Pantera Capital Partners LP

A. General Description of Advisory Firm

1. Pantera Capital Partners LP Pantera Capital Partners LP (the “Filing Adviser”) is a Delaware limited partnership that was formed in 2021. We have three offices, which are located in (i) San Francisco, California, (ii) New York, New York and (iii) San Juan, Puerto Rico. Our principal office and place of business is in San Francisco. The New York office primarily houses capital formation and infrastructure support personnel. We are ultimately controlled by our principal owner, Daniel Morehead (the “Principal Owner”). The Principal Owner has been appointed the manager of DMDM Ventures, LLC (“DMDM Ventures”). Pantera Capital Partners LP is controlled by its general partner, Pantera Capital Partners GP LLC, which is wholly owned by DMDM Ventures.

2. Pantera Advisors LLC Pantera Advisors LLC (“Pantera Advisors”) is a Delaware limited liability company that was formed in 2004. DMDM Ventures is the managing member of and controls Pantera Advisors LLC.

3. Pantera Capital Management LP Pantera Capital Management LP (“PCM LP”), is a Delaware limited partnership that was formed in 2004. Pantera Capital Management LP is controlled by its general partner, Pantera GP LLC, which is wholly owned by DMDM Ventures.

4. Pantera HK Limited Pantera HK Limited (collectively with Pantera Advisors and PCM LP, the “Relying Advisers” and, the Relying Advisers together with the Filing Adviser, the “Investment Adviser”, “we”, “us”, and similar terms) is a Hong Kong corporation formed in 2024. Pantera HK Limited is controlled by its general partner, Pantera GP LLC, which is wholly owned by DMDM Ventures.

5. Fund General Partner Entities Our registration on Form ADV also covers Pantera Venture GP LLC (the “Venture General Partner”), Pantera Venture II GP LLC (the “Venture II General Partner”), Pantera Venture III GP LLC (the “Venture III General Partner”), Pantera Blockchain GP LLC (the “Blockchain General Partner”), Pantera Blockchain Venture GP LLC (the “Blockchain Venture General Partner”), Pantera Liquid and Early-Stage Token GP LLC (the “Liquid and Early-Stage Token General Partner”),Pantera Opportunities GP LLC (the “Opportunities General Partner”), and Pantera Fund V GP LLC (the “Fund V General Partner”, collectively with the Venture General Partner, the Venture II General Partner, the Venture III General Partner, the Blockchain General Partner, the Blockchain Venture General Partner, the Liquid and Early-Stage Token General Partner, and the Opportunities General Partner, the “Fund General Partners”), which are all limited liability companies organized under the laws of the state of Delaware. The Fund General Partners are affiliates of the Investment Adviser and serve or may serve as the general partner of

Funds (as defined below) that are U.S. or offshore partnerships. The Fund General Partners’ facilities and personnel are provided by the Investment Adviser. The Principal Owner is the principal owner of, and controls, the Fund General Partners, which are directly owned by DMDM Ventures. B. Description of Advisory Services This Brochure generally includes information about us and our relationships with our clients and affiliates. While much of this Brochure applies to all such clients and affiliates, certain information included herein applies to specific clients or affiliates only.

6. Advisory Services We serve as the investment adviser, with discretionary trading authority, to private pooled investment vehicles, the securities of which are offered to investors on a private placement basis (each, a “Fund” and collectively, the “Funds”). Our “clients” are discussed herein. The Funds include:

Pantera Venture Fund LP, a Delaware limited partnership (the “Venture I Fund”);

Pantera Venture Fund II LP, a Delaware limited partnership (the “Venture II Fund”),

Pantera Venture Fund III LP, a Delaware limited partnership (the “Venture III Fund”);

Pantera Venture Fund III A LP, a Delaware limited partnership (the “Venture III A Fund”);

Pantera Venture Offshore Fund III LP, a Cayman Islands exempted limited partnership (the “Venture III Offshore Fund”, and together with the Venture I Fund, the Venture II Fund, the Venture III Fund and the Venture III A Fund, the “Venture Funds”);

Pantera Early-Stage Token Fund Ltd, a Cayman Islands exempted company (the “Early-Stage Token Offshore Fund”);

Pantera Early Stage Token Master Fund LP, a Cayman Islands exempted limited partnership (the “Early Stage Token Master Fund”, and together with the EarlyStage Token Offshore Fund, the “Early-Stage Token Offshore Funds”);

Pantera Early-Stage Token Fund LP, a Delaware limited partnership (the “EarlyStage Token Fund I”);

Pantera Early-Stage Token Fund II LP, a Delaware limited partnership (the “EarlyStage Token Fund II”, and together with the Early-Stage Token Fund I, the “Early- Stage Token Funds”);

Pantera Bitcoin Feeder Fund Ltd., a Cayman Islands exempted company (the “Bitcoin Feeder Fund”);

Pantera Bitcoin Fund Ltd., a Cayman Islands exempted company (the “Bitcoin Fund”, and together with the Bitcoin Feeder Fund, the “Bitcoin Funds”);

Pantera Liquid Token Fund LP, a Delaware limited partnership (the “Liquid Token Fund”);

Pantera Liquid Token Offshore Fund Ltd, a Cayman Islands exempted company (the “Liquid Token Offshore Fund”);

Pantera Liquid Token Offshore Master Fund LP, a Cayman Islands exempted limited partnership (the “Liquid Token Master Fund”, and together with the Liquid Token Fund, and the Liquid Token Offshore Fund, the “Liquid Token Funds”);

Pantera Blockchain Fund LP, a Delaware limited partnership (the “Blockchain Fund”);

Pantera Blockchain Venture Fund LP, a Delaware limited partnership (the “Blockchain Venture Fund”);

Pantera Blockchain Offshore Fund LP, a Cayman Islands exempted limited partnership (the “Blockchain Offshore Fund”);

Pantera Fund V LP, a Delaware limited partnership (the “Fund V Master Fund”);

Pantera Fund V Offshore LP, a Cayman Islands exempted limited partnership (the “Fund V Offshore Fund” and together with the Fund V Master Fund, the Blockchain Offshore Fund, and the Blockchain Fund, the “Blockchain Funds”);

Pantera Solana Offshore Fund LP, a Cayman Islands exempted limited partnership (the “Solana Offshore Fund”);

Pantera Solana Fund LP, a Cayman Islands exempted limited partnership (the “Solana Master Fund”, and together with the Solana Offshore Fund, the “Solana Funds”);

Pantera Token-25 Fund LP, a Delaware limited partnership (the “Token-25 Fund”);

Pantera Token-25 Offshore Fund LP, a Cayman Islands exempted limited partnership (the “Token-25 Offshore Fund”);

Pantera Token-25 Master Fund LP, a Cayman Islands exempted limited partnership (the “Token-25 Master Fund”, and together with the Token-25 Fund, and the Token- 25 Offshore Fund, the “Token-25 Funds”);

Pantera Fund V Beta Bridge LP, a Delaware limited partnership (the “Beta Bridge Fund”);

Pantera Fund V Beta Bridge Offshore LP, a Cayman Islands exempted limited partnership (the “Beta Bridge Offshore Fund” and together with the Beta Bridge Fund, the “Beta Bridge Funds”);

Pantera Opportunities Fund LP, a Delaware series limited partnership (the “Opportunities Domestic Fund”);

Pantera Opportunities Fund SPC, a Cayman Islands exempted limited company registered as a segregated portfolio company (the “Opportunities Offshore Fund”);

Pantera Opportunities Master Fund SPC, a Cayman Islands exempted limited company registered as a segregated portfolio company (the “Opportunities Master Fund” and together with the Opportunities Domestic Fund and the Opportunities Offshore Fund, the “Opportunities Umbrella Funds”);

Pantera Opportunities Fund LP Ton, a Delaware registered series (the “TON Fund”);

Pantera Opportunities Fund TON SP1, a Cayman Islands segregated portfolio (the “TON Offshore Fund”);

Pantera Opportunities Master Fund TON SP. a Cayman Islands segregated portfolio (the “TON Master Fund”, and together with the TON Fund and TON Offshore Fund, the “TON Funds”);

Pantera Opportunities Fund LP WLD, a Delaware registered series (the “WLD Fund”);

Pantera Opportunities Fund WLD SP1, a Cayman Islands segregated portfolio (the “WLD Offshore Fund”);

Pantera Opportunities Master Fund WLD SP. a Cayman Islands segregated portfolio (the “WLD Master Fund”, and together with the WLD Fund and WLD Offshore Fund, the “WLD Funds”);

Pantera Opportunities Fund LP DAT, a Delaware registered series (the “DAT Fund”);

Pantera DAT Opportunities Fund SP1, a Cayman Islands segregated portfolio (the “DAT Offshore Fund”); and

Pantera DAT Opportunities Master Fund SP, a Cayman Islands segregated portfolio (the “DAT Master Fund”, and together with the DAT Fund and the DAT Offshore Fund, the “DAT Funds”, and together with the Opportunities Umbrella Funds, the WLD Funds, and the TON Funds, the “Opportunities Funds”).

The Venture General Partner serves as the general partner of the Venture I Fund, the Venture II General Partner serves as the general partner of the Venture II Fund, the Venture III General Partner serves as the general partner of the Venture III Fund, the Venture III A Fund and the Venture III Offshore Fund, and the Liquid and Early-Stage Token General Partner serves as the general partner of the Liquid Token Funds, the Early-Stage Token Funds, the Early-Stage Token Offshore Funds, the Token-25 Funds and the Beta Bridge Funds. The Blockchain General Partner serves as the general partner to the the Blockchain Offshore Fund, the Blockchain Fund, and the Solana Funds. The Blockchain Venture General Partner serves as the general partner to the Blockchain Venture Fund. The Opportunities General Partner serves as the general partner to the Opportunities Funds.

The Fund V General Partner serves as the general partner to the Fund V Offshore Fund and the Fund V Master Fund.

7. Investment Strategies and Types of Investments We have included below summaries of the investment strategies for all of our clients. Please see Item 8 for additional information. (a) Venture Funds The Venture Funds pursue venture capital investments in businesses that seek to use blockchain technology and other less-liquid investments (excluding Early-Stage Token Offerings (as defined below) and digital assets (“Digital Assets”)) (“Blockchain Technology Venture Assets”). The Investment Adviser seeks to capitalize on the highly disruptive migration the Investment Adviser believes is about to occur, from existing ledger systems and communication channels that rely on centralized third-party trust, to blockchain technology that will allow peer-to-peer (enterprises and individuals) connection across myriad industries and geographies to directly transfer information and value. The Venture Funds generally plan to lead seed and Series A deals, taking board seats where appropriate. The Investment Adviser expects to have access to superior deal flow, by virtue of its active presence in the blockchain industry. The Venture Funds will seek to build a diversified portfolio to balance risk. Certain Venture Funds may, from time to time, hold tokens through earlystage token offerings (“Early-Stage Token Offerings”) that potentially convert into equity where the applicable Venture Fund invests in the underlying issuing company. Such Venture Funds will also be open to ancillary spaces, such as fintech, artificial intelligence, and machine learning. (b) Early-Stage Token Funds The investment objective of the Early-Stage Token Funds is to achieve capital appreciation and maximize absolute returns by participating in early-stage token opportunities within the blockchain space, with the ultimate goal of holding Liquid Tokens (defined below) resulting from such opportunities. The Early-Stage Token Funds seek to secure Liquid Tokens and access to Liquid Tokens using a wide variety of means and arrangements. In prior years, early-stage token opportunities arose primarily from new tokens, blockchain protocols or related services, financed and launched through Early-Stage Token Offerings of digital assets, virtual currencies, cryptocurrencies and/or other coins and tokens expected to have acceptable liquidity characteristics (collectively “Liquid Tokens”). Today, as the landscape for early-stage token opportunities is evolving, the Investment Adviser is adapting to market practices and novel ways of obtaining Liquid Tokens and the rights to Liquid Tokens, including in connection with or through preferred equity stakes in portfolio companies, Simple Agreements for Future Equity (“SAFEs”), warrants for tokens and purchase agreements for existing Liquid Tokens. (c) Early-Stage Token Offshore Funds The investment objective of the Early-Stage Token Offshore Funds is to achieve capital appreciation and maximize absolute returns by participating in Early-Stage Token Offerings of Liquid Tokens. The Investment Adviser will rely on various approaches to obtaining Liquid Tokens and the rights to Liquid Tokens, including in connection with or through preferred equity stakes in portfolio companies, SAFEs, warrants for tokens and purchase agreements for existing Liquid Tokens. The Early-Stage Token Offshore Funds generally intend to hold each investment for longterm appreciation over a period of not less than 12 months.

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A. Advisory Fees and Compensation The fees applicable to each Fund are set forth in detail in each Fund’s offering documents. A brief summary of such fees is provided below.

1. The Venture Funds (a) Management Fee Generally, the Venture Funds pay the Investment Adviser a fee for investment management services (the “Management Fee”) for each fiscal quarter of up to .25%-.5% (1%-2% per annum) of the aggregate capital commitments of certain investors for such fiscal quarter. The Management Fee is calculated and paid in advance. In the sole discretion of the applicable Fund General Partner, the Management Fee may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviser-related investor. (b) Carried Interest Generally, net proceeds of the investments of the Venture Funds will be distributed to the investors upon realization. The Fund General Partner is entitled to carried interest as follows (for certain Venture Funds the terms of the accrual of carried interest, including the distribution percentages listed below, may vary for certain investment classes). For the Venture Funds, the carried interest generally equals ten to twenty percent (10-20%) until such investor in the Venture II Fund, Venture III A Fund, or Venture III Fund receive aggregate distributions sufficient to provide it with a forty percent (40%) internal rate of return on its capital contributions. Thereafter the carried interest will equal 30% for the Venture II Fund, Venture III A Fund, and Venture III Fund. In the sole discretion of the applicable Fund General Partner, the carried interest may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviserrelated investor.

2. The Early-Stage Token Funds (a) Management Fee Generally, the Early-Stage Token Funds pays the Investment Adviser a Management Fee for each fiscal quarter equal to .75% (3% per annum) of the beginning balance of each capital account of an investor for such fiscal quarter. The Management Fee is calculated and paid in advance but is amortized monthly by the Early-Stage Token Funds over the quarter for which such Management Fee is paid. The Management Fee will be prorated for any capital contribution or withdrawal by an investor that is effective other than as of the first day of a quarter. In the event of a withdrawal by an investor other than as of the last day of a quarter, the Investment Adviser will pay to the applicable Fund an amount equal to the pro rata portion of the Management Fee, based on the actual number of days remaining in such quarter, and the applicable Fund will distribute such amount to the withdrawing investor. In the sole discretion of the Fund General Partner, the Management Fee may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any

Investment Adviser-related investor. The Fund General Partner’s capital account will not be debited with any Management Fee. (b) Incentive Allocation Generally, at the end of each fiscal year of the Early-Stage Token Funds, the Liquid and EarlyStage Token General Partner is entitled to an incentive allocation of an amount equaling 30% of the net capital appreciation (which includes both realized gains and losses and unrealized appreciation and depreciation of securities held in the applicable Fund’s portfolio) allocated to an investor’s capital account for such fiscal year after deducting the Management Fee debited to such investor’s capital account for such fiscal year, subject to a loss recovery account mechanism. In the event that an Early-Stage Token Fund is terminated or an investor withdraws other than at the end of a fiscal year, then for purposes of determining the incentive allocation allocable at such time to the Liquid and Early-Stage Token General Partner, net capital appreciation will be determined as if such dates were the end of the fiscal year, subject to certain adjustments. In the sole discretion of the Liquid and Early-Stage Token General Partner, the incentive allocation may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviser- related investor.

3. The Early-Stage Token Offshore Funds (a) Management Fee Generally, Pantera Early-Stage Token Fund Ltd pays the Investment Adviser a Management Fee for each fiscal quarter equal to .75% (3% per annum) of the gross asset value of each series of shares as of the beginning of such fiscal quarter. The Management Fee is calculated and paid in advance but is amortized monthly by the Pantera Early-Stage Token Offshore Fund Ltd over the quarter for which such Management Fee is paid. The Management Fee will be prorated for any subscription or redemption by an investor that is effective other than as of the first day of a quarter. In the event of a redemption by an investor other than as of the last day of a quarter, the Investment Adviser will pay to the Early-Stage Token Offshore Fund Ltd (or the Pantera Early-Stage Token Master Fund LP) an amount equal to the pro rata portion of the Management Fee, based on the actual number of days remaining in such quarter, and the Early-Stage Token Offshore Fund will distribute such amount to the redeeming investor. In the sole discretion of the Investment Adviser, the Management Fee may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviser-related investor. (b) Incentive Allocation Generally, at the end of the 12-month period ending on June 30, Early-Stage Offshore Incentive Allocation Year of the Early-Stage Token Master Fund, the Liquid and Early-Stage Token General Partner is entitled to an incentive allocation of an amount equaling 30% of the net realized and unrealized appreciation in the net asset value of each series of shares, adjusted for any redemption of shares in the series made during the year and any accruals of the incentive allocation and subject to a loss recovery account mechanism. In the event that shares are redeemed other than at the end of a fiscal year, the incentive allocation

will be determined solely with respect to the shares so redeemed as of the redemption date. In the sole discretion of the Liquid and Early-Stage Token General Partner, the incentive allocation may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviser-related investor.

4. The Bitcoin Funds (a) Management Fee Generally, the Bitcoin Funds pays the Filing Adviser a Management Fee for each month equal to the aggregate of a daily accrual equal to 0.00205% (0.75% per annum) of the net asset value of each series of shares of the fee-paying class (before taking into account any investor-related taxes that are accrued but not yet paid as of the applicable calculation date) calculated as of the beginning of each day (including, for the avoidance of doubt, non-business days). Certain share classes are not subject to the Management Fee. Payment of the Management Fee will be made upon redemption or within 10 days of the last day of each month. In the sole discretion of the Investment Adviser, the Management Fee may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviser-related investor. (b) Realization Fee Generally, amounts distributed to investors in the Bitcoin Funds upon redemption (whether voluntary or compulsory), other than upon dissolution of the Bitcoin Funds, will be reduced by a realization fee (“Realization Fee”) equal to 1.0%. Certain share classes are not subject to a Realization Fee. The Filing Adviser may, in its sole discretion, reduce or waive the Realization Fee with respect to any investor or share class, including, without limitation, any Investment Adviserrelated investor. The Realization Fee may be paid in Bitcoin or in its cash equivalent.

5. The Liquid Token Funds (a) Management Fee Generally, the Liquid Token Funds pay the Investment Adviser a Management Fee for each fiscal quarter equal to .5% (2% per annum) of the beginning balance of each capital account of an investor for such fiscal quarter. The Management Fee is calculated and paid in advance but is amortized monthly by the Liquid Token Funds over the quarter for which such Management Fee is paid. The Management Fee will be prorated for any capital contribution or withdrawal by an investor that is effective other than as of the first day of a quarter. In the event of a withdrawal by an investor other than as of the last day of a quarter, the Investment Adviser will pay to the applicable Fund an amount equal to the pro rata portion of the Management Fee, based on the actual number of days remaining in such quarter, and the applicable Fund will distribute such amount to the withdrawing investor. In the sole discretion of the Liquid and Early-Stage Token General Partner, the Management Fee may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviser-related investor. The Liquid and Early-Stage Token General Partner’s capital account will not be debited with any Management Fee. (b) Incentive Allocation Generally, at the end of each fiscal year of each Liquid Token Fund, the Liquid and Early-Stage

Token General Partner is entitled to an incentive allocation of an amount equaling 20% of the net capital appreciation (which includes both realized gains and losses and unrealized appreciation and depreciation of securities held in the applicable Fund’s portfolio) allocated to an investor’s capital account for such fiscal year or March 31, (the “LTF Incentive Allocation Year”) after deducting the Management Fee debited to such investor’s capital account for such fiscal year, subject to a loss carryforward mechanism. In the event that the Liquid Token Funds are terminated or an investor withdraws other than at the end of a fiscal year, then for purposes of determining the incentive allocation allocable at such time to the Liquid and Early-Stage Token General Partner, net capital appreciation will be determined as if such dates were the end of the LTF Incentive Allocation Year, subject to certain adjustments. In the sole discretion of the Liquid and Early-Stage Token General Partner, the incentive allocation may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviser-related investor. Fees and compensation paid to the Investment Adviser or its affiliates by the Funds are generally deducted from the assets of such clients. As discussed above, Management Fees are generally deducted on a quarterly basis and performance compensation is generally deducted on an annual basis.

6. The Blockchain Funds (a) Management Fee Generally, the Blockchain Funds pay the Investment Adviser a Management Fee for each fiscal quarter (or, in the case of the Fund V Master Fund and Fund V Offshore Fund, each calendar quarter) ranging from .25%- .5% (1% - 2% per annum) of the aggregate capital commitments of certain investors for such fiscal quarter. The Management Fee is calculated and paid in advance but is amortized monthly by the Blockchain Funds over the quarter for which such Management Fee is paid. In the sole discretion of the Investment Adviser, the Management Fee may be waived, reduced or calculated differently with respect to certain investors, including, without limitation, any Investment Adviser-related investor. The Blockchain General Partner’s capital account will not be debited with any Management Fee. The Blockchain Funds will be responsible for all expenses incurred in organizing the Blockchain Funds up to an operational expense cap, as described in the Blockchain Funds’ governing documents. Any amounts incurred by the Blockchain Funds in excess of such expense cap shall reduce the Management Fee of Management Fee-paying investors pro rata to their capital commitments. (b) Carried Interest Generally, net proceeds of the investments of the Blockchain Funds will be distributed to the investors upon realization. The applicable general partner is generally entitled to carried interest from certain investors in the Blockchain Funds as follows. First, one hundred percent (100%) of the capital invested shall be returned to the investor, after which eighty percent (80%) will be distributed to such investor and twenty percent (20%) will be distributed to the applicable general partner, until such investor has received aggregate distributions sufficient to provide it with a forty percent (40%) internal rate of return on its capital contributions (or in the case of the Fund V

Offshore Fund and Fund V Master Fund, until such investor has received aggregate distributions equal to five times (5.0x) multiple of such investor’s capital contributions). Thereafter, seventy percent (70%) of the remaining proceeds are paid to the investor and thirty percent (30%) are paid to the applicable general partner. In the sole discretion of the applicable general partner, the carried interest may be waived, reduced or calculated differently with respect to certain investors or with respect to certain classes of investors, including, without limitation, any Investment Adviserrelated investor. The Blockchain Fund will make certain investments through the Blockchain Venture Fund, which has fee structures. Where the Blockchain Fund invests through other Funds, such as the Blockchain Venture Fund, fees with respect to such investments will be assessed at the Blockchain Venture Fund level.

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A. Methods of Analysis and Investment Strategies The descriptions set forth in this Brochure of specific advisory services that we offer to clients, and investment strategies pursued and investments made by us on behalf of our clients, should not be understood to limit in any way our investment activities. We may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that we consider appropriate, subject to each client’s investment objectives and guidelines. The investment strategies we pursue 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. In this Item 8.A, we have included summaries of each of the investment objectives for the different clients we advise; however, more detailed descriptions of such methods of analysis and investment strategies are incorporated into such clients’ governing agreements. The Early-Stage Token Offshore Funds The investment objective of the Early-Stage Token Offshore Funds is to achieve capital appreciation and maximize absolute returns by participating in early-stage token opportunities within the blockchain space, with the ultimate goal of holding Liquid Tokens resulting from such opportunities. The Early- Stage Token Offshore Funds seek to secure Liquid Tokens and access to Liquid Tokens using a wide variety of means and arrangements. In prior years, early-stage token opportunities arose primarily from new tokens, blockchain protocols or related services, financed and launched through Early-Stage Token Offerings of Liquid Tokens. Today, as the landscape for early-stage token opportunities is evolving, the Investment Adviser is adapting to market practices and novel ways of obtaining Liquid Tokens and the rights to Liquid Tokens, including in connection with or through preferred equity stakes in portfolio companies, SAFEs, warrants for tokens and purchase agreements for existing Liquid Tokens. The Early-Stage Token Offshore Funds generally intend to hold each investment for long-term appreciation over a period of not less than 12 months. The Early-Stage Token Offshore Funds may invest in these and other Liquid Tokens that one or more jurisdictions, including the United States, or governmental authorities or courts within such jurisdictions, may now or in the future consider securities or other regulated products for purposes of their laws and regulations. The Early-Stage Token Funds The investment objective of the Early-Stage Token Funds is to achieve capital appreciation and maximize absolute returns by participating in early-stage token opportunities within the blockchain space, with the ultimate goal of holding Liquid Tokens (defined below) resulting from such opportunities. The Early-Stage Token Funds seek to secure Liquid Tokens and access to Liquid Tokens using a wide variety of means and arrangements. In prior years, early-stage token opportunities arose primarily from new tokens, blockchain protocols or related services, financed and launched through Early-Stage Token Offerings of Liquid Tokens. Today, as the landscape for early-stage token opportunities is evolving, the Investment Adviser is adapting to market practices and novel ways of obtaining Liquid Tokens and the rights to Liquid Tokens, including in connection with or through preferred equity stakes in portfolio companies, SAFEs, warrants for tokens and purchase agreements for existing Liquid Tokens. The Early-Stage Token Funds generally intend to hold each investment for long-term appreciation over a period of not less than 12 months. The Early-Stage Token Funds may invest in these and other Liquid Tokens that one or more

jurisdictions, including the United States, or governmental authorities or courts within such jurisdictions, may now or in the future consider securities or other regulated products for purposes of their laws and regulations. The Liquid Token Funds The investment objective of the Liquid Token Funds is to achieve capital appreciation and maximize absolute returns by investing in a diversified portfolio consisting primarily of Liquid Tokens. The Liquid Token Funds may also invest in related equity assets that exhibit strong market acceptance and liquidity. The Liquid and Early-Stage Token General Partner intends to manage the Liquid Token Funds so that investments in instruments that are securities for purposes of U.S. laws and regulations do not exceed forty percent (40%), measured at the time of investment, of the total value of the portfolio at any time. The Investment Adviser will employ a long-biased approach to capture the potential upside while retaining the flexibility to navigate market fluctuations using futures, options and other derivatives, including for short positions when warranted. The Investment Adviser employs in-depth research and due diligence on blockchain-enabled protocols that utilize Liquid Tokens created, issued, and transmitted using the underlying software. The Investment Adviser conducts fundamental research to ascertain the fair value of certain underlying Liquid Tokens and any associated assets in which the Liquid Token Funds invest. Tactical trading will be utilized to adjust exposure levels in response to perceived divergence from fair value. Moreover, the Investment Adviser may strategically deploy a moderate amount of leverage to enhance returns while maintaining appropriate risk management. The Liquid Token Funds do not (i) expect to participate in Early-Stage Token Offerings, (ii) intend to invest in assets that have limited liquidity or (iii) intend to invest extensively (and in no instance over 40%, measured at the time of investment, of the Liquid Token Master Fund’s investments) in assets that have been determined to be securities for purposes of U.S. laws and regulations. The Venture Funds The Venture Funds primarily invest in businesses that seek to use blockchain technology to disintermediate rent-seeking incumbents and enable peer-to-peer transactions using tokenized assets. The Investment Adviser believes that blockchain applications will disintermediate a myriad of industries. Certain Venture Funds may, from time to time, hold tokens (through Early-Stage Token Offerings) that potentially convert into equity where such Venture Funds invest in the underlying issuing company. Certain Venture Funds will also be open to ancillary spaces, such as fintech, artificial intelligence, and machine learning. Investment Criteria. The Venture Funds generally plan to lead “Seed” and “Series A” deals, taking board seats where appropriate. The Venture Funds will endeavor to leave ample capital for each investment to be in the position to allocate funding to the entire lifecycle of the company, if so determined. Investment Strategy. The Investment Adviser expects to have access to superior deal flow, by virtue of its active presence in the blockchain industry. The Venture Funds will seek to build a diversified portfolio (in terms of number of positions and industries of focus) of blockchain technology-related venture investments to balance risk. The goal will be for the portfolio companies to be complementary and be able to leverage mindshare and assets among one another. The Investment Adviser expects to provide industry-specific value-added resources to the portfolio companies

based on its industry knowledge. The Bitcoin Funds The investment strategy of the Bitcoin Funds is to invest substantially all of its assets in Bitcoin. The Bitcoin Funds will only take immediate delivery of Bitcoin. The Bitcoin Funds will not trade, buy, sell or hold Bitcoin derivatives for any purpose. Transactions in Bitcoin will not be made on a leveraged, margined, or offer-financed basis. Through the investment program, investors in the Bitcoin Funds may indirectly participate in the Bitcoin market without owning or controlling specific Bitcoin. The Bitcoin Funds may engage in Bitcoin lending transactions, in the sole discretion of the Filing Adviser. The Blockchain Funds The Blockchain Funds allocate their capital across Blockchain Venture Assets, Special Opportunity Investments, and Digital Assets. The concentration of Blockchain Venture Assets, Special Opportunity Investments, and Digital Assets in the portfolio will fluctuate over time, and the Blockchain Funds will allocate capital to Blockchain Venture Assets, Special Opportunity Investments, and Digital Assets in such amounts as the applicable general partner determines in its sole discretion. It is anticipated that the Blockchain Funds may initially be invested up to 100% in Digital Assets, which percentage is expected to decline over the Investment Period as capital is drawn down for investment in Blockchain Venture Assets. Blockchain Venture Assets The Blockchain Venture Assets portfolio consists of actively managed early-stage companies building products and services in the nascent blockchain ecosystem. The Investment Adviser expects to use technical capabilities, market leadership, and exclusive deal flow to invest in private companies building out core blockchain infrastructural products and services, and by actively guiding those companies to create successful exits. The Class A Portfolio generally will seek to invest in “Seed”, Series A, and Series B financings in initial investment sizes between $1-50 million, with a proportional amount reserved for follow- on rounds. However, the actual investment strategy used for the Class A portfolio may deviate from this description. Areas of focus for Blockchain Venture Asset investments are: infrastructure, payments, enterprise, media and financial services. Early-Stage Token Offerings The Blockchain Funds invest in new protocols and tokens issued by financing developer teams. New tokens, blockchain protocols and related services are often developed, financed, and launched through an Early-Stage Token Offering. For portfolio construction purposes, the Investment Adviser will consider an offering to be an Early-Stage Token Offering if such offering is not listed on any Digital Asset exchange with a weekly volume above either $21 million per week or $3 million per day. Early- Stage Token Offerings are potentially profitable, but very risky; it takes deep technical and market knowledge to invest successfully in such investments. Once the offering has taken place and after a vesting or lockup period, the Blockchain Funds will seek to sell sufficient tokens earned in the Early- Stage Token Offering to recover its invested cost. A core thesis driving the Investment Adviser’s early- stage token strategy is that DeFi will be a main driver of value. Early-Stage Token Offerings are generally subject to trading restrictions (such as vesting or lockup periods) at the beginning of their lifecycle and, therefore, are illiquid or only thinly traded. EarlyStage Token Offerings become more liquid over time as such trading restrictions expire. The Blockchain Funds generally expect to invest in Early-Stage Token Offerings early in their life cycle

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We provide investment advice to Funds, as described above.

We (including the Fund General Partners) accept performance-based compensation from every client (other than clients that are not assessed performance-based compensation because it is assessed through another entity in a single master-feeder or similar structure), with the exception of the Token-25 Funds, Bitcoin Funds and the Beta Bridge Funds, which do not charge performancebased compensation. For the avoidance of doubt, we may manage additional entities in the future which also do not assess performance-based compensation. Performance-based compensation creates an incentive for us to make investments that are riskier or more speculative than would be the case in the absence of such compensation. Certain of our Funds have higher fees or more favorable performance-based compensation arrangements than other Funds. Consequently, a conflict of interest exists because we have a greater incentive to favor Funds from which we receive higher fees or performance-based compensation arrangements. Please also see “Item 10: Other Financial Industry Activities and Affiliations” and “Item 12: Brokerage Practices” for more details on conflicts resulting from the management of multiple clients. We have adopted and implemented policies and procedures intended to address these conflicts of interest, including trade allocation and aggregation policies. Our allocation policy seeks to allocate investment opportunities among all clients fairly, to the extent practical and in accordance with each client’s applicable investment strategies, over a period of time. Investment opportunities will generally be allocated among those clients for which participation in the respective opportunity is considered appropriate, taking into account, among other considerations: (i) whether the risk-return profile of the proposed investment is consistent with a client’s objectives; (ii) the potential for the proposed investment to create an imbalance in a client’s portfolio; (iii) the liquidity requirements of a client; (iv) potentially adverse tax consequences; (v) regulatory restrictions that would or could limit a client’s ability to participate in a proposed investment; and (vi) the need to re-size risk in a client’s portfolio. Investments may be allocated among client portfolios, and such allocations will be determined based on the Investment Adviser’s allocation policy.

A. Broker-Dealer Registration Status The Investment Adviser and its management persons are not registered as broker-dealers and do not have any application pending to register with the SEC as a broker-dealer or registered representative of a broker-dealer. B. Futures Commission Merchant, Commodity Pool Operator or Commodity Trading Adviser Registration Status The Investment Adviser and its management persons are not registered as, and do not have any application to register as, futures commission merchants, commodity pool operators, commodity trading advisors or associated persons of the foregoing entities. C. Material Relationships or Arrangements with Industry Participants Certain clients hold investments in Digital Asset-related companies, while certain other funds hold those Digital Assets. Conflicts of interest may arise in that the Investment Adviser may be incentivized to purchase (and not divest) Digital Assets developed by blockchain technology companies in which certain clients invest. In the event the Investment Adviser determines that participation in an Early- Stage Token Offering is appropriate for certain clients, those clients will generally participate pro rata in such opportunity based on available capital. In addition, the Venture Funds may, from time to time, hold Digital Assets through Early-Stage Token Offerings where the Venture Funds invest in the underlying issuing company. In such case(s), investment opportunities in such Early-Stage Token Offerings of Digital Assets will be allocated among the applicable clients in a manner that is fair and equitable. It is anticipated that the Investment Adviser’s investment teams will develop numerous quantitative models and software for use by one or more investment teams for the benefit of one or more clients. Similarly, trading and other systems (e.g., order management) developed by employees of the Investment Adviser are expected to be used by the Investment Adviser’s investment teams, including investment teams that do not manage the same client’s assets. The determination of how models and systems will be allocated among the applicable clients and other pooled investment vehicles will be made on a fair and equitable basis, to the extent practical and in accordance with, among other factors, the applicable client’s investment strategies, over a period of time. From time to time, the Investment Adviser may license the software developed by the Investment Adviser or its personnel to third parties or use such software for proprietary trading purposes, which may increase competition by limiting the investment opportunities available to certain clients. Additionally, investment teams that do not manage a specific client’s assets and/or third parties with license to utilize an investment team’s proprietary models and software, may develop implementation methods for such models and software that provide a competitive advantage over one or more clients, thereby reducing and/or eliminating the effectiveness of such model or software with respect to one or more clients. The Investment Adviser may be subject to conflicts relating to its selection of Digital Asset intermediaries, exchanges and counterparties on behalf of clients. Client portfolio transactions will be allocated to intermediaries, exchanges and counterparties on the basis of numerous factors and not necessarily lowest pricing. Intermediaries, exchanges and counterparties have at times provided

other services that are beneficial to the Investment Adviser, other clients, or other vehicles managed by the Investment Adviser, but not necessarily beneficial to the Funds. The Investment Adviser, its affiliates, and certain clients have invested in or established Digital Asset exchanges or other Digital Asset service providers, including businesses that focus on storage, security and custody of Digital Assets. The Investment Adviser has caused and expects in the future to cause one or more clients to transact with such affiliated service providers. Such affiliated service providers receive compensation when effecting Digital Asset transactions on behalf of certain clients. Investors will have no right to request which Digital Asset service providers, intermediaries, exchanges and counterparties the clients transact with or invest in, and should not expect the clients to accommodate any such requests. Conflicts of interest may arise from the fact that any service provider to a client (“Service Provider”) or any affiliate of a Service Provider may provide services to, or have business, financial, personal or other relations with (i) other private funds with investment programs similar to that our clients or (ii) the Investment Adviser or any of its affiliates. Certain Service Providers or affiliates of Service Providers are investors in certain clients, a source of investment opportunities or a co-investor or commercial counterparty or entity in which the Investment Adviser has an investment. It is customary for a Service Provider to charge different rates or have different terms for different types of services. Based on the types of services used by the Investment Adviser and its affiliates as compared to the types of services used by clients and the terms of such services, a Service Provider has entered into an arrangement with the Investment Adviser or its affiliates that provides for more favorable rates or terms than an arrangement with a client. Similar arrangements may also be entered into in the future. Conflicts of interest may arise from the fact that the Investment Adviser and its affiliates provide, or may in the future provide, investment management services to Other Clients. The Investment Adviser currently manages the treasury of a DAT company focused on Solana, and may in the future manage the treasuries of additional DAT companies focused on other Digital Assets (each, a “PanteraManaged DAT”). The Investment Adviser’s purchase and sale of applicable Digital Assets (including Solana) on behalf of a Pantera-Managed DAT and one or more Other Clients will generally be allocated among such Pantera-Managed DAT and such Other Clients in a manner that the Investment Adviser determines is fair and equitable. The personnel of the Investment Adviser or their affiliates may invest in DAT companies and/or other investments, which may conflict or compete with the Funds, including by investing or selling investments in DAT companies when a Fund is doing the opposite. D. Material Conflicts of Interest Relating to Other Investment Advisers We do not recommend or select other investment advisers for our clients.

A. Code of Ethics We strive to adhere to the highest industry standards of conduct based on principles of professionalism, integrity, honesty and trust. In seeking to meet these standards, we have 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 Funds, including the Funds’ investors, must be kept confidential; and

independence in the investment decision-making process must be maintained at all times.

Clients and prospective clients may request a copy of the Code by contacting us at the address or telephone number listed on the first page of this document. B. Securities that the Investment Adviser or a Related Person Has a Material Financial Interest

1. Cross Trades The Investment Adviser may determine that it would be in the best interests of certain clients to transfer a security from one client to another (each such transfer, a “Cross Trade”) for a variety of reasons, including, without limitation, tax purposes, liquidity purposes, to rebalance the portfolios of clients, or to reduce transaction costs that may arise in an open market transaction. If the Investment Adviser decides to engage in a Cross Trade, the Investment Adviser will determine that the trade is in the best interests of each client involved in it and take steps to ensure that the transaction is consistent with the duty to obtain best execution for each of those clients. A cross transaction between two clients may occur as an “internal cross”, where the Investment Adviser instructs the custodian for the applicable client accounts to book the transaction at the price determined in accordance with the Valuation Policy. If the Investment Adviser effects an internal cross, the Investment Adviser will not receive any fee in connection with the completion of the transaction.

2. Principal Transactions To the extent that Cross Trades may be viewed as principal transactions (as such term is used under the Advisers Act) due to the ownership interest in a client by the Investment Adviser, its affiliates, or its personnel, the Investment Adviser will comply with the requirements of Section 206(3) of the

Advisers Act. For the avoidance of doubt, the Fund General Partners and the Investment Adviser will comply with the requirements of Section 206(3) of the Advisers Act for any principal transactions. In connection with principal transactions, Cross Trades, related-party transactions and other transactions and relationships involving potential conflicts of interest, the directors and/or the Fund General Partners are each authorized to select one or more persons who are not affiliated with the Investment Adviser (such as an independent director) to serve on a committee, which may be authorized, to approve or disapprove, to the extent required by applicable law or deemed advisable by the directors and/or the Fund General Partner, such transactions and conflicts of interest. Such committee may approve of such transactions prior to or contemporaneous with, or ratify such transactions subsequent to, their consummation. In no event will any such transaction be entered into unless it complies with applicable law. The person(s) so selected may be exculpated and indemnified by the Funds. Any decision of such committee will be binding on all Fund investors. Cross Trades between clients may occur, and will not be presumptively treated as principal transactions absent a determination by the Investment Adviser otherwise. C. Investing in Securities that the Investment Adviser or a Related Person Recommends to Clients The Code places restrictions on personal investments by employees, including that they disclose their personal holdings and transactions in securities and other instruments, including Bitcoin or other Digital Assets, to the Investment Adviser on a periodic basis. The Investment Adviser, its affiliates and its employees may invest on behalf of themselves in securities and Digital Assets that would be appropriate for, held by, or may fall within the investment guidelines of clients. The Investment Adviser, its affiliates and its employees also engage, and in the future may engage, in a broad spectrum of activities, including direct investment activities (including trading in Digital Assets and alternative currencies outside of client portfolios) and investment advisory activities, and have extensive investment activities (including investments for their own account), on behalf of both persons or entities to which they provide investment advice on a principal basis, that are independent from, and may from time to time conflict with or be adverse to advice given or action taken for clients, including by buying or selling Digital Assets at different times than clients, or when a client is doing the opposite. These activities have the potential to adversely affect the prices and availability of other securities or instruments held by or potentially considered for one or more clients. Additionally, the Investment Adviser and its affiliates may invest in or establish Digital Asset exchanges, indexes, and/or other Digital Asset service providers, including service providers utilized by clients. Potential conflicts also may arise due to the fact that the Investment Adviser and its personnel may have investments in some Funds but not in others or may have different levels of investments in the various Funds. In addition, certain employees of the Investment Adviser may have a material financial interest in instruments held by client portfolios, and such employees may receive a financial benefit from clients’ investment in such instruments. Certain employees of the Investment Adviser have provided, and may in the future continue to provide, advisory services to Early-Stage Token Offering issuers in connection with their offerings and development of their protocols. Clients and investors in the Funds should be aware that any compensation received in connection with such activities benefits the Investment Adviser (or its employees) and not clients. Compensation may take the form of Early-Stage Token Offering tokens. Such activities pose a potential conflict of interest because the Investment Adviser may be incentivized to cause clients to engage in investment activities with respect to such Early-Stage

Token Offering issuers, including but not limited to: (i) investing in such Early-Stage Token Offering issuers, (ii) participating in the Early-Stage Token Offerings of such issuers, or (iii) purchasing Digital Assets that were previously offered through Early-Stage Token Offerings of such issuers. The Investment Adviser has established policies and procedures to monitor and resolve conflicts with respect to investment opportunities in a manner it deems fair and equitable, including the restrictions placed on personal trading in the Code, as described above, and regular monitoring of employee transactions and trading patterns for actual or perceived conflicts of interest, including those conflicts that may arise as a result of personal trades in the same or similar securities made at or about the same time as client trades. D. Conflicts of Interest Created by Contemporaneous Trading The Investment Adviser provides investment advisory services on behalf of a number of clients and other pooled investment vehicles. Certain clients have investment programs that are similar to or overlap and may, therefore, participate with each other in investments. It is the policy of the Investment Adviser to allocate investment opportunities among all clients fairly, to the extent practical and in accordance with each client’s applicable investment strategies, over a period of time. Investment opportunities will generally be allocated among those clients for which participation in the respective opportunity is considered appropriate, taking into account, among other considerations: (i) whether the risk-return profile of the proposed investment is consistent with a client’s objectives; (ii) the potential for the proposed investment to create an imbalance in a client’s portfolio; (iii) the liquidity requirements of a client; (iv) potentially adverse tax consequences; (v) regulatory restrictions that would or could limit a client’s ability to participate in a proposed investment; and (vi) the need to re-size risk in a client’s portfolio. Investments may be allocated among client portfolios, and such allocations will be determined based on the Investment Adviser’s allocation policy. The Investment Adviser and its affiliates may, from time to time, offer one or more Fund investors, clients, employees, other vehicles managed by the Investment Adviser, or third parties (any such party, a “Co-Investor”) the opportunity to invest in special purpose vehicles (“SPVs”) that participate in select Early-Stage Token Offerings (“Special Purpose Opportunities”), including through SAFTs. Generally, SPVs will co-invest with clients in such opportunities. The Investment Adviser and its affiliates are not obligated to arrange, and Co-Investors will not be obligated to participate in, Special Purpose Opportunities. The Investment Adviser and its affiliates have sole discretion as to the amount (if any) of a Special Purpose Opportunity that will be allocated to a particular Co-Investor and may allocate Special Purpose Opportunities instead to other CoInvestors. The Investment Adviser or its affiliates receive fees and/or allocations from Co-Investors, which may differ from the fees and/or allocations borne by clients. To the extent that clients and Co-Investors participate in a particular investment, the Investment Adviser will generally seek to dispose of such investment in a manner that is fair and equitable (i.e., simultaneously), subject to legal, tax, regulatory or other concerns, other considerations such as the relative amounts of capital available for new investments, as applicable. The Investment Adviser will have no obligation to purchase or sell a security for, enter into a transaction on behalf of, or provide an investment opportunity to any client solely because the Investment Adviser purchases or sells the same security for, enters into a transaction on behalf of, or provides an opportunity to any client if, in its reasonable opinion, such security, transaction or investment opportunity does not appear to be suitable, practical or desirable for the client.

A. Factors Considered in Selecting or Recommending Broker-Dealers for Client Transactions We have full discretionary authority to make decisions regarding which securities are bought and sold; the prices paid or received; the brokers, dealers or investment banks to be used, if any, for a particular transaction and the commissions or fees to be paid. Our authority is limited by our own internal policies and procedures and each client’s investment guidelines. Currently, we do not plan to engage the services of registered broker-dealers on behalf of any of the Funds. If, in the future, we decide to utilize the services of a broker-dealer, we will adopt policies and procedures designed to fulfill the duties we owe to clients and comply with applicable laws.

1. Research and Other Soft Dollar Benefits We do not currently intend to receive research and other soft dollar benefits from broker-dealers.

2. Brokerage for Client Referrals Neither the Investment Adviser nor any related person receives client referrals from any brokerdealer or third party. However, as discussed above, subject to best execution, the Investment Adviser may consider, among other things, capital introduction and marketing assistance with respect to investors in the Funds in selecting or recommending broker-dealers for the Funds.

3. Directed Brokerage The Investment Adviser does not recommend, request or require that a client direct the Investment Adviser to execute transactions through a specified broker-dealer. B. Order Aggregation If the Investment Adviser determines that the purchase or sale of Digital Assets is appropriate with regard to multiple clients, the Investment Adviser may, but is not obligated to, purchase or sell Digital Assets on behalf of such clients with an aggregated order, for the purpose of reducing transaction costs, to the extent permitted by applicable law. When an aggregated order is filled through multiple trades at different prices on the same day, each participating client will receive the average price, with transaction costs generally allocated pro rata based on the size of each client’s participation in the order (or allocation in the event of a partial fill) as determined by the Investment Adviser. In the event of a partial fill, allocations may be modified on a basis that the Investment Adviser deems to be appropriate, including, for example, in order to avoid odd lots or de minimis allocations. When orders are not aggregated, trades generally will be processed in the order that they are placed with the Digital Asset counterparty selected by the Investment Adviser. As a result, certain Digital Asset trades for one client (including a client in which the Investment Adviser and its personnel may have a direct or indirect interest) may receive more or less favorable prices or terms than another client, and orders placed later may not be filled entirely or at all, based upon the prevailing market prices at the time of the order or trade. In addition, some opportunities for reduced transaction costs and economies of scale may not be achieved. When in the best interests of clients and other pooled investment vehicles, the Investment Adviser causes a client or other pooled investment vehicle to purchase assets in an aggregated single order for such client and subsequently allocate positions in that purchase to other clients through the use of Cross Trades.

A. Economic Benefits for Providing Services to Clients We do not receive economic benefits from non-clients for providing investment advice with respect to securities. B. Compensation to Non-Supervised Persons for Client Referrals Neither we nor any of our related persons directly or indirectly compensates any person who is not a supervised person, including placement agents, for client referrals.

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

A. Frequency and Nature of Review of Client Accounts or Financial Plans We perform various daily, weekly, monthly, quarterly and periodic reviews of each client’s portfolio. Such reviews are conducted by the members of the Investment Adviser’s investment committee and trading team. B. Factors Prompting Review of Client Accounts Other than a Periodic Review A review of a client account may be triggered by any unusual activity or special circumstances. C. Content and Frequency of Account Reports to Clients We generally provide annual audited financial statements to our clients within 120 days of the applicable client’s fiscal year end (or as soon as reasonably practical). These reports are made available electronically via e-mail or through the Investment Adviser’s password-protected website. Investors in the Funds receive letters on a periodic basis from the Investment Adviser documenting the performance of their Fund, along with a commentary by the Investment Adviser, although the Investment Adviser may provide certain investors with information on a more frequent and detailed basis if agreed to by the Investment Adviser. Information also may be available through the Investment Adviser’s password-protected website. In addition, the Investment Adviser issues investors tax reports and audited financial statements concerning their respective Funds within 120 days of the end of the Fund’s fiscal year (or as soon as reasonably practical). While all investors generally receive similar information, to the extent an investor receives additional information (that other investors have not received), which is in addition to information provided in a Fund’s regular reports to investors, such information may provide such investor with greater insight into the Fund’s activities. This may enhance such investor’s ability to make investment decisions with respect to the Fund and possibly affect such investor’s decision to request a redemption from the Fund.

The Investment Adviser is deemed to have custody of client funds and securities because it has the authority to obtain client funds or securities, for example, by deducting advisory fees from a client’s account or otherwise withdrawing funds from a client’s account. Account statements related to clients are sent by qualified custodians to the Investment Adviser. The Investment Adviser is subject to 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. Depending on whether a Digital Asset is a security, the Investment Adviser maintains Digital Assets with a qualified custodian, a non-qualified custodian, or internally. The Investment Adviser maintains clients’ Digital Assets that are securities with qualified custodians where the custodian supports the maintenance of such assets. The Investment Adviser maintains clients’ Digital Assets that are not securities with third-party custodians that, although they are not classified as qualified custodians, have implemented systems to safeguard such assets that the Investment Adviser has reviewed and diligenced. At times, Digital Assets are moved to trading platforms in order to effectuate transactions and other portfolio management activities. The Investment Adviser stores certain Digital Assets internally, and the Investment Adviser has developed an internal custody platform that incorporates dedicated hardware, encryption and redundancy into its architecture.

The Investment Adviser serves as the management company with discretionary trading authority to each Fund. Our investment decisions and advice with respect to each Fund are subject to each Fund’s investment objectives and guidelines, as set forth in its offering documents. The Investment Adviser or an affiliate of the Investment Adviser entered into an investment management agreement, or similar agreement, with each Fund, pursuant to which the Investment Adviser or an affiliate of the Investment Adviser was granted discretionary trading authority.

A. Policies and Procedures Relating to Voting Client Securities In compliance with Advisers Act Rule 206(4)-6, the Investment Adviser has adopted proxy voting policies and procedures. The general policy is to vote proxy proposals, amendments, consents or resolutions (collectively, “Proxies”) in a prudent and diligent manner that will serve the applicable client’s best interests and is in line with each client’s investment objectives. We may take into account all relevant factors, as determined by us in our discretion, including, without limitation:

the impact on the value of the securities;

the anticipated associated costs and benefits associated with the proposal;

the effect on liquidity; and

customary industry and business practices.

In limited circumstances, the Investment Adviser may refrain from voting Proxies where we believe that voting would be inappropriate, taking into consideration the cost of voting the Proxies and the anticipated benefit to its clients. Generally, clients may not direct our vote in a particular solicitation. Conflicts of interest may arise between the interests of clients on the one hand and us or our affiliates on the other hand. If we determine that we may have, or be perceived to have, a conflict of interest when voting Proxies, we will vote in accordance with our Proxy voting policies and procedures. Clients may obtain a copy of our Proxy voting policies and our Proxy voting record upon request.

The Investment Adviser 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.