Senvest Management, LLC

Senvest is an investment adviser organized as a limited liability company under the laws of the state of Delaware. Senvest was founded on April 1, 1997. Senvest is controlled by Richard Mashaal, Chief Executive Officer (the “CEO”) and Co-Chief Investment Officer (“Co-CIO”), and Brian Gonick, Co-CIO. Mr. Mashaal controls the Adviser through his direct interest in the Adviser. Mr. Mashaal and Mr. Gonick have ultimate responsibility for Senvest’s management, operations and investment decisions. Senvest’s registration on Form ADV also covers RIMA Senvest Master Fund GP, LLC (the “Master Fund General Partner”), RIMA Senvest Cyprus GP, Ltd. (the “Cyprus General Partner”) and Senvest Technology Partners GP, LLC (the “Senvest Technology General Partner”). (Collectively, the Master Fund General Partner, the Cyprus General Partner and the Senvest Technology General Partner are referred to as the “Fund General Partners”). The Master Fund General Partner and the Senvest Technology General Partner are limited liability companies organized under the laws of the state of Delaware. The Cyprus General Partner is a Cayman Islands exempted company. The Fund General Partners are affiliates of the Adviser and serve or may serve as the general partner of Funds that are U.S. or non-U.S. partnerships. The Fund General Partners’ facilities and personnel are provided by the Adviser or Senvest Capital (as defined below). Mr. Mashaal is the majority owner of and controls the Master Fund General Partner and the Senvest Technology General Partner. Mr. Mashaal jointly owns the Cyprus General Partner with Senvest Capital and Mr. Gonick. Mr. Mashaal controls the Cyprus General Partner. Senvest is affiliated with Senvest Capital Inc. (“Senvest Capital”), a Canadian public company that trades on the Toronto Stock Exchange. Richard Mashaal serves as joint President and Chief Executive Officer of Senvest Capital, and George Malikotsis, Chief Financial Officer of the Adviser, serves as joint President and Chief Executive Officer. Both Richard Mashaal and George Malikotsis serve on the board of Senvest Capital. Senvest Capital is the largest investor in the Funds (as defined below) and acted as the seed investor for Senvest. Certain employees of Senvest Capital are supervised persons of Senvest and are compensated for such services by Senvest Capital. All Senvest Capital employees that provide services to Senvest are treated as access persons of Senvest and are subject to Senvest’s Code of Ethics. Senvest has its principal place of business in New York, with offices in California, Montana, Florida, and Québec. Senvest Capital is based in Montreal, Québec. Certain employees of Senvest Capital who are supervised persons of the Adviser are based in Montreal. Senvest Capital has no US operations. Senvest serves as the investment adviser, with discretionary trading authority, to several private pooled investment vehicles, the securities of which are offered to Investors (as defined below) on a private placement basis (each, a “Fund” or collectively the “Funds”). The Funds include:

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Senvest Partners, LP, a Delaware limited partnership;

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Senvest Partners, LTD, a Cayman Islands exempted company;

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Senvest Master Fund LP, a Cayman Islands exempted limited partnership, which serves as the master fund into which Senvest Partners, LP and Senvest Partners, LTD invest substantially all of their assets through a “master feeder” structure;

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Senvest Cyprus Recovery Investment Fund, LP, a Cayman Islands exempted limited partnership;

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Senvest Technology Partners, L.P., a Delaware limited partnership;

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Senvest Technology Partners, LTD, a Cayman Islands exempted company; and

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Senvest Technology Partners Master Fund, LP, a Cayman Islands exempted limited company, which serves as the master fund into which Senvest Technology Partners, L.P. and Senvest Technology Partners, LTD invest substantially all of their assets through a “master feeder” structure.

The Master Fund General Partner serves as the general partner to Senvest Master Fund LP and Senvest Partners, LP. The Senvest Technology General Partner serves as the general partner to Senvest Technology Partners, L.P. and Senvest Technology Partners Master Fund, LP. The Cyprus General Partner serves as the general partner to Senvest Cyprus Recovery Investment Fund, LP. In addition, the Adviser serves as an investment adviser with discretionary trading authority over, and also provides discretionary advisory services to, a separately managed account (the “Managed Account”). The Adviser reserves the right to advise additional Managed Accounts in the future. As used herein, the term “client” generally refers to each Fund and each beneficial owner of a Managed Account. Senvest formulates its investment advice for each Fund based on that Fund’s investment objectives, directs and manages each Fund’s investment portfolio on a discretionary basis in accordance with the terms of each Fund’s offering memorandum, limited partnership agreements and other governing documents applicable to each Fund (collectively, the “Governing Fund Documents”). Because it provides its advice directly to the Funds, Senvest does not tailor its advisory services individually for investors in the Funds (the “Investors”). Certain clients managed by Senvest have significant overlap in terms of investment objectives and securities holdings, but each client has differing risk tolerances and investment goals, which result in different exposures. Senvest formulates its investment advice for the Managed Account based on the investment objectives of the beneficial owner of the Managed Account. Senvest may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that it considers appropriate, subject to each client’s investment objectives and guidelines. The investment strategies Senvest pursues are speculative and entail substantial risks. Clients should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any client will be achieved.

This Brochure does not constitute an offer to sell or solicitation of an offer to buy any securities. The securities of the Funds are offered and sold on a private placement basis under exemptions promulgated under the Securities Act of 1933 (the “Securities Act”) and other applicable state, federal or non-U.S. laws. Significant suitability requirements apply to prospective investors in the Funds, including requirements that they be “accredited investors” as defined in Regulation D, “qualified purchasers” as defined in the Investment Company Act, or non-“U.S. Persons” as defined in Regulation S. Persons reviewing this Brochure should not construe this as an offer to sell or a solicitation of an offer to buy the securities of any of the Funds described herein. Any such offer or solicitation will be made only by means of a confidential private placement memorandum. The Adviser does not participate in wrap fee programs. As of December 31, 2025, Senvest had approximately $ 4,115,033,177 in regulatory assets under management, all of which are managed on a discretionary basis.

Senvest provides investment advisory services to each Fund pursuant to a separate investment management agreement (collectively, the “Agreement”). The Agreement for each Fund, along with specific Governing Fund Documents, establishes the fee structure for each Fund. Senvest typically receives fees equal to a specified percentage of each Fund’s net asset value and performance-based compensation equal to a specified percentage of the Fund’s net profits each year. Unless otherwise specifically noted, all fixed fees and incentive compensation amounts are charged solely at the relevant master fund level. Management Fee: With the exception of the Senvest Cyprus Recovery Investment Fund, LP, clients pay Senvest an annual asset-based investment management fee (the “Management Fee”) at a rate ranging from 1.5% to 4% (per annum) of the net assets of each client, the specific rate being specified in each client’s governing documents or investment management agreement, as applicable. The Funds’ Management Fee is payable monthly in arrears based upon the total market value of the assets (including net unrealized appreciation or depreciation of investments and cash, cash equivalents and accrued interest) on the last day of the month, and are deducted directly from the Fund(s)’ assets in accordance with the Governing Fund Documents pursuant to instructions provided to each Fund’s custodian, as applicable. Senvest and its affiliates reserve the right to waive or reduce Management Fees, and have waived or reduced Management Fees, for certain Investors, including current and former employees, relatives of employees, Senvest Capital, and any entities controlled by Senvest, Senvest Capital, or certain Senvest employees, as may be determined in Senvest’s sole discretion. The Management Fee for the Managed Account is calculated based on the net asset value of the Managed Account at a quarterly basis, in arrears, excluding cash and cash equivalents. Note that in the event of certain waivers of material size, as specified in the applicable Fund’s governing documents, Investors will have the ability to participate in any such waivers. Incentive Allocations: A portion of each Fund’s net investment profit, if any, generally is allocated to the capital account of its General Partner (or the General Partner’s delegate) as an “Incentive Allocation.” The manner of calculation of the Incentive Allocation is based on a percentage of capital gains on or capital appreciation of the assets. The specific percentage is disclosed in each Fund’s Governing Fund Documents, and varies by Fund. Generally, however, 15% to 20% of the investment profits of each Fund, subject to a loss carryforward provision, are allocated as an Incentive Allocation on the last business day of the Fund’s fiscal year, or at the time of withdrawal or redemption by an Investor, subject to certain conditions set forth within the Governing Fund Documents. The Incentive Allocation of one Fund is further subject to a compounded annualized 8% hurdle rate with a high watermark, and the Incentive Allocation of a sub-class of interests in another Fund is further subject to a non-compounding annualized 6% hurdle rate subject to a loss carry forward provision. As is the case with Management Fees, Senvest and its affiliates reserve the right to waive or reduce Incentive Allocations, and have waived or reduced Incentive Allocations, for certain Investors, including current and former employees, relatives of employees, Senvest Capital, and any entities

controlled by Senvest, Senvest Capital, or certain Senvest employees, as may be determined in Senvest’s sole discretion. Other Expenses Charged to the Funds: Each client bears its own expenses, including, without limitation, the Management Fee and Incentive Allocations. Clients will generally bear organizational expenses, legal, accounting, auditing, tax and other professional expenses (including expenses of consultants, investment bankers, attorneys, accountants and other experts), fees and expenses relating to software tools, programs or other technology utilized in managing the Funds (including third-party software licensing, implementation, data management and recovery services and custom development costs); administration expenses, investment expenses such as commissions, research and market data expenses (including the cost of accounting software packages, as well as, without limitation, any information technology hardware, software or other technology incorporated into the cost of obtaining such research and market data, and including fees and expenses related to obtaining, processing and analyzing research or market data that may be considered “big data” or “alternative data”, including fees and expenses related to performing due diligence on potential providers of any of such research or market data services (including, without limitation, “big data” or “alternative data” services)), interest on margin accounts and other indebtedness, borrowing charges on securities sold short, custodial fees, bank services fees, fees and expenses for third party administration (including middle and back office services provided by CSC f/k/a Intertrust Group), expenses attributable to regulatory filings which are made with respect to the Fund or the assets of the Fund (including Section 13, Section 16 and Form PF filings), costs of printing and mailing reports and notices, taxes, corporate licensing, organizational expenses, indemnification expenses, extraordinary expenses and any other reasonable expenses related to the purchase, sale, preservation or transmittal of Fund assets. Fund(s) may also invest in investment company securities (e.g., mutual funds, closed- or open-end funds and exchange traded funds), which charge expense ratios and possibly other charges and expenses. Such expenses are in addition to Management Fees and Incentive Allocations received by Senvest (or its affiliate), and Senvest and its affiliates do not receive any portion of these charges. In addition, each Fund will incur brokerage and other transaction costs. Please refer to Item 12, the Brokerage section of this Brochure for a discussion of the Adviser’s brokerage practices. In the case of Funds structured as master-feeder funds, the feeder fund Investors bear a pro rata share of the expenses associated with the related master fund. Overhead Expenses: Each Fund General Partner and the Adviser will pay all of their respective ordinary administrative and overhead expenses in managing Fund investments, including office rent, supplies, secretarial expenses, printing and stationery, charges for furniture and fixtures, employee insurance, payroll taxes, compensation of security analysts and other administrative personnel, and other reasonable overhead expenses of the Funds as determined by the General Partner in its sole discretion. Where applicable, the Fund General Partner also bears any fees payable to the Adviser. Common expenses frequently will be incurred on behalf of the multiple client accounts. Senvest seeks to allocate those common expenses among its clients in a manner that is fair and equitable. However, expense allocation decisions involve potential conflicts of interest (e.g., an incentive to favor accounts that pay higher incentive compensation, or conflicts relating to different expense

arrangements with certain clients). Under its current expense allocation practices, Senvest generally expects to allocate common expenses among the client accounts pro rata based on assets under management or in some other manner which Senvest determines is fair and equitable given the nature of the expenses and other relevant factors. Senvest may, however, use other methods to allocate expenses among its clients in certain circumstances when it deems another method more appropriate based on certain criteria, including but not limited to, the relative use of the product or service, the nature or source of the product or service or the relative benefits derived by each client from the product or service. Nonetheless, Investors should note that the portion of a common expense that Senvest allocates to each client for a particular product or service may not reflect the relative benefit derived by the client from that product or service in any particular instance. Certain of Senvest’s determinations with respect to whether specific expenses should be borne by Senvest or by clients require subjective judgments. Senvest has a conflict of interest when making such judgments because Senvest will generally bear the costs of any expenses not allocated to a client. Senvest seeks to allocate expenses in a manner that it deems to be fair and equitable. Senvest and its supervised persons do not accept compensation or commissions for the sale of securities or other investment products. Each client’s governing documents provide comprehensive details about the expenses for which that particular client is responsible. Please refer to such governing documents prior to making any investment decision.

Methods of Analysis and Investment Strategies The Adviser utilizes a variety of methods and strategies to make investment decisions and recommendations. The methods of analysis include fundamental research, charting analysis, cyclical analysis as well as use of quantitative tools and investment approaches, or technical analytical tools and approaches. The Adviser may also use margin to implement its trading strategies. Due to the size and investments held by certain clients, the ability to utilize margin in certain cases may be affected by the actions taken by a related party. Clients (and Investors in the case of the Funds) should review the governing documents and investment management agreements for their respective investment vehicles for more information regarding the methods of investment analysis used by Senvest in regard to each client. The descriptions set forth in this Brochure of specific advisory services that the Adviser offers to clients, and investment strategies pursued and investments made by the Adviser on behalf of its clients, should not be understood to limit in any way our investment activities. The Adviser may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that the Adviser considers appropriate, subject to each client’s investment objectives and guidelines. The investment strategies the Adviser pursues are speculative and entail substantial risks. Clients should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any client will be achieved. The following risk factors do not purport to be a complete list or explanation of the risks involved in an investment in the clients advised by the Adviser. These risk factors include only those risks the Adviser believes to be material, significant or unusual and relate to particular significant investment strategies or methods of analysis employed by us. Market Risks. The profitability of a significant portion of a client’s investment program depends to a great extent upon the Adviser’s ability to correctly assess the future course of the price movements of securities and other investments. There can be no assurance that the Adviser will be able to accurately predict these price movements. Clients and Fund Investors should understand that all investments involve risk and a limited partner may lose some or all of its investment. There also can be no assurance that a client’s investment objective will be achieved. The value of a client’s portfolio may decrease as well as increase, due to a variety of factors, including general economic conditions, market factors and currency exchange rates. Additionally, investment decisions made by the Adviser may not always be profitable or prove to have been correct. Investment strategies, at any given time, may incur significant losses. Losses can occur for a number of reasons, including but not limited to an overall decline in the underlying market, a lack of liquidity in the underlying markets, excessive volatility in a particular market, government intervention or monetary and/or fiscal policies of a specific region or country. The Adviser’s investment strategy is speculative and involves substantial risk to clients due to, among other factors, the nature of a client’s investment strategy and the ongoing market environment. Clients must be fully able to bear the financial risks of such investment and be fully

able to sustain the possible loss of their entire investment. Investors in the Funds should consider an investment in a Fund as a long-term investment that is appropriate only for a limited portion of a limited partner’s overall portfolio. Options. Trading options is highly speculative and may entail risks that are greater than investing in other financial instruments. Prices of options are generally more volatile than prices of other financial instruments. In trading options, the Adviser speculates on market fluctuations of the underlying financial instrument (e.g., a security, an index, a commodity, exchange rate or other instrument), while only investing a small percentage of value relative to its client’s potential exposure. The price of any option is a function of direction (e.g., whether the option is a “put”—the right to sell—or a “call”—the right to buy), the time to expiry and the implied volatility of the underlying instrument. The Adviser may cause its clients to “sell” an option, which means such client receives a small payment, or premium, relative to a notional amount, or the Adviser may cause a client to “buy” an option, which means the client pays a premium to receive exposure to a larger notional amount. A “seller” of options is generally exposed to the entire notional amount of the option contract, and can be exposed to even more risk, it is selling a call option. A “buyer” of options risks losing all of its investment if the option expires “out of the money” (i.e., the trade goes against that option buyer). Purchasing put and call options, as well as writing such options, are highly specialized activities and entail greater than ordinary investment risks. Because option premiums paid or received by an investor will be small in relation to the market value of the investments underlying the options, buying and selling put and call options can result in large amounts of leverage. As a result, the leverage offered by trading in options could cause an investor’s asset value to be subject to more frequent and wider fluctuations than would be the case if the investor did not invest in options. Non-Diversification; Concentration; Volatility. Client portfolios may not be diversified among a wide range of issuers or industries. In addition, the Adviser may cause clients to take concentrated positions (e.g., 10% of the portfolio or more) in its high conviction ideas. However, the Adviser will not cause its clients to have exposure exceeding 10% of the client’s net assets in private investments (with new private investments valued at cost when acquired for the purposes of measuring this threshold). Accordingly, clients’ investment portfolios may be subject to more rapid change in value than would be the case if the Adviser were required to maintain a wide diversification in those portfolios among industries, areas, types of securities and issuers. Short Sales. Short selling, or the sale of securities not owned by clients, necessarily involves certain additional risks. Such transactions expose clients to the risk of loss in an amount greater than the initial investment, and such losses can increase rapidly and without effective limit. There is the risk that the securities borrowed by clients in connection with a short sale would need to be returned to the securities lender on short notice. If such request for return of securities occurs at a time when other short sellers of the subject security are receiving similar requests, a “short squeeze” can occur, wherein the Adviser might be compelled, at the most disadvantageous time, to replace a client’s borrowed securities previously sold short with purchases on the open market, possibly at prices significantly in excess of the proceeds received earlier. In addition to entering into short sales for speculative purposes, as the Adviser may cause its clients to do from time to time, and depending

on market conditions, the Adviser may cause clients to engage in short selling in an effort to hedge its portfolio positions. Hedging activities may involve taking short positions related to particular portfolio positions as well as short positions intended to hedge a client’s broader exposures or particular identified risks at an overall portfolio level. Short Selling Legal Restrictions and Reporting-Related Risk. Certain jurisdictions have enacted restrictions on short selling (including wholesale bans, at times) as well as public disclosure requirements. If additional short selling restrictions and disclosure requirements are enacted, the prices of the instruments in which the clients invest may be materially affected and the ability of the Adviser to take advantage of opportunities for short selling may be significantly reduced. Leverage. While the use of margin and borrowed funds can substantially improve the return on invested capital, such use may also increase the adverse impact to which a client’s investment portfolio may be subject. Borrowings will usually be from securities brokers and dealers and will typically be secured by a client’s securities and other assets. Under certain circumstances, such a broker-dealer may demand an increase in the collateral that secures a client’s obligations and if the Adviser is unable to provide additional collateral for that client, the broker-dealer could liquidate assets held in the account to satisfy the client’s obligations to the broker-dealer. Liquidation in that manner could have extremely adverse consequences. In addition, the amount of the client’s borrowings and the interest rates on those borrowings, which will fluctuate, will have a significant effect on the profitability of the client’s portfolios. Depending on the conditions in the credit markets at any given time, the Adviser may find it difficult or impossible to obtain leverage for its clients on acceptable terms or at all. Since leveraging its assets is a part of certain clients’ investment strategies, in such event the Adviser could find it difficult to fully implement a client’s strategy. In addition, any leverage obtained, if terminated on short notice by the lender, could result in the Adviser being forced to unwind a client’s positions quickly and at prices below what the Adviser deems to be fair value for the positions. Small and Mid-Cap Stocks. At any given time, clients may have significant investments in smallerto-medium sized companies with market capitalizations of less than $2 billion. While smaller companies may have potential for rapid growth, they often involve higher risks because they lack the management experience, financial resources, product diversification, and competitive strengths of larger corporations. These factors make smaller companies far more likely than their larger counterparts to experience significant operating and financial setbacks that threaten their short-term and long-term viability. In addition, in many instances, the frequency and volume of their trading is substantially less than is typical of larger companies. As a result, the securities of smaller companies may be subject to wider price fluctuations, and exiting investments in such securities at appropriate prices may be difficult, subject to substantial delay or impossible. When making large sales, clients may have to sell portfolio holdings at discounts from quoted prices or may have to make a series of small sales over an extended period of time due to the trading volume of smaller company securities. Non-U.S. Securities. Investing in securities of non-U.S. governments and companies domiciled or operating outside of the United States involves certain considerations comprising both risks and opportunities not typically associated with investing in securities of the United States Government or United States companies. These considerations include changes in exchange rates and exchange control regulations, political and social instability, expropriation, imposition of foreign taxes, less

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Senvest provides discretionary management and advisory services to its clients, which currently consist of Funds and a Managed Account. Senvest may in the future advise additional Managed Accounts. Senvest’s investment activities are subject to each client’s governing documents, the applicable investment management agreement, and any offering materials (in the case of Funds) applicable to the relevant client. Senvest does not advise Investors with respect to any investments such Investors have made into any Fund. Certain Managed Account clients are currently Investors in Funds advised by Senvest or its affiliates. Senvest has not but may in the future enter into separate agreements, commonly referred to as “side letters”, or other similar agreements with a particular Investor in connection with such Investor’s admission to a Fund that have the effect of establishing rights under or supplementing the terms of the applicable Fund’s Partnership Agreement with respect to such Investor in a manner more favorable to such Investor than those applicable to other Investors. Other Investors are not parties to such side letters. The rights or terms contained in any such side letter or other similar agreement may include, without limitation: (i) excuse rights applicable to particular investments (which may increase the percentage interest of other Investors in, and contribution obligations of other Investors with respect to, such investments), (ii) reporting obligations, (iii) waiver of certain confidentiality obligations, (iv) consent to certain transfers by such Investor or (v) rights or terms requested or necessary in light of particular investment, legal, regulatory or public policy characteristics of an Investor.

As described above, Senvest (or its affiliates) receives performance-based compensation in the form of Incentive Allocations from the Funds. The fact that the Adviser receives performance-based compensation creates an incentive for it to make investments for the Funds that are riskier or more speculative than would be the case in the absence of that compensation. However, the performance-based compensation payable to the Adviser by certain Funds differs in terms of the rates and method of calculation from the amounts charged to other Funds, which gives the Adviser an incentive to favor some Funds over others. Senvest has a fiduciary duty to allocate investment opportunities in a fair and equitable manner and has implemented policies and procedures designed to identify and mitigate conflicts of interest that arise in the investment allocation process. Senvest regularly reviews investment decisions and analyzes comparable client performance in order to monitor compliance with its investment allocation policies and procedures.

The Adviser is not registered as a broker-dealer or a registered representative of a broker-dealer. The Adviser and its management persons are not registered as, and do not have any application to register as, futures commission merchants, commodity pool operators, commodity trading advisors or associated persons of the foregoing entities. As noted above in Item 4, the Adviser is affiliated with Senvest Capital. Senvest Capital has an ownership interest in the Cyprus General Partner. Certain employees of Senvest Capital are supervised persons of the Adviser and are compensated for such services by Senvest Capital. In particular, Richard Mashaal, Chief Executive Officer of the Adviser, serves as joint President and Chief Executive Officer of Senvest Capital, and George Malikotsis, Chief Financial Officer of the Adviser, serves as joint President and Chief Executive Officer. Both Richard Mashaal and George Malikotsis serve on the board of Senvest Capital. Richard Mashaal and George Malikotsis also serves roles with respect to various investments and entities controlled by Senvest Capital. All Senvest Capital employees who provide services to the Adviser are treated as access persons of the Adviser and are subject to the Adviser’s Code of Ethics. Certain employees of the Adviser, including Richard Mashaal, own shares of Senvest Capital. Adviser employees are permitted, subject to certain blackout periods and applicable policies, to purchase additional shares of Senvest Capital. Senvest Capital is the largest Investor in the Funds and acted as the seed investor for Senvest, although Senvest Capital does not have any ownership interest in the Adviser. Certain employees of Senvest Capital are supervised persons of Senvest and are compensated for such services by Senvest Capital. All Senvest Capital employees that provide services to Senvest are treated as access persons of Senvest and are subject to Senvest’s Code of Ethics. The Adviser does not recommend or select other investment advisers for its clients.

Transactions and Personal Trading Code of Ethics and Personal Trading Pursuant to Rule 204A-1 of the Advisers Act, Senvest has adopted a written Code of Ethics (the “Code”) predicated on the principle that the Adviser owes a fiduciary duty to its clients. The Code is designed to identify and mitigate conflicts of interest between the Adviser and its clients. All of the Adviser’s officers, directors, members, partners or supervised persons (the “Supervised Persons”) are subject to the Code, as well as each Supervised Person’s spouse, minor children and other family members living in his or her household (the “Related Persons”). Individuals and entities designated in writing by the Chief Compliance Officer as being subject to all or a portion of the compliance procedures or policies adopted by the Adviser (collectively, the “Covered Persons”) are subject to the Code. The Adviser requires its Supervised Persons to act in accordance with Senvest’s fiduciary duties to its clients and abide by all applicable laws and regulations. The Code also sets forth procedures and controls to prevent the misuse of material nonpublic information, and requires prompt internal reporting of Code violations; the pre-clearance of all transactions in equities, initial public offerings, and limited offerings; and periodic reporting of Covered Persons’ personal securities transactions and all holdings. The Chief Compliance Officer has responsibility for the day-to-day administration of the Code and is responsible for reviewing the reports provided by Covered Persons under the Code. Supervised Persons are required to immediately report any violation of the Code, as well as any Federal securities laws, to the Chief Compliance Officer. The restrictions of the Code do not preclude purchases of interests in the Funds. Certain Covered Persons are Investors in the Funds, and some or all of the key personnel of the Adviser and its affiliates have significant interests in one or more of the Funds as Investors. Clients may request to review the Code by contacting Senvest at the address or telephone number listed on the first page of this document. Cross Transactions Senvest may effect cross transactions between its clients, except as otherwise noted below. Cross transactions enable the Adviser to affect a trade between two clients for the same security at a set price. The Adviser may determine that it would be in the best interests to cause certain clients to engage in a cross transaction for a variety of reasons, including, without limitation, tax purposes, liquidity purposes, to rebalance the portfolios of the clients, or to reduce transaction costs that may arise in an open market transaction. If the Adviser decides to engage in a cross transaction, the Adviser will determine that the trade is in the best interests of each client involved in it and take steps to ensure that the transaction is consistent with the duty to obtain best execution for each of those clients. The Adviser will generally execute cross transactions with the assistance of a broker-dealer who executes and books the transaction at the close of the market on the day of the transaction.

Alternatively, a cross transaction between two clients may occur as an “internal cross”, where the Adviser instructs the custodian for the clients to book the transaction at the price determined in accordance with the Adviser’s valuation policy. If the Adviser effects an internal cross, the Adviser will not receive any fee in connection with the completion of the transaction. To the extent that cross transactions are viewed as principal transactions due to the ownership interest in a client by the Adviser or its personnel, the Adviser will comply with the requirements of Section 206(3) of the Advisers Act, including that any such transactions will be considered on behalf of Investors in such a client and approved or disapproved by (i) an advisory board comprised of representatives of such Investors or (ii) a committee consisting of one or more persons selected by the Adviser (or its affiliate), and any valuation approved by such a committee will be determined by an independent third party that has appropriate experience in providing such valuations. In addition, cross transactions are not permitted for benefit plan or other similar accounts that are subject to ERISA, unless they have over $100 million in assets. Trade Errors If it appears that a trade error has occurred, Senvest will review the relevant facts and circumstances to determine an appropriate course of action. To the extent that trade errors and breaches of investment guidelines and restrictions occur, the Adviser’s error correction procedure is designed to identify and mitigate any problems that occur. The Adviser has discretion to resolve a particular error in any appropriate manner that is consistent with the above stated policy. In the event that a client account incurs a trade error as a result of actions that breach the applicable client’s standard of care (as specified in the applicable client’s governing documents), trade errors will be corrected by the Adviser as soon as practicable, in a manner such that the client incurs no loss. Trade errors that result other than by breach of the standard of care above are generally borne by the applicable client. Senvest has a conflict of interest when determining whether losses resulting from a trading error will be borne by a client because otherwise Senvest would generally be required to reimburse such losses. From time to time, the Adviser or its affiliates may elect to voluntarily reimburse clients for losses suffered as a result of certain trade errors identified by the Adviser or its affiliates or otherwise. However, notwithstanding the previous sentence, clients and Investors should not carry the expectation that a reimbursement will ever take place, and, in evaluating Senvest, no decisions should be made in reliance on it making any reimbursements to a client for losses suffered as a result of such trade errors. Any decision to reimburse is not precedential and should not create the expectation of any reimbursement in the future. Investing in Securities that the Adviser or a Related Person Recommends to Clients The Code places restrictions on personal trades by employees, including that they disclose their personal securities holdings and transactions to the Adviser on a periodic basis, and requires that employees pre-clear certain types of personal securities transactions. Generally, and subject to certain exceptions, employees are restricted from trading options or short selling in their personal accounts. The Adviser, its affiliates and its employees at times invest on behalf of themselves in

securities and other instruments that would be appropriate for, are held by, or fall within the investment guidelines of clients, at the time of such employees’ personal investments. However, all equity transactions are subject to mandatory pre-clearance. Further, employees are generally restricted from personal trading in client-held securities, excluding securities above a certain market capitalization threshold when a client is not trading in such securities on the same day. The Adviser may deny permission to engage in any equity transactions for any reason or no reason. The Adviser, its affiliates and its employees may give advice or take action for their own accounts that may differ from, conflict with or be adverse to advice given or action taken for clients. These activities may adversely affect the prices and availability of other securities or instruments held by or potentially considered for one or more clients. Potential conflicts also may arise due to the fact that the Adviser and its personnel have investments in some Funds but not in others or have different levels of investments in the various Funds. The Adviser has established policies and procedures to monitor and resolve conflicts with respect to investment opportunities in a fair and equitable manner, as determined in the Adviser’s sole discretion, including the restrictions placed on personal trading in the Code, as described above, and regular monitoring of employee transactions and trading patterns for conflicts of interest, including those conflicts that may arise as a result of personal trades in the same or similar securities made at or about the same time as client trades. Conflicts of Interest Created by Contemporaneous Trading The Adviser manages investments on behalf of a number of clients. Certain clients have investment programs that are similar to or overlap and, therefore, participate with each other in certain investments from time to time. It is the policy of the Adviser to allocate investment opportunities among all clients fairly, to the extent practical and in accordance with each client’s applicable investment strategies, over a period of time. The Adviser will have no obligation to purchase or sell a security for, enter into a transaction on behalf of, or provide an investment opportunity to any client solely because the Adviser purchases or sells the same security for, enters into a transaction on behalf of, or provides an opportunity to any client if, in its reasonable opinion, such security, transaction or investment opportunity does not appear to be suitable, practical or desirable for the client. The Adviser generally allocates investments on a pro rata basis for clients with similar investment strategies. Senvest has allocated investments on a non-pro rata basis in certain circumstances for various reasons, including but not limited to: varying investment strategies and restrictions between different clients, regulatory restrictions, differing risk management strategies among clients, hedging preferences specific to certain clients, position size, asset levels, cash flow considerations, portfolio liquidity and concentration, timing and size of capital contributions and redemptions, market conditions, whether certain clients would receive nominal or de minimis allocation amounts, and participation in prior investments in the same issuer. Even client accounts that are typically managed on a pari passu basis may from time to time receive differing allocations under certain circumstances, such as (but not limited to) variances in the total assets of each account eligible to invest in the applicable investment type.

The Adviser at times causes clients to acquire a substantial position in the securities of a company, and secures the appointment of persons selected or recommended by the Adviser to the company’s management team or board of directors. In so doing, the Adviser may acquire fiduciary duties to the company and to its other shareholders. These fiduciary duties may compel the Adviser to take actions that, while in the best interest of the company and/or its shareholders, may not be in the best interests of clients. Accordingly, the Adviser may have a conflict of interest between the fiduciary duties (if any) that it or its personnel owe to such companies and their shareholders, on the one hand, and those that it owes to its clients, on the other. Service on boards of directors can increase the likelihood that the Adviser will receive material, nonpublic information with respect to the company itself or other companies that are affiliated with such company, or that directly compete with or are in the same sector as such company. In such situations, the Adviser could potentially face restrictions on its ability to make certain investments on behalf of clients. This can include situations where the Adviser has selected or recommended board members for a company in which one client has invested, but where such board membership results in investment restrictions for clients that have not invested in the applicable company. Information received in connection with service on a company’s board of directors may, at times, constitute material nonpublic information with respect to securities issued by another company (e.g., market participant, key supplier, material competitor). Receipt of such information in connection with board memberships could result in investment restrictions for clients.

Senvest seeks to fulfill its fiduciary duties to its clients by selecting broker-dealers based upon their ability to provide best execution for the Funds. The Adviser considers a number of factors in selecting a broker-dealer to execute transactions (or series of transactions) and determining the reasonableness of the broker-dealer’s compensation. Such factors include, but are not limited to, net price, reputation, financial strength and stability, efficiency of execution and error resolution. In selecting a broker-dealer to execute transactions (or series of transactions) and determining the reasonableness of the broker-dealer’s compensation, the Adviser need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost. While the Adviser engages in transactions with certain broker-dealers on an “execution only” basis, the Funds will generally be paying for research, brokerage or other services provided by a broker-dealer, which are included in the commission rate. The Adviser has adopted policies and procedures intended to seek best execution on an ongoing basis for securities transactions, based upon the aforementioned factors. Senvest has discretionary investment authority pursuant to the investment management agreements or other governing documents applicable to each client. The Adviser has discretion to select the executing broker or dealer for any single transaction and the commission rates and commission equivalents charged for the transactions. Soft Dollar Benefits Senvest receives research or other products or services other than execution from a broker-dealer and/or a third party in connection with client securities transactions. This is known as a “soft dollar” relationship. From time to time, the Adviser causes its clients to pay broker-dealer commissions (or markups or markdowns with respect to certain types of riskless principal transaction) for effecting Fund and/or Managed Account transactions in excess of that which another broker-dealer might have charged for effecting the transaction in recognition of the value of the brokerage and research services provided by the broker-dealer. The Adviser will effect such transactions, and receive such brokerage and research services, only to the extent that they fall within the safe harbor provided by Section 28(e) of the Securities Exchange Act of 1934 (“Section 28(e)”), as amended, and subject to prevailing guidance provided by the SEC regarding Section 28(e). When the Adviser uses client brokerage commissions (or markups or markdowns) to obtain research or other products or services, the Adviser receives a benefit because it does not have to produce or pay for such products or services. The Adviser has an incentive to select or recommend a brokerdealer based on the Adviser’s interest in receiving research or other products or services, rather than on its clients’ interest in receiving most favorable execution. Also, consistent with Section 28(e), research products or services obtained with “soft dollars” generated by one or more Funds or Managed Accounts are used by the Adviser to service one or more other clients, including clients that may not have paid for the soft dollar benefits. The Adviser does not seek to allocate soft dollar benefits to client accounts in proportion to the soft dollar credits the client accounts generate. Where a product or service obtained with soft dollars provides both research and non-research assistance to the Adviser (i.e., a “mixed use” item), the Adviser will make

a good faith allocation of the cost which may be paid for with soft dollars. In making good faith allocations of costs between administrative benefits and research and brokerage services, a conflict of interest exists by reason of the Adviser’s allocation of the costs of such benefits and services between those that primarily benefit the Adviser and those that primarily benefit the Funds and/or Managed Accounts. During the Adviser’s last fiscal year, as a result of client brokerage commissions, Senvest and/or its affiliates acquired research and brokerage services, including: • Market data services, including real-time exchange data, company financials, and economic reports • Third-party investment research, including sector and industry analysis • Trading and execution services • Quantitative and technical research tools • Expert network services providing industry and sector-specific insights • Share recall services related to securities lending and borrowing activities • Alternative data services, including the acquisition and analysis of non-traditional datasets to support investment decision-making The Adviser participates in “client commission arrangements” pursuant to which Senvest would execute transactions through a broker-dealer and request that the broker-dealer allocate a portion of the commissions or commission credits to another firm that provides research and other products to the Adviser. The Adviser only receives products or research under these arrangements to the extent that such research or products are eligible under Section 28(e) and applicable regulatory interpretations. The proportion of the product or service attributable to assisting the Adviser in carrying out its investment decision-making responsibilities will be paid through brokerage commissions generated by client transactions and the proportion attributable to administrative or other purposes outside Section 28(e) will be paid for by the Adviser from its own resources. Investment transactions for clients and the use of such commissions by the Adviser may be outside the safe harbor provided by Section 28(e) and applicable regulatory interpretations for one or more of the following reasons: the type of investment, the market mechanism or the market intermediary compensation involved in the transaction or the types of services obtained with the commissions paid for the transaction. Even when investment transactions for clients are outside the Section 28(e) safe harbor, the commissions paid will be used for the acquisition of research and brokerage services that fall within the guidance regarding Section 28(e). At least annually, the Adviser considers the amount and nature of research and research services provided by broker-dealers, as well as the extent to which such services are relied upon, and attempts to allocate a portion of the brokerage business of its Funds and Managed Accounts on the basis of that consideration. Broker-dealers sometimes suggest a level of business they would like to receive in return for the various products and services they provide. Actual brokerage business received by any broker-dealer may be less than the suggested allocation, but can (and often does) exceed the suggested level, because total brokerage is allocated on the basis of all of the considerations described above. In no case will the Adviser make binding commitments as to the level of brokerage commissions it will allocate to a broker-dealer, nor will it commit to pay cash if

any informal targets are not met. A broker-dealer is not excluded from receiving business because it has not been identified as providing research products or services. Brokerage for Client Referrals Neither the Adviser nor any related person receives client referrals from any broker-dealer or third party. However, as discussed above, subject to best execution, the Adviser utilizes, among other things, capital introduction and marketing assistance with respect to Investors in the Funds from broker-dealers. In no event will Senvest select a broker-dealer as a means of remuneration for recommending the Adviser or any Fund or other product managed by the Adviser (or an affiliate) or affording the Adviser with the opportunity to participate in capital introduction programs. As such, client referrals are not considered when making brokerage decisions. The Adviser does not recommend, request or require that a client direct the Adviser to execute transactions through a specified broker-dealer. Order Aggregation The Adviser often purchases or sells the same security for clients, including accounts for affiliates managed by Senvest, contemporaneously and at or near the same time and using the same executing broker. It is the Adviser’s practice, where possible, to aggregate orders for the purchase or sale of the same security submitted at or near the same time for execution using the same executing broker. Such aggregation is intended to enable the Adviser to obtain for clients a more favorable price or a better commission rate based upon the volume of a particular transaction. In cases where trading or investment restrictions are placed on a Fund’s account, the Adviser may be precluded from aggregating that Fund’s transaction with others. In such a case, the Fund may pay a higher commission rate and/or receive less favorable prices than Funds who are able to participate in an aggregated order. When an aggregated order is completely filled, the Adviser generally allocates the securities purchased or proceeds of sale pro rata among the participating accounts, based on the purchase or sale order. The pro rata calculation will be affected by the relative size of the accounts. Adjustments or changes may be made under certain circumstances, including but not limited to efforts to avoid odd lots or excessively small allocations. If the order at a particular broker is filled at several different prices, through multiple trades, generally all such participating accounts will receive the average price and pay the average commission, subject to odd lots, rounding, and market practice. If an aggregated order is only partially filled, the Adviser’s procedures provide that the securities or proceeds are to be allocated in a manner deemed fair and equitable to each client participating in the transaction. Depending on the investment strategy pursued and the type of security, this may result in a non-pro rata allocation to all participating clients. The Adviser or its Covered Persons may also participate in an aggregated order. Sometimes the Adviser places trades on an individual basis and does not attempt to group orders for multiple Funds

for the same security and type of trade in a single, combined order. Because in these situations the Adviser does not engage in the practice of aggregating orders, its clients generally would not receive the potential benefits of aggregation, such as lower commission rates and uniform pricing. As a result, some opportunities for reduced transaction costs and economies of scale generally would not be achieved.

We do not receive economic benefits from non-clients for providing investment advice and other advisory services. The Adviser receives certain research or other products or services from brokerdealers through “soft dollar” arrangements. These “soft dollar” arrangements create an incentive for the Adviser to select or recommend broker-dealers based on the Adviser’s interest in receiving the research or other products or services and may result in the selection of a broker-dealer on the basis of considerations that are not limited to the lowest commission rates and may result in higher transaction costs than would otherwise be obtainable by the Adviser on behalf of its clients. Please see Item 12 for further information on the Adviser’s “soft dollar” practices, including the Adviser’s procedures for addressing conflicts of interest that arise from such practices. Senvest has not engaged any third party placement agents (i.e., solicitors) to introduce prospective Investors to the Funds, but it may in the future. The fees and expenses of any third-party placement agents will be paid by the Funds, but will be reimbursed by Senvest by offsetting its Management Fees. At the present time, Senvest has not engaged any third party placement agents.

On April 3,2024, the SEC issued a settled administrative order (the “Order”) finding that the Adviser violated (1) Section 204 of the Advisers Act and Rule 204-2(a)(7) by failing to adequately preserve certain off-channel communications related to its business, (2) Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder by failing to adopt and implement written policies and procedures reasonably designed to prevent violation of the Advisers Act and rules thereunder; (3) Section 204A of the advisers act and Rule 204A-1 by failing to establish, maintain, and enforce a written code of ethics that meets the minimum standards set forth in rule 204A-1; and (4) Section 203(e)(6) of the Advisers Act by failing to reasonably supervise certain employees. The Adviser paid a civil money penalty of $6,500,000 in connection with the Order. As part of the settlement, the Adviser agreed to retain a compliance consultant to review certain aspects of its compliance program related to the use of unauthorized communication methods for business communications, including related policies, procedures, trainings, surveillance program, technological solutions, and other preventative measures. The Adviser was censured and ordered to cease-and-desist from committing or causing any violations and any future violations of Sections 204, 204A, and 206(4) of the Advisers Act and Rules 204-2, 204A-1, and 206(4)-7.

The Fund’s portfolios and accounts will be regularly reviewed by the Adviser’s portfolio managers to ensure overall compliance with stated investment guidelines and restrictions, as set forth within the governing documents or other client-related documents. While the Funds will comply with all stated investment guidelines and restrictions, Senvest generally has broad investment authority with respect to the Funds under the applicable governing documents. The CEO has ultimate responsibility for all investment decisions. Senvest provides each Investor with the following reports in accordance with the terms of the applicable governing documents: audited annual financial statements and annual tax information necessary to complete any applicable tax returns. In addition, Senvest provides periodic information updates to Investors regarding fund performance and significant investments from time to time. Investors may also reach out to Senvest with any questions on their account.

Senvest is deemed to have custody of client funds and securities because it has the authority to obtain client funds or securities, for example, since it or an affiliate serves as the General Partner to the Funds structured as limited partnerships. As permitted under the Custody Rule, the Funds are subject to an annual audit by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, and the audited financial statements are distributed to each Investor. The audited financial statements will be prepared in accordance with generally accepted accounting principles and distributed within 120 days of each Fund’s fiscal year end. The Adviser complies with the Custody Rule with respect to the Managed Account by arranging for a surprise audit of the Managed Account’s financial statements.

In accordance with the terms and conditions of the Governing Fund Documents, the Adviser generally has discretionary authority to determine, without obtaining specific consent from the Funds or its Investors, the securities and the amounts to be bought or sold on behalf of the Funds, and to perform the day-to-day investment operations of the Funds. The Adviser has the discretion to invest, on behalf of its clients, in certain vehicles controlled by Senvest, structured to gain exposure to specific investments, but in such instances clients do not pay duplicate fees or operating expenses of such vehicles (though would be subject to a pro-rata share of portfolio expenses), and do not otherwise transact with such vehicles. Specifically, several clients have invested in Senvest Cyprus Recovery Investment Fund. Prior to assuming discretion in managing a prospective client’s assets, Senvest enters into an Agreement that sets forth the scope of its discretion. Senvest adheres to all such requirements and has established policies and procedures designed to ensure that Senvest’s investments are in line with the scope of Senvest’s discretion and the investment mandate of each client. As noted in Item 12 above, Senvest has the ability to effect cross transactions between different client accounts, except where prohibited by an agreement or applicable law.

In accordance with its fiduciary duty to clients and Rule 206(4)-6 of the Advisers Act, Senvest has adopted and implemented written policies and procedures governing the voting of client securities. To the extent the Adviser has been delegated proxy voting authority on behalf of the Fund, Senvest complies with its proxy voting policies and procedures that are designed to ensure that in cases where the Adviser votes proxies with respect to securities, such proxies are voted in the best interests of the Funds. Generally the Funds are not permitted to direct proxy votes in a particular solicitation. The Adviser has retained a third-party proxy voting service to assist in the proxy voting process. Both Senvest’s analysts and trader will be provided with voting service’s recommendation for each proxy vote. Unless a determination is made to vote against the recommendation, the securities will be voted in accordance with the proxy service’s recommendation. The CEO and/or a portfolio manager will have final approval of any instances when the Adviser determines that it will vote against the recommendations of the proxy voting service. The Adviser conducts due diligence on an annual basis to confirm that the proxy voting service is performing its work in a manner consistent with the Adviser’s policies and procedures. If Senvest detects a material conflict of interest in connection with a proxy solicitation, the Adviser will abide by the recommendation of the proxy voting service. Senvest conducts appropriate due diligence on the third-party proxy voting service on a periodic basis. In certain instances, Senvest has pledged to restrict its voting rights or otherwise forfeited its right to vote certain securities in order to avoid triggering certain regulatory thresholds or limit its ability to trade securities. In addition, Senvest may not vote proxies or may delegate proxy voting authority to an independent third party where the cost of doing so would exceed the expected benefits to the clients. All proxies that Senvest receives will be treated in accordance with these policies and procedures. A copy of Senvest’s written proxy voting policies and procedures, as well as a record of how Senvest has voted in the past, will be maintained and available for review upon request.

The Adviser is not required to include a balance sheet for its most recent fiscal year, is not aware of any financial condition reasonably likely to impair its ability to meet contractual commitments to clients, and has not been the subject of a bankruptcy petition at any time during the past ten years.