Quantinno Capital Management LP

Quantinno Capital Management LP ( “Adviser”) is an investment adviser with its principal place of business in New York, New York. The general partner of the Adviser is Quantinno Capital LLC. Quantinno is principally owned by Hoon Kim who is accompanied by the following partners: Todd Saunders, Glenn Shirley, Albert Kim, Paul Giordano, Sinan Kabak, and Charles Bulinski. Hoon Kim is the managing member of the General Partner of the Adviser. The Adviser commenced operations as an investment adviser on October 1, 2018. The Adviser provides discretionary investment advisory services to separately managed accounts (each an “SMA” or “Managed Account”) and a private fund (the private fund, with each SMA/Managed Account, a “Client” and, collectively, “Clients”). Separately Managed Accounts The Adviser builds customized Managed Accounts using quantitative models that incorporate an SMA Client’s account-specific investment guidelines and restrictions. A common way for qualified individuals to access the Adviser’s SMA services is through a registered investment advisor (“RIA”) who has engaged the Adviser as a sub-adviser for its clients. In such circumstances, the Adviser generally relies on the RIA to deliver the Adviser’s Form ADV Part 2A, Form ADV Part 2B, and Form ADV Part 3 to the RIA’s clients with Managed Accounts, and to disclose conflicts of interests the RIA believes exist arising from its relationship with the Adviser. Certain sophisticated individuals advised by an RIA or investment consultant (each an “Intermediary”) may enter into an investment management agreement directly with the Adviser for a Managed Account. In such circumstances the Adviser generally relies on the Intermediary to disclose conflicts of interest the RIA believes exist arising from its relationship with the Adviser. Additionally, the Adviser manages certain SMA Client accounts in which an Intermediary provides target account exposures to the Adviser, and the Adviser periodically rebalances those SMA Client accounts in accordance with such Intermediary’s target exposures for the given SMA Client account. All SMA Client accounts are subject to a written advisory agreement that sets the conditions of the relationship between the Adviser and any such SMA Client account. The advisory agreement describes the advisory services that the Adviser will provide, the Adviser’s duties, the Adviser’s compensation, and various other terms and conditions of the engagement. Private Fund The Adviser provides advice to the Quantinno Fundamental Arbitrage Fund LP, a Delaware limited partnership (the “Fund”). Quantinno Capital GP III LLC is the general partner of the Fund. The Adviser’s advice to the Fund is based on specific investment objectives and strategies described in the Fund’s offering memorandum. The Adviser will not tailor advisory services to the individual needs of Fund investors and Fund investors may not impose restrictions on investing in certain securities and other financial instruments or certain types of securities and other financial instruments. The Fund may enter into agreements, or “side letters,” with certain prospective or existing Fund investors whereby such Fund investors, including such persons that may be affiliated with the Adviser or its related persons, may be subject to terms and conditions that are more advantageous than those set forth in the offering memorandum for the Fund. Wrap Fee Programs From time to time, the Adviser may provide investment management services as a sub-adviser to SMA

Client accounts that participate in wrap fee programs sponsored by third-party investment advisers or broker-dealers. In these arrangements, the sponsor typically charges its client a single fee intended to cover investment management services and certain brokerage or custodial services. The Adviser does not sponsor or manage any wrap fee programs and does not prepare a wrap fee program brochure. The Adviser’s role in these arrangements is generally limited to providing discretionary portfolio management services pursuant to a sub-advisory agreement with the program sponsor. The Adviser’s investment decisions and advice to the Fund and the SMAs are subject to, and informed by, each such Client’s investment objectives and guidelines, as set forth in the Fund’s offering documents, and the SMAs’ written advisory agreements and corresponding selections made in the Adviser’s client portal on behalf of each SMA Client account (collectively, the “Investment Material”). Regulatory Assets Under Management As of December 31, 2025, the Adviser has regulatory assets under management of $60,907,900,000, all managed on a discretionary basis.

Advisory Fees for Separately Managed Accounts The Adviser provides discretionary investment management services to separately managed accounts for a fee based on assets under management. The Adviser’s standard management fee rate for Managed Accounts generally begins at 0.45% annually of assets under management. Actual management fees may vary and are negotiable depending on a number of factors, including the applicable investment mandate, the amount of leverage (if any) used to implement the long/short extensions in an SMA Client account, the services performed, the level of SMA Client account customization, and the overall size of the SMA Client account or the relationship with an SMA Client’s RIA. Fees are negotiable at the sole discretion of the Adviser. A minimum annual fee or minimum SMA Client account size may be applied in certain cases. Because management fees are negotiated and may vary based on the circumstances of each SMA Client relationship, SMA Clients receiving similar advisory services may pay different fees. Management fees paid by SMA Clients are typically calculated as a percentage of assets under management. Management fees are generally billed quarterly in advance, based on the closing value of an SMA Client account on the first business day of the new quarter. Generally, SMA Clients cause the SMA Client account custodians to pay the Adviser’s management fee directly from the SMA Client account. SMA Clients should review their custodial account statements to verify the accuracy of fee deductions. In certain cases, the Adviser may provide services as a sub-adviser to Client accounts managed by another investment adviser. In such arrangements, the Client may pay a single advisory fee to the Intermediary, and the Adviser may receive a portion of that fee pursuant to a sub-advisory agreement. The Adviser does not charge performance-based fees in Managed Accounts. Fund Management Fees and Incentive Fees The fee schedule for the Fund is described in detail in the Fund’s Investment Material. All investors in the Fund are “qualified purchasers” as defined in Section 2(a)(51) of the Investment Company Act of 1940, as amended (the “Investment Company Act”) or “knowledgeable employees” as defined in Rule 3c-5 under the Investment Company Act. The Fund will pay the Adviser an asset-based management fee each quarter in advance based on the value of each Investor’s capital account in the Fund on the first business day of each quarter and adjusted for subscriptions to, or withdrawals from, the Fund during each quarter (the "Fund Management Fee"). The Adviser may elect to reduce, waive, or calculate differently the Fund Management Fee with respect to any Fund investor, including without limitation, members, principals, employees, or affiliates of the Adviser or the Fund’s general partner, an affiliate of the Adviser, relatives of such persons, and for certain large or strategic investors. The Fund will be required to pay the Fund Management Fee in advance. In the event of a withdrawal from the Fund by an investor other than at the end of a quarter, the corresponding Fund Management Fee will be pro-rated and the excess returned to the withdrawing Fund investor. As a general matter, the Adviser will be entitled to receive annual performance-based compensation (the “Incentive Fee”) from the Fund, which is compensation that is based on a share of net profits, if any, expensed from each Fund investor’s capital account. The Incentive Fee is subject to a loss carryforward provision. The Fund’s general partner may, in its sole discretion, elect to reduce, waive, or calculate differently the Incentive Fee with respect to any Fund investor, including without limitation members, principals, employees, or affiliates of the Adviser or the General Partner, relatives of such persons, and for certain large or strategic investors. Additional information regarding performance-based fees and related conflicts of interest is provided in Item 6 – Performance-Based Fees and Side-by-Side Management.

The Fund Management Fee and any Incentive Fee will be deducted from a Fund investor’s capital account by the Fund’s administrator pursuant to instructions from the Adviser. Fund investors will not have the ability to choose to be billed directly for fees incurred. Expenses Separately Managed Accounts SMA Client accounts may incur certain fees and expenses in addition to the advisory fees charged by the Adviser. These fees and expenses are generally charged directly by the applicable service provider and are separate from, and in addition to, the advisory fees charged by the Adviser. These fees and expenses may include, but are not limited to: • • •

brokerage commissions and other transaction costs associated with the execution of trades. custodial fees and charges imposed by the Client account custodian. margin interest or other financing costs associated with leveraged positions.

Financing costs, margin interest, or securities borrowing fees borne by SMA Client accounts may vary significantly depending on market conditions and, in the case of securities borrowing fees, the availability of securities for borrowing. SMA Clients should review all fee disclosures provided by the custodian or other service providers to understand the total costs associated with their Managed Accounts. The Fund The Adviser is responsible for and pays all overhead expenses of an ordinary and recurring nature such as rent, supplies, secretarial expenses, its compliance expenses, stationery, charges for furniture and fixtures, employee insurance, payroll taxes and compensation of employees. In addition to bearing the Fund Management Fee and Incentive Fee, if any, Fund investors may also be subject to other expenses related to Fund investments and operations, such as legal, accounting (including third party accounting services), administration, audit, and other professional fees and expenses; organizational expenses; research fees and expenses (including Bloomberg and similar subscriptions and data services); expenses incurred in respect of statistical and pricing services or software; portfolio valuation expenses (including data feeds and third-party valuation agents); investment expenses such as commissions, interest on margin accounts, and other indebtedness; borrowing charges on securities sold short; insurance costs (including D&O and E&O insurance); compliance expenses of the Fund including expenses related to various filings (or portions thereof) that the Adviser is required to make as a result of managing the Fund, such as Section 13 and Section 16 Filings, Form PF, and fees and expenses relative to registration, filing and/or reporting requirements in any jurisdiction in which Fund interests are offered or sold, custodial fees, bank service fees, and other expenses related to the purchase, sale, preservation or transmittal of Fund assets. The allocation of expenses by the Adviser between it and the Fund represents a conflict of interest for the Adviser. The Adviser will adopt an expense allocation policy that is designed to address this conflict. The Adviser will allocate expenses to the Fund in accordance with the Fund’s Investment Material. The Adviser will seek to allocate any shared expenses for products and services benefitting more than one Client (including, for the avoidance of doubt, the Fund), or both the Adviser and a Client (including, for the avoidance of doubt, the Fund), and any expenses not covered in a Client’s Investment Material, in a fair and reasonable manner, and in accordance with the Adviser expense allocation policy. More detailed information regarding the fees and expenses paid by the Fund may be found in the Fund’s Investment Material.

Methods of Analysis and Investment Strategies Investment Objective and Strategy The Adviser seeks to achieve positive total returns and/or outperform a benchmark by developing and implementing systematic investment processes that utilize quantitative return forecasting models, systematic risk controls, and tax-aware portfolio optimization techniques to construct portfolios consisting primarily of long and short positions in equity securities and related instruments. The Adviser’s strategies generally invest in publicly traded equities and equity-related instruments traded on exchanges located in the United States. Depending on the mandate, the investment universe may include common stocks, exchange-traded funds, fixed-income instruments, options, and/or derivative instruments used to obtain or manage market exposures or facilitate efficient portfolio management. The Adviser’s strategies are generally implemented using a systematic investment process designed to evaluate a broad universe of securities and identify opportunities to take long positions in securities expected to outperform, and short positions in securities expected to underperform and/or reduce tracking error to a benchmark. These assessments are generated through quantitative models that analyze a range of financial, market, and statistical inputs. In addition, the Adviser may employ leverage in connection with its strategies, including through borrowing, short selling, or the use of derivative instruments. Variations of Tax-Aware Investment Strategies The Adviser manages a range of tax-aware equity strategies that will vary depending on a Client’s investment objectives, tax sensitivity, benchmark requirements, leverage parameters, investment guidelines, and/or other portfolio constraints. Certain Client accounts may emphasize maintaining exposures relative to a benchmark or other risk targets, while other Client accounts may prioritize taxefficiency objectives such as harvesting capital losses or deferring the realization of gains. Client accounts may also differ based on account-specific characteristics, including account size, tax status, legacy holdings, Client-imposed investment restrictions, and the degree of customization requested by the Client or its Intermediary. Portfolio Construction Process The Adviser’s investment process generally involves several stages. First, quantitative models are used to evaluate a broad universe of securities and generate forecasts of expected returns based on a variety of statistical and market-based factors. These models incorporate historical market data, company fundamentals, price and trading information, and other quantitative inputs. Second, these return forecasts are incorporated into a portfolio construction framework that seeks to determine an appropriate combination of long and short positions for each Client account. Portfolio construction typically involves the use of optimization techniques designed to balance expected returns with a range of other considerations, including diversification, risk exposures, financing costs, transaction

costs, Client-imposed constraints, and tax considerations. In most cases, the Adviser actively considers the tax consequences of trading decisions in the management of Client accounts. For example, the Adviser may seek to defer the realization of capital gains while accelerating the realization of capital losses where appropriate. Portfolio optimization components of Client account optimizations are evaluated holistically within the Adviser’s systematic portfolio construction process. Tax-Aware Portfolio Implementation In implementing tax-aware strategies, the Adviser will consider the interaction of long positions, short positions, and/or derivative exposures when evaluating potential tax consequences and portfolio optimization decisions. The Adviser will also consider the expected tax impact of trades when determining position sizes, holding periods, or the timing of portfolio adjustments. Accordingly, a Client account may hold positions for longer or shorter periods than it otherwise would if tax considerations were not taken into consideration. In addition, the Adviser may substitute one security for another to maintain similar investment exposure while attempting to manage potential tax consequences. Because portfolio construction incorporates several considerations — including investment forecasts, diversification, risk management, transaction costs, financing costs, and tax considerations — the Adviser’s portfolio optimization process seeks to balance these factors prior to trading a Client account. There can be no assurance that tax optimization objectives will be achieved or that sufficient capital losses will be available for realization in any given period. Risk Management Risk control is built into the Adviser’s investment models and processes, including monitoring of volatility levels, correlation structure, extreme events, liquidity, funding and counterparty credit considerations. The Adviser utilizes systematic procedures for drawdown control and market factor exposure management where these measures are deemed appropriate in the Adviser’s sole discretion. Monitoring and managing transaction costs is an integral part of the Adviser’s investment process. Transaction costs include commissions, bid-ask spreads, market impact and pre-trade costs (i.e., the timing difference between the investment decision and the trade implementation). A consideration of transaction cost is a part of the integrated portfolio construction algorithm. Ex-post transaction cost is actively monitored to enhance quality of execution and to re-estimate ex-ante trading costs of the portfolio construction process. Material Risks Relating to Investment Strategies The following summary identifies the material risks related to the Adviser’s investment strategies and should be carefully evaluated before making an investment with the Adviser. However, the following is not intended to identify all possible risks of an investment with the Adviser or provide a full description of the identified risks. Prospective clients and investors should consult their own legal, tax, and financial advisers about the risks related to a Managed Account or an investment in the Fund. A Managed Account or investment in the Fund may be deemed to be highly speculative and is not intended as a complete investment program. It is designed only for sophisticated individuals who are able to bear the economic risk of the loss of their entire investment and who have a limited need for liquidity in such investment. Prospective SMA Clients and Fund investors should refer to the relevant Investment Material for a complete understanding of the Adviser’s investment strategies and methods of analysis. The information contained herein is a summary only and is qualified in its entirety by such documents.

Quantitative and Systemic Strategy Risk The Adviser’s investment strategies rely heavily on quantitative models, systematic trading processes and automated trading systems. These strategies involve certain risks, including those described below. Market Neutral Risk The types of trading risks incurred by market-neutral strategies generally relate to either spreads or price differentials between related securities and/or their derivatives, or the volatility of security prices or spreads or the level of market liquidity. At times of heightened systemic market risk these market neutral risks tend to increase which may lead to underperformance of a market neutral portfolio. In addition, other risks common to such a portfolio may include credit spread risk and credit default risk. The market for credit spreads is often inefficient and illiquid, making it difficult to accurately calculate discounting spreads for valuing financial instruments. Algorithmic Trading; Systems Risk The likelihood of an investment strategy achieving its investment objectives is dependent, in part, on the expertise of the Adviser combined with the efficacy and availability of the software and automated trading systems utilized by the Adviser in managing Client account assets. The Adviser’s investment strategies involve active trading through the use of automated trading systems. Such active trading presents the risk of large, immediate losses. Automated trading systems, no matter how convenient or efficient, do not reduce risks associated with active trading. There can be no guarantee that the software and automated trading systems will achieve their intended objectives. As with all facilities and systems, the Adviser's trading systems, hardware, and software (as well as those of its and the Clients’ service providers) are vulnerable to temporary disruption, failure, inaccuracies, and/or security breaches, including, but not limited to: communication failures or inaccuracies; security quotation and data errors (whether as a result of software errors, automatic price or data misfeeds, or a dealer's mistype or mistake); system or software crashes; distortions; viruses; stolen passwords and/or unauthorized trades; signal power disruptions; and failures of Internet reception or routing. In addition, certain of the Adviser’s operations interface with, or depend on, systems operated by third parties and the Adviser may not be in a position to verify the risks or reliability of such third- party systems. System delays or failures can have negative results on investment selection and execution. The consequences of a system-related failure include, but are not be limited to: trades being executed without the Adviser's authorization, trades not being executed according to the Adviser's instructions or criteria, or failure to execute trades. Any such failure could have a significant negative effects on Client accounts. For example, such failures could cause settlement of trades to fail, lead to inaccurate accounting, reporting, or processing of trades, and/or cause inaccurate reporting, any of which may impede a Client’s ability to monitor the risks associated with its account. A Client account’s ability to recover certain losses or foregone profits due to such disruptions and failures may be subject to limits on liability imposed by system providers, the market, financial institutions, and/or the clearing house. In the absence of recovery, a Client account will typically bear the risks and losses of any system delays or failures, including, but not limited to, the system delays or failures described herein. Quantitative Model and Data Dependency Risk The Adviser’s investment strategies rely heavily on quantitative models, statistical techniques, and proprietary algorithms to evaluate securities, construct portfolios, and manage risk. These models depend on a variety of inputs, including historical market data, financial information, economic indicators, and other datasets obtained from internal and external sources. There can be no assurance that the data used by the Adviser’s models will be accurate, complete, or free

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The Adviser’s SMA Clients and Fund investors are high net-worth individuals, financially sophisticated individuals, and other sophisticated investors, institutions, and endowments. The minimum initial investment in the Fund is $1 million. However, the Fund’s general partner may, in its sole discretion, accept lower initial investments. Minimum investment amounts for Managed Accounts are negotiable.

The Adviser currently provides discretionary investment management services to Managed Accounts and to the Fund. The Adviser does not charge performance-based fees in Managed Accounts. However, the Adviser receives performance-based compensation in connection with the management of the Fund. Performance-based compensation may create an incentive for an investment adviser to favor accounts that pay such fees over accounts that do not, including by allocating investment opportunities differently or by taking greater investment risks in performance-fee accounts. These incentives may create potential conflicts of interest when an investment adviser manages accounts that pay performance-based fees alongside accounts that do not. At present, the asset classes traded by the Fund differ from those traded in SMA Client accounts. As a result, the Fund and SMA Client accounts generally do not participate in the same investment opportunities or trade the same asset classes. Accordingly, the Adviser does not currently expect material conflicts to arise between the Fund and SMA Client accounts with respect to the allocation of investment opportunities. Although the Adviser does not currently expect material conflicts to arise between the Fund and SMA Client accounts with respect to the allocation of investment opportunities, the Adviser’s investment strategies may evolve over time. If, in the future, the Fund (or another commingled fund managed by the Adviser) and one or more separately managed accounts were to pursue similar or overlapping investment strategies or trade the same asset classes or instruments, potential conflicts of interest could arise in connection with the allocation of investment opportunities, trade execution, or portfolio management decisions. In such circumstances, the Adviser would seek to address these potential conflicts through its policies and procedures governing trade allocation and portfolio management practices designed to ensure that Client accounts are treated fairly and equitably over time. There can be no assurance that the investment performance of any SMA Client account will be identical or that investment opportunities will be allocated in a manner that results in the same performance across SMA Client accounts.

Neither the Adviser nor the Adviser’s management personnel are registered as broker-dealers or have any application pending to register with the SEC as a broker-dealer or registered representative of a brokerdealer, respectively. Neither the Adviser nor any of the Adviser’s management personnel have any relationships or arrangements that pose material conflicts of interest to the business of the Adviser. Quantinno Capital GP III LLC serves as general partner to the Fund. While the Fund may trade commodity interests, the Adviser (and its affiliates) are exempt from registration with the Commodity Futures Trading Commission (the “CFTC”) as a commodity pool operator pursuant to CFTC Rule 4.13(a)(3).

Code of Ethics Pursuant to Rule 204A-1 of the Advisers Act, the Adviser had adopted a Code of Ethics (the “COE”) that obligates the Adviser and its Supervised Persons (as defined within the COE) to put the interests of Clients before the Adviser’s own interests, and to act honestly and fairly in all respects in the Adviser’s dealings with Clients. The COE includes provisions regarding general standards of conduct, as well as several specific issues including compliance with federal securities laws, personal trading of securities, private investments by employees, employee outside business activities, and gifts and entertainment. Each of the Adviser’s partners employees must acknowledge their understanding of, and agree to comply with, the COE upon employment and affirm annually that such partner or employee has read and understands the COE and has complied with it. In addition to compliance with the Adviser’s policies and procedures, the Adviser’s personnel are required to comply with applicable federal securities laws. The Adviser will provide a copy of the COE to Clients, Fund investors, or prospective clients or Fund investors upon request. See below for further provisions of the COE as they relate to securities transactions by the Adviser’s Supervised Persons. Material Non-Public Information While it is not expected to do so, if the Adviser comes into possession of confidential or material nonpublic information about issuers, including issuers in which the Adviser or its related persons have invested or seek to invest on behalf of a Client account, the Adviser will be prohibited from improperly disclosing or using such information for its own benefit or for the benefit of a Client account. The Adviser will maintain

and enforce written policies and procedures that prohibit the communication of such information to persons who do not have a legitimate need to know such information and to assure that the Adviser is in compliance with its internal policies and procedures and applicable law. Personal Trading The Adviser will require its Supervised Persons to obtain prior written approval of the Chief Compliance Officer (or its delegate) before engaging in any transaction in a Reportable Security in his or her Personal Account (as those terms are defined within the COE). The Adviser’s Supervised Persons will be required to disclose their securities transactions on a quarterly basis by providing transaction reports or duplicate copies of brokerage statements to the Chief Compliance Officer. In addition, the Adviser’s Supervised Persons will be required to disclose the holdings in their personal accounts upon commencement of employment with the Adviser and re-affirm disclosures on an annual basis thereafter. Supervised Persons may not acquire any direct or indirect beneficial ownership in any securities in any initial public offering without prior written approval of the Chief Compliance Officer. Further, Supervised Persons may not purchase or sell any security that appears on the Adviser’s Restricted List without prior approval from the Chief Compliance Officer. Trading in personal accounts of the Adviser’s Supervised Persons will be reviewed by the Chief Compliance Officer and cross-referenced against the Restricted List. Outside Business Activities The Adviser requires Supervised Persons to obtain written approval from the Chief Compliance Officer prior to engaging in any outside business activities, and to submit initial and quarterly certifications regarding participation in any such activities. Participation or Interest in Client Transactions The Adviser does not expect to effect transactions between Client accounts whereby one Client account will purchase securities from, or sell securities to, another Client account. In the event that the Adviser effects a cross trade between an account in which the Adviser or its affiliates owns more than twenty-five percent (25%) and another Client account, such transaction may be deemed to be a principal transaction under the Advisers Act. Such transactions may create a conflict of interest for the Adviser because it may put its or its affiliates’ interests in such accounts before the interests of a Client account. In order to mitigate this conflict of interest, the Adviser will not affect any cross trades between Client accounts if it believes that such trade would result in a principal transaction, unless the Adviser: 1. believes that such transaction is in the best interest of the Client accounts participating in the transaction; and 2. obtains the consent of the applicable Client, as required by the Advisers Act. No such transactions may be affected when the Adviser, or any person controlling, controlled by, or under common control with the Adviser, recommended the transaction to both the seller and the purchaser. The Chief Compliance Officer will be responsible for reviewing all cross trades for compliance with applicable procedures. Investments Not Suitable for Clients From time to time, the Adviser may become aware of certain investment opportunities in which one or more Client accounts may not be given an opportunity to participate (e.g., for investments that are deemed not suitable for one or more Client accounts).The Adviser may, however, offer such opportunities just to certain Client accounts, its employees and affiliates, or third parties, and therefore it is anticipated that not every Client account will be given an opportunity to participate in such investments.

Brokerage Selection and Best Execution The Adviser has a duty to seek best execution for Client account transactions. In seeking best execution, the Adviser endeavors to execute securities transactions for Client accounts in a manner that it believes will maximize the overall value of the transaction for the Client account under the particular circumstances. Best execution does not necessarily mean obtaining the lowest possible commission cost, but rather obtaining the most favorable overall result for the Client account considering a variety of factors including a broker-dealer’s execution capability, commission rates, financial stability, responsiveness, trading expertise, research services, and other factors relevant to the particular transaction. Execution Through Custodian SMA Client account assets are held at a designated custodian selected by the Client or the Client’s primary financial adviser. In general, the Adviser executes securities transactions for SMA Client accounts through the account’s custodian, the custodian’s affiliated broker-dealer, or other broker-dealers made available through the custodian’s trading platform. The Adviser generally does not execute transactions for such accounts away from the custodian because doing so may result in significantly higher transaction costs, including ticket charges or other fees assessed by the custodian for trades executed through other brokerdealers. Accordingly, the Adviser determined that executing trades through the Client account custodian or its available trading platform is generally consistent with seeking best execution for those accounts, considering the total cost and efficiency of the transaction. However, the practice of executing transactions through the custodian may limit the Adviser’s ability to access other broker-dealers that might otherwise provide more favorable execution in particular circumstances. Clients should understand that the Adviser’s ability to negotiate commission rates or obtain execution services from other broker-dealers may therefore be limited when transactions are executed through the Client account custodian. Aggregation and Allocation of Transactions When the Adviser determines that the purchase or sale of the same security is appropriate for multiple Client accounts, the Adviser may (but is not obligated to) aggregate such orders to seek more efficient execution and to reduce transaction costs. Transactions aggregated in this manner are generally allocated among participating Client accounts in a manner that the Adviser believes to be fair and equitable over time, taking into account factors such as account size, investment objectives, portfolio composition, and applicable investment restrictions. In some circumstances, aggregated transactions may result in different execution prices or transaction costs for different Client accounts. Wrap Fee Programs In certain cases, Client accounts managed by the Adviser may participate in wrap fee programs sponsored by third parties. In such arrangements, the program sponsor typically selects the custodian and brokerdealers used for the execution of transactions. As a result, the Adviser may have limited discretion to select broker-dealers or negotiate commission rates for such accounts. Consequently, the Adviser may not be able to achieve execution results for wrap program accounts that are as favorable as those that might be obtained if the Adviser had full discretion over broker selection. Research and Soft Dollar Practices The Adviser does not currently enter into soft dollar arrangements within the meaning of Section 28(e) of the Securities Exchange Act of 1934. However, brokerage commissions paid by Client accounts may

include the cost of proprietary or third-party research services provided by broker-dealers. To the extent such research is received, the Adviser may benefit from the availability of such information in connection with managing Client accounts. The Adviser maintains policies and procedures governing broker selection, trade execution, and trade allocation designed to ensure that Client accounts are treated fairly and that the Adviser fulfills its duty to seek best execution. Trade Errors From time to time, trade errors may occur in the course of executing transactions for Client accounts. Such errors may arise from a variety of causes, including human error, system or communication failures, data errors, or issues associated with automated or algorithmic trading systems used by the Adviser. The Adviser maintains policies and procedures designed to identify, address, and document trade errors and to monitor the operation of its trading systems. When a trade error is identified, the Adviser seeks to correct the error in a manner that it believes is fair and equitable to the affected Client accounts. In general, Client accounts will not bear losses resulting from trade errors caused by the Adviser’s gross negligence, willful misconduct, or fraud. The Adviser may absorb the costs associated with correcting such errors or otherwise take steps designed to ensure that affected Client accounts are treated fairly. Clients should refer to their respective Investment Materials for further disclosures with respect to trade errors.

Solicitation or Referral Arrangements The Adviser may enter into solicitation or referral arrangements with Intermediaries (as defined in Item 4 – Advisory Business) or other third parties (each a “Solicitor”) for the introduction of prospective clients for its separately managed account advisory services. Under these arrangements, the Adviser may compensate Solicitors upon inception of a new SMA Client account. Such compensation is paid by the Adviser from its own advisory fees and does not result in any additional charge to the SMA Client or the SMA Client account. Solicitors are typically compensated based on a percentage of the advisory fees received by the Adviser from SMA Clients introduced by the Solicitor or pursuant to another mutually agreed fee arrangement. Such arrangements are governed by written agreements and are intended to comply with applicable regulatory requirements, including those in the SEC’s Marketing Rule. The Adviser will take reasonable steps to ensure that required disclosures are provided to Clients regarding the solicitor’s role and compensation. Clients introduced through such arrangements should consider the Solicitor’s financial incentive to recommend the Adviser when evaluating the referral. Clarification of Dual Relationships In certain cases, the Adviser may have multiple business relationships with the same Solicitor. For example, a firm may act as an investment adviser or platform sponsor whose client accounts are managed by the Adviser on a sub-advisory basis, and the same firm may also introduce prospective clients to the Adviser or provide commercial client information to the Adviser. These arrangements are negotiated separately and may involve different contractual relationships. The Adviser seeks to manage any potential conflicts arising from such relationships through disclosure and by adhering to applicable regulatory requirements. Private Fund Placement Agents The Adviser does not currently compensate any third parties for the referral of investors to the Fund.

Neither the Adviser nor any of its management personnel are subject to, or have in the past been subject to, any criminal or civil action in any domestic or foreign court, and neither the Adviser nor any of its management personnel have been subject to any administrative proceedings before the SEC or any other state, federal, or foreign financial regulatory authority.

Separately Managed Accounts Each SMA Client account will be reviewed by the Adviser on at least a monthly basis SMA Clients will receive periodic performance reports from the Adviser pursuant to the terms of the relevant SMA Client’s Investment Material. Private Fund The Adviser continuously monitors and analyzes the transactions, positions, and investment levels of the Fund to ensure that they conform with the investment objectives and guidelines that are stated in the Fund’s Investment Material. The Adviser performs daily systematic reviews of the Fund’s holdings. The Adviser will distribute an audited financial report with respect to the previous fiscal year to all Fund investors within 120 days of the Fund’s calendar year end.

As the Adviser acts as investment adviser to the Fund, the Adviser is deemed to have custody of certain Fund assets under current applicable regulatory interpretations. As such, and as is required by the safekeeping requirement in Rule 206(4)-2 (the “Custody Rule”) of the Investment Advisers Act of 1940, as amended (the “Advisers Act”), all assets of the Fund are held by qualified custodians. Upon completion of the r Fund’s annual audit by an independent auditor that is registered with, and subject to inspection by, the Public Company Accounting Oversight Board (“PCAOB”), the Adviser will distribute the Fund’s audited financials to Fund investors within 120 days of the Fund’s fiscal year end. The Adviser takes the position that it does not have custody with respect to its separately managed accounts under the Custody Rule. Nevertheless, the Adviser has a reasonable basis to believe SMA Client accounts receive a custodian statement on at least a quarterly basis, as required by the Custody Rule if the Adviser was deemed to have custody with respect to separately managed accounts.

The Adviser has discretionary authority to determine which securities and the amounts of securities that are bought or sold, as well as the broker-dealer to be used and the commission rates to be paid. Clients generally do not have the ability to place any limits on the Adviser’s authority beyond the limitations set forth in the Client’s Investment Material. Prior to assuming full discretion in managing a prospective client’s assets, the Adviser will enter into an investment management agreement or other agreement that will set forth the scope of the Adviser’s discretion.

In compliance with the Advisers Act’s Proxy Voting Rule, the Adviser has adopted proxy voting policies and procedures. The Adviser’s general policy is to not engage in voting proxy proposals, amendments, consents, or resolutions (each a “Proxy” and, collectively, “Proxies”) as the Adviser has determined not voting is generally in the best interests of Client accounts. In making this determination, the Adviser considers various factors, including, but not limited to, (i) the nature of the quantitative strategy; (ii) the costs associated with exercising the Proxy (e.g., translation or travel costs); and (iii) any legal restrictions on trading resulting from the exercise of a Proxy. Clients may obtain a copy of the Adviser’s proxy voting policies and procedures by contacting the Chief Compliance Officer of the Adviser.

The Adviser is not required to include a balance sheet for its most recent fiscal year. In addition, the Adviser is not aware of any financial condition reasonably likely to impair its ability to meet Client contractual commitments, and nor has the Adviser been the subject of a bankruptcy petition at any time during the past ten years.