Polar Asset Management Partners Inc.

Polar Asset Management Partners Inc. (“Polar”) is a Canadian corporation formed in 1991. Its sole shareholder is Polar Financial Corporation. As of March 31, 2026, Polar managed approximately US$37.9 billion of regulatory assets under management on a discretionary basis. Polar provides discretionary investment advice and management services to privately offered investment funds (“private funds”), public investment funds offered in Canada under a prospectus (together with private funds, each, a “Fund” and collectively, the “Funds”), as well as separately managed accounts. The Funds may be organized as onshore or offshore limited partnerships, trusts or corporations. Polar’s private funds generally conduct their trading activities through a masterfeeder structure. In a master- feeder structure, each feeder fund contributes its investible assets to a master fund and participates on a pro-rata basis in the profits and losses of the master fund and bears a pro-rata portion of the expenses of the master fund, based on the respective capital account balances of all Funds investing through the master fund. An affiliate of Polar serves as the general partner to each U.S.-domiciled feeder fund that is set up as a limited partnership. Polar also has certain standalone private and public investment funds that conduct their trading activities directly, without the use of a master-feeder structure. Each Fund is managed only in accordance with its own investment objectives and is not tailored to any particular fund investor (each an “investor”). Polar currently manages various families of Funds, as follows:

Multi-Strategy Funds: these Funds employ multiple strategies and seek to achieve stable, superior rates of return while minimizing investment risk through the use of strategies including, but not limited to, arbitrage-oriented strategies; fixed income; credit; equity arbitrage; event driven; fundamental equity long/short; fundamental long-only equity; structured credit and/or private investments;

Long/Short Strategy Funds: these Funds primarily invest in, or sell short, equity and equity derivative securities and seek to generate positive absolute returns, with low volatility and low correlation to the equity market;

North American Micro-Cap Funds: these Funds seek to achieve long-term capital growth by investing primarily in the equity securities of small-sized Canadian and U.S. companies, which may, from time to time, include investments in private businesses;

Co-Investment Funds: from time to time, Polar may establish co-investment vehicles with respect to certain strategy(ies) implemented by another Fund. A co-investment Fund will seek to achieve its investment objective by investing on an opportunistic and overflow basis in an investment strategy that is pursued by another Fund. A Fund may invest through a coinvestment Fund or alongside a co-investment Fund.

Polar has entered into a sub-advisory agreement (the “Mirabella Sub-Advisory Agreement”) with Mirabella Financial Services LLP (“Mirabella”) pursuant to which Polar delegated certain discretionary investment management and trading authority over a portion of Polar Multi-Strategy Master Fund’s assets. Mirabella is authorized and regulated by the Financial Conduct Authority of Part 2A of Form ADV - Page 4

the United Kingdom (the “FCA”), in the conduct of its regulated activities in the United Kingdom. Under the terms of the Mirabella Sub-Advisory Agreement and related agreements, Polar has delegated to Mirabella its duties with respect to any of Polar’s trading activities within the United Kingdom. Any U.K.-based investment professionals of Polar are seconded to Mirabella and will trade on behalf of Polar Multi-Strategy Master Fund under Mirabella’s FCA registration. The aggregate amount of compensation payable by Polar Multi-Strategy Master Fund to Polar is not increased by virtue of the Mirabella Sub-Advisory Agreement or other arrangements between Polar and Mirabella. Polar has entered into a sub-advisory agreement (the “White Bear Sub-Advisory Agreement”) with White Bear Financial Partners Inc. (“White Bear”) pursuant to which Polar delegated certain discretionary investment management and trading authority over a portion of the assets of a whollyowned subsidiary of Polar Multi-Strategy Master Fund that invests in residential mortgage loans. White Bear is a wholly-owned subsidiary of Polar Financial Corporation, the parent entity of Polar. The aggregate amount of compensation payable by Polar Multi-Strategy Master Fund to Polar is not increased by virtue of the White Bear Sub-Advisory Agreement or other arrangements between Polar and White Bear. Since Polar does not provide individualized advice to the investors in the Funds and the investors may not impose restrictions (other than limitations and restrictions imposed by government legislation and/or regulations) on investing in certain securities or types of securities, investors must consider whether a particular Fund meets their investment objectives and risk tolerance prior to investing. Information about each private fund can be found in its offering documents, including its confidential offering memorandum (“Offering Memorandum”). However, the private funds rely on certain registration exclusions available under the Investment Company Act of 1940, as amended (“IC Act”) and exemptions available under the Securities Act of 1933, as amended (“Securities Act”). The public investment fund is offered to investors in Canada pursuant to a prospectus (the “Prospectus”) and is managed in accordance with its own investment objectives as outlined in the Prospectus. Therefore, this Brochure is designed solely to provide information about Polar and should not be considered an offer of interests in any Polar Fund. Any such offer may only be made by delivery to the prospective investor of the Offering Memorandum for the private fund and the Prospectus of the public investment fund under consideration. Each separately managed account is managed in accordance with its own investment objectives as outlined in the investment advisory agreement for the separately managed account. Polar currently provides advice to the Funds and separately managed accounts but reserves the right to provide advice to other types of clients. Any other client accounts would be managed in accordance with the client’s stated investment objectives, strategies, restrictions, and any other agreed upon guidelines.

Polar and/or the general partner of the Funds have the authority to (1) deduct management and performance-based fees from the assets of the Funds, and (2) authorize the payment or reimbursement of other fees or expenses to third parties from the assets of the Funds. Fees, expenses and/or allocations associated with an investment in a Fund vary, depending on the Part 2A of Form ADV - Page 5

Fund, and are set forth in such Fund’s Offering Memorandum or Prospectus. Any applicable fees, expenses and/or allocations are deducted from a Fund investor’s assets as described below. Management Fees Polar Funds, and consequently the underlying investors, incur an annual management fee of up to 2.5% based on the investor’s capital account balance as of the end of the specified fee period. The management fee is charged monthly or quarterly, in arrears, as disclosed in each fund’s Offering Memorandum or Prospectus. Polar reserves the right to charge reduced or no management fees to certain investors, including investors that are affiliates of Polar or the general partner. Polar has no obligation to disclose the specific details of such arrangements or to offer such additional rights, terms, or conditions to all investors. Performance-Based Fees Please see the “Performance-Based Fees and Side-by-Side Management” section in Item 6. Fund Expenses Polar and/or the general partner of the Funds are authorized to incur expenses on behalf of the Funds; when this occurs, the appropriate Fund reimburses Polar and/or the general partner in the amount of such expenses. Polar and/or the general partner of the Funds will be responsible for the costs of procuring office space and utilities, news, quotation and computer equipment, software, and secretarial, clerical and other personnel and all of its own overhead costs and expenses (“Overhead Expenses”), except for those expenses otherwise borne by the Funds described in the paragraphs below and in the fund offering documents. Notwithstanding the preceding sentence, certain goods, services, costs and expenses may be provided through soft dollars generated by a Fund as described in Item 12, Brokerage Practices. The Funds shall be responsible for all their expenses, and if applicable, the pro rata share of the relevant master fund’s expenses, other than Overhead Expenses, including expenses for investments specific to the relevant Fund, whether or not such investments are consummated. The general partner or Polar shall be authorized to incur and pay all expenses on behalf of the Funds in connection with the Fund’s business which it deems necessary or desirable, and to charge or to be reimbursed by the Funds for those expenses. The Funds may share certain expenses. The feeder funds bear their own expenses as well as a pro-rata share of the relevant master fund’s (as applicable) expenses including, but not limited to, management fee; performance fee; investment expenses (e.g., expenses that, in Polar's discretion, are related to the investment of the Fund's assets, whether or not such investments are consummated, such as brokerage commissions, expenses relating to short sales, clearing and settlement charges, custodial fees, bank service fees and interest expenses); expenses incurred in connection with memberships of the relevant master fund (or Polar on behalf of the relevant master fund) of a securities or derivatives exchange, or as a market participant in an energy market; professional fees (including expenses of consultants, investment bankers, attorneys, accountants and other experts) relating to investments (whether or Part 2A of Form ADV - Page 6

not consummated); expenses in connection with hedging currency exposure and/or conversion; directors' remuneration and certain out-of-pocket expenses; Fund directors and officers and professional indemnity insurance expenses; research and market data (including any computer hardware and connectivity hardware (e.g., telephone and fiber optic lines) incorporated into the cost of obtaining such research and market data); administrative expenses (including fees and expenses of the Fund’s administrator); legal expenses (which may include legal expenses of Polar that relate to the Fund and/or the relevant master fund); bonding costs under the Employee Retirement Income Security Act of 1974, as amended; external accounting and valuation expenses; audit and tax preparation expenses (including expenses of the relevant master fund’s partnership representative); costs of printing and mailing reports and notices; taxes imposed on the Fund or the relevant master fund as determined by Polar; corporate licensing; regulatory expenses and filing fees (including Forms PF, 13D, 13G, 13F, CPO-PQR and other regulatory and reporting forms relating to the Fund's and/or Polar's trading and investing); organizational expenses; expenses incurred in connection with the offering and sale of the Fund shares and other similar expenses related to the Fund; indemnification expenses; expenses incurred in connection with any threatened, pending or anticipated litigation, examination or proceeding or in connection with any subpoena or regulatory information requests that are either addressed to the Fund or addressed to Polar or an affiliate but relate to the Fund's activities or Polar's activities on the Fund's behalf; costs incurred in connection with the valuation of the portfolio; and extraordinary expenses. Polar seeks to allocate expenses fairly, equitably, and consistent with the documents governing Polar’s relationship with each Fund. When allocating expenses, Polar must interpret the Funds’ governing documentation and make determinations whether expenses are allocated and paid in full or in part by a Fund, by Funds, and/or by Polar, which creates a conflict of interest. Polar has implemented policies, procedures, and guidelines designed to mitigate such conflicts of interest. Polar will also charge expenses to the Funds in accordance with the policies as set out by the Fund’s board of directors. Further information with respect to the fees and other expenses incurred by the Funds, and ultimately the underlying investors, can be found in each Fund’s Offering Memorandum or Prospectus.

Polar employs a variety of methods of analysis and investment strategies in formulating investment advice and managing assets, including but not limited to fundamental research, quantitative research and relative value analysis. An investment in a Fund or a separately managed account involves a high degree of risk, including the risk of loss of the entire amount invested. The investment strategies summarized below represent Polar’s current intentions, are general in nature and are not exhaustive. There are no limits on the types of securities in which Polar may take positions on behalf of the Funds, the types of positions it may take, the concentration of its investments or the amount of leverage that it may use. Polar may use any trading or investment techniques, whether or not contemplated by such investment strategies. Depending on conditions and trends in securities markets and the economy generally, Polar may use any techniques that it considers appropriate and in the Funds’ interests. Below is a summary of some of the risks that investors should consider before investing in a Fund. These and other risks could materially and adversely affect investment performance, the value of a Fund or any security a Fund holds and could cause investors to suffer substantial losses. Investors should review the applicable Fund’s Offering Memorandum or Prospectus carefully and in its entirety, and consult with their professional advisors before deciding whether to invest. A potential investor should discuss such investor’s questions with Polar’s representatives before investing in a Fund.

No material limitation on Strategies; New Strategies and Techniques. Polar has considerable discretion in the types of securities which the Funds may trade and has the right to modify the trading strategies or hedging techniques of the Funds without the consent of the Fund's investors. Any new trading techniques selected by Polar may not be thoroughly tested in the market before being employed and may have operational or theoretical shortcomings which could result in unsuccessful trades and, ultimately, losses to the Funds. In addition, any new investment strategy or hedging technique developed by Polar may be more speculative than earlier techniques and may increase the risk of an investment in the Funds.

Hybrid and Other Strategies. The strategies to be executed by Polar may combine elements of more than one of the general strategy types described herein. Often, in the course of implementing a particular strategy an opportunistic trade representing a different trading approach will be made. For example, in seeking to identify a relatively mispriced pair of assets, Polar may conclude that an asset is sufficiently over or underpriced to merit taking an outright directional position.

Limited Diversification. In the normal course of making investments on behalf of the Funds, Polar may, but is not obligated to, diversify its investments. However, the Funds’ portfolios Part 2A of Form ADV - Page 9

could become significantly concentrated, for example, in any one issuer, industry, sector, strategy, country or geographic region, and such concentration of risk may increase any losses suffered by the Funds. In addition, it is possible that the Polar may select investments that are concentrated in a limited number or type of financial instruments. This limited diversity could expose the Funds to losses disproportionate to market movements in general if there are disproportionately greater adverse price movements in those financial instruments.

Hedging Transactions. Polar may utilize financial instruments, both for investment purposes and for risk management purposes in order to (i) protect against possible changes in the market value of the Funds’ investment portfolios resulting from fluctuations in the markets and changes in interest rates; (ii) protect the Funds’ unrealized gains in the value of its investment portfolios; (iii) facilitate the sale of any such investments; (iv) enhance or preserve returns, spreads or gains on any investment in the Funds’ portfolios; (v) hedge against a directional trade; (vi) hedge the interest rate, credit or currency exchange rate on any of the Funds’ liabilities or assets; (vii) protect against any increase in the price of any securities the Funds anticipate purchasing at a later date; or (viii) act for any other reason that Polar deems appropriate. Polar will not be required to hedge any particular risk in connection with a particular transaction or its portfolios generally. While Polar may enter into hedging transactions to seek to reduce risk, such transactions may result in a poorer overall performance for the Funds than if it had not engaged in any such hedging transaction. Moreover, the portfolio will always be exposed to certain risks that cannot be hedged.

Investment and Trading Risks. Any investment in financial instruments carries certain market risks. An investment in the Funds is speculative and involves a high degree of risk due to the nature of the Funds’ investments and the investment and trading strategies to be employed. An investment in the Funds should not in and of itself be considered a balanced investment program. Investors should be able to withstand the loss of their entire investment. All investments in financial instruments risk the loss of capital. No guarantee or representation is made that the Funds’ investment objectives will be successful. The Funds’ investment program will involve, without limitation, risks associated with possible limited diversification, leverage, volatility, tracking risks in hedged positions, security borrowing risks in short sales, credit deterioration or default risks, systems risks and other risks inherent in the Funds’ activities. Certain investment techniques of Polar can, in certain circumstances, magnify the impact of adverse market moves to which the Funds may be subject. In addition, the Funds’ investments in financial instruments may be materially affected by conditions in the financial markets and overall economic conditions occurring globally and in particular countries or markets where the Funds may invest their assets.

Long/Short Strategy. The success of the Funds’ long/short investment strategy depends upon Polar's ability to identify and purchase securities that are undervalued and identify and sell short securities that are overvalued. The identification of investment opportunities in the implementation of the Funds’ long/short investment strategies is a difficult task, and there are no assurances that such opportunities will be successfully recognized or acquired. In the event that the perceived opportunities underlying the Funds’ positions were to fail to converge toward, or were to diverge further from, values expected by Polar, the Funds may incur losses. Equity securities fluctuate in value in response to many factors, including, among others, the activities and financial condition of individual companies, the business market in which individual companies compete, industry market conditions, interest rates and general economic Part 2A of Form ADV - Page 10

environments. In addition, events such as the domestic and international political environments, terrorism and natural disasters, may be unforeseeable and contribute to market volatility in ways that may adversely affect investments made by the Funds. In the event of market disruptions, significant losses can be incurred which may force the Funds to close out one or more positions. Furthermore, the valuation models used to determine whether a position presents an attractive opportunity consistent with Polar's long/short strategies may become outdated and inaccurate as market conditions change. The Funds also may be exposed to risks that issuers will not fulfill contractual obligations such as, in the case of convertible securities or private placements, delivering marketable common stock upon conversions of convertible securities and registering restricted securities for public resale.

Non-U.S. Investments. Investing in the securities of companies (and, from time to time, governments) outside of the United States involves certain considerations not usually associated with investing in securities of U.S. companies or the U.S. government, including political and economic considerations, such as greater risks of expropriation, nationalization, confiscatory taxation, imposition of withholding or other taxes on interest, dividends, capital gains, other income or gross sale or disposition proceeds, limitations on the removal of assets and general social, political and economic instability; the relatively small size of the securities markets in such countries and the low volume of trading, resulting in potential lack of liquidity and in price volatility; the evolving and unsophisticated laws and regulations applicable to the securities and financial services industries of certain countries; fluctuations in the rate of exchange between currencies and costs associated with currency conversion; and certain government policies that may restrict the Funds’ investment opportunities. In addition, accounting and financial reporting standards that prevail outside of the U.S. may not be as high as U.S. standards and, consequently, less information may be available concerning companies located outside of the U.S. than for those located in the U.S. As a result, the Funds may be unable to structure its transactions to achieve the intended results or to mitigate all risks associated with such markets. It may also be difficult to enforce the Funds’ rights in such markets. For example, securities traded on non-U.S. exchanges and the non-U.S. persons that trade these instruments are not subject to the jurisdiction of the U.S. Securities and Exchange Commission (the "SEC"), the U.S. Commodity Futures Trading Commission (the "CFTC") or the securities and commodities laws and regulations of the U.S. Accordingly, the protections accorded to the Company under such laws and regulations are unavailable for transactions on non-U.S. exchanges and with nonU.S. counterparties. Trading on non-U.S. exchanges may be subject to more risks than trading on U.S. exchanges, such as the risks of exchange controls, expropriation, burdensome taxation, moratoria and political or diplomatic events.

General Economic and Market Conditions. The success of the Funds’ activities will be affected by general economic and market conditions, such as interest rates, availability of credit, credit defaults, inflation rates, economic uncertainty, changes in laws (including laws relating to taxation of the Funds’ investments), trade barriers, currency exchange controls, and national and international political circumstances (including wars, terrorist acts or security operations). These factors may affect the level and volatility of the prices and the liquidity of the Funds’ investments. Volatility or illiquidity could impair the Funds’ profitability or result in losses. The Funds may maintain substantial trading positions that can be adversely affected by the level of volatility in the financial markets; the larger the positions, the greater the potential for loss.

Exchange Rate Exposure. The Funds may invest a portion of their assets in the securities of Part 2A of Form ADV - Page 11

non-U.S. issuers listed on foreign exchanges and denominated in non-U.S. currencies. The Funds, however, values their securities and other assets in U.S. dollars. The Funds have the authority to hedge its non-U.S.-dollar positions through currency hedging transactions. The Funds may or may not seek to hedge their non-U.S. currency exposure by entering into currency hedging transactions, such as treasury locks, forward contracts, futures contracts and cross-currency swaps. There can be no guarantee that securities suitable for hedging currency or market shifts will be available at the time when the Funds wish to use them, or that hedging techniques employed by the Funds will be effective. Furthermore, certain currency market risks may not be fully hedged or hedged at all. To the extent unhedged, the value of the Funds’ positions in non-U.S. investments will fluctuate with U.S. dollar exchange rates as well as with the price changes of the investments in the various local markets and currencies. Such fluctuations may result in a loss to the Funds.

Interest Rate Risk. The Funds are subject to interest rate risk. Generally, the value of fixed income securities will change inversely with changes in interest rates. As interest rates rise, the market value of fixed income securities tends to decrease. Conversely, as interest rates fall, the market value of fixed income securities tends to increase. This risk will be greater for longterm securities than for short-term securities. Polar may attempt to minimize the exposure of its portfolio to interest rate changes through the use of interest rate swaps, interest rate futures and/or interest rate options. However, there can be no guarantee that Polar will be successful in mitigating the impact of interest rate changes on its portfolio.

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Polar provides investment advisory services to private funds, which are generally organized as limited partnerships under the laws of the State of Delaware or another appropriate jurisdiction or, in the case of offshore private funds, as exempted companies incorporated under the laws of the Cayman Islands or limited partnerships organized under the laws of the Cayman Islands. Polar expects each private fund to qualify for an exclusion from having to register as an investment company under the IC Act pursuant to Section 3(c)(1) or Section 3(c)(7) thereunder, and to offer interests to investors pursuant to Regulation D or Regulation S under the Securities Act. In addition, Polar provides investment advisory services to a public investment fund, which is organized as a trust under the law of Ontario, Canada. The public investment fund qualifies for distribution under a simplified prospectus to investors in the applicable jurisdictions in Canada. Thus, this Brochure may discuss information relevant to such investors, as necessary or appropriate. Nonetheless, this Brochure is designed solely to provide information about Polar and should not be considered as an offer of interests in any Polar Fund. Any such offer may be made only by delivery to the prospective investor of the Offering Memorandum or Prospectus for the Fund under consideration. Private fund investors may include high net worth individuals and a variety of institutional investors (e.g., trusts, employee benefit plans, endowments, foundations, public pension plans, sovereign wealth funds, private funds of funds, family offices, and other types of entities). Polar also provides investment advisory services to private or public investment funds organized as limited partnerships or mutual fund trusts in Canada which are marketed to eligible investors in Canada, and separately managed accounts which are owned by institutional investors. Certain investors in the Funds may expose Polar to potential conflicts of interest. For example, officers and directors of companies in which the Funds invest may have invested in the Funds. Investments in the Funds by such parties may expose Polar to potential conflicts of interest with respect to proxy voting decisions and investment decisions and could expose Polar to risks relating to the receipt of material non-public information or other confidential information relating to the company in question. In addition, Polar employees have made, or may make, contributions to Part 2A of Form ADV - Page 8

charitable organizations that have invested in the private funds. Polar may have a conflict between acting in the best interest of the Funds and making decisions that build goodwill with the aforementioned types of investors so they will maintain or increase their investments in the Funds. The Funds may impose minimum initial and subsequent investment amounts on the investors, as disclosed in the Offering Memorandum or Prospectus. The separately managed accounts may require minimum investment amounts as negotiated with Polar.

The Funds charge a performance-based fee generally up to 20% of the net profits, in certain cases after a performance hurdle or preferred return, attributable to each investor, which is paid to Polar, or the general partner of the Funds, either at the end of the year or upon withdrawal of capital. For withdrawals, the performance-based fee only applies with respect to the amount of capital withdrawn. The performance-based fee is calculated as specified in each Fund’s Offering Memorandum or Prospectus. Depending on the Fund (and the different investor tranches, as available for the relevant Fund), high water marks, hurdle rates, and preferred returns may apply to the performancebased fee. Performance-based fees are charged in compliance with Rule 205-3 under the Investment Advisers Act of 1940 (“Advisers Act”).

Part 2A of Form ADV - Page 7

Performance-based fees may create an incentive for Polar to make riskier or more speculative investments on behalf of the Funds than would be the case in the absence of such fees. In addition, some Funds have higher performance-based fees than others, which creates an incentive for Polar to devote more time and resources to these Funds. Polar addresses this conflict by disclosing the performance-based fee and the associated risk in the Offering Memorandum or Prospectus. Polar also has policies and procedures regarding allocating investments among the Funds and regularly reviews Fund portfolios in an effort to ensure that allocations are in accordance with those policies and procedures. Trading activities of the Funds will overlap at times and conflicts could arise in managing those activities. Finally, Polar reserves the right to charge reduced or no performance-based fees to certain investors, including investors that are affiliates of Polar or the general partner. Polar has no obligation to disclose the specific details of such arrangements or to offer such additional rights, terms, or conditions to all investors.

Polar is registered with the U.S. Commodity Futures Trading Commission as a commodity pool operator and a swap firm. In Canada, Polar is registered as a Portfolio Manager in each of Alberta Part 2A of Form ADV - Page 22

and Ontario, as an Investment Fund Manager in each of Newfoundland and Labrador, Ontario and Quebec, as an Exempt Market Dealer in each of Alberta, British Columbia, Manitoba, New Brunswick, Newfoundland and Labrador, Nova Scotia, Ontario, Prince Edward Island, Quebec and Saskatchewan and as a Commodity Trading Manager in Ontario. White Bear provides investment advice in residential mortgage loans to a wholly-owned subsidiary of Polar Multi-Strategy Master Fund. Certain entities that are solely owned (directly or indirectly) by Polar Financial Corporation serve as general partners of the Funds. Polar is under common control with the general partners. Other entities that are solely owned (directly or indirectly) by Polar Financial Corporation serve as general partners of limited partnerships that invest in private equity and venture capital investments that are outside of the investment mandate of the Funds and/or separately managed accounts based on the Funds’ and/or separately managed accounts’ investment objective and strategies.

Trading Polar has adopted a Code of Ethics in compliance with Rule 204A-1 under the Advisers Act, that establishes standards of conduct for its supervised persons. The Code of Ethics includes general requirements that Polar’s supervised persons comply with their fiduciary obligations to clients and applicable securities laws, and specific requirements relating to, personal trading, insider trading, conflicts of interest and confidentiality of client information. It requires supervised persons to comply with personal trading restrictions and report their personal securities transactions and holdings to Polar’s Chief Compliance Officer (the “CCO”) and requires the CCO to review those reports. It also requires supervised persons to report any violations of the Code of Ethics promptly to the CCO. Each supervised person receives a copy of the Code of Ethics and any amendments to it and must acknowledge in writing having received those materials. Annually, each supervised person must certify that he or she complied with the Code of Ethics during the preceding year. Current and prospective investors can obtain a copy of the Code of Ethics by contacting Polar at (416) 367-4364. Under the Code of Ethics, Polar and its partners, officers, directors (or other person occupying a similar status or performing similar functions), employee, intern, consultants and contract individual of Polar (who are deemed to be subject to this Code by the CCO) or any similar persons of Polar’s affiliates who are deemed to be subject to this Code by the CCO, as well as the family members sharing the same household of the aforementioned persons, typically must obtain preapproval before engaging in most types of securities transactions (including private placements or limited offerings of shares of private companies, second offerings and initial public offerings), other than those securities listed on the Firm’s “Exempt Security List.” They generally may not invest in the same securities that Polar purchases, sells or is considering for the Funds other than those securities on the “Exempt Security List” or securities of an issuer that is a member of certain designated major Canadian or U.S. equity indices. Employees generally cannot sell a security (or cover a short position) within three months of acquiring (or selling short) the security, other than those securities on the “Exempt Security List”. Polar maintains a Restricted List of securities that include: (i) securities of issuers for which a Polar employee sits on the board of directors or has considerable influence or involvement with the Part 2A of Form ADV - Page 23

issuer, and/or (ii) securities of issuers that Polar might have received material non-public information about. Polar, its affiliates and employees invest their own assets in some of the Funds. Such financial interest incentivizes Polar to devote more time and resources to those Funds than Funds and separately managed accounts in which Polar and its affiliates do not have an interest and to cause those Funds to make riskier investments. Polar, its affiliates and employees may give advice or take action for their own accounts that may differ from, conflict with or be adverse to advice given or action taken for the Funds. These activities may adversely affect the prices and availability of other investments held by or potentially considered for purchase by the Funds. Polar addresses this conflict by disclosing it. Polar also has policies and procedures regarding allocating investments among the Funds and regularly reviews Fund portfolios in an effort to ensure that allocations are in accordance with those policies and procedures. Polar has conflicts of interest over its time devoted to managing any one account and allocating investment opportunities among all accounts that it manages. Different clients have differing investment strategies and levels of trading. Polar may buy or sell a security for one client but not for another or may buy (or sell) a security for a client while simultaneously selling (or buying) the same security for another client. Polar may give advice to, and take action on behalf of, any of its clients that differs from the advice that it gives or the timing or nature of action that it takes on behalf of any other client. Polar is not obligated to acquire for any account any security that it, its affiliates or employees may acquire for its or their own accounts or for any other client. Subject to applicable law and the requirements set out therein, including National Instrument 81107 – Independent Review Committee for Investment Funds ("NI 81-107") of Canadian securities administrators, Polar may, on behalf of the Fund, purchase a security of an issuer from, or sell a security of an issuer to, another Fund managed or advised by Polar or its affiliate. Any such cross trades will be effected in accordance with applicable law (which may require an instrument’s valuation to change in order to comply with the pricing requirements under NI 81-107) and subject to Polar's overarching fiduciary obligations. Notwithstanding the foregoing, Polar is not required to engage in these transactions and there may be potential conflicts of interest or regulatory issues relating to these types of transactions which could limit Polar's decision to engage in these transactions, as the case may be.

Polar has complete discretion in selecting the brokers it uses for client transactions and the commission rates that clients pay such brokers. In selecting a broker, Polar considers a number of factors, including, for example:

Price; Speed of execution; Certainty of execution; and Overall cost of the transaction.

Section 28(e) of the Exchange Act of 1934 provides a “safe harbor” to investment advisers who use commission dollars of their advised accounts to obtain investment research and brokerage services that provide lawful and appropriate assistance to the adviser in performing investment decisionmaking responsibilities. Conduct outside of the safe harbor of section 28(e) is subject to traditional Part 2A of Form ADV - Page 24

standards of fiduciary duty under state and federal law. If Polar uses commission dollars to pay for products or services that provide administrative or other non-research assistance to itself or its affiliates, such payments are unlikely to fall within the section 28(e) safe harbor. Polar uses commercially reasonable efforts to stay within that safe harbor. Within the last fiscal year, Polar acquired the following types of products and services with commission dollars of the Funds: i) investment research on particular issuers or industries which are produced by the brokers, ii) investment research on particular issuers or industries which are produced by third parties, iii) market, financial, economic, and non-economic (which relates to securities issuers’ business and/or financial performance, for example, the number of mobile application downloads) data sets, iv) consulting services with third parties regarding products, issuers or industries, v) invitations to attend conferences or meetings with management or industry consultants, vi) software used to route orders to exchanges, vii) software that provides algorithmic trade execution strategies, and viii) software that provides analyses of the Funds’ portfolios. Polar may pay commissions and mark-ups that exceed those that another broker might charge for the same transaction because of the brokerage, research, other services and soft dollar relationships that such broker provides. Polar determines in good faith that such compensation is reasonable in relation to the value of such brokerage, research, other services and soft dollar relationships, in terms of either the specific transaction or Polar’s overall fiduciary duty to its clients. A client may, however, pay higher commissions and mark-ups than are otherwise available or may pay more commissions or mark-ups based on account trading activity. The research and other benefits resulting from Polar’s brokerage relationships benefit Polar’s operations as a whole and all accounts that it manages, including those that do not generate soft dollars. Polar does not allocate soft dollar benefits to client accounts proportionately to the soft dollar credits that the accounts generate. When Polar uses commission dollars to obtain investment research and brokerage services, Polar is benefitted because Polar does not have to produce or pay for the research, products or services. Polar’s relationships with brokers that provide soft dollar services influence Polar’s judgment and create conflicts of interest in allocating brokerage business between firms that provide soft dollar services and firms that do not. Polar has an incentive to select or recommend a broker based on Polar’s interest in receiving soft dollar services rather than clients’ interest in receiving the most favorable execution. These conflicts of interest are particularly influential to the extent that Polar uses soft dollars to pay expenses that are not reimbursed by the Funds and separately managed accounts. Polar addresses these conflicts of interest by periodically evaluating the trade execution services it receives from the brokers it uses to execute client trades. Such evaluation includes comparing those services to the services available from other brokers. Polar considers, among other things, alternative market makers and market centers, the quality of execution services, the value of continuing with various soft dollar services and adding or removing brokers, increasing or decreasing targets for each broker and the appropriate level of commission rates. Polar aggregates securities sale and purchase orders for clients with similar orders being made contemporaneously for other accounts that Polar manages or with its affiliates’ accounts. In such event, Polar typically charges or credits a client the average transaction price of all securities purchased or sold in such transactions. As a result, the price may be less favorable to the client than it would be if Polar were not executing similar transactions concurrently for other accounts. Part 2A of Form ADV - Page 25

Polar may direct a certain amount of brokerage to a broker in return for the broker’s referral of prospective investors. Directing brokerage in exchange for investor referrals creates a conflict of interest in that Polar has an incentive to refer its clients’ brokerage business to brokers to which it might not otherwise direct transactions.

Polar has engaged placement agents to whom it pays a percentage of the management and/or performance fees paid by investors referred by those placement agents. In such cases, this practice is disclosed to the investors.

Polar is required to disclose any legal or disciplinary events that are material to a client’s or a prospective client’s evaluation of Polar’s advisory business or the integrity of Polar’s management. Polar and its management personnel have no such legal or disciplinary events to disclose.

Polar’s portfolio managers continually review records for all Funds and separately managed accounts. These reviews take into account various factors, including but not limited to asset allocation, cash management, the prospects of individual securities, changes in issuer earnings, industry outlook, market outlook and price levels. Polar’s Chief Risk Officer periodically reviews key risk reports, such as market risk exposures, capital allocations, portfolio and issues concentrations, diversification limits, leverage levels, excess margin balances, and counterparty exposures. In addition, on a periodic basis, Polar’s CCO reviews Funds and separately managed account portfolio data to ensure the stated objectives, strategies and restrictions have been adhered to. All Fund investors may choose to receive a quarterly or annual letter (as applicable to the Fund) that discusses investment performance and outlook, and annual audited financial statements. Polar also provides Fund investors, if applicable, annual tax information for preparing U.S. tax returns.

Under the SEC’s custody rule applicable to investment advisers, Polar is deemed to have custody of the Funds’ assets. In accordance with the custody rule, Polar will ensure that (i) the Funds are audited by an independent public accountant registered with, and subject to inspection by, the Public Company Accounting Oversight Board, (ii) the Funds’ audited financial statements are prepared in accordance with U.S. generally accepted accounting principles, and (iii) Polar delivers such annual audited financial statements to investors within 120 days after the end of each Fund’s fiscal year. Polar does not have custody of the assets in the separate managed accounts.

Polar has discretionary authority to manage securities accounts on behalf of the Funds and the separately managed accounts pursuant to a grant of authority in each Fund’s or separately managed account’s limited partnership agreement or investment management agreement. Generally, this discretionary authority is to be exercised in a manner consistent with the stated investment objectives for the particular Fund. In certain circumstances, separately managed account Part 2A of Form ADV - Page 26

clients may provide specific limitations relating to certain transactions, provided such limitations do not conflict with the investment objectives or guidelines of the separately managed accounts.

Polar has the authority to vote proxies under the investment management agreements of the Funds and separately managed accounts. Polar shall take reasonable steps to vote all proxies received and does not delegate proxy-voting decision-making to third parties. Polar may abstain or otherwise withhold its vote if in its opinion such abstention or withholding is in the best interests of clients; it may also refrain from voting where administrative or other procedures result in the costs of voting outweighing the benefits including circumstances, such as:

Voting securities are part of a securities lending program and Polar is unable to vote securities that are out on loan;

A meeting notice is delivered close to the meeting date and Polar has insufficient time to process the vote;

Polar sells shares prior to a company’s meeting date and decides not to vote those shares. Polar shall not be restricted from trading in a security due to an upcoming shareholder meeting unless prohibited by the local market rules;

The ballot item is non-binding or advisory in nature to the company.

Circumstances may occur where Polar may have a potential conflict of interest relative to its proxy voting activities. Potential conflicts of interest could include business relationships with an issuer or proponent of a proxy proposal, participants in proxy contests, corporate directors, or candidates for directorships. In such cases, Polar shall vote the proxies in the client’s best interest. Fund investors and separately managed account clients can obtain a copy of Polar’s proxy voting policy and procedures by contacting Polar at (416) 367-4364. Polar has engaged a third-party vendor to monitor class action lawsuit settlements in which Polar Funds and separately managed accounts may be eligible to recover compensation. In the event that an eligible class action settlement is identified, Polar will complete the required documentation to attempt to recover the compensation on behalf of the applicable Fund(s) and/or separately managed account(s).

Polar does not require or solicit prepayment of management and/or performance fees from its clients. There are no financial conditions that are reasonably likely to impair Polar’s ability to meet contractual commitments to its clients. Polar has not been the subject of a bankruptcy petition at any time during the past ten years.