Quinn Opportunity Partners LLC

Quinn Opportunity Partners LLC (“Advisor,” “we” or “us”) is a Delaware limited liability company formed in March 2011 and is principally owned by Patrick Quinn.

We manage a private investment fund which is structured under a master-feeder arrangement, Quinn Opportunities Master LP (the “Master Fund”) is the master fund, Quinn Opportunities LP (the “Onshore Feeder”) is the onshore feeder fund, and Quinn Opportunities Offshore Ltd (the “Offshore Feeder”) is the offshore feeder fund (collectively, “Quinn Opportunities”). We also manage two private investment funds, Quinn Select Opportunities LP Series A (the “Series A”) and Quinn Select Opportunities LP Series D (the “Series D”). The Series A and the Series D, together with Quinn Opportunities are referred to herein as the “Funds”. Quinn Opportunity Partners GP LLC is the general partner of the Onshore Feeder and the Master Fund. Quinn Select Opportunities GP LLC is the general partner of the Series A and the Series D. Quinn Opportunity Partners GP LLC and Quinn Select Opportunities GP LLC (together, the “General Partners”) are “Relying Advisers” as defined in the SEC Staff No-Action Letter, dated January 18, 2012, to the American Bar Association, Business Law Section. The General Partners are our affiliates and are principally owned by Patrick Quinn. We provide discretionary investment advice to the Funds and one separately managed account. We generally invest and trade on behalf of our clients primarily through event-driven and value trading in publicly traded securities. Such securities may include, without limitation, domestic and foreign equities, corporate bonds, sovereign bonds, municipal bonds, closed-end funds, exchange-traded funds, and derivatives such as swaps, options or futures. We generally do not permit investors in the Funds to impose limitations on the investment activities described in the offering documents for the Funds. Under certain circumstances, we will contract with a managed account client to adhere to limited risk and/or operating guidelines imposed by the client. We negotiate such arrangements on a case-by-case basis. (See Item 16 “Investment Discretion” below) We do not participate in wrap fee programs. As of December 31, 2025, we managed approximately $2.6 billion in regulatory assets under management on a discretionary basis. We do not manage any assets on a non-discretionary basis.

Our fees and compensation are described in the advisory contracts we enter with our clients. Investors in Quinn Opportunities pay a quarterly management fee of 0.375% per quarter (approximately 1.5% per annum) and are subject to an annual performance-based allocation of up to 20% of net capital appreciation, subject to a high watermark. Investors in Series A and Series D are subject to just a performance-based allocation of up to 20% of net capital appreciation upon capital return. Fees charged to managed account holders are determined on a case-by-case basis but may include management fees and performance-based fees.

We generally deduct our management fees from client accounts quarterly in arrears. Management fees are generally pro-rated for less than full calendar quarters. Generally, we or our affiliates receive performance-based fees or allocations from client accounts on an annual basis in arrears and upon redemptions by investors in the Funds. The Funds will bear all expenses directly or indirectly related to its operations and investment transactions and positions for its account, including, but not limited to: the management fees and investment management expenses, interest expense, brokerage commissions, custodial fees, costs of borrowing securities to be sold short, research and due diligence fees and expenses (including any research and/or due diligence related travel) and materials (including online news and quotation services, computer hardware and software used for research, Bloomberg service, etc.), order management systems, withholding and transfer taxes imposed on it, blue sky fees, initial and periodic legal, audit, administration and accounting fees and expenses, investor reporting costs, insurance expenses, consulting fees and expenses, professional fees and expenses, and other similar fees and expenses. We may, in our discretion, fully or partially waive the reimbursement of any of the foregoing expenses by the Funds and in result bear such expenses. (See Item 12 “Brokerage Practices” below) The expenses that are charged to separately managed accounts are determined on a case-by-case basis. We may also allocate a portion of certain clients’ capital to money market funds, exchange-traded funds or similar fee-bearing products or private investment funds and accounts that are managed by other investment managers. In addition to the fees and expenses discussed above, a client will indirectly incur similar fees and expenses if we invest such client’s capital in such products, as these products in turn pay similar fees to their investment managers and other service providers.

Methods of Analysis and Investment Strategies Generally We seek, on behalf of our clients, capital protection and appreciation primarily through event-driven and value trading in publicly-traded securities. Such securities may include, without limitation, domestic and foreign equities, corporate bonds, sovereign bonds, municipal bonds, closed-end funds, exchange-traded funds, and derivatives such as swaps, options or futures. We may also employ leverage in our investment strategy. We believe an opportunistic and flexible approach is necessary for optimal trading of client assets. While event-driven opportunities are expected to exist in any market environment with resolutions generally independent of market movements, we believe that periods of market price dislocations or capital market closures often result in securities priced significantly below our estimate of intrinsic value. During such time, and insofar as expected returns from value trading opportunities exceed event-driven opportunities, we intend to trade a greater proportion of client assets in value opportunities. We seek to balance diversification benefits with the opportunity costs of diversification in order to optimize risk-adjusted returns. Because event-driven opportunities are generally not significantly correlated to the market or to each other, we may consider a portfolio of less than twenty-five (25) such positions to be well diversified, excluding hedges, but may exceed such amount in our discretion. We believe the loss associated with a negative event outcome is a better measure of risk for an event-driven position than measures of beta, long-market value, or short-market value. However, we seek to size event-driven trades so that generally no more than three percent (3%) of a client’s net assets (measured at the time of investment) would be lost in the event of a negative outcome, though there can be no guarantee that any position will not lose more than three percent (3%) of a client’s net assets. We utilize a “bottom-up” research approach. Trading decisions generally will be based on situational specifics rather than a broad view of the market or economy, and securities acquired for clients generally are individually selected. Event-Driven Trading Our clients will trade publicly-traded securities of companies involved in mergers, hostile takeovers, tender offers, exchange offers, spin-offs, rights offerings, bankruptcy re-organizations, and other current or potential future corporate events. The return on these trades is primarily linked to resolution of the event or the reversal of event-related price dislocations. We seek to profit by purchasing / (selling short) securities at a discount / (premium) to their expected value upon completion of the corporate event or reversal of the event-related price dislocation. Strategies that involve event-driven trading may include (but are not limited to):

Merger Arbitrage. Merger arbitrage includes securities of target companies that have signed contractual agreements for the sale of the company or that are the subject of nonbinding hostile bids. These securities generally trade at a discount to the expected deal value to reflect the time value of money and the risk that the transaction may not be completed on expected terms, or at all. The size of this discount (the “Spread”) constitutes the return an investor will earn if the transaction closes on expected terms. When a transaction closes, target shareholders will receive cash, stock, or a combination thereof, depending on the deal terms. In a cash deal, the Spread is captured by purchasing the target company’s shares and holding the shares until the closing of the transaction. If the deal consideration includes stock, the Spread is captured by also shorting the acquirer’s stock in the amount expected to be received upon the transaction’s closing. Self Tenders and Exchange Offers. Self tenders include securities of companies that have announced a tender offer to repurchase securities directly from security holders for cash or have announced an exchange offer to repurchase securities directly from security holders for consideration that includes newly issued securities. The company sets the offer consideration, the maximum amount of securities sought in the offer, and any conditions to the offer. When less than the maximum amount is submitted by shareholders, all submitted securities are accepted. When more than the maximum amount is submitted, submissions are pro-rated such that the acceptance percentage is the same for all security holders. Securities subject to an offer generally trade at a discount to the offer to reflect expected proration of the offer, the value of any returned securities after the offer closes, and the likelihood of amendment or termination of the offer. Because offer proration and the value of returned securities are unknown until the offer closes, expected value of the offer must be estimated. In this instance, the Spread is the size of the discount between the expected value of the offer (calculated after taking into account proration and value of returned securities) and the market price of the security. The Spread constitutes the return an investor will earn if the transaction closes on expected terms. Spin-Offs. Spin-off securities are created when a subsidiary or division of a parent company is separated to create a newly independent company. The new company’s shares are then distributed to parent company shareholders. Before the distribution occurs, financial material on the new company is prepared and filed with the SEC. All parent company shareholders receive shares of the new company. After the distribution, spin-off securities may trade at valuation extremes relative to comparable securities or the spin-off security’s estimated intrinsic value. Such extremes may occur when shareholders cannot, or otherwise choose not to, hold spin-off securities and sell their holdings in the market. Securities that may be acquired in spin-off trades include both parent company and distributed shares of the new company. Bankruptcy Re-Organizations. Re-organization equities are created when a company emerges from bankruptcy and former creditors receive shares in the newly reorganized company. The amount of stock each creditor receives, and financial information and business projections for the new company, are detailed in a disclosure statement that is filed with the bankruptcy court. The new shares are usually listed on an exchange and often lack research coverage. After listing, re-organization equities may trade at valuation extremes to comparable securities or the re-organization equity’s estimated intrinsic value. Such extremes may occur when shareholders – typically the company’s former creditors – do not wish to, or are unable to, own equity in the newly reorganized company.

Distressed Credit. Distressed credit securities are credit instruments of issuers in real or perceived distress or that are involved in bankruptcy proceedings. Such instruments may trade at a discount to recovery value or intrinsic value or may be subject to temporary price dislocations as a result of credit rating downgrades or misperceptions of issuer creditworthiness. Closed-End Fund Events. Closed-end funds may announce tender offers, rights offerings, mergers, or conversions to open-ended mutual funds. Depending on the closed-end fund’s discount or premium to net asset value and participation of such fund’s shareholders in the corporate event, opportunities to arbitrage the market price of such fund’s shares with the expected value of participation in the event may occur. Value Trading We intend to trade publicly-traded securities where price has significantly deviated from our estimate of intrinsic value. We seek to profit for clients by purchasing securities trading at meaningful discounts to intrinsic value and may also sell short securities trading at meaningful premiums to intrinsic value. Because we believe the quantitative methods we use to estimate intrinsic value are conservative, we expect that market prices for securities will often be significantly above our estimate of intrinsic value. If we are unable to find suitable value trades, we may not allocate clients’ capital to such opportunities. Investing in securities involves risk of loss that clients and investors should be prepared to bear. Certain Risks Associated with Methods of Analysis and Investment Strategies Investment and Trading Risks. All securities investments risk the loss of capital. We believe that our trading program and research techniques moderate this risk through a careful selection of portfolio positions, the use of short positions and other financial instruments. However, no guarantee or representation is made that our trading program will be successful or that our clients will not incur losses. In addition, results may vary substantially over time. Our trading program may utilize techniques, including, but not limited to, trading in put and call options and other derivatives, the use of leverage, and short sales, which in practice can, in certain circumstances, increase the adverse impact to which our clients may be subject. In addition, in certain transactions, our clients may not be “hedged” against market fluctuations or the degree of legal and regulatory risk associated with investments in the securities of companies in certain situations. We will attempt to assess the foregoing risk factors, and others, in determining the extent of the position we will take in the relevant securities and the price we are willing to pay for such securities. However, such risks cannot be eliminated. Concentration of Investments. Unless we agree otherwise, a client is not restricted in the amount of its capital that it may commit to any single security, geographic region, industry or sector, and at times clients may hold a relatively large concentration in a particular security, geographic region, industry or sector. Losses incurred in those positions could have a material adverse effect on a client’s overall financial condition. This is because the value of a client’s portfolio will be more susceptible to any single occurrence affecting one or more of those issuers, geographic regions, industries or sectors than would be the case with a more diversified investment portfolio.

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We provide investment advice to the Funds and to separately managed accounts. Investors in the Funds qualify as “accredited investors” (as defined in Rule 501 under the Securities Act of 1933, as amended) and “qualified clients” (as defined in Rule 205-3(d) under the Investment Advisers Act of 1940, as amended (the “Advisers Act”)). The minimum investment in the Funds is generally $500,000. We will

determine the minimum investment for a separately managed account on a case-by-case basis, but it is generally expected to be at least $50 million.

We or our affiliates receive performance-based fees or allocations from the Funds and the separately managed accounts we manage, which are based on a percentage of the capital appreciation of client assets. The terms of the performance-based fees and allocations may differ between the Funds and the separately managed accounts. This may result in a conflict of interest when we allocate opportunities among these accounts because we will have an incentive to favor an account that has higher performancebased fees and allocations. However, we try to avoid such conflicts of interest and do not consider the performance-based fees and allocations to which such accounts are subject. When we determine that a particular trading opportunity would be desirable for more than one client, we generally seek to allocate such opportunity among such clients in a manner that we deem fair and equitable under the circumstances existing at such time; provided, however, that we intend to grant priority to Quinn Opportunities and any other private investment funds that will trade on a pari passu basis with Quinn Opportunities in allocating such opportunities, and Quinn Opportunities and any such other private investment funds may purchase a particular security prior to the time such security is purchased by our other clients, which could result in our other clients buying such securities on less

favorable terms and/or at a higher price than Quinn Opportunities or any such other private investment funds. The factors that we may consider in making such determination include (but are not limited to): the relative amounts of capital in each client’s account available for new positions of the type at issue; the mandate of each client account; our perception of the appropriate risk/reward ratio for each client account; the intended trading strategy of each client account; the liquidity of each client account at the time of trading and thereafter; the ability to add positions to a client account on a leveraged basis; whether the position is an “odd lot”; whether the position is being added in a “de minimis” amount; the overall portfolio composition of each client account; and tax considerations. We also intend to grant priority to Quinn Opportunities and any other private investment funds that will trade on a pari passu basis with Quinn Opportunities with respect to any sales or other dispositions of securities held by Quinn Opportunities and/or any such other private investment funds, on the one hand, and our other clients, on the other hand, which could result in our other clients selling such securities on less favorable terms and/or at a lower price than Quinn Opportunities and/or any such other private investment funds. Although the separately managed accounts that we manage have trading strategies that are substantially similar to the Funds, such accounts are currently managed on an “excess capacity” basis (i.e., a particular trading opportunity generally is allocated to such accounts only if we determine the trading opportunity is not capacity constrained at the time, or, if we determine the trading opportunity is capacity constrained at the time, to the extent there is capacity in such opportunity after the Funds reach a target allocation in such opportunity). Notwithstanding the foregoing, we reserve the right to manage such accounts (and any other separately managed account and/or investment fund) on a different basis in the future if we so determine in our sole discretion in accordance with the terms of the respective investment managements agreements. New issues (as defined by FINRA rule 5130) are allocated to client accounts in accordance with the criteria set forth above. Our principal may have a greater portion of his personal assets invested in the Funds than in other client accounts. As a result, we may have a conflict of interest in allocating investment opportunities among the Funds and other client accounts. As the management fees and performance-based fees and allocations are based directly on the net asset value of the client accounts, we have a conflict of interest in valuing the assets held in the accounts. To the extent we are responsible for valuing a client’s assets, we will follow our documented valuation policies and consult with the third-party administrator to the client in order to mitigate this risk.

Quinn Opportunity Partners GP LLC is the general partner of the Onshore Feeder and the Master Fund. Quinn Select Opportunities GP LLC is the general partner of Series A and Series D. (See Item 4 “Advisory Business” above.)

Trading We have adopted a Code of Ethics (the “Code of Ethics”) which provides that we are committed to conducting our business in accordance with all applicable laws and regulations and in an ethical and professional manner. In addition, we recognize that we have a fiduciary duty to the investors in the Funds and the separately managed accounts we manage, and that we must conduct our business in a manner that enables us to fulfill this fiduciary duty. In this regard, we have developed policies and procedures in our Code of Ethics that are premised on fundamental principles of openness, integrity, honesty and trust. In addition, among other things, our Code of Ethics governs all personal investment transactions by our employees, our policies with respect to gifts and entertainment, compliance with applicable federal securities laws, the manner in which violations of our Code of Ethics are to be reported, and certain other outside activities of our employees. We will provide a copy of our Code of Ethics to any client or prospective client upon request. We make available to qualified prospective investors the opportunity to invest in the Funds. Our principal has significant personal investments in the Funds. In addition, we and our affiliates receive performancebased fees and allocations from the Funds and the separately managed accounts that we manage.

Subject to applicable law, we may effect transactions between client accounts (generally for rebalancing purposes and to correct misallocations of trades) whereby one client account will purchase securities from or sell securities to another client account. In the event that we effect a cross trade between an account in which we or our principal 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 us because we may put our or our principal’s interest in such accounts before the interests of our clients in the other account. In order to mitigate this conflict of interest, we monitor the interests of our principal, his immediate family members and their affiliates in our client accounts, and we will not effect any cross trades between accounts if we believe that such trade would result in a principal transaction unless: 1) We believe that such transaction is in the best interest of the clients participating in the transaction; and 2) We obtain the consent of the applicable clients as required by the Advisers Act. Employees are generally prohibited from engaging in a personal securities transaction without the prior written consent of our Chief Compliance Officer (currently, our principal). Generally, in granting or denying such requests, the Chief Compliance Officer takes the following guidelines into account: (i) requests should not be opposite of our recommendations (except in limited situations where the employee is suffering a financial hardship); (ii) requests should not engage in “frontrunning” of client accounts, which is a practice generally understood to be personally trading ahead of client accounts; and (iii) requests should not be in a security that is purchased or sold by a client account within five (5) days after the purchase or sale of such security by such client account. Prohibitions relating to personal trading also generally apply to an employee’s immediate family member (including any relative by blood or marriage either living in the employee’s household or financially dependent on the employee). The Chief Compliance Office has the discretion to approve any personal trading request that does not have an adverse effect on client accounts. We may buy or sell securities for one client at the same time that we or our related persons buy or sell the same security for one or more other clients (including the Funds which is our related person). This will typically happen when more than one client is capable of purchasing or selling a particular security based on investment objectives, available cash and other factors. This may create a conflict of interest if one account may benefit from making the trade before or after the other account.

Selection of Brokers In placing portfolio transactions for our clients, we seek to obtain the best execution for clients’ accounts, taking into account the following factors: price; the ability of the brokers to effect the transactions; the

brokers’ facilities, reliability and financial responsibility and; the provision or payment (or the rebate to our clients for payment) of the costs of property or services (e.g., short term custodial services, research services, news and quotation services, publications and other research and brokerage products or services). Brokers sometimes suggest a level of business they would like to receive in return for the various services they provide. We will not commit to provide any level of brokerage business to any broker, and actual brokerage business received by any broker may be less than the suggested allocations but can (and often does) exceed the suggestions, because total brokerage is allocated on the basis of all the considerations described above. On a quarterly basis, our principal, Patrick Quinn, periodically evaluates the execution performance of the broker-dealers we use to execute client transactions. Mr. Quinn also evaluates, and seeks to resolve, any conflicts of interest that we may have in selecting brokers to execute client transactions. Research and Other Soft Dollar Benefits We currently have adopted a policy not to enter into any formal soft dollar arrangements with brokers, although may determine to change this policy in the future. Our prime broker(s) provide us with capital introduction and front and back office services, including trading, securities lending, clearing, reporting, and settlement for equities, fixed income, foreign currency and options, and talent recruiting, among others. During our last fiscal year, we have taken into account the quality, comprehensiveness and frequency of available research services and products considered to be of value provided by brokers when directing client transactions to a particular broker. We directed transactions to such brokers only consistent with best execution. Brokers sometimes suggest a level of business they would like to receive in return for the research services and products they provide, however we have not committed to provide any level of brokerage business to any broker. Our principal, Patrick Quinn, also evaluated, on a quarterly basis, the execution performance of the broker-dealers we use to execute client transactions and resolved any conflicts of interest that we may have had in selecting brokers to execute client transactions. Brokerage for Client Referrals Subject to applicable law, we may direct some client brokerage business to brokers who refer prospective investors to the Funds, consistent with best execution. Because such referrals, if any, are likely to benefit us but will provide an insignificant (if any) benefit to the Funds, we have a conflict of interest with the Funds when allocating Funds brokerage business to a broker who has referred investors to us. To prevent Funds brokerage commissions from being used to pay investor referral fees, we will not allocate Funds brokerage business to a referring broker unless we determine in good faith that the commissions payable to such broker are not materially higher than those available from non-referring brokers offering services of substantially equal value to the Funds. Trade Error Policy

Subject to applicable law, we will reimburse the applicable client account(s) for net losses that occur as a result of trade errors resulting from our gross negligence or willful misconduct. We may correct misallocations of trades among client accounts by re-allocating the applicable trade using the intended allocation methodology prior to the trade’s settlement date. If an erroneous allocation cannot be corrected prior to or after settlement, we may, if appropriate and subject to applicable law, correct such erroneous allocation by effecting a cross trade between client accounts at the price at which the initial trade was effected. Aggregation of Orders Currently, we do not aggregate client trades; however, we may decide to do so in the future for accounts that trade on a pari passu basis. Aggregation, or “bunching,” describes a procedure whereby an investment adviser combines the orders of two or more clients into a single order. Aggregation opportunities for us generally arise when more than one client is capable of purchasing or selling a particular security based on investment objectives, available cash and other factors. Because we currently do not aggregate client trades, our clients will not benefit from any better price and lower commission rate or lower transaction cost that might have been available had the trades been aggregated. Trades will be executed separately for each participating client. Each client will bear the commission and ticket charges applicable to its own trades. Depending on the order in which trades are placed for participating clients, some clients may receive better or worse pricing relative to other clients on a tradeby-trade basis and/or over time. We will periodically review trade execution pricing to evaluate whether there are any unusual trading patterns and/or any client is being systematically disadvantaged over time, subject to the manner in which we allocate investment opportunities as described in Item 6 above. Should we decide to aggregate client trades in the future for accounts that trade on a pari passu basis, securities purchased or sold may be allocated among client accounts on an average price basis. When an aggregated order is only partially filled, we will allocate the investment opportunity as described in Item 6 above. If we decide to aggregate such client trades in the future, we may also aggregate subsequent orders for the same security entered during the same day with any previously filled orders. This determination would take into consideration, without limitation, changes in the market price of the security and differences in allocations among accounts.

We do not receive any economic benefit from any person that is not a client in exchange for providing investment advice or other advisory services to our clients. Neither we nor any of our related persons directly or indirectly compensates any person who is not a supervised person of ours for client referrals.

There have been no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our business or the integrity of our management.

Client portfolios are reviewed daily, and their performance analyzed, by our principal, Patrick Quinn. Client investments are evaluated based on performance, SEC filings, company fundamentals, news and press releases, analyst reports, general market conditions and such other considerations as we deem appropriate. We furnish investors in the Funds with periodic written unaudited performance reports on a monthly basis. On an annual basis, investors receive a copy of the Funds’ annual audited financial statements and a statement of taxable income (Form K-1).

We may provide certain investors access to more frequent and/or more detailed information regarding the Funds’ securities positions, performance, finances, and management and/or other information about the Funds or us (including, notification of the commencement of certain disciplinary actions, legal proceedings, investigations or similar matters against a fund, us and/or our personnel, or of redemptions from a fund by us and/or our personnel), possibly enabling such investors to better assess the prospects and performance of the Funds. We provide the owners of the separately managed accounts we manage with periodic unaudited reports at such times as the owners of such accounts and we agree. The custodians of such accounts send account statements to the owners of such accounts no less frequently than quarterly. In addition, since a managed account investor directly owns the positions in its separately managed account, such investor may have full, real-time transparency as to all transactions and holdings in such account and may be better able to assess the future prospects of a portfolio that is substantially similar to the portfolios of the Funds. The investors in a separately managed account may have the right to withdraw all or a portion of their capital from such managed account on shorter notice and/or with more frequency than the terms applicable to an investment in the Funds.

As noted above in Item 13, although we do not have custody of the funds or securities of the separately managed accounts that we manage, the owners of such accounts will receive account statements no less frequently than quarterly from the custodians of such accounts. The owners of such accounts should carefully review these statements that are received from the custodians. Although we are technically deemed to have custody of the Funds and securities of the Funds, investors in the Funds receive audited financial statements in lieu of account statements from the Funds’ custodians.

We have discretionary authority to manage securities accounts on behalf of our clients. The investors in the Funds generally may not place any limits on our authority beyond the limitations set forth in the offering and governing documents of the Funds. On a case-by-case basis, owners of the separately managed accounts that we manage may negotiate certain risk and/or operating guidelines that we will adhere to when exercising our discretionary authority over such accounts.

We generally have voting discretion over securities held in clients’ accounts. Clients are generally not able to direct their votes in a particular situation. We will exercise our discretion in the best interests of our clients. In fulfilling our obligations to our clients, we will act in a prudent and diligent manner intended to enhance the economic value of the securities. A client may obtain information about how we voted securities in the Funds or other account in which the client is invested by contacting us at the address set forth on the cover page of this brochure.

We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore we are not required to include a balance sheet for our most recent fiscal year.