Schonfeld Strategic Advisors LLC

Schonfeld Strategic Advisors LLC (the “Advisor”) primarily provides discretionary advisory services to private investment funds, trading vehicles and certain of the Advisor’s affiliates. In limited cases, the Advisor also may provide non-discretionary advisory services to an affiliate. The Advisor’s clients include, but are not necessarily limited to, private investment funds, trading vehicles and family office-related entities. The Advisor also selects, and delegates trading discretion to, affiliated portfolio managers (including internal traders) and unaffiliated portfolio managers (collectively, “Portfolio Managers”) which provide discretionary investment advisory services to clients, including for risk hedging purposes. The Advisor is a Delaware limited liability company that was formed on September 9, 2015. The Advisor is owned 100% by three trusts for the benefit of Steven Schonfeld and/or his family (together, with certain affiliates of Steven B. Schonfeld, including Schonfeld Group Holdings LLC and its subsidiaries, collectively, “SGH”). As of December 31, 2025, the Advisor’s regulatory assets under management were approximately $ 225,251,626,459 on a discretionary basis. When acting as a discretionary adviser, the Advisor has discretion to trade directly for clients and allocate client assets to Portfolio Managers in its discretion. Affiliates that are supervised persons of the Advisor, including internal traders, are referred to herein as “Internal Portfolio Managers.” Managers and general partners of U.S. and non-U.S. private investment funds advised by the Advisor are affiliates of the Advisor; non-U.S. funds are managed by a general partner or Board of Directors, one or more of whose members are affiliates of the Advisor (as set forth herein, the Board and each manager and general partner shall be each referred to as a “Manager” and collectively as the “Managers”). Certain Portfolio Managers may also be affiliated “Relying Advisers” of the Advisor which, in accordance with relevant SEC guidance, operate under the Advisor’s SEC investment adviser registration. The Advisor may utilize additional or different Relying Advisers in the future or may cease to utilize any Relying Advisers. Once selected by the Advisor, the Portfolio Managers exercise investment discretion for certain clients and trading vehicles (“Trading Vehicles”) managed by the Advisor and its affiliates. Clients’ assets are traded directly and/or through such Trading Vehicles. Assets of SGH are also traded through such Trading Vehicles both indirectly (via SGH’s investment in one of the Advisor’s private fund clients) and directly. A Trading Vehicle also may invest in another Trading Vehicle. The assets of each client or Trading Vehicle are allocated to Portfolio Managers who manage client or Trading Vehicle assets through managed accounts or sub-accounts thereof. The Advisor determines and adjusts in its discretion the amount of assets to be allocated to each Trading Vehicle and among the Portfolio Managers and reallocates the amount of such assets between Portfolio Managers and Trading Vehicles periodically (including monthly). Portfolio Managers may also manage client and/or Trading Vehicle assets through private investment funds managed by such Portfolio Managers and/or their respective affiliates. The investment strategies that the Advisor utilizes for any private investment fund client for which it acts as an investment adviser, as well as other information about an investment in such fund, including conflicts of interests, risk factors, and tax and other important disclosures, are described in a particular fund’s private offering documents, and investors in those funds must refer to such materials for specific information about such funds. The information in this Brochure is qualified

in its entirety by such offering documents with respect to such private investment funds, which must be read carefully, and in the event of any conflict between this Brochure and such offering documents, such offering documents will govern. The Advisor does not tailor its advisory services to the individual needs of the investors in any such fund or entity, and investors may not impose restrictions on investing in certain securities or types of securities. The Advisor does not participate in wrap fee programs. As set forth in a fund’s offering documents, various actual and potential conflicts of interest exist among the Advisor, the Managers, their respective principals and their respective employees, agents and affiliates, a fund, other clients, the Portfolio Investments (hereafter defined), Portfolio Managers, and other clients of the Portfolio Managers, including actual and potential conflicts of interest related to fees, portfolio composition, portfolio valuation, expense allocation, selection of counterparties and best execution, treatment of investors, governance matters, limitation of liability, indemnification, allocation of trades and investment opportunities among various clients of the Advisor and Portfolio Managers and outside business activities and personal trading. Certain Committees: The Advisor has organized an executive committee (the “Executive Committee”) currently comprised of Ryan Tolkin, Andrew Fishman, Danielle Pizzo, Adam Rockfeld and Michael Grad. The Executive Committee functions similarly to a board of directors and sets the strategic direction of the Advisor and the prioritization of major business initiatives. The composition of the Executive Committee may vary over time in the discretion of the Advisor. As a committee, the Executive Committee does not have discretionary authority or direct decision-making authority over client accounts. The Advisor has also formed a Global Investment Committee, and a Global Operating Committee comprised of certain senior officers of the Advisor. Certain senior officers of the Advisor are also senior officers of certain of its affiliates. Certain Transactions: The Advisor and certain of its affiliates entered into certain agreements with a large U.S. public financial services company (“Financial Services Company”) and certain of its affiliates in 2019, with respect to certain transactions as set forth below and as described more fully in the funds’ offering documents. The Financial Services Company is the parent company of an SEC-registered broker-dealer and of other U.S. and non-U.S. financial services entities. Under these agreements, (i) the Advisor purchased two asset management companies located in Asia which were owned by a subsidiary of the Financial Services Company and which specialize primarily in a fundamental equity investment strategy, (ii) as part of the purchase price and in connection with the transactions, an affiliate of the Financial Services Company shares in certain revenue relating to the management fees and performance-based compensation charged to, or in respect of, clients utilizing a fundamental equity strategy, including certain private funds primarily utilizing a fundamental equity strategy, as well as certain other clients, and (iii) an affiliate of the Financial Services Company (the “Company Investor”) made an investment in a private fund managed by the Advisor, and is entitled to certain preferential rights as set forth in a side letter arrangement between that fund, the fund’s Manager and the Advisor and the Company Investor. In addition, one or more other affiliates of the Financial Services Company may become an investor in a private fund managed by the Advisor. The applicable funds’ offering documents contain further disclosures regarding the foregoing transactions, including related conflicts of interest.

As part of the foregoing transactions and as described in the applicable funds’ offering documents, the Financial Services Company affiliate that receives the revenue share is also entitled to certain rights with respect to the business of the Advisor, its affiliates and certain funds utilizing a fundamental equity strategy but is not included in, and does not have authority over, day-to-day decision making with respect to the Advisor’s business or investments on behalf of the Advisor’s client accounts, including any fund. Such entity does not have any responsibility for the management or performance of any of the Advisor’s client accounts, including any fund. The revenue share is calculated across certain funds utilizing a fundamental equity strategy using a number of benchmarks and factors. The above revenue share does not apply to (i) an existing fund primarily utilizing a fundamental equity strategy, or (ii) an existing special purpose vehicle formed for the purpose of allowing certain investors exposure to the other private funds advised by the Advisor (the “SPV”).

The Advisor does not have a single standardized management fee or performance fee schedule. Generally, with respect to private investment funds managed by the Advisor that are generally available for subscriptions, the Advisor charges a management fee ranging from 0.75% to 2% (depending on the applicable class of ownership interest) and a performance allocation (including on realized and unrealized gains) ranging from 12.5% to 22.5% (depending on the applicable class of ownership interest) that is allocated to the Manager, an affiliate of the Advisor, of such fund. Certain classes and special purpose vehicles may not be charged a management fee and/or performance allocation. Investors in certain classes of one private fund do not pay a management fee and instead are allocated the expenses of the Advisor and its affiliates as set forth in the fund’s offering documents. Management fees and performance allocations may vary by investor or client, and the Advisor or the Manager may charge different fees or allocations and may waive or rebate a portion thereof. The management fee and performance allocations described above are in addition to the fees and performance-based compensation charged by Portfolio Managers who manage the funds’ assets. Currently, private investment funds managed by the Advisor that are generally available for subscriptions utilize either a (i) mini-master feeder structure in which one fund invests (as a “feeder” fund) substantially all of its assets in another fund, acting as a “master” fund, or (ii) master-feeder structure in which a domestic and offshore “feeder” fund each invests substantially all of its assets into a “master” fund. To the extent any such structure involves a feepaying fund client, management fees and performance-based compensation may be charged at either the “feeder” level, the “master” level, or an intermediate vehicle level, but not at more than one level. The expenses of the Advisor are generally borne by its non-management-fee-paying clients and certain management-fee-paying clients (in each case, either by payment or reimbursement) and are allocated in the discretion of the Advisor or relevant Manager, as applicable. Expenses of the Trading Vehicles, the Portfolio Managers and the Advisor’s affiliates are borne by non-management-fee-paying and management fee-paying clients of the Advisor, as applicable. Expenses of the Advisor may also be paid through an offset using management fees of a management-fee-paying client. Expenses for a particular client will be allocated to such client. Client expenses also include the fees and performance-based compensation charged by or paid to Portfolio Managers (including Internal Portfolio Managers) who manage or trade such client’s assets. Expenses for more than one client generally will be allocated to the applicable clients on a

pro rata basis generally based on the total assets invested by each such client; however, in certain circumstances, as set forth in the relevant fund’s private offering documents, the assets of Portfolio Managers (and their related parties, including, without limitation, investment vehicles sponsored and offered by Portfolio Managers and/or their affiliates) who invest in a certain class of a private fund are only traded pursuant to that Portfolio Manager’s strategy (and therefore not other Portfolio Managers in the fund) and are only subject to expenses associated with that class and its trading; accordingly, references to expense allocation on a pro rata basis do not include such class. Such class is also not subject to any performance allocation. The expenses of any such fund, the Trading Vehicles, the Advisor and its affiliates may be greater than the expenses incurred by investing in a similarly situated fund or utilizing the services of another investment adviser providing similar services and charging a management fee and performance-based compensation. Certain expenses paid and/or indirectly borne by non-management-fee-paying clients, as well as certain management-fee-paying clients, reflect overhead expenses of the Advisor and its affiliates. Both management-fee-paying and non-management-fee-paying clients pay and/or indirectly bear the cost of the applicable Portfolio Managers which manage such clients’ assets and the applicable Trading Vehicles through which client assets are managed, including advisory fees and performance-based compensation paid to Portfolio Managers. Internal Portfolio Managers receive performance-based compensation (and in limited cases, salaries) and certain employees and members of the Advisor and its affiliates are compensated (including through bonuses) based on the returns and/or performance of the Trading Vehicles and affiliates of SGH, the cost of which are indirectly borne by non-management-fee-paying clients and certain management-fee-paying clients on a pro rata basis as set forth in the applicable fund’s offering documents. All or a portion of the management fee compensation payable by certain management-fee-paying funds (to the extent not paid to the Financial Services Company and/or any Solicitor (hereafter defined)) will be used by the Advisor to offset expenses incurred by the Advisor and its affiliates. Any revenue paid to the Financial Services Company affiliate from amounts otherwise payable to the Advisor or the Manager from a fund will reduce the amount of the management fees available to be otherwise used to offset expenses as described herein. A similar offset will not occur in connection with performance-based compensation paid by the aforementioned management-fee-paying funds. Certain classes of private investment funds managed by the Advisor are subject to a lock-up period. Notwithstanding such lock-up, under certain cases as described in such funds’ offering documents, an investor in certain classes may be permitted to make a complete or partial withdrawal of its interest in such fund subject to a withdrawal fee ranging from 5% to 10% of the amount of withdrawal, which fee is payable to such fund (or the “master” fund in a “master- feeder” fund structure), not to the Advisor. Private investment funds are subject to their own respective expenses. A particular fund’s expenses are described in such fund’s private offering documents. In addition to the foregoing fees, clients incur additional costs including brokerage commissions, transaction fees, and other costs and expenses which shall be incurred by the client, including charges imposed by the Portfolio Managers, custodians, brokers, and other third parties. Overall expenses may be substantial. Portfolio Managers (including though any private investment funds managed by the Portfolio Managers) also charge their own advisory fees and/or performance-based compensation, which are indirectly or directly borne by clients (and if invested therein, such investments will also be subject to the expenses of such private investment funds managed by such Portfolio Managers).

Management fees and performance-based compensation will be set forth in the respective private fund’s offering documents or if applicable, other client disclosures and/or documentation.

The overall objective of the Advisor’s investment strategy is to achieve capital appreciation of client assets at superior risk-adjusted rates of return. The primary general investment strategies in which the Portfolio Managers invest are: fundamental equity, systematic, tactical trading, and discretionary macro and fixed income. In addition to these primary strategies, certain Portfolio Managers may also invest, directly or indirectly, in equity and debt securities of unaffiliated private companies (“Private Securities”). Specific risk disclosures related to such investments will be set forth in the respective private fund’s offering documents. The Advisor invests in U.S. and non-U.S. financial instruments for its clients, including, but not limited to, stocks, exchange-traded funds (“ETFs”) (including, but not limited to, digital asset ETFs), bonds, options, warrants, swaps, forwards, futures, currencies, digital assets, futures contracts (including, but not limited to, exchange-traded digital asset futures contracts and perpetual futures contracts on digital assets), commodities, repurchase agreements, partnership, limited liability company and other equity interests (including Private Securities), money market instruments, debt securities and other securities and derivatives (collectively, “Instruments”). The Portfolio Managers (including private investment funds managed by the Portfolio Manager) also invest in a variety of Instruments. The steps involved in the selection of Portfolio Managers are generally characterized by both quantitative and qualitative diligence, as described herein. The Advisor exercises significant discretion in the processes to be employed in identifying and selecting Portfolio Managers, and may not employ the same selection methodology described herein with respect to all Portfolio Managers (including, by way of example, where a prospective Portfolio Manager has a limited quantitative performance history or limited access to such history, in which case the Advisor’s

processes will rely more on qualitative criteria and other factors deemed relevant in the Advisor’s sole discretion). One method by which the Advisor identifies prospective Portfolio Managers is through disciplined “bottom-up” due diligence, which generally involves the quantitative assessment of historical risk/return characteristics of the Portfolio Manager, including performance during times of market stress, as deemed appropriate in the Advisor’s discretion. Other important quantitative considerations generally include, but are not limited to, market correlation and betas, return distribution skewness, growth in assets under management (and the potential for performance deterioration, as a result of this growth), investment identification methodology (e.g., statistical versus fundamental), frequency of position turnover, degree of position concentration with a Portfolio Manager’s holdings, and lock-up requirements. The Advisor bases decisions to allocate capital on both the quality of the Portfolio Manager and the particular fit of such Portfolio Manager’s investment strategies within the client’s portfolio, based on the then prevailing portfolio composition. In addition to the quantitative diligence used by the Advisor in assessing a Portfolio Manager, the Advisor also performs a qualitative and subjective assessment of a Portfolio Manager’s business operations and infrastructure to assess the existence of “operational risk.” The Advisor’s due diligence process on each prospective Portfolio Manager generally entails a background check and may include an on-site office visit when deemed necessary. Although the length of a Portfolio Manager’s performance track record is often an important factor in the decision, the Advisor may at times identify and allocate assets to new and unproven Portfolio Managers due to such Portfolio Managers’ pedigree, prior performance or other factors deemed relevant in the Advisor’s sole discretion. On behalf of a fund and/or applicable Trading Vehicle, the Advisor may engage or terminate a Portfolio Manager in its discretion, subject to the terms of the investment management or similar agreement with the Portfolio Manager, which agreement grants the Portfolio Manager trading discretion and generally sets forth terms related to the Portfolio Manager’s investment strategy, allocation limits, exclusivity period (if any), compensation, paid Portfolio Manager expenses and indemnification of the Portfolio Manager by such Fund (and/or Trading Vehicles) and other customary and specific terms. Each Portfolio Manager is responsible for its own portfolio composition and risk management activities. However, the Advisor monitors performance, strategy drift, portfolio composition, and portfolio diversification of the Portfolio Managers. In general, the Advisor has real-time or other intraday trading information with respect to the Portfolio Managers. The Advisor may allocate and reallocate assets to a Portfolio Manager or between and among Portfolio Managers in its discretion, subject to the terms of the investment management or similar agreement with each Portfolio Manager. Certain Portfolio Managers trade the assets of more than one Trading Vehicle. The Advisor (and its respective supervised persons) do and may serve as a Portfolio Manager. The following is a summary of the material risks associated with the Advisor’s strategy. Investors in private investment funds advised by the Advisor must review the fund’s offering documents for a description of the risks associated with the fund and its investment strategy,

including other risks such as general economic risks, regulatory risks, operational risks (including cybersecurity risks), tax risks, and other risks related to the fund(s). As used herein and elsewhere in this Brochure, as applicable: (i) the “Fund” refers to the private investment fund clients (which include funds that are part of “master-feeder” structures) advised by the Advisor and managed by a Manager; (ii) “investor” refers to an investor in a Fund; and (iii) “Portfolio Investments” generally refers to Trading Vehiclemanaged accounts or sub-accounts managed by the Portfolio Managers (and the Instruments traded therein) and the private investment vehicles managed by such Portfolio Managers. As applicable based on context, references to a Fund include the Trading Vehicles through which such Fund trades its assets and references to Trading Vehicles and trading conducted by Trading Vehicles also includes references to Fund(s) and trading conducted by such Fund(s) to the extent those Fund(s) trade directly and not through Trading Vehicles. Risk of Loss: Investing in securities involves risk of loss that clients should be prepared to bear. All investments in securities and other financial investments involve substantial risk of volatility arising from numerous factors that are beyond the control of the Advisor and investment managers utilized by the Advisor, including market conditions, changing domestic or international economic or political conditions, changes in tax laws and government regulation and other factors. Multiple Levels of Expense. As with most multi-manager investment platforms, in addition to fees and compensation charged by the Advisor and its affiliates, and expenses at one or more Fund levels, Trading Vehicle levels, the Portfolio Managers and the Portfolio Investments charge and/or impose fees (including management fees and performance-based compensation) and expenses. These fees and expenses result in lower returns on investment than if such fees and expenses were not charged or imposed. Portfolio Managers may charge fees directly or through an underlying fund which they and/or their affiliate manage (at which level, such fund will also bear its own expenses). The multiple levels of fees and expenses will reduce the overall profitability of the Fund. Investors in the Fund are subject to higher aggregate fees and expenses than if they were able to invest with such Portfolio Managers or Portfolio Investments directly. General Investment and Trading Risks. All investments risk the loss of capital. No guarantee or representation is made that the Fund’s and the Portfolio Investments’ investment programs will be successful or profitable. The Fund’s and the Portfolio Investments’ investment programs may involve, without limitation, risks associated with limited diversification, leverage, interest rates, currencies, volatility, tracking risks in hedged positions, security borrowing risks in short sales, credit deterioration or default risks, systems risks and other risks inherent in the Fund’s and the Portfolio Investments’ activities. Certain investment techniques utilized by the Fund and the Portfolio Investments will, in certain circumstances, substantially increase the impact of adverse market movements to which the Fund and such Portfolio Investments will be subject. In addition, the Fund’s and the Portfolio Investments’ investments will be materially affected by conditions in the financial markets and overall economic conditions occurring globally and in particular countries or markets where the Fund and the Portfolio Investments invest their assets, including conditions resulting from wars, terrorist acts, natural disasters, security operations, local epidemics or global pandemics. The Fund’s and the Portfolio Investments’ methods of minimizing such risks may not accurately predict future risk exposures. Risk management techniques are based in part on the observation of historical market behavior, which may not predict market divergences that

are larger than historical indicators. Also, information used to manage risks may not be accurate, complete or current, and such information can be misinterpreted. Activities of Investment Managers and Investment Funds: While the Advisor receives information about the Portfolio Managers, the Advisor ultimately will not have complete control over the day-to-day operations of any unaffiliated investment fund or investment manager. As a result, there can be no assurance that every investment fund or investment manager will invest on the basis expected by the Advisor. Furthermore, because the Advisor will not have complete control over any investment fund’s or investment manager’s day-to-day operations, clients may experience losses due to the fraud, poor risk management or recklessness of the investment funds or the investment managers. Allocation Risks: Investment performance will depend largely on the Advisor’s decisions as to strategic asset allocation and tactical adjustments made to the asset allocation. At times, the Advisor’s judgments as to the asset classes in which clients should invest may prove to be wrong, as some asset classes may perform worse than others or the equity markets generally from time to time or for extended periods of time. In certain cases, orders on behalf of certain Funds and Portfolio Investments may be placed on an aggregated basis. If each Fund and Portfolio Investment participating in an aggregated order receives its full desired allocation, then each participating Fund and Portfolio Investment generally receives the average price per share paid or received with transaction costs shared pro rata among participating clients. If each participating Fund and Portfolio Investment receives less than its full allocation, then each participating Fund and Portfolio Investment generally receives its pro rata portion of the executed order with transaction costs shared among all participants proportionately. Under certain circumstances, the Advisor has discretion to utilize alternative allocation procedures with respect to certain Fund and Portfolio Investment allocations, provided that all participating Funds and Portfolio Investments are treated fairly and equitably. In certain situations, the Advisor may be responsible for allocating trades to multiple Funds and Portfolio Investments without instructions from the Portfolio Managers on how to make such allocations or without the Portfolio Manager’s knowledge of pre-trade peraccount order demands. While the Advisor generally will use commercially reasonable efforts to allocate trades in a fair and equitable manner such that trades made across multiple accounts are executed in a pari passu manner, the Advisor’s allocation of trades may not accurately reflect intended trade allocations, in particular during the initial ramp-up period with respect to a particular Fund’s or Portfolio Investment’s trading activities. During any period in which the Advisor’s allocation of trades may not accurately reflect intended trade allocations, investors in the Funds and Portfolio Investments may face certain risks. Such risks may include, but are not limited to, (a) heightened potential for performance drift between pari passu accounts, the overall length and magnitude of which may be more significant during the initial ramp-up period with respect to a particular account’s trading activities, (b) suboptimal rebalancing, and (c) potential biased treatment of an account with respect to capital rebalancing or trade allocations, all of which could adversely impact a Fund’s or Portfolio Investment’s performance. In addition, in accordance with the Advisor’s allocation policy, there are situations in which the Advisor may allocate trades in a non-pari passu manner. Such circumstances include, but are not limited to, the Advisor being unable to allocate trades in a pari passu manner due to the (1) different executing brokers being used by applicable accounts; (2) a Fund’s or Portfolio

Read the rest in the brochure

A description of the Advisor’s clients is provided above in Item 4 – Advisory Business. As described above, in certain circumstances, private investment funds managed by the Advisor (so called- “feeder” funds) invest in other private investment funds acting as “master” funds, also managed by the Advisor. Certain fund clients have been formed under the laws of a foreign jurisdiction (i.e., a non-U.S. fund). With respect to any private investment fund, investment advice will be provided to such fund, as applicable, and not individually to each of the investors in the fund. A private investment fund may have different classes with different subscription, withdrawal and other terms. The investment minimums and investor eligibility requirements relating to investments in a private investment fund advised by the Advisor are stated in the fund’s offering documents. The Managers of such funds (which are affiliates of the Advisor) may waive or reduce the amount of any such minimum initial or additional subscriptions or withdrawals in their sole discretion, subject to applicable legal or regulatory requirements.

Generally, with respect to private investment funds managed by the Advisor that are generally available for subscriptions, a performance allocation of, depending on the applicable class of ownership interest, 12.5% to 22.5% (including on realized and unrealized gains) may be allocated to the Manager of a respective fund. Performance allocations are subject to a loss recovery account or “high water mark,” and may be subject to certain other adjustments, as described in a fund’s offering documents. These funds’ performance allocations are in addition to the fees and performance-based compensation charged by Portfolio Managers who manage such funds’ assets. For all clients, Portfolio Managers (including Internal Portfolio Managers) are paid performance-based compensation, which is directly or indirectly borne by clients whose assets are managed or traded by such Portfolio Managers. Internal Portfolio Managers receive performance-based compensation (and in limited cases, salaries) and certain employees and members of the Advisor and its affiliates are compensated (including through bonuses) based on the returns and/or performance of the Trading Vehicles and affiliates of SGH, the cost of which are indirectly borne by nonmanagement-fee-paying clients and certain management-fee-paying clients on a pro rata basis as set forth in the applicable fund’s offering documents. Performance-based compensation may create an incentive for the Advisor or a Portfolio Manager to cause the funds described above, or, as applicable, a client, to make investments that are riskier or more speculative than would be the case in the absence of performance-based compensation. In addition, because the performance-based compensation is calculated on a basis that includes unrealized appreciation of such funds’ or client’s assets, it may be greater than if such compensation were based solely on realized gains. The Advisor manages the assets of SGH (both directly and indirectly) within the same Trading Vehicles as assets of non-affiliated clients (over which Portfolio Managers of such Trading Vehicles exercise trading discretion). As described above, the Advisor also manages client assets for which the Advisor itself does not charge any management fee, and such clients are subject to various expenses, including Advisor overhead expenses. The Advisor may have a conflict of interest by managing these management-fee and non-management-fee paying clients at the same time, including that the Advisor may have an incentive to favor a client for which it (or a Manager affiliate of it) receives a performance-based fee or allocation (including by devoting more time to such client) and may have an incentive to allocate expenses to non-management-fee-paying clients instead of management-fee-paying clients who do not bear such expenses. In connection with the foregoing, the Advisor has agreed that all or a portion of the management fee compensation payable by the management-fee-paying funds described above (to the extent not paid to the Financial Services Company and/or any Solicitor (hereafter defined)) will be used by the Advisor to offset expenses incurred by the Advisor and its affiliates. See also Item 5 – Fees and Compensation and Item 4 –Advisory Business above and Item 10 – Other Financial Industry Activities and Affiliations below.

The Advisor may receive management fees, and the Advisor’s affiliates may receive performancebased compensation from other private investment funds in the future. Such compensation will be set forth in the respective private fund’s offering documents.

As discussed in Item 4 – Advisory Business, Portfolio Managers can include internal individual supervised persons trading on behalf of the Advisor and other Portfolio Managers affiliated with the Advisor. Certain Portfolio Managers are employed by an affiliate of the Advisor, but are not supervised persons of the Advisor and are not registered under the Advisor’s SEC investment adviser registration. Given that such Portfolio Managers are affiliates of the Advisor, the Advisor has a potential disincentive to use an unaffiliated portfolio manager for the provision of such services and terminate the services provided by such Portfolio Managers. SSM, an affiliate of the Advisor, serves as the Manager of a private investment fund and certain trading vehicles advised by the Advisor and is a registered Commodity Pool Operator and serves in that capacity with respect to several private investment funds. Each of Schonfeld FE Partners LLC, SSAF Fund GP LLC, SBOS Fund I GP LLC and SBOS Fund II GP LLC, each an affiliate of the Advisor, serves as the Manager of one of the private investment funds advised by the Advisor and is exempt from registration as a Commodity Pool Operator. Schonfeld Strategic AWF GP LLC, an affiliate of the Advisor, serves as the Manager of the SPV, which is advised by the Advisor and is exempt from registration as a Commodity Pool Operator. The Advisor is also exempt from registration as a Commodity Trading Advisor. Certain affiliates of the Advisor act as Portfolio Managers and are “Relying Advisers” and as such are subject to the Advisor’s oversight, and their personnel are considered supervised persons of the Advisor. Such Relying Advisers currently include Schonfeld Strategic Advisors (Brazil) Ltda., Schonfeld Strategic Advisors (Singapore) Pte. Ltd., Schonfeld Strategic Advisors (Hong Kong) Limited, Schonfeld Strategic Advisors (UK) LLP, Schonfeld Strategic Advisors (Japan) Pte. Ltd., Schonfeld Strategic Advisors (Australia) Pty Ltd. and Schonfeld Strategic Advisors (DIFC) Ltd., each of which is also regulated under local law. Certain other affiliates of the Advisor like the foregoing Managers are considered “special purpose vehicles” (i.e., managers) for private investment funds managed by the Advisor and are subject to the Advisor’s oversight, and their personnel are considered supervised persons of the Advisor. An affiliate of the Advisor provides technology and administrative products and services to the Advisor and its affiliates, Trading Vehicles and fund clients as set forth in the Funds’ offering documents. The Advisor has established and operates various investment funds and may enter into other investment advisory relationships with other clients in the future. Such other funds or clients can be allocated all or part of investment opportunities that would also be appropriate for the Advisor’s current clients, and such allocations may be disadvantageous to the Advisor’s current clients. The Advisor and its affiliates may have a conflict of interest because of differing financial interests, direct or indirect, with respect to the Advisor’s clients. As a result, the Advisor may have an incentive to favor certain clients with regard to the allocation of opportunities or participation in particular investments and with regard to the terms of any transactions among clients, or favor fee paying (or higher fee paying) clients over other non-fee paying (or lower fee paying) clients. Further, decisions regarding the allocation of initial public offerings, secondary offerings, and other capital markets transactions are shaped by a variety of qualitative and quantitative factors

that the Advisor considers when distributing Portfolio Investments amongst Portfolio Managers. Such factors may include but are not limited to, the Portfolio Manager’s early communication of interest, regional wallet contribution, sector knowledge and expertise, contribution of work to the specific transaction and overall participation in transactions. This approach is intended to enable the allocations to reflect the strategic contributions and engagement of Portfolio Managers, rather than the numerical size of their orders. See Item 5 – Fees and Compensation and Item 6 – Performance-Based Fees and Side-By-Side Management above.

The Advisor has adopted a Code of Ethics for itself and all employees and supervised persons of the Advisor describing its high standard of business conduct and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, gifts and entertainment items, and personal securities trading procedures, among other things. All access persons of the Advisor must acknowledge the terms of the Code of Ethics annually, and as amended. Client assets may be invested in the Trading Vehicles which are advised and managed by the Advisor and its affiliates. Also, certain affiliates of the Advisor are clients, and their assets are managed on a discretionary basis with client assets in the Trading Vehicles. The Advisor manages these conflicts of interest by disclosure to clients and managing the Trading Vehicles pursuant to its fiduciary obligations under the U.S. Investment Advisers Act of 1940, as amended (the “Advisers Act”). The Advisor’s Code of Ethics also addresses conflicts of interest between personal trading and client trading. The Advisor, its affiliates and their officers, directors and employees may trade for their own accounts in certain securities which are recommended to and/or purchased for Advisor’s clients. The Code of Ethics is designed so that the Advisor may monitor the personal securities transactions to protect clients. The Code requires reporting of personal trading information and pre-clearance of transactions in equity and equity-linked securities and private placements and generally prohibits purchasing securities in initial public offerings. Nonetheless, because the Code of Ethics in some circumstances would permit personnel to transact in the same securities as clients, there is a possibility that persons might benefit from market activity by a client in a security held by such person. Personal trading is monitored under the Code of Ethics to reasonably minimize or prevent conflicts of interest between the Advisor and its clients. Subject to regulatory requirements relating to investor eligibility, officers and other Advisor personnel have invested, and may from time to time in the future invest, their personal funds in the private investment funds advised by the Advisor. The Advisor generally does not effect principal transactions for client accounts. In the event any such transaction(s) occur, each will be done in accordance with applicable regulatory requirements, including prior consent by the client or an independent representative acting on the client’s behalf. The Advisor or a Portfolio Manager may engage in transactions in which it causes the Fund (or a Trading Vehicle) to purchase Instruments from, or sell Instruments to, the Fund or Funds or managed accounts managed by the Managers, the Advisor or a Portfolio Manager and/or their affiliates (as applicable) (“cross-trades”) for purposes of portfolio rebalancing or for other

reasons as may arise from time to time. Neither the Advisor nor a Portfolio Manager (as applicable) will take brokerage commissions or otherwise be specially compensated for effecting these crosstrades. The Advisor and each Portfolio Manager (as applicable) intends that cross-trades will, to the best of its ability, reflect the market value of the security or other instrument being purchased or sold, and the cross-trade will be subject to the Advisor’s or the Portfolio Manager’s duty of best execution, as applicable. Prior to effecting any cross-trade, the Advisor or the Portfolio Managers (as applicable) will make a good faith determination that the transaction is in the best interests of the Fund and other clients, as applicable. The Advisor will not effect agency cross transactions. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions may arise where an adviser is dually registered as a brokerdealer or has an affiliated broker-dealer. Advisor’s clients or prospective clients may request a copy of the Advisor’s Code of Ethics by contacting Hung Luc, Global Chief Compliance Officer, at +44 0 20 7154 6662 or hluc@schonfeld.com.

The Advisor does not adhere to any specific allocation criteria or other formulas in selecting brokers and will weigh a combination of the criteria described herein. In selecting brokers, the Advisor need not solicit competitive bids, does not have an obligation to seek the lowest available commission cost and may select a broker which charges brokerage commissions in excess of that which another broker might have charged for effecting the same transaction. The Advisor does not select brokers on the basis of the commission rates only, and thus a client may be deemed to be paying for brokerage and/or research provided by the broker, which is or may be deemed to be included in the commission rate. The extent to which commission rates or net prices charged by brokers reflect the value of research provided, and other products and services received cannot be readily determined. The Advisor will make a good faith determination that the amount of commission is reasonable in relation to the value of the brokerage and research received, viewed in terms of either the specific transaction or series of transactions or the Advisor’s overall responsibility to its clients. Research and other products and services may be used by the Advisor in servicing some or all of its clients. Private funds (or Trading Vehicles, as applicable) enter into prime brokerage arrangements with one or more prime brokers. The Advisor and/or the Portfolio Managers select brokers to execute portfolio transactions on behalf of the Trading Vehicles. Generally, the Advisor or its affiliate selects the custodians that hold the assets of a Fund(s) or Trading Vehicle(s), as the case may be. The brokers, prime brokers and custodians can be replaced, and other brokers, prime brokers and custodians may be retained at any time without the consent of clients. In selecting brokers and negotiating commission rates, the Advisor or a Portfolio Manager can take into account the financial stability and reputation of brokerage firms, and the research, brokerage or other services provided by such brokers. A Fund or Trading Vehicle may have more than one prime broker.

The Advisor and its affiliates and the Portfolio Managers will also look at factors such as price, the ability of the brokers to effect the transactions, the brokers’ facilities, reliability and financial responsibility, execution and routing services and brokerage or research services (“soft dollar items”) provided by such brokers. Generally, the Advisor expects to use soft dollars, and engage Portfolio Managers whose use of soft dollars will be, within Section 28(e) of the U.S. Securities Exchange Act of 1934, as amended (the “Exchange Act”), or its equivalent. Section 28(e) establishes a safe harbor (the “Section 28(e) safe harbor” or “safe harbor”) allowing investment managers to use client funds, by way of commission dollars, to purchase certain “brokerage and research services.” To the extent that such “brokerage and research services” are provided to a Fund, the Advisor, the Portfolio Managers and their respective principals and affiliates and/or other funds and/or accounts managed by the Advisor, Portfolio Managers and/or their respective affiliates in connection with trading futures or options on futures, it is expected that such incidental benefits would fall within the Section 28(e) safe harbor as if such benefits were being provided in connection with the trading of securities. Pursuant to such safe harbor, the brokerage and research services must provide lawful and appropriate assistance to the investment manager in the performance of its investment decision-making responsibilities. The Advisor or Portfolio Managers may allocate transactions to brokers in consideration of such brokers’ provision of, or payment of the cost of, certain services that are of benefit to the applicable Trading Vehicles and/or other clients of the Advisor or Portfolio Manager. In such circumstances, portfolio transactions are allocated to brokers in consideration of such factors as price, the ability of the brokers to effect the transactions, the brokers’ facilities, reliability and financial responsibility, and any research, investment management-related and/or brokerage products and services provided by such brokers. Accordingly, if the Advisor or a Portfolio Manager determines in good faith that the amount of commissions charged by a broker is reasonable in relation to the value of the brokerage and research or investment managementrelated services and equipment provided by such broker, the Advisor or a Portfolio Manager may pay commissions to such broker in an amount greater than the amount another broker might charge. In the cases where it selects brokers and negotiates commission rates, consistent with its duty of best execution, the Advisor or a Portfolio Manager will take into account a number of factors, including, among others, the financial stability, reliability and reputation of brokerage firms, the size and type of the transaction, execution capabilities, the difficulty of execution, commission rate/net pricing, the broker’s expertise with the particular financial instrument, the broker’s ability to handle a block order and other brokerage and research products and services provided by such brokers. In selecting brokers, the Advisor will consider the value of brokerage (such as efficiency of execution, order routing, clearing and settlement services) and research products and services (collectively, “research”) received by a broker, either directly provided by the broker (proprietary research), or paid for by the broker to be provided by others (third party research). By its receipt and use of research or certain brokerage services, the Advisor or a Portfolio Manager may be considered to be receiving “soft dollar” benefits from the brokers it utilizes. The Advisor, however, does not participate in any formal soft dollar arrangements, earn soft dollar credits or pay specific additional brokerage commissions for research or other types of soft dollar benefits. To the extent the receipt of research or brokerage by the Advisor or a Portfolio Manager are deemed to be soft dollar benefits, such benefits in connection with the trading of (i) securities, will fall within the safe harbor of Section 28(e) of the Exchange Act, and (ii) futures or options on futures, will fall

within the Section 28(e) safe harbor as if such benefits were being provided in connection with the trading of securities. Research under Section 28(e) that the Advisor or a Portfolio Manager receives and may incorporate into its investment decisions and recommendations may be in written, electronic or oral form and may include, among other things, research concerning market, economic and financial data, a particular aspect of economics or on the economy in general, statistical information, pricing information and performance measurement services, analyses concerning specific securities, instruments, companies, industries or sectors and market, economic and financial studies and forecasts. To the extent that such products and services are obtained, the Advisor and Portfolio Managers will be receiving a benefit by reason of the direction of commissions. The Advisor believes that overall clients benefit from the Advisor’s receipt of research although research may not be used by the Advisor in servicing all of its clients or any particular client. In addition, some research may not necessarily be used by the Advisor or Portfolio Manager in servicing the client(s) whose commission dollars may be deemed to have provided for such research. A client may not, in any particular instance, be the direct or indirect beneficiary of the specific brokerage or research products and services provided. The Advisor or Portfolio Manager may have an incentive to select a broker based on the fact that it will receive research. Therefore, the Advisor or Portfolio Manager may have a conflict of interest between its duty to obtain best execution for a client and its interest in receiving such benefits. The Advisor’s or a Portfolio Manager’s expenses could increase materially if it attempted to generate such additional information and services on its own. The Advisor at least annually evaluates its brokerage practices and the reasonableness of commissions paid by its clients. The extent to which commission rates charged by brokers reflect the value of brokerage and research received cannot be readily determined. Although the commission rates charged by such brokers are generally deemed to not specifically reflect such additional benefits, the commission rates charged by such brokers may be higher or lower than other brokers.

Except as set forth with respect to certain soft dollar benefits in Item 12 – Brokerage Practices, the Advisor will not receive any economic benefits from any non-client for providing investment advisory services to the Advisor’s clients. The Advisor or one of its affiliates has entered into, and may from time to time enter into additional, referral or placement agent agreements with thirdparty marketing firms, including third party consultants, solicitors, placement agents and others (“Solicitors”), whereby such Solicitors agree to solicit and refer prospective clients or qualified investors. Any arrangements with Solicitors will be disclosed to the prospective clients or investors

involved prior to them becoming advisory clients or admitting them as fund investors. Depending on the arrangement, the Solicitor may be compensated by a particular Fund as permitted by the Fund’s offering documents (e.g., if the referred investor is a strategic investor), by the referred client or investor, or by the Advisor (and/or its affiliate) by paying a portion of its management fees, performance-based compensation or otherwise. Because of the transactions with the Financial Services Company, a Manager may have an incentive to utilize an affiliate of the Financial Services Company for placement agent or related services. Solicitation arrangements with respect to advisory clients shall comply with SEC Rule 206(4)-1, as applicable. A Fund’s offering documents will contain provisions applicable to Solicitors and Fund investors.

On June 6, 2024, Schonfeld Strategic Management LLC (“SSM”), an affiliate of the Advisor (as described further below in Item 10), accepted an offer of settlement (neither admitting nor denying) regarding an alleged violation of New York Mercantile Exchange (“NYMEX”) Rule 538.C (the Exchange for Related Positions or “EFRP” rule). More specifically, SSM exchanged January 2023 platinum futures contracts that it was unable to take physical delivery of for an equivalent overthe-counter position. A Panel of the NYMEX Business Conduct Committee found this October 2022 EFRP to be non-bona fide (as required in the EFRP rule) due to the absence of any market risk. SSM agreed to pay a $20,000 fine to the Chicago Mercantile Exchange to settle the matter.

Other than as described above, the Advisor and the Advisor’s management personnel do not have any disciplinary events that are material to an evaluation of the Advisor’s business or the integrity of management.

The Advisor monitors compliance with the investment objectives of its clients on an ongoing basis, but at least monthly. In general, the Advisor receives real-time or intraday information regarding Trading Vehicle accounts. As set forth in the Funds’ offering documents, investors in a private investment fund advised by the Advisor will receive periodic information, which shall include Fund performance information, and copies of the annual audited financial statements for the Fund.

The Advisor and/or its affiliates have entered into agreements with qualified custodians to maintain custody of client assets as required by Rule 206(4)-2 under the Advisers Act. While the Advisor does not maintain physical custody of any client funds or securities, its affiliates will act as the manager of private investment funds advised by the Advisor, and, therefore, pursuant to the SEC’s custody rule (Rule 206(4)-2), the Advisor (through its affiliate) does have custody of such client assets. Pursuant to the custody rule, audited financial statements will be delivered to each Fund investor within 120 days of the end of each fiscal year, and the Advisor is, therefore, exempt from certain other requirements of the SEC’s custody rule.

As stated above in Item 4 – Advisory Business, the Advisor primarily provides discretionary advisory services to private investment funds and to certain of the Advisor’s affiliates. The investment advisory agreement between the Advisor and a client specifies whether the Advisor is delegated discretionary or non-discretionary authority over the client’s account. In limited cases, the Advisor also provides non-discretionary advisory services to an affiliate. Under a discretionary advisory agreement, the Advisor has full power and authority to invest the assets of the client (including a private investment fund or a Trading Vehicle) on a discretionary basis and to act as the client’s attorney-in-fact in furtherance of such advisory services. The Advisor’s exercise of discretion is governed by (and if applicable, limited by) the relevant investment advisory agreement, the relevant private fund offering documents and its fiduciary duty. Generally, advisory agreements will be renewed automatically for successive one-year periods as of December 31 of each year unless the Advisor gives sixty (60) days’ prior written notice of its intention not to renew the agreement. Each advisory agreement may be terminated as set forth therein (generally by prior written notice or upon events of default).

To the extent the Advisor has been delegated proxy voting authority on behalf of its clients, the Advisor will comply with its proxy voting policies and procedures that are designed to ensure that in such cases where the Advisor votes proxies with respect to client securities, such proxies are voted in the best interests of its clients. The Advisor does not vote all proxies and generally only votes those non-standard or noncustomary proxies in cases where client accounts hold a material position in the company. The Advisor’s clients are not permitted to direct their votes in a particular solicitation. If a material conflict of interest between the Advisor and a client exists, the Advisor will determine whether voting in accordance with the guidelines set forth in the proxy voting policies and procedures is in the best interests of the client or take some other appropriate action. A copy of the Advisor’s voting procedures and information about how the Advisor will vote proxies can be obtained by contacting Hung Luc, Global Chief Compliance Officer, at +44 0 20 7154 6662 or hluc@schonfeld.com.

Certain investment advisers are required in this Item 18 to provide you with certain financial information or disclosures. The Advisor has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding.