Peakline Partners, LLC

Firm Information Founded in 2017 by Avy Stein and Eric Becker as a Delaware limited liability company (“LLC”), Peakline Partners, LLC (“Peakline Partners”), is a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”). Peakline Partners is a wholly-owned subsidiary of Peakline Midco, LLC, which is a wholly-owned subsidiary of Peakline Parent, LLC. Peakline Parent is governed by a Board of Directors, which Board of Directors controls Peakline Partners through its ownership of Peakline Midco. Peakline Partners acts as investment manager to its clients along with certain affiliated entities that serve as general partners and managing members (as applicable) to many of its funds under a subadvisory agreement (each, in such capacity, a “Fund Manager”). Except where otherwise noted herein, all references to the “Adviser,” “us,” “we,” or “our” are intended to collectively encompass Peakline Partners and its affiliates (including the Fund Managers). A. Advisory Services Offered We provide discretionary investment management services solely to private investment funds, that are exempt from registration under the Investment Company Act of 1940, as amended (the “1940 Act”) and whose securities are not registered under the Securities Act of 1933, as amended (the “Securities Act”) (each, a “Fund,” and collectively, the “Funds”). Such discretionary investment management services primarily consist of sourcing, structuring, and negotiating investments and dispositions, monitoring the performance of investments and performing certain administrative services. The Funds to which the Adviser provides portfolio and investment management services include: (i) private equity, private credit, and venture capital funds (“PC Funds”) and (ii) real estate funds (“RE Funds”). These services are detailed in the offering documents for each Fund, which include as applicable, operating agreements, private placement memorandum and/or term sheets, subscription agreements, separate disclosure documents, and all amendments thereto (“Offering Documents”). The Adviser manages each Fund based on the investment objectives, policies and guidelines as set forth in the respective Fund’s Offering Documents and not in accordance with the individual needs or objectives of any particular investor therein. Each prospective investor interested in investing in a Fund is required to complete a subscription agreement in which the prospective investor attests as to whether or not such prospective investor meets the qualifications to invest in the Fund and further acknowledges and accepts the various risk factors associated with such an investment. In general, investors in the Funds are not permitted to impose restrictions or limitations. However, the Adviser or certain Fund Managers have entered into, and could in the future, enter into, side letter or other written agreements with one or more investors which have the effect of establishing rights under, or altering, modifying, or changing the terms of interest held by investors. Certain types of side letters create a conflict of interest among the Adviser and investors, and/or between investors themselves. For more detailed information on investment objectives, policies, and guidelines, please refer to the respective Fund’s Offering Documents.

Wrap Fee Programs The Adviser does not participate in wrap fee programs. B. Assets Under Management The Adviser managed $2,805,468,495 in client assets on a discretionary basis based on the fund valuations reported at the time of this annual filing which are primarily as of December 31, 2025. Such amount includes capital that can be called by certain Funds from investors. The Adviser does not manage client assets on a non-discretionary basis. Clients may request more current information at any time by contacting the Adviser.

The following paragraphs detail the fee structure and compensation methodology for services provided by the Adviser. PC Funds As compensation for the investment management services rendered to each PC Fund, the Adviser typically receives an annual management fee that is calculated and payable quarterly in advance pursuant to the terms of the Adviser’s agreement with the relevant PC Fund and Offering Documents thereof. Such management fees are generally based on the invested capital amount at the end of the previous quarter and at an annual rate of up to 2.00%. If an investor withdraws from a PC Fund, the Adviser will refund any unearned portion of any advance payment back to such Fund. RE Funds As compensation for the investment management services rendered to each RE Fund, the Adviser typically receives an annual management fee at an annual rate of up to 1.50%, calculated and payable quarterly in advance. Certain real estate investments may also have an asset oversight and accounting fee which is a fixed fee that is paid to the Adviser and is typically less than $100,000 annually. Fund Expenses In general, each Fund will also bear all costs and expenses related to their organization, management and operation, including, but not limited to:

expenses incurred in connection with the formation of the Fund, the Fund’s investment management entity (i.e., the general partner) and other vehicles or entities, as applicable;

expenses incurred in the offering of the Fund’s interests;

the costs related to acquiring, holding and disposing of investments;

third-party legal, accounting, tax and other consulting fees;

fees paid to the administrator;

costs associated with preparing and distributing tax documents and reports;

In certain circumstances, costs and expenses paid to third-party broker-dealers connection with raising capital;

premiums for insurance; and

certain taxes.

Other Fees The Adviser receives and, in the future, expects to receive, certain acquisition, disposition, capital structuring, consulting, advisory, directors’, investment banking, monitoring, transaction, closing, break-up, real estate brokerage, asset management, construction management, guaranty, development or other transactional fees or fees for services rendered in relation to the investments held by the Funds (“Other Fees”); provided that any such Other Fees are within a reasonable range of market-standard fees and compensation that would be paid to third-party providers pursuant to an arm’s length agreement. The Adviser does not buy or sell securities, other than the recommendation of interests in the Funds, and does not receive any compensation for securities transactions in any client account, other than the management fees noted above and performance-based fees noted below. For more detailed information on the fees and compensation received by the Adviser and its affiliates, please refer to the respective Fund’s Offering Documents.

A. Methods of Analysis and Investment Strategies The Adviser serves as the investment manager to each Fund. The Adviser generally seeks investments in projects, companies, credit, leases, other assets or opportunities in which its investment professionals have prior industry, operating and/or investing experience. Each Fund has specific investment strategies, which are detailed in the respective Offering Documents. More details on the Adviser’s present focus strategies are below:

Real Estate – generally seeks high-quality, institutional real estate investments in multifamily, office, industrial & logistics, and hospitality development projects.

Private Equity – targets investments that the Adviser believes offer potential long-term risk-adjusted returns, with a focus on market sectors with favorable macro-growth fundamentals and relatively low cyclicality, including healthcare, food and beverage, financial services, and specialty manufacturing.

Private Credit – focused on direct lending and leasing, which includes any debt or assets held by or extended to privately held companies and most commonly involves non-bank institutions making loans or leasing equipment to private companies.

Venture Capital – generally seeks investments in early stage, growth equity, and buyout opportunities.

Investment structures generally include direct investments, co-investments, secondary investments, joint venture arrangements, and investments in third-party funds. The Adviser generally sources investment opportunities consistent with these strategies by leveraging Peakline Partners’ ecosystem of entrepreneurs, business owners, family offices, experts and referral partners. Opportunities are typically screened or evaluated using both qualitative and quantitative analyses. After an opportunity has gone through an analysis, then the opportunity is either rejected or taken to the Investment Committee for that particular Fund. The applicable Investment Committee will hold a vote on whether to pursue the opportunity. The Adviser provides advice and direction to each Fund during the entirety of the investment process, from sourcing to realization in an effort to create value. B. Risk Factors General Investment and Strategy Risks Risk of Loss; No Assurance of Investment Return – An investment in the Funds requires a long-term commitment with no certainty of return. The Funds normally invest in securities, companies or sectors that are not publicly traded. These investments are generally illiquid and can be volatile; therefore, they are not suitable for investors who may need the proceeds of such investments for frequent or unknown cash needs. There is normally no public market for the types of investments in which the Funds invest. If investors need to sell their Fund interests, they would likely do so at a substantial discount. Further, depending on the terms of the investment, the investor may not be able to transfer or sell his/her Fund interests. The risk of investing in alternative investments is the majority or complete loss of invested monies, depending on the underlying assets. In addition, investors may not see any return on investment for some time depending on the type of investment; these investments should be seen as a long-term investment subject to high risk of loss. The risk factors discussed below do not purport to be an exhaustive list of all such risks. For a more detailed discussion of the specific risks associated with each Fund and its underlying investments, please refer to each Fund’s respective Offering Documents, which should be read fully in order to understand all applicable risks. Lack of Liquidity of Investments – The Funds are generally illiquid. Although the Funds’ investments could generate current income, the return of capital and the realization of gains, if any, from such investments is expected to occur upon their disposition. In addition, it is expected that investments will not be sold until a number of years after they are made. The types of investments held by the Funds may be such that they require a substantial length of time to liquidate. Given the nature of these investments, a Fund may be unable to realize its investment objectives by sale or other disposition at attractive prices within any given period of time or may otherwise be unable to complete any exit strategy for its investments. In some cases, the Funds may be prohibited by contract from selling investments for a period of time, or there may be contractual rights or obligations that may otherwise significantly affect price and/or liquidity. In the event a loan repayment or other funding obligation arises at a time in which a Fund does not have sufficient cash assets to cover such payment, such Fund may have to liquidate certain

investments at less than their expected returns to satisfy the obligations thereby, resulting in lower realized proceeds to a Fund than might otherwise be the case. Underlying Investments – The Funds are subject to risks incident to the ownership of the underlying investments, including: changes in general economic or local conditions; changes in investment preferences that reduce the attractiveness of a Fund’s underlying investments to investors; increases in maintenance, insurance and other operating costs; changes in tax laws and rates; and changes in the laws and regulations applicable to any one or more underlying investments. Concentration Risk – Because each Fund generally invests in a limited number of investments (sometimes, only a single investment), its overall returns could be adversely affected by the negative performance of a single investment. Such a risk will be considerably greater than if the Fund were not permitted to concentrate their investments to such an extent. To the extent a Fund concentrates investments in a particular geographic region, security, sector, industry or stage of investment, it will be more susceptible to fluctuations in value resulting from adverse economic or business conditions relating thereto. In addition, the Funds may make investments in some transactions with the intent of refinancing or selling a portion thereof, and in such cases, there will be the risk that a Fund will be unable to complete the refinancing or sale, which could lead to increased risk as a result of a Fund having an unintended long-term investment and reduced diversification. Risks Upon Dispositions of Investments – In connection with the disposition of a Fund investment, a Fund will generally need to make representations about the business and financial affairs of such asset typical of those made in connection with the sale of such a business or asset. It could also be required to indemnify the purchasers of such investment if any such representation turns out to be inaccurate. These arrangements create contingent liabilities for a Fund, which might ultimately have to be funded by the Fund investors if such contingent liabilities exceed the reserves and other assets of the Fund and such investors have received prior distributions from the Fund. Furthermore, under the Delaware Revised Uniform Limited Partnership Act and Revised Uniform Limited Liability Company Act, as applicable, each investor that receives a distribution in violation of such act must, in some cases, return such distribution to the Fund. Early Termination of a Fund and/or Distributions in Kind – Pursuant to the respective Fund’s governing documents, it can be dissolved and terminated prematurely and therefore could be unable to accomplish its objectives or required to dispose of its investments at a disadvantageous time or make an in-kind distribution (causing investors not having their capital invested or deployed in the manner originally contemplated, or causing the investments to be liquidated at a time when values are relatively low). Risk of Uninsured Losses – While the Funds tend to carry customary comprehensive liability and casualty insurance, certain insurance policies may not be available or may be available only at prohibitive cost. In addition, losses may exceed insurance policy limits, and policies may contain exclusions with respect to various types of losses or other matters. Consequently, all or a portion of a Fund’s investments may not be covered by insurance, and insurance may not cover all losses. Recourse to a Fund’s Assets – A Fund’s assets, including any investments made by such Fund, are available to satisfy all liabilities and other obligations of the Fund. If a Fund itself becomes subject to a liability, parties seeking to have the liability satisfied could have recourse to the Fund’s

assets generally and not be limited to any particular asset, such as the investment leading to the liability. Highly Competitive Market for Investment Opportunities – The activity of identifying, completing, and realizing attractive Fund investments is long and complex and involves a high degree of uncertainty, especially with respect to timing. In addition, searching for appropriate investments is highly competitive. Even if investment opportunities are identified, there can be no assurance that a Fund’s bids to acquire interests in such investments will succeed; and, upon a successful bid, legal or contractual transfer restrictions, including rights-of-first-refusal, changeof-control, and similar provisions applicable to such investment could prevent a Fund from acquiring all or a portion of such investment. In addition, the Adviser could be unable to obtain as favorable terms as it would otherwise in a less competitive investment environment. The availability of investment opportunities generally will be subject to market conditions as well as the prevailing regulatory or political climate. In addition, the current private investment environment has become even more competitive as other market participants, including hedge funds and special purpose acquisition companies, have been competing for investment opportunities that have traditionally been targeted by private investment funds. The Funds will be competing with other investors, private equity and real estate funds, financial institutions and corporate or strategic buyers, some of which will have greater resources than the Funds, for the investments that the Funds would like to make. Furthermore, additional pooled investment vehicles with similar investment objectives are expected to be formed in the future by other unrelated parties. As a result, there can be no assurance that the Funds will be able to identify and complete Fund investments that satisfy their investment objectives or realize the value of those Fund investments, or that they will be able to fully invest their commitments. The Funds could incur significant expenses investigating potential investments that are ultimately not consummated, including expenses relating to due diligence, transportation, legal expenses and the fees of other third-party advisors. Borrowing and Leverage – Sometimes, the Funds are permitted to borrow or obtain leverage on a secured or unsecured basis and to borrow funds or otherwise obtain leverage for the purpose of making investments as well as for other purposes, including to make distributions to its investors, which will be in addition to indebtedness that is incurred, directly or indirectly, by the Fund’s underlying investments. Accordingly, a Fund could effectively be highly leveraged at any given time, however such instances are expected to be infrequent and temporary due to limitations on subscription line borrowings. The interest expense and other costs incurred in connection with such borrowings may not be recovered by appreciation of or cash flow from such Fund’s investments. If the investments’ performance fails to cover the cost of borrowings, a Fund’s assets (including uncalled capital commitments) could decrease faster than if there had been no borrowings. Additionally, if a Fund’s investments fail to perform to expectation or suffer losses, the value of the Fund’s investments, and therefore the underlying investors’ investment, will decrease more than if the Fund had not incurred borrowings or other leverage, so that borrowings or other leverage will magnify any such adverse consequences. Repayment of borrowings and other leverage incurred by a Fund is an obligation senior to the equity investments of its investors, and the agreements for such obligations may prohibit distributions to its investors in certain circumstances. Further, to the extent income received from investments is used to make interest and principal payments, the investors in such Fund could nonetheless be allocated income, and therefore have tax liability in excess of cash received by them in distributions. Where a Fund is permitted to engage in portfolio financing where several investments are cross-collateralized, multiple investments may be subject to the risk of loss. As a result, such Fund could lose its interests in performing investments in the event such investments are cross-collateralized with 10 | P a g e

Read the rest in the brochure

The Adviser offers portfolio management services solely to its Fund clients; therefore, references throughout this Brochure to “clients” and to the Adviser’s related duties to, and practices on behalf of, its clients and/or investors should be construed accordingly. As such, the Adviser has only one type of client: private investment funds. The Funds generally include investment partnerships, limited liability companies or other investment entities that are not registered under the 1940 Act in reliance on the exemptions provided in Sections 3(c)(1), 3(c)(5) and 3(c)(7) thereunder, as applicable. Additionally, the interests, shares or units (as applicable) are not registered under the Securities Act pursuant to an exemption from registration under Regulation D thereunder. Generally, the investors in the Funds meet the definition of “accredited investor” as defined in Regulation D, “qualified purchaser” as defined in Section 2(a)(51) of the 1940 Act, and “qualified client” as defined in Rule 205-3 under the Advisers Act, and/or (iv) “knowledgeable employee” under Rule 3c-5 of the 1940 Act. Such investors include individuals, entities, trusts, estates, other corporations or business entities, or family offices. In addition, owners, principals and other related persons of the Adviser can and have invested in one or more of the Funds. Investors who wish for more information about the Funds, or to subscribe for an interest therein will be required to demonstrate their investment qualifications prior to accessing any information about Peakline Partners’ Funds. The various requirements for investing in a Fund, including the minimum investment size, are set forth in each Fund’s Offering Documents. The Adviser has the ability, in its sole discretion, to permit commitments below the minimum amounts set forth in the Offering Documents.

Each Fund Manager (in each case, an affiliate of Peakline Partners) is generally entitled to a performance-based fee (or “carried interest”) on the Fund’s profits in accordance with the provisions of the respective Fund’s Offering Documents. The amount of carried interest, and how it is calculated, varies by Fund but is generally equal to a percentage of the investment proceeds distributable by the Fund in excess of the capital invested by the Fund’s investors and their allocable share of fees and expenses, is sometimes subject to a preferred return, and in any event is paid out of cash otherwise distributable to investors. Additional information regarding the calculation of such fees is fully disclosed in the applicable Fund’s Offering Documents. Investors should understand that the receipt of performance-based fees creates a conflict of interest as the Adviser has the potential to receive higher compensation. Performance-based fees create an incentive for the Adviser to make investments that are riskier or more speculative than might otherwise be the case in the absence of such arrangement. Additionally, the Adviser is incentivized to favor and devote more time and effort to managing investments when there is a potential for receipt of carried interest. In allocating investments, the Adviser has an incentive to favor Funds with higher potential for carried interest distributions over Funds with lower potential for carried interest. As explained in Item 11 below, the Adviser seeks to mitigate these conflicts through disclosures in this Brochure; additional disclosures in the applicable Offering Documents, as well as through the Adviser’s Code of Ethics and policies and procedures contained in its Compliance Manual.

A. Financial Industry Affiliations Cresset Asset Management, LLC Cresset Asset Management, LLC (“CAM”), an affiliated entity through common control, is also a registered investment adviser with the SEC. CAM offers investment advisory, financial planning and family office services to individuals, high net worth individuals, trusts, estates, retirement plans, charitable organizations, corporations, other business entities and pooled investment vehicles. CAM may conduct business under one or more ‘doing business as’ names, including CH Investment Partners. The Adviser may refer investors to utilize the advisory services of CAM. Due to the affiliation, owners will benefit financially in their individual capacity if investors utilize the advisory services of CAM. Any investor that is referred to CAM will receive additional disclosure information which will include relevant details regarding material financial interests and compensation surrounding the utilization of these services. There is no requirement for the Adviser to recommend the services of CAM, nor are investors obligated to utilize CAM’s services in order to invest in the Peakline Partner Funds. The Adviser is governed by a Board of Directors, whose Directors overlap with the Board of Directors of Cresset Capital Management, LLC, which in turn owns and controls CAM. Because the overlapping Directors will govern both the Adviser and CAM, such overlapping Directors could have an incentive to favor one such investment adviser over the other. These overlapping Directors could also face competing obligations among each investment adviser from a time commitment and cost allocation perspective. To address these conflicts, the Adviser will monitor such competing interests and take any steps it deems appropriate to ensure that its clients and investors are ultimately treated fairly and equitably over time. Willis Stein & Partners Management III, L.P. The Adviser is affiliated, through common ownership, with Willis Stein & Partners Management III, L.P. (herein “Management III”), a Delaware limited partnership and general partner of several private equity funds. Investors in the Funds will not be offered private equity funds of Management III. The Adviser shares premises and employees with Management III, however, Management III has no other business dealings in connection with the Adviser’s investment advisory business or services provided to the Funds, and the Adviser has no reason to believe that this sharing with Management III creates a conflict of interest. All appropriate and necessary security policies and procedures are in place to ensure security of Fund information. Caretta Partners, LLC The Adviser is affiliated, through common ownership, with Caretta Partners, LLC (“Caretta”). Caretta is a private equity and venture capital firm specializing in early stage, growth equity, and buyout investments. The Adviser shares premises with Caretta, however, Caretta has no other business dealings in connection with the Adviser’s investment advisory business or services provided to the Funds, and the Adviser has no reason to believe that this sharing with Caretta creates a conflict of interest. All appropriate and necessary security policies and procedures are in place to ensure security of Fund information. While certain of the Adviser’s supervised persons 29 | P a g e

and Fund investors are currently invested in Caretta, which occurred prior to the establishment of the Funds, the Adviser does not currently offer any investment opportunities in or managed by Caretta. VennPoint Real Estate, LLC The Adviser is affiliated, through common ownership, with VennPoint Real Estate, LLC (“VennPoint”). VennPoint invests in real estate for local communities, focused on the development, redevelopment and acquisition of property. While certain supervised persons and Fund investors are currently invested in VennPoint, which occurred prior to the establishment of the Funds, the Adviser does not currently offer any investment opportunities in or managed by VennPoint. True Capital Insurance Services, LLC True Capital Insurance Services, LLC (“TCIS”), is an affiliated insurance brokerage company, licensed as such in AZ, CA, FL, TX, TN, and WA, offering life and disability insurance placed through various carriers. TCIS also provides consulting services related to minimizing risk and protecting assets through health, umbrella, and property and casualty insurance. Certain licensed agents are authorized to act on behalf of TCIS and may sell life and disability insurance placed through various carriers. These services may be offered to clients of CAM, an affiliate of the Adviser, who may also be investors in the Adviser’s Funds. The Adviser does not utilize any of TCIS’s services and there is no requirement that a TCIS agent recommend TCIS or its services to the Adviser, nor are any investors in the Adviser’s Funds obligated to utilize TCIS or any of its services. Additionally, the Adviser does not receive any compensation or fees from the activities of TCIS. While the Adviser endeavors at all times to put the interests of its clients/investors first, the affiliated relationship between TCIS and the Adviser inherently creates a conflict of interest as both entities are under common control. This conflict is disclosed to all clients/investors of the Adviser if offered any TCIS service. See “Cresset Asset Management, LLC” in this section above for further information. Cresset Trust Company, LLC The Adviser is affiliated, through common control, with Cresset Trust Company, LLC (“CTC”) (fka Meristem Trust Company, LLC). CTC received its Certificate of Authority to transact business as a South Dakota-chartered public trust company effective March 30, 2015. All account administration and trust company operations are performed in South Dakota through services agreements with South Dakota Trust Company, LLC, and SDTC Services, LLC. Through this affiliation, trust services can be offered to investors of the Adviser and the Adviser’s funds can be offered to CTC trust clients. Conflicts arise due to this affiliation where CTC is responsible for making investment decisions for an investor’s trust and where the potential for additional economic benefit exists when such decisions involve an affiliated fund of the Adviser. Accordingly, if CTC has a role in making investment decisions, it agrees that any decision will be made independent of any consideration relative to the economic impact of such investments. Further, all investment recommendations of trust accounts will be based solely on the best interests of the trust. As an SEC registered investment adviser to Funds, the Adviser does not utilize the trust services of CTC or receive any direct or indirect economic benefit due to this affiliation.

30 | P a g e

The Connable Office, a Cresset Company The Adviser is affiliated, through common control, with The Connable Office, Inc. (the “Connable Office”), a Michigan-based multi-family office and organized as a private trust company. Through this affiliation, the Connable Office’s trust services can be offered to investors of the Adviser and the Adviser’s funds can be offered to trust clients of the Connable Office. Conflicts arise due to this affiliation where the Connable Office is responsible for making investment decisions for an investor’s trust and where the potential for additional economic benefit exists when such decisions involve an affiliated fund of the Adviser. Accordingly, if the Connable Office has a role in making investment decisions, it agrees that any decision will be made independent of any consideration relative to the economic impact of such investments. Further, all investment recommendations of trust accounts will be based solely on the best interests of the trust. Monticello Associates, LLC The Adviser is affiliated, through common control, with Monticello Associates, LLC (“Monticello”), who is also a registered investment adviser with the SEC. Monticello offers asset management consulting services to its clients, which includes endowments, foundations, high net-worth families, and retirement plans. The Adviser may refer investors to utilize the advisory services of Monticello. Due to the affiliation, owners will benefit financially in their individual capacity if investors utilize the advisory services of Monticello. Any investor that is referred to Monticello will receive additional disclosure information which will include relevant details regarding material financial interests and compensation surrounding the utilization of these services. There is no requirement for the Adviser to recommend the services of Monticello, nor are investors obligated to utilize Monticello’s services in order to invest in the Peakline Partner Funds.

Trading A.

Code of Ethics

The Adviser has implemented a Code of Ethics (the “Code”) that applies to all persons associated with Peakline Partners (our “Supervised Persons”) and which defines our fiduciary commitment to each client. The Code requires all Supervised Persons to place the interests of the Funds and investors above their own interests or those of the Adviser and its affiliates. Specifically, the Adviser and its Supervised Persons owe a duty of loyalty, fairness, and good faith towards each client. It is the obligation of the Adviser’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest, including insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. To request a copy of our Code, please contact us at (312) 429-2401 or via email at info@peakline.com. B.

Personal Trading with Material Interest

The Adviser allows Supervised Persons and personnel of affiliated entities as referenced in Item 10 (herein collectively as “Peakline Entities”) to purchase or sell the same securities that may be recommended to and/or purchased on behalf of its Clients or Fund Investors. The Adviser does not act as principal in any transactions. In addition, the Adviser itself does not act as the general partner 31 | P a g e

of a Fund or advise an investment company, though certain of its affiliate entities act in such capacity. The Adviser does not have a material interest in any securities traded in Client or Investor accounts. C.

Personal Trading in Same Securities as Clients

The Adviser allows Supervised Persons and personnel of Peakline Entities to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that we recommend (purchase or sell) to you presents a conflict of interest that, as fiduciaries, we must disclose to you and mitigate through policies and procedures. As noted above, we have adopted the Code to address and manage such conflicts. When trading for personal accounts, Supervised Persons may have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can potentially be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material nonpublic information. Supervised Persons may receive more favorable terms when investing alongside Clients in the same investment opportunities, such as reduced or waived fees and/or carried interest. This risk is mitigated by the Adviser conducting a coordinated review of personal accounts and the accounts of its Clients. We have also adopted written policies and procedures to detect the misuse of material, non-public information. Related Persons of the Adviser may invest alongside Client Funds in certain investment opportunities, and certain personnel or Related Persons may also have an interest in the allocation of investors among the Funds. These circumstances create conflicts of interest because the Adviser and its personnel may have material financial interests that could influence decisions regarding the allocation of investors to particular Funds or the allocation of investment opportunities among participating Funds and Related Persons. The Adviser has adopted policies and procedures governing allocation designed to identify, manage, and mitigate these conflicts, including policies governing the allocation of investors among the Funds and the allocation of investment opportunities. The Adviser allocates investors among the Funds will not give preferential treatment to Related Persons. Similarly, in the event an investment opportunity is oversubscribed, other investment vehicles of Related Persons will be excluded from participation to ensure that Client Funds receive priority. D.

Personal Trading at Same Time as Client

The Adviser allows Supervised Persons and personnel of Peakline Entities to purchase or sell the same securities that may be held by the Funds. In these instances, Supervised Persons trades are typically executed after trades in the Funds. At no time will the Adviser, or any Supervised Person of the Adviser, transact in any security to the detriment of any Client. *** The foregoing list of conflicts of interest does not purport to be a complete enumeration or explanation of the conflicts of interest involved in an investment in a Fund.

Recommendation of Custodians

32 | P a g e

The Adviser does not make regular use of brokers for the purposes of purchasing or selling securities on behalf of its Clients because the securities that typically purchased or sold on behalf of the Funds are acquired and/or disposed of in privately negotiated purchase and sale transactions. When, on occasion, the Adviser or the Funds transact in publicly traded securities, the Adviser will seek to facilitate such transactions through the retention of broker-dealer/custodian (herein the “Custodian”) for custody and execution services. The Adviser has the sole discretion over the purchase and sale of investments (including the size of such transactions) and the Custodian, if any, to be used to effect transactions. In placing each transaction for the Fund involving a Custodian, the Adviser will seek “best execution” of the transaction except to the extent it may be permitted to pay higher brokerage commissions in exchange for brokerage and research services. When seeking best execution, the main factor is not the lowest cost, but whether the transaction represents the overall best qualitative execution, taking into consideration the full range of a broker-dealer/custodian’s services, including among other things, execution capability, commission rates, responsiveness, and reputation of the Custodian. Following are additional details regarding the brokerage practices of the Adviser: 1. Soft Dollars – Soft dollars are revenue programs offered by broker-dealers/custodians whereby an investment adviser enters into an agreement to place security trades therewith in exchange for research and other services. The Adviser does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. 2. Brokerage Referrals – The Adviser does not receive compensation from any third party in connection with the selection of a Custodian. 3. Directed Brokerage – The Adviser has the sole discretion over the purchase and sale of investments (including the size of such transactions) and the Custodian, if any, to be used to effect transactions. B.

Aggregating and Allocating Trades

As each of the Funds has different underlying investments, there is generally not an opportunity to aggregate orders among the Funds. To the extent that more than one investment opportunity is suitable for multiple Funds, the Adviser will seek to allocate the opportunity in a manner that is fair and equitable to each eligible Fund in accordance with the Offering Documents of such Funds and in accordance with its Allocation Policy. Additionally, in instances in which a Fund's investment opportunity is oversubscribed, the Adviser will allocate the investment opportunity among investors in such Fund in accordance with its Allocation Policy and the applicable Offering Documents. The Adviser’s Allocation Policy prioritizes entities that have entered into most-favored-nations arrangements with the Adviser and takes into account factors including, but not limited to, the size of the investment, risk management considerations, and the tax, legal, contractual and/or regulatory burdens applicable to an investor, as well as the nature and scope of the relationship between the Adviser and the investor.

Compensation Received by the Adviser

The Adviser does not receive commissions or other compensation from product sponsors, brokerdealers or any unrelated third parties. The Adviser is permitted to refer investors to various unaffiliated, non-advisory professionals (e.g., attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its investors. Likewise, the Adviser may receive non-compensated referrals of prospective investors from various third parties. B.

Referrals from Promoters

The Adviser may use promoters to refer investors, and may compensate such promoters for those services. In using promoters, the Adviser must comply with Advisers Act Rule 206(4)-1 and any related state securities requirements. Except for employees and certain affiliated persons of the Adviser, in accordance with exemptions under the rule, the promoter must disclose certain aspects of its relationship with the Adviser if receiving compensation greater than the de minimis amount.

There are no legal, regulatory, or disciplinary events involving the Adviser or its management. The Adviser values the trust you place in us. As we advise all investors, we encourage you to perform the requisite due diligence on any Adviser or service provider with whom you partner. Our backgrounds are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching our firm name or our CRD# 306449. 28 | P a g e

The investments made by the Funds are generally private, illiquid, and long-term in nature. Accordingly, the review process is not directed toward a short-term decision to dispose of securities. However, the Adviser closely monitors companies and other assets in which the Funds invest, and 33 | P a g e

the Adviser’s compliance function periodically checks to confirm that each Fund is maintained in accordance with its stated objectives as outlined in the Offering Documents. Investors in the Funds will receive statements no less than quarterly from the administrator. These statements are sent directly from the administrator to the investor. The Adviser may also provide investors with periodic reports regarding the respective Fund’s holdings, allocations, and performance. Investors are encouraged to notify the Adviser if changes occur in their personal financial situation that might impact the appropriateness of investing in a Fund.

The Adviser is deemed to have “custody” (within the meaning of Advisers Act Rule 206(4)-2) of Client assets held in the name of one or more Funds and maintain such assets with a qualified custodian. In accordance with the requirements of Rule 206(4)-2, each of the Funds obtains an annual audit of its financial statements performed by an independent public accountant that is registered with, and subject to examination by the Public Company Accounting Oversight Board (PCAOB). Copies of the annual audited financial statements, which are prepared in accordance with generally accepted accounting principles, are distributed to all investors within the following time frames of the end of the fiscal year of the Fund: 120 days for funds, 180 days for fund of funds, and 260 days for fund of funds of funds. Investors should carefully review statements received from thirdparty custodians and should compare the audited annual financial statements received from a Fund against the account statements received from the qualified custodian.

The Adviser generally has discretion to make investment decisions on behalf of the Funds. Investment decisions shall be made in accordance with the investment objectives, policies and guidelines as set forth in the respective Offering Documents and not in accordance with the 34 | P a g e

individual needs or objectives of any particular investor therein. The Adviser assumes this discretionary authority pursuant to the terms outlined in the Offering Documents.

The Adviser does not accept proxy-voting responsibility for any Fund as the Funds’ underlying investments, which consist of real estate and private securities, generally do not issue proxies.

Neither the Adviser, nor its management, have any adverse financial situations that would reasonably impair the ability of the Adviser to meet all obligations to its Clients. Neither the Adviser, nor any of its management, have been subject to a bankruptcy or financial compromise. The Adviser is not required to deliver a balance sheet along with this Brochure as the Adviser does not collect advanced fees of $1,200 or more for services to be performed six months or more in the future.

35 | P a g e