RUSH ISLAND MANAGEMENT, LP

A. RIM is a Delaware limited partnership formed in April 2017 to provide investment advisory services. RIM maintains its principal place of business in New York, New York and is principally owned by Stephen Millham and Raleigh Nuckols. B. RIM manages investment portfolios with an objective to seek to achieve value by taking long and short positions in assets that consist primarily of publicly traded real estate and real estate-related securities. RIM generally invests in public equities but may also invest in corporate credit, preferred securities, options, CMBS, derivatives, and other securities that have a significant exposure to real estate. C. RIM provides discretionary investment advisory services to pooled investment vehicles organized as private funds (the “Fund”, the “Funds”) and tailors its advisory services to the respective investment objectives set forth in the applicable Fund’s Offering Documents (defined below) and governing documents. RIM’s current Fund clients include a family of private investment funds operating through a “master-feeder” structure (the “Primary Fund”) and a special purpose vehicle, RIM Co1, LP, which was created in 2024 to provide a single co-investment alongside the Primary Fund (the “SPV”). The Primary Fund includes the following entities:   

Rush Island Master, LP, a Cayman Islands exempted limited partnership (the “Master Fund”); Rush Island, LP, a Delaware limited partnership (the “Onshore Feeder”); and Rush Island Offshore, Ltd, a Cayman Islands exempted company (the “Offshore Feeder”).

Entities affiliated with RIM serve as the general partner of certain of the Funds. More specifically, Rush Island GP, LLC (“Primary Fund GP”), serves as the general partner of the Master Fund and the Onshore Feeder Fund, while RIM Co1 GP, LLC (“SPV GP”) serves as the general partner of the SPV. RIM generally does not, however, provide individualized investment advice to investors in the Funds (“Investors”). Nonetheless, RIM reserves the right to enter into additional agreements with certain Investors (“Side Letters”) that alter, supplement, or provide terms and conditions that are more advantageous than those set forth in the respective Fund’s governing documents. RIM also provides its services to one or more separately managed accounts (“SMA”, collectively with the Funds, “Clients”). Such services are tailored to the SMA as described in their investment management agreement (“IMA”). D. RIM does not participate in wrap-fee programs.

E. RIM has $2,018,851,000 in discretionary regulatory assets under management as of December 31, 2025. Investors should review not only this brochure but also the full content of the applicable offering materials (collectively “Offering Documents”) for any Fund in which they are considering investing. This brochure is intended to be a general summary of advisory services provided by RIM to its general client base. This brochure may be both supplemented and superseded by the Offering Documents for each Fund.

A. RIM typically charges fees that are based upon a set percentage of assets under management and performance. In consideration for investment management services provided to the Funds, RIM generally receives a management fee and the respective general partner is generally eligible to receive an incentive allocation. The fee rates are dependent upon which Fund and which series of interest an investor is invested. Fees applicable to the SMA are individually negotiated with the underlying investor and are documented in the terms of the IMA. B. RIM typically receives from investors in the Primary Fund a management fee calculated at an annual rate dependent upon which series of interest an Investor is invested. The management fee is calculated and payable quarterly in advance based on the value of each Investor’s account as of the first day of each calendar quarter, or on the date of a contribution if other than the beginning of a quarter. RIM deducts the management fee directly from each Investor’s account. The management fees for different series of interest in the Funds ranges from 0% - 1.5% per annum. In the case of a withdrawal or redemption by an Investor other than as of the last day of a fiscal quarter, a pro rata portion of the management fee shall be distributed to the withdrawing or redeeming Investor. In addition, the Primary Fund GP is eligible to receive an annual incentive allocation reallocated from the capital accounts of each Primary Fund Investor in an amount specific to the series of interest to which the Investor is subscribed. The incentive allocation is calculated based on an Investor’s realized and unrealized return subject to a loss carryforward provision as described in the respective Fund’s Offering Documents. If an Investor withdraws capital, the incentive allocation would be “crystallized,” meaning that it will be deducted from the Investor’s account and reallocated to the Primary Fund GP as if the withdrawal date were the last day of the fiscal year or, in the case of a loss carryforward, the loss carryforward will be subject to reduction on a pro rata basis. The incentive allocation for different series of interest of the Primary Fund ranges from 0% - 20% per annum. With respect to the SPV, RIM does not charge Investors a management fee, however, the SPV GP is eligible to receive an incentive allocation reallocated from the capital accounts of each SPV Investor in an amount of up to 10% of net profits in excess of a hurdle rate. Generally, the incentive allocation accrues monthly and is “crystallized”, meaning it is calculated and allocated to the SPV GP, when an Investor makes a partial or full redemption. The management fee and incentive allocation are negotiable in that RIM, in its sole discretion, can waive, modify or calculate different such fees for certain Investors including those who

are members, principals, employees, or affiliates of RIM or the general partners, relatives of such persons, and for certain large or strategic Investors. Other clients, such as the SMA, are typically also charged a management fee and an incentive allocation at individually negotiated rates as described in the respective IMAs. Management fees for other clients are generally collected quarterly in arrears while the incentive allocation is typically collected annually in arrears. However, fees may be charged in arrears or in advance depending upon the terms of the specific governing documents. In the event that fees are charged in advance, RIM will ensure that at the point of redemption no client is charged a fee for a time period in which they were not invested. C. The Funds generally bear their own operating expenses as more fully described in each Fund’s Offering Documents. These expenses may include but are not limited to Fund administration, research, audit, tax, fund organizational expenses, and others. Please see the relevant Offering Documents for a more complete listing of a Fund’s potential expenses. Investors will also indirectly incur brokerage and other transaction costs related to their investments that are in addition to the advisory fees payable to RIM. Please see Item 12 of this brochure for a more detailed discussion of RIM’s brokerage practices. Subject to the terms of the applicable IMA, SMAs are typically responsible for all operating expenses in connection with the management of their respective accounts. RIM renders its services to Clients at its own expense and will be responsible for overhead expenses including office rent; utilities; furniture and fixtures; stationery; secretarial/internal administrative services; salaries and bonuses; entertainment expenses; employee insurance and payroll taxes. D. As discussed above, if for some reason an investment in a Fund is withdrawn or redeemed prior to the expiration of a period in which the Investor has pre-paid fees, RIM would typically rebate the fees for the period of time during which the Investor was not invested. E. At this time neither RIM nor any of its supervised persons accept compensation for the sale of securities or other investment products. It is very important that Investors refer to their respective Fund’s Offering Documents for a complete understanding of how RIM is compensated for its advisory services. The information contained herein is a summary only and is qualified in its entirety by the relevant Offering Documents.

WHO HAVE A LIMITED NEED FOR LIQUIDITY IN THEIR INVESTMENT IN THE FUND. THERE CAN BE NO ASSURANCE THAT RIM WILL ACHIEVE ITS INVESTMENT OBJECTIVE ON BEHALF OF ANY CLIENT, INCLUDING ANY FUND. A. RIM uses fundamental, bottom-up analysis to identify what it considers to be undervalued or overvalued investment opportunities and to capture fundamental valuation disparities in the market for publicly traded real estate related assets on behalf of Clients. RIM believes that over 80% of real estate in the United States is owned in the private market, and the private market correspondingly sets real estate values. Securities in the public

markets may exhibit greater volatility than the underlying private market real estate values. The long track record of RIM personnel in both the private and public real estate related opportunities gives RIM a great deal of expertise in identifying, underwriting, and monitoring public real estate related investments. RIM believes that investing via a long/short opportunistic structure is an underpenetrated strategy in this niche sector. The objective of RIM is to seek to achieve value for Clients by taking long and short positions in a portfolio that consists primarily of publicly traded real estate and related securities. RIM will generally invest in public equities on behalf of Clients, however, RIM may also make investments in corporate credit, preferred securities, options, CMBS, derivatives, and any securities that have a significant exposure to real estate. While it is anticipated that RIM will invest primarily in equities, equity-related securities, and debt securities on behalf of Clients, RIM generally holds broad and flexible investment authority. Accordingly, investments made for Clients may at any time include, without limitation, long or short positions in U.S. or non-U.S. publicly-traded or privately issued common stocks, preferred stocks, stock warrants and rights, convertible securities, restricted securities, futures, swaps (including credit default swaps and total rate of return swaps), “custom baskets,” options (purchased or written), bonds and other fixed income securities, partnership interests and other securities or financial instruments including those of investment companies. RIM may also purchase put and call options, write uncovered put and call options and invest in bonds or other fixed income securities on behalf of Clients, when deemed appropriate. In addition, RIM may invest in spot foreign exchange, foreign exchange deliverable and non-deliverable forward contracts, commodity investments, derivatives, and other “over-the-counter” instruments on behalf of Clients. RIM may also invest in New Issues on behalf of Clients, provided that the Client first complies with all of the rules and regulations pertaining to such investments, including applicable FINRA Rules. B. The following risks should be carefully evaluated before making an investment in any Fund. These risk factors may be supplemented and or superseded by each Fund’s Offering Documents. Potential Investors are reminded to review the applicable Fund’s Offering Documents prior to investing. Risk Factors An investment in a Fund involves significant risks and is suitable only for those persons who can bear the economic risk of the loss of their entire investment, who have limited need for liquidity in their investments, and who have met the conditions set forth in the offering document for any Fund in which they plan to invest. There can be no assurances that RIM will achieve its investment objectives for Clients. An investment managed by RIM carries with it the inherent risks associated with investments in equities, equity-related securities, debt, the use of short sales, and leverage. Nature of Investments RIM typically has broad discretion to make investments for Clients. Investments will generally consist of equities; equity-related securities; debt securities; options; commodity instruments

and derivatives; and other assets that may be affected by business, financial market or legal uncertainties. There can be no assurance that RIM will correctly evaluate the nature and magnitude of the various factors that could affect the value of and return on investments. Prices of investments may be volatile and a variety of factors that are inherently difficult to predict, such as domestic or international economic and political developments, may significantly affect the results of RIM’s activities and the value of its investments. In addition, the value of each Fund’s portfolio may fluctuate as the general level of interest rates fluctuates. No guarantee or representation is made that RIM’s investment objective will be achieved. Equity-Related Instruments in General RIM may use equity-related instruments in its investment program. Certain options and other equity-related instruments may be subject to various types of risks, including market risk, liquidity risk, counterparty credit risk, legal risk, and operations risk. In addition, equity-related instruments can involve significant economic leverage and may, in some cases, involve significant risks of loss. Debt Securities RIM may take positions in debt securities for Clients which (may or may not) rank junior to other outstanding securities and obligations of an issuer, all or a significant portion of which may be secured on substantially all of an issuer’s assets. RIM may take positions in debt securities which are not protected by financial covenants or limitations on additional indebtedness. RIM may invest in securities which are moral obligations of issuers or subject to appropriations. RIM will therefore be subject to credit and liquidity risks. Credit Risks and Interest Rate Risks Debt investments are subject to credit and interest rate risks. Credit risk refers to the likelihood that an issuer will default in the payment of principal and/or interest on an instrument. Financial strength and solvency of an issuer are the primary factors influencing credit risk. Interest rate risk refers to the risks associated with market changes in interest rates. Generally, the value of fixed-income securities changes inversely with changes in interest rates. As interest rates rise, the value of fixed-income securities tends to decrease. Conversely, as interest rates fall, the market value of fixed-income securities tends to increase. This risk is greater for long-term securities than for short-term securities. Real Estate Industry and REIT Risks On behalf of Clients, RIM will invest primarily in securities with a connection to the real estate industry and, therefore, may be subject to risks associated with the direct ownership of real estate, such as decreases in real estate values, overbuilding, increased competition, and other risks related to local or general economic conditions, increases in operating costs and property taxes, changes in zoning laws, casualty or condemnation losses, possible environmental liabilities, regulatory limitations on rent, and fluctuations in rental income. Equity real estate investment trusts (“REITs”) generally experience these risks directly through fee or leasehold interests, whereas mortgage REITs generally experience these risks indirectly through mortgage interests, unless the mortgage REIT forecloses on the underlying real estate.

REITs in which RIM invests on behalf of Clients may be affected by changes in underlying real estate values, which may have an exaggerated effect to the extent that REITs in which RIM invests may concentrate investments in particular geographic regions or property types. Additionally, rising interest rates may cause investors in REITs to demand a higher annual yield from future distributions, which may in turn decrease market prices for equity securities issued by REITs. Rising interest rates also generally increase the costs of obtaining financing, which could cause the value of RIM’s investments for clients to decline. During periods of declining interest rates, certain mortgage REITs may hold mortgages that the mortgagors elect to prepay, which prepayment may diminish the yield on securities issued by such mortgage REITs. In addition, mortgage REITs may be affected by the ability of borrowers to repay when due the debt extended by the REIT, and equity REITs may be affected by the ability of tenants to pay rent. Certain REITs have relatively small market capitalizations, which may tend to increase the volatility of the market price of securities issued by such REITs. Furthermore, REITs are dependent upon specialized management skills, have limited diversification and are, therefore, subject to risks inherent in operating and financing a limited number of projects. REITs depend generally on their ability to generate cash flow to make distributions to investors. REITs and real estate in general currently enjoy a favorable tax status, which may change in the future. Commercial Mortgage-Backed Securities RIM may invest in commercial mortgage-backed securities (“CMBS”) on behalf of Clients. Commercial mortgage loans underlying CMBS are generally secured by income-producing property, such as multifamily housing or commercial property, and may entail risks of delinquency and foreclosure, and risk of loss in the event thereof, that are greater than similar risks associated with loans secured by one- to four-family residential property. If the net operating income of the property underlying the CMBS is reduced (for example, if rental or occupancy rates decline or real estate tax rates or other operating expenses increase), the borrower’s ability to repay the loan may be impaired. CMBS may be backed by an underlying mortgage pool of only a few mortgage loans, or mortgage loans secured by properties in only a few states or regions. As a result, each commercial mortgage loan in the underlying mortgage pool represents a large percentage of the principal amount of CMBS backed by such underlying mortgage pool. In addition, the mortgage loans may be more susceptible to geographic risks relating to the areas in which the underlying properties are located. A failure in performance of any one commercial mortgage loan in the underlying mortgage pool will have a much greater impact on the performance of the related CMBS. Short Sales Short sales can, in certain circumstances, substantially increase the impact of adverse price movements on a Client’s portfolio. A short sale involves the risk of a theoretically unlimited increase in the market price of the particular investment sold short, which could result in an inability to cover the short position and a theoretically unlimited loss. There can be no assurance that securities necessary to cover a short position will be available for purchase.

Options The purchase or sale of an option involves the payment or receipt of a premium by the investor and the corresponding right or obligation, as the case may be, to either purchase or sell the underlying security, commodity or other instrument for a specific price at a certain time or during a certain period. Purchasing options involves the risk that the underlying instrument will not change price in the manner expected, so that the investor loses its premium. Additionally, the premium paid for an option is based, in part, on the time to expiration, and with the passage of time, the premium associated with an option declines, assuming all other factors being equal. Selling options involves potentially greater risk because the investor is exposed to the extent of the actual price movement in the underlying security rather than only the premium payment received (which could result in a potentially unlimited loss). Over-thecounter options also involve counterparty solvency risk. Use of Leverage RIM may utilize leverage. This may result in a Client controlling substantially more assets than such Client has equity. Leverage may increase a Client’s returns if the Client earns a greater return on investments purchased with borrowed funds than such Client’s cost of borrowing such funds. However, the use of leverage exposes a Client to additional levels of risk, including (i) greater losses from investments than would otherwise have been the case had the Client not borrowed to make the investments, (ii) margin calls or interim margin requirements which may force premature liquidations of investment positions and (iii) losses on investments where the investment fails to earn a return that equals or exceeds such Client’s cost of borrowing such funds. In the event of a sudden, precipitous drop in the value of a Client’s assets, such Client might not be able to liquidate assets quickly enough to repay its borrowings, further magnifying its losses. In an unsettled credit environment, RIM may find it difficult or impossible to obtain leverage for Clients. In such event, RIM could find it difficult to implement its strategy. In addition, any leverage obtained, if terminated on short notice by the lender, could result in RIM being forced to unwind a Client’s positions quickly and at prices below what RIM deems to be fair value for such positions. Hedging Transactions Clients may utilize a variety of financial instruments such as derivatives, options, swaps, caps and floors, and forward contracts for both risk management and general investment and speculation purposes. With respect to RIM’s risk management and hedging transactions for Clients, there can be no assurance that a particular hedge is appropriate, or that a certain risk is measured properly. Further, while RIM may enter into hedging transactions on behalf of Clients to seek to reduce risk, such transactions may result in poorer overall performance and increased (rather than reduced) risk for a Client than if it did not engage in any such hedging transactions. In addition, RIM may choose not to enter into hedging transactions on behalf of Clients with respect to some or all of its positions. Portfolio Turnover

Read the rest in the brochure

RIM provides investment advisory services to pooled investment vehicles operating as private investment funds. When deemed appropriate for a large or strategic investor, RIM may elect to establish additional separately managed accounts, which may (i) tailor their investment objectives to specific financial instruments and/or (ii) be subject to different terms and fees than those of other Clients. Such investment objectives, fee arrangements and terms will be individually negotiated, and it should be noted that any such separately managed account relationships would generally be subject to significant account minimums. Investors in the Funds must meet certain eligibility provisions: interests in the Funds are generally offered to (A) U.S. investors who are (i) accredited investors within the meaning of Regulation D of the Securities Act of 1933, as amended (“Accredited Investors”) and (ii) “qualified clients” under Rule 205-3 of the Advisers Act, and (B) non-U.S. investors (as applicable). Additionally, the minimum initial investment is $2 million subject to reduction at the discretion of the respective general partner or board of directors, as applicable.

A. RIM or the respective general partner is eligible to receive performance-based compensation in the form of an incentive allocation or fee, as discussed in Item 5. A significant percentage of the appreciation of Client assets which would otherwise be allocated to Clients or Investors, as applicable, is paid to RIM as performance-based fees or allocations. Performance-based

compensation is based on unrealized as well as realized gains and such unrealized gains may never be recognized by the Client or Investor. B. It should be noted that the possibility for RIM or the respective general partner to receive performance-based compensation creates a potential conflict of interest in that it may create an incentive for RIM to make investments that are riskier or more speculative than would be the case in the absence of such a performance-based fee. However, this incentive may be tempered somewhat by the fact that losses will reduce Client performance and thus the fees earned. Investors and Clients are provided with clear disclosure as to how performance-based compensation is charged with respect to a particular account and the risks associated with such performance-based compensation prior to making an investment. RIM recognizes that it is a fiduciary and, as such, must act in the best interests of Clients. Further, RIM recognizes that it must treat all Clients fairly and must refrain from favoring one Client’s interests over another’s interests.

A. Neither RIM nor any of its management persons are registered or have an application pending to register as a broker-dealer or a registered representative of a broker-dealer. B. Neither RIM nor any of its management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or as an associated person of the foregoing entities. However, RIM operates as an exempt commodity pool operator and commodity trading advisor. C. RIM, from time to time, offers co-investment opportunities alongside Clients. Co-investment opportunities may be made available through limited partnerships, limited liability companies, or other entities formed to make such investments. RIM and its affiliates may earn different asset-based fees and/or performance-based compensation (which may or may not be different than the fees and/or compensation charged by RIM) in connection with such coinvestments than what is earned with respect to RIM. These co-investment opportunities may create the potential for conflicts of interest. RIM will attempt to mitigate such potential conflicts via its trade allocation policy and testing. RIM’s access persons may have close relationships with senior executives of public or private companies, the securities of which RIM may recommend to Clients. Additionally, RIM’s employees and related persons may serve on the board of directors, advisory boards, executive committees or in other management capacities at public or private companies and/or other organizations. The potential for such relationships may give rise to conflicts of interest. For example, given the potential for these relationships, it is possible that senior executives of the underlying companies could seek to exert influence on RIM to invest in such a company or may give RIM information that is not publicly known. As such, RIM maintains insider trading procedures which forbid any access person from trading, either personally or on behalf of others, including Clients, on material non-public information or communicating material non-public information to others in violation of the law. Further, RIM maintains internal compliance policies that require access persons to, among other things, obtain prior written approval from the Chief Compliance Officer before engaging in certain outside business activities and update disclosure on such activities on a periodic basis. Please also see Item 17 of this Brochure (below) for details related to how RIM handles potential conflicts of interest related to proxy votes. D. RIM does not recommend or select other investment advisers for Clients.

Trading RIM has adopted a Code of Ethics, which is a part of RIM’s compliance manual, that is designed to comply with the requirements of Advisers Act Rule 204A-1. Among other things, the Code of Ethics requires all employees (i) to comply with federal securities laws, (ii) submit to reports to the Chief Compliance Officer containing their personal securities holdings and transactions in reportable securities, and (iii) obtain pre-approval of personal investments, with limited exceptions. Generally, employees are prohibited from trading in their personal accounts the securities that are in the investable universe of RIM’s Clients absent authorization from the Chief

Compliance Officer, which is typically only granted in extenuating circumstances. The Code of Ethics also contains policies and procedures designed to prevent the misuse of material, nonpublic information. All personnel of RIM are required to certify their compliance with the Code of Ethics. RIM will provide access to a copy of its Code of Ethics to any Client, prospective Client, Investor, or prospective Investor to review upon request made to the Chief Compliance Officer at RIM’s principal address.

A. RIM is typically authorized to determine the broker or dealer to be used for each securities transaction for Clients. In selecting brokers or dealers to execute transactions, RIM need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost. It is not RIM’s practice to negotiate “execution only” commission rates, thus RIM may be deemed to be paying for research, brokerage, or other services provided by the broker which are included in the commission rate. Section 28(e) of the Securities Exchange Act of 1934, as amended, provides a “safe harbor” that permits an investment adviser to use commissions or “soft dollars” to obtain research and brokerage services that provide lawful and appropriate assistance to the investment decisionmaking process. Except for services that would be a Fund expense, RIM will limit the use of “soft dollars” to obtain research and brokerage services to services which constitute research and brokerage within the meaning of Section 28(e). The use of commissions arising from a Fund’s investment transactions for services other than research and brokerage will be limited to services that would otherwise be a Fund expense. The use of commissions to obtain such other services would be outside the parameters of Section 28(e). In some instances, RIM may receive a product or service that may be used only partially for functions within Section 28(e) (e.g., an order management system, trade analytical software or proxy services). In such instances, RIM will make a good faith effort to determine the relative proportion of the product or service used to assist RIM in carrying out its investment decisionmaking responsibilities and the relative proportion used for administrative or other purposes outside Section 28(e). The proportion of the product or service attributable to assisting RIM in carrying out its investment decision-making responsibilities will be paid through brokerage commissions generated by Client transactions and the proportion attributable to administrative or other purposes outside Section 28(e) will be paid for by RIM from its own resources. Research and brokerage services obtained by the use of commissions arising from Client portfolio transactions may be used by RIM in its other investment activities and thus, a Client may not necessarily, in any particular instance, be the direct or indirect beneficiary of the research or brokerage services provided. Although RIM will make a good faith determination that the amount of commissions paid is reasonable in light of the products or services provided by a broker, commission rates are generally negotiable and thus, selecting brokers on the basis of considerations that are not limited to the applicable commission rates may result in higher transaction costs than would

otherwise be obtainable. The receipt of such products or services and the determination of the appropriate allocation in the case of “mixed use” products or services create a potential conflict of interest between RIM and Clients. In selecting brokers and negotiating commission rates, RIM will take into account the financial stability and reputation of brokerage firms, and the research, brokerage, or other services provided by such brokers. RIM may place transactions with a broker or dealer that (i) provides RIM (or an affiliate) with the opportunity to participate in capital introduction events sponsored by the broker-dealer or (ii) refers Investors to RIM or other products advised by RIM (or an affiliate), if otherwise consistent with seeking best execution; provided that RIM is not selecting the broker-dealer as remuneration for the opportunity to participate in such capital introduction events or the referral of Investors. When appropriate, RIM may, but is not required to, aggregate Client orders to achieve more efficient execution or to provide for equitable treatment among accounts. Clients participating in aggregated trades will be allocated securities based on the average price achieved for such trades. RIM may maintain accounts with the prime brokers and or executing brokers, through which RIM may execute trades, borrow securities, and maintain custody of its securities. RIM reserves the right to change the brokerage and custodial arrangements described above. B. When it would be beneficial to Clients RIM may aggregate purchase or sale orders for Clients and allocate based on a fair and equitable methodology that may include allocation by capital or allocation by other fair and equitable means as deemed appropriate by RIM.

A. RIM does not receive any economic benefit from anyone other than Clients for providing investment advice or other advisory services. However, as described in Item 12, RIM may receive Investor referrals from broker-dealers providing services to its Clients. Further, Item 12 discusses how RIM receives certain research or other products or services from brokerdealers through “soft-dollar” arrangements. B. N/A

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to an investor or potential investor’s evaluation of RIM or the integrity of RIM’s management. RIM has no disciplinary information to disclose.

A. RIM portfolio managers have daily access to trades and positions for Clients and review accounts daily. Additionally, RIM reviews clearing and settlement activity daily. RIM provides a daily transaction report to the administrator of the SMA, which includes complete same-day trading activity. B. N/A C. Each investor in the Funds will receive annual audited financial statements within 120 days of the respective Fund’s fiscal year-end, K-1s and other tax informational statements (as applicable) within the time period required by law, monthly unaudited performance reports and quarterly letters which include unaudited performance of the applicable Fund. The Funds may offer certain investors, upon request, additional information and reporting that other Investors may not receive. SMA clients will receive statements from their custodian(s) on a monthly basis.

RIM will maintain the assets of the Funds in accounts with “qualified custodians” pursuant to Rule 206(4)-2 under the Advisers Act. RIM and/or the respective general partner, as applicable, are deemed to have custody of the Funds by virtue of their status as investment manager or general partner, respectively. RIM will ensure compliance with the custody rule for each of the Funds by providing Investors with annual audited financial statements within 120 days of the Funds’ fiscal year-end. RIM does not have custody of assets of the SMA.

Investment advice is provided directly to the Funds on a discretionary basis, subject to the direction and control of each Fund’s general partner or board of directors, and not to individual Investors. Investment advisory services are provided to the Funds in accordance with the respective Offering Documents of each Fund. RIM exercises this discretion in determining which securities to trade on behalf of the Funds. This discretion includes but is not limited to discretion over the amount and timing of transactions as well as the choice of executing brokers for such transactions. All limitations and restrictions placed upon an Investor’s investment, such as a Side Letter, must be presented to RIM and agreed to in writing by RIM and such Investor. RIM also exercises investment discretion over the SMA subject to the limitations in the IMA.

Unless otherwise agreed with a particular Client, RIM holds the authority to vote proxies on behalf of its Clients and has adopted proxy voting policies and procedures designed to ensure that such proxies are voted in its Clients’ best interests. Pursuant to RIM’s proxy voting procedures, in the absence of a finding by the Chief Compliance Officer of a material conflict of interest relating to the proxy vote at hand, RIM will vote proxies as directed by the appropriate portfolio manager. However, if a material conflict of interest exists, RIM will take steps to ensure that its voting decision is based on the best interests of the applicable Client(s), which may include without limitation engaging an independent third party to cast any such proxy vote on behalf of the respective Client(s).

Clients and Investors cannot direct RIM as to how to vote, in any solicitation or otherwise. RIM reserves the right to abstain from voting a specific proxy or proxy item when it concludes that the cost of voting outweighs the potential benefit, or when RIM otherwise does not believe voting serves its Clients’ best interests. The mechanics of proxy voting typically are handled by a thirdparty service provider. Clients may obtain a copy of RIM’s proxy voting policies and procedures and information about how RIM voted any proxies on behalf of such Client by contacting the Chief Compliance Officer at RIM’s principal address.

Not applicable to RIM.