SIR Capital Management, L.P.

SIR Capital Management, L.P. is a Delaware limited partnership that was founded in 2007. For purposes of this Form ADV Part 2A only, the term “SIR” means SIR Capital Management, L.P. and/or SIR Advisors (as defined below), as the context requires. SIR provides advice on a discretionary basis to the following investment funds (each a “Fund” and collectively “the Funds”): (i) Standard Investment Research Hedged Equity Fund, L.P., a Delaware limited partnership (the “Hedged Equity Onshore Fund”); (ii) Standard Investment Research Hedged Equity Overseas Fund, Ltd., a Cayman Islands exempted company (the “Hedged Equity Offshore Fund”, and together with the Hedged Equity Onshore Fund, the “Hedged Equity Funds”); (iii) Standard Investment Research Energy Opportunities Fund, L.P., a Delaware limited partnership (the “Energy Opportunities Onshore Fund”); (iv) Standard Investment Research Energy Opportunities Overseas Fund, Ltd., a Cayman Islands exempted company (the “Energy Opportunities Offshore Fund”, and together with the Energy Opportunities Onshore Fund, the “Energy Opportunities Funds”); (v) Standard Investment Research Energy Transition Fund, L.P., a Delaware limited partnership (the “Energy Transition Onshore Fund”); Standard Investment Research Energy Transition Overseas Fund, Ltd., a Cayman Islands exempted company (the “Energy Transition Offshore Fund”, and together with the Energy Transition Onshore Fund, the “Energy Transition Funds”) (collectively, the “Funds”). SIR also provides advisory service to a separately managed account. Our affiliate, SIR Advisors, L.L.C., a Delaware limited liability company (“SIR Advisors”), acts as the general partner for our U.S.-based Hedged Equity Funds and Energy Opportunities Funds. Another SIR affiliate, SIR ET Advisors LLC., a Delaware limited liability company, acts as the general partner for our US-based Energy Transition Fund. Messrs. Vincent S. Maddi and Shawn M. Brennan (together, the “Managing Members”) are the principal owners of SIR. The Funds are privately-offered hedge funds that focus on investments in energy and related industries. The Funds are organized in master-feeder structures, pursuant to which feeder funds invest substantially all of their assets in master funds. The Hedged Equity Funds invest in the Standard Investment Research Hedged Equity Master Fund, Ltd., a Cayman Islands exempted company (the “Hedged Equity Master Fund”), the Energy Opportunities Funds invest in Standard Investment Research Energy Opportunities Master Fund Ltd., a Cayman Islands exempted company (the “Energy Opportunities Master Fund”), the Energy Transition Funds invest in the Standard Investment Research Energy Transition Master Fund, L.P, a Cayman Islands exempted limited partnership (the “Energy Transition Master Fund” and together with the Hedged Equity Master Fund, the Energy Opportunities Master Fund the “Master Funds”). The operating and trading activities of the Funds are conducted, and the portfolios of the Funds are held, by the Master Funds. SIR also provides advice on a discretionary basis to the Master Funds. References in this Brochure to the Hedged Equity Funds, the Energy Opportunities Funds, the Energy Transition Funds, and the Funds should be construed to refer to the Hedged Equity Master Fund, the Energy Opportunities Master Fund, the Energy Transition Funds, and the Master Funds, respectively, unless otherwise specified or the context so requires. SIR does not participate in wrap fee programs. SIR manages the Funds’ assets on a discretionary basis. As of December 31, 2025, the regulatory assets under management of SIR were $2,126,184,181.

Please see Item 7 (Types of Clients), Item 8 (Methods of Analysis, Investment Strategies and Risk of Loss) and Item 10 (Other Financial Industry Activities and Affiliations).

The fees, performance-based compensation and expenses applicable to each Fund are set forth in detail in each Fund’s governing and offering documents. Summaries of such fees, performancebased compensation and expenses are set forth below. Please refer to the documents for each Fund for a complete description of the fees, performance-based compensation and expenses an investor in a Fund may bear. Management Fees The Funds pay SIR a fixed management fee (the “Management Fee”), calculated and payable quarterly in advance, in the sum of (i) 0.50% (2.0% annualized) of the beginning net asset value (“Net Asset Value”) of each series of shares or the beginning balance of each capital account balance, as applicable (as described in the fund documents) with respect to the Hedged Equity Funds and (ii) 0.375% (1.5% annualized) of the beginning Net Asset Value of each series of shares or the beginning balance of each capital account balance, as applicable (as described in the fund documents ) with respect to new investors in the Energy Opportunities Funds. The Energy Transition Funds generally charge investors a management fee of 0.375% (1.5% annualized) of net assets at the beginning of each calendar quarter. The Management Fee will be prorated or refunded, as applicable, for additions to, and withdrawals or redemptions from, a Fund during a quarter. The separately managed account is charged a monthly management fee based on a percentage of the account’s net asset value. SIR may, in its sole discretion, reduce, waive or calculate differently the Management Fee with respect to investors that are members, partners or employees of SIR, or any of its affiliates, members, officers or employees (collectively, “Affiliates”), or members of their immediate families, or entities formed for the benefit of the principals, such employees or members of their immediate families (collectively, “Related Persons”) of such persons. Performance-Based Compensation Generally, as of each December 31, SIR receives an annual performance-based incentive allocation (the “Incentive Allocation”), or in the case of the Hedged Equity Offshore Fund, an annual performance-based incentive fee (the “Incentive Fee”) as described further below. Hedged Equity Funds Generally, at the end of each fiscal year of the Hedged Equity Onshore Fund, 20% of the excess of the net capital appreciation allocated to an investor’s capital account (as described in the fund documents) for such fiscal year over the Management Fee debited to such investor’s capital account for such year will be reallocated to SIR, subject to a loss recovery mechanism. An Incentive Allocation will also be determined with respect to all or a portion of the net capital appreciation allocated to an investor’s capital account for a partial fiscal year in the event of a withdrawal from the Hedged Equity Onshore Fund other than as of the end of a fiscal year.

The Hedged Equity Onshore Fund will maintain a memorandum loss recovery account for each capital account of an investor (a “Loss Recovery Account”), the opening balance of which will be zero. At the end of each fiscal year, the balance in the Loss Recovery Account attributable to such capital account will be adjusted as follows: (i) if, in the aggregate, there is net capital depreciation with respect to such capital account since the immediately preceding date as of which a calculation of an Incentive Allocation was made, there will be added to such Loss Recovery Account an amount equal to such net capital depreciation; and (ii) if, in the aggregate, there is net capital appreciation with respect to such capital account since the immediately preceding date as of which a calculation of any Incentive Allocation was made, an amount equal to such net capital appreciation will be subtracted from and reduce any unrecovered balance in such Loss Recovery Account, but not below zero. For the avoidance of doubt, such net capital appreciation or net capital depreciation is determined after payment of any Management Fee for the applicable period. In addition, the unrecovered balance in a Limited Partner's Loss Recovery Account will be adjusted for withdrawals of capital. Additional capital contributions will not affect a Limited Partner's Loss Recovery Account. Generally, at the end of each fiscal year of the Hedged Equity Offshore Fund, an Incentive Fee will be determined with respect to each series of its shares. Additionally, an Incentive Fee will be determined with respect to shares redeemed at other times of the year. The Incentive Fee is equal to 20% of the increase in the net asset value of a series of shares (as described in the fund documents) (the “Adjusted NAV”) above the Prior High NAV of such series. The “Prior High NAV” of a series of shares is the net asset value of that series immediately after the determination of an Incentive Fee with respect to such series (or if no Incentive Fee has yet been determined with respect to such series, the Net Asset Value of the series immediately following its initial offering). The Prior High NAV of a series will be appropriately adjusted for issuances and redemptions (on a dollar-for-dollar basis for (i) issuances and (ii) redemptions made at such time as the Adjusted NAV is the same as, or greater than, the Prior High NAV; on a pro rata basis for redemptions made at such time as the Adjusted NAV is less than the Prior High NAV). With respect to the Hedged Equity Funds, the Incentive Allocation or the Incentive Fee, as applicable, is paid at the feeder fund level. Energy Opportunities Funds Generally, at the end of each fiscal year of the Energy Opportunities Master Fund, an amount equal to 20% of the excess of the net capital appreciation (other than net capital appreciation in Special Investments (as defined below)) allocated to the capital account of an investor in the Energy Opportunities Onshore Fund will be reallocated to SIR through its class M shares at the Energy Opportunities Master Fund, subject to a loss recovery mechanism. For the avoidance of doubt, such net capital appreciation or net capital depreciation is determined after payment of any Management Fee and prior to the deduction of any investor-related taxes for the applicable period. An Incentive Allocation will also be determined with respect to all or a portion of the net capital appreciation (other than net capital appreciation in Special Investments) allocated to a capital account of an investor for a partial fiscal year in the event in the event of a withdrawal from the Energy Opportunities Onshore Fund other than as of the end of a fiscal year.

The Energy Opportunities Onshore Fund will maintain a Loss Recovery Account, the opening balance of which will be zero. At the end of each fiscal year, the balance in the Loss Recovery Account attributable to each capital account of an investor will be adjusted as follows: (i) if, in the aggregate, there is net capital depreciation with respect to such capital account since the immediately preceding date as of which a calculation of an Incentive Allocation was made, there will be added to such capital account’s Loss Recovery Account an amount equal to (A) such net capital depreciation or (B) if an investor has fully withdrawn from the Energy Opportunities Onshore Fund except with respect to its interest in Special Investment Accounts, an amount equal to the net capital depreciation as of, and subsequent to, such withdrawal; and (ii) if, in the aggregate, there is net capital appreciation with respect to such capital account since the immediately preceding date as of which a calculation of any Incentive Allocation was made, an amount equal to such net capital appreciation (before any Incentive allocation) will be subtracted from and reduce any unrecovered balance in such capital account's Loss Recovery Account, but not below zero. Generally, at the end of each fiscal year of the Energy Opportunities Master Fund, an amount equal to 20% of the increase in the net asset value of each series of shares of the Energy Opportunities Offshore Fund during the year (adjusted for any issuance or redemption of shares in such series made during such year and prior to the deduction of any investor-related taxes) in excess of the Prior High NAV of such series will be reallocated to SIR through its class M shares at the Energy Opportunities Master Fund. Additionally, an Incentive Allocation will be determined with respect to shares redeemed at other times of the year. With respect to the Energy Opportunity Funds, the Incentive Allocation is made at the master fund level. To the extent that the Energy Opportunities Funds make direct investments, rather than through the Energy Opportunities Master Fund, then, at the end of each fiscal year of the Energy Opportunities Funds, 20% of the excess of the net capital appreciation relating to such investments will be reallocated to SIR, subject to a loss recovery mechanism similar to those described above. With respect to the Energy Opportunities Funds, the Incentive Allocation does not take into consideration gains and losses applicable to Special Investments that continue to be designated as Special Investment as of the end of each fiscal year. No Incentive Allocation will be calculated with respect to a Special Investment until a Realization Event (as defined below) occurs with respect to the Special Investment. Energy Transition Funds As noted in the Energy Transition Funds’ governing documents, investors in the Energy Transition Funds pay a performance allocation in an amount equal to twenty percent (20%) of the net increase in the net asset value of the fund. The performance allocation will be paid by debiting each investor’s capital account. The performance allocation is subject to a loss carryover, which is similar to the Loss Recovery Account process described above for the Hedged Equity Funds and Energy Opportunity Funds. SIR may, in its sole discretion, reduce, waive or calculate differently the Incentive Allocation and the Incentive Fee with respect to investors in the Funds that are Affiliates or Related Persons of SIR.

The separately managed account is charged a performance fee equal to twenty percent (20%) of the net increase in the net asset value on an annual basis. Expenses In consideration of the Management Fee, SIR bears the administrative expenses of the Funds and the Master Funds and provides news, quotation and computer equipment and services (in each case except to the extent paid for through the permitted use of “soft dollars” (as described herein) generated by the Funds and/or the Master Funds), office space and utilities, administrative services and secretarial, clerical and other personnel. The Management Fee may exceed the expenses borne by SIR on behalf of the Funds and the Master Funds. The Funds bear their own expenses (including investment-related expenses, to the extent the Funds invest directly) and their pro rata share of the Master Funds’ expenses related to the Master Funds’ operations, such as investment-related expenses (i.e., expenses that SIR reasonably determines to be related to the investment of the Master Funds’ assets, such as brokerage commissions, research expenses, interest on margin accounts and other indebtedness, borrowing charges on securities sold short, custodial fees, bank service fees, withholding and transfer fees, entity-level taxes, clearing and settlement charges, professional fees (including, without limitation, expenses of consultants and experts) relating to investments and other expenses related to the purchase, sale or transmittal of investments), travel expenses related to investments (including, without limitation, attendance at industry conferences), legal, administration, accounting, audit and tax preparation fees and expenses, fees of the Funds’ administrator, corporate licensing fees, third-party proxy service fees, the Management Fee, organizational and offering expenses, premium payments of the directors' and officers' and general partner's insurance/errors and omissions insurance and other similar expenses related to the Funds and any extraordinary expenses as SIR determines in its sole discretion. In the event that investment-related or other similar expenses are allocable to the Master Funds, the Funds and/or any other investment funds and other accounts to which SIR and its Affiliates may provide discretionary investment management services in the future (collectively, the “Other Accounts”), such expenses generally are allocated to the Master Funds, the Funds and/or such Other Accounts pro rata based on their respective interests in, use or receipts of the related investment, service, product and/or benefit. The Funds and any other investment entity that may invest in the Master Funds indirectly bears the portfolio and other expenses of the Master Funds referred to above pro rata based on their respective interests in the Master Funds. Notwithstanding the foregoing, to the extent the Master Funds pay any costs, fees or expenses that are particular to one or more of the Funds or other investment entities, on behalf of such Funds or on such entities, such amounts are attributable solely to such investment entities (including without limitation, the Funds). Expenses of the Funds generally are shared by all investors pro rata in accordance with their capital account balances or the net asset value of their shares, as applicable. With respect to the Energy Opportunities Funds, such funds specially allocate expenses related to Special Investments to investors that participate in Special Investments, such allocation to be in proportion to the extent of such investors’ participation in Special Investments. Please see Items 8 (Methods of Analysis, Investment Strategies and Risk of Loss), 10 (Other Financial Industry Activities and Affiliations) and 12 (Brokerage Practices).

The investment strategies, approaches and techniques discussed below may evolve over time due to, among other factors, market developments and trends, the emergence of new or enhanced investment products, changing industry practice and/or technological innovation. As a result, these investment strategies, approaches and techniques may not reflect the investment strategies, approaches and techniques actually employed by the Funds or SIR. Nevertheless, the investments made on behalf of the Funds will be consistent with the Funds’ investment objectives.

Hedged Equity Funds The Hedged Equity Funds’ investment objective is to achieve superior absolute returns that are not correlated with or dependent upon changes in commodity prices, the S&P 500 Index, energy equity indices or any other equity market index. The Hedged Equity Funds seek lower risk exposure to principal and lower volatility than what is usually associated with equity-like returns. The Hedged Equity Funds have a highly disciplined investment and portfolio construction process. The Hedged Equity Funds rely on fundamental research to exploit relative value opportunities in global energy equities and equities of issuers in related industries. The Hedged Equity Funds generally takes offsetting long and short positions in comparable securities which typically have an economic relationship to each other and where a distortion exists between either the historical price or the fair value of that relationship. A key objective of the portfolio construction process is limiting the risk of significant loss. The key elements of portfolio construction and risk controls are low net exposure, diversification, high liquidity and a well-researched fundamental view. The Hedged Equity Funds primarily employ a bottom-up approach in their investment decisionmaking process, while at the same time taking significant account of investor sentiment, companyspecific events, liquidity, current macroeconomic conditions and political developments in determining the appropriate relative weightings of positions. Generally, the selection of a long or short position is determined primarily by its relative attractiveness to other stocks in the portfolio rather than a view that the stock is likely to go up or down in absolute terms. SIR believes that its strategy will have little correlation to the market and will exhibit significantly less volatility than the equity markets as a whole. Furthermore, periods of increased market volatility may create dislocations in the relative value of individual stocks and, as a result, may create attractive opportunities in these types of strategies. The fundamental research process involves frequent interaction with company managements, sellside analysts, buy-side analysts and industry experts. In addition, proprietary financial models are maintained for most of the portfolio investments and many potential investments. Equity securities in which the Hedged Equity Funds may invest include companies involved in exploration and production, refining and marketing, oil field services, drilling, shipping, coal, chemicals, energy transition, steel, engineering and construction, alternative energy and natural gas processing, transportation and distribution, as well as regulated utilities. The Hedged Equity Funds may invest in master limited partnerships and limited liability companies taxed as partnerships (collectively, “MLPs”), U.S. royalty trusts and income trusts (“royalty trusts”), exchange-traded funds (“ETFs”), listed and over-the-counter derivatives, private placements and other securities. This universe currently includes more than 400 companies SIR considers to have sufficient liquidity to be potential investments for the Hedged Equity Funds. The Hedged Equity Funds’ core investments usually have a 3 to 6 month expected time horizon. However, a portion of the portfolio’s investments will have a time horizon as long as 12 to 18 months or more or as short as several days. The Hedged Equity Funds may also actively trade around positions in their core portfolios, in an effort both to reduce the Hedged Equity Funds’ overall volatility and to generate additional returns over time.

The Hedged Equity Funds will generally maintain a diversified investment portfolio consisting of approximately 50 to 100 long positions and 50 to 100 short positions. The Hedged Equity Funds expect the total number of positions will gradually increase as SIR continues to expand the number of companies it researches. The Hedged Equity Funds may, in the future, diversify beyond energy into related industries and sectors in which SIR believes its investment strategy may be successful. The Hedged Equity Funds invest across a wide variety of market caps. Large and mid-cap positions are expected to comprise the bulk of the Hedged Equity Funds’ portfolio, generally representing 70% to 90% of the Hedged Equity Funds’ gross assets. Smaller capitalization investments (defined as issuers with market capitalization of less than $2 billion) are likely to remain a more modest allocation at approximately 10% to 30% of gross assets. SIR places great importance on overall portfolio liquidity and individual stock liquidity. Generally, SIR expects that it will limit the size of most investments to a maximum of one to two days of average trading volume. However, the Hedged Equity Funds will invest in less liquid positions when the risk/reward opportunity is very compelling. Less liquid positions (i.e., where positions size exceeds two days average trading volume) generally will represent less than 10% of the portfolio and may include, for example, late-stage private equity or direct investments with lock-up arrangements. The Hedged Equity Funds intend to pursue opportunities globally within energy and related industries. The majority of investments are expected to be in North America (60% to 80%), with the remainder invested in foreign investments. The Hedged Equity Funds expect that any emerging market exposure will be limited to less than 5% to 10% of the overall portfolio. As a key part of their risk management philosophy, the Hedged Equity Funds intend to maintain a fairly balanced long/short exposure. Net long exposure within the Hedged Equity Funds is generally expected to be in a range of -10% to +10%, although from time to time the Hedged Equity Funds could be up to 25% net long or short if compelling directional opportunities arise. In addition to balancing overall long/short exposure, the Hedged Equity Funds closely monitor exposures by geography, market capitalization and sub-sectors (e.g., oil field services, integrated oils, exploration and production) and typically limit net exposures by these categories. The Hedged Equity Funds expect to use a moderate amount of financial leverage, which provides flexibility in managing the portfolio. Gross exposure (defined as longs plus shorts divided by fund equity) generally will be in the range of 150 to 300%. The level of gross exposure is determined by the amount and timing of specific relative value opportunities and by the overall level of portfolio volatility. The Hedged Equity Funds generally operate under position sizing guidelines whereby no position is expected to exceed 5% of the Hedged Equity Funds’ gross exposure, although these guidelines may be exceeded from time to time. In practice, it is anticipated that individual positions usually will represent 1 to 4% of gross exposure. Therefore, the Hedged Equity Funds’ top ten long holdings generally will represent less than 50% of the long portfolio and, likewise, their top ten short holdings generally will represent less than 50% of the short portfolio.

Although the Hedged Equity Funds have no current intention to do so, sub-advisers may be retained to manage discrete portions of the Hedged Equity Funds’ investments. Investments with subadvisers will not comprise in the aggregate more than 15% of the Hedged Equity Funds’ net assets (determined at the time of any such investment). Compensation to sub-advisers will be borne by SIR. The Hedged Equity Funds also may invest through special purpose vehicles or other collective investment schemes, including those managed or administered by SIR or any of its Affiliates or by any company or firm managed or controlled by any member, partner, officer or employee of SIR. In seeking to achieve the Hedged Equity Funds’ investment objective, SIR generally has the flexibility to allocate the Hedged Equity Funds’ assets among a wide range of relative-value strategies and instruments as opportunities arise. The Hedged Equity Funds expect to manage their portfolios with low net exposure, although the Hedged Equity Funds may be net long or short at any given time. From time to time, a portion of the Hedged Equity Funds’ assets may be invested in cash equivalents and short-term debt securities. Energy Opportunities Funds The investment objective of the Energy Opportunities Funds is to achieve long term capital appreciation and superior risk adjusted returns by investing in a portfolio of securities of companies in the energy and related industries. The Energy Opportunities Funds seek to achieve their investment objective by implementing a traditional long/short hedge fund strategy. Although the universe of companies and securities that the Energy Opportunities Funds invest in are substantially similar to those securities that the Hedged Equity Funds currently invest in, the overall investment strategy of the Energy Opportunities Funds differ in material aspects from the investment strategy that is employed in the management of the Hedged Equity Funds and that has been employed by the principals with respect to various pooled investment vehicles and other accounts. The Energy Opportunities Funds rely on fundamental research to identify absolute return opportunities in global energy equities and equities of issuers in related industries. The Energy Opportunities Funds generally take long and short positions in companies that SIR believes are valued at a discount or a premium to their intrinsic value. A key objective of the portfolio construction process is to achieve long term capital appreciation while reducing the risk of significant loss. The key elements of portfolio construction and risk controls are high liquidity and a wellresearched fundamental view. Gross and net exposure is also adjusted as market risks and opportunities are identified. The Energy Opportunities Funds may also use options and other derivatives for managing risk. The Energy Opportunities Funds primarily employ a bottom-up approach in their investment decision-making process, while at the same time taking significant account of investor sentiment, company-specific events, liquidity, current macroeconomic conditions and political developments in determining the appropriate relative weightings of positions. Generally, the selection of a long

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SIR currently provides investment advisory services to the Funds but may in the future provide investment advisory services to additional types of clients. The Funds advised by SIR are exempt from registration under the Investment Company Act of 1940, as amended (the “Investment Company Act”), pursuant to Section 3(c)(1) or Section 3(c)(7) thereof. Investors in the Funds are required to represent that they meet the respective suitability requirements under the Securities Act of 1933, as amended, the Investment Advisers Act of 1940, as amended, and the Investment Company Act, as applicable, as well as other suitability requirements. Minimum investment requirements vary for each Fund although the Funds reserve the discretion to accept less, but in no case will the minimum subscription amount be less than the minimum amount specified under Cayman Island law with respect to the offshore Funds. Please see Items 4 (Advisory Business) and 10 (Other Financial Industry Activities and Affiliations).

SIR only manages the Funds, which are subject to the Incentive Allocation and the Incentive Fee described above. SIR may provide investment advisory services to additional clients in the future that may have similar or different fees than the fees and/or allocations of the Funds. The Incentive Allocation and the Incentive Fee paid to SIR may create an incentive for SIR to cause the Funds to make investments that are riskier or more speculative than would be the case if such allocation or fee were not made. In addition, because the Incentive Allocation and the Incentive Fee are calculated on a basis that includes unrealized gains of the Funds’ net assets, such allocation or fee may be greater than if it were based solely on realized gains. Please see Items 5 (Fees and Compensation) and 10 (Other Financial Industry Activities and Affiliations).

There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of SIR’s advisory business or the integrity of its management. Other Financial Industry Activities and Affiliations

Industry Affiliations SIR Capital Management, L.P., a Delaware limited partnership, provides advice on a discretionary basis to the Funds and the Master Funds and its affiliates, SIR Advisors, L.L.C., and SIR ET Advisors, L.L.C. Delaware limited liability companies, act as the general partners for the U.S.based Funds. Potential Conflicts of Interest The Funds are subject to a number of actual and potential conflicts of interest, as described below: SIR currently provides investment advisory services to the Funds. The Funds invest in a similar universe of companies and securities, but employ a materially different investment strategy. The strategies of the Funds differ in many ways. For example, the Energy Opportunities Funds and Energy Transition Funds are significantly more volatile and have a higher level of concentration than the Hedged Equity Funds. The Energy Opportunities Funds and Energy Transition Funds generally will have a much higher net exposure to the energy sector and generally may, therefore, be more highly correlated to energy indices and the broader markets. SIR expects that the Energy Opportunities Funds and Energy Transition Funds will trade less frequently than the Hedged Equity Funds and that the Energy Opportunities Funds and Energy Transition Funds will have a longer time horizon in pursuing their investment objective with limited short-term trading. The Energy Opportunities Funds and Energy Transition Funds generally will be much more focused on the absolute value of securities, including a much higher reliance on the macro outlook for energy markets as opposed to the relative value strategy pursued by the Hedged Equity Funds. Investment opportunities identified by SIR and its Affiliates may be allocated only to certain of the Funds. SIR takes into account the interests of each of the Funds in making investment decisions for the Funds. For example, SIR may decide that the one Fund should not invest in a thinly traded security that is

held by another Fund if SIR determines in its sole discretion that the Fund's investment may adversely impact the liquidity of such security (and, as a result, the liquidity of the Funds). As a result, a Fund may not be afforded the chance to participate in attractive investment opportunities in which another Fund is given the opportunity to participate, or in some cases may be allocated a small part of an investment opportunity when the other Funds are allocated a larger portion. SIR may provide investment advisory services to clients other than the Funds. Therefore, it is possible that the Other Accounts will take positions either similar or opposite to positions taken by the Funds in connection with their investment strategies, and may from time to time compete with the Funds for similar investments. A Fund may co-invest in portfolio investments at substantially the same time as other Funds. There can be no assurance that a Fund would dispose of such a portfolio investment at substantially the same price or time as another Fund due to many factors that may or may not be foreseeable at the time of investment, including, but not limited to, the availability of capital, differing basis in the investment, differing financing terms applicable to different investments and different investment objectives and investment programs of the Funds. The Funds regularly may acquire confidential information and enter into confidentiality and/or “standstill” agreements when assessing investment opportunities. These activities could prevent the Funds from disposing of (or acquiring additional) securities of an issuer, potentially for an extended period. A Fund may hold interests in an issuer that are of a different class or type than the class or type of interest held by other Funds. From time to time, a Fund may acquire securities or other assets of an entity that are senior or junior to, or otherwise have different rights, preferences and privileges than, securities or assets of the same entity that are held by, or acquired for, another Fund. The Funds will not be required to take any action or withhold from taking any action to mitigate losses in such a scenario. The Managing Members and certain employees of SIR may serve as a member of the board of directors, as a member of an investment or advisory committee, or otherwise in an advisory capacity for one or more corporations, foundations or other organizations, some of which may be shareholders or partners, as applicable, of the Funds. Such positions may create a conflict between the services and advice provided to such organizations and the responsibilities owed to the Funds. Although the Managing Members and such employees of SIR will seek to limit any such conflicts and will act in a manner that is in accordance with their fiduciary duties to the Funds and such organizations, there can be no assurance that serving in such positions will have no impact on the person’s ability to perform his responsibilities on behalf of the Funds. SIR’s Affiliates may from time to time make personal investments in securities or instruments in which SIR may invest the Funds’ assets. However, all such trades will require approval by SIR. Generally, such approval will be denied to the extent that the Funds hold such securities in their portfolios at the time of the request. From time to time, various additional potential and actual conflicts of interest may arise from the overall advisory, investment and other activities of SIR and its Affiliates. SIR has established

policies and procedures to monitor and resolve conflicts and will endeavor to resolve conflicts with respect to investment opportunities in a manner it deems equitable to the extent possible under the prevailing facts and circumstances. Certain investments may be appropriate investments for the Funds as well as appropriate investments for Other Accounts. Nonetheless, for various reasons, SIR may give advice and recommend securities to other clients which may differ from advice given to, or securities recommended or bought for, the Funds, even though their investment objectives may be the same or similar to those of the Funds. SIR or its Affiliates may invest on behalf of themselves in securities and other instruments that would be appropriate for, are held by or fall within the investment guidelines of, the Funds. SIR or its Affiliates may give advice or take action for their own accounts that may differ from, conflict with or be adverse to advice given or action taken for the Funds. SIR devotes as much of its time to the activities of the Funds as SIR deems necessary and appropriate. By the terms of the Funds’ organizational documents, SIR is not restricted from forming managed accounts or other investment partnerships or funds, from entering into other investment advisory relationships, or from engaging in other business activities, even though such activities may be in competition with the Funds and/or may involve substantial time and resources of SIR. These activities could be viewed as creating a conflict of interest in that the time and effort of SIR and its Affiliates are not devoted exclusively to the business of the Funds, but will be allocated between the business of the Funds and other business activities of SIR and its Affiliates. If it is determined by SIR that a Fund and/or one or more Other Accounts will participate in the same investment opportunity, SIR may seek to execute orders for all of the participating investment accounts, including the Funds, on an equitable basis, taking into account such factors as SIR in its sole discretion may deem appropriate. Orders may be combined for all such accounts, and if any order is not filled at the same price, they may be allocated on an average price basis. Similarly, if an order on behalf of more than one account cannot be fully executed under prevailing market conditions, investments may be allocated among the different accounts on a basis which SIR considers equitable. Average pricing, however, is not permitted under applicable CFTC regulations and, therefore, it is possible that different accounts will have orders for the same commodity interest transactions filled at different prices. Investments generally will be allocated among clients pro rata based on the net asset value of each respective client; provided, however, that the following factors, among others, may be considered with respect to each respective client in determining that an allocation other than pro rata is appropriate: the investment objectives and guidelines of each client; risk management guidelines; relative historical participation of a client in the proposed investment and related exposure considerations; cash and liquidity needs of each of the clients; ability to borrow and the cost of borrowed funds; regulatory differences among the clients; legal restrictions, including those that arise in foreign jurisdictions; tax status differences among the clients; nature and size of the trade allotment made available to clients; new clients with substantial amount of investable cash; and to avoid odd-lots. The Funds (and the Master Funds) may engage in agency, agency cross and principal transactions with Affiliates of SIR to the extent permitted by applicable securities laws.

The use of a master-feeder structure also may create a conflict of interest in that different tax considerations for the domestic and offshore Funds may cause the Master Funds to structure or dispose of an investment in a manner that is more advantageous to one feeder fund than to another feeder fund. Please see Items 4 (Advisory Business), 8 (Methods of Analysis, Investment Strategies and Risk of Loss), 11 (Code of Ethics, Participation or Interest in Client Transactions and Personal Trading) and 12 (Brokerage Practices).

SIR has adopted a code of ethics pursuant to Advisers Act Rule 204A-1. SIR’s code of ethics requires compliance with all applicable laws and regulations governing the provision of investment management services to SIR’s clients. In addition, SIR’s code of ethics highlights the fiduciary duty that SIR owes to its clients, including the affirmative duty to act in the best interests of its clients and to make full and fair disclosure of material facts. SIR expects each supervised person to act with integrity, competence, dignity, and in an ethical manner when dealing with the public, the Funds, investors and prospective investors in the Funds, service providers and fellow supervised persons. SIR also expects supervised persons to adhere to the highest standards with respect to any potential conflict of interest with clients. SIR’s code of ethics has specific provisions relating to identifying potential conflicts of interest. The provisions prohibit a supervised person from directing client transactions for the purpose of obtaining a personal benefit. They also generally prohibit certain personal business dealings with clients or investors without the prior approval of the Chief Compliance Officer or his designee. The code of ethics includes provisions relating to accepting offers of gifts or entertainment from third parties. Access persons are required to conduct all personal securities transactions in full compliance with SIR’s code of ethics, and should not take any action in connection with personal securities transactions that could cause even the appearance of unfairness or impropriety, relative to SIR’s clients. Ambiguous situations should be promptly brought to the attention of the Chief Compliance Officer or his designee, and should be resolved in favor of client interests. Finally, SIR’s code of ethics requires access persons, among other things, to: (i) have all personal securities transactions involving IPO’s, Limited Offerings and securities of issuers within energy or energy related industries pre-approved by the Chief Compliance Officer or his designee and are subject to a day holding period; (ii) report all their personal securities transactions involving reportable securities to the Chief Compliance Officer or his designee periodically in accordance with Rule 204A-1; and (iii) certify their compliance with SIR’s code of ethics on at least an annual basis. All violations of the code of ethics must be promptly reported to the Chief Compliance Officer or his designee, who is primarily responsible for administering and enforcing SIR’s code of ethics.

SIR will provide any client or prospective client with a copy of SIR’s code of ethics upon request by contacting the Chief Compliance Officer at the following address: c/o SIR Capital Management, L.P. Attention: Chief Compliance Officer 640 Eighth Avenue, 34th Floor New York, New York 10036 SIR and its Related Persons do not recommend to clients, or buy or sell for client accounts, securities in which SIR or its Related Persons have a material financial interest. Although the principals, employees and officers may buy and sell securities for their own account or the account of others, they may not buy securities from or sell securities to the Funds or the Master Funds. Please see Items 10 (Other Financial Industry Activities and Affiliations) and 12 (Brokerage Practices).

As part of its fiduciary duty, SIR has an obligation to seek the best execution of securities transactions for the Funds when SIR is in a position to direct brokerage transactions. SIR conducts the following types of reviews to evaluate the qualitative and quantitative factors that influence execution quality: (i) contemporaneous reviews by SIR’s traders; (ii) periodic (which SIR expects generally to be on a weekly basis) broker/dealer score sheets completed by SIR’s analysts and portfolio managers; and (iii) periodic (which SIR expects to be no less frequently than on a semiannual basis) meetings of the Best Execution Committee, which is comprised of SIR’s portfolio managers, traders and the Chief Compliance Officer. The Chief Compliance Officer is responsible for documenting the date of each Best Execution Committee meeting, the participants, and any substantive determinations made by the committee. SIR allocates transactions for the Funds to brokers in consideration of such factors as price, transaction costs, a broker's ability to effect the transactions, its facilities, reliability and financial responsibility, commitment of capital, access to company management, access to deal flow and the provision or payment by the broker of the costs of research and research-related services which are of benefit to SIR and the Funds, as well as other factors that are deemed appropriate to consider under the circumstances. Accordingly, the commission rates (or dealer markups and markdowns arising in connection with riskless principal transactions) charged to the Funds by brokers in the foregoing circumstances may be higher than those charged by other brokers who may not offer such services. The use of commission dollars (or dealer markups and markdowns arising in connection with riskless principal transactions) for research services comes within the safe harbor for the use of soft dollars provided under Section 28(e) of the Securities Exchange Act of 1934, as amended. SIR’s traders are responsible for monitoring the commissions paid to SIR’s soft dollar brokers, while the Best Execution Committee is responsible for overseeing the soft dollar relationships. Finally, the Chief Compliance Officer is responsible for approving soft dollar products and services and monitoring SIR’s overall compliance with this policy.

In some instances, SIR may obtain a product or service that is used, in part, by SIR for Section 28(e) eligible purposes and, in part, for other purposes. In such instances, SIR will make a good faith effort to determine the relative proportion of the product or service used to assist SIR in carrying out its investment decision-making responsibilities and the relative proportion used for administrative or other purposes outside Section 28(e). Such determination will be made based on the actual use of the product or service by SIR personnel. The proportion of the product or service attributable to assisting SIR in carrying out its investment decision-making responsibilities will be paid through brokerage commissions generated by client transactions. The determination of the appropriate allocation of “mixed use” products and services creates a potential conflict of interest between SIR and clients. Research products or services generated using soft dollars by SIR’s advisory clients may be used by SIR to service one or more client accounts, including, but not necessarily limited to, client accounts that may not have paid for the soft dollar benefits. SIR does not seek to allocate soft dollar benefits to client accounts in proportion to the soft dollar credits the clients generate. The Funds may, from time to time, avail themselves of short-term trading opportunities and the turnover rate of the Funds' portfolios in those circumstances may be substantially greater than the turnover rates of other types of investment vehicles. Subject to the considerations described above, the selection of a broker-dealer (including a prime broker) to execute transactions, provide financing and securities on loan, hold cash and short balances and provide other services may be influenced by, among other things, the provision by the broker-dealer of the following: consulting with respect to technology, operations and equipment, commitment of capital, access to company management and access to deal flow. Generally, SIR and the Funds do not separately compensate any broker-dealer for any of these other services. Such services and items may influence SIR's selection of brokers. The prime brokers clear (generally on the basis of payment against delivery) the securities transactions for the Funds which are effected through other brokerage firms. The Funds may select additional or different brokers in the future to act as prime brokers for the Funds, and such prime brokers are selected from the leading prime brokerage service providers in the marketplace. Investor Introductions from Prime Brokers - The broker dealers that have entered into prime brokerage arrangements with the Adviser may occasionally provide the Adviser with introductions to potential investors. Capital introduction is a service provided by primer brokers and is designed to introduce hedge fund managers to potential investors, typically through individual meetings or in a conference format. Although capital introduction is customarily offered as a “free” service, various conflicts of interest are presented by such arrangements. While the Adviser does not compensate these broker-dealers based on capital introductions, the Company may be incentivized to use the services of a specific prime broker due to the broker’s ability to raise capital for the Adviser. In addition, the Adviser benefits from arrangements where investors are referred to the Adviser because its management fees are generally based upon a percentage of assets managed and its incentive or performance-based fees are generally based upon a percentage of net profits on such assets. Thus, the more assets the Adviser has under management, the higher its management fee income and, potentially, its incentive fee income. Also, there is a direct conflict between the prime brokers’ desire to increase their revenues by raising capital through their prime

brokerage services. The prime broker and/or its affiliates generally receive fees/commissions as a result of the Adviser’s decision to utilize its services as follows: custodian of client accounts managed by the Adviser; securities transactions executed on behalf of the Adviser’s clients; and lending funds and/or securities to the Adviser as part of the Adviser’s investment strategy, i.e. margin/short sale and/or securities lending programs. While the relationship may present the appearance of a conflict of interest, the availability of the foregoing products and services to the Adviser is not contingent upon Adviser committing to the primer brokers any specific amount of business (assets in custody or trading commissions).

SIR may enter into arrangements with placement agents to solicit investors in the Funds, and such arrangements may provide for the compensation of such placement agents at SIR’s expense. A prospective investor solicited by a placement agent will be advised, and asked to acknowledge its understanding, of any such arrangement. SIR may in the future into arrangements to compensate firms or individuals that are independent of and unaffiliated with SIR for referrals that result in a prospective investor becoming an investor in a SIR Private Fund. SIR intends to pay such consideration in compliance with applicable SEC rules and other laws and regulations that may be in effect from time to time. SIR does not compensate any person for client referrals, however, SIR participates in several capital introduction programs pursuant to which broker-dealers with which SIR executes private fund securities transactions introduce prospective investors to SIR.Please see Items 10 (Other Financial Industry Activities and Affiliations) and 12 (Brokerage Practices).

SIR performs periodic reviews of the Funds’ portfolios. These reviews are conducted by various groups within SIR, including: (i) the Managing Members, (ii) traders and research analysts who monitor and review positions and risk, (iii) certain back office personnel who are responsible for valuation, confirmations, settlements, and position reconciliation and allocating profits and losses of the Funds, and (iv) certain risk management personnel. The Funds provide unaudited summary performance information to investors on a periodic basis. Investors in the Funds are sent the Funds’ audited financial statements within the later of (i) 90 days after each fiscal year end or (ii) 10 business days after the completion of each year-end audit of the Funds’ books and records, or as soon as reasonably practicable thereafter.

SIR is deemed to have custody of client funds and securities because it has the authority to obtain client funds or securities, for example, by deducting advisory fees from a Fund or otherwise withdrawing funds from a Fund. SIR is also deemed to have custody as its affiliates, SIR Advisors, L.L.C. and SIR ET Advisors, L.L.C., serve as the general partner of the U.S.-based Funds.

Accordingly, SIR is subject to Rule 206(4)-2 under the Advisers Act (the "Custody Rule"). The Funds’ assets are held in custody by unaffiliated, long-standing broker dealers or banks, all of which are qualified custodians as the term is defined in the Custody Rule. The Funds are subject to an annual audit by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, and the Funds audited financial statements are provided to all investors within 120 days of the end of the Fund’s fiscal year end.

Pursuant to the investment advisory agreements and limited liability operating agreements of the Funds, SIR and its Affiliates have discretionary authority to manage the Funds. These agreements generally include a power of attorney given by the Funds to SIR and its Affiliates. There are no limitations placed on this authority. Please see Item 4 (Advisory Business).

SIR has been delegated the authority and right to vote proxies received by the Funds. SIR has adopted a proxy voting policy that requires SIR to act in the best interests of its clients when exercising proxy voting authority. SIR has established a Proxy Voting Committee that includes the managing partners and the Chief Compliance Officer and has the authority to vote proxies on behalf of the Funds. The Proxy Voting Committee also is responsible for the periodic review of SIR’s policies and procedures with respect to proxy voting and their implementation. SIR has retained an independent proxy service and directed it to apply its proxy voting guidelines in making recommendations with respect to proxy voting. In most cases, SIR expects to follow the recommendation of the independent proxy service. If SIR does not follow the recommendation of the independent proxy service, it will document the reason for not doing so. Further, SIR will not vote proxies for which a client has expressly retained voting authority. If the Proxy Voting Committee identifies a conflict between SIR’s interests and the interests of the Funds with respect to a particular proxy vote, it will vote in accordance with the recommendation of the independent proxy service. Proxies will not be required to be voted if the Funds’ interests are insignificant (less than $1,000) or if the cost of voting would exceed the foreseeable benefit of the vote.

Clients may obtain, free of charge, a copy of SIR’s proxy voting policies and procedures and/or a record of proxy votes cast since the effective date of SIR’s registration with the SEC by contacting the Chief Compliance Officer at the following address: c/o SIR Capital Management, L.P. Attention: Chief Compliance Officer 640 Eighth Avenue, 34th Floor New York, New York 10036

There is no current financial condition that is reasonably likely to impair SIR’s ability to meet its contractual commitments to its clients. SIR has never been the subject of a bankruptcy petition.