Ratan Capital Management LP

Ratan Capital Management, LP (“Ratan” or the “Firm”), a Delaware limited partnership, is an alternative investment management firm founded by Nehal Chopra. Ratan provides investment advisory services to private investment funds that we sponsor (collectively, the “Funds”). Ms. Chopra is the sole owner of Ratan and is responsible for all investment decisions made by the Firm. As of December 31, 2025, our regulatory assets under management were approximately $401,858,567, all of which are managed on a discretionary basis. Ratan commenced operations in March 2009. Our current staff consists of two employees and our principal place of business is in Miami, FL. The Funds currently advised by Ratan are:

Ratan Capital Fund, LP, a private investment fund organized under the laws of the State of Delaware open to U.S. investors (the “Ratan U.S. Fund”);

Ratan Capital Fund (Cayman), Ltd., a private investment fund organized under the laws of the Cayman Islands open to non-U.S. investors and tax-exempt U.S. investors (the “Ratan Offshore Fund”);

Ratan Capital Master Fund, Ltd., a private investment fund organized under the laws of the Cayman Islands that serves as the investment vehicle for the U.S. Fund and the Offshore Fund (the “Ratan Master Fund”); and

Adi Long Short Equity Fund LP, a private investment fund organized under the laws of the State of Delaware open to U.S. investors (the “Adi Fund”).

The Ratan U.S. Fund, Ratan Offshore Fund and Ratan Master Fund are part of a single “masterfeeder” structure and are collectively referred to in this brochure as the “Ratan Funds”. The Adi Fund is a stand-alone onshore fund and is managed by Mr. Paritosh Gupta, the spouse of Ms. Chopra and an employee of Ratan. Unless otherwise specified, the Ratan Funds and the Adi Fund may collectively be referred to as the “Funds”. Ratan Capital Group LLC, a Delaware limited liability company, affiliated with the Firm (the “Ratan General Partner”), serves as the general partner of the Ratan U.S. Fund, and the manager of the Ratan Master Fund. Ms. Chopra is the managing member of the Ratan General Partners. Adi Capital Advisors LLC, a Delaware limited liability company, affiliated with the Firm (the “Adi General Partner”), serves as the general partner of the Adi Fund. Mr. Gupta is the managing member of the Adi General Partner.

Each Fund’s confidential offering memorandum, formation documents and other offering documents contain additional important information and are available upon request to qualified potential investors. Persons who invest in the Funds are referred to in this brochure as “Investors”. We use the term “Interests” to refer to the limited partnership interests issued to Investors in the Ratan U.S. Fund and the Adi Fund and the shares issued to Investors in the Ratan Offshore Fund. The Interests are offered only through private transactions exempt from registration under U.S. and foreign securities laws. Investment Advisory Services & Types of Investments Ratan Funds Ratan serves as discretionary investment adviser to the Ratan Funds. As an investment adviser, Ratan is responsible for sourcing potential investments, conducting research and due diligence, analyzing investment opportunities and structuring and monitoring investments. Our investment objective is to generate attractive risk-adjusted returns primarily by using a fundamental researchintensive strategy to invest long and/or short in publicly traded equity securities, including equity derivative securities, of companies worldwide. Ratan seeks to identify companies that we believe are being undervalued by the market and are trading at a discount to their intrinsic or fundamental value and which we expect to appreciate in value, often due to a “catalyzing event” or change in circumstances, including CEO/management changes, significant corporate events such as transformational mergers, spin-offs, recapitalizations, bankruptcy reemergence and other major changes. We typically select investments for their attractive valuation and long-term growth potential, but may also identify specific investment opportunities that we believe have good shortterm trading potential. While Ratan generally focuses on investments in equity securities, there are no material limitations on the types of securities, sectors, markets or countries in which the Ratan Funds may invest and from time to time the Ratan Funds may invest in exchange-traded funds, fixed income securities and other financial instruments and assets that we deem appropriate to carry out the overall objectives of the Ratan Funds. Adi Fund As of January 1, 2021, Ratan (and previously Adi Capital Management and Mr. Gupta) serves as discretionary investment adviser to the Adi Fund. As an investment adviser, Ratan is responsible for sourcing potential investments, conducting research and due diligence, analyzing investment opportunities and structuring and monitoring investments. The Adi Fund’s investment objective is to achieve capital appreciation through utilization of a global long-short equity investment strategy with a value-oriented, event-driven bias. Ratan seeks to achieve this objective primarily through the purchase and sale of equity securities of companies associated with dramatic structural and corporate change, married with a focus on shareholder valueoriented CEOs. In advising the Adi Fund, Ratan invests in companies globally but mostly in the United States. Ratan takes long and short positions primarily in equities, ADRs, GDRs, convertible securities, bonds and other fixed income securities, options, warrants and puts and calls on stocks. Notwithstanding the foregoing, Ratan expects the Adi Fund to be significantly long biased and may have extended periods without taking short positions.

The Adi Fund’s assets usually consist of a mix of long-term investment ideas with at least a two-to three-year time horizon to benefit from investment themes. Shorter-term investment ideas seek to capture opportunities in fast changing market conditions that might impact near term earnings outlooks against consensus views. Shorter-term investment ideas may have a time horizon of six to twelve months. While Ratan incorporates a long and short investment strategy, in advising the Adi Fund, Ratan usually maintain a long-bias. While the Adi Fund invests primarily in long-short equities, Ratan has broad and flexible investment authority. Accordingly, the Adi Fund’s investments may at any time include, long or short positions in credit instruments, U.S. or non-U.S. publicly traded or privately issued or negotiated common stocks, preferred stocks, stock warrants and rights, bank loans, corporate debt, bonds, notes or other debentures or debt participations, convertible securities, fixed income securities, swaps, options (purchased or written), and partnership interests and other securities or financial instruments including those of investment companies. Please refer to Item 8 for further information about our methods of analysis and investment strategies, the types of securities we generally invest in, and the material risks. Customized Services & Client-Imposed Restrictions Ratan provides investment advice directly to the Funds and not the Investors in accordance with the Funds’ investment objectives. Ratan seeks to achieve the Funds’ investment objectives by continuous management and monitoring of the portfolio according to the investment strategy and terms described in the offering documents and investment advisory agreements. Under the terms of the investment advisory agreements, the Funds have granted us broad authority and discretion to determine which securities and the amount of securities to be bought or sold. Ratan is not required to seek approval to make any investment or maintain any position.

Ratan Funds Ratan is generally entitled to receive two types of fees as compensation for the investment advisory services provided to the Ratan Funds: (i) a management fee equal to 2.0% per annum, based on the net asset value of an Investor’s capital account (or shares in the case of the Offshore Fund) and (ii) an incentive allocation equal to 20% of the net profits attributable to an Investor’s capital account or shares (as applicable). The Firm only charges the full incentive allocation when an Investor’s account is above its “high-water mark”, or, in other words, when an Investor’s account value as of the end of the relevant period has recovered any losses from prior periods. Adi Fund Ratan receives two types of fees as compensation for the investment advisory services provided to the Adi Fund: (i) a management fee equal to 1.0% per annum, based on the net asset value of an Investor’s capital account; and (ii) an incentive allocation generally equal to 10% of the net profits in excess of a non-cumulative hurdle return if any subject to a loss carryforward provision, attributable to an Investor’s capital account.

The hurdle return with respect to each Investor shall be equal to the amount that would have been credited or debited to such Investor’s capital account for the fiscal year if the rate of return had been equal to the total return of the MSCI World Index. In the event that the MSCI World Index ceases to exist, the hurdle return will be calculated using an alternative index selected by the General Partner that, in the good faith discretion of the Adi General Partner, measures the performance of the global equity markets in a manner similar to the MSCI World Index. When calculating the incentive allocation, net profits will be reduced by the management fee, and all items of income, loss and expense incurred at the partnership level and the master fund level will be taken into account. Since the Adi General Partner will receive the incentive allocation at the partnership level, no incentive allocation will be made at the master fund level. For the avoidance of doubt, if there are no net profits attributable to a capital account in a given fiscal year and/or there are not enough net profits attributable to a capital account to exceed the hurdle rate, there will be no additional catch-up amount of net profits required before any incentive allocation is allocated in a subsequent fiscal year. The Adi General Partner has previously and may waive or modify the incentive allocation for Investors that are members, employees or affiliates of the Adi General Partner or the Firm, relatives of such persons, and for certain large or strategic investors. Please refer to Item 6 for further information about performance-based compensation and our conflicts of interest. Valuation Procedures Ratan’s fees are based on the net asset value of the Funds, as calculated by the Funds’ independent administrator, NAV Fund Administration (the “Administrator”). We anticipate that most of the Funds’ securities and other investments will be actively traded on an exchange, and will be valued at the current market price in the principal market where traded. All market prices are obtained from recognized data providers, typically Bloomberg and Reuters. Securities or other investments not traded on an active market will be valued in accordance with the pricing procedures established by Ratan from time to time. Please refer to the offering documents for further information about our valuation procedures and the calculation of the Funds’ net asset value. Payment of Fees Management fees are paid quarterly in advance and incentive allocations for the Ratan Funds and the Adi Fund are paid annually in arrears as of the end of each year. All fees, allocations and carried interest amounts are calculated by the Administrator and deducted directly from the Funds upon receiving approval from Ratan. If an Investor withdraws capital from the Ratan Funds or the Adi Fund, the incentive allocation on that capital will be deducted from the Investor’s account and paid to the Ratan General Partner or the Adi General Partner as if the withdrawal date were the last day of the year and any loss carryforward will be reduced on a pro-rata basis. An Investor is not permitted to choose to have the management fee, incentive allocation or carried interest amount billed directly for payment. Early Withdrawal Fees Withdrawals from the Ratan Funds and the Adi Fund requires prior notice and can be made only on a periodic basis. Interests in the Ratan Funds are subject to a “soft” initial lock-up of one year,

meaning that capital may be withdrawn prior to the first anniversary of issuance, subject to an early withdrawal fee payable to the Ratan Funds. Negotiability of Terms Fees and other terms are generally non-negotiable. Ratan retains the authority and discretion to waive all or a portion of the management fee and incentive allocation or any other term. Other Fees & Expenses Ratan’s fees are exclusive of expenses relating to the operation, administration and management of the Funds, including research expenses (including research-related travel and the costs of research-related publications and periodicals); filing and registration fees and expenses (including Forms 13D, 13F, 13G, 13H and PF); legal fees (including the costs of negotiating trade-related and account-specific counter-party documentation and side letters); expenses of the continuous offering of Interests, including marketing related travel and associated expenses, the cost of producing and distributing offering memoranda and other marketing materials; printing and distribution costs; accounting, audit, and tax preparation expenses; any taxes and duties payable in any jurisdiction in connection with the Funds trading and operations; administration fees, costs and expenses (including the fees and out-of-pocket expenses of the Administrator and its agents as well as any other third-party administrator which Ratan may select for the Funds, paying agency, transfer agency, accounting verification (if any) and/or investor registrar services and the costs of middle-office and back-office support as provided by the Administrator); the costs and fees attributable to any third-party proxy voting service or consultant; certain computer hardware and software, licensing, programming and operating expenses (including the installation, implementation and maintenance of order management and execution management hardware, systems and software, the costs of trading, research and/or data screens, as well as risk management and data services and systems); data processing costs; due diligence expenses; fees for consultants and other professionals or experts; costs and expenses incurred in connection with the Funds borrowings; interest expenses (including interest due to repurchase agreements and borrowing by the Funds); insurance expenses (including errors and omissions and directors and officers insurance, including for the principals, members, directors, officers and employees of the Firm and its affiliates, and the Master Fund’s directors); costs relating to establishing or using any entities in the course of the Funds trading and investing; custody fees, bank charges, brokerage commissions (including options trades), spreads, mark-ups on securities, swaps and forwards, short dividends, currency hedging costs, and other investment and operating expenses; and fees of each Conflicts Advisory Representative (as defined in the offering documents), all of which are incurred by the Funds. The Funds also bear the costs associated with extraordinary expenses, if any, such as: indemnification payments, litigation costs and damages. The Funds may invest in money market funds or other short-term investment vehicles managed by third parties (typically large financial institutions), pending investment in other securities or for purposes of liquidity. While assets are held in these short-term investments, the Funds will incur customary fees and expenses. To the extent that expenses are shared by more than one of the Funds, Ratan will seek to allocate such expenses among the participating Funds in a fair and equitable manner. The allocation of expenses among participating Funds will be done on a pro-rata basis. Expenses of the U.S. Fund

and the Offshore Fund are generally allocated to and paid by the Master Fund. Accordingly, all Investors in the Ratan Funds bear a pro-rata share of all of such expenses. Please refer to Item 12 for additional information regarding brokerage and custody and the factors we consider in selecting broker-dealers, and in determining the reasonableness of their compensation. Compensation from the Sale of Securities or other Investment Products Neither Ratan nor any of our principals or employees accepts compensation for the sale of Interests. Side Letters In accordance with common industry practice, a Fund or its general partner may from time to time enter into a “side letter” or similar agreement with an investor pursuant to which the Fund or its general partner grants the investor specific rights, benefits or privileges that are not generally made available to all investors. See “Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss” below for more details.

Ratan Funds Ratan is a fundamental, long/short equity investment manager. We primarily employ a value, change-driven investment strategy. Our investment process focuses on identifying securities of companies that we believe are trading at a significant discount to their estimated intrinsic or fundamental value and which we expect to appreciate in value in the foreseeable future, often due to a “catalyzing event” or change in circumstances. Investment candidates may include companies that have experienced change that we anticipate will “unlock” value, including new management, transformational mergers, spinoffs, bankruptcy reemergence or other major changes. The companies that we invest “long” in are typically undergoing transformational change and have one or more of the following characteristics at the time of initial purchase: (i) strong free cash flow characteristics, (ii) high returns on invested capital, (iii) defensive competitive positioning and/or (iv) strong management teams with alignment of interests. On the short side, we look for weak businesses that are undergoing structural change and have one or more of the following characteristics at the time of initial purchase: (i) trade at a premium to their intrinsic value, (ii) deteriorating fundamentals, (iii) non defensive and weak competitive positioning and/or (iv) weak management teams that are not incentivized to work in the best interests of shareholders. Our primary method of analysis is fundamental, bottom-up-research. Once a company is identified as a potential investment candidate, we undertake a fundamental research effort that may include qualitative, quantitative and comparative assessments of the company’s earnings power, ability to generate cash flow, asset values and financial strength, and reinvestment opportunities, as well as a subjective evaluation of the strengths and weaknesses of the company’s management, among other items. This internal research is supplemented with due diligence, which may include discussions with the company’s current or former management, competitors, customers, suppliers and analysts. The sources of information that we typically use include: SEC and other public filings, company reports, broker research, press releases, prospectuses, financial and trade periodicals and other secondary sources. Our research process may also identify other investment opportunities based on shorter term momentum, price dislocations or reactions to news. Ratan has broad and flexible investment authority and trades opportunistically on behalf of the Ratan Funds. To maintain flexibility and capitalize on investment opportunities as they arise, we are not required to invest any particular percentage of the Ratan Funds’ portfolio in any type of investment or region, and the portfolio’s concentration in any country, sector, industry or strategy can change at any time. The Ratan Funds may have exposure to any asset or asset class directly or through derivative instruments. In connection with the implementation of our investment

strategies, the Ratan Funds may from time to time utilize short sales, options, financial instruments, commodity futures, financial futures (and options thereon) and other securities to hedge investments. The Ratan Funds may also use leverage as part of the strategy and to enhance investment returns. The Funds’ net market exposure may vary depending on our assessment of shifting economic and/or market conditions. The size and concentration of the Funds’ positions typically reflect our conviction in respect of a value realization opportunity, based in part on one or more of the valuedrivers identified through our fundamental analysis. As Portfolio Manager, Ms. Chopra has final authority over all of the Funds’ portfolio decisions and is responsible for position sizing, capital allocation among sectors and the maintenance of targeted gross and net exposures. When investing in the Funds, Investors rely on the general market skill, knowledge and expertise of our investment team and ultimately rely on the expertise and judgment of Ms. Chopra, drawing on her experience in value and change-driven investing. Adi Fund Ratan seeks to achieve the investment objective of the Adi Fund primarily through the purchase and sale of equity securities of companies associated with dramatic structural and corporate change, married with a focus on shareholder value-oriented CEOs. In advising the Adi Fund, Ratan invests in companies globally but mostly in the United States. Ratan takes long and short positions primarily in equities, ADRs, GDRs, convertible securities, bonds and other fixed income securities, options, warrants and puts and calls on stocks. In addition, we may invest in commodities futures or other derivative securities, such as contracts for differences. Notwithstanding the foregoing, Ratan expects the Adi Fund to be significantly long biased and may have extended periods without taking short positions. The Adi Fund’s assets usually consist of a mix of long-term investment ideas with at least a two-to three-year time horizon to benefit from investment themes. Shorter-term investment ideas seek to capture opportunities in fast changing market conditions that might impact near term earnings outlooks against consensus views. Shorter-term investment ideas may have a time horizon of six to twelve months. While Ratan incorporates a long and short investment strategy, Ratan usually maintains a long-bias. While the Adi Fund invests primarily in long-short equities, Ratan has broad and flexible investment authority. Accordingly, the Adi Fund’s investments may at any time include, long or short positions in credit instruments, U.S. or non-U.S. publicly traded or privately issued or negotiated common stocks, preferred stocks, stock warrants and rights, bank loans, corporate debt, bonds, notes or other debentures or debt participations, convertible securities, fixed income securities, swaps, options (purchased or written), futures contracts, commodities, forward contracts and other derivative instruments, and partnership interests and other securities or financial instruments including those of investment companies. The descriptions of our specific advisory services and the investment strategies pursued and investments made should not be understood to limit in any way our investment activities. We may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this brochure, that we consider appropriate, subject to each Fund’s investment objectives and guidelines. In addition, Ratan may in the future organize other investment funds or manage investment funds or separately managed accounts that may either co-invest with the Funds or follow an investment program similar to or different from the Funds’ programs.

The investment strategies we pursue are speculative and entail substantial risks. The investment practices described above could result in substantial losses. There can be no assurance that our strategy will be profitable or that our investment objectives will be achieved. In the absence of a change in investment thesis, we may use price volatility as a potential opportunity to add to or trim positions, as opposed to viewing volatility solely as a source of risk. Investors must be willing to bear the risks of this strategy and the accompanying volatility. Certain Risks Relating to Our Investment Strategies and Investments Made The following risk factors do not purport to be a complete list or explanation of the risks involved with the activities of Ratan and the Funds. These risk factors include only risks we believe to be material, significant or unusual, and relate to particular investment strategies employed by Ratan and investments made pursuant thereto. We do not address material, significant, or unusual risks associated with other factors, including, without limitation certain instrument types, operational risks and certain market risks. Please refer to the Funds’ confidential offering memorandum for a more complete description of the risk factors. General Market Conditions. The success of our investment strategy is highly dependent upon conditions in the global financial markets and economic conditions throughout the world that are outside our control and difficult to predict, such as interest rates, availability of credit, inflation rates, economic uncertainty, changes in laws, trade barriers, commodity prices, currency exchange rates and controls, national and international political circumstances and the occurrence of various events (including hurricanes, earthquakes and other natural disasters). Unpredictable or unstable market conditions may result in reduced opportunities to find suitable investments and make it more difficult to exit and realize value from existing investments, which could materially adversely affect our investment strategy. The performance of our investment strategy also depends to a great extent upon correctly assessing the future course of the price movements of securities and other investments. There can be no assurance that we will be able to predict accurately these price movements. The Funds could incur material loses even if Ratan reacts quickly to difficult market conditions, and there can be no assurance that the Funds will not suffer material losses and other adverse effects from broad and rapid changes in market conditions in the future. Investors should realize that the markets for the financial instruments in which the Funds seek to invest can correlate strongly with each other at times or in ways that are difficult for Ratan to predict. Even a well-analyzed approach may not protect the Funds from significant losses under certain market conditions. Risks of Investments Generally. All investments risk the loss of capital. Our investment strategies may involve risks associated with limited diversification and high concentration, leverage, speculative assets and the use of speculative and possibly untested investment strategies and techniques, interest rates, currencies, volatility, tracking, short sales, credit deterioration or default, systems and other inherent risks. Certain investment techniques (e.g., use of leverage) can magnify the impact of adverse market movements. In addition, investments may be materially affected by conditions in the financial markets and by overall economic conditions occurring globally and in particular countries or markets where we invest. Some of these risks cannot and/or will not be hedged. Our methods for minimizing such risks may not accurately predict future risk exposures. Risk management techniques are based in part on the observation of historical market behavior, which may not predict market divergences that are greater than historical indicators. Also, information used to manage risks may not be accurate, complete or current, and such information may be misinterpreted.

Read the rest in the brochure

Ratan provides discretionary investment advisory services to private investment funds (i.e., hedge funds). Investors in the Funds include high net worth individuals, banks, trusts, pension plans, foundations, endowments, fund of funds, corporations and other types of business entities. Investors in the U.S. Fund must be: (i) “accredited investors” as defined in Regulation D under the Securities Act of 1933, as amended and (ii) “qualified purchasers” within the meaning of Section 2(a)(51) of the U.S. Investment Company Act of 1940. Investors in the

Offshore Fund must be: (i) non-U.S. investors or (ii) qualified U.S. tax-exempt investors who are both accredited. Foreign investors are generally not subject to any particular wealth requirements. Additional investor requirements are stated in each Fund’s offering documents, which prospective investors should review prior to investing. The minimum investment is $1,000,000. We retain the right to waive the minimum subscription requirements in our sole discretion. The Funds are intended for sophisticated investors who can accept a high degree of risk in their investments, do not need regular current income and can accept a potential loss of their entire investment. Each prospective investor should make such investigation and evaluation of the risks as he or she concludes is appropriate.

Performance-Based Fees The Ratan General Partner and the Adi General Partner is be entitled to receive performancebased compensation from the Funds. The receipt of performance-based compensation may create a conflict of interest because it provides an incentive to invest in riskier or more speculative investments with the potential for higher rewards than we might otherwise recommend if our compensation was not based on performance, such as fees calculated solely as a percentage of assets under management, or a flat fee, or hourly fee. Investors in the Ratan Funds and the Adi Fund should also consider that performance-based compensation is calculated as a percentage of realized and unrealized appreciation of the Ratan Funds’ assets. Because some or all of the Ratan Funds’ and/or the Adi Fund’s gains and losses will not have been realized when the performance-based compensation is calculated, the amount paid by Investors in the Ratan Funds and the Adi Fund may be higher than if performance-based compensation were based solely on realized net capital appreciation. Side-By-Side Management If Ratan was to advise clients other than the Ratan Funds or the Adi Fund and those other clients were to have investment objectives that were substantially similar to the Ratan Funds or the Adi Funds Ratan may manage the accounts side-by-side and make investments or sell investments in the same securities. This may create a conflict of interest where there is limited availability or limited liquidity for the investments. Measures to Address Conflicts of Interest Ratan has adopted the following measures to address these side-by-side management risks:

We disclose to Investors and prospective investors the existence of the material conflicts of interest in connection with performance-based compensation, the risk of riskier investments and the potential to earn more compensation from accounts that have such arrangements.

We collect and maintain information necessary to establish an Investor’s qualifications and suitability to participate in performance-based compensation arrangements.

We have implemented policies and procedures for the fair and consistent allocation of investment opportunities.

Please refer to Item 12 for further information regarding our allocation policy.

Neither Ratan nor any of our management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer, futures

commission merchant, commodity pool operator, commodity trading adviser, or an associated person of the foregoing entities. As noted above, Ratan Capital Group LLC (previously defined as the Ratan General Partner), an affiliate of Ratan, serves as the general partner of the Ratan U.S. Fund and the manager of the Ratan Master Fund. Further, Adi Capital Advisors LLC (previously defined as the Adi General Partner), an affiliate of Ratan, serves as the general partner of the Adi Fund. Any persons acting on behalf of the General Partner are subject to the supervision and control of Ratan in connection with any investment advisory activities. Ms. Chopra and Mr. Gupta will devote so much of their time and effort to the affairs of Ratan as may, in their judgment, be necessary to accomplish the purposes of Ratan. It should be noted that Ms. Chopra’s husband, Mr. Gupta manages the Adi Fund with a substantially similar investment strategy to the Ratan Funds. Ms. Chopra and Mr. Gupta will periodically discuss research-related information, analysis, models, notes and ideas, including with respect to securities that may be owned by Ratan. It is anticipated that there will be substantial overlap in the investment positions held by the Ratan Funds and the Adi Fund.

Code of Ethics Ratan has adopted a Code of Ethics (the “Code”), pursuant to Rule 204A-1 under the Advisers Act, which sets forth the standards of business and ethical conduct required of our principals and employees. The Code reflects fiduciary obligations to clients and requires Ratan principals and employees to act with honesty and integrity, adhere to the highest ethical standards and comply with applicable federal securities laws and regulations. The Code is based on the principle that we and our principals and employees owe a fiduciary duty to clients to ensure that personal securities transactions do not interfere with client transactions or otherwise take unfair advantage of client relationships. The Code includes provisions relating to personal securities trading, insider trading and market manipulation, rumor mongering, and participation in outside business interests, among other things. All principals and employees attend annual training and certify annually that they have read, understand and will abide by the Code. Personal Trading Subject to satisfying the Code and applicable laws, principals and employees are permitted, based on personal investment considerations, to buy or sell securities for their own accounts. Ratan has established the following policies and procedures to address conflicts of interests resulting from personal trading:

We require our principals and employees to disclose all personal brokerage accounts to our Chief Compliance Officer and submit initial and annual holding reports, disclosing all securities held. We require our principals and employees to notify their brokerage firms to provide duplicate copies of all trade confirmations and statements directly to our Chief Compliance Officer. We prevent short term trading by subjecting all transactions to a holding period.

We require all personal securities transactions be pre-cleared with our Chief Compliance Officer, other than securities (such as mutual funds) not treated as “reportable securities” under SEC Rule 204A-1. Personal transactions may be disapproved if our Chief Compliance Officer determines that the partner, principal or employee is unfairly benefiting from, or that the transaction is in conflict with, any pending client transaction.

Ratan’s principals and employees are generally prohibited from personal trading in publiclytraded equity securities. However, if a new principal or employee holds any publicly-traded equity securities (“legacy positions”) prior to being hired, such principal or employee may retain them indefinitely or, subject to preapproval by the Chief Compliance Officer, close any such legacy positions, but may not make new investments in such securities while they are employed by Ratan. Insider Trading All Ratan principals and employees are subject to our policy on preventing the misuse of material non-public information (the “Insider Trading Policy”), which is included as part of the Code. The Insider Trading Policy broadly prohibits the use of material, non-public information and includes policies and procedures that are intended to prevent insider trading by our principals and employees. Ratan maintains a “restricted list” that identifies companies for which we may have, or be deemed to have, material, non-public information. All principals and employees attend annual training on insider trading and are required to certify annually that they have read, understand and will abide by the Insider Trading Policy. Our Chief Compliance Officer may, in certain circumstances, grant exceptions under any section of the Code on a case-by-case basis, subject to applicable law. A copy of the Code is available to Investors and prospective investors, upon request, by mail or telephone to the address or telephone number on the front of this brochure. Conflicts of Interest Throughout this brochure, we disclose a number of conflicts of interest and provide summaries of a number of our policies and procedures designed to detect and address these conflicts and others. Each Fund’s confidential offering memorandum contains a more complete description of what we believe to be the most significant conflicts of interest associated with an investment in the Funds. Investors and prospective investors should carefully consider the conflicts of interest described here and in each Fund’s confidential offering memorandum before deciding to invest. Additional Conflicts Gifts and Entertainment; Political Contributions. Brokers, counterparties, service providers and other third parties with whom we do business occasionally provide gifts and entertainment to our principals and employees. Gifts and entertainment may create a conflict of interest in our selection and retention of service providers. To address this conflict, Ratan’s compliance program includes policies and procedures to monitor gifts and entertainment received and to limit the value of gifts and entertainment. The compliance program also includes policies and procedures to monitor, and in certain cases limit, the political contributions that our principals and employees make to public officials and candidates for elected office.

Allocation of Investment Opportunities and Other Accounts. We may advise additional funds and managed accounts in the future as there are no limits on the number of funds or managed accounts that we may advise. We may have financial incentives to favor certain funds and managed accounts over others. To address this conflict, we allocate, and will in the future continue to allocate, investment opportunities and treat all similarly situated funds and managed accounts fairly and equitably over time. There can be no assurance that a particular order or investment opportunity will be allocated in a particular manner. The performance of the Funds and such other funds or managed accounts may differ even though their investment objectives may be substantially the same or similar. Cross Trades and Principal Transactions. A “cross trade” occurs when Ratan causes the purchase and sale of a security between two or more client accounts. The opportunity to enter into a cross trade can arise for many reasons. For example, one client may have incoming cash that needs to be invested while another client has redemptions that need to be met by selling portfolio holdings. We may also “rebalance” the portfolios of clients following similar investment strategies to ensure that they have appropriate allocations and percentages invested in each holding. By “crossing” these types of transactions, Ratan can save the clients brokerage commissions or “mark-up/mark-downs” that would be charged in transactions effected on the open market. In addition, clients usually save on market impact costs – adverse movements in the market price that directly results from the client transactions, as well as other related costs such as custody and transfer expenses. Cross trades raise conflicts of interest concerns, including that the adviser and its personnel may have different economic interests in the participating funds and will have a potentially conflicting division of loyalties and responsibilities to clients on both sides of the transaction. These conflicts are particularly inherent when a cross trade is also a “principal transaction”. A principal transaction occurs when an investment adviser, acting for its own account (or the account of an affiliate) buys a security from, or sells a security to, a client’s account. Ratan has adopted policies and procedures governing cross trades. Ratan generally does not engage in cross trades on behalf of our clients and will currently only do so in compliance with Section 206(3) of the Advisers Act, which generally prohibits cross transactions involving principal accounts unless, prior to the completion of each such transaction, the adviser (1) discloses to the client in writing the capacity in which the adviser is acting and (2) obtains the client’s consent to the transaction. Trade Errors. Ratan may on occasion make trading errors in executing trading instructions. Examples of trading errors include: buying or selling an investment at a price or quantity inconsistent with the trading instructions; or buying rather than selling a particular investment and vice versa. If an error occurs, it is: (i) corrected as soon as practicable, (ii) investigated, evaluated and quantified, and (iii) reported to our Chief Compliance Officer. The Funds are generally liable for trading errors, including errors resulting in losses or gains, unless the errors result from conduct that breaches the standard of care set forth in the investment advisory agreements. We have a conflict of interest in determining whether a trading error has occurred, and in determining how to deal with such trading error.

Broker- Dealer Selection Ratan has full discretionary authority to determine the brokers-dealers used and the commission rates paid for the Funds’ transactions. When we execute orders, we have a duty to seek to obtain “best execution,” which means that the Funds’ total costs or proceeds are the most favorable under

the circumstances. We have established general criteria to determine which brokers are qualified to provide brokerage services and consider the full range and quality of the brokerage and related services provided; including:

research and access to management/conferences; quality of execution; reputation, financial strength and stability; ability to handle difficult trades; confidentiality of trading activity; willingness and ability to commit capital;

overall costs of trades (i.e., net price paid or received) including any commissions, mark-ups, markdowns or spreads; nature of the security and the available market makers; desired timing of the transaction and size of trade; operational facilities, including back office efficiency; block trading and block positioning capabilities; and

market intelligence regarding trading activity.

We are not required to solicit competitive bids and do not have an obligation to seek the lowest available commission or transaction costs. Commission rates are generally negotiable and thus selecting brokers on the basis of considerations that are not limited to the applicable commission rates may result in higher transaction costs than would otherwise be obtainable. Accordingly, in any transaction or series of transactions, the Funds may pay commissions to a broker in an amount greater than the amount another broker might charge. Research and Soft Dollar Benefits Ratan may select broker-dealers that furnish us with brokerage and research services that provide, in our view, appropriate assistance in the investment decision-making process. As a result, we may pay for such brokerage and research services with “soft dollars”. The term soft dollars refers generally to the practice by investment advisers of paying for research and brokerage services using brokerage commissions generated by the execution of trades for their clients. The types of brokerage and research services that Ratan acquired with client brokerage commissions in 2016 included: research reports on companies, industries and securities; economic, market and financial data; access to broker-dealer analysts and corporate executives; and attendance at industry seminars and broker organized conferences. The soft dollar benefits we receive do not generally have a mixed use and we generally do not utilize them for functions unrelated to making investment decisions. We primarily use research services and products to assist with investment decision-making responsibilities and enhance our capability to discharge those responsibilities. When Ratan uses client commissions to obtain brokerage and research services, we receive a benefit because we do not have to produce or pay for the brokerage and research services itself. As a result, we may have an incentive to select or recommend a broker-dealer based on our interest in receiving brokerage and research services, rather than solely on the Funds’ interest in receiving the most favorable execution. However, when selecting broker-dealers that provide brokerage and research services, we are obligated to determine in good faith that the commissions are reasonable in relation to the value of the brokerage and research services they provide to us. Reasonableness is viewed in terms of the particular transactions and our overall responsibilities to the Funds, even though that

broker-dealer itself, or another broker-dealer might be willing to execute the transactions at a lower commission. Accordingly, transactions will not always be executed at the lowest available price or commission, and we may cause the Funds to pay commissions higher than those charged by other broker-dealers. We intend to use soft dollars to obtain investment research and brokerage services in accordance with Section 28(e) of the Securities Exchange Act of 1934, which provides a “safe harbor” to investment managers who use commission dollars generated by their advised accounts to obtain investment research and brokerage services that provide lawful and appropriate assistance to the manager in the performance of investment decision-making responsibilities. We use brokerage and research services in connection with our advisory services for any client, not necessarily for only the account that “paid” for them. We do not seek to allocate soft dollar benefits to clients in proportion to the soft dollar credits the client generates. We intend to allocate soft dollar benefits to each client account in a fair and equitable manner. Ratan’s evaluation of the brokerage and research services provided by a broker-dealer may be a significant factor in selecting a broker-dealer to execute transactions. For this purpose, we have established a process in which certain members of our investment team rate broker-dealers that supply them with brokerage and research services. In addition, we distribute periodically a year-todate commission report to investment professionals who provide feedback regarding the research services provided. Subject to our duty to seek best execution, we allocate commissions, in part, in accordance with the outcome of this process. At least annually, Ratan considers the amount and nature of research and brokerage services provided by broker-dealers. Broker-dealers sometimes suggest a level of business they would like to receive in return for the various products and services they provide, but we are under no contractual or other requirement to provide such business. The Funds may have investors who are themselves service providers or are affiliated with service providers used by Ratan or the Funds; however, this is not a consideration in our determination as to whether to do business with a particular broker-dealer. Brokerage for Client Referrals We do not select or recommend broker-dealers based upon client referrals from a broker-dealer or third party. Directed Brokerage We do not recommend, request or require clients to direct us to execute transactions through a specified broker dealer. We require clients to grant us discretion to select the broker-dealers to effect transactions for their accounts, and do not accept client instructions to direct brokerage to other broker-dealers. Aggregation of Orders When placing orders, we may combine orders for the Funds into a single “aggregated” order for each broker-dealer we choose to execute a trade through. The Funds’ custodians allocate the securities or proceeds received (and related transaction expenses) among the Funds, as we direct. The allocation will be done on a pro-rata basis, except when another allocation is more appropriate, including due to investment restrictions, varying levels of cash, liquidity, differences in portfolio holdings, and desire to avoid “odd lots,” among other factors. We believe that combining and allocating orders in this way will, over time, prove advantageous

to the Funds by reducing transaction costs and providing for more efficient execution of trades. In unusual circumstances, the use of an aggregated order may be less advantageous to a particular client than if the client had been the only client participating in the transaction.

Ratan does not currently have any solicitation arrangements for referring investors to us; however, in the future, we may engage solicitors to refer prospective investors to the Funds. In the event we enter into a written referral agreement, we will disclose the terms of the arrangement, including the fee structure, to all such prospective investors, in accordance with Rule 206(4)-7 under the Advisers Act and relevant SEC guidance.

On December 5, 2017, the SEC instituted an administrative proceeding against Ratan and Ms. Chopra pursuant to Sections 203(e), 203(f), and 203(k) of the Advisers Act alleging that (i) Ratan and Ms. Chopra willfully violated Section 206(4) of the Advisers Act and Rule 206(4)8 thereunder, and (ii) Ratan and Ms. Chopra willfully violated Section 207 of the Advisers Act by failing to disclose to Ratan’s investors the significant role that Paritosh Gupta, Ms. Chopra’s husband and the owner and principal of Adi Capital Management LP (“Adi”), an unaffiliated investment adviser, played in Ratan’s investment process and operations. On December 5, 2017, the SEC issued an order (“SEC Order”) accepting an offer of settlement from Ratan and Ms. Chopra. Pursuant to the settlement, Ratan and Ms. Chopra neither admitted nor denied the findings of the SEC Order. Ratan and Ms. Chopra were both censured and ordered to cease and desist from committing or causing any violations and any future violations of Sections 206(4) and 207 of the Advisers Act and Rule 206(4)-8 thereunder and Ratan and Ms. Chopra were each ordered to pay a civil money penalty of $200,000.

Periodic & Other Account Reviews Our investment team monitors the Funds’ portfolio on a continuous basis to determine whether positions should be maintained based on performance, company fundamentals, current market conditions, news and press releases, analyst reports and other considerations. We also generate profit and loss reports for every position as of the end of every U.S. trading day. The Portfolio Manager is responsible for overseeing this process. In addition, the Administrator prepares daily reviews and reconciliations of cash, positions, and activity to the prime brokers’ records and reports reconciliation breaks for resolution to our back-office team. The monthly net asset value calculations are prepared by the Administrator and reviewed by our back-office team. Reports Investors currently receive the following information:  end-of-month unaudited performance estimates;  monthly capital statements detailing account information, including beginning and ending equity;  annual audited financial statements; and  applicable tax information for taxable U.S. investors invested in the U.S. Fund. We provide Investors with an annual report containing audited financial statements, as well as a statement of the Investor’s capital account as of the end of the fiscal year within 120 days of the close of each Fund’s fiscal year. This report includes information concerning valuations, profits, gains and losses of the Funds. Investors should carefully review any statements or reports provided by the Administrator as well as the Funds’ audited financial statements. Disclosure of Portfolio and Other Information In the course of conducting due diligence, Investors and prospective investors periodically request information pertaining to the Funds and Ratan. We may respond to these requests, and may provide information that is not generally made available to other Investors. When we provide this information, we do so without an obligation to update any of the information provided. We sometimes provide portfolio holdings information to third party service providers that have been retained by Investors to evaluate portfolio risk. For example, we have in the past provided portfolio holdings information to Riskmetrics, a provider of independent risk-transparency and riskmeasurement solutions for institutional investors. We provided this information in our sole discretion, and reserved the right to cease providing it at any time. We make reasonable efforts to preserve the confidentiality of the information we provided, but we cannot ensure that the entities to which we provided information will fulfill their confidentiality obligations.

Ratan is deemed to have custody of the Funds’ assets because of our authority to deduct fees and because an affiliate serves as the general partner of the Ratan U.S. Fund. We are exempt from certain provisions of the “custody rule” because (i) the Funds’ financial statements are prepared in accordance with U.S. generally accepted accounting principles and audited in accordance with U.S. generally accepted auditing standards by an independent public accountant registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board and (ii) audited financial statements are distributed to each Investor within 120 days of the end of each Fund’s fiscal year. Actual custody of the Funds’ assets is at a broker-dealer, bank or trust company. We currently hold the assets at the Funds’ prime broker, Goldman Sachs & Co. Prime brokers are periodically reviewed and may change without notice. Investors should carefully review any statements or reports provided by the Administrator as well as the Fund’s audited financial statements. Please refer to Item 13 for further information about the reports and audited financial statements we provide.

Ratan has full discretionary authority to manage the Funds’ assets. Under the terms of the investment advisory agreements, the Funds grant us the authority and discretion to determine, among other things, which securities and the amount of securities to be bought or sold, the broker-dealer to be used in the transaction and the commission rate to be paid to the brokerdealer that executes the transaction.

Ratan has full discretionary authority to manage the Funds’ assets, including the authority to vote proxies when solicited. In compliance with Advisers Act Rule 206(4)-6, Ratan has adopted proxy voting policies and procedures which we believe are reasonably designed to ensure that proxies are voted in the best interest of the Funds. Our proxy voting policies and procedures include guidelines regarding: (i) responsibilities of certain parties with regard to the proxy voting process; (ii) how material conflicts of interest are resolved to ensure that all proxies are voted in the best interests of the Funds; and (iii) recordkeeping issues. Investors may obtain a copy of our complete proxy voting policies and procedures and applicable proxy voting records by contacting us by telephone or in writing at the telephone number or address shown on the cover page of this brochure.

This Item requires us to disclose any financial condition reasonably likely to impair our ability to meet contractual commitments to clients. We have no information to report that is applicable to this Item. Additionally, Ratan does not require or solicit prepayment of more than $1,200 in fees per Fund, six months or more in advance and therefore has not included a balance sheet.