Politan Capital Management LP

General Description of Advisory Firm

Politan Capital Management, L.P. (“Politan”, the “Firm”, “we”, or “us”) is a Delaware limited partnership that was formed in July 2021. Politan began operations as an investment adviser in September 2021 and serves as the discretionary investment manager to private fund clients. Politan is controlled by its principal owner, Quentin Koffey, Managing Partner & Chief Investment Officer (the “Chief Investment Officer”). The Chief Investment Officer is a limited partner of Politan and has ultimate responsibility for its management and investment decisions. Politan Capital Management GP, LLC, a Delaware limited liability company, serves as the general partner of Politan and is owned and controlled by the Chief Investment Officer (and/or entities owned or controlled by the Chief Investment Officer). Politan’s registration on Form ADV also covers Politan Capital Partners GP LLC (“Politan GP”), a Delaware limited liability company. Politan GP is an affiliate of Politan and serves as the general partner of certain clients that are organized as U.S. and Cayman Islands exempt limited partnerships. Politan and Politan GP share facilities and personnel. The Chief Investment Officer (and/or entities owned and controlled by the Chief Investment Officer) is the principal owner of Politan GP. B.

Description of Advisory Services

Politan serves as the investment adviser, with discretionary trading authority, to private fund clients, the securities of which are offered to investors on a private placement basis (each, a “Fund” and collectively, the “Funds”). The Funds include:

Politan Capital Partners LP, a Delaware limited partnership (the “Domestic Fund”);

Politan Capital Offshore Partners LP, a Cayman Islands exempted limited partnership (the “Offshore Fund”), and

Politan Capital Partners Master Fund LP, a Cayman Islands exempted limited partnership (the “Master Fund”), which serves as the master fund into which the Domestic Fund and Offshore Fund invest substantially all of their assets through a “master feeder” structure.

Politan GP serves as the general partner of the Funds. The Funds have an "evergreen" structure with the ability to create separate series (each a “Series”) with separate portfolios. Each Series will effectively be accounted for as a separate investment vehicle with its own investments, commitments and/or contributions, distributions, investments, investment restrictions, investment periods, fees, withdrawal rights and expenses.

Through its investment authority with respect to its management of client assets, Politan seeks to acquire undervalued and/or underperforming companies pursuant to an "activist investment" strategy where Politan believes that operational improvements and/or strategic initiatives can create value. Notwithstanding the foregoing, subject to any limitations in the governing documents of the Funds, Politan is not limited with respect to the types of investment strategies it may employ or the markets or instruments in which it may invest. As used herein, the term “client” generally refers to each Fund and to any other private fund or separately managed account Politan may advise in the future. Tailored Advisory Services for Clients Politan manages assets in accordance with the stated investment objectives of each client, as described in the applicable investment management agreement or in an offering memorandum (collectively, the “Offering Documents”). Investment advice is provided directly to clients and not individually to the investors in clients (the “Investors”). C.

Wrap Fee Programs

Politan does not participate in wrap fee programs. D.

Assets Under Management

As of December 31, 2025, Politan had regulatory assets under management of $855,678,000, all managed on a discretionary basis.

Advisory Services and Fees

Politan, either directly or indirectly through Politan GP, receives management fees and performance-based compensation in connection with the management of the Funds. The fees and/or compensation applicable to each series of a Fund are set forth in detail in each Fund’s Offering Documents. A brief summary of such fees and compensation is provided below. Management Fee The standard management fee with respect to each Series is 1.50% per annum (the “Management Fee”), based on each investor in the Fund’s (“Fund Investor”) interest in the applicable Series as of the beginning of each calendar quarter, payable in advance on the first day of each calendar quarter. Politan has modified the Management Fee charged to certain Series Investors, and may in the future, in its sole discretion, elect to waive, reduce or calculate differently the Management Fee with respect to any Fund Investor, including any member, partner, director, officer, employee and principal of Politan, or any family members of any of the foregoing, which includes accounts, trusts, partnerships or other entities primarily for the benefit of any of the foregoing or their family members (collectively, “Politan-Related Investors”). Typically, no Management Fee will be paid by any Politan-Related Investor. Each Fund may offer other series of interests into which Investors may invest, as detailed further in the applicable Fund’s Offering Documents. The management fee rate will differ among such series of interests and therefore the specific management fee amounts charged to Investors will be determined by the specific investor’s series of interests. Carried Interest, Incentive Fees and Incentive Allocation Generally, Politan GP is entitled to receive performance-based carried interest distributions and/or incentive fees or allocations (“Carry/Incentive”) of up to 20% as more fully set forth in the applicable Offering Documents. Politan has modified the Carry/Incentive charged to certain Series Investors, and may in the future elect to reduce, waive, or calculate differently the Carry/Incentive with respect to any Fund Investor, including Politan-Related Investors. The Funds have entered into side letter arrangements with certain Investors which provide for different or additional terms than those described above including, without limitation, different or more favorable withdrawal rights, such as more frequent withdrawals or shorter withdrawal notice periods, different fee or Carry/Incentive terms, greater information than may be provided to other

Investors, more favorable transfer rights, key-person notifications, “most favored nation” clauses, and other rights. B.

Payment of Fees

Fees and compensation paid to Politan and its affiliates by clients are generally deducted from the assets of such clients. As discussed above, Management Fees are generally deducted on a quarterly basis and any Carry/Incentive is allocated as set forth in the Fund’s Offering Documents. C.

Additional Expenses

Each client pays costs and expenses of such client’s activities as set forth in the applicable Offering Documents, including but not limited to some or all of the following:

Expenses associated with all investments and transactions considered, evaluated and/or consummated by a client, including but not limited to expenses associated with sourcing, negotiating, investigating, researching, financing and structuring of investments and potential investments, whether or not consummated (including third-party investment sourcing fees, third-party research, data, analytics, modeling, structuring, pricing, execution and other third-party information systems, software (including any information technology hardware, software or other technology incorporated into the cost of obtaining such research and market data and expenses related to obtaining, processing and analyzing “big data” or “alternative data”), service fees (including data feeds, subscriptions, reports and similar items)); Expenses associated with holding, financing, monitoring, hedging, maintaining and disposing of all investments (including expenses related to order management systems, portfolio management systems and asset and property management expenses of third parties) and all transaction and other costs associated therewith; Travel and related expenses associated with investments and potential investments of a client; Professional fees associated with investment and potential investments of a client, including, but not limited to, consulting, accounting, investment banking, legal and other advisory fees and expenses; Fees and expenses related to outsourced middle and back office providers (including fees and expenses for services relating to Investment Advisers Act of 1940 compliance); Transaction fees, brokerage, prime brokerage and futures commission merchant fees, commissions and expenses (including fees, commissions and expenses paid or reimbursed to an external trading desk), clearing and settlement charges and similar fees and expenses associated with the acquisition, disposition and settling of investments and potential investments of a client; Expenses relating to short sales, clearing and settlement charges, custodial fees and expenses, bank service fees, interest expenses and fees related to financings or refinancings; Fees and expenses of proxy research and voting services;

Fees and expenses (including travel and lodging expenses) associated with activist campaigns (both long and short) such as fees and expenses related to event hosting and production, public presentations, creating and maintaining informational websites and engaging in online campaigns including via social media, public relations, public affairs and government relations, forensic and other analyses and investigations, proxy contests, solicitations and tender offers, and compensation, indemnification and other fees and expenses of any nominees proposed by Politan as directors or executives of portfolio companies; Administrative, custodial, appraisal, valuation, legal, consulting, advisory and similar fees and expenses associated with a client’s operations, investments and transactions, including fees and expenses of a client’s administrator; Broken-deal, failed transaction, break-up and similar fees, costs and expenses; Costs and expenses of leverage of a client, including interest charges and fees; Auditing and accounting expenses, including expenses associated with the preparation of a client's financial statements, tax returns and Schedules K-1; Costs and expenses associated with investor communications and reports and the delivery thereof to investors; Insurance expenses, including, but not limited to, directors' and officers' liability insurance, errors and omissions insurance and other policies; Costs and expenses (including taxes, fees or other governmental charges) associated with the formation, organization and operation of any additional investment vehicles, trading vehicles and/or other subsidiary, holding company or similar entity formed with respect to investments, credit facilities or other transactions entered into for the benefit of client; Wind up, liquidation, termination and dissolution expenses; Costs, fees and expenses related to registration, qualification and/or exemption under any applicable U.S. federal, state, local or non-U.S. laws, rules or regulations, including blue sky fees and other securities and/or investment-related filing expenses (including fees and expenses incurred as a result of failing to make such filings); Costs related to any transfers of interests, unless otherwise charged to or borne by the applicable transferor and/or transferee; Any extraordinary expenses (including all litigation-related and indemnification and contribution expenses, including those expenses incurred in accordance with the applicable Offering Documents, including the amount of any judgment or settlement paid in connection therewith); Fees and expenses in connection with the admission of new Investors to a client (or series of a client) pursuant to the offering of interests in such series, including the cost of updating the subscription agreement, any series addendum, to the extent applicable, and other relevant documents; Expenses incurred in connection with client’s Board of Managers, if applicable; Expenses incurred in connection with negotiating and complying with provisions of any side letter agreement; Fees and expenses relating to the offer and sale of the interests, classes of interests and/or sub-classes of interest;

Expenses incurred in connection with loan and asset servicing and settlement activities, collateral management, loan administration and due diligence services for a client; and All other fees, costs, taxes, charges and expenses associated with the business, affairs and/or operations of a client.

When Politan incurs expenses on behalf of multiple clients or series , it will allocate the expenses among the applicable clients/series in a fair and equitable manner; however, it is possible that not all expenses will be allocated ratably across all clients/series. D.

Prepayment of Fees

With respect to the Funds, Management Fees are paid quarterly in advance. E.

Additional Compensation

Neither Politan nor its personnel receive a brokerage commission or any other compensation attributable to the sale of securities or other investment products. The Chief Investment Officer currently serves on the board of directors of certain portfolio companies in which the Funds invest. In connection with such service, the Chief Investment Officer receives directors’ fees or similar fees, payments or compensation. To the extent the Chief Investment Manager or Politan or its affiliates receive such fees, payments, and compensation, any such fees, payments, and compensation (or a pro rata portion thereof based on the amount of invested capital in the applicable investment) will reduce the Management Fee otherwise due to Politan.

Method of Analysis, Investment Strategies and Risk of Loss A.

Methods of Analysis and Investment Strategies

The descriptions set forth in this Brochure of specific advisory services that Politan offers to clients, and investment strategies pursued and investments made by it on behalf of clients, should not be understood to limit in any way Politan's investment activities. Politan may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that are considered appropriate, subject to each client's investment objectives and guidelines. The investment strategies that Politan pursues are speculative and entail substantial risks. Clients and Investors should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any client will be achieved. The primary investment objective of the Funds is to acquire undervalued and/or underperforming companies pursuant to an "activist investment" strategy where Politan believes that operational improvements and/or strategic initiatives can create value. B.

Material, Significant or Unusual Risks Relating to Investment Strategies

The investment program that Politan pursues on behalf of clients is speculative and involves substantial risks. There can be no assurance that clients will achieve their investment objectives. An investment in any client carries with it the inherent risks associated with investments in equity securities, corporate debt, and other instruments. Risk Factors The following risk factors and other relevant risks could have a material adverse effect on clients and the Investors’ investments therein. Risks Relating to Investment Strategy Risk of Loss. No guarantee or representation is made that a client’s investment program, including a client’s investment objective, diversification strategies or risk monitoring goals, will be successful. Investment results may vary substantially over time. No assurance can be made that profits will be achieved or that substantial or complete losses will not be incurred. Activist Investing. The success of a client’s activist investment strategy depends upon, among other things: (i) Politan’s ability to properly identify portfolio companies whose securities prices can be improved through corporate and/or strategic action; (ii) a client’s ability to acquire sufficient securities of such portfolio companies at a sufficiently attractive price; (iii) a client’s ability to avoid triggering anti-takeover and regulatory obstacles while aggregating its position; (iv) the willingness of the management of such portfolio companies and other security holders to respond positively to Politan’s proposals; and (v) favorable movements in the market price of any

such portfolio company’s securities in response to any actions taken by such portfolio company. There can be no assurance that any of the foregoing will occur. Corporate governance strategies may prove ineffective for a variety of reasons, including: (i) opposition of the management or investors of the subject company, which may result in litigation and may erode, rather than increase, the value of the subject company; (ii) intervention of a governmental agency; (iii) efforts by the subject company to pursue a “defensive” strategy, including a merger with, or a friendly tender offer by, a company other than the offeror; (iv) market conditions resulting in material changes in the prices of securities; (v) the presence of corporate governance mechanisms such as staggered boards, poison pills and classes of stock with increased voting rights; and (vi) the necessity for compliance with applicable securities laws. In addition, opponents of a proposed corporate governance change may seek to involve regulatory agencies in investigating the transaction or clients and such regulatory agencies may independently investigate the participants in a transaction, including the clients, as to compliance with securities or other law. Furthermore, successful execution of a corporate governance strategy may depend on the active cooperation of investors and others with an interest in the subject company. Some investors may have interests which diverge significantly from those of the clients, and some of those parties may be indifferent to the proposed changes. Moreover, securities that Politan believes are fundamentally undervalued or incorrectly valued may not ultimately be valued in the capital markets at prices and/or within the timeframe Politan anticipates, even if a corporate governance strategy is successfully implemented. Even if the prices for a portfolio company’s securities have increased, no guarantee can be made that there will be sufficient liquidity in the markets to allow the clients to dispose of all or any of their securities therein or to realize any increase in the price of such securities. Proxy Contests and Unfriendly Transactions. Clients expect to purchase securities of companies that may be the subject of a proxy contest. There can be no assurance that a proxy contest will be successful and therefore the clients may not be able to fully implement the desired change at the company. In addition, where an acquisition or restructuring transaction or proxy fight is opposed by the subject company’s management, the transaction often becomes the subject of litigation. Such litigation involves substantial uncertainties and may impose substantial cost and expense on the company participating in the transaction. Concentration and Nature of Investments. Since Politan intends to concentrate the investments of its clients, the overall adverse impact on a given portfolio investment and adverse movements in the value of the securities of the applicable portfolio investment will be greater than if Politan was not permitted to concentrate the investments of the clients. Clients investment strategy may depend upon the ability to acquire a sufficient position in a portfolio investment to enable it to influence certain management actions. In order to achieve this objective, clients may need to reach a sufficient amount of assets to permit it to acquire positions of the necessary magnitude. There can be no assurance that clients will reach an asset level large enough to permit it to obtain

ownership stakes of such size or that even if it does it will be able to accumulate ownership stakes in portfolio investments in the size desired or necessary to achieve the clients’ objectives. Equity Securities. Clients will invest in equity and equity-related securities. Equity securities in general fluctuate in value in response to many factors, including the activities, results of operations and financial condition of individual companies, the business market in which individual companies compete, industry market conditions, interest rates and general economic environments and movements in the equity markets in general. As a result, clients may suffer losses if it invests in equity instruments of issuers whose performance diverges from Politan’s expectations or if equity markets generally move in a single direction and a client has not hedged against such a general move. Swap Agreements and Synthetic Assets. Clients may acquire exposure to the risk of structured finance securities, debt securities and loans synthetically through products such as credit default swaps (including CDS and ABX and CDX contracts), total return swaps, credit-linked notes, structured notes, trust certificates and other derivative instruments (each, a “Synthetic Asset”). A Synthetic Asset could take many forms, including a credit derivative transaction that references a structured finance security, debt security and loan or a credit derivative transaction that references a portfolio or index of corporate reference entities or a portfolio or index of reference obligations consisting of structured finance securities, debt securities, bonds or other financial instruments (each, a “Reference Obligation”). Exposure to such Reference Obligations through Synthetic Assets presents risks in addition to those resulting from direct purchases of the assets referenced. Clients have a contractual relationship only with the Synthetic Asset counterparty, and not with the issuer(s) (the “Reference Entity”) of the Reference Obligations unless a credit event occurs with respect to any such Reference Obligation, physical settlement applies and the synthetic asset counterparty delivers the Reference Obligation to clients. Other than in the event of such delivery, clients generally will have no right directly to enforce compliance by the Reference Entity with the terms of any such Reference Obligation and clients will not have any rights of set-off against the Reference Entity. In addition, clients generally will not have any voting or other consensual rights of ownership with respect to the Reference Obligation. Clients also will not directly benefit from any collateral supporting the Reference Obligation and will not have the benefit of the remedies that would normally be available to a holder of such Reference Obligation. Clients will be subject to the credit risk of the synthetic asset counterparty, as well as that of the Reference Entity, as well as the documentation risk associated with these instruments. In the event of the insolvency of the Synthetic Asset counterparty, client will be treated as a general creditor of such counterparty, and will not have any claim of title with respect to the Reference Obligation. Consequently, clients will be subject to the credit risk of the Synthetic Asset counterparty, as well as that of the Reference Entity. As a result, concentrations of Synthetic Assets entered into with any one synthetic asset counterparty will subject such Synthetic Assets to an additional degree of risk with respect to defaults by such Synthetic Asset counterparty as well as by the respective Reference Entities. While Politan expects that returns on a Synthetic Asset may reflect those of each related Reference Obligation, as a result of the terms of the Synthetic Asset and the assumption of the credit risk of

the Synthetic Asset counterparty, a Synthetic Asset may have a different expected return, a different (and potentially greater) probability of default and different expected loss and recovery characteristics following a default. Leverage and Borrowing. Leverage for Investment Purposes The use of leverage will allow clients to make additional investments, thereby increasing its exposure to assets, such that its total assets may be greater than its capital. However, leverage will also magnify the volatility of changes in the value of a client’s portfolio. The effect of the use of leverage by a client in a market that moves adversely to its investments could result in substantial losses to a client, which would be greater than if a client were not leveraged. Borrowing for Cash Management Purposes Clients may have the authority to borrow for cash management purposes, such as to satisfy withdrawal requests. The rates at and terms on which such clients can borrow will affect the operating results of the client. Collateral The instruments and borrowings utilized by clients to leverage investments may be collateralized by all or a portion of the clients’ portfolio. Accordingly, clients may pledge its securities in order to borrow or otherwise obtain leverage for investment or other purposes. Should the securities pledged to brokers to secure the clients’ margin accounts decline in value, clients could be subject to a “margin call”, pursuant to which clients must either deposit additional funds or securities with the broker or suffer mandatory liquidation of the pledged securities to compensate for the decline in value. The banks and dealers that provide financing to clients can apply essentially discretionary margin, “haircut”, financing and collateral valuation policies. Changes by counterparties in any of the foregoing may result in large margin calls, loss of financing and forced liquidations of positions at disadvantageous prices. Lenders that provide other types of asset-based or secured financing to the clients may have similar rights. There can be no assurance that clients will be able to secure or maintain adequate financing. Costs Borrowings will be subject to interest, transaction and other costs, and other types of leverage also involve transaction and other costs. Any such costs may or may not be recovered by the return on a client’s portfolio. Risks Relating to Market Conditions Generally General Economic and Market Conditions. The success of a client’s 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 clients’ investments), trade barriers, currency exchange controls, and national and international

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Performance-Based Fees and Side-By-Side Management As set forth in Item 5.A above, Politan and its affiliates are entitled to receive performance-based compensation from certain clients in connection with providing advisory services to such clients. Performance-based compensation will only be charged in accordance with the requirements of the Investment Advisers Act of 1940. Such performance-based compensation may give rise to potential conflicts of interest including the incentive for Politan to allocate certain trades in favor of clients with performance-based compensation arrangements over clients that are not charged performance-based compensation. In addition, performance-based compensation can incentivize Politan to make investments that are riskier or more speculative than it would otherwise make due to the higher return potential associated with higher risk investments. Politan seeks to mitigate such conflicts of interest through the adoption and implementation of its investment allocation policy.

Broker-Dealer Registration

Neither Politan nor any of its management persons is registered, or has an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. B. Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor Registration Neither Politan nor any of its management persons is registered, or has an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or is an associated person of any of the above. Politan GP claims an exemption from CFTC registration under Rule 4.13(a)(3), which exempts commodity pool operators that (i) trade only a de minimis level of commodity interests, (ii) market to “accredited investors” and (iii) do not market trading in commodity interests. C.

Material Relationships and Conflicts of Interests with Industry Participants

As noted above, Politan GP serves as the general partner to the Funds. Politan does not have any material relationships or arrangements with industry participants. Conflicts of interest may arise from the fact that Politan, Politan GP, and their affiliates may in the future provide investment management services to clients other than the Funds, including investment funds, managed accounts, proprietary accounts and other investment vehicles (the “Other Accounts”). Other Accounts may have investment objectives, programs, strategies and positions that are similar to or may conflict with those of the Funds or may compete with or have interests adverse to the Funds. Such conflicts could affect the prices and availability of securities in which the Funds invest. Even if an Other Account has investment objectives, programs or strategies that are similar to those of the Funds, Politan may give advice or take action with respect to the investments held by, and transactions of, the Other Accounts that may differ from the advice given or the timing or nature of any action taken with respect to the investments held by, and transactions of, the Funds for a variety of reasons, including differences between the investment strategy, financing terms, regulatory treatment and tax treatment of the Other Accounts and the Funds . As a result, the Funds and an Other Account may have substantially different portfolios and investment returns. Conflicts of interest may also arise when Politan makes decisions on behalf of the Funds with respect to matters where the interests of Politan or one or more Other Accounts differs from the interests of the Funds. D.

Material Conflicts of Interest Relating to Other Investment Advisers

Politan does not recommend or select other investment advisers for the clients.

Code of Ethics

Politan has adopted a Code of Ethics that is designed to reinforce and enhance Politan’s ethical way of doing business and, in particular, to provide procedures consistent with the provisions of the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and the rules and regulations thereunder, and all other applicable laws, including all applicable federal securities laws. The Code of Ethics is based on the principle that Politan has a fiduciary duty to its clients, and Politan must, in this fiduciary capacity, act in the best interest of its clients. The Firm’s Code of Ethics contains rules concerning conflicts of interest, personal securities transactions, gifts and entertainment, outside business activities, and employee screening. Additionally, Politan’s Code of Ethics provides for a range of sanctions, as deemed appropriate by the Chief Compliance Officer, should anyone violate the Code of Ethics. Such sanctions include censure, fines, reversal of transaction(s) and disgorgement of profits, suspension or termination of employment. The Code of Ethics incorporates the following general principles which all employees are expected to uphold:

The interests of Politan’s clients must always come first. Trading in client accounts must be in their best interests and always be supported by research and reasonable judgment. Employees must comply with all applicable laws and regulations of the countries in which Politan conducts business. All personal securities transactions must be conducted in such a manner as to avoid actual or potential conflicts of interest or abuses of an individual’s position of trust and responsibility. Employees must not take any inappropriate advantage of their positions at Politan.

Politan will provide a copy of its entire Code of Ethics to any client or any Investor that requests one. Copies of the Code of Ethics may be requested by contacting Politan at compliance@politanmgmt.com. B.

Participation or Interest in Client Transactions

Politan does not intend to purchase or sell any securities for its own account. However, on occasion and subject to a client’s applicable investment guidelines and restrictions, Politan may determine that it would be in the best interests of certain clients to transfer a security from one client account to another (each such transfer, a “Cross Trade”) for a variety of reasons, including tax purposes, liquidity purposes, to rebalance the portfolios of Politan’s clients, or to reduce transaction costs that may arise in an open market transaction. If Politan decides to engage in a Cross Trade, Politan will determine that the trade is in the best interests of both of the clients involved and take steps to ensure that the transaction is consistent with Politan’s duty to seek best execution for each of those clients. Politan generally intends to execute Cross Trades, if at all, with the assistance of a broker27

dealer that executes and books the transaction at the close of the market on the day of the transaction. Alternatively, a cross transaction between two clients may occur as an “internal cross”, where Politan instructs the custodian for the client to book the transaction at the price determined in accordance with Politan’s valuation procedures. If Politan effects an internal cross, Politan will not receive any fee in connection with the completion of the transaction. When effecting Cross Trades between clients, Politan will have potentially conflicting division of loyalties and responsibilities with respect to each participating client. To the extent that any such Cross Trade may be viewed as a principal transaction due to an ownership interest in the client by Politan or its personnel, Politan will comply with all applicable requirements of the Advisers Act. C.

Personal Trading

Politan’s Code of Ethics places restrictions on personal trades by its employees, including that they disclose their personal securities holdings and transactions to the Chief Compliance Officer on a periodic basis, and requires that employees pre-clear certain types of personal securities transactions. Employees may engage in transactions in certain permitted investments without preclearance. Permitted investments include mutual funds and broad-based ETFs. Clients may invest in the same or similar mutual funds and ETFs. Politan, its affiliates, and its 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 clients. These activities may adversely affect the prices and availability of other securities held by or potentially considered for purchase by clients. D.

Conflicts of Interest Created by Contemporaneous Trading

Politan seeks to allocate investment opportunities in a manner it considers fair and equitable, to the extent practical and in accordance with the clients’ applicable investment strategies, over a period of time. Investment opportunities will generally be allocated among those clients for which participation in the respective opportunity is considered appropriate, taking into account, among other considerations: (i) whether the risk-return profile of the proposed investment is consistent with a client’s objectives; (ii) the potential for the proposed investment to create an imbalance in a client’s portfolio; (iii) the liquidity requirements of a client; (iv) potentially adverse tax consequences; (v) regulatory restrictions that would or could limit a client’s ability to participate in a proposed investment; and (vi) the need to re-size risk in a client’s portfolio. Politan will have no obligation to purchase or sell a security for, enter into a transaction on behalf of, or provide an investment opportunity to one client solely because Politan purchases or sells the same security for, enters into a transaction on behalf of, or provides an opportunity to, another client, in its reasonable opinion, such security, transaction or investment opportunity does not appear to be suitable, practicable or desirable for clients.

Brokerage Practices A. Factors Considered in Selecting or Recommending Broker-Dealers for Client Transactions To the extent Politan uses broker-dealers or other intermediaries to effect securities transactions for client accounts, Politan will consider a number of factors in selecting such broker-dealers or intermediaries and determining the reasonableness of the broker-dealers’ or intermediaries’ compensation. Such factors may include net price, reputation, financial strength and stability, efficiency of execution and error resolution. In selecting a broker-dealer or an intermediary to execute transactions (or series of transactions) and determining the reasonableness of the brokerdealer’s compensation, Politan need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Politan maintains an Operating Committee that will periodically meet to review the quality of execution and various trading matters. Politan has executed its trading program with a consolidated list of broker-dealers. 1. Research and Other Soft Dollar Arrangements Politan may pay broker-dealer commissions for executing client portfolio transactions in excess of those which another broker-dealer might have charged for executing the transaction in recognition of the value of the brokerage and research services provided by the broker-dealer. Politan will effect such transactions, and receive such brokerage and research services, only to the extent that they fall within the safe harbor provided by Section 28(e) of the Exchange Act and subject to prevailing guidance provided by the SEC regarding Section 28(e). Politan may also execute securities transactions under “commission sharing arrangements” with one or more brokerage firms. Under these arrangements, a portion of the commission is paid to that broker-dealer for execution services and the remainder of the commission is paid to other approved broker-dealers or third-party research providers for research services provided by such broker-dealers or vendors. Transactions executed under these commission sharing arrangements generate a higher commission rate than transactions executed with other broker-dealers. On a periodic basis, the Operating Committee will evaluate the transactions executed under these arrangements to ensure that the brokerage and research services received by Politan are within the safe harbor provided under Section 28(e). 2. Brokerage for Client Referrals Politan currently does not consider whether Politan or a related person receives client referrals from a broker-dealer or third-party in selecting or recommending broker-dealers or intermediaries to effect portfolio investments or securities transactions for client accounts.

3. Directed Brokerage Politan does not recommend, request, or require that a client direct Politan to execute transactions through a specified broker-dealer. 4. Trade Errors Trade errors involving transactions in any account directly or indirectly held by a client may occur. Trade errors include: (i) the placement of orders (either purchases or sales) in excess of, or less than, the amount of securities the account intended to trade; (ii) the sale of a security when it should have been purchased; (iii) the purchase of a security when it should have been sold; (iv) the purchase or sale of the wrong security; and (v) the purchase or sale of a security for the wrong account and the post-settlement discovery of such purchase or sale. Trades implemented as a result of faulty data, systems, coding, modeling or analysis, trades that are properly executed but result in losses, errors committed by other persons (including brokers and custodians), or that are otherwise caused by human error other than those specifically described above, are not considered trade errors. The loss of an investment opportunity is not considered a trade error. Such errors may result in losses or gains. Politan will use reasonable efforts to detect such errors prior to settlement and promptly correct them. To the extent that an error is caused by a counterparty, such as a brokerdealer, Politan will use reasonable efforts to recover any losses associated with such error from the counterparty. Clients (and not Politan) will benefit from any gains resulting from trade errors and other errors and will be responsible for any losses (including additional trading costs) resulting from trade errors and other errors, absent bad faith, gross negligence, willful misconduct or actual fraud by Politan or its employees. Politan does not intend to offset any such gains and losses resulting from trade errors and other errors unless the underlying transactions constitute a single transaction or closely related series of transactions. B.

Aggregating Orders for Various Clients

If Politan determines that the purchase or sale of a security is appropriate with regard to multiple clients, Politan will typically, but is not obligated to, purchase or sell such a security on behalf of such clients with an aggregated order, for the purpose of reducing transaction costs, to the extent permitted by applicable law. When an aggregated order is filled through multiple trades at different prices on the same day, each participating client will receive the average price, with transaction costs generally allocated pro rata based on the size of each client’s participation in the order (or allocation in the event of a partial fill) as determined by Politan. In the event of a partial fill, allocations may be modified on a basis that Politan deems to be appropriate, including, for example, in order to avoid odd lots or de minimis allocations. When orders are not aggregated, trades generally will be processed in the order that they are placed with the broker or counterparty selected by Politan. As a result, certain trades in the same security for one client (including a client in which Politan and its personnel may have a direct or indirect interest) may receive more or less favorable prices or terms than another client, and orders placed later may not be filled entirely or

at all, based upon the prevailing market prices at the time of the order or trade. In addition, some opportunities for reduced transaction costs and economies of scale may not be achieved.

Economic Benefits Received from Non-Clients for Providing Services to Clients

Politan currently does not receive any economic benefits from non-clients for providing services to clients. B.

Compensation to Non-Supervised Persons for Client Referrals

Politan does not compensate any third-party for client referrals directly to it for advisory services and does not receive any economic benefit from a third-party for providing investment advice or other services to its clients.

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

Frequency and Nature of Review of Client Accounts

Politan reviews the performance and holdings of clients on an ongoing basis. The Chief Investment Officer has ultimate responsibility for all investment decisions made and conducts such reviews to ensure that portfolio holdings are consistent with each client’s investment objectives and strategy set forth in the Offering Documents and/or applicable investment management agreement. Reviews of client accounts may be triggered by changes in variables such as market, political, or economic circumstances, or a change in a client’s individual circumstances. B.

Factors Prompting Review of Client Accounts Other than Periodic Review

Significant market events affecting the prices of one or more investments in client accounts, among other things, may trigger reviews of client accounts on other than a periodic basis. C.

Contents and Frequency of Account Reports to Fund Clients

Within 120 days after the end of each fiscal year or as soon as practical thereafter, Politan will deliver to each Fund Investor audited financial statements of the Funds for such fiscal year, prepared using GAAP and comprising a balance sheet, income statement and statement of changes in Partners’ capital. Politian will also provide final Schedules K-1 to Fund Investors within 120 days of the last day of each tax year of the Fund or as soon as reasonably practicable thereafter. In addition, Politan provides Fund Investors with performance and other updates on a periodic basis.

Custody Politan is deemed to have custody of client assets with respect to each of the Funds because Politan GP, which is under common control with Politan, serves as general partner of the Funds. Fund assets are maintained by qualified custodians and an independent public accounting firm subject to inspection by the Public Company Accounting Oversight Board will audit the Funds’ financial statements annually. Such audited financial statements are distributed to investors in the Funds within 120 days of the Funds’ fiscal year end.

Investment Discretion Politan provides investment advisory services on a discretionary basis to clients. Any limitations with respect to such investment discretion are set forth in the Offering Documents and the applicable investment management agreement. Unless otherwise instructed or directed by a discretionary client, Politan will have the authority to determine (i) the portfolio investments or the securities to be purchased and sold for the client account (subject to restrictions on its activities set forth in the applicable investment management agreement, any written investment guidelines or the Offering Documents, as the case may be) and (ii) the amount of portfolio investments or securities to be purchased or sold for the client account. Because there may be differences in client investment objectives and strategies, risk tolerances, tax status and other criteria, there may be differences among clients in invested positions and portfolio investments or securities held.

Voting Client Securities Politan has the authority to vote its clients’ securities. As a result, Politan has adopted proxy voting policies and procedures pursuant to and in compliance with the Advisers Act Rule 206(4)-6. The Firm’s general policy is to vote proxy proposals, amendments, consents or resolutions in a prudent and diligent manner that will serve the applicable client’s best interests and in line with each client’s investment objectives. Although Politan may take into account numerous relevant factors, as determined by Politan in its discretion, Politan generally expects to vote proxies in accordance with the recommendations of company management. However, there are many complexities to proxy votes, and Politan will vote against a proposal or recommendation of management if it determines that such a vote is in the best interests of its clients. In addition, Politan has retained Institutional Shareholder Services, an independent third-party proxy voting service (“ISS”), to provide Politan with in-depth research analysis of shareholder meeting agendas and vote recommendations. Politan will process every vote it receives for U.S. and non-U.S. proxies. Certain types of matters that are the subject of a proxy vote may require a more detailed analysis than the analysis required for some routine or uncontested matters. Politan will abstain from voting or affirmatively decide not to vote if it determines, after considering a variety of factors, that abstaining or not voting is in the best interests of Politan’s clients. In effecting Politan’s policy of voting proxies in the best interests of its clients, there may be occasions where the voting of such proxies may present an actual or perceived conflict of interest between Politan and its clients. Some of these potential conflicts of interest situations include, but are not limited to: (i) business relationships; (ii) personal relationships; or (iii) familial relationships. Clients may obtain a copy of Politan’s current written proxy voting policies and procedures and/or information concerning proxy votes on its behalf by contacting Politan at compliance@politanmgmt.com.

Financial Information Politan is not required to include a balance sheet for its most recent fiscal year, is not aware of any financial condition reasonably likely to impair its ability to meet contractual and fiduciary commitments to its clients, nor has it been the subject to any bankruptcy proceeding.