Rokos Capital Management (US) LP

Operational and Organizational Information Rokos Capital Management (US) LP (“RCM US”) is an investment advisory firm specializing in investment management for private investment funds. RCM US was formed in September 2019. Rokos Services (Singapore) Private Limited (“RCM SG”), a private company limited by shares in Singapore, is licensed with the Monetary Authority of Singapore to conduct fund management. RCM SG was incorporated in June 2021 and received its approval as a Licensed Fund Management Company in February 2023. Rokos Capital CLO Management (US) LP (“RCCM”), a Delaware series limited partnership, is an investment advisory firm that provides discretionary investment advisory services to collateralized loan obligations (“CLOs”), and related warehouse facilities. In this capacity, RCCM acts as collateral manager to CLOs. RCCM was formed in April 2026. Rokos Capital Management (Middle East) Limited (“RCM ME”, and together with RCM US, RCM SG, and RCCM, “RCM”, “we”, or the “firm”), a private company limited by shares in the United Arab Emirates, is licensed with the Abu Dhabi Global Market Financial Services Regulatory Authority to manage assets, advise on investments, arrange deals in investments, and deal in investments as agent. RCM ME was incorporated in November 2025 and received its approval for Financial Services Permission in March 2026. The ultimate principal owner of RCM is Mr. Christopher Rokos. Mr. Rokos is also the ultimate owner of Rokos Capital Management (Jersey) LP (“RCM Jersey”) which serves as a manager to certain of our Clients, and Rokos Capital Management LLP (“RCM LLP”), which acts as investment manager to certain of our Clients and is registered with the SEC as an investment adviser. RCM Jersey, acting as manager of certain of our Clients, has delegated authority to RCM LLP. RCM LLP has delegated responsibility for certain portfolio management activities to each of RCM US, RCM SG, and RCM ME under sub-advisory arrangements. In addition, RCM US provides certain investment advisory services to other Clients and acts as investment manager of RCCM. In this document the “RCM Entities” means each of RCM US, RCM SG, RCCM, RCM ME, RCM Jersey, and RCM LLP. Under these arrangements, RCM US and its relying advisers provide sub-advisory services in relation to pooled investment vehicles managed by RCM Jersey and investment managed by RCM LLP, including but not limited to Rokos Global Macro Master Fund LP and its feeder funds (the “Global Macro Fund”), and RCM Co-Investment Opportunities Limited (the “Co-Invest Fund”). RCM US also serves as the investment manager of certain pooled investment vehicles, such as RCM Private Markets Master Fund LP and its feeder funds (“Directly Advised Clients”). RCCM serves as the investment manager to RCM US CLO 1 Ltd. (“CLO 1”). For purposes of this brochure, “Clients” and “our Clients” refers to the Clients in connection with our sub-advisory arrangement with RCM LLP, Directly Advised Clients managed by RCM US, and to CLOs managed by RCCM. Types of Advisory Services Offered We offer investment advisory services to our Clients. We tailor our investment advisory services to the investment objectives of each Client. These objectives are described in the offering documentation for our private investment fund Clients. We manage the assets of each Client in accordance with the terms of the documents governing our relationship with the applicable Client. The RCM Entities provide investment advice directly to the Clients and not individually to the Clients’ investors. Wrap Fee Programs Our firm does not participate in wrap fee programs.

Regulatory Assets Under Management As of December 31, 2025, RCM US manages $20,195,507,416 of regulatory assets under management for our Clients on a discretionary basis. Regulatory assets under management for the purposes of this Form ADV are calculated as the regulatory assets under management of the Directly Advised Clients, CLOs managed by RCCM and, the portion of the assets of Clients over which we have discretion under the sub-advisory arrangement between each of RCM US, RCM SG, and RCM ME with RCM LLP. While much of this brochure applies to all of our Clients, certain information applies to specific Clients only. Please closely review the applicable governing documents with respect to, among other things, the terms, conditions and risks of investing in a particular Client. This brochure should not be construed as an offer or a solicitation of an offer to purchase an interest in our Clients.

We have intentionally omitted the full section on compensation for advisory services, as we are an SEC registered adviser and this brochure is being delivered only to “qualified purchasers” as defined in Section 2(a)(51)(A) of the Investment Company Act of 1940, as amended. We receive compensation directly and indirectly from our Clients. Sub-Advisory Clients For its management services, RCM Jersey receives compensation, including management, performance, and infrastructure fees, from certain of our Clients. RCM Jersey pays certain compensation, including management, performance, and infrastructure fees and allocations, to RCM LLP in respect of the investment management services it provides to those Clients. RCM LLP pays a fee to each of RCM US, RCM SG, and RCM ME in compensation for the investment advisory services they provide to those Clients pursuant to the sub-advisory arrangement between RCM LLP and each of RCM US, RCM SG, and RCM ME. Other Clients RCM US receives a management fee from certain of our Clients calculated with respect to their assets under management and as agreed between RCM US and these Clients. RCCM receives management fees from its Clients calculated with respect to their assets under management and/or the performance of the Client’s account, as agreed between RCCM and these Clients. RCCM may, in its discretion, waive, reduce, or rebate the management and/or performance fees with respect to the investment of any investor in its CLOs, including the Global Macro Fund. Other Fees and Expenses Other fees and expenses incurred by Clients that are not directly related to our services include, but are not limited to, the following: 

costs and expenses directly related to portfolio investments or prospective investments (whether or not the relevant investment is made), such as brokerage commissions, interest on debit balances or borrowings, research, market data, market data management systems, (including, without limitation, fees of third party consultants for the management, configuration and support of such systems), economic, political or market

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intelligence and other information utilized with respect to a Client’s investment program (including, without limitation, consultants’ fees and expenses, data or software subscriptions or licenses, journals and papers); costs incurred in connection with maintaining a Client and any of its investment subsidiaries, including any administrative, management or other fees (including directors’ fees) incurred in connection with the operation of the Client and its investment subsidiaries; any withholding or transfer taxes imposed on a Client; fees of the independent administrator of each Client and any out-of-pocket expenses of the administrator, including applicable data, communication and technology-related charges, expenses relating to accounting, audit and preparing, printing and distributing financial and other reports and proxy forms, general administration and legal expenses; the costs of acquiring and maintaining Clients’ memberships of relevant exchanges; expenses relating to accounting, audit and communication expenses with respect to investor services, meetings of directors and shareholders of Clients; administration, legal and tax advisory expenses (including where services are provided via subscription services – subscription, license and related support fees) and the fees and expenses of regulatory, tax and other filings, reporting and compliance relating to Clients (for example, without limitation, FATCA/CRS compliance costs, license fees and associated costs incurred in monitoring (and making applicable disclosures of) exchange and other regulatory limits applicable to the Client’s investment positions, or calculating and reconciling the Client’s regulatory initial margin obligations); the costs of any litigation or investigation involving a Client, indemnification and other extraordinary expenses, the insurance (if any) for the benefit of the Client or its directors and obtaining and maintaining any future listing of shares of the Client; any fees and expenses charged by proxy voting, or class action service providers on behalf of the Clients; the licensing and configuration of certain electronic order management systems and software, the costs of developing and maintaining applications to support Clients’ trading strategies (including, without limitation, third party consultants’ fees in respect of such applications and software); the costs and charges of the RCM Entities’ and certain third party consultants’ usage of artificial intelligence, machine learning technology and similar tools, models and systems (collectively, “AI Tools”) provided by third parties, including usage-based input and output “token” charges (or similar) which may be calculated by reference to the volume of data or other content submitted to, or processed or generated by, such AI Tools, in each case to the extent borne by a Client in accordance with its governing documents; any costs associated with and resulting from reporting and providing information to existing and prospective investors of Clients; and costs incurred by the Clients or directly associated with registering or marketing the Client in a particular jurisdiction (including expenses related to international regulatory or tax filings).

The RCM Entities allocate expenses to the Clients that incur them, and to the extent multiple Clients incur expenses in the same transaction, the RCM Entities allocate the expenses among the applicable Clients and the applicable investments of each Client in a fair and equitable manner. All fees or expenses in connection with the use of brokerage services are separate and distinct from the management, infrastructure, and performance fees received by RCM and its affiliates. Please review Item 12: Brokerage Practices below, which discusses conflicts of interest related to brokerage practices and provides additional information on brokerage transactions and costs. For additional details regarding fees and expenses charged to our Clients, please refer to the governing documents of the relevant Client. We do not require Clients to pay any fees in advance. Neither RCM nor any of its supervised persons accepts compensation for the sale of securities or other investment products.

Loss Sub-advisory Clients As described more fully in our Clients’ offering documents, the RCM Entities (including our firm) employ an investment process which primarily uses a combination of macro (economic change and monetary policy), fundamental (bottom-up valuation) and relative value (market inefficiencies) strategies. The underlying philosophy

is to construct strategies, often contingent in nature, with favorable risk/return profiles whose outcome will frequently be crystallized by an expected event or scenario occurring within a pre-determined period of time. The RCM Entities are active in multiple asset classes, including rates, FX, equities, credit, emerging markets, commodities and mortgages across a range of developed and emerging markets. Allocations among these and other asset classes are expected to vary over time, and there are no restrictions on the types of assets or instruments that they may invest in on behalf of these types of Clients. These include, but are not limited to, debt securities and obligations (which may be below investment grade or unrated), credit default swaps, bank loans, listed and unlisted equities, exchange-traded funds, mortgage securities, other collective investment schemes (which may be open-ended or closed-ended, listed or unlisted, may employ leverage and of which the manager or the investment manager may be an affiliate of our firm), currencies, commodities, futures, options, warrants, swaps and other derivative instruments, including event contracts. Derivative instruments may be exchange-traded or traded over-the-counter. We also engage in short sales. Given the nature of the approach of the RCM Entities, the portfolio of these Clients may or may not be invested across a wide range of instruments at any time. Directly Advised Clients As described more fully in our Directly Advised Clients’ offering documents, RCM US seeks to generate riskadjusted returns by investing in global venture-backed companies based in developed markets, at a later stage in their private lifecycles for these types of Clients. RCM US looks at companies that are not expected to face technology or product/product market fit risk and is focused on identifying companies that exhibit high rates of growth and that are predominantly technology or technology enabled businesses. RCM US looks to invest in companies with a strong likelihood of achieving an initial public offering (“IPO”) but may also consider companies that would offer another type of liquidity event, in either case within 24-48 months of investment. CLOs RCCM sponsors, structures and manages CLOs that actively manage a diversified portfolio of senior secured leveraged loans. General Despite the investment analysis and risk management approach of the RCM Entities, investing in these instruments involves a risk of loss that our Clients must be prepared to bear. The RCM Entities do not offer a guaranteed level of risk or return, or any guarantee that the original capital value of any investment will be maintained. There can be no assurance that our investment activities will be successful or that our Clients will not suffer losses. This section describes some of the significant investment strategies and products that we may utilize in advising our Clients, and some of the risks associated with them, which are more fully described in our Clients’ governing documents. The following explanation of risks is not exhaustive. For purposes of this Item 8, we have included strategies and risk factors applicable to our Clients as a result of the investment management and advisory services of the RCM Entities. Availability of Investment Strategies: The success of our Clients’ investment activities depends on our ability to identify investment opportunities as well as to assess the importance of news and events that may affect the financial markets. Identification and exploitation of the investment strategies to be pursued by our Clients involves a high degree of uncertainty. No assurance can be given that we will be able to locate suitable investment

opportunities in which to deploy all of our Clients’ assets or to exploit discrepancies in the securities and derivatives markets. Clearing House Protections: For cleared derivatives, Client transactions are represented at the Clearing House, through client segregated accounts, often provided on a net omnibus basis for all the clients of the clearing broker. Such net omnibus balances would be guaranteed at the Clearing House, but any outstanding balance will be dependent on the solvency of the broker. There is normally no clearing house for off-exchange instruments which are not traded under the rules of a recognized or designated investment exchange other than for off-exchange instruments which are subject to mandatory clearing requirements. Concentration of Investments: Although it is our policy to aim to diversify each Client’s investment portfolios, there may be a substantial correlation between a Client’s positions and the Client may at certain times hold fewer investments. Upon the occurrence of certain market events, a Client’s portfolio could become more correlated. Our Clients could be subject to significant losses if they hold a large position in a particular investment, or correlated positions, that decline in value or are otherwise adversely affected, including by default of the issuer(s). Counterparty Risk: Our Clients may suffer losses if a counterparty to a financial instrument defaults and fails to meet its payment obligations to them. In addition, in certain circumstances, assets of a Client may be utilized in support of trading activities engaged in by the Client with a counterparty and may be deposited with or otherwise held by another third party. In such circumstances, the assets of the Client will also be subject to the risk of such third party, or third party used in connection with transfer agency services, failing to perform its obligations in respect of transactions whether due to insolvency, bankruptcy or other causes. Our Clients use counterparties located in various jurisdictions around the world. Such counterparties are subject to various laws and regulations in various jurisdictions that are designed to protect their customers in the event of their insolvency. However, the practical effect of these laws and their application to the Client’s assets will be subject to substantial limitations and uncertainties. Discretion of the RCM Entities, New Strategies and Techniques: We have considerable discretion in the types of securities, instruments or assets that our Clients may trade and the right to modify the investment or trading strategies or hedging techniques of our Clients without the consent of their investors. Any of these new trading techniques of our Clients may not be thoroughly tested in the market before being employed and may have operational shortcomings which could result in unsuccessful trades and, ultimately, losses to our Clients. In addition, any new trading strategies or hedging technique developed by the RCM Entities may be more speculative than earlier techniques and may increase the risk of an investment in our Clients. Emerging Markets: Investment in emerging market securities involves a greater degree of risk than an investment in securities of issuers based in developed countries. Among other things, emerging market securities investments may carry the risks of less publicly available information, more volatile markets, less strict securities market regulation, less favorable tax provisions, and a greater likelihood of severe inflation, unstable currency, war, nationalization of assets, and expropriation of personal property than investments in securities of issuers based in developed countries. In addition, a Client’s investment opportunities in certain emerging markets may be restricted by legal limits on foreign investment in local securities. Emerging markets generally are not as efficient as those in developed countries. In some cases, a market for the security does not exist locally, and transactions will need to be made on a neighboring exchange. Volume and liquidity levels in emerging markets are lower than in developed countries. When seeking to sell emerging market securities, little or no market may exist for the securities. In addition, issuers based in emerging markets are not generally subject to uniform accounting and financial reporting standards, practices and requirements comparable to those applicable to issuers based in developed countries, thereby potentially increasing the risk of fraud or other deceptive practices. Furthermore, the quality and reliability

of official data published by the government or securities exchanges in emerging markets may not accurately reflect the actual circumstances being reported. Epidemics, Pandemics, and Other Catastrophic Events: Epidemics, pandemics and other catastrophic events (such as natural disasters, war, civil disturbance and acts of terrorism), and related government responses (such as quarantines, travel restrictions and shutdowns), can disrupt global supply chains, economic activity and financial markets, causing volatility and reduced liquidity. They may also disrupt the operations of the RCM Entities and their service providers, restrict our ability to value Clients’ investments, and adversely affect the calculation of Clients’ net asset values. They may lead to margin calls or require our Clients to repay indebtedness or other financial obligations early, which could force the sale of assets and result in the loss of invested capital and anticipated profits. No previous success by the RCM Entities in dislocated markets is any guarantee of our Clients’ success in investing in, and managing, any investment during or after an epidemic or pandemic. Exchange Protections: On many exchanges, the performance of a transaction by a broker (or third party with whom it is dealing on a Client’s behalf) is “guaranteed” by the exchange. However, this guarantee is unlikely in most circumstances to cover a Client and may not protect a Client if a broker or another party defaults on its obligations to a Client. General Economic and Market Conditions: The success of our Clients’ activities will be affected by general economic and market conditions, such as interest rates, availability of credit, inflation rates, economic uncertainty, changes in laws, trade barriers, currency exchange controls and national and international political circumstances. These factors may affect the level and volatility of securities prices and the liquidity of our Clients’ investments. Volatility or illiquidity could impair our Clients’ profitability or result in losses. Illiquid Investments: We may make investments for our Clients that due to legal or other restrictions suddenly become illiquid. The market prices, if any, of illiquid investments tend to be more volatile and it may not be possible to sell such investments when desired or to realize their fair value in the event of a sale. Moreover, securities in which our Clients may invest include those that are not listed on a stock exchange or traded in an over-the-counter market. As a result of the absence of a public trading market for these securities, they may be less liquid than publicly traded securities. There may be substantial delays in attempting to sell non-publicly traded securities. Although these securities may be resold in privately negotiated transactions, the prices realized from these sales could be less than those originally paid. Further, companies whose securities are not publicly traded are not subject to the disclosure and other investor protection requirements that would be applicable if their securities were publicly traded. Investments may be Difficult to Liquidate: The market for our Clients’ portfolio investments may be limited and there may be certain restrictions on a Client’s ability to liquidate its investments on a timely basis at a reasonable value. A Client may have to sell, distribute or otherwise dispose of one or more of its investments at a disadvantageous time if it is able to do so at all. As a result, a Client may sell, distribute or otherwise dispose of one or more of its investments for a price which is less than the price that could have been obtained if the investments were held for a longer period of time. Conversely, a Client may not be able to dispose of certain of its assets for a substantial period of time. Investment Management Risk: The investment performance of our Clients is wholly dependent on the services of certain members of, and/or individuals employed by the RCM Entities. In the event of the death, disability, departure, insolvency or withdrawal of any of these individuals, the performance of our Clients may be adversely affected. There can be no assurance that we would be able to mitigate the effects of the loss of any such individuals. Legal and Regulatory Change: Market disruptions over recent years, significant financial events and the increase in investment vehicles have led to increased scrutiny and regulation over the hedge fund and asset management

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As described in Item 4: Advisory Business, our Clients are private investment funds managed by RCM Jersey and investment managed by RCM LLP (for which RCM US, RCM SG and RCM ME act as sub-advisers), private investment funds that RCM US advises directly, and CLOs for which RCCM acts as investment manager. We determine in our sole discretion any requirements for entering into an investment advisory contract with a Client, including whether a private fund is large enough to implement its desired investment program.

As described in Item 5: Fees and Compensation above, the RCM Entities receive part of their compensation from certain Clients in the form of performance-based compensation, and certain of our investment personnel may receive a portion of performance-based compensation from time to time. This may create an incentive to make investments for our Clients that are riskier than would be the case in the absence of performance-based fees. The RCM Entities receive performance-based fees on realized and unrealized gains from certain Clients. The RCM Entities also have differing compensation arrangements with certain Clients, which may create an incentive to allocate investment opportunities to Clients from whom we receive more compensation. However, RCM Entities will generally seek to mitigate the resulting conflict by allocating investment opportunities on an equitable basis between Clients with a similar strategy or structure where investing opportunities for each of the Clients coincide simultaneously. Equitable allocation may be determined on the basis of proportionality to the size of each Client’s strategy in respect of that position, or based on the Client’s prevailing net asset value, depending on which measure is more appropriate to that process, as determined solely in the discretion of the RCM Entities. In certain circumstances, the RCM Entities may request that a Client’s administrator use a certain third party valuation source to value an investment held by a Client. Any involvement by the RCM Entities in the valuation process may create a conflict of interest due to that RCM Entity’s receipt of performance-based fees. We have designed and implemented procedures to identify and mitigate potential conflicts of interest including those with respect to the allocation of investment opportunities or the valuation of assets. Specifically, the RCM Entities address any potential future conflicts of interest relating to varying fee arrangements by adhering to a trade allocation policy, which sets forth objective factors for determining how to allocate investment opportunities among our Clients.

Neither RCM nor any of its management persons is registered, or has an application pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, a commodity trading advisor, or is an associated person of any of the foregoing entities. RCM LLP is authorized and regulated with the U.K. Financial Conduct Authority as an alternative investment fund manager and is registered as an investment adviser with the SEC. RCM SG, an affiliate of RCM US and RCM LLP, is licensed with the Monetary Authority of Singapore to conduct fund management. RCM ME is licensed with the Abu Dhabi Global Market Financial Services Regulatory Authority to manage assets, advise on investments, arrange deals in investments, and deal in investments as agent. RCM Jersey, which is licensed and regulated by the Jersey Financial Services Commission to conduct fund services business under the Financial Services (Jersey) Law 1998, serves as the manager of certain of our Clients and delegates to RCM LLP all of its authority to provide investment advisory services to those Clients. RCM LLP and each of RCM US, RCM SG, and RCM ME have entered into a sub-advisory arrangement pursuant to which RCM LLP has delegated responsibility for certain portfolio management activities to RCM US, RCM SG, and RCM ME, respectively. RCM Jersey generally receives compensation, including management, infrastructure, and performance fees and allocations from these Clients. RCM Jersey pays certain compensation, including management, infrastructure and performance fees to RCM LLP in consideration of the investment advisory services it provides to these Clients. RCM LLP pays a fee to each of RCM US, RCM SG, and RCM ME in compensation for the investment advisory services they provide to these Clients pursuant to the sub-advisory arrangement between RCM LLP and each of RCM US, RCM SG, and RCM ME respectively. Our investment personnel may receive a portion of performancebased compensation from time to time.

Please see Item 5: “Fees and Compensation” for further information. The relationship between the RCM Entities does not create a material conflict of interest with our Clients. RCM Jersey and its affiliates sponsor certain of the Clients that we manage. Rokos Global Macro (GP) Limited and Rokos Private Markets (GP) Limited (together, the “General Partners”), affiliates of RCM US, serve as the general partner to certain of our Clients that are limited partnerships. The General Partners and our Clients have independent boards of directors. Prospective investors of the Clients receive disclosure of the terms of all fees and performance-based compensation charged to Clients, as well as the other terms of investment, in the offering documents for each Client. We do not recommend or select other investment advisers for our Clients.

Transactions and Personal Trading Code of Ethics RCM has adopted a Code of Ethics to:  set forth standards for ethical conduct of our professionals;  address conflicts of interest; and  promote compliance with applicable legal and regulatory requirements. The key policies under our Code of Ethics are as follows:  our employees must comply with certain restrictions on personal trading, including preclearance of certain transactions, and must report personal securities transactions;  our employees must not trade for personal accounts ahead of our Clients;  our employees must abide by our insider trading policies; and  our employees must avoid taking advantage of their position of employment by accepting investment opportunities, gifts or other gratuities from individuals seeking to conduct business with RCM, other than in accordance with our gifts and entertainment policy. The personal trading restrictions, preclearance requirements and reporting requirements contained in the Code of Ethics are intended to reduce certain conflicts of interest that may arise between our Clients and the personal trading activities of our employees. Personal securities transactions (with certain exceptions, such as units or shares in open-ended mutual funds) are subject to preclearance by the RCM Entities. Generally, our employees are prohibited from personal trading in securities held or traded by our Clients, except in certain circumstances where personal positions are small. Reports of personal trading activity are monitored by Compliance. Although RCM Entities advise multiple Clients, we engage in cross trades only when exceptional circumstances arise. In the event of any proposed transactions with or between Clients, we endeavor to conduct all cross trades on a fair and equitable basis between the relevant Clients. In order to address any potential conflicts of interest, the RCM Entities record evidence to show that both sides of the trade are in the best interests of the participating Clients, prior to execution. The price achieved must support the case that the Clients involved were treated fairly

and equitably under the circumstances. In transparent markets this is likely to be the market mid point for the security. In non-transparent markets the transaction must be executed at a price derived, following reasonable inquiry, from independent market data such as reported transactions, independent dealer quotes or bona fide offers in an active secondary market. In addition, RCM and individuals associated with our firm are generally not permitted to engage in principal transactions. A principal transaction is a transaction where RCM or a person associated with RCM, as principal, buys securities from, or sells securities to, a Client. The Chief Compliance Officer must be notified of any proposed principal transaction involving a Client and must provide approval before the principal transaction is affected. Prior to the settlement of any principal transaction, RCM must obtain any affected Client’s informed written consent to the transaction. Any prospective Client, any Client or any investor in our Clients may receive a copy of our Code of Ethics by submitting a written request to RCM at the mailing address or email address listed on the front page of this document, marked for the attention of the Chief Compliance Officer of RCM US.

In placing portfolio transactions for our Clients, we seek to obtain best execution for Clients’ accounts, taking into account the following execution factors: price, cost, speed, size and nature of the transaction, likelihood of execution and settlement, broker’s financial strength, stability and reputation, operational efficiency, and any other consideration relevant to the execution of the order. The firm maintains a process for monitoring delivery of best execution by its brokers and dealers and reviews broker selection periodically and at least on a quarterly basis. While RCM does not currently maintain any formal soft dollar arrangements, we transact with multiple executing and prime brokers, some of whom provide us with proprietary research in exchange for executing client transactions. This presents a conflict of interest in selecting such brokers, as it may cause RCM to select a broker based on the research received rather than on the relevant Client’s interest in receiving the most favorable execution. RCM has established internal review processes in an attempt to mitigate this conflict. Additionally, research received will generally be used to service all RCM Clients. Research services include, among other things: market, economic or financial data; a particular aspect of economics or on the economy in general; statistical information; data on pricing and availability of securities; financial publications; electronic market quotations; analyses concerning specific securities, companies, industries or sectors; and market, economic and financial studies and forecasts. If we were to engage in formal soft dollar arrangements, any services and/or products obtained by us as a result of transactions that are executed on an agency basis (or, in certain circumstances, a “riskless principal” basis) generally would be expected to qualify for the safe harbor provided by Section 28(e) of the U.S. Securities Exchange Act of 1934, as amended. However, any services and/or products obtained by us as a result of transactions that are executed on a “principal basis” (e.g., transactions in futures, fixed income and asset-backed securities) generally would be expected to fall outside such safe harbor. The prime brokers to our Clients provide front and back office services, including the provision of financing, execution, clearing, settlement, reporting, securities lending and foreign exchange facilities, among other services. Subject to applicable law, the prime brokers may also provide RCM with capital introduction services.

From time to time, our personnel may speak at conferences and programs for potential investors interested in investing in hedge funds which are sponsored by prime brokers. These conferences and programs may be a means by which we can be introduced to potential investors for our Clients. Currently, neither RCM nor our Clients compensate prime brokers for organizing such “capital introduction” events or for any investments ultimately made by prospective investors attending such events (although they may do so in the future). While such events and other services provided by a prime broker have the capacity to influence us in deciding whether to recommend the use of such prime broker in connection with brokerage, financing and other activities of our Clients, we will not commit to allocate a particular amount of brokerage to a broker-dealer in any such situation and the brokerage services of such prime broker will always be subject to the best execution review as all other broker services, which is not permitted to take into account capital introduction services. We do not routinely recommend, request or require our Clients to direct us to execute transactions through a specified broker-dealer, or permit our Clients to make such directions.

RCM does not, nor do any of its members, officers or employees, receive any economic benefit from non-Clients for providing services to our Clients. RCM does not, nor do any of its members, officers or employees, directly or indirectly compensate any person that is not a supervised person for referrals of Clients in any fund advised by RCM. RCCM is permitted to pay (and from time to time has paid) placement fees and certain expenses to certain brokerdealers, acting as placement agents that solicit investors for CLOs, as described in the offering documents of the relevant CLOs. These fees and expenses are negotiated on a case by case basis and are addressed in the relevant CLO’s offering documents.

There are no legal or disciplinary events that are material to an existing or prospective Client’s evaluation of RCM’s advisory business or the integrity of its management.

The investments of our Clients are managed in accordance with the investment objectives and approach applicable to our Clients. The investment strategies applied by RCM on behalf of our Clients are implemented by its investment personnel who regularly review the portfolio for each Client to ensure that it is managed in accordance with the applicable investment objectives and approach. In addition, the portfolio of each of our Clients is reviewed on a regular basis, according to the requirements of the Client by the risk team of the RCM Entities. With respect to our sub-advisory Clients, our risk team monitors various measures, guidelines, and flags, including “value at risk” measures, Greek measures and drawdown guidelines. A number of risk flags have been implemented to indicate whether our traders are taking large risk positions relative to the risk target of such Clients. Ultimate risk oversight for the portfolio of such Clients is the responsibility of the Chief Risk Officer of the RCM Entities and a team of dedicated risk specialists. The RCM Entities also operate a Risk Committee which reviews current risk and positions on at least a monthly basis. During these meetings the attendees review fund level market, credit, counterparty and liquidity risk. The portfolios of CLO 1 and our Directly Advised Clients are reviewed from a risk perspective on a quarterly basis. Content and Frequency of Account Reports The RCM Entities prepare periodic risk reports and investor letters and communications, as appropriate, for our Clients and their investors. Generally, investor communications are provided on a monthly basis. An annual audited financial report is also provided to investors in relation to our Clients. Our Clients are subject to financial audit by independent public auditors. Audited financial statements are delivered to investors in our Clients within 120 days of the end of the fiscal year.

While we do not have physical custody of our Clients’ funds, we are deemed under Rule 206(4)-2 of the Investment Advisers Act of 1940, as amended, to have custody of the Clients’ funds as a result of our affiliates, including RCM LLP, being deemed to have custody due to (i) their access to Clients and authority to instruct the administrator to deduct fees and other expenses from a Client’s account and (ii) services provided by our affiliates, including as general partners of certain of our Clients. The RCM Entities utilize the services of banks or other qualified custodians (as defined under Rule 206(4)-2) to hold all assets of these fund Clients. The RCM Entities also endeavor where reasonably possible to ensure that the qualified custodians maintain these funds in accounts that contain only Clients’ funds and securities, under the Client’s name or our name as agent or trustee for the Clients. While Rule 206(4)-2 generally requires an investment adviser to ensure that a qualified custodian sends account statements to fund Clients at least quarterly, we are not subject to this requirement because all our Clients are subject to audit at least annually by an independent auditor that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board. In these cases, we expect that audited financial statements will be distributed to all investors in our Clients within 120 days of the end of the fiscal year of the relevant Client.

Except with respect to the Co-Invest Fund, RCM has discretionary authority to determine, without obtaining specific Client consent from our Clients or their investors, which securities to buy or sell and the amount of securities to buy or sell. Despite this broad authority, RCM is committed to adhering to the investment objectives and program set forth in each of the governing documents for our Clients. Pursuant to the sub-advisory agreement with RCM LLP, each of RCM US, RCM SG, and RCM ME has authority to carry out certain investment advisory services with respect to certain Clients’ assets in accordance with their investment objectives and program. Pursuant to an investment advisory agreement, RCM US has authority to carry out investment advisory services with respect to certain other Clients’ assets in accordance with their investment objectives and program. Pursuant to an investment advisory agreement, RCCM has authority to carry out investment advisory services with respect to CLO 1 in accordance with its investment objectives and program.

RCM has the authority to vote proxies relating to securities in Client accounts. All proxies that RCM receives will be treated in accordance with our policies and procedures for voting Client proxies. RCM employs an independent firm that analyses proxies and provides research and objective vote recommendations for individual proxy matters. The independent firm assists with the due diligence process related to making appropriate proxy voting decisions, while RCM utilizes the proxy voting service provider to facilitate the voting process and assist with recordkeeping with respect to how we voted on proxies. RCM maintains a record of all proxy votes cast on behalf of the Clients. RCM attempts to identify any conflicts of interests prior to voting proxies. If a material conflict of interest is identified in voting a proxy, RCM has policies and procedures in place to determine the appropriate vote. RCM will generally seek to vote all proxies for portfolio securities held by its Clients, however in certain circumstances RCM may abstain if it deems it is in the best interests of its Clients. For example, RCM may be unable to vote securities that have been lent by a custodian or prime broker. In addition to maintaining the authority to vote the proxies of any investments in the portfolios that it manages for our Clients, RCM may also decide to vote on corporate actions such as restructurings, bankruptcy reorganizations and mergers, and similar events related to our Clients’ debt (and other) investments where we believe that the subject matter of such corporate action may be material to a Client’s account. Clients and investors of Clients may not direct RCM to vote in a particular way for a particular solicitation. A copy of RCM’s proxy voting policy and procedures, and information about how we voted securities in a particular proxy vote, if applicable, is available to Clients upon request. RCM US’s Chief Compliance Officer will document any potential material conflict of interest, together with our final determination regarding the same, and may consult with outside counsel or other third parties regarding the potential conflicts. With respect to class actions, RCM has engaged a third party that monitors and files for any class action recoveries in respect of litigation entitlements of Clients. The third party provider has been engaged on an “opt-out” basis as it is generally RCM’s policy to participate in recoveries related to securities and anti-trust class actions. The provider is responsible for filing all necessary claim forms on behalf of our Clients and to assist with the recovery of settlement process. RCM has not acted as a lead plaintiff with respect to such actions and does not currently anticipate doing so.

RCM does not require or solicit prepayment of fees in advance of services rendered. RCM is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to its Clients. RCM has never been the subject of a bankruptcy petition.

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