Seven Fleet Capital Management LP

Seven Fleet Capital Management LP (“Seven Fleet”) is a Delaware limited partnership that was formed in February 2025 with a principal place of business in Mountain View, California. The controlling principal of Seven Fleet and the General Partner (defined below) is Brian Liu (the “Principal”). However, Rod Lim has substantial economics in Seven Fleet and the General Partner, has certain limited management approval rights and investment decisions will generally be made jointly by the Principal and Rod Lim. Seven Fleet currently provides investment advisory services to the following private investment funds: (a) Seven Fleet Partners LP (the “Domestic Fund”); (b) Seven Fleet Offshore Fund Ltd., (the “Offshore Fund” and, together with the Domestic Fund, the “Feeder Funds”); and (c) Seven Fleet Master Fund LP (the “Master Fund” and, together with the Feeder Funds, the “Funds” and each a “Fund”). Notwithstanding the foregoing, Seven Fleet is required to invest all of the capital of the Feeder Funds in limited partnership interests of the Master Fund, other than cash and cash equivalents held for investment into the Master Fund, distributions to investors and/or payment of operating expenses. Seven Fleet Advisors LLC (the “General Partner”), an affiliate of Seven Fleet, is the general partner of the Domestic Fund and the Master Fund. The General Partner is a “relying adviser” that is also controlled and principally owned by the Principal. The General Partner has ultimate responsibility for decisions relating to the management and operations made on behalf of the Domestic Fund and the Master Fund. The General Partner has delegated certain responsibilities, including investment management of the Domestic Fund and the Master Fund, to Seven Fleet. Seven Fleet currently provides discretionary investment advice to a separate fund which is managed and operated by a third party, and may in the future provide discretionary advise to other funds and accounts, pursuant to separate investment management agreements (the “Other Accounts,” and together with the Funds, the “Client Accounts”). Additional detailed information about Seven Fleet is provided below, including information about Seven Fleet’s advisory services, investment approach, personnel, affiliations, and brokerage practices. Seven Fleet provides discretionary investment management services to the Funds pursuant to investment guidelines set forth in the relevant governing and offering documents of the Funds, including any limited partnership agreement, investment management agreement, private placement memorandum and/or subscription agreement, as the case may be (each an “Offering Document,” and collectively, the “Offering Documents”). Seven Fleet does not tailor its advisory services to the individual investors of a Fund (each an "Investor" and collectively the “Investors”), or provide Investors with the right to specify, or restrict the Funds’ investment objectives or any investment or trading decisions. With respect to any Other Accounts, Seven Fleet may contract with such Other Account to adhere to limited risk and/or operating guidelines imposed by such Other Account. Seven Fleet negotiates such arrangements on a case-by-case basis. Each Investor/Client Account is strongly encouraged to undertake appropriate due diligence, including but not limited to a review of relevant governing documents and the additional details about Seven Fleet’s investment strategies, methods of analysis and related risks (as discussed in Item 8 of this Brochure and each Client Account’s governing documents) in considering whether Seven Fleet’s advisory services/ an

investment in the Funds are appropriate to its own circumstances, based on all relevant factors including, but not limited to, their own investment objectives, liquidity requirements, tax situation and risk tolerance before making an investment decision. Seven Fleet’s investment objective is to generate attractive risk-adjusted returns primarily by investing in publicly traded equity securities of biotechnology companies. The investment strategy seeks to generate uncorrelated returns by trading around events such as clinical trial readouts, regulatory decisions, commercial milestones, and corporate transactions. Seven Fleet believes that these events typically exhibit lower beta characteristics, allowing the Client Accounts to invest across various market conditions. Seven Fleet does not participate in wrap fee programs. As of April 30, 2026, Seven Fleet managed $434,581,362 in regulatory assets under management, all of which are managed on a discretionary basis.

Seven Fleet’s fees and compensation are described in each Feeder Fund’s Offering Documents and/or the investment management agreements Seven Fleet enters into with the Other Accounts, as applicable. All of Seven Fleet’s current Other Accounts and the investors in the Feeder Funds are “qualified purchasers” as defined in Section 2(a)(51) of the Investment Company Act of 1940, as amended (the “1940 Act”). Management fees to Seven Fleet are generally paid quarterly in advance from the Master Fund and the management fees will be pro-rated for subscriptions to the Feeder Funds made other than the first day of a calendar quarter. Management Fees are generally non-refundable, except in the case of a mid-quarter liquidation of the Funds or compulsory redemption. The General Partner generally receives performancebased allocations from the Master Fund on an annual basis in arrears and upon redemptions and withdrawals by Investors. Management fees, performance-based compensation and/or expenses may be reduced, rebated, discounted or waived in certain circumstances, including, without limitation, with respect to investments in the Feeder Funds by Seven Fleet’s personnel and/or other related persons. The Other Accounts have management fees and performance-based compensation that differ in one or more respects from those applicable to Investors in the Funds since they are negotiated on a case-by-case basis. However, performance fees are generally paid on an annual basis and upon the withdrawal of capital. Other Fees and Expenses Subject to an expense cap, the Master Fund will bear, or reimburse Seven Fleet and/or the General Partner for advancing the expenses of the Funds, including, without limitation, the following: (i) expenses related to the research, execution and monitoring of actual and prospective investments (whether or not consummated) and the consummation of investments, including, without limitation, the following: thirdparty investment sourcing fees; consulting fees; expert fees; fees and expenses of and related to obtaining research, analytics and market data (including, without limitation, third-party data sources and any information technology hardware, software and data subscriptions (such as Bloomberg and FactSet) or other technology incorporated into the cost of obtaining such research and market data); due diligence expenses including, without limitation, consulting and appraisal fees; investment- and research-related travel expenses consistent with Seven Fleet’s travel policy; any outsourced trading provider fees; brokerage and prime brokerage fees, commissions and expenses (including the costs of negotiating, documenting and/or amending agreements with prime brokers, ISDAs and other agreements with trading and financing counterparties); expenses relating to borrowing securities to be sold short; clearing and settlement charges; custodial fees and expenses; bank service fees; interest expenses and other borrowing costs; fees and expenses of proxy research and voting services; broken deal expenses; fees and expenses

of third-party professionals, including, without limitation, consultants, investment bankers, attorneys, accountants and service providers who, in each case, provide services to the Funds or provide services to Seven Fleet, the General Partner or the Principal (on matters that would not have arisen but for their respective advisory relationships with the Funds); and expenses relating to engagement with a company irrespective of the outcome of such engagement, such as shareholder and management communication, soliciting proxies, hiring proxy advisory consultants, hosting shareholder forums, hiring public relations consultants and proposing or nominating directors or executives, including sourcing, recruiting, standby and indemnification and other expenses, regardless of whether the nomination is successful; (ii) organizational fees and expenses and fees and expenses incurred in connection with the offering and sale of interests in the Funds; (iii) operational expenses, including, without limitation, the following: fees and expenses relating to information technology hardware, software or other technology (including, without limitation, costs of software licensing, implementation, data management and recovery services and custom development) used to research investments, evaluate and manage risk, facilitate valuations, facilitate accounting functions, facilitate compliance with the rules of any self-regulatory organization or applicable law (including, without limitation, reporting obligations) in connection with the activities of the Funds, and facilitate and manage the order execution of securities or otherwise manage the Funds (such as portfolio management systems and order management systems); fees and expenses of third-party risk management products, models and services; third-party administrative fees and expenses, including fees and expenses of the administrator and any middle and/or back office service provider; fees and expenses of third-party professionals, including, without limitation, consultants, valuation service providers, attorneys, accountants and tax preparers; third-party audit and tax preparation expenses; insurance expenses, including, without limitation, premiums for cybersecurity insurance and liability insurance (including directors and officers liability insurance and errors and omission insurance) covering the Funds, the General Partner, Seven Fleet and the principals, directors, officers, employees, managers, partners, members, affiliates or agents of any of the foregoing; fees and expenses associated with director and governance committee meetings and meetings of the Investors as a whole; costs of preparing and distributing reports and notices to Investors (including the development, implementation and maintenance of an investor electronic delivery site and/or system); entity-level taxes; fees and expenses related to compliance with applicable law and regulations in connection with the activities of the Funds, including, without limitation, any governmental, regulatory, licensing, filing, reporting or registration expenses, fees or taxes (including, without limitation, fees and expenses incurred in connection with the preparation and filing of Form PF, Section 13 filings, Section 16 filings and other similar regulatory filings for the Funds or Seven Fleet, the General Partner or the Principal on matters that would not have arisen but for their respective advisory relationships with the Funds, and any filings or reporting with respect to compliance with FATCA, AEOI or similar laws enacted in other jurisdictions, as well as any foreign tax regime registrations, tax filings and associated annual fees and expenses); and any fees and expenses related to compliance with anti-money laundering laws and regulations applicable to the Funds (including AML officer fees and expenses); and (iv) extraordinary expenses, including, without limitation, the following: the costs of any litigation or investigation involving the activities of the Funds (including attorney’s fees and investigative fees and expenses); the cost of settlements and indemnification expenses (including advances thereof) (for clarity, Seven Fleet and the General Partner are authorized to commit the Funds to potential indemnity obligations toward certain counterparties entering into agreements with the Funds for the provisions of services and otherwise); fees and expenses incurred in connection with any tax audit by any U.S. federal, state or local authority, including, without limitation, any related administrative settlement and judicial review; and fees and expenses incurred in connection with the reorganization, restructuring, dissolution, winding-up or termination of any of the Funds. The expenses that are charged to the Other Accounts are determined on a case-by-case basis.

Other Fees and Expenses Seven Fleet may allocate a portion of the capital of the Client Accounts to exchange-traded funds or similar fee-bearing products that are managed by other investment managers. In that case, such Client Accounts generally would be responsible for paying any and all management fees and expenses associated with such products, which would be in addition to those discussed above. General To the extent a Client Account shares trading and other expenses with other Client Accounts managed by Seven Fleet or its affiliates, such Client Account will bear an equitable share of the associated expenses, taking into account its written agreements with such Client Accounts and applicable facts and circumstances, including the relative size of the applicable entity or account, the nature or source of the product or service and the benefits derived from and the extent of use of the product or services. Nonetheless, the portion of an expense that Seven Fleet allocates to a Client Account for a particular product or service might not reflect the relative benefit derived by such Client Account from that product or service in any particular instance. Furthermore, it is possible that under some of Seven Fleet’s advisory contracts it may not require a Client Account to incur certain expenses, despite the fact that such Client Account will receive a benefit in connection with Seven Fleet’s incurrence of such expenses (and in such Seven Fleet will bear the pro rata share of such expense that would otherwise be allocated to such Client Account). Seven Fleet’s expense allocations often depend on inherently subjective determinations, but the expense allocations made by Seven Fleet will be in good faith. However, in all cases, subject to applicable legal, regulatory, contractual or similar restrictions, Seven Fleet will make expense allocation decisions in its sole discretion in good faith. Seven Fleet and its personnel generally can be expected to receive certain intangible and/or other benefits and/or perquisites arising or resulting from their activities on behalf of Client Accounts, including benefits and other discounts provided from service providers. For example, airline travel or hotel stays incurred as a Client Account expense typically result in cash rebates, “miles,” “points” or credit in loyalty/status programs, and such benefits and/or amounts will exclusively benefit Seven Fleet and/or such personnel even though the cost of the underlying service is borne by the Client Accounts. The value of such benefits and perquisites will neither be subject to an offset against fees or expenses payable by clients nor will they otherwise be shared with Client Accounts and/or portfolio investments. The Principal serves on the board of directors of certain portfolio companies of the Client Accounts, and in such capacity is reimbursed by such companies for travel costs and other expenses related to attendance at portfolio company board meetings.

Investment Objective Seven Fleet’s investment objective in advising the Client Accounts is to generate attractive risk-adjusted returns primarily by investing in publicly traded equity securities of biotechnology companies. The Client Accounts’ investment strategy seeks to generate uncorrelated returns by trading around events such as clinical trial readouts, regulatory decisions, commercial milestones, and corporate transactions. Seven Fleet believes that these events typically exhibit lower beta characteristics, allowing the Client Accounts to invest across various market conditions. Investment Strategy Seven Fleet brings technical experience in evaluating the fundamentals of therapeutics companies, including an understanding of biology, clinical trial design, biostatistics, regulatory pathways, and competitive dynamics. Seven Fleet intends to use this experience to generate long and short ideas based on its views of the anticipated outcomes of key events. Since value dislocations are frequent in the biotechnology sector, typical holding periods will range from weeks to months to years, with position size changing based on correction of value dislocations, outcome of events, and/or other factors. The majority of the Client Accounts’ portfolios will include long and short positions of common stock, with options used for risk management or enhancement of returns. The Client Accounts may from time to time make investments in late growth stage private companies. While the Client Accounts intend to primarily invest in U.S. securities, the Client Accounts may from time to time acquire non-U.S. securities. Investment Process Seven Fleet will deploy an investment process that spans three categories of analysis: 1) Technical analysis, including assessment of preclinical and clinical data, clinical need and market opportunity, regulatory risk, manufacturing requirements, and competitive dynamics. 2) Equity analysis, including cash requirements, balance sheet, and trading dynamics. 3) Valuation analysis, which applies a comprehensive framework incorporating elements such as stage, therapeutic modality, and indication to quantify value relative to peers. These three elements are incorporated to seek to analyze the likely outcome of an event, anticipated price movements, and size positions based on the desired risk-reward profile. In advising the Client Accounts, Seven Fleet will typically take long positions if Seven Fleet believes that a company has a depressed valuation relative to peers, a high probability of technical or regulatory success relative to what is being priced into the stock, indications of high strategic or investor interest, and a credible management team. Seven Fleet will typically take short positions in the Client Accounts if Seven Fleet believes that a company has an upcoming catalyst with low probability of success, a weak rationale for the development program based on biology, clinical data, or clinical trial design, and tractable trading dynamics based on volume and short interest. Initial position sizing will be determined by assessing a number of factors, including, without limitation: strength of the fundamental science driving the investment; expected financial risk/reward return profiles; expected time horizon of the investment thesis; factor considerations such as liquidity, short interest and position crowding; and portfolio balances across parameters such as sub-sectors and types of investment. Monitoring of portfolio investments will generally be focused on the risk/reward profile given changing securities prices, and on new data points regarding the key drivers that have been identified for each company.

The development of an investment strategy for the Client Accounts is an ongoing process. The strategies, techniques and methods described above will therefore be modified by Seven Fleet over time. There is no limitation on the investment strategies, techniques, methods or processes that Seven Fleet may adopt for the Client Accounts or the factors that Seven Fleet may consider in analyzing investments for the Client Accounts. Depending on conditions and trends in securities markets and the economy generally, Seven Fleet may pursue other objectives, or employ other strategies, techniques, methods or processes, that it considers appropriate and in the best interests of the Client Accounts, without notice to, or the consent of, investors. Summary of Material Risks There can be no assurance that Seven Fleet’s investment objective in managing the Client Accounts will be achieved, and that the Client Accounts will not incur losses. Each Investor is also encouraged to consult with Seven Fleet to review the specific risk parameters of, and assets that comprise, the Client Accounts’ portfolio at any given time and from time to time. The risk factors described below are not intended to be an exhaustive listing of all potential risks associated with an investment in the Client Accounts. Investment and Trading Risks. All securities investments risk the loss of capital. Seven Fleet believes that the investment program and Seven Fleet’s research techniques will mitigate this risk through a careful selection of securities and other financial instruments; however, no guarantee or representation is made that the investment program will be successful or that the Client Accounts will not incur losses. The investment program may utilize investment techniques including, but not limited to, trading in put and call options, the use of leverage and short sales, which in practice can, in certain circumstances, increase the adverse impact to which the Client Accounts may be subject. In certain transactions, the Client Accounts may not be “hedged” against market fluctuations or, in reorganization or liquidation situations, may not accurately value the assets of the subject company or the degree of legal and regulatory risk associated with investments in the securities of companies in such situations. This can result in losses, even if the proposed transaction is consummated. Seven Fleet will attempt to assess the foregoing risk factors, and others, in determining the extent of the position it will take in the relevant securities and the price it is willing to pay for such securities; however, such risks cannot be eliminated. Investment Analysis. When assessing investment opportunities, Seven Fleet relies on resources that may have limited or incomplete information. In particular, Seven Fleet relies on publicly available information and data filed with various government regulators or made directly available to Seven Fleet by the issuers of securities or through sources other than the issuers. Although Seven Fleet expects that it will evaluate information and data as it deems appropriate and will seek independent corroboration when reasonably available, Seven Fleet will not evaluate all publicly available information and data and cannot confirm the completeness, genuineness or accuracy of the information and data that it evaluates. As a result, there can be no assurance that the due diligence exercise carried out by Seven Fleet will reveal or highlight all relevant facts that may be necessary or helpful in evaluating investment opportunities. Any failure to have identified the relevant facts may result in an inappropriate investment decision, which may have a material adverse effect on the value of any investment in the Client Accounts. Concentration of Investments. Subject to any limitations adopted by Seven Fleet from time to time, the Client Accounts are not restricted in the amount of their capital that they may commit to any issuer or security, and at times the Client Accounts may hold a relatively large concentration in a limited number of issuers or securities. Losses incurred in connection with those investments could have a material adverse effect on the Client Accounts’ overall financial condition. This is because the value of the Client Accounts’

investment portfolios will be more susceptible to any single occurrence affecting one or more of those issuers or securities than would be the case with a more diversified investment portfolio. In addition, because the Client Accounts invest solely in the biotechnology sector, poor performance of such sector will have a greater effect than if the Client Accounts invested in a wide variety of sectors. Investing in Biotechnology Companies. Many of the biotechnology companies in which Seven Fleet may invest on behalf of the Client Accounts are in a developmental stage and will have little or no revenue, and the value of such companies will be largely dependent upon their research and development (R&D) pipelines. Accordingly, the value of such investments will especially be affected by problems related to product development, testing, regulatory compliance, manufacturing, sales and marketing capabilities and competition. Moreover, any time a biotechnology company is developing a new drug, there is significant uncertainty around both the ultimate costs and expenses that will be incurred and the time it will take a company to bring the drug to market, if the drug is brought to market at all (which itself is a significantly uncertain proposition). In addition, biotechnology companies are affected by general trends related to the demand for health-related products and services as well as the uncertainty of the results of clinical trials and approval of their products by the Food and Drug Administration (the “FDA”) or a foreign equivalent. Biotechnology product development is heavily regulated by the FDA and other agencies and a very small percentage of the biotechnology products developed are approved for sale by the FDA or a foreign equivalent. Even if approved, there can be no assurance that the products will be commercially successful. The success of the biotechnology companies will depend, among other factors, on their ability, and the ability of any licensors, to obtain and maintain patent protection for their products and technologies and to preserve trade secrets. There can be no assurance that patents licensed to companies will be valid or will afford companies protection against competitors with similar technologies. The enforcement of patent rights may require costly litigation. The introduction of new drugs and medical devices can be subject to potential product liability risks which are inherent in the testing, manufacturing, marketing and sale of such drugs and medical devices. Product liability insurance for the biotechnology industry is expensive, if available at all, and no assurance can be given that any company in which the Client Accounts invest will have adequate insurance coverage or that a product liability claim would not have a material adverse effect on such company. General Risk of Investing in the Biotechnology Sector. Investing in securities and other instruments of company in the biotechnology space involves substantial risks, including, but not limited to: certain companies in the Client Accounts’ portfolios may have limited operating histories; scarcity of management and marketing personnel with appropriate scientific or medical training may slow or impede companies’ growth; the possibility of lawsuits related to patents or products; obsolescence of products; change in government policies; changing investor sentiments and preferences with regard to the sector investments (some of which are generally perceived as risky) may have an adverse effect on the price of underlying securities; volatility in the U.S. stock markets affecting the prices of biotechnology company securities may cause the Client Accounts’ performance to experience substantial volatility; and many companies in this sector are subject to extensive government regulation. General Equity Securities Risks. In advising the Client Accounts, Seven Fleet will invest in equity securities. Equity securities fluctuate in value in response to many factors, including the activities, results of operations and financial condition of individual companies, the business market in which individual companies compete, industry market conditions, interest rates and general economic environments. In addition, events such as epidemics, pandemics, political instability, terrorism and natural disasters may be unforeseeable and contribute to market volatility in ways that may adversely affect the Client Accounts’ positions. Small to Medium Capitalization Companies. In advising the Client Accounts, Seven Fleet may invest their assets in the stocks of companies with small- to medium-sized market capitalizations. While Seven

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Seven Fleet provides investment advice to the Client Accounts. The Offering Documents of the Funds set forth the eligibility criteria and minimum investment requirements for Investors. Initial and additional subscription minimums are disclosed in the Offering Documents (currently US $1,000,000 for an initial investment), which may be waived at the discretion of Seven Fleet. Each Investor in the Feeder Funds generally must be (i) an “accredited investor,” as defined in Regulation D under the U.S. Securities Act of 1933 (the “Securities Act”), and (ii) a “qualified purchaser,” as defined in the Advisers Act. The subscription agreement contains representations and questionnaires relating to these qualifications. Seven Fleet determines the qualifications and minimum investment (as well as any other conditions) for the Other Accounts on a case-by-case basis.

As generally described above in Item 5, Seven Fleet generally receives performance-based fees from the Other Accounts and the General Partner generally receives performance-based allocations from the Master Fund (and indirectly from the Feeder Funds). Clients Accounts and Fund investors are provided with detailed disclosure in their written agreements with Seven Fleet and the applicable Offering Documents for such Fund, as applicable, as to how the relevant performance-based compensation is calculated and charged. Performance-based compensation will conform to Rule 205-3 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), to the extent applicable. As management fees and performance-based compensation are based directly on the net asset value of Client Accounts, Seven Fleet will be subject to a conflict of interest in valuing the assets held in the Client Accounts. To the extent that Seven Fleet is responsible for valuing a Client Account’s assets, Seven Fleet will follow its documented valuation policies in order to mitigate this risk.

The existence of performance-based compensation may create certain conflicts of interest. More specifically, it may create an incentive for Seven Fleet to pursue riskier or more speculative investments, then it would be the case if there were no performance-based fees. Seven Fleet recognizes that it has a fiduciary duty and as such must act in the best interests of its Client Accounts. The specific terms applicable to performance-based fees and allocations may differ among the various Client Accounts. This may result in a conflict of interest when Seven Fleet and its affiliates allocate opportunities among these Client Accounts because there may be an incentive to favor allocations to Client Accounts that have higher performance-based fees and allocations. To avoid such conflict of interest, Seven Fleet will follow documented procedures in allocating opportunities amongst the Client Accounts (as discussed in Item 12 of this Brochure), which would not take into account the performancebased fees and allocations to which such Client Accounts are subject. Notwithstanding the foregoing, there can be no assurance that certain allocation decisions will not directly or indirectly adversely affect the Client Accounts, even if such decisions are made in good faith. Allocations are subject to a significant degree of discretion exercised by Seven Fleet, including, but not limited to, in connection with portfolio rebalancing, investing in new, different or additional investment strategies and in connection with admissions and withdrawals of investors to and from the private investment funds that Seven Fleet manages. Even allocations designed to mitigate conflicts do not eliminate the possibility that an allocation of assets will not adversely affect the Client Accounts. Seven Fleet will have no obligation to purchase or sell a security for, enter into a transaction on behalf of, or provide an investment opportunity to, a Client Account solely because Seven Fleet purchases or sells the same security for, enters into a transaction on behalf of, or provides an opportunity to, another Client Account if, in Seven Fleet’s reasonable opinion, such security, transaction or investment opportunity does not appear to be suitable, practicable or desirable for such other Client Account. Seven Fleet’s personnel and/or other related persons may invest in one or more of Seven Fleet’s Clients Accounts. In such case, Seven Fleet may have an incentive to favor Client Account(s) in which Seven Fleet has a greater economic interest and/or may have a conflict of interest in allocating investment opportunities among those Client Accounts and other Client Accounts. In order to mitigate these potential conflicts, Seven Fleet will generally follow the documented procedures referenced above.

As noted above in Item 4, the General Partner is an affiliate of Seven Fleet by common ownership and control and a “relying adviser” of Seven Fleet. Neither Seven Fleet nor the General Partner are registered or have an application pending to register as a broker-dealer or a registered representative of a broker-dealer. Neither Seven Fleet nor the General Partner are registered or have an application pending to register as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. Seven Fleet is subject, and each Client Account is exposed, to a number of actual and potential conflicts of interest. Any such conflict of interest could have a material adverse effect on the Client Accounts (and on Investors in the Funds). However, the existence of an actual or potential conflict of interest does not mean that it will be acted upon to the detriment of any Client Account. When a conflict of interest arises, Seven Fleet will endeavor to ensure that the conflict is resolved fairly and in an equitable manner that is consistent with its fiduciary duties to the relevant Client Account(s). Seven Fleet has in place policies and procedures that it believes are reasonably designed to identify and resolve actual and potential conflicts of interest. However, there can be no assurance that these policies and procedures will be successful in identifying or mitigating all actual or potential conflicts of interest. Affiliated Funds and Other Clients Seven Fleet’s management of its Client Accounts may result in conflicts of interests when Seven Fleet and its related persons allocate time and investment opportunities among its Client Accounts (including Client Accounts in which Seven Fleet or its related persons may be invested). In addition, terms regarding fees and performance-based compensation may differ among Client Accounts. This may result in a conflict of interest when Seven Fleet allocates opportunities among its Client Accounts because Seven Fleet has an incentive to favor Client Accounts that have higher fee and/or performance-based compensation arrangements as well as Client Accounts in which Seven Fleet or its related persons have invested. To avoid such conflicts of interest Seven Fleet generally follows documented procedures in allocating opportunities among such Client Accounts, which do not take into account the fees or performancebased compensation to which such Client Accounts are subject or the investment in such Client Accounts by Seven Fleet or its related persons. Seven Fleet, the General Partner, the Principal and their affiliates may determine, in their sole discretion, to participate in investments with persons not affiliated with the Client Accounts. In addition, Seven Fleet may offer to certain Client Accounts, or to any third party, the opportunity to co-invest in opportunities in which a Client Account has invested or that become available to a Client Account. Seven Fleet may offer such opportunities to investors that Seven Fleet selects in its sole discretion without notice to or the consent of any other Client Account or investor. The economic and other terms of any co-investment will be determined by Seven Fleet in its discretion on a case-by-case basis, and Seven Fleet may receive fees and/or allocations from co-investors, which may differ among co-investors and also may differ from the fees and/or allocations borne by the Client Accounts (or investors in the Funds).

Employment with Another Firm The Principal and Rod Lim are employed by Longitude Capital Management Co., LLC (“Longitude”), a registered investment adviser, and will continue to perform services for Longitude as employees. They will allocate their time, and investment opportunities, among Longitude, and the Client Accounts. Additionally, in connection therewith, the Principal expects to continue to hold board seats with certain private and public companies on behalf of Longitude. Since the Principal and Rod Lim will be Longitude access persons and subject to the Longitude restricted list, there may be investment opportunities that Seven Fleet cannot pursue on behalf of the Client Accounts because such securities are on the restricted list and the Client Accounts may hold securities that Seven Fleet is unable to dispose of if such securities are on the restricted list. In particular, the inability to sell a position as a result of such restricted list could have an adverse effect on the Client Accounts as the Client Accounts may be unable to avoid losses in a position that Seven Fleet believes will depreciate in value or realize gains in a position that Seven Fleet believes will appreciate in value until the position is removed from the restricted list. The Principal’s and Rod Lim’s continued employment with Longitude creates a conflict of interest to the extent Client Account investment opportunities being pursued by the Principal and Rod Lim via Seven Fleet are also investment opportunities for Longitude funds. Seven Fleet may be unable to pursue an investment opportunity as a result of such conflicts and an investment opportunity that is appropriate for the Client Accounts, may be instead offered to one or more Longitude funds; however, the Principal’s services to Longitude will relate to both private and public company investments, including participation in certain transactions involving public companies in the healthcare sector. Potential and actual conflicts of interest are created to the extent that the Principal’s services to Longitude involve public companies that are also within the investment mandate of the Client Accounts. Additionally, while Rod Lim will advise Longitude regarding public and private securities in the healthcare space, his services to Longitude have been and are expected to be more advisory in nature unless Longitude launches a public securities fund structure. If the overlap between Longitude’s and Seven Fleet’s investment activities increases materially in the future, Seven Fleet and Longitude will either adopt additional policies to address applicable conflicts of interest or restructure the dual-employment arrangement. Service Providers Certain advisors and other service providers, or their affiliates, to Seven Fleet and its Client Accounts may also provide services to or have business, personal, familial, political, financial or other relationships with Seven Fleet or its affiliates. Such advisors and service providers may be Seven Fleet’s clients or Investors, sources of investment opportunities for Seven Fleet or Client Accounts, prime brokers and placement agents to Client Accounts, or co-investors with or counterparties to transactions involving the foregoing. These relationships may influence Seven Fleet in deciding whether to select or recommend any such advisor or service provider to perform services for the Client Accounts (the cost of which will generally be borne directly or indirectly by the Client Accounts), and may influence such advisors or service providers to do business with Seven Fleet. Notwithstanding the foregoing, Seven Fleet will generally seek to engage advisors and service providers for Client Accounts on the basis of, without limitation, the overall quality of advice and other services provided. In addition, Seven Fleet has a conflict of interest where a service provider (e.g., legal counsel or accountants) provides services directly to Seven Fleet or one of its affiliates, and separately provides services to one or more Client Accounts, in that Seven Fleet or its affiliates may potentially obtain services at a lower cost (or obtain other terms that are more beneficial) than Seven Fleet or its affiliates otherwise could have as a result of the service provider’s work performed on behalf of, and the compensation paid to the service provider by, such Client Accounts. In particular, unless inconsistent with the applicable written agreement with respect to the Client Account, costs associated with services rendered to the

benefit of a Client Account may be borne by such Client Account. Seven Fleet or its affiliates may use some of the same service providers as are retained on behalf of one or more Client Accounts and, in some cases, fee rates, amounts or discounts may be offered to Seven Fleet or its affiliates by a third-party service provider which differ from those offered to a Client Account as a result of scheduled or ad hoc rate changes, differences in the scope, type or nature of the service or transaction, alternative fee arrangements and negotiation.

Trading Code of Ethics Seven Fleet has adopted a Code of Ethics pursuant to Rule 204A-1 of the Advisers Act (the “Code”) that establishes certain standards of conduct and rules for its employees and/or access persons (as applicable). A summary of the Code is provided below. All access persons of Seven Fleet must acknowledge annually that they understand and agree to the terms of the Code. The Code incorporates the following general principles that all employees are expected to always uphold: •

Employees must place the interest of Client Accounts first;

•

Employees must conduct all personal securities transactions in a manner consistent with the Code and seek to avoid both actual conflicts of interest and the appearance thereof, and;

•

Employees may not take inappropriate advantage of their own positions with Seven Fleet for their own personal benefit.

Personal Trading The Code permits access persons (generally employees and their immediate family members), upon prior approval from the CCO, to purchase or sell publicly traded securities for their own accounts or accounts that the access person controls or which the access person may be deemed to have beneficial ownership (such as an account of a spouse or minor child). Seven Fleet generally prohibits access persons from trading in securities that largely comprise the investable universe of the Client Accounts. Access persons are permitted to buy and sell private securities (such as investments in hedge fund, private equity funds and private companies) with prior approval. Access persons are also permitted to invest in mutual funds and U.S. and non-U.S. government issued obligations without prior approval. In addition, Seven Fleet may permit access persons to maintain accounts that are managed on a discretionary basis by a third party if the access person has no direct or indirect influence or control over the investments for the account. Seven Fleet employees are required to disclose their personal securities holdings on an initial and annual basis, and their personal securities transactions quarterly, which requirements are designed to address potential conflicts of interest that might interfere or appear to interfere with making decisions in the best interest of the Client Accounts. Gifts and Entertainment, Political Activities and Outside Activities

The Code provides that gifts and entertainment must be reasonable considering industry practices and should never be given or received if the purpose is to influence the recipient. Seven Fleet requires access persons to report or receive approval for the receipt or giving of gifts and entertainment under certain circumstances. The Code also generally requires access persons to obtain prior approval before the access person, a spouse or certain other immediate family members makes a political contribution or engages in certain campaign-related fundraising activities. This policy is intended to prevent scenarios whereby an access person may make a contribution or engage in an activity for the selection of Seven Fleet as an investment adviser for a governmental equity. Finally, the Code provides that, without prior approval, access persons are generally not permitted to engage in certain types of outside business activities. This policy is intended to prevent material conflicts of interest that could arise from an access person’s personal activities. Participation or Interest in Client Account Transactions Seven Fleet, the Principal and employees do not purchase or sell any securities for their own accounts to or from the Client Accounts. However, subject to the investment guidelines and restrictions of the Client Accounts, Seven Fleet may effect rebalancing or internal cross transactions. In such cases, Seven Fleet may determine that it would be in the best interests of a Client Account and one or more other Client Accounts to transfer a security from one Client Account to another (each such transfer, a “Cross Trade”) for a variety of reasons, including tax purposes, liquidity purposes, to rebalance the portfolios of the Client Accounts, or to reduce transaction costs that may arise in an open market transaction. If Seven Fleet decides to engage in a Cross Trade, Seven Fleet will determine that the trade is in the best interests of both Client Accounts involved and take steps to ensure that the transaction is consistent with the duty to obtain best execution for each of those accounts. If Seven Fleet were to execute Cross Trades, it might be with the assistance of a broker-dealer that executes and books the transaction at the close of the market on the day of the transaction. Alternatively, a cross transaction between two Client Accounts may occur as an “internal cross,” where Seven Fleet instructs the custodian for the accounts to book the transaction at the price determined in accordance with Seven Fleet’s valuation policy. If Seven Fleet effects an internal cross, Seven Fleet will not receive any fee in connection with the completion of the transaction. In the event that Seven Fleet effects a Cross Trade between an account in which it or its controlling persons own more than twenty five percent (25%) and another Client Account, such transaction may be deemed to be a principal transaction under the Advisers Act. Such transactions may create a conflict of interest for Seven Fleet because Seven Fleet may put its or its control persons’ interests in such accounts before the interests of its clients in the other account. In order to mitigate this conflict of interest, Seven Fleet monitors the interests of its principals, their immediate family members and their affiliates in Client Accounts, and will not effect any cross trades between accounts if Seven Fleet believes that such trade would result in a principal transaction unless: 1) Seven Fleet believes that such transaction is in the best interest of the clients participating in the transaction; and 2) Seven Fleet obtains the consent of the applicable Client Account as required by the Advisers Act. Additional Considerations

From time to time, various potential and actual conflicts of interest may arise from the overall advisory, investment and other activities, partners and personnel in connection with Client Account transactions. Seven Fleet has established written policies and procedures, which contain procedures to monitor and resolve conflicts and will endeavor to resolve conflicts in a manner it deems equitable to the extent possible under the prevailing facts and circumstances. Investors may also contact Seven Fleet via email or telephone to request information about Seven Fleet’s Code.

Seven Fleet has complete discretion in deciding which securities are bought and sold, the amount and price of those securities, the brokers or dealers to be used for a particular transaction, and commissions or markups and markdowns paid. Portfolio transactions for the Client Accounts are allocated to brokers and dealers on the basis of numerous factors and not necessarily lowest pricing. Brokers and dealers may provide other services that are beneficial to Seven Fleet but not beneficial to the Client Accounts. Subject to best execution, in selecting brokers and dealers (including prime brokers) to execute transactions, provide financing and securities on loan, hold cash and short balances and provide other services, Seven Fleet may consider, among other factors that are deemed appropriate to consider under the circumstances, the following: the ability of the brokers and dealers to effect the transaction; the brokers’ or dealers’ facilities, reliability and financial responsibility; and the provision by the brokers of capital introduction, talent introduction, marketing assistance, consulting with respect to technology, operations and equipment, commitment of capital, access to company management and access to deal flow. Accordingly, the prices and commission rates (or dealer markups and markdowns arising in connection with riskless principal transactions) charged to the Client Accounts by brokers or dealers in the foregoing circumstances may be higher than those charged by other brokers or dealers that may not offer such services. Seven Fleet need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost or spread. Generally, neither Seven Fleet nor the Client Accounts separately compensate any broker or dealer for any of these other services. Seven Fleet maintains policies and procedures to review the quality of executions, including periodic reviews by its investment professionals. Soft Dollar Usage From time to time, Seven Fleet pays a broker-dealer commissions (or markups or markdowns with respect to certain types of riskless principal transactions) for effecting Client 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. Seven Fleet 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 Exchange Act and subject to prevailing guidance provided by the SEC regarding Section 28(e). Seven Fleet believes it is important to its investment decision-making processes to have access to independent research. Also, consistent with Section 28(e), research products or services obtained with “soft dollars” generated by a Client Account may be used by Seven Fleet to service one or more other Client Accounts, including accounts that may not have paid for the soft dollar benefits. Seven Fleet will not seek to allocate soft dollar benefits to Client Account(s) in proportion to the soft dollar credits the Client Account(s) generate. Where a product or service obtained with soft dollars provides both research and non-research assistance to Seven Fleet (i.e., a “mixed use” item), Seven Fleet 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 may exist because of Seven Fleet’s allocation of the costs of such benefits and services between those that primarily benefit Seven Fleet and those that primarily benefit the Client Account(s). When Seven Fleet uses brokerage commissions (or markups or markdowns) generated by any Client Account to obtain research or other products or services, Seven Fleet receives a benefit because it does not have to produce or pay for such products or services. While Seven Fleet is obligated to seek best execution for each Client Account, the fact that Seven Fleet can obtain or receive such products or services may create an incentive for it to select or recommend a particular broker-dealer based on Seven Fleet’s interests, to the exclusion of another broker-dealer that offers business terms that are also favorable to one or more Client Accounts. At least annually, Seven Fleet 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 Client 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 the considerations described above. In no case will Seven Fleet 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. Additionally, brokers may provide Seven Fleet and the Client Accounts with capital introduction services, talent recruitment, and front and back office services, including trading, securities lending, clearing, reporting, and settlement for equities, fixed income, foreign currency and options, among others. Brokerage for Client Referrals Subject to applicable law, Seven Fleet may direct some client brokerage business to brokers who refer prospective investors to the Funds, consistent with best execution. Because such referrals, if any, are likely to benefit Seven Fleet but will provide an insignificant (if any) benefit to Investors and Other Accounts, Seven Fleet has a conflict of interest when allocating client brokerage business to a broker who has referred Investors to Seven Fleet. To prevent client brokerage commissions from being used to pay investor referral fees, Seven Fleet will not allocate client brokerage business to a referring broker unless Seven Fleets determines in good faith that the commissions payable to such broker are not materially higher than those available from non-referring brokers offering services of substantially equal value to the Client Account. Trade Aggregation and Allocation Policies and Procedures and Aggregation of Orders Seven Fleet intends to execute trades and investments in the Client Accounts. It is Seven Fleet’s policy to allocate investment opportunities to the Client Accounts on a fair and equitable basis, to the extent practical and in accordance with the Client Accounts’ applicable investment strategies, over a period of time. Investment opportunities will generally be allocated among those accounts for which participation in the respective opportunity is considered appropriate, taking into account, among other considerations: whether the risk-return profile of the proposed investment is consistent with an account’s objectives, the potential for the proposed investment to create an imbalance in an account’s portfolio, the liquidity requirements of an account, potentially adverse tax consequences, regulatory

restrictions that would or could limit an account’s ability to participate in a proposed investment, and the need to re-size risk in an account’s portfolio. Seven Fleet will have no obligation to purchase or sell a security for, enter into a transaction on behalf of, or provide an investment opportunity to, a Client Account solely because Seven Fleet purchases or sells the same security for, enters into a transaction on behalf of, or provides an opportunity to, another Client Account if, in its reasonable opinion, such security, transaction or investment opportunity does not appear to be suitable, practicable or desirable for the other Client Account(s). When a Client Account is ramping up its investment or trading strategies, it may receive larger allocations of certain securities than the other Client Accounts to obtain its desired risk and portfolio size and the other Client Accounts may receive less. Seven Fleet will generally aggregate client trades, subject to best execution. Aggregation, or “bunching,” describes a procedure whereby an investment adviser combines the orders of two or more clients into a single order for the purpose of obtaining better prices and lower execution costs. Aggregation opportunities for Seven Fleet generally arise when more than one Client Account is capable of purchasing or selling a particular security based on investment objectives, available cash and other factors. In such event, securities purchased or sold will generally be allocated among Client Accounts on an average price basis. If an aggregated order is only partially filled, securities will be allocated among the Client Accounts as described in the paragraphs above. When orders are not aggregated, trades generally will be processed in the order that they are placed with the broker or counterparty selected by Seven Fleet. As a result, certain trades in the same security for one Client Account (including a Client Account in which Seven Fleet and its personnel may have a direct or indirect interest) may receive more or less favorable prices or terms than another Client Account, and orders placed later may not be filled entirely or at all, based upon the prevailing market prices at the time of the order or trade. In addition, some opportunities for reduced transaction costs and economies of scale may not be achieved. Trade Errors Trade errors involving transactions in any account directly or indirectly held by the Client Accounts or any derivatives contract or other similar agreement of the Client Accounts and/or any trading vehicle (each, a “Trade Error”) may occur. Trade Errors include the placement of orders (either purchases or sales) in excess of, or less than, the amount of securities the account intended to trade; the sale of a security when it should have been purchased; the purchase of a security when it should have been sold; the purchase or sale of the wrong security; and the purchase or sale of a security for the wrong account and the post-settlement discovery of such purchase or sale. Trades implemented because of faulty data, systems, coding, modeling or analysis, trades that are properly executed but result in losses, errors committed by other persons (including brokers and custodians), or that are otherwise caused by human error other than those specifically described above, are not considered Trade Errors. The loss of an investment opportunity is not considered a Trade Error. Such errors may result in losses or gains. Seven Fleet will use reasonable efforts to detect such errors prior to settlement and promptly correct them. To the extent that an error is caused by a counterparty, such as a broker-dealer, Seven Fleet will use reasonable efforts to recover any losses associated with such error from the counterparty. Pursuant to the exculpation and indemnification provided by the Client Accounts to Seven Fleet and its affiliates and personnel, Seven Fleet and its affiliates and personnel will generally not be liable to the Client Accounts for any act or omission, absent willful misconduct or gross negligence (and absent a violation of law with respect to a particular Other Account) of such person (the “carve outs”), and the Client

Accounts will generally be required to indemnify such persons against any losses they may incur by reason of any act or omission related to the Client Accounts, subject to such carve outs. As a result of these provisions, the Client Accounts (and not Seven Fleet) will benefit from any gains resulting from Trade Errors and other errors and will be responsible for any losses (including additional trading costs) resulting from Trade Errors and other errors, subject to the carve outs. Seven Fleet will reimburse the Client Accounts for losses for which Seven Fleet is responsible under the exculpation provisions. Seven Fleet faces a potential conflict of interest because, should a trade error occur, generally Seven Fleet (and not an independent third party) would be the party that determines whether such trade error resulted from Seven Fleet’s willful misconduct or gross negligence (or violation of law if applicable). However, notwithstanding this potential conflict of interest, in all cases, Seven Fleet would make such determination in good faith. Given the potentially large volume of transactions executed by Seven Fleet on behalf of the Client Accounts, Investors should assume that Trade Errors and other errors will occur and that, to the extent permitted by applicable law and under each Client Account’s respective governing documents, the Client Accounts will be responsible for any resulting losses, even if such losses result from the negligence (but not gross negligence, willful misconduct or, in certain cases, a violation of law) of Seven Fleet’s personnel. Third Party Trading Seven Fleet uses a third-party trader to execute certain trades. When using a third-party trader, Seven Fleet may select a specific broker that the third party-trader must use to execute the trade in question. Seven Fleet’s decision to instruct the third-party trader to use a specific broker (or otherwise) is subject to the broker selection criteria described above.

Although Seven Fleet does not currently have any third-party placement agents, Seven Fleet may agree to pay third-party placement agents that refer investors to the Funds or refer clients to Seven Fleet for advisory services. The compensation typically paid to those placement agents includes a portion of the management fee and/or performance allocation/fees earned by Seven Fleet in respect of investors referred to by such placement agents. Investors are generally not subject to any incremental fees in connection with the referral unless incremental fees are payable by the investor/client directly to the placement agent under the terms of the separate agreement between the investor/client and the placement agent (to which Seven Fleet is not a party). The referral arrangements described above involve potential conflicts of interest because the placement agent may have an incentive to favor sales of interests/shares in the Funds (or setting up a separately managed account) over recommendations of other investment products for which the agent will receive no or lower fees. Prospective and existing investors should consider this potential conflict of interest when evaluating any recommendation or referral by an agent regarding an investing with Seven Fleet.

Seven Fleet has not been subject to any disciplinary action, whether criminal, civil or administrative (including regulatory) in any jurisdiction. Likewise, no persons involved in the management of Seven Fleet have been subject to such action.

Seven Fleet conducts daily reviews of the Funds’ portfolios to ensure conformity with investment objectives and guidelines. In addition, Seven Fleet reviews transactions, positions, and cash balances daily, along with conducting various other periodic formal and informal reviews. Investors in the Funds generally receive quarterly account statements. Investors also receive copies of audited financial statements on an annual basis and a Schedule K-1 (for the Domestic Fund) on an annual basis. Seven Fleet may enter into agreements (“side letters”) with one or more Investors in the Feeder Funds that result in investment terms that differ from the terms applicable to other Investors, including, without limitation, with respect to fees, performance-based fees or allocations, and/or withdrawal terms. In addition, pursuant to side letters, Seven Fleet may provide particular Investors with more frequent and/or more detailed information regarding a Fund’s positions, performance, finances, and management and/or other information about such Fund or Seven Fleet (including, notification of senior employee departures, the commencement of disciplinary actions, legal proceedings, investigations or similar matters, or redemptions from the Funds by Seven Fleet, its affiliates and/or its respective personnel), possibly enabling such Investors to better assess the prospects and performance of the Funds. As a result of such side letters, certain Investors may receive additional rights and/or information that other investors will not necessarily receive. Subject to applicable law and contractual arrangements, Seven Fleet does not intend to disclose the terms of side letter agreements or other arrangements and does not intend to disclose the identities of the Investors that have entered into such agreements with the Funds or Seven Fleet.

Seven Fleet will not be required to offer such additional or different rights and terms to any or all other Investors. Seven Fleet may provide certain additional information to any Investor, or prospective investor, in a Fund (or to any of Other Accounts clients) who requests such information. This information may be provided in response to questions and requests and in connection with due diligence meetings and other communications, but will not distributed to other Investors and prospective investors (or Other Account clients) who do not request such information. Such information may affect a decision to invest, and Investors (which may include Seven Fleet personnel, affiliates and/or related persons) and Other Account clients who receive such additional information may be able to act on such additional information and redeem their investments potentially at higher values than other Investors (or Other Account clients). Each Investor and Other Account client is responsible for asking such questions that it believes are necessary in order to make its own investment decisions and must decide for itself whether the limited information provided by Seven Fleet is sufficient for its needs. Seven Fleet may provide Investors/Other Accounts with reports in such forms and at such times as such Investors/Other Accounts and Seven Fleet may agree. The custodians of the Other Accounts send account statements to the owners of the accounts no less frequently than quarterly. In addition, since a client that is an Other Account directly owns the positions in the Other Account, such client has full, real-time transparency as to all transactions and holdings in its account, and may be better able to assess the future prospects of a portfolio that may have significant overlap with the portfolios of the Funds, especially with respect to long positions. The Other Account clients generally have the right to withdraw all or a portion of their capital from their accounts on shorter notice and/or with more frequency than the terms applicable to an investment in the Funds.

Seven Fleet is deemed to have custody of the Funds’ assets because it has the authority to obtain the Funds’ funds or securities, for example, by withdrawing funds from a Fund account. Seven Fleet is also deemed to have custody of the Funds’ assets because the General Partner (a related person of Seven Fleet) serves as general partner of certain of the Funds.

Each Fund is subject to an annual financial statement audit by an independent public accountant registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board. The audited financial statements will be prepared in accordance with generally accepted accounting principles in the U.S., and will be distributed to each Investor within 120 days of the applicable Fund’s fiscal year end. In accordance with Rule 206(4)-2, the Funds’ cash and securities are maintained with one or more qualified custodians. Seven Fleet may change the custodians at any time and from time to time without the consent of, or notice to, investors. Qualified custodians do not provide statements directly to investors in the Funds. Seven Fleet does not have custody over the Other Accounts. The qualified custodian selected by the Other Accounts will typically provide these clients with at least quarterly account statements relating to the assets held within the Other Accounts. These clients should carefully review the qualified custodian’s statement upon receipt to determine that it completely and accurately states all holdings in the Other Account and all account activity over the relevant period. Any discrepancies identified by an Other Account should be immediately reported to Seven Fleet and the qualified custodian.

Seven Fleet has full discretionary authority to manage the Client Accounts, including authority to make decisions with respect to which securities are bought and sold, the amount and price of those securities, the brokers or dealers to be used for a particular transaction, and the commissions paid. Seven Fleet’s authority is limited by its own internal policies and procedures and the Client Accounts’ investment guidelines. The Investors in the Funds may not place any limits on Seven Fleet’s authority beyond the limitations set forth in a Fund’s respective Offering Documents. On a case-by-case basis, the Other Accounts may negotiate certain risk and/or operating guidelines that Seven Fleet will adhere to when exercising its discretionary authority over such accounts.

Proxy Voting Policies and Procedures Seven Fleet generally has voting discretion over securities held in the Client Accounts. Seven Fleet has established proxy voting policies and procedures designed to ensure that proxies, to the extent Seven Fleet has been delegated authority to vote such proxies on behalf of the Client Accounts and elects to vote, are voted in the best interest of the Client Accounts and that any material conflict of interest between Seven Fleet’s interests and the interests of its Client Accounts will be resolved in a manner that is consistent with the best interests of the Client Accounts and in a manner not affected by such conflict of interest. Specifically, Seven Fleet monitors the potential for conflicts of interest that might arise from personal relationships that Seven Fleet or its employees may have with parties involved in the vote, significant Investor or the Client Account relationships with those parties, and other unusual circumstances. Seven Fleet will vote proxies as it deems necessary or appropriate, on a case-by-case basis. Prior to voting, the CCO will determine whether the conflict is material to the vote and will either resolve the conflict or refer the proxy vote to an outside service for its independent consideration.

There may be times (which may be frequent) when Seven Fleet is authorized to vote proxies for a Client Account and determines that refraining from voting is in the best interest of that Client Account. For example, Seven Fleet may refrain from voting a Client Account proxy when (without limitation): (i) the economic effect on shareholder’s interests or the value of the portfolio holding is indeterminable or insignificant; (ii) voting the proxy would unduly impair the investment management process; or (iii) the cost of voting the proxies outweighs the benefits or is otherwise impractical. In addition, Seven Fleet may abstain from voting a proxy on behalf of a Client Account due to (1) de minimis holdings; (2) de minimis impact on the portfolio; (3) contractual arrangements with Client Accounts; (4) their authorized delegates or the failure of a proxy to provide sufficient information to allow for informed decision making; and/or (5) items relating to non-U.S. issuers. To the extent that Seven Fleet has discretion to participate in class action lawsuits filed against companies or issuers in which the Client Accounts are invested, Seven Fleet will generally participate in such class action lawsuits unless it believes that such participation is not in the best interest of the Client Accounts. Note that the Principal currently votes proxies for certain positions held by Longitude Capital’s funds; however, Seven Fleet has determined that this does not currently pose a material conflict of interest with its own Client Accounts, given differences in the investment mandates of Seven Fleet’s Client Accounts and Longitude’s funds. Should such a conflict arise in the future, Seven Fleet will determine, with the assistance of counsel and its compliance consultant, as necessary, the appropriate course of action to resolve such conflict. Investors may also contact Seven Fleet via e-mail or telephone to request a copy of Seven Fleet’s proxy voting policy.

Seven Fleet has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to Investors and has not been the subject of a bankruptcy proceeding.