocation policies designed to ensure that investments are suitable for Clients and all Clients are treated fairly and equitably and to prevent these conflicts of interest from influencing the allocation of investment opportunities among Clients. The Flagship Funds, Credit Funds, the OCSS Fund, the OC Solutions Fund and the Owl Creek Aviation Fund are subject to both forms of compensation. The side-by-side management of these types of funds may create a potential conflict, as more compensation may be payable in respect of accounts subject to both fixed fees and performance-based compensation arrangements. However, Owl Creek has adopted investment allocation policies and procedures designed to allocate investment opportunities among Clients (including the OCSS Fund, the OC Solutions Fund and the Owl Creek Aviation Fund, where consistent with their investment objectives and guidelines) to ensure that investments are allocated in a fair and equitable basis over time among all suitable Clients, regardless of the fee and compensation arrangements.

As indicated above, the General Partner serves as the general partner to the U.S. Funds and certain Offshore Funds. The Investment Manager and the General Partner are each exempt from registration with the CFTC pursuant to CFTC Rule 4.13(a)(3). The General Partner is associated with Owl Creek and provides investment advisory services to each U.S. Fund and Master Fund. The General Partner will comply, in all respects, with SEC rules that apply to registered advisers. Personnel of the General Partner, if any, will be deemed to be associated persons of the Investment Manager and will be subject to the Investment Manager’s compliance program.

The Investment Manager and its SPV General Partner Affiliates do not have any other relationships or arrangements with other financial services companies that pose material conflicts of interest.

Transactions and Personal Trading

Owl Creek and its personnel do not purchase or sell any securities for their own accounts from or to Clients (however, certain Funds may be deemed to be principal accounts under applicable SEC guidance to the ownership interest of persons affiliated with the Investment Manager, and such Funds may engage in cross transactions pursuant to the process described below). Subject to applicable laws as well as each Fund's respective investment guidelines and restrictions, Owl Creek may enter into internal cross transactions between the Funds for the purpose of rebalancing the portfolios of such Funds (certain Funds may be deemed to be principal accounts under applicable SEC guidance). Such transactions may be affected by direct purchases and sales of securities (and other instruments) by/from one Fund from/to another Fund or by increasing or decreasing a Fund's participation in securities that are held through special purpose vehicles in which two or more of the Funds are members. Owl Creek effects these transactions at a predetermined time, generally after the close of the market on the last business day of each month, pursuant to a formula that generally will result in each Fund holding substantially similar securities relative to each Fund's respective net asset value. With respect to publicly traded securities, Owl Creek effects these transactions based on the then current independent market price as of the applicable month end (although effected at month end, final valuations for equity securities are not finalized until the first business day of the following month, and the valuation of credit instruments is generally not finalized until approximately the fourth day of the following month). All cross transactions are affected at prices determined in accordance with the valuation procedures established by Owl Creek for all Funds. With respect to bank debt and similar securities held through special purpose vehicles, Owl Creek adjusts ownership participation through relative participating percentages. Neither Owl Creek nor any related party receives any compensation in connection with these rebalancing transactions. These cross transactions generally will be made without brokerage commissions being charged; except to the extent local market regulations require that transactions be affected on a security or a commodity market, as presently occurs with US Futures, US equity options and Hong Kong equities. (Owl Creek and its affiliates do not receive any commissions or compensation in respect of such transactions). A majority of securities owned by the Flagship Funds are currently being rebalanced. There may be a percentage of investments that Owl Creek does not rebalance due to, among other things, regulatory, business or tax considerations. Owl Creek may also affect cross transactions for non-rebalancing purposes in accordance with applicable law and the policies set forth herein. By executing a partnership agreement or subscription agreement, as applicable, each limited partner of a U.S. Fund and shareholder of an Offshore Fund has authorized the General Partner or Investment Manager, as applicable, on behalf of such limited partner or shareholder, to select one or more persons, who will not be affiliated with the General Partner or Investment Manager, to serve on a committee or as an independent representative, the purpose of which will be to consider and, on behalf of investors, approve or disapprove, to the extent required by applicable law,

principal transactions and certain other related party transactions (the “Independent Representative”). The General Partner and Investment Manager have appointed Mayflower Management Services (Bermuda) Limited to serve as the Independent Representative for the Funds. A principal or employee of Owl Creek or a related person may, from time to time, serve as a director with respect to companies, the securities of which are purchased on behalf of the Clients. In the event Owl Creek or a related person (i) obtains material non-public information in such capacity with respect to any such company or (ii) is subject to trading restrictions pursuant to the internal policies of Owl Creek, Owl Creek may be prohibited from engaging in transactions with respect to the securities or instruments of such company, which prohibition may have an adverse effect on the Clients. Additional Considerations From time to time, various potential and actual conflicts of interest may arise from the overall advisory, investment and other activities of Owl Creek, its affiliates and its personnel (each an “Advisory Affiliate” and, collectively, the “Advisory Affiliates”). Owl Creek has established policies and procedures to monitor and resolve conflicts and will endeavor to resolve conflicts with respect to investment opportunities in a manner it deems equitable to the extent possible under the prevailing facts and circumstances. In addition, Owl Creek may give advice or take action with respect to the investments of one or more Clients that may not be given or taken with respect to other Clients with similar investment programs, objectives, and strategies. Accordingly, although the Clients have similar strategies, they may not hold the same securities or instruments or achieve the same performance. These activities also may adversely affect the prices and availability of other securities or instruments held by or potentially considered for one or more Clients. The Advisory Affiliates may also have ongoing relationships with companies whose securities are in or are being considered for the Clients. Owl Creek recognizes that conflicts may arise under such circumstances and will endeavor to treat all Clients fairly and equitably. Code of Ethics Owl Creek strives to adhere to the highest industry standards of conduct based on principles of professionalism, integrity, honesty and trust. In seeking to meet these standards, Owl Creek has adopted a Code of Ethics (the “Code”). The Code incorporates the following general principles that all employees are expected to uphold: employees must at all times place the interests of clients first; all personal securities transactions must be conducted in a manner consistent with the Code and any actual or potential conflicts of interest or any abuse of an employee’s position of trust and responsibility must be avoided; employees must not take any inappropriate advantage of their positions; information concerning the identity of securities and financial circumstances of the Clients, including the Clients’ investors, must be kept confidential; and independence in the investment decision-making process must be maintained at all times. The Code also places restrictions on personal trades by employees, including disclosing their personal securities holdings and transactions to Owl Creek on a periodic basis. Owl Creek generally prohibits purchases or short selling by employees of individual securities or purchases of IPOs. However, employees may be permitted to sell securities held in their personal accounts, purchase

securities to cover short positions held in their personal accounts, and engage in certain other transactions, in each case, where appropriate, with appropriate prior electronic or written approval. Employees are permitted to purchase and sell uncovered securities (including index funds, treasury securities and certain exchange-traded funds). Some clients may invest in the same or similar instruments. The Code includes restrictions designed to supervise the giving or receiving of gifts and entertainment, and employees’ outside business activities. The Code also includes restrictions on certain political contributions and related solicitation activities. Investors may request to review a copy of the Code by contacting Owl Creek at the address or telephone number listed on the first page of this document. The Altman Family Foundation The Altman Family Foundation (formerly known as The Jeffrey A. Altman Foundation, Inc., the “Foundation”), a charitable foundation for which Jeffrey Altman has investment authority, may purchase or sell the same securities as the Clients; however, Owl Creek has established a policy, as reflected in the Compliance Manual, whereby investment opportunities are generally first allocated to the Clients. Owl Creek may occasionally place trades on behalf of the Foundation or suggest an execution counterparty to the Foundation’s broker, it may perform incidental advisory services such as coordinating proxy votes. Accordingly, the Foundation may be deemed to be a client of Owl Creek. However, neither Mr. Altman nor Owl Creek receives any compensation in respect of the Foundation and Owl Creek does not provide investment recommendations to the Foundation. The Foundation is not included in client counts and Regulatory Asset Under Management as described on page 6 in the “Ownership and AUM” section of Item 5 of ADV Part 1. The Foundation is included in responses to 5C and 5D (n). Restrictions Due to Insider Information Owl Creek also maintains insider trading policies and procedures (the “Insider Trading Policies”) that are designed to prevent the misuse of material, non-public information. Owl Creek’s personnel are required to certify their compliance with the Code, including the Insider Trading Policies, on a periodic basis. Owl Creek’s Insider Trading Policies prohibit Owl Creek and its personnel from trading for the Clients or themselves, or recommend trading, in securities of a company while in possession of material, non-public information (“Inside Information”) about the company, and from disclosing such information to any person not entitled to receive it. Because of its various activities, Owl Creek may have access to Inside Information or be restricted from effecting transactions in certain investments that might otherwise have been initiated. Owl Creek has designed and implemented policies and procedures reasonably designed to shield its investment professionals in most cases from access to Inside Information so that investment decisions may be made on the basis of public information only. Among other things, such policies seek to control and monitor the flow of Inside Information to and within Owl Creek, as well as prevent trading based on Inside Information. Accordingly, Owl Creek may not have access to Inside Information that other market participants or counterparties are eligible to receive. Notwithstanding such policies and procedures, there may be certain cases where Owl Creek either may receive Inside Information due to its various activities on behalf of itself or the Clients or may be restricted in acting for the Clients, resulting in limited liquidity or using such information for the

benefit of certain clients in specific securities. Owl Creek seeks to minimize those cases whenever possible, consistent with applicable law and its Insider Trading Policies, but there can be no assurance that such efforts will be successful and that such restrictions will not occur.

In selecting and approving brokers to effect portfolio transactions for the Clients, the factors Owl Creek considers include, but are not limited to: quality of execution, reputation, financial strength, stability, block trading and block positioning capabilities, willingness to execute difficult transactions, willingness and ability to commit capital, access to underwritten offerings and secondary markets, ongoing reliability and financial responsibility, overall costs of a trade, nature of the security and the available market makers, desired timing of the transaction and size of the trade, confidentiality of trading activity, market intelligence regarding trading activity, idea generation, conferences, the receipt of brokerage or research services, and the brokers’ facilities. Owl Creek need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Accordingly, if Owl Creek determines in good faith that the commissions charged by a broker are reasonable in relation to the value of the brokerage and research products or services provided by such broker, the Clients may pay commissions to such broker in an amount greater than the amount another broker might charge. Soft Dollar Usage Owl Creek intends that the use of commissions or “soft dollars” to pay for “research” or “brokerage” products or services will come within the safe harbor created by Section 28(e) of the Securities Exchange Act of 1934, as amended. Generally, eligible research and brokerage products and services provided by broker-dealers may include research reports on particular industries and companies, economic surveys and analyses, recommendations as to specific securities, market data, market research related to securities (including pre-trade and post-trade analytics, software and other products that depend on market information to generate market research, including research on optimal execution venues and trading strategies) and other products and services providing lawful and appropriate assistance to Owl Creek in the performance of its investment decision-making responsibilities. Eligible brokerage products and services under Section 28(e) also may include communication systems related to the execution, clearing and settlement of securities transactions (i.e., connectivity services to broker-dealers and other relevant parties such as custodians, including dedicated lines and message services used to transmit orders), trading software used to route orders to market centers and software used to transmit orders. Consistent with Section 28(e), Owl Creek will make a good faith determination that client commissions paid to a broker are reasonable in relation to the value of the products or services provided by such broker. Also, consistent with Section 28(e), research and brokerage products or services obtained with "soft dollars" generated by one or more Clients may be used by Owl Creek to service one or more other Clients, including Clients that may not have paid for the soft dollar benefits. Owl Creek does not seek to allocate soft dollar benefits to Clients in proportion to the soft dollar credits the Clients generate. Where a product or service obtained with soft dollars provides both research and nonresearch assistance to Owl Creek (i.e., a "mixed use" item), Owl Creek will make a reasonable allocation of the cost which may be paid for with soft dollars. In making good faith allocations of

costs between administrative benefits and research and brokerage services, a conflict of interest may exist by reason of Owl Creek's allocation of the costs of such benefits and services between those that primarily benefit Owl Creek and those that primarily benefit the Clients. The portion of these services that was utilized for non-research or brokerage within Section 28(e) (e.g., compliance, operational and accounting functions) was borne by Owl Creek, and not the Clients. Although at present the Firm does not pay for any mixed-use items with soft dollars, the Firm may elect to do so again in the future. When Owl Creek uses client brokerage commissions (or markups or markdowns) to obtain research or other products or services, Owl Creek receives a benefit because it does not have to produce or pay for such products or services. Owl Creek may consider its receipt of such research or other products or services, as well as other factors, in determining what broker-dealer to select or recommend. All proposed soft dollar research agreements must be approved by the Compliance Officer, General Counsel, one of the Co-Chief Operating Officers or the Firm’s Brokerage Committee. Certain designated Owl Creek employees, subject to oversight from the Compliance Officer, General Counsel, and the Co-Chief Operating Officers, and/or the Brokerage Committee, in the case of commission sharing arrangements (“CSAs”), review soft dollar products and services periodically to: (1) determine compliance with Section 28(e); (2) confirm soft dollar balances; (3) ensure soft dollar bills are appropriately paid and; (4) as applicable, conduct a mixed-use analysis. The Firm’s Brokerage Committee periodically reviews the Firm's overall soft dollar activities. Owl Creek intends to maintain reasonable documentary evidence to substantiate its soft dollar compliance processes. CSAs are a form of soft dollar arrangement which allow the use of all or a portion of commissions from an executing broker to a third party who has supplied execution services and/or research to an investment manager. The Firm participates in CSAs to pay for research in a manner intended to come within the Section 28(e) safe harbor. Such arrangements are reviewed and approved by the Brokerage Committee periodically as described above. At least annually, Owl Creek considers the amount and nature of research and research services provided by broker-dealers, as well as the extent to which such services are relied upon, and attempts to allocate a portion of the brokerage business of its clients on the basis of that consideration. Broker-dealers sometimes suggest a level of business they would like to receive in return for the various products and services they provide. Actual brokerage business received by any broker-dealer may be less than the suggested allocation but can (and often does) exceed the suggested level, because transactions are allocated on the basis of all of the considerations described above. In no case will Owl Creek make binding commitments as to the level of brokerage commissions it will allocate to a broker-dealer, nor will it commit to pay cash if any informal targets are not met. A broker-dealer is not excluded from receiving business because it has not been identified as providing research products or services. The soft dollar disclosures in this section are a brief summary of the procedures followed by Owl Creek in determining how to direct Client transactions to a particular broker-dealer in return for soft dollar benefits received and are not intended to be a full description of such procedures.

MiFID II provisions relating to research and inducements may cause certain European brokers or counterparties to no longer offer the Firm and its clients bundled research as part of their overall execution service. In such cases the applicable advisory clients may pay for such research with hard dollars as described in the expenses section of item 5. Additional Brokerage Considerations From time to time, brokers (including prime brokers such as Goldman, Sachs & Co., and Morgan Stanley & Co.) may assist the Funds in raising additional funds from investors, and representatives of Owl Creek may speak at conferences and programs sponsored by such brokers for investors interested in investing in hedge funds. Through such "capital introduction" events, prospective investors in the Funds would have the opportunity to meet with representatives of Owl Creek. Currently, neither Owl Creek nor the Clients compensate any broker for organizing such events or for any investments ultimately made by prospective investors attending such events, nor do they anticipate doing so in the future. Clients may accept subscriptions from investors who also provide services to the Clients, including brokers and their affiliates. Relationships such as the ones described above could be viewed as creating a conflict of interest that potentially could affect Owl Creek's ability to seek best execution. While our relationship with brokers may influence Owl Creek in deciding whether to use such broker in connection with brokerage, financing and other activities of the Clients, Owl Creek will not commit to allocate a particular amount of brokerage to a broker in any such situation. Furthermore, Owl Creek conducts periodic best execution reviews in an effort to identify and mitigate compliance risks associated with brokerage relationships, and to determine that Owl Creek is obtaining best execution for clients' accounts. Trade Allocation and Aggregation Policies and Procedures Owl Creek will generally execute transactions for Clients the Firm manages on an aggregated basis when Owl Creek believes that to do so will allow it to seek best execution and to negotiate more favorable commission rates or other transaction costs that might have otherwise been paid had such orders been placed independently. Instances in which client orders will not be aggregated include, but are not limited to, the following:

Clients directing Owl Creek to use certain broker/dealers, in which case such orders shall be separately effected; Traders and/or portfolio managers determining that the aggregation is not appropriate because of market conditions; Situations where portfolio managers must effect the transactions at different prices, making aggregation unfeasible; and A determination by the portfolio managers not to aggregate orders because of tax, legal, regulatory or administrative reasons. Administrative reasons may include counterparty or unaffiliated investment adviser approvals.

When aggregating orders, all Clients will be treated in a fair and equitable manner. Owl Creek will not aggregate orders unless aggregation is consistent with its duty to obtain best execution. Each Client that participates in an aggregated order will participate equitably, with transaction costs shared pro rata based on each Client's participation in the transaction. It is the policy of Owl Creek to allocate investment opportunities for the Clients fairly and equitably, to the extent possible, over

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There are no sales charges payable to Owl Creek in connection with the offering of interests and shares in the Funds. Owl Creek may in the future enter, into agreements with other placement agents in connection with the solicitation of investors in the Funds and such agreements may provide for payment to the relevant placement agent of a portion of the subscription amount by investors or ongoing payments to the relevant placement agent based upon a percentage of the Management Fee or Incentive Allocation attributable to the investments introduced by such placement agent. At present, there are no such arrangements with third-party placement agents. Unless otherwise expressly disclosed to an investor, any fees paid to such placement agents that are paid by a Fund will offset the Management Fee or Incentive Allocation otherwise payable or allocable to Owl Creek. If a subscriber is introduced to the Funds through a placement agent, the arrangement, if any, with such placement agent will be disclosed to the subscriber.

There are no legal or disciplinary events that are material to a client's or prospective client's evaluation of Owl Creek's advisory business or the integrity of Owl Creek's management.

Owl Creek performs various daily, weekly, monthly, quarterly and periodic reviews of the Clients’ portfolios. Such reviews are conducted by the portfolio managers, senior analysts, senior traders, operations and accounting, legal and compliance teams and the Co-Chief Operating Officers.

Investors in the Funds receive a periodic written letter from Owl Creek documenting the performance of the Fund(s) in which they invest. Owl Creek may provide certain investors with information on a more frequent basis if agreed to by Owl Creek. In addition, Owl Creek issues investors written audited financial statements at least annually for the Funds in which they invest, generally within 90 days (but no later than the 120 days prescribed by the Custody Rule) after the end of period to which the audit relates. Owl Creek also issues investors in the U.S. Funds tax reports with respect to their investments in the relevant Funds.

Owl Creek is subject to Rule 206(4)-2 under the Advisers Act (the "Custody Rule"). However, it is not required to comply (or is deemed to have complied) with certain requirements of the Custody Rule with respect to each Fund because it complies with the provisions of the so-called "Pooled Vehicle Annual Audit Exception", which, among other things, requires that each Fund be subject to audit at least annually by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, and requires that each Fund distribute its audited financial statements to all investors within 120 days of the end of its fiscal year.

As noted previously, Owl Creek has full discretionary authority to manage the Clients, including authority to make decisions with respect to which securities are bought and sold, the amount and price of those securities, the brokers or dealers to be used for a particular transaction, and commissions or markups and markdowns paid. Owl Creek's authority is limited by its own internal policies and procedures and each Client's investment guidelines.

Proxy Voting Policies and Procedures The SEC adopted Rule 206(4)-6 under the Advisers Act, which requires registered investment advisers that exercise voting authority over client securities to implement proxy voting policies. In compliance with such rules, Owl Creek has adopted proxy voting policies and procedures (the

"Proxy Policies"). The general policy is to vote proxy proposals, amendments, consents or resolutions relating to client securities, including interests in private investment funds, if any (collectively, "proxies"), in a manner that serves the best interests of the Clients, as determined by Owl Creek in its discretion, taking into account the following factors: (i) the impact on the value of the investments; (ii) the anticipated associated costs and benefits; (iii) the continued or increased availability of portfolio information; and (iv) industry and business practices. The Firm may also assist the Foundation with voting its proxies. In limited circumstances, Owl Creek may abstain or affirmatively decide not to vote a proxy where Owl Creek believes it is in the best interest of the Clients, considering such factors as costs and legal restrictions. When applicable, Owl Creek will generally refrain from moving securities out of margin accounts for the express purpose of ensuring the ability to vote, unless Owl Creek determines that it would be in the best interests of the Clients to do so. Not actively segregating securities could potentially result in a loss of the ability to vote shares, if they are re-hypothecated or otherwise unregistered to vote as of record date. The Clients generally do not have the ability to direct voting for a particular situation. Owl Creek's Proxy Policies include procedures to identify and address conflicts or potential conflicts that could arise between Owl Creek's own interests and those of the Clients. In order to avoid the perception of a potential conflict of interest, to the extent record date holdings of the Foundation (or Jeff Altman personal accounts) and the Firm’s advisory clients overlap, the Foundation (or Jeff Altman personal accounts) will generally vote in a manner consistent with the advisory clients. To the extent Jeffrey Altman wishes to vote a proxy on behalf of the Foundation (or himself) in a manner inconsistent with the above, the Foundation’s fiduciaries (or Jeff Altman if applicable) will inform the Firm's Compliance Officer or General Counsel, who will be required to evaluate and approve the decision. In the event that a material conflict of interest is found between Owl Creek and the Clients in voting proxies, Owl Creek will follow requirements in its Proxy Policies to ensure the proxy is voted in the best interests of the Clients. Owl Creek utilizes Glass, Lewis & Co. to assist in the coordination, voting, and record-keeping of proxies. Investors may request a copy of the Proxy Policies and the proxy voting record by contacting Owl Creek at the address or telephone number listed on the first page of this document. Class Action Lawsuits From time to time, Owl Creek may receive notices or initiate claims regarding class action lawsuits involving securities that are or were held by the Clients. Owl Creek reserves the right to serve as the lead plaintiff in class action matters. Owl Creek may refrain from submitting proofs of claim where it believes that either the recovery amounts are likely to be negligible or it cannot be assured of confidential treatment of the data submitted in connection with the proof of claim. Owl Creek uses the services of a third-party class action processor that works on a contingency basis to submit class action claims on behalf of certain clients.

Owl Creek is not required to include a balance sheet for its most recent fiscal year, is not aware of any financial condition reasonably likely to impair its ability to meet contractual commitments to clients, and has not been the subject of a bankruptcy petition at any time during the past ten years.