Pharo Management

Pharo Management was incorporated on February 25, 2019, in the State of Delaware and is based in New York City. It is the successor to Pharo Management LLC, a Delaware limited liability company formed by Guillaume Fonkenell in 2000. Pharo Management serves as an investment adviser to Pharo Macro Fund, Ltd., Pharo Trading Fund, Ltd., Pharo Africa Fund, Ltd., Pharo Gaia Fund, Ltd., Pharo Allocation Fund, Ltd., and Pharo Opportunities Fund SPC (collectively, the “Pharo Hedge Funds”). Pharo Management LLC registered with the SEC as an investment adviser on February 10, 2012, and with the Commodity Futures Trading Commission (the “CFTC”) as a commodity pool operator (“CPO”) on January 1, 2013. As part of a restructuring of the Pharo group in 2019, Pharo Management LLC converted to a limited partnership under Delaware law, changed its name to Pharo Management, L.P., and contributed its assets, liabilities and business to Pharo Management in exchange for all the issued stock of Pharo Management, making Pharo Management, L.P. the sole owner of Pharo Management. The general partner of Pharo Management, L.P. is Pharo GP LLC, a Delaware limited liability company owned and controlled by Guillaume Fonkenell. Mr. Fonkenell also is the Chief Investment Officer and Chairman of the Board of Directors of Pharo Management. Pharo Management is registered with the SEC as an investment adviser, having succeeded to the registration of Pharo Management LLC. On March 14, 2019, Pharo Management registered as a CPO with the CFTC. It is a member in good standing of the National Futures Association (“NFA”). Pharo Management, L.P. (formerly Pharo Management LLC) is no longer registered as an investment adviser or CPO. Pharo Global Advisors Limited (“PGAL”), a Jersey, Channel Islands corporation formed in 2004, served as the Investment Manager of the Pharo Hedge Funds until August 11, 2019. On August 12, 2019, Pharo Management was substituted for PGAL as Investment Manager and assumed the responsibilities and obligations of PGAL under the Investment Management Agreements PGAL had with the Pharo Hedge Funds. PGAL was registered with the Jersey Financial Services Commission, but de-registered on September 23, 2019, when it ceased performing the functions that require JFSC registration. In 2005, Guillaume moved to London and established Pharo Management (UK) LLP (“Pharo UK”), where he serves as a Member. Pharo UK serves as an investment advisor to the Pharo Hedge Funds and is authorized by the UK Financial Conduct Authority. Pharo Management (HK) Limited (“Pharo HK”), located in Hong Kong, was established in 2010 and also serves as an investment advisor to the Pharo Hedge Funds. Pharo HK is registered with the Hong Kong Securities and Futures Commission.

Pharo Manarah Limited (“Pharo AD”), located in Abu Dhabi, United Arab Emirates, was established in 2025 and also serves as an investment advisor to the Pharo Hedge Funds. Pharo AD is registered with the ADGM Financial Services Regulatory Authority. Pharo UK, Pharo HK, and Pharo AD are affiliates of Pharo Management and are collectively hereinafter referred to as the “Affiliated Investment Advisors”. Pharo UK, Pharo HK, and Pharo AD each provide discretionary investment advisory services to the Pharo Hedge Funds pursuant to sub-advisory agreements with Pharo Management. Pharo Management is the Investment Manager of the Pharo Hedge Funds, each of which is a Cayman Islands exempted company registered with the Cayman Islands Monetary Authority pursuant to the Cayman Islands Mutual Funds Act. Pharo Management also is the Manager of Pharo Allocation Fund, Ltd., a Cayman Islands exempted company registered with the Cayman Islands Monetary Authority pursuant to the Cayman Islands Mutual Funds Act. The sole purpose of Pharo Allocation Fund, Ltd. is to facilitate the allocation of investor capital across the Pharo Hedge Funds. Pharo Management trades primarily in emerging markets across a broad range of global assets. Pharo Management is not restricted in its activities and has authority to trade in any market or situation it believes advantageous to the Pharo Hedge Funds, including investing in developed markets across the same range of asset classes. Pharo Management advises fourof the Pharo Hedge Funds but can advise one or all of the Pharo Hedge Funds at any given time pursuant to its Investment Management Agreements with the Pharo Hedge Funds and the capital allocations in effect at such time. Pharo Management may in the future advise other Pharo private funds as well as funds managed by unaffiliated investment managers. Pharo Management provides discretionary advisory services pursuant to the investment objectives and strategies of the Pharo Hedge Funds disclosed in their respective Information Memorandums. We tailor our advice to the investment objectives of the Pharo Hedge Funds we advise. As of December 31, 2025, Pharo Management advised on a discretionary basis $1,794,000,000 of client assets. This amount represents the internal capital allocation made to Pharo Management from the assets of the Pharo Hedge Funds and differs from the regulatory assets under management (RAUM) disclosed in Item 5.F of Form ADV Part 1A. Item 5.F of Form ADV Part 1A discloses RAUM of $14,616,287,000, which represents the aggregate RAUM of all the Pharo Hedge Funds, not just the portion of those assets allocated to and managed by Pharo Management. Pharo Management does not manage client assets on a nondiscretionary basis. The Pharo Macro Fund, Ltd. invests a portion of its NAV in the

Pharo Africa Fund, Ltd., which increases the Pharo Africa Fund’s NAV by the size of the Pharo Macro Fund’s investment. Pharo Management does not double count the amount of this investment in the Firm’s RAUM calculation. It is possible that the sum of the capital allocations to Pharo Management’s Portfolio Managers (PMs), together with the capital allocations to the PMs of Pharo UK, Pharo HK, and Pharo AD, may be higher or lower than the aggregate net asset values of the Pharo Hedge Funds.

Pharo Management does not have a standardized fee schedule for its discretionary investment management services. Pursuant to its Investment Management Agreements with the Pharo Hedge Funds, Pharo Management generally receives a monthly management fee equal to one-twelfth of two percent of the net asset value of the shares of each fund (2% per annum) and an annual performance fee equal to 20% of the increase, if any, in the value of each class of shares of each fund during each performance period, subject to a high-water mark. Pharo Management charges a lower management fee and higher performance fee on certain share classes of certain Pharo Hedge Funds. Such fees are disclosed in the Information Memorandums of the applicable Pharo Hedge Funds. Management fees are charged by Pharo Management monthly in arrears and performance fees are charged annually (although certain funds have a longer performance fee cycle for certain share classes) in arrears and upon an intra-year redemption of shares. Pharo Management’s performance-based fees are calculated taking into account both realized and unrealized gains and are based on the overall performance of each Pharo Hedge Fund, which is not dependent entirely on the performance of Pharo Management. The management fees and performance fees paid by each Pharo Hedge Fund are set forth in the Information Memorandum of the Pharo Hedge Fund. The Administrator of the Pharo Hedge Funds calculates the management fees and performance fees owed to Pharo Management, which are then reviewed and approved by Pharo Management. The fees are then paid by the Administrator to Pharo Management from the assets of the Pharo Hedge Funds. Pharo Management pays the Affiliated Investment Advisors a portion of the management fees and performance fees based upon the terms of its sub-advisory agreements with Pharo UK, Pharo HK, and Pharo AD. Pharo Management does not accept compensation for the sale of securities or other investment products, including asset-based sales charges. The Pharo Hedge Funds pay or reimburse Pharo Management for all of their normal recurring operating expenses, including, without limitation: the cost of maintaining the fund’s corporate existence and registered office; Directors’ fees; the cost of attendance by the Directors at meetings of the Board of Directors;

brokerage commissions and all other investment-related expenses, including fees and expenses incurred in connection with investigating potential investments or seeking to maximize returns on existing investments; custodian safekeeping fees monthly in arrears based on assets in custody and transaction fees charged per transaction, in each case based on the custodian’s standard schedule of fees charged for similar services and subject to a monthly minimum; fees charged by prime brokers, FCMs, exchanges and clearing houses related to trading and settling and clearing transactions on behalf of the Pharo Hedge Funds; costs associated with failed trades that did not result from Pharo Management’s willful misfeasance, bad faith or gross negligence; insurance premiums (including cyber security insurance premiums, prorated in the case of policies having more than one insured party); interest expense on borrowings and commitment fees and related expenses payable to lenders; taxes imposed on the Pharo Hedge Funds; fees and expenses for research (to the extent described in each Pharo Hedge Fund’s Information Memorandum) and data, including the cost of Bloomberg terminals used by investment personnel; consulting, statistical and risk reporting services; fees of valuation agents engaged by Pharo Management; the cost of business and research-related travel related to the Pharo Hedge Funds; audit and legal fees; the Administrator’s fees and expenses; registrar and transfer agent’s fees and expenses; accounting fees; tax advisory and preparation fees, and other similar expenses; and all extraordinary or non-recurring expenses, including litigation expenses. In addition, Pharo Management may charge the Pharo Hedge Funds a pro rata portion of the cost of preparing and filing Form PF and Form CPOPQR and other regulatory filings relating to the Pharo Hedge Funds. See Item 12Brokerage Practices for additional information. When more than one Pharo Hedge Fund incurs a shared expense, Pharo Management or an Affiliated Investment Advisor allocates such shared expense among the applicable Pharo Hedge Funds (i) in proportion to the net asset value of each applicable Pharo Hedge Fund; (ii) in proportion to the size of the investment made by each Pharo Hedge Fund to which the expense relates; (iii) based on the Investment Manager’s or the Affiliated Investment Advisors’ assessment of the relative benefit derived by each Pharo Hedge Fund from the product or service giving rise to the expense; or (iv) in such other manner as the Investment Manager or the Affiliated Investment Advisors consider fair and reasonable. At any time, the Investment Manager or the Affiliated Investment Advisors may elect to bear certain Pharo Hedge Fund expenses but have no obligation to do so. When a particular product or service has a mixed-use such that only a portion of its cost is properly treated as a Pharo Hedge Fund expense, the Investment Manager or the Affiliated Investment Advisor makes a good faith effort to reasonably allocate the costs of such product or service according to its use and only allocates to each applicable Pharo Hedge Fund the portion of such costs that constitutes allowable expenses for such Pharo Hedge Fund. The portion of the cost that is not an allowable Pharo Hedge Fund expense is paid for by the Investment Manager or the Affiliated Investment Advisors. In allocating the costs

of a mixed-use product or service, the Investment Manager and the Affiliated Investment Advisors have an incentive to allocate as much of the costs as possible to the Pharo Hedge Funds to minimize the amount that the Investment Manager or the Affiliated Investment Advisors must pay directly. To address this conflict of interest, the Investment Manager and the Affiliated Investment Advisors maintain documentation of their methodology for allocating the costs of mixed-use products and services between those that are allowable and non-allowable expenses of the Pharo Hedge Funds. Such documentation is reviewed periodically by the Chief Compliance Officer to determine that the allocations were reasonable.

Risk of Loss Investment Strategies Pharo Management seeks to generate attractive risk-adjusted returns over a market cycle (typically three to five years) by trading primarily in emerging markets across a range of asset classes, including but not limited to foreign exchange, credit, interest rates, commodities and equities. PMs invest across the emerging market universe (e.g., Latin America, Asia, Central and Eastern Europe, Middle East and Africa) as well as the developed markets (e.g., North America, Japan, Western Europe and Australia). We rely on our experience in trading emerging markets across the economic cycle and in numerous stressed market environments. Pharo Management considers trading of market risk factors to be an important feature of the risk management process. We seek to anticipate the cash flows required by the Pharo Hedge Funds and closely manage the liquidity of the Pharo Hedge Funds’ positions to that end. Pharo Management, Pharo UK, Pharo HK, and Pharo AD may invest using a computer-driven algorithmic trading system. There can be no assurances that a Pharo Hedge Fund will achieve its investment objective or that the strategies pursued and methods utilized by Pharo Management will be successful under all or any market conditions. Instruments Investments are made in deliverable and non-deliverable currencies and forwards, bonds, listed and over-the-counter futures and options, credit (primarily sovereign, but also, quasi-sovereign and corporate), rates, swaps (including interest rate, cross currency, and total return swaps), caps, collars, floors, volatility, credit derivatives (including single name credit default swaps, credit default swaps referencing a standardized basket of credit entities, credit default swap indices and indices referencing leveraged loans), equities and equity indices, exchange traded funds (ETFs) that track the weighted average performance of a basket of underlying debt or equity securities or portfolios of leveraged loans, forward rate agreements, credit linked notes and other structured products and derivative instruments on a global basis. There are no restrictions on the types of trading activities Pharo Management is permitted to undertake. We can invest in any situation if we believe the profit opportunity is commensurate with the apparent risk presented by the investment. These investments may include privately issued sovereign and corporate debt securities, distressed credit and defaulted sovereign bonds. We make all types of investments, including selling short currencies and securities and

other investments in the Pharo Hedge Funds’ investment universe, buying and selling call and put options, and other types of investments presenting in our view favorable risk/reward characteristics. We utilize margin, debt and other sources of leverage to make certain investments, including short sales. In addition, options trading includes options that are not traded on a securities exchange and options that are listed on registered options exchanges in the United States and elsewhere. One of the purposes of this type of trading activity is to attempt to reduce portfolio exposure to risks arising from price fluctuations in short and long positions. We also engage in options transactions in order to capture the potential for gain in the underlying currencies and securities. Methods of Analysis The investment process relies on rigorous analysis of the macroeconomic drivers of the various asset classes that we trade. This fundamental analysis is combined with an equally rigorous focus on market technicals, e.g., market positioning, flows, momentum, correlation, volatility, and acute attention to liquidity at the trade and position level. Capital is allocated to PMs based on their level of experience and track record. Pharo Management’s PMs operate in an open environment with PMs of the Affiliated Investment Advisors, which facilitates a continuous exchange of economic views, investment ideas and trades. The objective of this investment model is to create a team approach to generating ideas and trades, with all the attendant benefits of a multiplicity of views yet retaining the dynamics and accountability of a single decision maker. Most of the PMs, managing the majority of the capital, are generalists in terms of markets and asset classes and can thus trade where they see opportunities as opposed to a more specialist model where a PM is compelled to keep capital employed in a market or asset class even though prospective returns and/or risk are not attractive at the time. Some PMs spend a significant amount of time on fundamental valuation based on macro drivers (e.g., growth, inflation, fiscal dynamics, balance of payments, domestic politics, etc.) and idiosyncratic factors at the security or instrument level (e.g., issuer cash flow dynamics, real effective exchange rate estimates, inter- and intra-market yield curve analysis, volatility skew and term structure, etc.). Others tend to focus more on market technicals, such as positioning by other market participants, asset class and market specific flows, time series analysis, etc. Holding periods for these PMs tend to be significantly shorter than the more fundamentally oriented PMs. All PMs pay attention to both fundamental and technical factors. Investment research is the responsibility of the PMs. They are supported by in-house economists and research analysts in credit, macroeconomics and risk. Analysts focus their research on specific market opportunities. Pharo Management receives a large supply of research from external sources, including a wide variety of trading counterparties.

PMs typically rely on their own primary research and internal discussions for underlying investment decisions but will often look for external sources to corroborate or make them question internal assumptions, analyses and conclusions. Technical surveys are also monitored to inform the PMs of market positioning. Pharo Management is committed to increasing the number and generational diversity of its PMs. To achieve that goal, Pharo Management, Pharo UK, Pharo HK, and Pharo AD may recruit experienced, well-established PMs with successful track records as well as PMs with less experience and candidates with no previous discretionary investment experience that show potential to develop into successful PMs. Pharo Management is also grooming its next generation of PMs internally from the ranks of its economists, research analysts and execution traders who have not previously managed capital on a discretionary basis but have a deep knowledge of Pharo Management’s investment philosophy. All PM trainees, whether recruited laterally or from within, start with a small allocation of fund capital and operate under stricter risk controls. Pharo Management believes that identifying portfolio management talent early and developing it under our oversight complements our lateral recruitment process for experienced PMs and will enhance performance in the long term; however, in the short term, allocating even small amounts of fund capital to PM trainees with no investment management experience is riskier than allocating that capital to more experienced PMs. The success ratio for trainees will be lower than PMs with years of experience. Certain Risk Factors Investing in the instruments described above involves risk and the possibility for the loss of principal. What follows is a summary of the material risks involved with the investment strategies and financial instruments used by Pharo Management. For a more comprehensive description of the risks associated with an investment in one of the Pharo Hedge Funds, including certain non-investment related risks, investors should carefully review the Risk Factors section of the Information Memorandum of the relevant Pharo Hedge Fund, copies of which are available upon request. There can be no assurance that Pharo Management’s investment strategy will be successful or that the Pharo Hedge Funds will not suffer losses. An investment in the Pharo Hedge Funds should not be made by any person who cannot afford a total loss of their principal. Emerging markets are subject to a wide array of domestic as well as global risk factors. Overall Investment Risk. All investments in currencies, securities and commodity interests risk the loss of capital. The nature of the currencies, securities and commodity interests purchased and traded by the Pharo Hedge Funds and the investment techniques and strategies employed by Pharo Management increase this risk. While we will use our best efforts in the management of the

Pharo Hedge Fund portfolios, there can be no assurance that the Pharo Hedge Funds will not incur losses. Many unforeseeable events, including actions by various government agencies, and domestic and international economic and political developments, will cause sharp market fluctuations which could adversely affect the portfolio and performance of a Pharo Hedge Fund. Transactions in Currencies, Securities and Commodity Interests. There is no assurance that Pharo Management will correctly evaluate the nature and magnitude of the various factors that could affect the prospects of the currencies, securities and commodity interests purchased or sold short. The Pharo Hedge Funds may lose their entire investment or be required to accept cash or other consideration with a value less than their original investment. Highly Volatile Markets. The movement of currencies and the prices of financial instruments in which Pharo Management invests can be highly volatile and be influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. The effect of such factors on exchange rates, interest rates, the prices of securities and commodity interests in general, or a particular security or commodity interest, is difficult to predict. In addition, there is unpredictability to the change in general economic conditions, which affect the profitability of the investment strategy. Global Economic and Market Conditions. The success of the Pharo Hedge Funds’ activities also may be affected by global economic and market conditions, such as interest rates, availability of credit, inflation rates, economic uncertainty, climate change, local epidemics and global pandemics, and national and international political circumstances (including wars, terrorist acts or security operations), and changes in laws. These factors may affect the level and volatility of securities prices and the liquidity of the Pharo Hedge Funds’ investments. Unexpected volatility or illiquidity could impair the Pharo Hedge Funds’ profitability or result in losses. Emerging Markets Risk Generally. Investment in emerging markets subjects the Fund to a greater risk of loss than investments in developed markets. This is due to, among other things, greater market volatility, lower trading volume, different accounting and auditing standards, less securities regulation, higher transaction and custodial costs, political, economic and social instability, high levels of inflation, deflation or currency devaluation, possible exchange controls, greater risk of market shut down, and more governmental limitations on foreign investment than those typically found in a developed market. In addition, the financial stability of issuers (including governments) in emerging market countries may be more precarious than in other countries. As a result, there will tend to be an increased risk of price volatility in the Pharo Hedge Funds’ investments, which may be magnified by currency fluctuations. Settlement practices for transactions in these markets also may differ from those in U.S. and other developed markets. Such differences include delays beyond periods customary in the U.S. and Europe

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Pharo Management advises the Pharo Hedge Funds pursuant to its Investment Management Agreements. Pharo Management reserves the right to advise other funds, including funds managed by an unaffiliated investment manager. Each of the Pharo Hedge Funds is registered pursuant to Section 4(3) of the Cayman Islands Mutual Funds Act, is a private fund as defined under the Advisers Act, and is not an investment company within the meaning of the Investment Company Act of 1940 in reliance on Section 3(c)(7) of such Act.

Management See performance-based fee description in Item 5- Fees and Compensation above. Performance based compensation received by Pharo Management will be in conformity with Rule 205-3 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). The receipt by Pharo Management of a portion of the performance fees paid by the Pharo Hedge Funds creates an incentive for Pharo Management to take greater risk to increase profits and hence its fees. Such fee arrangements also create an incentive for Pharo Management to favor one Pharo Hedge Fund over another in the allocation of investment opportunities (e.g., if one Pharo Hedge Fund is under its high water mark when other Pharo Hedge Funds are not). In addition, since the value assigned to a portfolio security affects the performance fees received by Pharo Management, any involvement by Pharo Management or the Affiliated Investment Advisors in the valuation process creates a potential conflict of interest. Pharo Management has adopted and implemented procedures reasonably designed to ensure that all Pharo Hedge Funds are treated fairly and equitably and to prevent any potential conflict from influencing the allocation of investment opportunities.

Affiliations

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Pharo Management is a related person of the Affiliated Investment Advisors. Pharo Management is the Investment Manager of the Pharo Hedge Funds, Pharo UK, Pharo HK, and Pharo AD provide discretionary investment advisory services to the Pharo Hedge Funds. See Item 4- Advisory Business above. Guillaume Fonkenell is Member of Pharo UK and is registered with the United Kingdom Financial Conduct Authority (“FCA”) and holds two senior management functions- SMF1: CEO and SMF27: Partner. He is also listed as a principal with the NFA on behalf of Pharo Management, in its capacity as a CPO. He owns, directly or indirectly, Pharo Management and the Affiliated Investment Advisors and serves as Chief Investment Officer of Pharo Management, Pharo UK, Pharo HK, and Pharo AD. Mr. Fonkenell has capital allocations from the Pharo Hedge Funds managed by Pharo Management. Mr. Fonkenell has personal investments of various sizes in the Pharo Hedge Funds. In addition, employees of Pharo Management and the Affiliated Investment Advisors may also have deferred compensation balances invested in the Pharo Hedge Funds including those over which they have investment discretion. As a result of the above, Mr. Fonkenell’s time is split among Pharo Management and the Affiliated Investment Advisors, which creates a conflict should one or more of them require a disproportionate amount of his attention. In addition, Mr. Fonkenell’s investment advice is spread across multiple Pharo Hedge Funds in which he has personal investments of various sizes. These circumstances create a conflict of interest in dedicating his resources with regard to his investment analysis, which vary by Pharo Hedge Fund. Mr. Fonkenell’s

personal investments as well as other PMs deferred compensation balances (which may be invested in the Pharo Hedge Fund they advise) also create a conflict of interest as they stand to gain personally by the performance of the Pharo Hedge Funds over which they have discretionary authority. Because of Mr. Fonkenell’s ownership of Pharo Management and the Affiliated Investment Advisors and his managerial responsibilities and portfolio management roles with Pharo Management, Pharo UK, Pharo HK, and Pharo AD, Mr. Fonkenell is deemed a key man risk. Jeff Hanlon, Pharo Management’s Senior Partner, Global Chief Operating Officer and Chief Financial Officer, is also registered with the FCA holding senior management function SMF27: Partner on behalf of Pharo UK. Mr. Hanlon’s time is therefore split among both entities, which will create a conflict of interest by disproportionately allocating his time to one of the companies. In addition, Mr. Hanlon is a registered principal and Associated Person of Pharo Management in its capacity as a registered CPO. He is also a member of the NFA. These inter-company affiliations and the conflicts of interest they create are mitigated by the following: 1. Pharo Management has personnel with significant managerial and portfolio management experience. This allows it to manage the portfolios of the Pharo Hedge Funds using a team approach that is not dependent on any one person. 2. Pharo Management has implemented investment allocation policies that require fair and equitable allocations among the Pharo Hedge Funds over time on an overall basis. Investment opportunities that are allocated to more than one Pharo Hedge Fund or client account may not necessarily be done on a pro rata basis. These procedures are monitored by the CCO or his designee to detect if one Pharo Hedge Fund is being favored over another. Other Potential Conflicts of Interest Pharo Management will use its best efforts in connection with the objectives of the Pharo Hedge Funds and will devote as much of our time and effort to the affairs of the Pharo Hedge Funds that in our judgment is necessary to accomplish the objectives of the Pharo Hedge Funds. Pharo Management may conduct any other business, including any business within the securities industry, whether or not such business is in competition with the Pharo Hedge Funds. Without limiting the generality of the foregoing, Pharo Management, its members, officers, directors and principals may act as investment advisor or investment manager for others, may manage multiple hedge funds or capital for others, may make and hold investments in their own name or through other entities, and may serve as a

manager, consultant, partner or stockholder of one or more hedge funds, partnerships, securities firms or advisory firms. Pharo Management may manage co-investment Funds alongside the other Pharo Hedge Funds, which can create potential conflicts of interest in the allocation of investment opportunities, pricing, and execution. Pharo Management has an investment opportunity allocation policy that seeks to allocate investment opportunities in a fair and equitable manner over time. Such allocations may not always be done on a pro rata basis and could result in less favorable terms for one or more of the Pharo Hedge Funds and co-investment Funds. One of the Directors of the Pharo Hedge Funds is also a non-executive Director of Pharo Manarah Limited and Pharo Global Advisors Limited, which serves as a holding company for each of the Investment Advisors. He has no financial interest in the Pharo Hedge Funds or Pharo Management. In the unlikely event of a conflict occurring between a Pharo Hedge Fund and Pharo Manarah Limited or Pharo Global Advisors Limited, the Pharo Hedge Fund would manage the conflict by having a committee comprised of the non-conflicted Directors decide the matter. Investment and Trading Opportunities Pharo Management gives advice and recommends securities to, and buys or sells securities for, multiple Pharo Hedge Funds. Our advice and recommendations may differ between the Pharo Hedge Funds even though their investment programs, objectives and strategies are similar. Accordingly, Pharo Hedge Funds with similar strategies may not hold the same securities or instruments or achieve the same performance. Pharo Management will act in a fair and equitable manner in allocating investment opportunities among the Pharo Hedge Funds. Valuations The net asset values of the Pharo Hedge Funds are determined by their Administrator. Since the value assigned to portfolio securities affects the performance fee paid by each Pharo Hedge Fund to Pharo Management, the involvement by Pharo Management, Pharo UK, Pharo HK or Pharo AD in the valuation process will create a potential conflict of interest. If and to the extent that Pharo Management, Pharo UK, Pharo HK, or Pharo AD are responsible for or otherwise involved in the pricing of any portfolio securities or other assets, the Administrator may accept, use and rely on such prices in determining the net asset values of the Pharo Hedge Funds. Pharo Management, on the advice of Pharo UK, Pharo HK, or Pharo AD, may in its sole discretion take the following actions with regard to valuations: for any security which is listed or quoted on any securities exchange, adjust the mean based upon bid/asked prices on which a valuation is based taking into account size of holdings; where prices for a security are available on more than one

exchange or system, determine the exchange or system that provides the fairest criteria to value such security; for investments other than securities that can be dealt in or traded on more than one market, determine the market that shall prevail; for any security which is not listed or quoted on any securities exchange or similar electronic system or if so listed or quoted is not regularly traded thereon or no prices are available, determine the securities probable realization value in good faith on factors deemed relevant; for investments or cash valued in a currency other than US dollars, determine the rate deemed applicable at the close of business on the relevant valuation date taking into account any premium or discount deemed relevant to costs of exchange. The Directors of the Pharo Hedge Funds are ultimately responsible for the valuation policies and procedures adopted by the Pharo Hedge Funds. The Directors may, at their discretion, permit any other method of valuation to be used if they consider that such method of valuation better reflects fair value and is in accordance with sound accounting practices. All values assigned to securities held by the Pharo Hedge Funds shall be final, binding and conclusive on all of the Pharo Hedge Funds’ shareholders. Trade Errors Trading errors are an intrinsic factor in any complex investment process and will occur notwithstanding the execution of due care and the existence of procedures reasonably designed to prevent such errors and to detect them in a timely manner when they do occur. Such errors include, for example, a transaction executed for the wrong asset, quantity or price, a transaction to buy when Pharo Management meant to sell or vice versa, an incorrect entry of a trade into an electronic trading system, and/or drafting errors related to trade contracts or confirmations. The Investment Manager and Investment Advisors execute a high volume of trades for the Funds, many of which are esoteric and involve complex instruments, and trading errors frequently occur. However, the number of errors as a percentage of the aggregate number of trades executed by Pharo Management and its Affiliated Investment Advisors for all Pharo Hedge Funds was 0.03% and 0.04% in 2024 and 2025 respectively. When trading errors occur, they are for the account of the Pharo Hedge Fund (including those which result in losses and those which result in gains) unless they are the result of conduct inconsistent with Pharo Management’s standard of care set forth in the Management Agreement or Pharo UK’s, Pharo HK’s, and Pharo AD’s standard of care in their respective Sub-Advisory Agreements. Pharo Management does not ascribe a hypothetical gain or loss to a trade error that results in a missed investment opportunity (for example, a misallocation of an investment). Pharo Management does not compensate for any amounts that, in our judgement, are speculative, including any lost opportunity costs. Losses resulting from trade errors could have a material adverse effect on the performance of a Pharo Hedge Fund.

The limitation on Pharo’s liability established by the Management Agreement and Sub-Advisory Agreements does not constitute a waiver of any fiduciary duty owed to the Fund or a waiver of any of the Fund’s legal rights under applicable federal securities laws or any other federal or state laws the applicability of which is not permitted to be waived. Cross Trades; Principal Transactions Pharo Management, Pharo UK, Pharo HK, and Pharo AD from time-to-time direct trades in securities or financial instruments between the Pharo Hedge Funds (“cross-trades”). Pharo Management believes that cross-trading provides various benefits to the Pharo Hedge Funds, including obtaining a better price by eliminating the bid/ask spread in the market, eliminating market slippage, and generally eliminating or reducing other transaction costs. Pharo Management, Pharo UK, Pharo HK, and Pharo AD in their discretion, determine the securities or financial instruments to cross-trade between and among the Pharo Hedge Funds. All cross-trades will be affected through brokers at market prices. Because of the level of equity ownership by the principals of Pharo Management and the Affiliated Investment Advisors in certain Pharo Hedge Funds that enter into cross trades, such transactions may be deemed principal transactions for purposes of the Advisers Act. Pharo Management, Pharo UK, Pharo HK, and Pharo AD face various conflicts of interest when they engage, through the Pharo Hedge Funds, in principal transactions, including but not limited to the fact that they have an incentive to price securities in principal trades in a manner advantageous to the Pharo Hedge Fund in which they participate, sell unwanted securities from such funds, or cause such funds to purchase desirable securities from the other Pharo Hedge Funds. To address these conflicts of interest, these principal transactions (like all cross trades) will be effected through brokers at market prices, and before any principal transaction is settled, the material terms of the transaction, including the security or securities involved, the capacity in which Pharo Management and the Affiliated Investment Advisors acted, the manner in which the trade was executed, and the price at which the trade was consummated, will be fully disclosed to the Directors of the respective Pharo Hedge Funds in writing. The Pharo Hedge Funds will cancel any such principal transaction unless the Directors, after reviewing the terms of the transaction, approve the transaction in writing. Tricolore Management Limited Tricolore Management Limited (“TML”) was launched by Guillaume Fonkenell in September 2022 to serve as his personal “family office”. TML will identify investment opportunities for Mr. Fonkenell and monitor and manage his personal investments, including conducting due diligence on investment opportunities, negotiating the terms of investments, liaising with management of the businesses in which Mr. Fonkenell is invested, and preparing financial reports relating to those investments and businesses. TML also provides accounting, tax and cash management services to Mr. Fonkenell. TML provides its services only

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Transactions and Personal Trading Pharo Management has adopted a Code of Ethics (the “Code”), which is available to clients upon request. The Code incorporates the following principles among others that all employees are expected to uphold: (a) employees must treat clients in a fair and equitable manner; (b) investment decisions must be made in accordance with Pharo Management’s fiduciary duties; (c) all personal securities transactions by Pharo Management employees must be conducted in a manner consistent with the Code, which includes restrictions and requirements that they disclose their personal securities transactions at least quarterly and holdings annually; and (d) information concerning the identity of securities, the financial circumstances of our clients and personal non-public information regarding individual investors or clients must be kept confidential. Pharo Management stresses the importance of confidentiality in our Code and identifies the scope of confidential information. In addition, the Code outlines procedures to protect against the receipt of inside information, the procedures to follow in the event an employee receives inside information intentionally or unintentionally, and our means of surveillance to detect the receipt of inside information. Our Code also includes our policy and procedures with regard to market rumors. The Code seeks to gather information from employees to identify conflicts of interest in various areas of our business in order to develop controls around such conflicts. In addition, the Code requires that all political contributions be approved in advance by the CCO regardless of the dollar amount of the contribution. Pharo Management limits the types of securities in which Pharo Management employees and their related persons may invest. In addition, we generally do not permit personal investing in the same securities that we hold on behalf of our clients. We permit employees and their related persons to invest in a limited number of securities to mitigate the conflicts that may arise by allowing personal trading. We allow trading in Mutual Funds, Open and Closed End ETFs (subject to restrictions that present a conflict of interest), Government securities (as defined in the Code), municipal securities, closed end funds that invest in municipal securities (“closed end municipal funds”), private placement partnerships or similarly structured commingled investment vehicles including hedge funds, UCITS, REITS, NURS (non UCITS retail scheme) and Crypto currencies. These instruments are permitted on the basis that they are unlikely to create a conflict with our investments for clients. Should we invest in such securities for our clients after an employee’s personal investment (which was approved on the basis that the security was not held for clients at the time of the employee’s or related person’s personal investment), 3 days will have to elapse from the date of the last trade in the issuer in any client account before an employee or individual related person will be granted permission to liquidate such security.

The CCO or his designee may grant a waiver to these procedures if it is deemed warranted and no client is disadvantaged. The Code requires approval of all gift giving by employees. In addition, employees must report the direct or indirect offering or acceptance of gifts or other consideration in merchandise or services (other than perishable items of nominal value) from or to any person, firm, corporation, or other entity in the course of their employment or relating to their employment with Pharo Management. Pharo Management or its employees will engage in principal transactions with its clients. This may occur when a PM, control person, or affiliate has a personal or proprietary investment in a Pharo Hedge Fund (including any deferred compensation balances of Pharo Management but excluding any notional investments for purposes of tracking employee deferred balance earnings), which represents 25% (alone or in aggregate) or more of a Pharo Hedge Fund’s net asset value. Client consent is sought prior to the settlement date of principal transactions. If consent is not obtained prior to settlement, the principal transaction will be cancelled. See Cross Trades; Principal Transactions above. Neither Pharo Management nor a related person acts as general partner or in a similar capacity to a partnership or other legal structure in which we solicit clients to invest nor do we act as an investment advisor to an investment company that Pharo Management recommends to clients.

Pharo Management has been in business for over twenty years and its PMs and traders as well as the PMs and traders of Pharo UK, Pharo HK, and Pharo AD have substantial experience in the financial services industry. Pharo Management relies on this experience and knowledge to identify the markets, instruments and services in which different brokers excel. Pharo Management is responsible for the selection of brokers and dealers to effect transactions, and the negotiation of brokerage commissions. Our prime brokers provide us with securities lending, financing, and capital introduction services. Brokers and prime brokers may be selected based on, products offered, commissions, collateral requirements, reputation and operations. When executing a transaction, our traders will take into account the circumstances associated with the execution of particular types of financial instruments. There is no obligation to solicit competitive bids or seek the lowest available commissions or other transaction costs. Accordingly, the commission rates (or dealer markups and markdowns arising in connection with riskless principal transactions) charged by brokers to Pharo Management’s clients may be higher than those charged by other brokers. Subject to the considerations described above, the selection of a broker (including a prime broker) to execute transactions, provide financing and securities

on loan, hold cash and short balances and provide other services may be influenced by, among other things, the provision by the broker of the following: research; consulting with respect to technology and operations; the commitment of capital; and access to company management. Pharo Management’s securities transactions will generate brokerage commissions and other compensation, all of which the client, not Pharo Management, will be obligated to pay. Pharo Management will have complete discretion deciding what brokers and dealers its clients will use and negotiating the rates of compensation they will pay. In addition to using brokers as “agents” and paying commissions, we will buy or sell securities directly from or to dealers acting as principals at prices that include markups or markdowns. Pharo Management is provided opportunities to participate in capital introduction events sponsored by prime brokers where the Pharo Hedge Funds and or clients maintain accounts. Prospective investors are introduced to Pharo Management at such events. Capital introduction services are provided incidental to the other prime brokerage/brokering services provided to Pharo Management in connection with the overall prime brokerage relationship. Pharo Management executes brokerage transactions through the sponsors of these events. None of the Pharo Hedge Funds or Pharo Management compensates brokers for organizing such events or for any investments ultimately made by prospective investors attending such events (although Pharo Management may do so in the future). However, such events and other services provided by a broker may influence Pharo Management in deciding whether to use the broker in connection with brokerage, financing and other activities for the Pharo Hedge Funds or clients we advise. Some of these arrangements create a conflict of interest whereby Pharo Management will have an incentive to use a particular broker or prime broker based upon its interest, rather than the interest of our clients. For example, Pharo Management will have an incentive to use a broker based upon capital introduction groups rather than receiving the lowest commission cost or best execution price for its clients. Pharo Management does not direct client transactions to a particular broker-dealer in return for client or investor referrals. Pharo Management will conduct periodic best execution analysis whereby brokers will be assessed based upon what Pharo Management deems critical criteria to its investment strategy. Part of the analysis will be to evaluate why certain brokers earn their share of our overall transaction cost and identify the execution services in which they excel. In addition, the basis for adding or dropping a broker will be assessed based upon our “Counterparty On-Boarding and Monitoring Policy”. Our goal is to identify conflicts and direct transactions which are suited to a particular broker’s execution expertise to satisfy the interest of our clients as opposed to the interest of Pharo Management. Pharo Management anticipates that the counterparties with which the Pharo Hedge Funds will enter into repurchase agreements and derivative

transactions will be financial institutions having a global presence. However, we have the discretion to cause the Pharo Hedge Funds to enter into transactions with counterparties that do not satisfy the foregoing criteria if we determine that such arrangements are beneficial to the Pharo Hedge Funds. Pharo Management does not have any directed brokerage arrangements. Pharo Management has never entered into formal soft dollar arrangements with any broker and our policy is not to enter into such arrangements. However, Pharo Management may receive research as part of its Prime Brokers’ and other brokers’ full servicing arrangements. This research would technically constitute receipt of soft dollars and would mandate a yes response to the soft dollar question on Form ADV. Pharo Management does not use soft dollars outside of the safe harbor provided by Section 28(e) of the Securities Exchange Act of 1934. Orders for the Pharo Hedge Funds are routinely aggregated and if filled at different prices, may be allocated using an average price. For average price allocations, purchase or sale orders placed during a trading day that are combined and executed are allocated among the participating Pharo Hedge Funds on an average price basis. Such aggregation of orders may not always be to the benefit of each of the Pharo Hedge Funds with regard to the price or quantity executed. Pharo Management is not obligated to aggregate orders and has complete discretion to aggregate or enter separate orders depending on its assessment of the best means to execute a particular order. If orders are separated, the Pharo Hedge Funds may be filled at different prices and incur different execution cost.

Not applicable. See also Item 5- Fees and Compensation above. Pharo Management may in the future retain placement agents in connection with the offering of shares of the Pharo Hedge Funds and may compensate such agents for their private placement services. Such compensation may be one-time or ongoing, and may be based on the subscription amount, management or performance fees paid by an investor, or aggregate dollar amount invested in the Pharo Hedge Funds by an investor. Pharo Management will act in accordance with the requirements of the Advisers Act to the extent applicable.

None

Pharo Management’s Risk Committee is responsible for setting the Risk Management framework of the Pharo Hedge Funds, which consists of a number of risk controls at different levels of the Pharo Hedge Funds; Portfolio Manager positions, capital allocation and aggregated positions. The Risk Committee will address market risk, concentration risk, liquidity risk, and other risks as needed. The Risk Committee meets generally once a month to review the portfolio positions and take action where appropriate, which may include setting new risk limits. The Risk Team is responsible for monitoring and enforcing all risk limits and reporting matters to the Risk Committee as necessary. It is also responsible for developing and improving the risk modelling and infrastructure. The Risk Team reports to the Chief Risk Officer, a member of the Risk Committee. The Risk Team monitors position profit target/stop loss limits, PM drawdown limits, VaR limits (The objective of the VaR methodology is to estimate how much the Fund can gain or lose in a single trading day under normal market conditions), country exposure limits, position concentration limits among others. If such limits are triggered it prompts an additional review to determine if a limit extension is granted, the limits are modified or positions are unwound. The Risk Committee may impose additional constraints and/or limits at its discretion. The Risk Committee's discretion to modify risk limits includes, without limitation, the discretion to increase a portfolio

manager's drawdown limits. Investors may therefore suffer losses greater than the stated draw down limits. During periods of high market volatility, material dislocations and/or extraordinary events, it may not be possible to limit drawdowns. The committee or members thereof will meet informally as required to address periodic issues (e.g., concentration, counterparty or the profit target/loss limits discussed above). The limitations of the VaR methodology referenced above can be enumerated as: Portfolio VaR does not take into account the liquidity of the portfolio. Portfolio VaR does not capture tail risk events. See the respective Pharo Hedge Fund’s Standard Due Diligence questionnaire for more details on Pharo Management’s risk management process for the specific fund. The Directors of the Pharo Hedge Fund receive various hedge fund reports including but not limited to a monthly or quarterly letter disclosing performance, net asset value and other performance metrics, fund risk reports and fund transparency reports among others. In addition, we are in frequent communications with the Directors of the Pharo Hedge Funds. Investors in a Pharo Hedge Fund generally receive the reports noted above in addition to annual audited financial statements for the Pharo Hedge Fund they are invested in.

Pharo Management is deemed to have custody of client assets by virtue of serving as Investment Manager to the Pharo Hedge Funds we advise. Neither Pharo Management, nor any of the Affiliated Investment Advisors actually has physical possession of any assets of the Pharo Hedge Funds. Nonetheless, Pharo Management may be deemed to have constructive custody of the assets of the Pharo Hedge Funds by virtue of being the Investment Manager to the Pharo Hedge Funds and the authority assigned to Pharo Management by the Pharo Hedge

Funds. Cash and securities of the Pharo Hedge Funds are held by qualified custodians and the Pharo Hedge Funds satisfy the requirements of Rule 206(4)-2 of the Advisers Act by having annual audits conducted by an independent public accountant registered with and subject to inspection by, The Public Company Accounting Oversight Board (PCAOB). The Pharo Hedge Funds have retained PricewaterhouseCoopers (Cayman Islands) as independent auditors. Within 90 days after each fiscal year end the audited financial statements of the Pharo Hedge Funds are delivered to investors. Pharo Management and the administrator to the Pharo Hedge Funds also provide periodic unaudited information, not less frequently than monthly, to investors. Qualified custodians generally send account administrator, Citco Fund Services (Curacao) B.V.

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See Item 4- “Advisory Business” above. Pharo Management has authority, pursuant to its Investment Management Agreements, to invest and reinvest on a discretionary basis a portion of the assets of the Pharo Hedge Funds.

Pharo Management will, if applicable, generally vote proxies and corporate actions for the Pharo Hedge Funds it advises and other advisory clients through prime brokers, broker dealers and or custodians who carry accounts on behalf of such Pharo Hedge Funds. Pharo Management retains ultimate discretion on how to vote proxies and corporate actions. In certain circumstances, Pharo Management may disagree with management’s recommendation and may vote contrary to such recommendation. Pharo Management will document its rationale for making such vote in such circumstances. The general policy is to vote proxy proposals, amendments, consents or resolutions relating to client securities, including securities held in the Pharo Hedge Funds we advise, in a manner that serves the best interests of the Pharo Hedge Funds’ or client’s accounts. Investors may request a copy of our proxy policies and procedures and the proxy voting record relating to how we voted specific proxies for securities held by the Pharo Hedge Funds by contacting Pharo Management at the address or telephone number on the cover page.

Balance Sheet Not Applicable Pharo Management is not subject to any financial condition that impairs its ability to meet contractual commitments to clients and has not been the subject of a bankruptcy proceeding.