Sands Capital Alternatives, LLC

Sands Capital Alternatives is an independent investment management firm that was formed in October 2010. Sands Capital Management, LP is the principal owner of Sands Capital Alternatives and, in turn, is principally owned, directly and indirectly, by the companies and trusts identified in Schedule B of Part 1. Sands Capital Alternatives and Sands Capital Management, LP are ultimately controlled by Frank M. Sands. Sands Capital Alternatives provides investment advisory services to private funds (the “Funds”) and separately managed accounts (“SMAs” and, together with the Funds, the “Clients”). The Funds are exempt from registration under the U.S. Investment Company Act of 1940, as amended (the “1940 Act”), and their securities are not registered under the U.S. Securities Act of 1933, as amended (the “Securities Act”). Sands Capital Alternatives provides investment advisory services with respect to investment strategies that invest in publicly traded and/or privately held companies. Sands Capital Alternatives’ investment strategies and methods of analysis are described in Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss. Sands Capital Alternatives sources investment opportunities, and advises with respect to the acquisition, management, monitoring and disposition of investments, for each Client. Sands Capital Alternatives’ investment strategies target investments across geographies and industries, including life sciences, technology, and consumer, and across multiple stages of development, from early-stage venture capital to late-stage growth equity, to publicly-traded companies. Depending on the investment strategy, investments may be made in U.S. and non-U.S. companies through private placements, public offerings, and/or secondary public market transactions. From time to time, employees of Sands Capital Alternatives or its affiliates will serve on the boards of directors of portfolio companies or otherwise act to influence control over management of portfolio companies. Sands Capital Alternatives, from time to time, engages persons unaffiliated with Sands Capital Alternatives to represent the relevant Fund on portfolio companies’ boards of directors. Some of the Funds have the authority to also invest in investment funds managed by unaffiliated third parties that principally target venture capital and/or growth equity investments. Sands Capital Alternatives’ investment advisory services are performed in accordance with the advisory agreement or side-letter agreement with, and/or the organizational documents of, each Client (“Client Documentation”) and, in the case of Funds, are subject to the direction and control of the general partner of each Fund, as applicable. Any investment restrictions, including with respect to types of securities, industries, or diversification, are set forth in the Client Documentation. Once invested in a Fund, investors cannot change or impose new investment restrictions on a Fund. Sands Capital Alternatives may agree to amend the investment advisory agreements with SMA Clients to change or impose new investment restrictions with respect to the SMAs. Sands Capital Alternatives constructs and maintains model portfolios for each investment strategy that principally targets investments in publicly traded securities. Clients invested in such

strategies are generally invested in the same portfolio businesses and at approximately the same weights as the applicable strategy model unless the Client Documentation prohibits or restricts an investment. Each general partner of a Fund is subject to the U.S. Investment Advisers Act of 1940, as amended (the “Advisers Act”), pursuant to the registration of Sands Capital Alternatives in accordance with SEC guidance. This Brochure also describes the business practices of the general partners of the Funds, which operate as a single advisory business together with Sands Capital Alternatives. Investors in a Fund generally have no right to redeem their interests in the Fund prior to the expiration of its term and can obtain liquidity only upon the termination of the Fund or a partial disposition of the Fund’s investments. SMA Clients are permitted to periodically add to or redeem their interests in their SMAs, subject to the terms set forth in the Client Documentation. Sands Capital Alternatives had assets under management of approximately $5,405.4 million as of December 31, 2025. Sands Capital Alternatives is affiliated with other investment advisers that also operate under the name Sands Capital (“Advisory Affiliates”). Under personnel-sharing and other arrangements, certain Advisory Affiliates’ employees act on behalf of Sands Capital Alternatives for purposes of providing services with respect to the Clients, which services may include back office, trading, and administrative services. Certain Advisory Affiliates’ employees are also officers of Sands Capital Alternatives. Sands Capital Alternatives believes that harnessing the collective capabilities of Sands Capital Alternatives and the Advisory Affiliates benefits the Clients. These joint teams use expanded and shared capabilities, including the sharing of research and other information by investment staff members relating to economic perspectives, market analysis and securities research.

Whistleblowing No provision in any agreement between Sands Capital Alternatives and any third party, including the Clients, restricts any party from communicating with or recovering a monetary award from any governmental authorities or other regulatory agencies, or from making disclosures that are protected under the whistleblower provisions of federal law or regulation.

Sands Capital Alternatives or its affiliates generally receive Management Fees (as defined below), and/or incentive allocation or similar performance-based remuneration from Clients. A Fund and/or its portfolio companies, have in the past and may in the future also make other payments to Sands Capital Alternatives or its affiliates for services provided to the Fund and/or the portfolio companies, which, in certain circumstances, consistent with the Client Documentation, would reduce

the Management Fees payable to Sands Capital Alternatives. Additionally, consistent with the Client Documentation, the Fund typically bears certain out-of-pocket expenses incurred by Sands Capital Alternatives in connection with the services provided to the Fund and/or the portfolio companies. Further details about certain common fees and expenses are set forth below.

Management Fees Funds Investors in a Fund typically are directly or indirectly subject to an investment management fee (the “Management Fee”) payable by the Fund to Sands Capital Alternatives as the investment manager of the Fund equal to a percentage of the capital commitments to or the capital invested by such Fund. The precise amount of, and manner and calculation of, the Management Fee are established by Sands Capital Alternatives and are set forth in the Client Documentation provided to an investor prior to investment in a Fund. The Management Fee is typically not open to negotiation. Additionally, Management Fee rates currently and may in the future differ from one Fund to another, and certain Funds grant investors the ability to choose among different Management Fee rate options that correspond to different incentive allocation percentages. Certain Funds, from time to time, also grant investors participating in the initial closings of such Funds lower Management Fee rates. Further, Sands Capital Alternatives may waive the Management Fee for certain investors (if consistent with the Client Documentation). Currently Sands Capital Alternatives does not waive the Management Fee except as described below. Generally, the Management Fee is payable until the final proceeds from capital investments are distributed or until Sands Capital Alternatives’ relationship with the Fund is terminated for other reasons as described in the Client Documentation. The Management Fee may be lowered or offset by certain fees received by Sands Capital Alternatives or its affiliates, as described in more detail below. The Management Fee structures described herein may be modified from time to time. Upon termination of an advisory agreement, Management Fees that have been prepaid are generally returned on a prorated basis. Generally, Sands Capital Alternatives’ affiliates, employees of Sands Capital Alternatives or its affiliates, and other “friends and family” of Sands Capital Alternatives (together, “Adviser Investors”) who invest in a Fund will not be subject to a Management Fee or will receive a reduction in Management Fees. However, Adviser Investors (or Sands Capital Alternatives or its affiliates on their behalf) will bear their pro rata share of certain Fund expenses. In addition, and in accordance with the Client Documentation, as applicable, Sands Capital Alternatives has entered into and anticipates entering into letter agreements or other similar agreements (collectively, “Side Letters”) with one or more investors that provide such investors with additional and/or different rights (including with respect to Management Fees) than provided in the Client Documentation. The Management Fee paid by a Fund will generally be reduced by a percentage of: (1) the amount of fees paid by such Fund to persons acting as a placement agent in connection with the offer and sale of interests in such Fund, (2) the fees incurred by Sands Capital Alternatives in connection with the organization of such Fund that exceed a limit specified in such Fund’s Client Documentation,

and/or (3) certain Other Fees (as defined below) received by Sands Capital Alternatives or its affiliates. The amount and manner of such reduction, if any, is set forth in the applicable Client Documentation. To the extent a reduction relates to more than one Fund, Sands Capital Alternatives will allocate the reduction fairly among the Funds, at its discretion. To the extent a reduction relates to a portfolio company held by more than one Fund, Sands Capital Alternatives shall allocate the resulting Management Fee reduction among the applicable Funds in proportion to their respective interest (or prospective interest) in the portfolio company(ies) to which the reduction relates. As some Funds, coinvestment vehicles, or investors may not pay Management Fees, any such reduction will not benefit such Funds, vehicles, or investors. Generally, the portion of Other Fees allocable to capital invested by a Fund, co-investment vehicle or third-party investor that does not pay Management Fees will be retained by Sands Capital Alternatives and such amounts will not offset any Management Fee. In addition, Sands Capital Alternatives may waive or reduce all or a portion of the Management Fee paid by a Fund in full or partial satisfaction of any obligation of Sands Capital Alternatives, its affiliates, and/or their employees to invest in or alongside such Fund, which could result in acceleration of investor capital contributions. Waived or reduced Management Fees may not be subject to various offsets or the reductions described above. Fund investors may not receive the full benefit of reductions or offsets in Management Fees due to certain factors. These factors include waived or reduced Management Fees and the timing of compensation subject to offsets. For example, during periods when Sands Capital Alternatives no longer receives Management Fees and receives compensation that would otherwise be subject to offset, Sands Capital Alternatives may be entitled to retain such compensation without remitting any such amounts to the applicable Fund or its investors, depending on certain elections that may be made by Fund investors. Generally, the Client Documentation provides that a Fund’s Management Fees will be calculated and charged on a basis that generally is not tied to the Fund’s then-current net asset value. As further specified in the Client Documentation, from the effective date of the relevant Fund until the end of the Fund’s Commitment Period (as defined in the Client Documentation), Management Fees generally will be charged based on a formula tied to the amount of the relevant Fund’s aggregate committed capital. After the end of the Commitment Period, Management Fees generally will be charged based on a formula tied to the amount of the relevant Fund’s aggregate capital contributions made to investments held by the Fund that have not been realized or fully and permanently written off. Investments that are fully and permanently written off are those that are subject to Section 165(g) of the Internal Revenue Code of 1986 (as amended) (the “Code”) and such determination is made in the sole discretion of the Fund’s general partner, which creates a conflict of interest. In many circumstances, the aggregate capital contributions component of Management Fees calculated after the end of the Commitment Period will include capitalized transaction-specific expenses of investments. Further, Management Fees will not be reimbursed or refunded under the Client Documentation in the event of realizations, dispositions or partial write-offs that occur partway through the relevant calculation period. The Client Documentation sets forth the full list of terms under which Management Fees will be reduced, offset, or otherwise limited, and consequently,

investors should expect to bear the full specified Management Fee rate in the Client Documentation until they are reduced in the circumstances and on the date(s) specified therein. SMAs Sands Capital Alternatives is primarily compensated by its SMA Clients in the form of Management Fees but may also agree to performance fee arrangements with Clients. Generally, the Management Fee for an SMA will be billed at regular intervals, as specified in the relevant advisory agreement, in advance or arrears, and is calculated as a percentage of the market value of the SMA’s assets. Unless otherwise negotiated, Management Fees are calculated based upon the market value of the SMA’s assets as of the last business day of each calculation period, as valued by our portfolio management system. The valuation on which fees are based may differ from the value reported by the SMA’s custodian. Please refer to Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss for additional risks associated with valuation. Sands Capital Alternatives has the discretion to negotiate different Management Fee structures with its SMA Clients, based on any factor it deems relevant, including the total amount of assets being managed. Any such negotiated fee arrangement is done at the sole discretion of Sands Capital Alternatives and is entered into generally without notice to, or consent from, any other Client, including any other SMA or Fund that may invest alongside the SMA. Sands Capital Alternatives has relationships with certain intermediaries, and, in some cases, the fees assessed against the underlying SMAs are based on a fee schedule applicable to the relevant intermediary. Such fee schedule may or may not aggregate the assets of the intermediary’s clients that are under the management of Sands Capital Alternatives and/or its affiliates.

Other Fees Fees Payable by the Portfolio Companies Sands Capital Alternatives and its affiliates provide various services such as financial advisory and transaction-related services to the companies in which the Funds have invested or may invest in the future. This includes helping to structure investments in these companies, as well as facilitating mergers, acquisitions, add-on acquisitions, refinancings, public offerings, sales, or other dispositions involving these companies. In return for these services, in some cases Sands Capital Alternatives and its affiliates will receive fees (“Transaction Fees”) from these companies. Sands Capital Alternatives and its affiliates may also provide advice, consultation, and other similar ongoing services to portfolio companies of the Funds pursuant to monitoring agreements and receive monitoring fees (“Monitoring Fees”) for such services. The terms of a monitoring agreement may include (among other things) annual automatic renewals and the payment of Monitoring Fees (which may be fixed fees or calculated as a percentage of EBITDA or similar performance metric).

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Fundamental, bottom-up, company-focused research is the core of Sands Capital Alternatives’ investment process. Sands Capital Alternatives uses input from various methods of security analysis and various combinations of methods in rendering investment advisory services. Sands Capital Alternatives’ methods of security analysis include general market, specific industry, or individual security technical or trend analysis. Sands Capital Alternatives’ investment professionals often conduct on-site visits with senior management of companies it regards as potential investments.

Identification of Investments Sands Capital Alternatives’ principal sources of information include company-prepared and disseminated information, physical inspections of corporate offices, plants, and other assets, discussions with corporate management, research materials prepared by others, prospectuses, SEC filings, company press releases, scientific and medical literature, and discussions with consultants, physicians, scientists, or others concerning underlying technology. Sands Capital Alternatives uses input from various methods of security analysis and various combinations of analytical methods.

Targeted Investment Characteristics Sands Capital Alternatives focuses its investment research primarily on venture capital, growth equity, and related investments, across stages, from early-stage venture capital to late-stage growth capital to publicly traded companies. Sands Capital Alternatives evaluates businesses in varying stages of development, with a preference for revenue-generating businesses with validated technologies and platforms and with an identifiable path to profitability. Sands Capital Alternatives may identify businesses that span various stages of financing, ranging from non-revenue-producing businesses to profitable businesses seeking growth capital.

Sands Capital Alternatives identifies investment opportunities in domestic and non-U.S. equity securities, including preferred and convertible stock, common stock of any type, secured or unsecured debt, convertible debt, options, warrants, rights, or such other securities as it deems advisable. As specified in the Client Documentation of certain Clients, Sands Capital Alternatives has the flexibility to engage its Advisory Affiliates with respect to certain investments in the publicly traded securities of portfolio companies held by the respective Clients. Global Venture Capital Strategy The Global Venture strategy seeks to make minority investments in early to mid‐stage, emerging technology and technology‐enabled consumer businesses in dynamic markets with the potential for high growth. The Global Venture strategy focuses on businesses that are enabling and building on rapid digitalization and continued advancements in computing power that have the potential to drastically change the way we work and live. The Global Venture strategy seeks to invest in companies in industries including, but not limited to, artificial intelligence and application infrastructure, identity intelligence, digital life, and healthcare technology. Global Innovation Strategy The Global Innovation strategy seeks to make minority investments in mid-to late-stage private growth companies that Sands Capital Alternatives believes have the potential to become leading public businesses. The Global Innovation strategy seeks to invest in technology and technology-enabled growth businesses that have high-quality teams building innovative and durable businesses across the globe. The Global Innovation strategy utilizes investment concentration, which causes the strategy to be highly selective in assessing and pursuing investment opportunities, seeking to evaluate prospective investments in detail, and partner closely with portfolio companies. Life Sciences Pulse Strategy The Life Sciences Pulse strategy seeks to make investments in innovative life sciences businesses that have the potential to improve patient outcomes, increase efficiencies of the healthcare system, and become market leaders in attractive business spaces. The Life Sciences Pulse strategy partners with businesses in specific areas of life sciences, including, but not limited to, therapeutics, diagnostics, medical devices, and life sciences tools. This strategy generally seeks an entry point in such businesses in the private markets, which allows the strategy to have the optionality to seek to scale its investments in these companies’ subsequent private rounds, initial public offerings and/or thereafter in the public markets. The Life Sciences Pulse strategy invests in certain businesses in the public markets (either in their initial public offerings or thereafter) that satisfy its investment criteria. Scaling Innovation Strategy

The Scaling Innovation strategy is a concentrated portfolio that normally consists of the equity and equity-related securities of approximately 10-20 primarily mid-capitalization growth businesses. Generally, the holding period is typically less than 5 years. Portfolio companies are primarily domiciled in the U.S. but there is no restriction on investing directly or indirectly in non-U.S. issuers in other developed and emerging markets. The Scaling Innovation strategy has broad authority to invest in various types of securities, including equity, equity-related securities, such as ADRs, GDRs, warrants, convertible securities, debt securities (including debt securities convertible into equity securities, investment grade bonds and debentures, and high-quality short-term debt instruments), and access products, including Low Exercise Price Warrants (“LEPWs”) and Participation Notes (”P-Notes”), to gain exposure to certain non-U.S. markets where direct investment is not always practical or cost efficient. The Scaling Innovation strategy is expected at times to invest in options, futures, swaps, or other derivatives for hedging purposes and as a substitute for comparable market positions in the securities that may be held in the strategy, and to engage in securities lending. The Scaling Innovation strategy may also enter into non-U.S. currency hedging transactions. The Scaling Innovation strategy is offered through an SMA and may also be accessed through a Fund.

Investment Risks Investing in securities involves risk of loss, which investors must be prepared to bear; investments of the type targeted by Sands Capital Alternatives involve a particularly high level of risk, and clients should be able to bear the loss of all or part of their investment. The risk factors listed below represent a limited summary of the various risks presented by the investment opportunities Sands Capital Alternatives identifies. Additional risks associated with an investment in a Client are disclosed in the Client Documentation. Risk Inherent in Investments. The investments Sands Capital Alternatives identifies will involve a high degree of risk. In general, the financial and operating risks confronting these companies are often significant. While targeted returns should reflect the perceived level of risk in any investment situation, there is no assurance that investors will be adequately compensated for risks taken. Early-stage and development-stage companies often experience unexpected problems in the areas of product development, manufacturing, marketing, financing, and general management, which, in some cases, cannot be adequately solved. In addition, such companies often require substantial amounts of financing, which may not be available through institutional private placements or public markets. The percentage of companies that survive and prosper can be small. Investments in more mature companies in the expansion or profitable stage also involve substantial risks. In some instances, companies have previously obtained capital in the form of debt or equity to expand rapidly, reorganize operations, acquire a business, or develop new products and markets. By definition, these activities involve a significant amount of change in a company and could give rise to significant problems in sales, manufacturing, and general management of these activities.

Additional Capital Requirements of Portfolio Companies. Some of the companies Sands Capital Alternatives identifies as investment opportunities, especially those in a development or “platform” phase, require additional financing to satisfy their working capital requirements or acquisition strategies. Following its initial investment in portfolio companies, a Fund is often called upon to provide additional funds to portfolio companies or will have the opportunity to increase its investment in a portfolio company, including the opportunity to participate in the initial public offerings of such portfolio companies, and in the subsequent purchase of publicly traded shares. Although the Fund may make follow-on investments, there is no assurance that the Fund and its co-investors will provide all necessary follow-on capital or that any Fund will have sufficient funds to make all or any of such investments. Any decision by a Fund not to make add-on investments or its inability to make such investments may have a substantial negative impact on a portfolio company in need of such investment (including an event of default under applicable debt documents in the event an equity cure cannot be made), result in a lost opportunity for such Fund to increase its participation in a successful operation or the dilution of the relevant Fund’s ownership in a portfolio company if a third party or co-investor is permitted to invest. If the funds provided by the Funds are not sufficient, a company may have to raise additional capital at a price unfavorable to the existing investors, including the Fund. In addition, a Fund may make additional debt and equity investments or exercise warrants, options, or convertible securities that were acquired in the initial investment in such company in order to preserve the Fund’s proportionate ownership when a subsequent financing is planned, or to protect the Fund’s investment when such portfolio company’s performance does not meet expectations. The availability of capital is generally a function of capital market conditions that are beyond the control of a Fund or any portfolio company. There can be no assurance that the portfolio companies will be able to predict accurately the future capital requirements necessary for success or that additional funds will be available from any source. Leveraged Investments. If authorized by its Client Documentation, a Fund may make use of leverage by incurring or having a portfolio company or intermediate entity incur debt to finance a portion of its investment. Leverage generally magnifies both such Fund’s opportunities for gain and its risk of loss from a particular investment. The cost and availability of leverage is highly dependent on the state of the broader credit markets (and such credit markets may be impacted by regulatory restrictions and guidelines), which state is difficult to accurately forecast, and at times it may be difficult to obtain or maintain the desired degree of leverage. Leverage often imposes restrictive financial and operating covenants on a company, in addition to the burden of debt service, and will constrain its ability to operate its business as desired and/or finance future operations and capital needs. The leveraged capital structure of portfolio companies will increase the exposure of a Fund’s investments to any deterioration in a company’s condition or industry, competitive pressures, an adverse economic environment or rising interest rates and could accelerate and magnify declines in the value of such Fund’s investments in the leveraged portfolio companies in a down market. These risks generally are expected to increase as interest rates rise, including in circumstances where a portfolio company’s creditworthiness is such that it must borrow at higher interest rates than are available to the relevant Fund. In the event any portfolio company cannot generate adequate cash flow to meet its debt service, a Fund may suffer a partial or total loss of capital invested in the portfolio company, which could

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Sands Capital Alternatives provides investment advisory services to private funds and separately managed accounts, as described above in Item 4 – Advisory Business. Interests in the Funds are offered pursuant to applicable exemptions from registration under the Securities Act and the 1940 Act. Investors in the Funds are generally “accredited investors” as defined in Regulation D under the Securities Act, and may include high net worth individuals, principals or other knowledgeable employees of Sands Capital Alternatives and its affiliates (including the Advisory Affiliates), Operations Support Providers (as further defined in Item 11 – Code of Ethics, Interest in Client Transactions, and Personal Trading below), or other service providers retained by Sands Capital Alternatives, banks, thrift institutions, pension and profit-sharing plans, trusts, estates, charitable organizations, university endowments, corporations, limited partnerships, limited liability companies, or other entities. Subscription and capital commitment minimums are disclosed in the Client Documentation of the Funds and are, at times, waived for certain investors at Sands Capital Alternatives’ discretion. Sands Capital Alternatives is also generally permitted to establish Funds that are alternative investment vehicles in order to permit certain investors to participate in one or more particular investment opportunities in a manner desirable for tax, regulatory, or other reasons. Alternative investment vehicle sponsors generally have limited discretion to invest the assets of these vehicles

independent of limitations or other procedures set forth in the Client Documentation of such vehicles and the Client Documentation of the related Fund. Sands Capital Alternatives has entered into written advisory agreements granting it authority to provide discretionary investment advisory services to certain institutional investors, which services are tailored based on the relevant investor’s individual investment objectives, guidelines and/or limitations on the types of securities and other instruments in which the given portfolio may invest. Such institutional investors may include banking or thrift institutions, pension and profit-sharing plans (including those governed by the Employee Retirement Income Security Act of 1974), charitable organizations, state or municipal government entities (including government pension plans), insurance companies, sovereign wealth funds and foreign institutions, corporations or other business entities, and trusts (including collective investment trusts and their trustees). The minimum account size for institutional separate accounts is generally $50 million. Minimum account sizes are negotiable.

Performance-Based Fees Investors in the Funds are also typically subject to an incentive allocation paid to Sands Capital Alternatives or its affiliate equal to a percentage of the net realized gains on the full or partial disposition of the investments held by the Fund. Sands Capital Alternatives has in the past and may again have Funds where investors are subject to an incentive allocation paid to Sands Capital Alternatives or its affiliate based on the Fund’s performance, in general, including with respect to unrealized investments. Generally, an incentive allocation will be distributed following a full or partial disposition of a Fund’s assets or another liquidity event that gives rise to a distribution by the Fund to the investors. For some Funds, an incentive allocation will be distributed on a periodic basis, as specified in the relevant Client Documentation. An incentive allocation will generally only be made with respect to an investor after the investor has received a full return of its capital contributions to the Fund. Sands Capital Alternatives or its affiliate has the ability to separately negotiate terms with individual investors, which may result in an investor being subject to an incentive allocation that is different from those applicable to other investors of the same Fund. The incentive allocation applicable to certain investors may be reduced or eliminated for such period(s) as Sands Capital Alternatives, or its affiliate, determines at its discretion. Certain Funds have granted investors participating in the initial closings of such Funds lower incentive allocation rates. Adviser Investors generally will not be subject to an incentive allocation (or may be subject to a reduced allocation), at Sands Capital Alternatives’ or its affiliate’s discretion. Incentive allocations are based on the net realized appreciation of assets held by a Fund. Such performance-based compensation may create an incentive for Sands Capital Alternatives to make investment decisions that are riskier or more speculative than would be the case in the absence of a financial incentive based on performance, although Sands Capital Alternatives generally considers performance-based compensation to better align its interests with those of its investors, particularly in instances where the Client Documentation, as applicable, include terms requiring clawback or giveback of performance-based compensation amounts at the end of the relevant Fund’s life or at certain interim intervals. The payment by some, but not all, Funds of an incentive allocation, the payment of incentive allocations at varying rates (including varying effective rates based on the past performance of a Fund) and/or other terms (e.g., amount, timing, waterfall conditions, etc.) creates an incentive for Sands Capital Alternatives to disproportionately allocate time, services, or functions to Funds paying incentive allocations or Funds paying incentive allocations at a higher rate, or allocate investment opportunities to such Funds. Generally, and except as may be otherwise set forth in the Client Documentation, this conflict is mitigated, as applicable, by (i) certain limitations on the ability of Sands Capital Alternatives to establish new investment vehicles, (ii) contractual provisions requiring certain Funds to purchase and sell investments contemporaneously, and/or (iii) contractual provisions and internal procedures setting forth investment allocation requirements. Additionally, Sands Capital

Alternatives evaluates on an ongoing basis the time and services being devoted to the Funds to ensure that the necessary resources are being allocated to each Fund. Sands Capital Alternatives monitors the investments held by the Clients on an ongoing basis and will endeavor to ensure that it is appropriate to continue holding each investment without regard to the potential for performance-based compensation. In addition, each investor bearing an incentive allocation is required to represent that it is a “qualified client” within the meaning of Rule 205-3 under the Advisers Act. Any performance-based fee arrangements will be consistent with the requirements of applicable law, including the Advisers Act.

Side-by-Side Management Certain Sands Capital Alternatives portfolio managers make investment decisions for multiple strategies. These portfolio management responsibilities create conflicts of interest as described herein. Sands Capital Alternatives seeks to conduct itself in a manner it considers to be the most fair and consistent with Sands Capital Alternatives’ fiduciary obligations to the Clients. Sands Capital Alternatives makes investment decisions based on a Client’s portfolio construction, available cash or committed capital, investment objectives, restrictions, permitted investments, and other relevant considerations. For additional information regarding brokerage practices, please see Item 12 – Brokerage Practices below. Sands Capital Alternatives may cause a Client to hold a short or short-equivalent exposure to an issuer, sector, or factor while another Client, or a Client account managed by an Advisory Affiliate, simultaneously holds a long position in that same issuer. An Advisory Affiliate may engage in direct short selling of individual securities on behalf of its clients. In such cases, the Advisory Affiliate may simultaneously hold a short position in a security or sector (including through a derivative position) in which a Client holds a long position, and neither Sands Capital Alternatives nor the Advisory Affiliate is obligated to coordinate its investment decisions with the other or to take into account the interests of the other's clients. The investment objectives, portfolio construction, and risk management considerations applicable to each Client will generally govern the investment decisions made on behalf of each Client, and neither Sands Capital Alternatives nor the Advisory Affiliate is obligated to coordinate or align the investment positions of different clients, or to refrain from taking positions for one client that may disadvantage another client. Allocation of aggregated trades, particularly trade orders that were only partially completed due to limited availability and allocation of investment opportunities, generally, are conflicts of interest, as Sands Capital Alternatives and its Advisory Affiliates have an incentive to allocate securities that are expected to increase in value to favored clients of the Advisory Affiliates. Decisions to buy or sell a particular security for each Client advised by Sands Capital Alternatives are made by each strategy’s portfolio managers, and as a result, a particular investment can be bought or sold for one Client in different amounts, or at different times, than it is bought or sold for a different Client. Similarly, an investment can be purchased for one Client at the same time

as it is sold for a different Client. A conflict arises because actions with respect to one Client are adverse to the interests of another Client. Conflicts like those described above arise where Clients are invested in different strategies or in different parts of an issuer’s capital structure, also including instances where one or more Client (or a client of the Advisory Affiliates) owns private securities of an issuer and another Client (or a client of the Advisory Affiliates) owns public securities of the same issuer. Actions by one Client in one part of the capital structure can have an adverse consequence on Clients in another part of the capital structure. Differences may develop between the holdings and performance of Clients in the same investment strategy due to a variety of factors, including but not limited to, differences in account size, account restrictions or limitations, regulatory restrictions, registration in non-U.S. jurisdictions, cash flows, tax status, the timing and terms of execution of trades, and individual Client needs. Sands Capital Alternatives exercises limited discretion over the timing and order of registrations to trade in non-U.S. jurisdictions, which could result in certain Clients’ availability to trade in such non-U.S. jurisdictions prior to others. Sands Capital Alternatives has established policies and procedures designed to manage the potential conflicts described above. Sands Capital Alternatives monitors a variety of areas, including compliance with Client investment guidelines, review of allocations, and compliance with Sands Capital Alternatives’ Code of Ethics. As described under Item 12 – Brokerage Practices, Sands Capital Alternatives has policies and procedures designed to achieve fair and equitable allocation of investment opportunities among the Clients over time.

Sands Capital Alternatives has entered into a services agreement with an Advisory Affiliate, pursuant to which the Advisory Affiliate is providing the staff members and resources (e.g., trading, investment research, marketing, compliance, human resources and other finance or administrative services) to conduct Sands Capital Alternatives’ business, and the Advisory Affiliates and Sands Capital Alternatives share certain executive officers. As part of this shared services arrangement, the Advisory Affiliate’s trading desk executes securities transactions on behalf of the Sands Capital Alternatives’ Clients, including but not limited to short sales and OTC derivative transactions. Such transactions may involve heightened risk characteristics and potential conflicts of interest. Sands Capital Alternatives shares proprietary research and other information with the Advisory Affiliates and the Advisory Affiliates share similar information with Sands Capital Alternatives from time to time. Certain investors doing business with the Advisory Affiliates are investors in the Clients, and vice versa. Sands Capital Alternatives and the Advisory Affiliates refer potential investors to each other from time to time. The Advisory Affiliates and their affiliates and their officers and staff members invest, and may in the future invest, in the Clients or on a side-by-side basis through separate investment vehicles, and, subject to the Client Documentation, invest, and may in the future invest, in opportunities that are not presented to the Clients or their investors. Sands Capital Alternatives invests, and may in the future invest, in companies in which the Advisory Affiliates or their affiliates or their officers and staff members have interests. In the event the securities issued by a portfolio company in which Sands Capital Alternatives’ Clients, officers, staff members, or affiliates have directly or indirectly invested become listed on a national securities exchange, Advisory Affiliates have in the past and may in the future invest in such securities for its client accounts. For a description of potential material conflicts of interest created by the relationship between Sands Capital Alternatives and its related persons, as well as a description of how such potential conflicts are addressed, please see Item 11 – Code of Ethics, Interest in Client Transactions, and Personal Trading below.

Code of Ethics and Personal Trading Sands Capital Alternatives has adopted a code of ethics in compliance with the Advisers Act that is applicable to all of its members, principals, staff members, and other personnel, as well as principals, staff members, and other personnel of its affiliates, including the Advisory Affiliates, and certain independent contractors. The code of ethics is designed to comply with Rule 204A-1 under the Advisers Act and is based on the principle that Sands Capital Alternatives and its staff members owe a fiduciary duty to Clients. The code of ethics establishes guidelines for professional conduct and personal trading procedures, including certain pre-clearance and reporting obligations. The code of ethics helps Sands Capital Alternatives detect and prevent potential conflicts of interest. Sands Capital Alternatives’ code of ethics permits Sands Capital Alternatives staff members to trade in certain securities for their own accounts, provided that they comply with the restrictions imposed by the code. Under the code, personal securities transactions are limited to certain types of securities and certain issuers and must receive approval before a transaction can be initiated. The code also requires periodic reporting of personal securities transactions and holdings reports upon hire and annually thereafter. Each calendar quarter, Sands Capital Alternatives staff members are required to provide copies of all transactions in reportable securities to Sands Capital Alternatives’ Compliance Team. All Sands Capital Alternatives staff members must also comply with all applicable federal securities laws. Principals, staff members, or other personnel who violate the code of ethics will be subject to such sanctions as deemed necessary and appropriate under the circumstances. The range of sanctions include, but are not limited to, written warning or reprimand, cancellation of trades, disgorgement of profits or sale of positions at a loss, restriction on trading privileges, fines, suspension of employment without pay, termination of employment and/or referral to regulatory or law enforcement authorities. Principals, staff members, and other personnel are also required to promptly report any violations of the code of ethics of which they become aware and certify annually to compliance with the code of ethics. However, Sands Capital Alternatives reserves the right to refine and modify the code and its other policies and procedures over time. No investor or prospective investor should invest with Sands Capital Alternatives on the basis of, or otherwise rely on, the provisions thereof, and any such refinements or modifications have the potential to materially affect the investments available to the Clients or the expenses borne thereby. Clients may request a copy of the current Sands Capital Alternatives’ code of ethics by contacting the Chief Compliance Officer, writing to 1000 Wilson Blvd., Suite 3000, Arlington, VA 22209, or emailing ComplianceTeam@sandscap.com. Material, Nonpublic Information. As a result of the extensive operations of Sands Capital Alternatives and its affiliates, including the Advisory Affiliates, Sands Capital Alternatives and its staff members at times come into possession of material, nonpublic information through a number of means, including as a result of sitting on or serving as an observer to the board of directors of a company whose securities are held by a Client. Sands Capital Alternatives has adopted policies

addressing the handling and protection of material, nonpublic information. In accordance with these policies, Sands Capital Alternatives and its staff members will be prohibited from using material, nonpublic information to buy or sell securities until the information has been disclosed to the public or is no longer material and such information is not subject to any contractual restrictions on its use and disclosure. This may cause Sands Capital Alternatives to be unable to dispose of or otherwise take action with respect to an investment at a given time (including making an investment that otherwise might have been made or selling an investment that otherwise might have been sold), even if the action were in the best interests of applicable Clients. Additionally, there may be circumstances in which one or more individuals associated with Sands Capital Alternatives or its affiliates will be precluded from providing services to Sands Capital Alternatives or Clients because of certain confidential information available to those individuals or to Sands Capital Alternatives or its affiliates, which could have an adverse effect on Clients. Restricted List. In certain circumstances, Sands Capital Alternatives or its Advisory Affiliates may conclude that a particular security should be placed on a “restricted list” or “blackout list.” While a security is on this list, purchases, sales, or other transactions in the security must be pre-cleared with Sands Capital Alternatives’ or its affiliates’ Chief Compliance Officer (or his or her delegate). The reasons for placing a security on the restricted list include, but are not limited to, (i) preventing the appearance of impropriety in connection with a trading decision, and (ii) preventing the misuse, or appearance of the misuse, of material, nonpublic information.

Participation or Interest in Client Transactions From time to time, Sands Capital Alternatives or its affiliates (including the Advisory Affiliates), principals, or staff members will purchase, hold or sell securities that are recommended to Clients. This is the case where Sands Capital Alternatives or its affiliates, principals, or staff members invest in a Fund managed by Sands Capital Alternatives or its affiliates and receive a distribution of securities from such a vehicle. Conflicts of interest arise in connection with staff members having knowledge about the timing of public markets transactions, opportunities, and/or broker selections and, therefore, have information about the implications of such transactions. As a result, staff members are in a position to use such information to their advantage and/or to the possible disadvantage of Clients. Additionally, staff members of Sands Capital Alternatives and its Advisory Affiliates provide advice and take action in connection with their investment advisory duties for some Clients that differ from advice given, or the timing of actions taken, for other Clients or with respect to their personal accounts. Therefore, the purchase and sale of securities that are recommended to Clients by Sands Capital Alternatives or its affiliates, principals or staff members are subject to the policies and procedures set forth in Sands Capital Alternatives' code of ethics, which includes its personal securities trading policy and insider trading policy. Sands Capital Alternatives’ related persons have invested, and will likely invest in the future, in a Fund alongside other investors as direct investors in the Funds or in investment opportunities on a side-by-side basis with a Fund. A Fund, or its general partner, as applicable, has in the past and will

likely in the future reduce all or a portion of the Management Fee and incentive allocation related to investments held by such persons. Related persons who invest in a Fund will receive distributions in respect of their pro rata interest at the same time as other investors, and their interest will be subject to the same limitations on withdrawal pursuant to the Client Documentation, as applicable. Related persons who invest alongside a Fund will make their respective investments contemporaneously with the Fund’s investment, on the same terms and conditions as the Fund, and will dispose of each such investment at substantially the same time and terms as the Fund.

Conflicts of Interest Sands Capital Alternatives and its affiliates (including the Advisory Affiliates) engage in a broad range of activities, including investment activities for their own accounts and for the accounts of other investment funds, and provide transaction-related, investment advisory, management, and other services to funds and operating companies. In the ordinary course of conducting its activities, the interests of a Client will, from time to time conflict with the interests of Sands Capital Alternatives, other Clients, an Advisory Affiliate, or their respective affiliates. The material conflicts of interest encountered by a Client include those discussed below, although the discussion below does not necessarily describe all of the conflicts of interest that may be faced by a Client. Other conflicts may be disclosed throughout this brochure and in the offering documents of each Fund, or in the case of SMAs, the Client Documentation, and the brochure and such offering documents should be read in their entirety for other conflicts. Resolution of Conflicts In the case of all conflicts of interest, Sands Capital Alternatives’ determination as to which factors are relevant, and the resolution of such conflicts, will be made using Sands Capital Alternatives’ best judgment, but in its sole discretion. In resolving conflicts, Sands Capital Alternatives will consider various factors, including the interests of the applicable Clients with respect to the immediate issue and/or with respect to their longer-term courses of dealing. Certain procedures for resolving specific conflicts of interest are set forth below. When conflicts arise, the following factors generally mitigate, but will not eliminate, conflicts of interest:

a Client will not make an investment unless Sands Capital Alternatives believes that such investment is an appropriate investment considered solely from the viewpoint of such Client;

many important conflicts of interest will generally be resolved by set procedures, restrictions, or other provisions contained in the Client Documentation;

generally, each Fund has the right to establish an advisory committee, consisting of representatives of investors not affiliated with Sands Capital Alternatives. The advisory committees, if established, would meet as required to consult with Sands Capital Alternatives as to certain potential conflicts of interest. On any issue involving actual

conflicts of interest, Sands Capital Alternatives will be guided by its good faith discretion; for some Funds, Sands Capital Alternatives has the right to refer certain conflicted transactions, including principal transactions, to an “independent representative” whose determinations will be binding on the Funds;

where Sands Capital Alternatives deems appropriate, unaffiliated third parties may be used to help resolve conflicts, such as the use of an investment banker to opine as to the fairness of a purchase or sale price;

prior to subscribing to interests in a Fund, each investor receives information relating to significant potential conflicts of interest arising from the proposed activities of the Fund; and

Sands Capital Alternatives and certain of its affiliates have adopted written policies establishing information communication guidelines designed to guard against unlawful and inappropriate disclosure of material, nonpublic information among Sands Capital Alternatives and its affiliates.

Valuation Sands Capital Alternatives will typically be responsible for determining the value of investments. To do so, Sands Capital Alternatives has adopted a valuation policy, which may be updated from time to time in the sole discretion of Sands Capital Alternatives. Many of the securities owned by the Funds will not be publicly traded, and there exists no actively traded market for such securities. For such securities, there will be no reliable market quotations on which to determine valuation. The process of valuing these securities is based on inherent uncertainties, and the resulting values may differ from values that would have been determined had an active market existed and may differ from the prices at which such securities may ultimately be sold. Third-party pricing information may sometimes not be available but regardless, will generally not be used when valuing such assets. Further, Sands Capital Alternatives has discretion as to which methodology(ies) to use when valuing such assets, and choice of valuation methodology(ies) could have a material impact on the valuation. Periods of market disruption or heightened volatility may further limit observable inputs, increasing reliance on judgement and the uncertainty of valuations. The valuations of investments are likely to impact the amount of management fees or incentive allocation Sands Capital Alternatives or its affiliates will receive. Further, valuations of investments have in the past and are likely to in the future be provided to potential investors in connection with fundraising for Funds or investment strategies. In such cases, Sands Capital Alternatives will have an incentive to adopt valuation methodologies that will result in higher valuations. Allocation of Investment Opportunities Among Clients Sands Capital Alternatives and its affiliates, including the Advisory Affiliates, manage a number of funds (including Funds) and accounts with investment strategies substantially similar to, overlapping, or different from, each other. In addition, Sands Capital Alternatives expects that it, its

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Sands Capital Alternatives typically has the authority to select broker-dealers to execute securities transactions for Clients. Sands Capital Alternatives and the Advisory Affiliates share a trading function, and transactions in public securities for Clients are generally effectuated by the shared trading function.

In selecting brokers-dealers, Sands Capital Alternatives seeks to obtain the best overall execution available. In assessing the best overall terms available for any transaction, Sands Capital Alternatives considers factors that it deems relevant, which may include the quality of the brokerdealer, risks associated with the broker-dealer, and potential conflicts of interest between the brokerdealer and Sands Capital Alternatives and/or employees of Sands Capital Alternatives or its affiliates. Factors used to assess the quality of a broker-dealer may include the quality of the research provided, the quality of the trading coverage, the quality of trade operations, and whether the broker-dealer has differentiated technology that may increase Sands Capital Alternatives’ usability or access to liquidity. Factors used to assess the risks associated with a broker-dealer may include minimum net capital requirements and legal and regulatory matters (including FINRA disclosure events). In selecting broker-dealers and negotiating commissions for a particular transaction, Sands Capital Alternatives considers those factors it considers to be relevant, which may include the price of the security, the quality of execution and liquidity services provided, the ability to obtain a timely execution, and the size and difficulty of the order. Sands Capital Alternatives may also consider the reliability, efficiency, accuracy, and the integrity of the broker-dealer’s general execution and operational capabilities, the cost to trade away from a directed broker or custodian (where applicable), the quality of the broker-dealer’s research products or services and other value-add services, and the broker-dealer’s financial condition (but does not consider whether it or a related person receives client referrals from a broker-dealer or third party). In evaluating the best overall terms available, and in selecting the broker-dealer to execute a particular transaction, Sands Capital Alternatives also considers the eligible brokerage and research services (within the meaning of Section 28(e) of the U.S. Securities Exchange Act of 1934, as amended “Section 28(e)”), provided, that Sands Capital Alternatives determines in good faith that the amount of commission is reasonable in relation to the value of the brokerage and research services provided, viewed in terms of either the particular transaction or Sands Capital Alternatives’ overall responsibilities with respect to the Clients as to which it exercises investment discretion. Sands Capital Alternatives may execute securities transactions on an agency or principal basis with a broker-dealer, which may result in a Client (and thus Fund investors) incurring two transaction costs for a single trade: a commission paid to the executing broker-dealer plus the market maker’s markup. Fund investors are not permitted to direct brokerage with respect to purchases or sales of securities by the Funds. Soft Dollars Pursuant to the safe harbor provided in Section 28(e) and to the extent permitted by other applicable law, a broker-dealer who executes a portfolio transaction may receive a commission that is in excess of the amount of commission another broker-dealer would have charged for effecting that transaction if the investment adviser determines in good faith that such compensation was reasonable

in relation to the value of the brokerage and research services provided. This determination may be made on the basis of either that particular transaction or on the basis of the overall responsibility which the investment adviser and its affiliates have for accounts over which they exercise investment discretion. The Advisory Affiliates use such excess commission to pay for Section to 28(e) eligible research and brokerage services (“soft dollar benefits”) that are available to be used by Sands Capital Alternatives for the benefit of Sands Capital Alternatives and Clients. When selecting a broker-dealer to execute certain Client security transactions and to the extent that Sands Capital Alternatives uses soft dollar benefits, Sands Capital Alternatives considers the broker-dealer’s ability to provide soft dollar benefits. Soft dollar benefits include a variety of research and brokerage services provided by the broker-dealer directly or through third parties that are expected to provide lawful and appropriate assistance to Sands Capital Alternatives’ investment decisionmaking responsibilities. To the extent soft dollar benefits are used, these services benefit Clients as well as Sands Capital Alternatives and, in some cases, are not obtainable without the payment of commissions to the providing broker-dealer. To the extent soft dollar benefits are used, Sands Capital Alternatives has an incentive to select broker-dealers based on the benefits it receives from them, whether or not pursuant to soft dollar arrangements described herein. As a fiduciary, Sands Capital Alternatives has an obligation to seek to obtain best execution of Clients’ transactions under the circumstances of the particular transaction. Consequently, notwithstanding the safe harbor provided under Section 28(e), no soft dollars may be generated unless best execution of the transaction is reasonably expected to be obtained. Regardless of the manner in which they are generated and received, Sands Capital Alternatives’ soft dollar benefits, to the extent they are used, are intended to meet the safe harbor requirements under Section 28(e). A product or service may have multiple uses, some of which are eligible under the Section 28(e) safe harbor, and others of which are not. Sands Capital Alternatives can use soft dollars to pay for that portion of the product or service that falls within the safe harbor and will make a reasonable allocation of the cost of the product or service according to its use. Broker-dealers provide a variety of products and services through soft dollar benefits arrangements that include: (i) furnishing advice as to the value of securities and the advisability of investing, purchasing, or selling securities; (ii) furnishing analysis and reports concerning issuers, securities, and performance of accounts; (iii) providing access to third-party research including discussions with third-party analysts, corporate management teams, and groups of professionals with expertise in particular industries and/or subject matter areas (e.g., expert networks) for advice regarding existing or potential investments; or (iv) facilitating securities transactions and performing functions incidental to such transactions, such as clearance, settlement, and custody. Research services received also include data (including alternative data), seminars, written reports, telephone contacts, and meetings with sell-side security analysts, economists, and senior representatives of issuers. Research services received are supplemental to our own research efforts and, when used, are subject to internal analysis before incorporation into our investment process.

The use of soft dollar benefits creates a conflict of interest because a Client’s brokerage commissions pay for products and services that do not exclusively benefit such Client but benefit Sands Capital Alternatives or other Clients, the Advisory Affiliates and their clients. Clients that pay a greater amount of commissions relative to other accounts generally bear a greater share of the cost of brokerage and research services than such other accounts. Certain soft dollar benefits practices benefit some Clients more than others. Research services that are paid for with soft dollars are available for the benefit of all accounts managed or advised by Sands Capital Alternatives and the Advisory Affiliates. In addition, the availability of these non-monetary benefits have the ability to influence Sands Capital Alternatives’ selection of a particular broker-dealer over another to perform services for Clients. Where a broker-dealer does not provide a dollar value of any research products and services or brokerage services obtained with Clients’ commissions, Sands Capital Alternatives will make a good faith determination that the amount of commission paid is reasonable in relation to the value of the brokerage and research products and services provided. Commission Sharing Arrangements Sands Capital Alternatives obtains some of its soft dollar benefits through commission-sharing arrangements (“CSAs”) with certain brokers. Under CSAs, Sands Capital Alternatives arranges with executing brokers to “unbundle” their commission rates in order to allocate a portion of total commissions paid to a pool of “credits” maintained by the broker that can be used, at the direction of Sands Capital Alternatives, to obtain soft dollar benefits made available by service providers. After accumulating credits within the pool, Sands Capital Alternatives or its affiliate directs the broker to use credits to pay service providers for soft dollar benefits made available to Sands Capital Alternatives. Sands Capital Alternatives seeks to match the level of credits accumulated in pools held by various brokers with its anticipated soft dollar benefit requirements based on (1) an annual vote by relevant investment professionals providing services to Sands Capital Alternatives and/or its Advisory Affiliates that rates the quality of the research provided by the brokers and (2) the discretion of the Director of Research of the Advisory Affiliate. CSAs will have surpluses or deficits depending on factors such as the timing of billings for qualifying products or services, the level of trading being executed by Sands Capital Alternatives, and the nature of the executions, among other things. Although agreements with brokers participating in the CSAs typically authorize Sands Capital Alternatives to request that the broker consider using pool credits to pay service providers as recommended by Sands Capital Alternatives, Sands Capital Alternatives does not own the pools of credits maintained with brokers in connection with CSAs. Sands Capital Alternatives uses the eligible research and brokerage products and services furnished by brokers in servicing Clients; not all such products and services will be used exclusively for the benefit of the Clients that pay execution commissions, as described above. Trade Aggregation and Allocation.

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Neither Sands Capital Alternatives nor any related person directly or indirectly compensates any person who is not a supervised person for client referrals. For details regarding economic benefits provided to Sands Capital Alternatives by non-Clients, including a description of the related material conflicts of interest and how they are addressed, please see Item 11 – Code of Ethics, Interest in Client Transactions, and Personal Trading. In addition, Sands Capital Alternatives and its related persons may, in certain instances, receive discounts on products and services provided by portfolio companies and/or the customers or suppliers of such portfolio companies. Sands Capital Alternatives expects from time to time to engage one or more persons to act as a placement agent for a Client in connection with the offer and sale of interests to certain potential investors. Such persons generally receive a fee in an amount equal to a percentage of the capital commitments for interests made by such potential investors to such Client that are subsequently accepted. Management Fees received by Sands Capital Alternatives are generally reduced by the amount of such fees paid by the Client. As some Clients or co-investment vehicles may not pay Management Fees, any such reduction will not benefit such Clients or vehicles (or their underlying investors). In addition, Sands Capital Alternatives expects from time to time be engaged to provide sub-advisory services to investment funds sponsored by unaffiliated third parties. In such circumstances, the third parties or their affiliates will generally be entitled to fees or other remuneration from the relevant investment fund, which will not reduce the amount of fees paid to Sands Capital Alternatives. Sands Capital Alternatives pays nominal fees to be listed and include information about its investment strategies in consultant registries or databases that describe services provided by investment managers including Sands Capital Alternatives.

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to an evaluation of their advisory business or the integrity of their management. Sands Capital Alternatives has no such events and, therefore no information to disclose pursuant to this item.

The investment team of Sands Capital Alternatives monitors the portfolio holdings of each Client on a continuous basis. Reviews evaluate portfolio holdings, as applicable, to: (i) that of the associated strategy model; (ii) Client-specific (or Fund investor-specific) restrictions; (iii) Client investment objectives; (iv) types of securities authorized under Client Documentation; (v) the investment process; (vi) performance; and (vii) other similar matters. Employees of Sands Capital Alternatives or its affiliates have assumed, and likely will continue to assume, seats on portfolio company boards of directors and serve as observers to boards. In conjunction with such positions, Sands Capital Alternatives may provide operational, strategic, and scientific support to the companies. Sands Capital Alternatives generally will provide underlying investors in the Funds with periodic written status reports on investments then held by a Fund, to the extent permitted or required under the applicable Client Documentation. In addition to the reporting provided to all investors,

Sands Capital Alternatives expects to provide certain investors with additional or more frequent information that other investors will not receive (e.g., under a Side Letter, investment management agreement, or in response to diligence or other requests). Sands Capital Alternatives will generally provide to Fund investors: (i) annual GAAP audited and quarterly unaudited financial statements, (ii) annual tax information necessary for each limited partner’s tax return and (iii) at least annual reports providing a narrative summary of the status of each portfolio company. Notwithstanding the foregoing, Sands Capital Alternatives does not provide GAAP audited financial statements to underlying investors in Funds for certain co-investment vehicles. Designated intermediaries of SMAs typically receive a report of their accounts showing account holdings, performance information, and, as applicable, compliance with investment guidelines on a monthly or other interim basis, and investment commentary on a quarterly or other interim basis.

Sands Capital Alternatives generally does not have physical custody of Client funds or securities. However, Sands Capital Alternatives or its affiliates will generally be deemed to have

custody of the funds and securities of one or more Funds under Advisers Act Rule 206(4)-2 (the “Custody Rule”), subject to certain exceptions set forth in the Custody Rule and related guidance. In such cases, (a) the funds and securities will be held with a “qualified custodian,” as defined in the Custody Rule (generally a bank or broker-dealer) independent of Sands Capital Alternatives; and (b) the Funds will be subject to either an annual audit in accordance with generally accepted accounting principles or actual examination at least once during each calendar year by an independent public accountant registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board. Notwithstanding the foregoing, Funds that are subject to an annual audit may have certain privately offered securities recorded only on the books and records of the issuer (if the security is uncertificated) or held in a safe location on Sands Capital Alternatives’ premises (if the security is certificated in accordance with applicable SEC guidance). Investors in a Fund that is not subject to an annual audit receive at least quarterly statements from the Fund’s qualified custodian and should review such statements carefully. SMAs engage custodians directly to maintain custody of their funds and securities, and Sands Capital Alternatives does not have custody of such funds or securities. Sands Capital Alternatives is neither party to, nor responsible for, the terms of any contract between a SMA Client and its custodian.

Sands Capital Alternatives generally provides its investment advisory services to Clients on a discretionary basis, subject, in the case of Funds, to the direction and control of the general partners of the Funds. Such authority, and any policies, restrictions or limitations relating to such authority, are set forth in the Client Documentation.

Sands Capital Alternatives has adopted policies and procedures with respect to the voting of securities held by Clients and has authority to vote proxies on behalf of Clients unless otherwise stated in Client Documentation. Sands Capital Alternatives’ policy is to evaluate and vote in a manner consistent with a Client’s best interests. Sands Capital Alternatives believes that it acts in the best interests of a Client when it votes in a manner that maximizes the economic value of the Client’s holdings. Prior to a voting deadline, Sands Capital Alternatives determines whether and how to vote on each proposal based on its analysis of the information received. In voting, Sands Capital Alternatives is not an automatic supporter of management. Further, there may be times when it determines that refraining from voting is in a Client’s best interest, such as when the cost of voting exceeds the expected benefit to the Client. Clients and investors in a Fund are not able to direct the vote of Sands Capital Alternatives, unless the Client Documentation states otherwise. If a material conflict exists, Sands Capital Alternatives takes steps to ensure that its voting decision is based on the best interests of the relevant Client and is not a product of the conflict. If the Chief Compliance Officer determines that a material conflict of interest exists, then Sands Capital Alternatives may, at its discretion: (a) disclose the conflict of interest to the Client or a committee thereof (or investors in a Fund, as applicable) and consult with such persons (or committee) or defer

to such persons’ (or committee’s) voting recommendation; (b) defer to the voting recommendation of an independent third party provider of proxy voting services; or (c) take such other action that Sands Capital Alternatives in good faith believes would serve the best interests of the relevant Client. Depending on the particular circumstances involved, the appropriate resolution of one conflict of interest may differ from the resolution of another conflict of interest, even though the general facts underlying both conflicts may be similar (or identical). If a Client participates in a securities lending program, Sands Capital Alternatives will not be able to vote the proxy for shares out on loan. Sands Capital Alternatives will generally not seek to recall for voting shares on loan. However, under rare circumstances, for voting issues that may have a particularly significant impact on the investment, Sands Capital Alternatives may request a Client to recall securities that are on loan if Sands Capital Alternatives determines that the benefit of voting outweighs the costs and lost revenue to the Client and the administrative burden of retrieving the securities. Clients may obtain information regarding how Sands Capital Alternatives voted proxies relating to securities held by a Client or request a copy of Sands Capital Alternatives’ proxy voting policies and procedures, by contacting the Chief Compliance Officer at (703) 562-4000 or writing to 1000 Wilson Blvd., Suite 3000, Arlington, VA 22209.

Sands Capital Alternatives does not believe that there are any financial commitments that are reasonably likely to impair the ability of Sands Capital Alternatives to meet its contractual commitments to Clients. Further, Sands Capital Alternatives has not been the subject of a bankruptcy petition at any time during the past 10 years.