Polychain Capital

As of December 31, 2025, Polychain manages approximately $2,901,320,856 in regulatory assets under management on a fully discretionary basis. Polychain does not manage any of its clients’ assets on a nondiscretionary basis.

ITEM 5:

FEES AND COMPENSATION

Item 5.A. Management Fees With respect to an Investor in Fund I and the Math Prophecy Fund, Polychain Capital and Polychain VC, respectively, will generally receive a monthly management fee on such Investor’s capital account. The management fee is calculated and paid monthly in advance, based on the value of each Investor’s capital account, as of the first day of the month. With respect to an Investor in each of the Dfinity Ecosystem Fund, Polkadot Ecosystem Fund, and Celo Ecosystem Fund, Polychain VC will generally receive a quarterly management fee of the aggregate capital commitments of the Investors during the applicable investment period, as defined in the Fund’s Governing Documents. With respect to an Investor in each of Polychain Ventures Fund and Polychain Ventures II Fund, Polychain VC will generally receive a quarterly management fee as defined in each Fund’s Governing Documents. After such period, the management fee is reduced as provide in the Funds’ Governing Documents. The management fee for each of these Funds is calculated and paid quarterly in advance, as of the first day of the calendar quarter. With respect to an Investor in each of the Opportunities Fund and Opportunities II Fund, Polychain VC will generally receive a quarterly management fee. The management fee is calculated and paid quarterly in advance as of the first day of the calendar quarter. With respect to an Investor in each of Polychain Ventures III Fund and Polychain Ventures IV Fund, Polychain VC II will generally receive a quarterly management fee as defined in the Fund’s Governing Documents. After such period, the management fee is reduced as provided in the Fund’s Governing Documents. The management fee is calculated and paid quarterly in advance, as of the first day of the calendar quarter.

Polychain, in its sole discretion, may elect to reduce, otherwise modify, or waive the management fee with respect to any Investor. Performance-Based Fees Each Fund’s respective General Partner is entitled to receive an allocation, generally annually, equal to a percentage of the net income allocated for the year to each Investor’s account (and each Investor’s interest participating through the applicable feeder fund) as of the end of each calendar year (the “Incentive Allocation”). An Incentive Allocation is also made as to amounts withdrawn, as of the effective time of the withdrawal or redemption by Investors. Incentive Allocations are subject to a “high water mark” under which the General Partner receives an Incentive Allocation only to the extent the net income allocated to an Investor’s capital amount exceeds any net losses previously allocated to it since the date the last Incentive Allocation was assessed (or the original date of contribution if no Incentive Allocation has previously been assessed). Net investment proceeds from portfolio investments available for distribution in Polychain Ventures Fund, Dfinity Ecosystem Fund, Polkadot Ecosystem Fund, Opportunities Fund, Celo Ecosystem Fund, Polychain Ventures II Fund, Polychain Ventures III Fund, Polychain Ventures IV Fund, and Opportunities II Fund will be distributed among the applicable General Partner and the Investors in proportion to their respective capital contributions. The General Partner will receive a portion of amounts distributable to each Investor

(the “Carried Interest”) equal to a percentage of aggregate distributions that are above the Investor’s original capital contribution. As noted above, the Funds from time to time co-invest with, or provide co-investment opportunities to, certain other co-investors, including Investors and other persons, through special purpose vehicles. Polychain, or its affiliates, as applicable, may earn management fees and carried interest with respect to such co-investments. Each Fund’s General Partner or Board of Directors (each, a “Board”), as applicable, in its sole discretion, may elect to reduce, otherwise modify, or waive the Incentive Allocation or Carried Interest with respect to any Investor. It should be noted that any Fund launched by Polychain after the date of this Brochure may have materially different terms than those summarized above and any terms for any existing Fund may be amended from time to time. Item 5.B. Polychain deducts its fees and compensation from the Funds’ accounts by instructing the Funds’ administrator. Fees and compensation from the Funds are collected at the frequency discussed above for the management fee, Incentive Allocation, and Carried Interest, in response to Item 5.A. above. Item 5.C. Below is a general description of the Funds’ expenses and other fees. Investors should refer to the Funds’ relevant Governing Documents for a complete understanding of expenses and fees. The information herein is qualified in its entirety by such documents. Polychain and each General Partner bears its own expenses, including office space and utilities, computer equipment and software (not otherwise paid by the Funds) and secretarial, clerical, employee-related and other personnel, except as assumed by the Funds or except as paid for through the permitted use of commission dollars. Organizational Expenses Each Fund generally will bear the following expenses: formation and organization costs and expenses; the offering and sale of Fund interests and partnership interests in any parallel investment vehicle, including expenses incurred by any placement agent and placement agent fees; and the negotiation, execution, and delivery of the Fund’s partnership agreements, any side letter, any investment management agreement and any related or similar documents, including, without limitation, any related legal and accounting fees and expenses, travel expenses, and filing fees. Expenses of Fund I and Math Prophecy Fund Each of Fund I and the Math Prophecy Fund bears and shall be responsible for its own expenses, including but not limited to, investment-related expenses such as the Fund’s currency exchange fees, hardware and physical vaults for storage of private keys, the Fund’s custodian fees, insurance for the assets of the Fund, interest on margin accounts and other indebtedness, bank service fees, withholding and transfer fees, taxes, systems and technology expenses, third party research tools, corporate licensing fees, legal and auditing expenses, accounting, fund administration, filing fees and expenses (including regulatory filings made in respect of the Fund such as Form PF preparation and filing expenses), outsourced risk management advisory and software, investment-related consultants and travel costs that are research-related, expenses incurred

with respect to the preparation, duplication, and distribution to Investors and prospective Investors of each Fund’s Governing Documents, annual reports and other financial information, marketing and syndication expenses (including those incurred in marketing the Fund’s interests in the European Union), and any other services or service provider expenses (including consultants or other service providers that are affiliates of Polychain) deemed necessary by the applicable General Partner on behalf of the Fund. In addition, Fund I bears and shall be responsible for its allocable share of the costs and expenses of Underlying Funds (defined below) and any special purpose vehicles (including their organizational, offering, and operating costs and expenses) and expenses, including fees payable to Polychain affiliates who provide custody services to Fund I, as well as fees payable to consultants or other service providers that are Polychain affiliates. As discussed below in “Other Fees,” Fund I will receive services from, and participate in transactions or other arrangements with, affiliates of the Investment Manager, which creates conflicts of interest. Expenses of Polychain Ventures Fund, Dfinity Ecosystem Fund, Polkadot Ecosystem Fund, Opportunities Fund, Celo Ecosystem Fund, Polychain Ventures II Fund, Polychain Ventures III Fund, Polychain Ventures IV Fund, and Opportunities II Fund Each of Polychain Ventures Fund, Dfinity Ecosystem Fund, Polkadot Ecosystem Fund, Opportunities Fund, Celo Ecosystem Fund, Polychain Ventures II Fund, Polychain Ventures III Fund, Polychain Ventures IV Fund, and Opportunities II Fund bears and will be responsible for its own expenses, including, but not limited to, investment-related expenses such as costs and expenses related to the sourcing, investigation, due diligence, identification, analysis, pursuit, negotiation, purchase, holding, monitoring, sale, or exchange of any investments and licenses, regardless of whether such investments are subsequently consummated, the Fund’s currency exchange fees, interest on margin accounts and other indebtedness, the Fund’s allocable share of the costs and expenses of special purpose vehicles (including their organizational, offering, and operating costs and expenses), hardware and physical vaults for storage of private keys, insurance for the assets of the Fund, payments pursuant to the Fund’s indemnification obligations, the Fund’s custodial fees (including fees payable to Polychain affiliates who provide custody services), bank service fees, withholding and transfer fees, taxes, systems and technology expenses, third party research tools, corporate licensing fees, legal and auditing expenses, accounting, fund administration, filing fees and expenses (including regulatory filings made in respect of the Fund such as Form PF preparation and filing expenses), outsourced risk management advisory and software, investment-related consultants and travel costs that are research-related (including lodging and other expenses incurred in connection with meeting members of management of existing or prospective portfolio companies), meetings of the Investors of the Fund and similar meetings, if applicable, expenses incurred with respect to the preparation, duplication, and distribution to Investors and prospective Investors of the Fund’s Governing Documents, annual reports and other financial information, any other services or service provider expenses (including consultants or other service providers that are affiliates of Polychain) deemed necessary by the applicable General Partner on behalf of the Fund. As discussed below in “Other Fees,” each of Polychain Ventures Fund, Polkadot Ecosystem Fund, Polychain Ventures II Fund, Polychain Ventures III Fund, and Polychain Ventures IV Fund currently receive or expect in the future to receive services from, and participate in transactions or other arrangements with, affiliates of the Investment Manager, which creates conflicts of interest. Other Fees; Affiliated Service Providers Polychain, Polychain Personnel, or other affiliates may receive transaction, commitment, break-up, advisory, syndication, guarantee, directors, officers, management, and other fees (excluding legal fees) from a portfolio company of Polychain Ventures Fund, Polkadot Ecosystem Fund, Polychain Ventures II Fund, Polychain Ventures III Fund, or Polychain Ventures IV Fund. In the event any of Polychain, Polychain Personnel, or other affiliates, is paid such fees, 100% of the fees will offset the management fees

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Currently, the Investment Manager retains Unit 410, LLC (“Unit 410”) and Coinbase Custody, LLC (“Coinbase Custody”) to provide Staking Services to the Funds, depending on the Fund asset to be staked. Unit 410, formerly Polychain Crypto Laboratory LLC, is a former affiliate of Polychain that was sold to Coinbase Global, Inc. (“Coinbase”) in September 2021. Unit 410 provides certain non-custodial Staking Services to the Funds as a third-party service provider. As part of the transaction, certain Polychain Personnel have a financial interest in the use of either Unit 410 or its affiliates to provide Staking Services to the Funds. As a result, decisions to engage Unit 410 or its affiliates, including Coinbase Custody, on behalf of the Funds are subject to Polychain’s conflict protocols. For further discussion, see the description of the transaction in Item 14.A.

The Funds are a highly speculative investment and are not intended as a complete investment program. The Funds are designed only for sophisticated persons who can bear the economic risk of the loss of their investments in the Funds and who have a limited need for liquidity in their investment. There can be no assurance that the Funds will achieve their investment objective or that substantial losses will not be incurred. Each prospective investor in a Fund should carefully review the applicable Fund’s Governing Documents and the agreements referred to therein prior to deciding to invest in the Fund. Investment Program of Fund I Fund I invests in a diversified portfolio of blockchain assets. The creation of Bitcoin has led to the emergence of a new digital asset class in which scarcity is based on mathematical properties. Through cryptographic verification and a game-theoretic equilibrium, blockchain-based digital assets can be created, issued, and transmitted using software. Fund I invests in digital assets based on the fundamental technological promise of the underlying protocol, with mid- to long-term positions. As blockchain technology expands, Fund I seeks to achieve maximum returns for Investors by constructing a diversified portfolio of these digital assets. Fund I also participates in certain staking activities that produce profits and losses (the “Staking Income”). The Investment Manager delegates Fund assets to the Staking Services

provider, also known as a “validator”, in any of the cryptocurrencies or tokens that are eligible for the Staking Services, where the Investment Manager in its good faith judgment determines that any such investments meet the Fund’s investment criteria and are fit for the Fund’s strategy. Staking Income generated in connection with any received Staking Service is shared between the Fund and the applicable Staking Service provider in accordance with the agreement between the General Partner or Investment Manager and the service provider. A decision to engage in staking Fund I’s assets will be made consistent with Polychain’s policies and procedures regarding staking. Participation in Staking Income may be limited to certain Investors, as described in Fund I’s governing documents. Fund I may also invest in equity securities, including new issues (i.e., IPO allocations), PIPEs, and equity securities of special purpose acquisition companies and digital asset treasury companies, buy or sell options, and engage in opportunistic short sales of digital assets and securities. Fund I may also invest in ICOs (as defined below), Simple Agreements for Future Tokens (“SAFTs”) (as described in more detail below) and other similar agreements, interests in other pooled investment vehicles (“Underlying Funds”), including but not limited to pooled investment vehicles managed by Polychain or its affiliates, subject to certain conditions, and other illiquid investments, and such investments generally would be held as “Side Pocket Investments” until realized, deemed realized, or distributed, or removed from the Side Pocket Investment, in each case in the sole discretion of the Investment Manager, and no withdrawals are allowed with respect to such Side Pocket Investment until such time. Fund I may make investments in Underlying Funds provided that either (i) the Underlying Fund does not charge the Fund any management fees or performance fees/allocations (collectively, “Underlying Fund Fees”) or (ii) if any Underlying Fund Fees are charged to the Fund, the General Partner will cause each Fund I limited partner’s allocable portion of such Underlying Fund Fees to be offset by a commensurate reduction in either or both of the management fees or the incentive allocations payable by such Fund I limited partner. Investment Program of Polychain Ventures Fund Polychain Ventures Fund’s investment objective is to generate long-term capital appreciation through privately-negotiated venture capital investments in early-stage companies (“Portfolio Companies” and each a “Portfolio Company”) that are active in blockchain technology and the digital assets market, including but not limited to businesses focused on cryptocurrencies and other cryptographic tokens. Polychain Ventures Fund may also seek to invest a portion of its assets directly in cryptographic tokens and other blockchain technology, otherwise known as digital assets. In addition, Polychain Ventures Fund may invest some of its assets in other pooled investment vehicles, including but not limited to pooled investment vehicles managed by Polychain or its affiliates. Polychain Ventures Fund also participates in, and is expected to continue to participate in, certain Staking Services and to receive Staking Income. Investment Program of Polychain Ventures II Fund, Polychain Ventures III Fund, and Polychain Ventures IV Fund Each of Polychain Ventures II Fund’s, Polychain Ventures III Fund’s, and Polychain Ventures IV Fund’s investment objective is to generate long-term capital appreciation through privately-negotiated venture capital investments in Portfolio Companies that are active in blockchain technology and the digital assets market, including but not limited to businesses focused on cryptocurrencies and other cryptographic tokens. Polychain Ventures II Fund, Polychain Ventures III Fund, and Polychain Ventures IV Fund may also seek to invest a portion of their assets directly in cryptographic tokens and other blockchain technology, otherwise known as digital assets, including but not limited to investments in DeFi and NFTs (both as defined below), digital art, digital collectibles, decentralized autonomous organizations and their underlying protocol tokens, and any other digital assets that the Investment Manager deems to be complementary to the applicable Fund’s primary investment objective, and to otherwise engage in network participation. In addition, each of Polychain Ventures II Fund, Polychain Ventures III Fund, and Polychain Ventures IV Fund may invest some of its assets in other pooled investment vehicles (i.e., Underlying Funds), including

but not limited to pooled investment vehicles managed by Polychain or its affiliates. Each of Polychain Ventures II Fund, Polychain Ventures III Fund, and Polychain Ventures IV Fund Fund is expected to participate in certain Staking Services and to receive Staking Income. Investment Program of the Dfinity Ecosystem Fund The Dfinity Ecosystem Fund’s investment objective is to generate long-term capital appreciation through investments in Portfolio Companies that are active in Dfinity blockchain technology and the digital assets market in respect of the Dfinity ecosystem, including but not limited to businesses focused on cryptocurrencies and other cryptographic tokens and investments in any of the following, whether readily marketable or not: cryptographic tokens and other blockchain technology, other pooled investment vehicles, securities and other financial instruments of United States and foreign entities, including, without limitation, capital stock; shares of beneficial interest; partnership interests and similar financial instruments, bonds, and notes and debentures (whether subordinated, convertible, or otherwise). The Dfinity Ecosystem Fund will be permitted to invest idle cash, pending investment, usage for expenses or fees, or distribution by the Fund, in liquid securities or digital currencies and digital assets on a short-term basis, or as otherwise specified in the limited partnership agreement. Investment Program of the Polkadot Ecosystem Fund The Polkadot Ecosystem Fund’s investment objective is to generate long-term capital appreciation through investments in Portfolio Companies that are active in the development of blockchain technology related to the Polkadot blockchain protocol and the digital assets market in respect of the Polkadot ecosystem, including but not limited to businesses focused on cryptocurrencies and other cryptographic tokens and investments in any of the following, whether readily marketable or not: cryptographic tokens and other blockchain technology, other pooled investment vehicles, securities and other financial instruments of United States and foreign entities, including, without limitation, capital stock; shares of beneficial interest; partnership interests and similar financial instruments, bonds, and notes and debentures (whether subordinated, convertible, or otherwise). The Polkadot Ecosystem Fund will be permitted to invest idle cash, pending investment, usage for expenses or fees, or distribution by the Fund, in liquid securities or digital currencies and digital assets on a short-term basis, or as otherwise specified in the limited partnership agreement. Investment Program of the Celo Ecosystem Fund The Celo Ecosystem Fund’s investment objective is to generate long-term capital appreciation through investments in Portfolio Companies that are active in the development of blockchain technology related to the Celo blockchain protocol and the digital assets market in respect of the Celo ecosystem, including but not limited to businesses focused on cryptocurrencies and other cryptographic tokens and investments in any of the following, whether readily marketable or not: cryptographic tokens and other blockchain technology, other pooled investment vehicles, securities and other financial instruments of United States and foreign entities, including, without limitation, capital stock; shares of beneficial interest; partnership interests and similar financial instruments, bonds, and notes and debentures (whether subordinated, convertible, or otherwise). The Celo Ecosystem Fund will be permitted to invest idle cash, pending investment, usage for expenses or fees, or distribution by the Fund, in liquid securities or digital currencies and digital assets on a short-term basis, or as otherwise specified in the limited partnership agreement. Investment Program of the Opportunities Fund and the Opportunities II Fund Each of the Opportunities Fund’s and Opportunities II Fund’s investment objective is to generate long-term capital appreciation by investing in privately placed securities of a single Portfolio Company.

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As disclosed in Item 4.B., Polychain’s clients are privately offered pooled investment vehicles. Investors in the Funds generally are accredited investors under Rule 501 of Regulation D of the Securities Act of 1933, as amended, and are either qualified clients under Rule 205-3 of the Investment Advisers Act of 1940, as amended (the “Investment Advisers Act”) or qualified purchasers under Section 2(a)(51) of the Investment Company Act of 1940, as amended (the “Investment Company Act”) so as to comply with the exemption under Section 3(c)(1) or Section 3(c)(7), respectively, of the Investment Company Act. The minimum initial subscription amount required to invest in a Fund ranges from $1,000,000 to $5,000,000, and may be subject to waiver at the discretion of the respective Fund’s General Partner or Board. Additional subscription amounts required to invest in the Funds are detailed within each Fund’s Governing Documents. Polychain’s clients may also include special purpose vehicles which Polychain Ventures Fund, Polychain Ventures II Fund, Polychain Ventures III Fund, or Polychain Ventures IV Fund co-invests in along with Investors and third-party investors. ITEM 8:

METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS

Polychain and its affiliates receive a performance-based fee in the form of an Incentive Allocation or Carried Interest, as discussed in response to Item 5.A. Polychain understands that there exist certain potential conflicts of interest associated with the presence of performance-based fees. Such a fee may create an incentive for the Investment Manager to cause the Funds to make investments that are riskier or more speculative than would be the case if there were no performance fee. Performance-based compensation may vary with respect to the Funds and any special purpose vehicles, which may create an incentive to favor clients that pay higher performance-based compensation in the allocation of investment opportunities. However, Polychain advises each of the Funds in accordance with its investment strategy and any allocation

restrictions set forth in each Fund’s organizational documents so that Investors in the Funds are aware of the applicable investment strategy, restrictions, and risks. Additionally, Polychain has established policies and procedures designed to address potential conflicts of interest relating to the side-by-side management of pooled investment vehicles and special purpose vehicles used for co-investment where the performance-based compensation varies, including the allocation of investments and opportunities. The Investment Manager reviews the portfolio holdings of each client to determine whether any patterns exist which indicate improper allocation, or whether there is any other indication of impropriety. The Investment Manager’s procedures require fair and equitable treatment in light of the relevant circumstances for the allocation of limited opportunities among clients.

Not Applicable. Polychain does not recommend or select other investment advisers for its clients. ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING

Polychain has adopted a Code of Ethics (the “Code”) under Rule 204A-1 under the Investment Advisers Act designed to provide that Polychain employees comply with applicable federal securities laws. The Code addresses, among other things, Polychain’s standard of business conduct, requirements and restrictions relating to personal securities trading, policy regarding political contributions, policy regarding outside business activities, policy regarding gifts and entertainment, and confidentiality. Polychain employees must acknowledge, in writing, to having received and read a copy of the Code and any amendments to the Code, initially upon employment and upon receipt of any such amendments. The Code requires all employees to report personal securities holdings (initially and annually) and certify quarterly personal trading activity. The Code places certain restriction on employees when transacting in the same investments as the Funds. The Code is monitored by Polychain’s Chief Compliance Officer and any exceptions to the Code need prior approval by Polychain’s Chief Compliance Officer. A copy of the Code is available to clients or Investors and prospective clients or Investors upon their individual request. Items 11.B., 11.C., and 11.D. The Investment Manager or its affiliates also manage internal portfolios for the account of the Investment Manager and its affiliates, including Polychain Personnel (collectively, “Proprietary Accounts”) in a similar manner to how the Funds’ assets are managed or in order to evaluate a possible investment strategy. Polychain also seeks to make investments for one or more Funds in which one or more Proprietary Accounts or Polychain Personnel hold investments. Proprietary Accounts and Polychain Personnel may also, at any time, seek to make investments alongside the Funds or investments that Polychain determines are not, at such time, appropriate for the Funds. Such activities give rise to conflicts of interest, including the incentive for the Investment Manager, the General Partners or their affiliates to favor such Proprietary Accounts or Polychain Personnel over Fund accounts, including without limitation, with respect to allocation of investments, time and attention, and the management of and exit from such investments. See Item 4.B. and “Allocations” in Items 8.B. and 8.C. above for additional disclosure regarding allocation among the Funds, as well as between the Funds, on the one hand, and the Proprietary Accounts and Polychain Personnel, on the other hand. Polychain will allocate an investment among the Funds, the General Partners, Polychain Personnel and Proprietary Accounts in accordance with the procedures set forth in Polychain’s Allocation Policy, taking into account factors such as whether a pro rata allocation is appropriate, how much of the investment is available in the aggregate, what the allocation to the Funds would be absent any allocation to the Proprietary Account, and whether such investment is consistent with the Funds’ investment mandate and risk appetite. However, if a conflict should arise as between Polychain’s Allocation Policy and a Fund’s Governing Documents, the Governing Documents will govern. See “Allocations” in Items 8.B. and 8.C. for additional disclosures regarding allocation among the Funds, as well as between the Funds, on the one

hand, and the Investment Manager and its affiliates, Polychain Personnel and Proprietary Accounts on the other hand. From time to time, the Investment Manager may effect “cross” transactions such that certain assets held by one or more Funds managed by the Investment Manager are expected to be transferred to other of the Funds managed by the Investment Manager, including for the purpose of rebalancing the portfolios of such Funds or to allow a Fund that may be ineligible from making a certain investment directly to seek to gain exposure to such investment synthetically by means of an agreement with another Fund. At times, the Investment Manager may enter into “principal transactions” within the meaning of Section 206(3) of the Investment Advisers Act, such that certain assets held by one or more Proprietary Accounts may also be transferred to any of the Funds managed by the Investment Manager. This may happen in the event that an investment or investment strategy tested in a Proprietary Account becomes appropriate and to the benefit of the Funds to invest in or employ. From time to time, the Funds also invest in the same investment as a Proprietary Account, including as a co-investor. Such activities give rise to a conflict of interest for the Investment Manager, the General Partners, or their affiliates to favor making investment decisions for the Funds that would either directly or indirectly benefit the Proprietary Accounts. Such transactions will be conducted in accordance with, and subject to, the Investment Manager’s fiduciary obligations to each of the Funds as well as consistent with the investment objectives of each of the Funds involved in such transactions. Moreover, transactions between the Funds and Proprietary Accounts or that involve the Funds and Proprietary Accounts investing in the same underlying investment will also be subject to Polychain’s policies for handling conflicts of interest. If and to the extent required by applicable law or Polychain’s conflicts policy, the Investment Manager will seek approval for these transactions from the applicable Fund’s Investors (or LPAC), which approval will be deemed to constitute the approval of, and be binding upon, the relevant Funds and all Investors (in the case of LPAC approval). Polychain, as a fiduciary, endeavors to always make decisions in the best interest of its clients if a conflict of interest arises between the Investment Manager’s transactions on behalf of its clients and those of Proprietary Accounts and Polychain Personnel. In order to monitor any conflict of interest, Polychain employees are required to pre-clear certain contemplated transactions in their personal accounts which may present the appearance of impropriety, and must disclose on an initial and annual basis the holdings of all personal accounts, as well as all transactions on a quarterly basis. ITEM 12:

BROKERAGE PRACTICES

Item 12.A.1. The Funds intend to make portfolio investments that will be privately placed, on digital exchanges, or OTC without the use of a broker-dealer. In the event Polychain requires the services of a broker-dealer, Polychain will seek to obtain best execution for all transactions. To inform Polychain’s decisions in placing transactions with digital exchanges or in assessing the quality of an OTC counterparty, Polychain considers the following factors: speed, ability to handle various trades and orders, liquidity, reliability, transaction fees, pricing, customer services, security, and geography, among other criteria. Polychain does not currently engage in the use of soft dollars. Item 12.A.2. Polychain does not participate in selecting or recommending broker-dealers in exchange for client referrals.

Item 12.A.3. Not Applicable. Polychain does not engage in directed brokerage by its clients.

Polychain may face actual or potential conflicts of interest when allocating investment opportunities among the Funds. The general policy of Polychain is to allocate investment opportunities among the applicable Funds in a fair and equitable manner and in accordance with its Allocation Policy and the applicable Governing Documents for such Funds. See Items 4.B., 8.B. and 8.C. for additional disclosures regarding investment allocations among the Funds, as well as between the Funds, on the one hand, and the Investment Manager, its affiliates, Polychain Personnel and Proprietary Accounts, on the other hand. ITEM 13:

REVIEW OF ACCOUNTS

Items 13.A. and 13.B. Client holdings are reviewed on a regular basis to determine their conformity with their risk parameters, investment objectives, and guidelines. Polychain regularly monitors the portfolio investments of the Funds. Polychain’s investment personnel periodically convene to evaluate each position’s conformance with the relevant Fund’s Governing Documents, including the offering memorandum and any investment limitations, restrictions, or risk parameters.

Polychain does not currently maintain any referral arrangements with individuals or entities that may be compensated, directly or indirectly, for referrals. However, Polychain may establish referral or placement arrangements in the future.

There are no material legal or disciplinary events related to the Investment Manager. ITEM 10:

OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS

Item 10.A. and Item 10.B. Not Applicable. Polychain and its management persons are not registered and do not have any application pending to register as a broker-dealer, a registered representative of a broker-dealer, a futures commission merchant, a commodity pool operator, a commodity trading advisor, or an associate of the foregoing entities. Item 10.C. As noted in Item 4, Polychain is an affiliate of, and under common control with, affiliated entities that serve as general partners to the Funds. Polychain’s affiliate, Polychain Consulting, currently provides services, such as Consulting Services, to portfolio companies, projects and protocols that a Fund has invested in. This relationship creates conflicts of interest, as described in Item 5.C. with respect to Consulting Services, where Polychain Consulting directly or indirectly benefits by a Fund’s engagement to provide such services or by the Fund’s

investments in companies or projects that receive Consulting Services from Polychain Consulting. These arrangements are subject to conflicts management protocols.

Investors in the Funds will each receive written unaudited reports of the performance of the Fund in which they are an investor on a monthly or quarterly basis, as applicable, and written audited year-end financial statements prepared using U.S. generally accepted accounting principles on an annual basis within 120 days after the fiscal year end of such Fund or as soon thereafter as reasonably practicable. ITEM 14:

CLIENT REFERRALS AND OTHER COMPENSATION

Item 14.A. Under the transaction agreement for the sale of Unit 410 by Polychain’s principals to Coinbase, a portion of the purchase price paid by the buyer is contingent on Unit 410 or its affiliate, including Coinbase Custody, continuing to provide specified levels of Staking Services to the Funds consistent with past practice. Certain members of Polychain’s senior management team, including Polychain’s principal owner Olaf Carlson-Wee, were prior shareholders of Unit 410 and will receive a portion of that purchase price. As a result, Polychain has an incentive to recommend staking activities to the Funds and, specifically, to delegate Fund assets to Unit 410 and/or its affiliate for Staking Services, rather than third party service providers. As such, conflicts of interest arise when Polychain considers whether to recommend a Fund partake in staking activities and the selection of Staking Service providers. As a result, decisions to engage Unit 410 or Coinbase Custody on behalf of the Funds are subject to Polychain’s conflict protocols. Further, any decision to engage in staking is made consistent with Polychain’s policies and procedures regarding staking and if in the best interest of the Fund. Polychain and members of its senior management team do not otherwise receive a direct economic benefit from any third party for providing investment advice or other advisory services to any of the Funds.

Polychain seeks to maintain each Fund’s assets with a qualified custodian in an account in the name of the respective Fund or in accounts that contain only assets owned by the Fund, under Polychain’s name as agent or trustee for the Fund. Polychain custodies certain digital assets internally as well as with third party wallet providers. Although Polychain is not a qualified custodian under the meaning of Rule 206(4)-2 under the Investment Advisers Act, Polychain has developed policies and procedures for safekeeping of digital assets that it self-custodies that it believes are consistent with the objectives of the Investment Advisers Act’s custody provisions. Where assets are held in self-custody, Polychain currently safekeeps the Fund assets using sophisticated wallet technologies and may in the future engage an affiliate to provide custodial services, as described in Item 5.C. In addition, digital assets are held at exchanges, which take various measures to safeguard the digital assets held by such exchanges. Polychain conducts due diligence on all service providers (including Affiliate Service Providers), exchanges, or qualified custodians prior to utilizing their services. See the “Custody of Fund Assets” discussion in Item 8 for risks related to custody of digital assets. The nature of custodial arrangements, and associated risks, are also described in the Governing Documents for the relevant Funds. Where Polychain seeks to stake a Fund’s assets, it will generally delegate assets to be staked to the provider of the Staking Services. Depending on the features of the underlying digital asset network, the Staking Services provider may or may not be deemed to have custody over Fund assets that are staked (or are preparing to be staked). In general, if the Investment Manager determines that no available qualified custodians can provide appropriately secure custody arrangements with robust functionality for exercising governance rights for one or more Fund assets that are staked or if Staking Services are not provided by a qualified custodian for the relevant Fund asset, the Investment Manager expects to custody the relevant Fund assets itself using sophisticated wallet technologies and to engage Unit 410 to provide Staking Services. See the description of conflicts of interest in relation to the use of Unit 410 for Staking Services provided in Item 14.A. In the future, the Investment Manager may engage an Affiliate Service Provider to provide Staking Services and that entity could have custody of Fund assets. In these circumstances, Polychain applies its procedures regarding self-custody and a conflicts management protocol that requires a determination that using Unit 410 or an affiliate is in the best interest of the Fund without taking into account the benefits to the Investment Manager. All material facts associated with such arrangements, including the conflicts of interest and any fees paid by the Funds, are disclosed to the Funds and Investors. The Funds will be subject to an annual audit by an independent public accountant registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board (“PCAOB”) and audited financial statements of each Fund will be prepared in accordance with generally accepted accounting principles and distributed to investors within 120 days of the end of each Fund’s fiscal year or as soon thereafter as reasonably practicable. Investors should carefully review the audited financial statements of the Funds upon receipt, and should compare these statements to any account information provided by Polychain. Additionally, although Polychain is not a qualified custodian under the meaning of Rule 206(4)-2 under the Investment Advisers Act, Polychain has developed policies and procedures for digital assets that it self-custodies that it believes are consistent with the objectives of the Investment Advisers Act’s custody

provisions, including providing quarterly account statements to Investors and distributing annual audited financial statements of the Funds. Investors should carefully review their account statements upon receipt, and should compare these statements to any account information provided by Polychain. Certain assets of the Funds may be exempt from the requirement to be held by a qualified custodian where: (1) the assets are acquired from the issuer in a transaction or chain of transactions not involving any public offering; (2) the assets are uncertificated, and ownership thereof is recorded only on the books of the issuer in the name of the client; and (3) the assets are transferable only with prior consent of the issuer or holders of the outstanding securities of the issuer.

Polychain accepts discretionary authority to manage securities accounts on behalf of clients and therefore, determines which securities and the amounts of securities it buys and sells for the clients. This authority has been granted to Polychain by means of the execution of the relevant organizational and/or advisory agreements that set forth the scope of the Investment Manager’s discretion with respect to each of the Funds. ITEM 17:

VOTING CLIENT SECURITIES

Item 17.A. Polychain generally has proxy voting authority with respect to securities held by the Funds due to the fact that it has discretionary authority over the securities held in the Funds. Accordingly, Polychain has adopted proxy voting policies and procedures to vote proxy proposals, amendments, consents, or resolutions (collectively, “proxies”) relating to the Funds’ investments. The Funds, Investors, or other clients generally cannot direct the proxy voting of Polychain. Polychain understands its fiduciary responsibility to monitor corporate events and to vote proxies and cast votes in the best economic interests of its Funds and their Investors, and not to put these interests second to its own economic interests. Each proxy is voted on a case‐ by‐case basis taking into consideration any relevant facts and circumstances at the time of the vote. Conflicts may arise between the interests of the Funds and their Investors versus the interests of Polychain and its affiliates. In such cases, the Investment Manager will address each such conflict, and endeavor to resolve it in a fair and equitable basis. Notwithstanding the foregoing, because proxy proposals and individual company facts and circumstances may vary, Polychain may not always vote proxies in accordance with the proxy voting policy. In addition, many possible proxy matters are not covered in such policy. Investors may request a copy of the proxy voting policies and procedures and the proxy voting records by contacting the Investment Manager at the address, email or telephone number listed on the cover page of this Brochure.

Not Applicable; see response to Item 17.A. Polychain has authority to vote client securities.

ITEM 18:

FINANCIAL INFORMATION

Item 18.A. Not Applicable. Polychain does not require nor solicit pre-payment of more than $1,200 in fees per client, six months or more in advance. Item 18.B. Polychain is not aware of any financial condition that is reasonably likely to impact its ability to meet its contractual commitments to clients.

Not Applicable. Polychain has not been the subject of a bankruptcy petition at any time during the past ten years.