Simcoe Capital Management, LLC

Simcoe Capital Management, LLC (“Simcoe” or the “Investment Manager”) is a Delaware limited liability company established in January 2003. Jeffrey Jacobowitz is the Managing Member and Principal Owner of Simcoe. David Sandel is the Head of Operations and Chief Compliance Officer. Simcoe is the investment manager to private funds organized in a master feeder structure: Simcoe Partners, L.P. a domestic 3(c)7 Fund and Simcoe Partners Offshore, Ltd. a 3(c)7 Offshore Feeder Fund (the “Simcoe Funds”). The Feeder Fund invests substantially all of its assets in Simcoe Partners, L.P. Simcoe Management Company, LLC is the general partner of Simcoe Partners, L.P. Additionally, Simcoe is the investment manager and managing member of SDR Partners, LLC a single member 3(c)1 private fund (the “SDR Fund”). Simcoe is the investment manager of Simcoe Select, L.P. (the “Select Fund”), which is a highly focused 3(c)1 fund with Simcoe’s most compelling ideas. Occasionally, Simcoe may find investment opportunities that are larger than the desired investment size for the Simcoe and SDR Funds. In such instances, Simcoe may present co-investment opportunities to certain investors and/or other strategic partners of Simcoe. Simcoe Management Company, LLC is the general partner of the Select Fund. All funds managed by Simcoe will generally be referred to as “Funds” or “Clients” throughout this document. Simcoe manages the Funds in a manner consistent with the investment strategy described in the Funds’ offering documents. Investment advice is provided directly to the Funds, subject to the discretion and control of the general partner or the board of directors of each Fund, as applicable. Simcoe does not provide specifically tailored advice to investors in the Funds. Simcoe has full discretionary authority with respect to the investment decisions of the Simcoe Funds and Select Fund, however the SDR Fund is managed on a non-discretionary basis. As of December 31, 2025, discretionary regulatory assets under management were approximately $633,820,245.00. Non-discretionary regulatory assets under management were approximately $15,133,203.00.

Simcoe Funds Simcoe receives a management fee at the annual rate of up to 1.0% from the Simcoe Funds. The fees are paid quarterly in advance in accordance with the terms outlined in the private offering memorandums. Management fees are calculated by a third-party administrator, approved by Simcoe and deducted from each investor’s capital account. Simcoe has discretion to waive or reduce the management fee with respect to the accounts of one or more investors/shareholders, including principals, employees or affiliates of Simcoe. Select Fund and SDR Fund There is currently no management fee. Other Fees The Simcoe Funds and Select Fund bear all costs and expenses directly or indirectly related to their investments and operations, including, but not limited to, legal, accounting, audit and other professional

fees and expenses (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 and any filings or reporting with respect to compliance with FATCA 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)); third-party administration fees and expenses, research fees and expenses (e.g., researchrelated travel; Bloomberg and similar subscriptions and data services), fees and expenses of trade order management systems (including systems that facilitate trade compliance, commission management, stock locates and transaction cost analysis), fees and expenses for consulting and statistical services, costs for purchase of insurance and bonds for protection of the Partnership's properties and business, any non-U.S withholdings taxes, investment expenses (such as expenses charged by the outsourced trader, commissions, interest on margin accounts and other indebtedness), custodial fees, bank service fees, direct fees and expenses (such as legal fees and due diligence expenses related to the analysis, purchase or sale of investments whether or not the investment is consummated), Cayman Islands legal fees and expenses, filing fees in the Cayman Islands, directors' fees and expenses, and other reasonable expenses related to the purchase, sale or transmittal of Fund assets. Investors should refer to the Simcoe Funds and Select Fund offering documents for a complete description of fees and compensation. Generally, all expenses borne by the Simcoe Funds and Select Fund will be debited to all investors on a pro rata basis in accordance with their ownership percentages. Investors in the Select Fund will share in the cost of such expenses that are directly attributable to their participation in an investment. Factors that will be considered in the allocation of such expense will include the relative size of the co-investment, the involvement in the due diligence process and the timing of the determination to seek co-investors. Investors in a co-investment transaction would not be expected to share in certain expenses that were largely incurred prior to their involvement. SDR Fund does not bear expenses and its share in the cost of expenses attributable to its participation in an investment will be borne by Simcoe. Certain Funds’ expenses are limited to 0.5% of the Fund’s net assets on an annual basis, however in 2025, expenses did not exceed this limit. Item 12 further describes the factors that Simcoe considers in selecting or recommending broker-dealers for transactions and determining the reasonableness of their compensation.

Investment Objective and Strategy The Simcoe Funds’ objective is to generate above-average long-term returns while preserving its capital. To achieve its investment objective, the Simcoe Funds purchase, trade and invest in securities that the Investment Manager believes to be selling at a discount to their intrinsic value. The Simcoe Funds’ investment focus is on equity and equity-related securities of small-cap and mid-cap companies listed on U.S. securities exchanges or traded on the over-the-counter market. The Simcoe Funds may also invest in companies believed by the Investment Manager to possess “special situation” characteristics. In pursuing its investment strategy, the Simcoe Funds utilize a variety of investment techniques, some of which may be considered speculative, including short selling, the purchase and sale of options on securities and the use of leverage. The Select Fund’s objective is to generate enhanced long-term capital appreciation. To achieve its investment objective, the Select Fund will focus on investing in the securities of a small select number of issuers that Simcoe believes to be selling at a discount to their intrinsic value. The Select Fund’s investment focus is on equity and equity-related securities of small-cap and mid-cap companies listed on U.S. securities exchanges or traded on the over-the-counter market. The Select Fund may also invest in companies believed by Simcoe to possess “special situation” characteristics. In pursuing its investment strategy, Simcoe may utilize a variety of investment techniques, some of which may be considered

speculative, including short selling, the purchase and sale of options on securities and the use of leverage.

Methods of Analysis The Funds seek to achieve their objective by investing in companies that possess one or more of the following characteristics: discretionary free cash flow, superior quality business, strong management, and low valuation. Simcoe seeks out newly public companies that have come public in non-traditional ways such as spin-offs and post-bankruptcy situations. Companies that are undergoing change are also of significant interest; a debt laden company that sells off an asset intensive marginally profitable business in order to focus on a high-quality core business will emerge from the restructuring with a better balance sheet and a more profitable business overall. Additionally, the Investment Manager searches for companies with significant outside shareholders, such as a leveraged buyout firm, who may seek to monetize their investment by selling the whole company. Simcoe is a long-term contrarian investor and seeks to avoid Wall Street’s latest fads. Simcoe will seek to avoid “growth companies”, those trading at unsustainably high multiples, and “acquisitive companies” who destroy capital will be avoided. The Investment Manager typically maintains a three to five-year time horizon when considering investment opportunities and runs a concentrated portfolio. The Funds may invest in companies meeting its criteria on a non-diversified basis. While the Funds’ portfolio will typically contain a number of positions, the Fund’s portfolio may contain one or more positions that represent more than 25% of the Funds’ portfolio. Although the Funds typically invests in the securities of companies on the basis of intrinsic value, the Funds may invest from time to time in companies that are determined by the Investment Manager to possess “special situation” characteristics. In general, a special situation is a company whose securities are expected to increase in value solely by reason of a development particularly or uniquely applicable to that company. Developments that may create special situations include, among others, a liquidation, reorganization, recapitalization or merger, material litigation and new management or management policies. The Funds from time to time actively seek to influence the management or business direction of some of its portfolio companies. The Funds may invest in a particular company based upon its belief that the company’s business and operations could improve as a result of the Fund’s influence. Alternatively, it is possible that the Investment Manager deem it necessary to seek representation for the Funds on the board of directors of, or on official or unofficial creditors’ committees for, a distressed company in order to better monitor the financial condition of the distressed company or developments in the proceeding and/or to be in an improved position of advocacy during any negotiations. There are currently instances where the Funds will be restricted in transacting in or redeeming a particular investment as a result of its activist investment strategy. The Funds may invest a portion of their net assets in securities of non-U.S. issuers. The Funds’ investing in non-U.S. securities involves considerations not typically associated with investing in securities of U.S. companies. The Funds purchase and hold securities for long-term growth of capital and the Investment Manager anticipates that changes to the Fund’s portfolios will not be made for short-term trading purposes or to take advantage of short-term swings in the market. Changes may be made in the Funds’ portfolios consistent with the Funds’ investment objectives and policies, however, whenever those changes are believed by the Investment Manager to be in the best interests of the Funds.

Risks Investment in the Funds is suitable only for persons who can bear the economic risk of the loss of their entire investment, who have limited need for liquidity in their investment, and who meet the conditions set forth in the Funds’ offering documents. There can be no assurance that the Funds will achieve their investment objective. Investment in the Funds involves significant risks, and while the following summary of certain of these risks must be carefully evaluated before making an investment in the Funds, the following does not intend to describe all possible risks of such an investment. Market Risks The profitability of a significant portion of the Funds’ investment program depends to a great extent upon correctly assessing the future course of the price movements of securities and other investments. There can be no assurance that the Investment Manager will be able to predict accurately these price movements. Although the Investment Manager may attempt to mitigate market risk through the use of long and short positions or other methods, there is always some, and occasionally a significant, degree of market risk. Nature of Investments The Investment Manager has broad discretion in making investments for the Funds. Investments will generally consist of global equity securities and other assets that may be affected by business, financial market or legal uncertainties. There can be no assurance that the Investment Manager will correctly evaluate the nature and magnitude of the various factors that could affect the value of and return on investments. Prices of investments may be volatile, and a variety of factors that are inherently difficult to predict, such as domestic or international economic and political developments, may significantly affect the results of the Funds’ activities and the value of its investments. In addition, the value of the Funds’ portfolio may fluctuate as the general level of interest rates fluctuates. No guarantee or representation is made that the Funds’ investment objective will be achieved. Non-Diversification While the Simcoe Funds’ portfolio will generally contain a number of both long and short positions, the Funds will be invested primarily in equity securities. In addition, it is possible that, at a given time, positions (long or short) in a highly concentrated number of issuers may comprise substantially all of the Simcoe Funds’ portfolio. While the Simcoe Funds’ portfolio will typically contain a number of positions, the Simcoe Funds’ portfolio may contain one or more positions where each such position may represent more than 25% of the Simcoe Funds’ portfolio. The Select Fund generally expects to invest its assets in a relatively small number of issuers; however, there is no formal ceiling or floor on the number of investments that may be made by the Select Fund. As a result, the investment portfolio of the Funds will be subject to more rapid changes in value than would be the case if the Funds were required to maintain diversification among issuers, industries, geographic areas, capitalizations or types of investments. Volatility Due to the fact that the Funds’ portfolios are not required to be diversified and will take concentrated positions, the performance of the Funds may be volatile. Special Situations The Funds may invest in companies involved in (or the target of) acquisition attempts or tender offers or in companies involved in or undergoing work-outs, liquidations, spin-offs, reorganizations, bankruptcies or other catalytic changes or similar transactions. In any investment opportunity involving any such type of special situation, there exists the risk that the contemplated transaction either will be unsuccessful, will take considerable time or will result in a distribution of cash or a new security the value of which will be less than the purchase price to the Funds of the security or other financial instrument in respect of which such distribution is received. Similarly, if an anticipated transaction does not in fact occur, the Funds may be required to sell its investment at a loss. Because there is substantial uncertainty concerning the

Read the rest in the brochure

As disclosed in Item 4, Simcoe provides investment management services to private funds. Generally, the minimum initial investment for the Simcoe Funds is $1,000,000 and the minimum initial investment for the Select Fund is $500,000. However, Simcoe or its affiliates reserve the right to accept lesser amounts as long as the investor qualifies to invest based on all other suitability and regulatory requirements. Simcoe may decline to accept the subscription of any prospective investor.

Simcoe Funds and SDR Fund For each fiscal year, 20% of each investor’s share of net profits, if any, will be allocated from the capital account of each investor to the capital account of the General Partner or one or more other persons or entities. The Simcoe Funds may be subject to a hurdle rate as outlined in the fund offering documents. Select Fund For each fiscal year, 15% of each investor’s share of net profits, if any, will be allocated from the capital account of each investor to the capital account of the General Partner, which may be subject to a loss carryforward provision as outlined in the fund offering documents. Simcoe and its affiliates have discretion to waive or reduce the performance fee with respect to the capital accounts of one or more investors/shareholders, including principals, employees and affiliates, without notifying the other investors/shareholders or without reducing the fee with respect to the capital accounts of the other investors/shareholders. Simcoe and its affiliates, may agree to a different incentive compensation arrangement with respect to any of its Clients or underlying investors, including rebating incentive fees, deferring or spreading incentive fee calculations over multiple years, or providing a hurdle for which incentive fees are only earned above a certain amount.

Conflicts Surrounding Performance-Based Fees Simcoe recognizes that performance-based fee arrangements create an incentive to recommend investments which may be riskier or more speculative than those which would be recommended under a different fee arrangement. Simcoe recognizes that such arrangements create an incentive to favor higher fee paying accounts over other accounts in the allocation of investment opportunities. In addition, there is an incentive to favor accounts for which the principals have a personal capital investment. In order to address these potential conflicts, Simcoe has investment and trade allocation policies and procedures, a comprehensive Code of Ethics and investment management oversight processes in place. Simcoe has implemented policies and procedures that govern the allocation of portfolio transactions and investment opportunities across the Funds. Where permissible, the Simcoe Funds and SDR Fund are managed on a “pari-passu” basis with the intent of creating pro-rata allocations in similar securities based upon a percentage of total assets under management. However, position weighting may vary over time due to capital flows of the funds and/or the investment limitations and restrictions applicable to certain funds that may limit Simcoe’s ability to purchase and sell securities to maintain certain security weighting or position sizes. Supporting documentation for trade allocation is reviewed periodically by the Chief Compliance Officer to determine compliance with established policies and procedures. Side Letters The Simcoe Funds have entered into side letters and other agreements with certain investors which have established different rights or privileges with respect to various items, including but not limited to liquidity, management fees, performance allocation fees, custodial fee reimbursements, portfolio transparency, reporting, capacity, and withdrawal notifications. Simcoe enters into such side letters without approval from, or notice to, any investor.

Neither Simcoe nor any of its employees are registered, or have an application pending to register, as a broker-dealer, registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor, or associated person of any of the foregoing entities. Simcoe Management Company, LLC is the General Partner of Simcoe Partners, L.P. and Simcoe Select, L.P. The General Partner is under common control with Simcoe Capital Management, LLC. Simcoe recognizes the potential conflict of interest that this affiliation presents. In order to address any potential conflicts, the Investment Manager has developed and implemented various policies and procedures with respect to employee personal trading and fund trading and brokerage practices, as well as a comprehensive compliance program administered by Simcoe’s Chief Compliance Officer, to ensure that all Funds are treated fairly and equally. Simcoe seeks representation on the board of directors of a company held by Simcoe’s Clients in order to better monitor the financial condition of the company. As a result of such board positions, Simcoe’s Funds will be restricted in transacting in or redeeming a particular investment at certain times during the course of Simcoe’s board representation.

Simcoe has adopted a Code of Ethics for all supervised persons. The Code describes the Investment Manager’s high standard of business conduct and fiduciary duty to its Clients and includes provisions relating to the confidentiality of Client information, a prohibition on insider trading, guidelines surrounding gifts and business entertainment items, personal securities trading procedures, conflicts of interest, among other things. All supervised persons of Simcoe must acknowledge the terms of the Code annually, or as amended. Simcoe’s personal trading policy permits employees to make investments in their personal accounts, subject to certain restrictions. All trades in reportable securities, excluding multi-name ETFs, must be preapproved by the Chief Compliance Officer or Managing Member. While employees may seek permission to transact in investments that may be purchased or sold for a Fund, these investments are only approved after scrutiny to determine whether entering or exiting a position would pose a conflict or potentially harm one of the Funds. The procedures within Simcoe’s Code are intended to ensure Fund investment activities are fully satisfied prior to an employee being given permission to invest. A copy of the Simcoe Code of Ethics is available upon request. Principal and Cross Transactions It is Simcoe’s policy that it will not affect any principal or agency cross securities transactions for Client accounts.

Simcoe has engaged an outsourced trader to facilitate the trading process. The outsourced trader generally serves in the capacity of agent broker and will typically route orders to executing brokers (including brokers affiliated with the outsourced trader) in a manner consistent with Simcoe’s duty to seek best execution. For the avoidance of doubt, the outsourced trader has no discretion to select Fund investments. Simcoe believes that utilizing the outsourced trader provides an efficient means of executing the Fund’s transactions. Simcoe’s overall objective when trading is to meet investment objectives while managing within any established guidelines. Simcoe works with the outsourced trader to consider the full range and quality of each broker’s services, taking into consideration the financial stability and reputation of brokerage firms, creditworthiness, efficiency of execution and error resolution, the actual executed price and the Commission, custodial and other services provided for the enhancement of the Investment Manager’s portfolio management capabilities, the size and type of the transaction, the difficulty of execution and the ability to handle difficult trades, and the operational facilities of the brokers and/or dealers involved (including back office efficiency) and the research, brokerage or other services provided by such brokers. . In selecting a broker-dealer to execute transactions (or series of transactions) and determining the reasonableness of the broker-dealer’s compensation, Simcoe need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost. It is not Simcoe’s practice to negotiate “execution only” commission rates; thus the Funds may be deemed to be paying for research, brokerage, capital introduction to connect Simcoe to investors, or other services provided by a broker-dealer which are included in the commission rate. Simcoe executes trades through Robotti & Company, Inc. (“Robotti”). The controlling shareholders of Robotti and its affiliates are indirect minority members of Simcoe and Simcoe Management Company, LLC, therefore Robotti is an affiliated broker-dealer. Simcoe therefore has an incentive to direct trades to Robotti to provide additional compensation to its affiliate. However, Simcoe will only direct trades to Robotti to the extent Simcoe can obtain best execution as described above. Simcoe does not currently participate in any soft dollar or directed brokerage arrangements and does not select brokers based upon client referrals.

Aggregation Simcoe understands that it has a fiduciary duty to the Funds by allocating securities involving more than one Fund in a fair and equitable manner. Simcoe may, for a number of reasons, aggregate brokerage orders for the Funds rather than execute individual transactions for each account. Some of these reasons include: (1) obtaining lower commission rates; (2) avoiding the time and expense of simultaneously entering similar orders for multiple Funds that are managed similarly; (3) ensuring that all accounts managed in a particular style obtain the same execution to minimize differences in performance; and (4) obtaining a better execution price even though the commission rate may be higher than the lowest rate otherwise available. Consistent with our obligation to seek best execution, Simcoe aggregates orders whenever possible. We have developed procedures to ensure that purchase and/or sell orders which have been aggregated are fairly allocated so that, over time, all Funds are treated fairly and consistent with their investment objectives. An order filled through a series of executions through the same broker on the same terms (e.g., market or limit order) on the same day is generally allocated using an average price. Preliminary allocations are made before execution. As a general policy, the allocation is finalized no later than the close of business on trade date. When an aggregated order is filled in its entirety, the order is allocated to participating accounts in accordance with the preliminary allocation schedule. When an aggregated order is only partially filled (and there is no reasonable expectation that the entire transaction will be completed within a reasonable period), the order will generally be allocated among the participating Funds on an objective basis and in accordance with our established policies and procedures. Where permissible, the Simcoe Funds and SDR Fund are managed on a “pari-passu” basis with the intent of creating pro-rata allocations in similar securities based upon a percentage of total assets under management. However, position weighting may vary over time due to capital flows and/or the investment limitations and restrictions applicable to certain Funds that may limit Simcoe’s ability to purchase and sell securities to maintain certain security weighting or position sizes. The SDR Fund typically maintains less available cash in its portfolio; therefore, the SDR Fund often maintains more concentrated positions relative to the Simcoe Funds’ holdings in those same positions. The Select Fund generally trades in respect of certain larger positions held in the Simcoe Fund’s portfolio; accordingly, the Select Fund is more concentrated than the Simcoe Fund’s portfolio and it does not invest in a number of the positions therein. In cases in which different Funds invest in the same companies or securities, certain Funds’ investments will likely not be made at the same time and in some cases may be at prices higher than those paid by other Funds which would possibly result in lower possible investment returns from such investments. It is unlikely that the performance of each Fund will be identical. Simcoe co-investment opportunities are generally offered to certain investors of the Simcoe Funds and/or other outside parties. Simcoe has sole discretion as to the amount (if any) of a co-investment opportunity that will be allocated to a particular investor and may allocate co-investment opportunities instead to third parties.

Simcoe previously had an agreement in place with Silver Leaf Partners, LLC (“Silver Leaf”), whereby the firm agreed to solicit potential investors for the Funds. Simcoe has terminated its Solicitation Agreement with Silver Leaf. Simcoe has agreed to pay Silver Leaf a percentage of the Management Fee and Performance Fee paid or allocated to Simcoe with respect to investors previously referred by Silver Leaf. All such compensation will be paid by Simcoe from the advisory fees or performance allocations that they receive, and no additional fees or other kind of payment is added to those fees or allocations as a result of the participation of Silver Leaf in the solicitation of investors. Simcoe will not receive any new investor referrals from Silver Leaf. At times, Simcoe or its affiliates occasionally request or are requested to sit on a company’s board of directors. In general, traditional board member compensation, if any, such as directors’ fees or options, received by a Simcoe employee for serving as a director of a company is retained by the employee. The compensation retained Simcoe personnel in their personal capacities create an incentive for the Investment Manager to enter into trades and transactions on behalf of the Funds where such opportunities for additional compensation exist. Since the controlling shareholders of Robotti are indirect minority members of Simcoe, the fact that Robotti may effect transactions for Simcoe should be viewed as additional compensation to an affiliate of Simcoe and a conflict of interest. However, Simcoe will only direct trades to Robotti to the extent Simcoe can obtain best execution as described in Item 12.

Simcoe has no legal or disciplinary events to report that would impact the evaluation by an investor, prospective investor, of our advisory business or the integrity of our management.

Reviews Portfolio reviews are primarily conducted by Jeffrey Jacobowitz on a regular basis. Mr. Jacobowitz continuously reviews the Funds’ investments to ensure they are consistent with the investment objectives, philosophy, strategy and methodologies set forth in such Funds’ offering documents.

Reporting – Fund Investors On a monthly basis, investors receive performance updates. On a monthly basis, investors receive individualized capital statements prepared by the Fund Administrator and quarterly portfolio manager commentary. On an annual basis, investors receive a copy of the Fund’s audited financial statements prepared by the independent auditors and tax reporting information. Simcoe may also provide periodic ad hoc reports/information to investors upon request.

Simcoe does not maintain physical possession of client cash and/or securities. However, as the investment manager with an affiliated General Partner for the Funds, Simcoe does have access to cash and securities in the Funds, along with the authority to perform various acts that result in custody, as defined under Rule 206(4)-2 of the Advisers Act. Consistent with the requirements under the Advisers Act, Client assets are held in accounts maintained with custodians that qualify as “Qualified Custodians.” Qualified Custodians are banks, registered brokerdealers, registered futures commission merchants and foreign financial institutions that hold customer assets in separate customer accounts. The Funds receive account statements from the account administrator/custodian. The Funds are audited annually in accordance with GAAP by an independent public accounting firm that is registered with, and subject to regular inspection by the Public Company Accounting Oversight Board (the PCAOB). Copies of the audited financial statements are independently distributed to each investor within 120 days of the Funds fiscal year end.

Simcoe has full discretionary authority over the Simcoe Funds and Select Fund pursuant to investment management agreements. Discretion is exercised in a manner consistent with the investment objectives and strategies described in the confidential offering memorandums. Simcoe does not have sole authority to make investment decisions for the SDR Fund. Since the investor must approve all trades made for the SDR Fund, Simcoe may not be able to pursue certain investment opportunities or hedge certain risks for the SDR Fund that it would otherwise be able to pursue if the SDR fund was managed on a discretionary basis. As a result, the SDR Fund’s performance may be materially different than the performance of other portfolios managed by Simcoe that utilize substantially the same investment strategy as that of the SDR Fund.

Simcoe has authority to vote proxies on behalf of the Funds. A proxy voting policy is maintained and followed to ensure proxies are voted in the best interests of the Fund and address any conflicts of interests that may arise. A conflict of interest could arise between the interests of Simcoe and the interests of the Funds with respect to a voting decision. If a proxy vote creates a material conflict between the interests of Simcoe and a Fund, it will be resolved before voting the proxy. Simcoe has identified various potential conflicts as part of its policies and procedures. One or more of the following methods may be used to resolve a conflict, should one arise:  

In the case of a conflict of interest resulting from a particular employee’s personal relationships, removing such employee from the decision-making process with respect to such proxy vote; or Any other method as is deemed appropriate under the particular facts and circumstances, given the nature of the conflict.

Investors may obtain a copy of Simcoe’s Proxy Voting Policy and Procedure and/or information about how their securities were voted upon request.

Simcoe does not require or solicit prepayment of any fees six months or more in advance and does not have any financial condition that would impair its ability to meet contractual commitments to clients or investors.