Rock Springs Capital Management LP

Rock Springs is organized as a limited partnership under the laws of the State of Delaware. Rock Springs is owned and controlled by Kris Jenner and Gordon Margraf (“Mark”) Bussard (collectively, the “Principals”). The Principals own and control the general partners of the Funds (defined below) (collectively and as applicable in each case, the “General Partner”); unless and only to the extent that the context otherwise requires, references to “Rock Springs” include the General Partner. The investment activities of Rock Springs are led by the Principals along with a number of other investment professionals who work with the Principals to execute Rock Springs’ investment strategies. The Funds and the General Partner Rock Springs provides discretionary investment advice to private investment funds organized as domestic or foreign private pooled investment vehicles (the “Funds”). The Funds are organized as master-feeder structures whereby each domestic fund (“Domestic Fund”) and offshore fund (“Offshore Fund” and together with the applicable Domestic Fund, the “Feeder Funds”) invests substantially all of its assets in a master fund (“Master Fund”). All trading occurs at the Master Fund level. Rock Springs began providing investment advisory services in October 2013. The Funds have been established to pursue investment strategies that focus primarily on investing in companies in healthcare and healthcare-related industries, with an emphasis on companies and/or products that Rock Springs believes serve critical unmet needs. The Funds’ investment objective is to generate capital appreciation, primarily through investments in publicly traded and privately placed securities of companies in these industries. Rock Springs manages the Funds in accordance with the investment strategies, objectives, restrictions and guidelines set forth in their respective confidential offering documents, limited partnership agreements and/or investment management agreements (the “Governing Fund Documents”), as applicable, and does not provide investment advice individually to the limited partners of the Funds (each, an “Investor” and together, “Investors”). Rock Springs generally does not permit Investors to impose restrictions on investments made by the Funds. However, Investors elect whether to participate in special investments, which include investments by the Funds in private companies and privately-placed debt as well as certain illiquid securities and restricted securities, as described in more detail in Item 8 below. Client Assets Under Management As of the close of business on December 31, 2025, Rock Springs managed approximately $1.8679 billion of client assets on a discretionary basis. Rock Springs does not currently manage any assets on a non-discretionary basis.

Compensation Payable to Rock Springs Rock Springs’ compensation for the investment advisory services it provides to the Funds is comprised of, in each case, an asset-based management fee (which is calculated as of the first day of each calendar quarter) and incentive compensation (which is allocated/paid annually in arrears and upon withdrawals and distributions) that is based on the performance achieved for the account of each Investor, subject to a benchmark or a hurdle and high water mark (as applicable), which amounts are deducted from the

Funds. The fees and expenses applicable to each Fund are set forth in detail in each of the Fund’s Governing Fund Documents. Rock Springs’ fee schedule is omitted because this brochure is only being delivered to qualified purchasers as defined in the Investment Company Act of 1940, as amended (the “Investment Company Act”). Rock Springs’ compensation is negotiable and Rock Springs may, in its sole discretion, elect to waive, reduce or calculate differently any compensation with respect to any person, including partners or employees of Rock Springs or its affiliates, such persons’ family members and trusts or other entities established for the benefit of such persons or their family members (collectively, and together with Rock Springs and its affiliates, “Related Persons”). Organizational, Operating and Other Expenses As a general matter, expenses borne by the Feeder Funds are set forth in the relevant Governing Fund Documents. The Feeder Funds bear all of their organizational, operating and other costs and expenses, as well as indirectly bear their pro rata share of the applicable Master Fund’s organizational, operating and other expenses, including investment-related expenses (e.g., costs and expenses associated with the investigation of investment opportunities (whether or not consummated) (which also includes expenses relating to attendance at medical and industry conferences), research, negotiating, financing, sourcing, acquiring, holding, hedging, settling and disposing of its investments) or other transaction costs, including travel expenses (including, for the avoidance of doubt, research and investigation-related travel (which includes first-class airfare in accordance with Rock Springs’ travel policy)), transaction fees, consulting (e.g., expert network fees), fees and reasonable out-of-pocket expenses incurred by an independent investor representative, advisory, investment banking, legal and other professional fees relating to investments or contemplated investments, the Master Fund’s brokerage commissions, information-related expenses (including costs and expenses associated with Bloomberg, FactSet, market data and market data feeds, vendors of portfolio analytics software (e.g., best execution analytical software) and tools and other similar costs and expenses), clearing and settlement charges, custodial fees, interest expenses, appraisal fees and expenses, expenses, interest charges and costs incurred in connection with any credit facilities, expenses incurred in collection of monies owed to the applicable Fund, legal, auditing and accounting expenses (including, but not limited to, expenses associated with the preparation of the applicable Fund’s financial statements, any tax returns and with respect to Schedules K-1), out-of-pocket costs incurred by Rock Springs (including its counsel) relating to the preparation of regulatory filings or the determination of whether such regulatory filings are necessary, and any other costs associated with such regulatory filings related to the Funds or Rock Springs with respect to the Funds (including, but not limited to Schedules D, F, G and/or 13H filings, Section 16 filings, Form PF filings, Form N-PX, Form SHO and Hart-Scott-Rodino), insurance expenses (including directors’ and officers’ insurance, errors and omissions insurance, cybersecurity insurance and other similar policies), fees and expenses of the Funds’ administrators, organizational expenses, expenses relating to the ongoing offer and sale of interests and withdrawals and transfers thereof, including, but not limited to legal expenses incurred by the Feeder Funds and Rock Springs in amending the Feeder Funds’ confidential offering documents, printing and mailing costs, management fees, any entity-level taxes, fees or other governmental charges levied against the Funds or any special purpose vehicle, all litigation-related and indemnification expenses, wind-up and liquidation expenses, extraordinary expenses and expenses comparable to any of the foregoing. The Feeder Funds also bear their pro rata share of the third-party expenses incurred by the applicable Master Fund in relation to its compliance obligations with respect to applicable anti-money laundering laws or the laws, regulations, and executive

orders administered by the Treasury Department’s Office of Foreign Assets Control or other laws or regulations by any person in any relevant jurisdiction, including expenses incurred with respect to the preparation of compliance manuals and ongoing training. The Feeder Funds share all items of profit, loss, income and expense of the applicable Master Fund on a pro rata basis in accordance with their respective capital account balances in the Master Fund, unless, in the judgment of Rock Springs, tax, regulatory, legal or other considerations make such pro rata arrangements inappropriate; provided that costs, fees and expenses incurred for the benefit of only a Domestic Fund or an Offshore Fund will be allocated solely to such Domestic Fund or Offshore Fund, respectively. Rock Springs Personnel Compensation All remuneration paid to Rock Springs, the General Partner and their respective principals, officers, partners or employees (collectively, “Rock Springs Personnel”) in connection with service by Rock Springs Personnel on the board of directors of a company in which a Fund invests (collectively, “Director’s Compensation”) shall reduce (but not below zero) the management fee that Rock Springs receives from the Funds by the amount of such Director’s Compensation following receipt or realization of such Director’s Compensation. Director’s Compensation received by Rock Springs in the form of warrants, options or securities shall be exercisable or disposable, as the case may be, in Rock Springs’ sole discretion, and shall reduce the management fee by the amount received. Any Director’s Compensation received by Rock Springs that is attributable to more than one Fund shall be prorated on a fair and equitable basis among all Funds as determined in good faith by Rock Springs. Allocation of Expenses Costs and expenses borne by more than one Fund will be allocated in accordance with Rock Springs’ expense allocation policy, which seeks to allocate expenses pro rata based on respective net asset values (which may be based on single investments or overall net asset value of the relevant Funds) and/or based on other equitable considerations that may be appropriate under the circumstances as determined by Rock Springs. Rock Springs will allocate all research- and investigation-related costs and expenses (including, but not limited to, attendance at or participation in broker-sponsored, industry- or sectorspecific or other conferences, expenses incurred in relation to meetings with industry or corporate spokespersons, physicians, government representatives and/or other key opinion leaders, expert network fees and expenses, and travel (which includes first-class airfare in accordance with the Rock Springs travel policy), lodging and other incidental costs, fees and expenses related to any of the foregoing) (collectively, “Research Expenses”) pro rata to the Funds based on their respective net asset values at the time such allocation is made; provided, however, that Research Expenses that relate directly to investment opportunities which are exclusive to a strategy implemented by one or more Funds will be allocated solely to such Fund(s), as applicable, based on its/their respective net asset value(s) at the time such allocation is made; and provided further that the allocation of Research Expenses to any special investment accounts of the Funds will be as provided in the expense allocation policy and the applicable Governing Fund Documents. The Funds will also share equally (i.e., 50/50) in certain expenses, including any out-of-pocket expenses related to any amendment to Governing Fund Documents except to the extent the amendment pertains to solely one Fund. The allocation of expenses involves subjective determinations by Rock Springs which may involve conflicts of interest. For example, although some expenses will be allocated pro rata among the Funds (e.g., based on respective net asset values or another methodology determined by Rock

Springs to be appropriate), other expenses may be allocated on a non-pro rata basis. In some instances, allocations may result in one or more Funds paying a disproportionate portion of an expense relative to the benefits actually received. Moreover, allocations of expenses will generally be based on information available at the time such allocations are made, on estimates (rather than exact figures) and on assumptions which Rock Springs believes are reasonable and appropriate but which may be imprecise. While Rock Springs believes that its expense allocation policy is reasonably designed, other reasonably designed allocation methodologies exist that will yield different results. To the extent that expenses of the Funds are paid by Rock Springs or its affiliates (in excess of its ratable share), the Funds will reimburse such party for such expenses. For more information regarding Rock Springs’ brokerage expenses, please see Item 12 herein entitled “Brokerage Practices.”

The investment objective of the Funds is to generate capital appreciation through investments in a combination of public and private securities of companies in healthcare and healthcare-related industries. The Funds focus mostly on public equities, utilizing a long-term, research-intensive approach to investing in healthcare and healthcare-related industries, with a particular emphasis on those companies and/or products that Rock Springs believes serve critical unmet needs. The Funds may invest in private companies and may make investments in companies outside of healthcare-related industries, as Rock Springs determines to be appropriate for the given Fund’s long-term investment strategy. In addition, the Funds may invest in securities which are illiquid, have limited liquidity or for which there is no ready market, including without limitation securities issued by private companies, restricted securities and privately-placed debt. Rock Springs will designate investments in private companies and privatelyplaced debt as well as certain illiquid securities and restricted securities as special investments. Each Investor must elect either to participate in or to not participate in special investments at the time that the Investor initially invests in a Fund (or makes any additional investment in a Fund). There can be no assurance that the Funds will achieve their investment objectives. The Funds seek to achieve the compounding of gains in long-term, secular winners in an industry prone to extreme outcomes and/or in companies that are innovative in discovering and developing therapeutic solutions to critical unmet healthcare needs. Rock Springs’ investment process leverages a long-term horizon, seeking to take advantage of the healthcare sector’s inherent volatility to increase position sizes over time. There can be no assurance that Rock Springs will achieve the objectives of the Funds. Investors may lose all or substantially all of their investment in the Funds. Summary of Principal Investment Risks Investing involves substantial risks, including the risk of total loss of capital, and may not be suitable for all Investors. No guarantee or representation is made that the Funds’ investment programs, including, without limitation, the Funds’ investment objectives, diversification strategies or risk monitoring goals, are or will be successful. Investment results may vary substantially over time. No assurance can be made that profits will be achieved or that substantial or complete losses will be avoided. Past results of investments made by the investment professionals of Rock Springs are not necessarily indicative of the Funds’ or Rock Springs’ future performance. The following are certain of the principal risks associated with the investment activities of the Funds, the structure of the Funds, and investing in the Funds in general. Some of the below risks apply to some but not all of the Funds. Investors should refer to the applicable Governing Fund Documents for a more comprehensive description of the various risks applicable to each Fund. General Investment Risk. Investments, including that of the Funds, are subject to the general risks associated with the underlying businesses, including general economic and market conditions, changes in regulatory requirements and laws (including laws relating to taxation of the Funds’ investments), reliance on management at the company level, interest rate and currency fluctuations, high inflation rates, general economic downturns, economic uncertainty, domestic and foreign political situations, and other factors. All of the Funds’ investments risk the loss of capital. The Funds could incur material losses even if Rock Springs 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. Thus, there can be no assurance that the Funds’ program will be successful or that an Investor will not lose some or all of its investment in the Funds. Cybersecurity Risk. The Funds are subject to risks associated with a breach in their cybersecurity. Cybersecurity is a generic term used to describe the technology, processes and practices designed to protect networks, systems, computers, programs and data from “hacking” by other computer users, other unauthorized access and the resulting damage and disruption of hardware and software systems, loss or corruption of data as well as misappropriation of confidential information. In recent years, cybersecurity attacks on companies, including companies in the financial services industry, have become increasingly prevalent. If a cybersecurity breach occurs, the Funds may incur substantial costs, including those associated with: forensic analysis of the origin and scope of the breach; increased and upgraded cybersecurity; investment losses from sabotaged trading systems; the impeding of trading; identity theft; unauthorized use of proprietary information; litigation; adverse investor reaction; the dissemination of confidential and proprietary information; and reputational damage. A cybersecurity breach could adversely affect the Funds and their investors by, among other things, interfering with the processing of shareholder transactions; impeding the ability to calculate net asset value; causing the release or misuse of confidential Funds information or private investor information (which may violate privacy and other laws, including those related to identity theft). Cybersecurity breaches may involve unauthorized access to a Fund’s digital information systems (e.g., through “hacking” or malicious software coding), and may come from multiple sources, including outside attacks such as denial-of-service attacks (i.e., efforts to make network services unavailable to intended users) or cyber extortion, including exfiltration of data held for ransom and/or “ransomware” attacks that render systems inoperable until ransom is paid, or insider actions (e.g., intentionally or unintentionally harmful acts of Rock Springs personnel). In addition, cybersecurity breaches involving a Fund’s third-party service providers (e.g., the administrator and prime brokers), trading counterparties or issuers in which the Funds invest can also subject a Fund to many of the same risks associated with direct cybersecurity breaches or extortion of data. Although Rock Springs has established business continuity plans and risk management systems designed to reduce the risks associated with cybersecurity, there are inherent limitations in these plans and systems, including that certain risks may not have been identified, in large part because different or unknown threats may emerge in the future. As such, there is no guarantee that such efforts will succeed, especially because the Funds do not directly control the cybersecurity systems of issuers in which a Fund may invest, trading counterparties or third-party service providers to the Funds. Such entities have experienced cyber attacks and other attempts to gain unauthorized access to systems from time to time, and there is no guarantee that efforts to prevent or mitigate the effects of such attacks or other attempts to gain unauthorized access will be successful. There is also a risk that cybersecurity breaches are not detected. There can be no assurance that the Funds will not suffer losses relating to cyber attacks on the Funds, their service providers, trading counterparties or the issuers in which the Funds invest. Any cybersecurity breach could expose Rock Springs and/or the Funds to civil liability as well as regulatory inquiry and/or action. Financial Institution Risk/Distress Events. An investment in the Funds is subject to the risk that one of the Funds’ banks, brokers, hedging counterparties, lenders or other custodians of some or all of the Funds’ assets (each, a “Financial Institution”) fails to perform its obligations or experiences insolvency, closure, receivership or other financial distress or difficulty, similar to events that occurred in the United States banking sector in March 2023 (each, a “Distress Event”). Distress Events can be caused by factors including eroding market sentiment, significant withdrawals, fraud, malfeasance, poor performance or accounting irregularities. In the event a Financial Institution experiences a Distress Event, the Funds and/or their portfolio companies may not be able to access deposits, borrowing facilities or other services

for an extended period of time or ever. Although assets held by regulated Financial Institutions in the United States frequently are insured up to stated balance amounts by organizations such as the Federal Deposit Insurance Corporation (“FDIC”), in the case of banks, or the Securities Investor Protection Corporation (“SIPC”), in the case of certain broker-dealers, amounts in excess of the relevant insurance are subject to risk of loss, and any non-U.S. Financial Institutions that are not subject to similar regimes pose increased risk of loss. Although in recent years governmental intervention has resulted in additional protections for depositors, there can be no assurance that governmental intervention will be successful or avoid the risk of loss, substantial delays or negative impact on banking or brokerage conditions or markets. Any Distress Event has a potentially adverse effect on the ability of Rock Springs to manage the Funds and their investments, and on the ability of Rock Springs, the Funds and/or portfolio companies to maintain operations, which in each case could result in significant losses and unconsummated investment acquisitions and dispositions. Such losses have the potential to include the Funds to pay fees and expenses in the event the Funds are not able to close a transaction (whether due to the inability to draw capital on a credit line provided by a Financial Institution experiencing a Distress Event, the inability of investors to make capital contributions or otherwise), as well the inability of the Funds to acquire or dispose of investments at prices that the relevant General Partner believes reflect the fair value of such investments and/or the inability of portfolio companies to make payroll, fulfill obligations and maintain operations. Although Rock Springs expects to exercise contractual remedies under the agreements with Financial Institutions in the event of a Distress Event, there can be no assurance that such remedies will be successful or avoid losses or delays. Many Financial Institutions require, as a condition to using their services or otherwise, that Rock Springs and/or the Funds maintain all or a set amount or percentage of their respective accounts or assets with the custodian, which heightens the risks associated with a Distress Event with respect to such custodians. Although Rock Springs seeks to do business with custodians that it believes are creditworthy and capable of fulfilling their respective obligations to the Funds, Rock Springs is under no obligation to use a minimum number of custodians with respect to any Fund, or to maintain account balances at or below the relevant insured amounts. Leverage and Borrowing Risks. The Funds have the power to borrow funds and will do so when deemed appropriate, including enhancing the Funds’ returns and satisfying withdrawal requests that would otherwise result in the premature liquidation of investments. The Funds may borrow funds from broker-dealers, banks and other lenders to finance trading operations, which borrowings may be secured by assets of the Funds. The use of such leverage can, in certain circumstances, increase the losses to which the Funds’ investment portfolios may be subject. Any event that adversely affects the value of an investment would be magnified to the extent that an asset or the Funds are leveraged. The cumulative effect of the use of leverage by the Funds in a market that moves adversely to the Funds’ investments could result in a substantial loss to the Funds, which would be greater than if the Funds were not leveraged. Leverage may be achieved through, among other methods, direct borrowing, purchases of securities on margin and the use of options, futures, forward contracts, repurchase and reverse repurchase agreements, swaps and other derivative instruments. The access to capital could be impaired by many factors, including market forces or regulatory changes. Illiquid Investments. The Funds invest in securities that are illiquid, that are not publicly traded and/or for which no market is currently available, and the Funds may not be able to sell or otherwise dispose of such securities on a short-term basis. Such non-publicly traded securities and financial instruments may not be readily disposable and, in some cases, may be subject to contractual, statutory or regulatory

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Rock Springs provides investment advisory services to the Funds. Investment advice is provided directly to the Funds, subject to the direction and control of the General Partner, and not individually to the Investors. Investors in the Funds may include, but are not limited to, high net worth individuals, family offices, funds of hedge funds, endowments, foundations, trusts, charitable organizations, pension plans, and corporate or business entities. Details concerning applicable Investor suitability criteria are set forth in the respective Fund’s Governing Fund Documents. The minimum commitment for an Investor is outlined in the respective Fund’s Governing Fund Documents, but is generally $10 million. However, Rock Springs and/or its affiliates maintain discretion to accept less than the minimum investment threshold. Each Investor is required to meet certain suitability qualifications, such as being an “accredited investor” within the meaning set forth in Regulation D under the Securities Act of 1933, as amended, and a “qualified purchaser” as defined in Section 2(a)(51) of the Investment Company Act.

As referenced in Item 5 above, Rock Springs may receive annual performance-based compensation in the form of incentive allocations/fees from the Funds. These performance-based compensation arrangements may create an incentive for Rock Springs to make more speculative investments than would otherwise be made, or make decisions regarding the timing and manner of realization of investments differently than if such allocations were not received. In measuring a Fund’s net profits for the purpose of calculating performance-based compensation, Rock Springs includes unrealized capital gains and losses and, as a result, the performance-based compensation may be based on gains that Investors never ultimately realize. In addition, as the Funds are subject to different performance-based compensation structures, Rock Springs may have an incentive to favor certain Funds over others. Please see Item 8 and Item 12 for additional information about the Allocation Procedures (as defined below), which are reasonably designed to mitigate such conflicts of interest. Rock Springs has adopted a code of ethics to enforce a standard of conduct for its employees and to address potential conflicts of interest, including conflicts of interest between Rock Springs and its clients that may arise as a result of performance-based compensation arrangements. Please see Item 11 below for a discussion of Rock Springs’ code of ethics.

The General Partner is the general partner of the Funds. While the General Partner is not separately registered as an investment adviser with the SEC, all of its investment advisory activities are subject to the Advisers Act and the rules thereunder. In addition, employees and persons acting on behalf of the General Partner, if any, are subject to the supervision and control of Rock Springs. The General Partner is also an “exempt commodity pool operator” under the rules of the Commodity Futures Trading Commission. Other than as described in this brochure, Rock Springs and its employees do not have any relationships or arrangements with other financial services companies that pose material conflicts of interest.

Transactions and Personal Trading Code of Ethics Rock Springs has adopted a written Code of Ethics (the “Code”) that is applicable to all employees. Among other things, the Code requires Rock Springs and its employees to act in the clients’ best interests, abide by all applicable regulations, avoid even the appearance of insider trading, and pre-clear and report on many types of personal securities transactions. Rock Springs’ restrictions on personal securities trading apply to employees, as well as employees’ family members living in the same household and are designed to prevent personnel who have information regarding Rock Springs’ transactions or proposed transactions on behalf of the Funds from trading for their own accounts on the basis of such information. Participation or Interest in Client Transactions Related Persons have investments in the Funds and/or other accounts managed by Rock Springs. In addition, Rock Springs directs the Feeder Funds’ investments into the applicable Master Fund, for which the General Partner serves as general partner. As a result, Related Persons have interests in investments that may also be recommended to clients. See “Conflicts of Interest” in Item 8 above for a summary of some of the circumstances in which such conflicts of interest arise. If such a conflict arises, Related Persons (including employees) are generally required to subordinate the interests of any other parties (or their own interest) to the Funds, and in any event would be required to disclose the conflicts. Personal Trading To mitigate the conflicts discussed above, except for investment in the Funds or accounts (including any proprietary accounts) managed by Rock Springs, employees must pre-clear certain personal securities transactions, including listed equity transactions and securities obtained through a private placement, before completing the transactions. Rock Springs may deny any proposed transaction, particularly if the transaction poses a conflict of interest or if Rock Springs is planning on transacting in the same security

at or about the same time on behalf of the Funds or any other account managed by Rock Springs. Transactions with respect to healthcare-related securities, public or private, (as determined by Rock Springs) as well as non-healthcare securities held by the Funds in their personal accounts (other than accounts managed by Rock Springs) will be subject to heightened scrutiny and pre-clearance requests may be denied at the CCO’s discretion. Such a situation could provide an incentive for a portfolio manager to trade in a way that would be advantageous to him or her personally but that would not be expected to have a positive effect on (and could even be adverse to) a Fund. Consideration of such matters is a factor in our decision as to whether permission will be granted for any particular transaction. See “Conflicts of Interest” under Item 8 above for additional information. Employees are also required to provide annual reports of holdings and quarterly reports of securities transactions in “Reportable Securities” as defined in the Advisers Act. Employees must disclose all personal trading accounts initially upon commencement of employment and annually thereafter Rock Springs will provide a copy of the Code to any client, Investor or qualified prospective client or Investor upon request. To review a copy of the Code, please contact Rock Springs by telephone at (410) 220-0130.

Selection of Brokers and Dealers Rock Springs has discretion in deciding which securities are bought and sold, the amount and price of those securities, the brokers or dealers to be used for a particular transaction, and commissions or markups and markdowns paid. See Item 16 below regarding investment discretion. In selecting broker-dealers to effect portfolio transactions for the Funds, Rock Springs considers such factors as: the ability to effect prompt and reliable executions at favorable prices (including the applicable dealer spread or commission, if any); the quality of execution, including the operational efficiency with which transactions are effected and the speed of error resolution, taking into account the size of order and difficulty of execution; the financial strength, integrity and stability of the brokerdealer; the quality, comprehensiveness and frequency of research and other related services considered to be of value; the state of the broker-dealer’s facilities and computer trading systems; the quality of a broker-dealer’s confidentiality program; and the competitiveness of commission rates in comparison with other broker-dealers satisfying Rock Springs’ selection criteria. Accordingly, if Rock Springs determines in good faith that the amount of commissions charged by a broker-dealer is reasonable in relation to the value of the brokerage and products or services provided by such broker-dealer, the Funds may pay commissions to such broker-dealer in an amount greater than the amount another broker-dealer might charge for effecting the same transaction. Rock Springs has a Best Execution Committee which meets to evaluate the Funds’ brokerage arrangements. It should be noted that when Rock Springs uses client brokerage commissions to obtain research and related services, Rock Springs receives a benefit because it does not need to produce or pay for the research or other products or services. In addition, Rock Springs has an incentive to select or recommend a broker or dealer based on its interest in receiving the research or other products and services, rather than on the Funds’ interests in receiving best execution. Soft Dollar Benefits Section 28(e) of the Exchange Act provides a safe harbor that allows an investment adviser to pay more

than the lowest available commission in order to obtain brokerage and research services (commonly referred to as a “soft dollar” arrangement). This practice involves a conflict of interest, but Section 28(e) of the Exchange Act provides that it will not constitute a breach of Rock Springs’ fiduciary duty to the Funds if the services and products consist of eligible “research” and “brokerage” services and products and certain other conditions are met. Rock Springs will only use soft dollars to obtain products and services that fall within the safe harbor provided by Section 28(e) of the Exchange Act (provided, that from time to time, broker-dealers provide without being requested to do so, research or other products or services to most or all of their customers and Rock Springs accepts such products or services rather than producing or paying for the same from another provider). Where a product or service provided has both “eligible” uses under Section 28(e) (i.e., uses related to Rock Springs’ investment decision-making process) and other uses, Rock Springs will allocate the cost of any such product or service between the eligible and non-eligible uses in good faith. Only the percentage of the product/service that is used for brokerage/research may be paid with soft dollars. Research and brokerage services obtained by the use of commissions arising from the Funds’ portfolio transactions may be used by Rock Springs in its other investment activities. The Funds may not necessarily, in any particular instance, be the direct or indirect beneficiaries of such research or brokerage services. Because the Feeder Funds invest in Master Funds and all trading occurs at the Master Fund level, any soft dollar benefits that arise from client brokerage commissions paid by a Master Fund will benefit the Master Fund as the trading entity. To the extent that Rock Springs advises more than one entity that generates soft dollar benefits, Rock Springs will not necessarily allocate such benefits to the entities in proportion to the soft dollar benefits each entity generates. Rock Springs seeks to allocate soft dollar benefits in a fair and equitable manner. The types of products and services that Rock Springs received with client brokerage commissions in the past year 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-dealer organized conferences. Investor Introductions Rock Springs may receive introductions to Investors through broker-dealers that execute trades on behalf of Rock Springs. Rock Springs does not believe that it pays any additional fees or higher commissions as a result of these introductions. Rock Springs seeks best execution on all transactions. However, Rock Springs has an incentive to select or use a broker-dealer based on receiving Investor referrals from that counterparty, rather than the Funds’ interest in receiving best execution. Rock Springs will only utilize a broker-dealer if the Best Execution Committee has determined that the arrangement would be in the Funds’ best interest, including considering the factors set forth above in this Item 12. Allocation of Investment Opportunities Rock Springs has established and maintains Allocation Procedures, which it will amend from time to time, that it believes are reasonably designed to assure that investment opportunities which are suitable and determined by Rock Springs to be appropriate for more than one Fund are allocated among such Funds fairly and equitably over time and in a manner that is consistent with applicable law and contractual obligations. The Allocation Procedures do not guarantee that any Fund will invest in each opportunity that would be permissible or that it will invest any particular amount of its assets in an investment opportunity. Rather, Rock Springs evaluates the appropriateness of each investment opportunity that is potentially suitable for more than one Fund (including the relative amount to be allocated among participating Funds) based on Funds’ objectives, policies and restrictions, as well as a

number of other factors specified in the Allocation Procedures and Governing Fund Documents. Allocation decisions sometimes involve subjective determinations by Rock Springs. See “Allocation of Investment Opportunities” in Item 8 above for additional information. Trade Aggregation If Rock Springs determines to buy or sell the same security using the same trading parameters (i.e., market vs. limit order, price, etc.) on behalf of more than one Fund at the same time, Rock Springs will generally, but is not obligated to, place an aggregated order for such accounts consistent with the duty to seek best execution. Where Rock Springs determines to implement a new investment or trading decision for a Fund on a contemporaneous basis, it expects to place such orders on an aggregated basis. Aggregated orders that result in partial fills will be allocated between participating Funds according to the Allocation Procedures. Trade Errors Trade errors may occur as a result of mistakes made on the part of broker-dealers, or mistakes on the part of Rock Springs’ personnel including portfolio managers and traders. Trade errors are an intrinsic factor in any complex investment process, and will occur notwithstanding the exercise of due care and special procedures designed to prevent trade errors. Trade errors are, therefore, distinguishable from errors in judgment, due diligence or other factors leading to a specific trading instruction being generated, as well as from unauthorized trading or other improper conduct by personnel. Trade errors might include, for example, keystroke errors that occur when entering trades into an electronic trading system, failures of oral communication between the portfolio managers and traders or typographical or drafting errors related to derivatives contracts or similar agreements. Rock Springs maintains trade error policies and procedures. In accordance with such policies and procedures, to the extent any trade errors occur, they will be (i) corrected by Rock Springs as soon as practicable after their discovery and (ii) corrected in a manner such that any profit and loss as a result of such trade errors are minimized. Rock Springs will strive to correct all trade errors prior to settlement. Trade errors are considered to be one of the costs of the Funds doing business. Thus, any profit or loss that results from a trade error is left in the account of the applicable Fund. Broker-dealers that cause trade errors as a result of their own mistakes may be responsible for any losses that result from such errors. The applicable Fund shall not be responsible for any losses resulting from trade errors and similar human errors (to the extent not borne by the relevant broker-dealer), absent Rock Springs’ bad faith, gross negligence, willful misconduct or fraud.

Rock Springs does not receive any economic benefits from non-clients in connection with the provision of investment advice to clients. Rock Springs may enter into arrangements with placement agents providing for payments to such agents of a one-time or ongoing fee, including fees based on a percentage of the management fee and/or the incentive compensation. If an Investor is introduced to the Funds through a placement agent, the arrangement, if any, with such placement agent will be disclosed to the Investor in accordance with Rule 206(4)-1 under the Advisers Act.

Neither Rock Springs nor any of its officers, directors, or employees or other management persons, has been involved in any legal or disciplinary events that would require disclosure in response to this Item 9.

The Funds’ portfolios are reviewed on a continuous basis. Rock Springs’ investment personnel under the supervision of the Principals hold regular investment discussions regarding investment ideas, investment strategies, economic developments, current events, and other issues related to current portfolio holdings and potential investment opportunities. In addition, Rock Springs reviews the accounts of the Funds on a monthly basis. During the month-end reconciliation process with the administrator, the finance team is primarily responsible for reviewing the accounts of the Funds. As part of that process, the finance team and the administrator reconcile the portfolios and profits and losses prior to the distribution of net asset value statements to Investors.

Subject to a Fund’s Governing Fund Documents, Investors generally receive (i) monthly performance summaries; (ii) annual audited financial reports; and (iii) annual tax information necessary to complete any applicable U.S. tax returns. Investors in certain Funds may be provided commentary on such Funds’ quarterly performance in quarterly investor letters.

Rock Springs is deemed to have custody of the Funds’ assets because of the authority that Rock Springs and/or its affiliated entities have over those assets. The Funds’ financial statements are subject to an annual audit by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, and the audited financial statements are distributed to each Investor. The audited financial statements are prepared in accordance with generally accepted accounting principles and distributed within 120 days of the Funds’ fiscal year end.

Rock Springs generally has discretionary authority to determine, without obtaining specific consent from the Funds or its Investors, the securities and the amounts to be bought or sold on behalf of the Funds. Any limitations on such authority are included in the respective Fund’s Governing Fund Documents, including with respect to special investments.

Rock Springs has voting authority and responsibility with respect to securities held by the Funds. Rock Springs’ proxy voting policy is overseen and implemented by the Chief Compliance Officer and such other persons as may be appointed from time to time. Institutional Shareholder Services, Inc. (“ISS”) has been retained to assist in the proxy voting process. Specifically, ISS (1) populates each vote based either on ISS’ recommendation or on Rock Springs’ voting instructions and/or (2) automatically submits Fund votes to be counted. Rock Springs has determined that in light of the resources necessary in connection with proxy voting, it is in the Funds’ best interests to rely on the analysis and recommendations of ISS. Accordingly, ISS will generally vote proxies on behalf of the Funds in favor of management proposals, in accordance with ISS’ Proxy Voting Guidelines, available at https://www.issgovernance.com/. In cases where ISS recommends a vote against a management proposal, ISS will notify Rock Springs of the upcoming vote and of the proposal(s) for which ISS is recommending a vote against management. Rock Springs will then request ISS’ research report detailing the reasons for such recommendation(s). Rock Springs evaluates the report to determine whether to accept ISS’ recommendation(s). In the event that Rock Springs decides to vote a proxy (or particular proposals within a proxy) in a manner different from ISS’ recommendation, Rock Springs will document the reasons supporting the decision.

Rock Springs retains ultimate authority with regard to voting client securities and may override ISS’ recommendation or choose to abstain from voting if it determines, in its discretion, that the vote is not in the best interests of the Funds. Rock Springs retains all required documentation associated with proxy voting. Rock Springs has the authority to vote a proxy (or particular proposals within a proxy) contrary to ISS’ recommendation, including in the event of a material conflict of interest. In the event of a material conflict of interest where Rock Springs does not intend to accept ISS’ recommendation with regard to a proxy vote (or one or more proposals within a proxy), Rock Springs’ Proxy Committee (as defined in Rock Springs’ proxy voting policy) will review the particular proxy to determine whether a particular intended vote is in the Funds’ best interests. In addition, Rock Springs requires ISS to notify it if ISS experiences a material conflict of interest in the voting of the Funds’ proxies. If such material conflict of interest occurs, ISS procures independent research relating to such proxy vote and Rock Springs determines the appropriate vote. Rock Springs may abstain from voting client securities if exercising voting authority would impose costs on the Funds, including opportunity costs resulting from restricting the use of securities for lending in order to preserve the right to vote. In general, Rocks Springs believes it is in the Funds’ best interests to abstain from voting client securities that have been lent to third parties, rather than to incur the cost of recalling those securities in order to vote the accompanying proxy. A copy of Rock Springs’ proxy voting policies and procedures and information about how Rock Springs voted proxies may be obtained by contacting Rock Springs at (410) 220-0130.

Not applicable