SONA ASSET MANAGEMENT (US) LLC

Sona Asset Management (US) LLC is a limited liability company formed in Delaware in 2016, with its principal place of business in New York. The Firm is a wholly owned subsidiary of Sona Asset Management Limited, a UK-based private limited company, which is itself a wholly owned subsidiary of Sona Asset Management Cayman Limited (the “Cayman Manager”), a corporation organized under the laws of the Cayman Islands. John Brian Aylward is the ultimate beneficial owner of the Cayman Manager. The Firm has a sub-advisory relationship with Sona Asset Management (UK) LLP (the “UK LLP”). The Firm, the Cayman Manager, and the UK LLP are herein referred to as “Sona Asset Management”. The Firm provides investment advisory services to a managed account (the “Managed Account”) which is a portfolio in a private investment fund (the “Paloma Fund”), under an Investment Management Agreement (the “Agreement”) between the Cayman Manager, the UK LLP, and Paloma Partners Management Company (“Paloma”). Sona Asset Management conducts trading for the Managed Account in a manner that observes the strategy and risk parameters provided by Paloma and agreed upon with Sona Asset Management from time to time. The Firm also serves as the investment adviser, with discretionary trading authority, to private, pooled investment vehicles, the securities of which are offered through a private placement memorandum to “accredited investors”, as defined in Regulation D under the Securities Act of 1933, as amended, and “qualified purchasers”, as defined in the Investment Company Act of 1940, as amended. The Firm does not tailor advisory services to the individual needs of any particular investor. As of December 2025, the Firm manages the following private, pooled investment vehicles: • Sona Credit Master Fund Limited (the “Credit Master Fund”); • Sona Credit Fund Limited (the “Credit Offshore Fund”); • Sona Credit Fund LP (the “Credit Onshore Fund”); • Sona Credit Opportunities Master Fund Limited (the “Credit Opportunities Master Fund”); • Sona Credit Opportunities Fund Limited (the “Credit Opportunities Offshore Fund”); • Sona Credit Opportunities Fund LP (the “Credit Opportunities Onshore Fund”) • Sona Fios Loan Management II Cayman LP (the “Sona Fios Loan Management II Cayman”); • Sona Fios Loan Management II Delaware LP (the “Sona Fios Loan Management II Delaware”); • Sona SRT Trading SPC (the “Sona SRT Trading”); • Sona SRT I Master Fund S.à r.l. SICAV-RAIF (the “Sona SRT I Master Fund”); • Sona SRT I Co-Invest Feeder Fund LP (the “Sona SRT I Co-Invest Feeder Fund”); • Sona SRT I Co-Invest US Feeder Fund LP (the “Sona SRT I Co-Invest US Feeder Fund”); • Sona SRT I Feeder Fund LP (the “Sona SRT I Feeder Fund LP”); and • Sona SRT I US Feeder Fund LP (the “Sona SRT I US Feeder Fund LP”). In addition, the Firm manages five separately managed account clients (the “SMAs”). The Credit Master Fund, the Credit Offshore Fund, the Credit Onshore Fund, the Credit Opportunities Master Fund, the Credit Opportunities Offshore Fund, the Credit Opportunities Onshore Fund, Sona Fios Loan Management II Cayman, Sona Fios Loan Management II Delaware, Sona SRT Trading, Sona SRT I Master Fund, Sona SRT I Co-Invest Feeder Fund, Sona SRT I Co-Invest US Feeder Fund, Sona SRT I Feeder Fund LP, Sona SRT I US Feeder Fund LP, and the SMAs are herein referred to collectively as the “Sona Funds”, and each individually as a “Sona Fund”. The Credit Onshore Fund’s and the Credit Opportunities Onshore Fund’s “Limited Partners” and the Credit Offshore Fund’s, the Credit Opportunities Offshore Fund’s, and the SMAs’ “Shareholders” are hereafter referred to collectively as the “Investors”. Our investment decisions and advice with respect to the Sona Funds are subject to the investment objectives and guidelines of each of them, as set forth in their -4-

respective “Offering Documents”. The Managed Account, the SMAs, and the Sona Funds are herein collectively referred to as the “Clients”. We do not currently participate in any wrap fee programs. As of December 31, 2025, the Firm had regulatory assets under management of approximately $33.4 billion, managed on a discretionary basis, for the Clients.

The fees and expenses applicable to each Client are set forth in detail in their respective Offering Documents, the Agreement, and other governing documents. The Firm may enter into different fee arrangements on a Client-by-Client basis. It is critical that all Clients and Investors refer to the applicable Client’s governing documents for a complete understanding of how the Firm and its affiliates are compensated for advisory services. The information contained herein is a summary only and is qualified in its entirety by each applicable Client’s governing documents. Paloma Fund Pursuant to the Agreement, Paloma will pay Sona Asset Management a monthly management fee payable in advance. We are also entitled to receive an annual performance fee (subject to a hurdle rate and high-water mark) calculated based on net trading profits (after the deduction of losses carried forward from the previous year, if any) as of the end of each calendar year. The performance fee is calculated by the Paloma Fund’s administrator and approved by the Paloma Fund general partner – we neither calculate the performance fee, nor authorize its payment. Other fees and expenses borne by the Managed Account include a pro rata share of the Paloma Fund’s administration fees and expenses as well as any transaction or investment fees or expenses related to the Managed Account’s activities. Sona Funds The Firm is paid an investment management fee (the “Management Fee”) ranging from 1.5% - 2.0% per annum of the net asset value of the applicable Sona Funds. The Management Fee is charged on a monthly basis and paid in arrears based on the applicable Sona Fund’s net asset value on the Valuation Day (as defined in the Offering Documents). Generally, the Management Fee is not negotiable. However, Sona Asset Management in its sole discretion, may waive, rebate or reduce the Management Fee at any time, without notice to or consent from any Sona Fund (or underlying investor in such Sona Fund). In addition to the Management Fee and Performance Allocation (see below) and as set forth in more detail in the applicable Offering Documents, each Sona Fund will generally pay all costs and expenses related to its investments and its operations. See the Offering Documents for details of all applicable fees and expenses. Expenses will generally be shared by all of the investors in the Sona Funds, while expenses related to one or more particular series or classes of investments will be allocated accordingly. For each Sona Fund that invests all or a substantial portion of its assets through a “master fund,” each such “feeder fund” will also be responsible for its pro rata portion of such master fund’s costs and expenses. Expenses of more than one Sona Fund will be shared on an equitable basis among such Sona Funds in accordance with Sona Asset Management’s expense allocation policy. The Sona Funds will reimburse the Firm for any expenses it pays on behalf of the Sona Funds. In addition, certain common expenses of Sona Asset Management and the Sona Funds may initially be billed to the Firm but will ultimately be allocated among the Firm and the Sona -5-

Funds in accordance with Sona Asset Management’s expense allocation policy regarding common expenses. Notwithstanding the foregoing, Sona Asset Management may elect to bear some or all of the above expenses of the Sona Funds. The Firm and its employees do not accept compensation, including sales charges or service fees, from any person for the sale of securities or other investment products.

The investment objective of the Clients is to generate positive net returns in all markets, while preserving capital, primarily by investing within Europe, through active investment and trading across the full breadth of the credit quality spectrum. The Clients may trade in other markets around the globe, should attractive opportunities be identified. Each trade in the Clients’ portfolios will be driven by varying degrees of fundamental credit, technical and relative value analyses. The degree to which each factor is weighted is fluid and depends on numerous quantitative and qualitative factors. The Clients have maximum flexibility to invest in a wide range of instruments including, but not limited to, debt securities and obligations (which may be below investment grade and rated or unrated), listed and unlisted equities, currencies/foreign exchange, commodities, interest rate products, futures, options, warrants, swaps, contracts for differences and other derivative instruments. Derivative instruments may be exchange-traded or over-the-counter. The Clients may engage in short sales. The Clients may also hold cash and cash equivalents (including money market funds) or other securities deemed appropriate by Sona Asset Management pending reinvestment, for use as collateral, or if considered appropriate in order to support the Client’s investment objectives. While the current intention of Sona Asset Management is to achieve the investment objective of the Clients by investing primarily in the instruments referred to above and in accordance with the portfolio composition guidelines referred to above, in exceptional market conditions or where Sona Asset Management is of the opinion that there are insufficient investment opportunities in such markets and instruments, they may retain a significant portion of the Clients’ portfolio in cash and/or in liquid assets including cash equivalents, money market instruments or U.S. Treasury or other government securities of any maturity. Risk Factors An investment in the Sona Fund and/or the Paloma Fund involves a high degree of risk, including the risk that the entire amount invested may be lost. Investors and potential investors should pay attention to the section entitled “Risk Factors” in the Offering Documents for further information about the risk associated with the investment program. Any capitalized terms not otherwise defined in this Brochure have the meanings ascribed to them in the Offering Documents. Sona Asset Management is responsible for the overall risk management of the Sona Funds. As a result of the Risk Factors, as well as other risks inherent in any investment, an investment in the Clients is not appropriate for all investors. There can be no assurance that the Clients will meet their investment objective or that investors will receive a return on their capital. The General Partner of the Onshore Funds and the Directors of the Master Funds and Offshore Funds do not actively manage for each risk described below but rather focus the risk management of the Sona Fund on those risks they deem most relevant to the Sona Fund, as applicable at any given time and from time to time. In addition, over time the risks may evolve or change, with new risks appearing and some risks ceasing to be applicable. The probability of a certain risk having an effect on the Sona Fund may also vary over time. -7-

Primary Risks: Alternative investment strategies are speculative and involve a high degree of risk, including, without limitation, risks associated with limited diversification, leverage, interest rates, currencies, volatility, tracking risks in hedged positions, security borrowing risks in short sales, credit deterioration or default risks, operational risks, counterparty risk and other risks inherent in the Clients’ investment activities and financial instruments traded. The use of leverage can magnify the impact of adverse market moves to which the Clients may be subject. Investments may be materially affected by conditions in the financial markets and overall economic conditions occurring globally or in particular countries or markets in which the Clients invest. There may be risks that are not monitored or controlled by us and risks that may be greater than forecasted, especially in unusual market conditions. Information used to manage risks may not be accurate, complete or current, or misinterpreted by us. Primary Risks include, but are not limited to, the possibilities below. Investment Risk: Inherent in any alternative investment strategy is the risk of total loss of capital. We cannot predict, measure or hedge all market, or other risks inherent in our investment strategies. We may choose or determine that it is economically appropriate not, to hedge certain risks. The profitability of our investment strategies depends to a great extent on our ability to correctly assess the future course of price movements of securities and other investments. There can be no assurance that we will be able to accurately predict price movements. The performance of any investment is subject to numerous factors which we cannot predict or control. These factors include a wide range of economic, political, competitive and other conditions that may affect investments in general or in specific industries or companies. Market volatility may cause performance to fluctuate substantially over time. We may not accurately predict what the exit strategy will ultimately be for any given position. Exit strategies which appear to be viable when an investment is initiated ultimately may be precluded due to economic, legal, political or other factors. Competition: The success of the Sona Fund’s investment activities depends on the Firm’s ability to identify investment opportunities as well as to assess the importance of news and events that may affect the financial markets. Identification and exploitation of the investment strategies to be pursued by the Sona Fund involves a high degree of uncertainty. No assurance can be given that the Adviser will be able to locate suitable investment opportunities in which to deploy all of the Sona Fund’s assets or to exploit discrepancies in the securities and derivatives markets. Execution, Market and Liquidity Risk: We may trade in markets that are volatile and which may become illiquid. Closing positions may be difficult if there is a significant decrease in trading volume or increase in price volatility. Orders may not be executed timely or efficiently in periods of market distress due to various circumstances including liquidity and market restrictions. At times, the fixed income markets have experienced significant falloffs in liquidity. While such events may sometimes be attributable to changes in interest rates or other factors, the cause is not always apparent. During periods of market illiquidity, we may not be able to close out positions or may only be able to do so at unfavourable prices. This liquidity risk could adversely impact the performance of the Clients and may be difficult or impossible to hedge against. We may also invest in financial instruments that are not publicly traded and may not be able to readily dispose of such instruments and, in some cases, may be contractually prohibited from disposing of such securities for a specified period of time. The prices of securities can be highly volatile. Price movements are influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events. Although market volatility can create trading opportunities, too much volatility may create additional risks that may impact our ability to put on and maintain effective hedges. It can cause the correlation between long positions and hedges to diverge, with the hedge having the opposite effect of that intended. Special Situations, Event-Driven Investing and Merger Arbitrage: Event-driven strategies often involve the purchase of a company’s securities after the announcement or disclosure of a significant event, including -8-

but not limited to a spin-off, auction of the company or subsidiary, merger, bankruptcy, recapitalizations, litigation or other liability impairments, turnarounds, management changes, consolidations, tender offer and other catalyst-oriented situations. Merger or “risk” arbitrage strategies seek to exploit merger activity to capture or sell short the spread between current market values of securities and their values after successful completion of a merger, restructuring or similar corporate transaction. Merger arbitrage investments typically incur significant losses when the anticipated merger or acquisition transactions are not consummated. Merger arbitrage and event driven strategies also depend on the overall volume of merger activity, which historically has been cyclical in nature. The success of these strategies is dependent on our ability to make predictions about the likelihood that an event will occur and the impact such event will have on the value of a company’s securities. If the event fails to occur or it does not have the effect foreseen, losses can result. The consummation of mergers and tender and exchange offers can be prevented or delayed by a variety of factors, including, but not limited to: (i) opposition of the management or stockholders of the target company, which will often result in litigation to enjoin the proposed transaction; (ii) intervention of a federal or state regulatory agency; (iii) efforts by the target company to pursue a “defensive” strategy, including a merger with, or a friendly tender offer by, a company other than the offeror; (iv) in the case of a merger, failure to obtain the necessary stockholder approvals; (v) market conditions resulting in material changes in securities prices; (vi) compliance with any applicable federal or state securities laws; and (vii) inability to obtain adequate financing. Because of the inherently speculative nature of event driven investing, performance results can be expected to fluctuate from period to period. Securities of Non-U.S. Companies: Investments in securities of non-U.S. issuers have a range of risks which may include expropriation, confiscatory taxation, imposition of withholding or other taxes on dividends, interest, capital gains or other income, political or social instability, illiquidity, price volatility and market manipulation. In addition, less information may be available regarding securities of non-U.S. issuers, and non-U.S. issuers may not be subject to accounting, auditing and financial reporting standards and requirements comparable to, or as uniform as, those of U.S. issuers. There may also be less government supervision and regulation of exchanges, brokers and issuers than there is in the U.S., and we may have greater difficulty taking appropriate legal action in non-U.S. courts. Non-U.S. markets also have different clearance and settlement procedures which in some markets have at times failed to keep pace with the volume of transactions, creating substantial delays and settlement failures that could adversely affect the Clients’ performance. Transaction costs of investing in non-U.S. securities markets may be higher than in the U.S., and securities denominated or whose prices are quoted in non-U.S. currencies also pose currency exchange risks (including blockage, devaluation and non-exchangeability). Stock markets in certain countries or sectors may have a relatively low volume of trading. Securities of companies in such markets may also be less liquid and more volatile than securities of comparable companies elsewhere. There may be low levels of government regulation of stock exchanges, brokers, and listed companies in certain countries. In addition, settlements of trades in some markets are slow and subject to failure. Accounting for Uncertainty in Income Taxes: Accounting Standards Codification 740 (“ASC 740”), “Income Taxes” (in part formerly known as “FIN 48”), provides guidance on the recognition of uncertain tax positions. ASC 740 prescribes the minimum recognition threshold that a tax position is required to meet before being recognised in an entity’s financial statements. It also provides guidance on recognition, measurement, classification and interest and penalties with respect to tax positions. The financial statements of the Sona Funds will be prepared in accordance with U.S. GAAP and prospective investors should be aware that, among other things, ASC 740 could have a material adverse effect on the periodic calculations of the Net Asset Value of the Clients, including reducing the Net Asset Value of the Client to reflect reserves for income taxes that may be payable in respect of current and/or prior periods by the Clients. This could cause benefits or detriments to certain Investors, depending upon the timing of their entry into and exit from the Sona Funds. Amortisation of Establishment Costs: The financial statements of the Fund will be prepared in accordance -9-

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The Firm provides investment advisory services to the Managed Account, which is a portfolio in the Paloma Fund, under the Agreement between the Cayman Manager, the Firm, and Paloma. The Firm also provides investment advisory services to the Sona Funds (as described in Item 4 above), and -6-

the Sona Funds are generally open to, among others, institutions, funds of funds, pension plans, foundations, endowments, high net-worth individuals, financially sophisticated individuals, and other sophisticated investors. Generally, the minimum initial investment in the Sona Funds is $1 million. However, Sona Asset Management may, in its sole discretion, accept smaller initial investments from time to time.

Paloma Fund Pursuant to the Agreement, Paloma will pay Sona Asset Management an annual performance fee (the “Performance-Based Fee”) with respect to the Managed Account. Performance-Based Fees can provide an incentive to take excessive risks. However, the Paloma Fund’s general partner (who is not affiliated with Sona Asset Management) is the Paloma Fund’s risk manager and monitors the Managed Account’s trading and investment activity daily. Per the Agreement, the trading discretion granted to Sona Asset Management is subject to the general partner’s general direction concerning matters of risk, and Sona Asset Management therefore cannot act independently with respect to decisions on the amount of investment risk taken in the Managed Account. Performance-Based Fees can also create an incentive to overvalue assets, thereby inflating net trading profits through unrealized appreciation. However, Sona Asset Management has no authority to value the Managed Account’s assets; it is the general partner of the Paloma Fund (which is not affiliated with Sona Asset Management) that is responsible for final determinations regarding the valuation of the Managed Account’s positions. Sona Funds Sona Asset Management is entitled to an annual performance-based allocation of 17.5% of realized and unrealized income and gains of the Sona Funds, subject to a high-water mark limitation, as described in the Offering Documents. Performance-based allocation arrangements may create an incentive for us to recommend investments which may be riskier or more speculative than those which we would recommend under a different arrangement in an effort to maximize a Client’s gross profits and receive greater compensation. The Performance-Based Fee will increase with regard to unrealized appreciation as well as realized gains and, accordingly, the Performance-Based Fee may be paid on unrealized gains which may subsequently never be realized. Furthermore, given that an Investor may hold multiple sub-series of a class of Fund interests having subscribed at different times, there is a risk that an Investor may pay a Performance-Based Fee on one or more of the sub-series, and not on the remaining sub-series, despite the aggregate investment not being above “high-water mark”. In addition, the Performance-Based Fee may create an incentive for the Firm and its affiliates to hold Sona Fund investments for a longer duration than would be the case in the absence of a fee based on the Sona Fund performance. Finally, the Firm and its affiliates may provide valuations of certain investments to the Sona Fund administrator.

Neither the Firm nor any of its management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. In addition, the Firm and its management persons are not affiliated with any broker-dealer. Neither the Firm nor any of its management persons are registered, or have an application pending to register, as a registered futures commission merchant, commodity pool operator or commodity trading advisor. As mentioned in Item 4 above, the Firm has a sub-advisory relationship with the UK LLP. In addition, the Firm’s affiliates act as general partners or sponsors of the Sona Funds. These relationships create certain conflicts of interest some of which are discussed below. Other than these affiliated entities, the Firm has no relationships or arrangements with any related person listed in the instructions to Item 10 that are material to its advisory business or to its Clients. Potential Conflicts of Interest: The Firm and/or its affiliates currently do, and may continue to, engage in activities that are independent from and may, from time to time, conflict with those of the Sona Funds and other Clients. In the future, there might arise instances where the interests of the Firm or its affiliates conflict with the interests of the Clients or Investors. The Firm, its affiliates, and/or their respective principals engage in transactions with and/or provide services to companies and other entities in which the Clients invest or could invest. The Firm, its affiliates, and/or their directors, employees, members, and related parties may, in certain circumstances, provide valuations of certain investments to the administrator. There may be a conflict of interest between their involvement in the valuation process and their entitlement to receive fees from the Clients calculated with regard to the valuation of assets and the net asset value of the Client. Allocation of Trading Opportunities: The Firm and its affiliates are required to act in a manner that they consider fair, reasonable and equitable in allocating investment opportunities to any Client but otherwise have no specific obligations or requirements concerning the allocation of time, effort, or investment opportunities to a particular Client. None of the Firm, its affiliates, or their directors, employees, members, related entities, affiliates or connected persons is obligated to devote any specific amount of time to the affairs of any Client, and none will generally be required to accord exclusivity or priority in respect of a Client in the event of limited investment opportunities. Non-Public Information: From time to time, the Firm and/or its affiliates may come into possession of nonpublic information concerning specific companies, although internal procedures are intended to prevent the receipt of such information in accordance with relevant law and regulation. Under applicable securities laws, this may limit the Firm’s flexibility to buy or sell portfolio securities issued by such companies. A - 23 -

Client’s investment flexibility may be constrained as a consequence of the Firm’s and its affiliates’ inability to use such information for investment purposes. Capital Introduction Services: From time to time, the Firm’s and its affiliates’ personnel may speak at conferences and programs for potential investors interested in investing in hedge funds which are sponsored by a prime broker and custodian or another third party. These conferences and programs may be a means by which the Firm and its affiliates can be introduced to potential Sona Fund Investors. Currently, none of the Firm or its affiliates intend to compensate the relevant prime broker and custodian or any other third party for organizing such “capital introduction” events or for any investments ultimately made by prospective Investors attending such events, although they may do so in the future. While such events and other services may influence the Firm and its affiliates in deciding whether to use such prime broker and custodian or other third parties in connection with brokerage, financing, and other activities of the Sona Funds, Sona Asset Management will not commit to allocate a particular amount of brokerage to such a party in any such situation. The above does not purport to be a complete list of all potential conflicts of interest involving the Clients and Investors. The Firm will seek to ensure that any conflict of interest of which it is aware is resolved fairly. The Firm does not recommend or select other investment advisers for its Clients.

Pursuant to Rule 204A-1 of the Advisers Act, Sona Asset Management has adopted a Code of Ethics (the “Code of Ethics”) and an employee personal trading policy (the “Personal Account Dealing Policy”) that establishes various procedures with respect to investment transactions in accounts in which Sona Asset Management employees or related persons have a beneficial interest or accounts over which an employee has investment discretion. Sona Asset Management has adopted policies and procedures governing personal securities transactions by its employees. Employees may engage in personal securities transactions only in accordance with the Firm’s Code of Ethics and Personal Account Dealing Policy, which include pre-clearance requirements for certain transactions, reporting obligations, holding period requirements, restricted list controls, and other measures designed to identify and mitigate conflicts of interest with Client trading activities. Transactions in Reportable Securities (as defined in the Code of Ethics) are permitted only in accordance with those policies and procedures and, where applicable, with the prior approval of the Firm’s Chief Compliance Officer (the “CCO”) or their designee. Certain securities and transactions are subject to different pre-clearance and reporting requirements under the Firm's Code of Ethics, which sets forth the applicable definitions, requirements, and exceptions. The Code of Ethics and Personal Account Dealing Policy are designed to prevent conflicts of interest and personal trading activities that may disadvantage Clients or violate applicable law. In addition, employees generally may not acquire securities for their own account in an initial public offering without prior approval from the CCO (or their designee). Employees also must obtain pre-approval from the CCO (or their designee) before participating in any private placement or other limited offering. All of Sona Asset Management’s employees must direct their brokers to send duplicate brokerage statements to the Firm’s Compliance department or make similar alternative arrangements. These records are used to monitor compliance with the foregoing policies. Sona Asset Management prohibits the misuse or inappropriate communication of inside information in connection with its securities transactions with respect to the Clients. Sona Asset Management, as well as federal and state securities laws, also prohibit the practice of market manipulation, which comprises conduct intended to deceive or defraud investors by controlling or artificially affecting the price of securities. Sona Asset Management has also adopted communications guidelines designed to assist personnel in - 24 -

understanding their duties and responsibilities regarding the receipt and the communication of financial and other sensitive information. Employees are required to disclose outside business activities to Sona Asset Management’s Compliance department. Certain outside business activities require prior approval by the Firm’s Compliance department in accordance with the Firm’s policies and procedures, including activities that may create actual, potential, or perceived conflicts of interest with the Firm or its Clients. Sona Asset Management has adopted a policy regarding the giving and receiving of business gifts and entertainment. Sona Asset Management has also adopted a policy governing political contributions, the holding of public office and impermissible payments. This policy is designed, among other things, to address the requirements of Rule 206(4)-5 under the Advisers Act. Sona Asset Management’s Code of Ethics, including the Personal Account Dealing Policy, is available to any current or potential Client or Investor upon request. Neither the Firm nor any of its related persons currently recommend to Clients, or buy or sell for Client accounts, investments in which the Firm or any of its related persons have a material financial interest. However, to the extent the Firm or its related persons may recommend investments to Clients in which the Firm or any of its related persons have a material financial interest, the Firm and its related persons will consider and resolve in the best interests of the Clients any conflicts of interest associated with such recommendations. Investors are provided with disclosure related to conflicts of interest in the Offering Documents prior to subscribing for interests in the Sona Funds. Additionally, the Firm enforces a robust Code of Ethics that generally requires, subject to the terms of a Client’s governing documents, the Firm and its employees to place the interests of the Clients over their own or those of a related party. It is critical that Investors review the Offering Documents for a detailed description of potential conflicts of interest related to an investment in the Sona Fund. The information contained herein is a summary only. In connection with sponsoring any Sona Fund, the Firm and certain of its affiliates have an economic interest in such fund, the general partner or sponsor, or both. The Firm may, from time to time, recommend a security in which the Firm, directly or indirectly, has an interest. For instance, Sona Fund assets may be invested in securities of issuers in which one or more other Sona Funds or Clients hold positions. Given the likely frequency of such occurrence, Clients will not be provided with notification of such occurrences. This may represent a conflict of interest for the Firm. The Firm will disclose to Clients this and any other material conflict of interest which might reasonably be expected to impair the Firm’s rendering of unbiased and objective investment advice. The Firm’s policies and procedures prohibit its supervised persons from trading ahead of Client transactions or otherwise engaging in personal trading that would create actual or potential conflicts of interest with Clients. Although supervised persons may, in certain circumstances, have direct or indirect interests in the same securities purchased or sold for Client accounts, the Firm addresses these conflicts through its Code of Ethics and Personal Account Dealing Policy, including pre-clearance requirements where applicable, restricted list controls, reporting obligations, holding period requirements, and prohibitions on trading while in possession of material non-public information. These controls are designed to ensure that Client interests are placed ahead of employee personal trading activities.

Sona Asset Management is authorized to determine the broker or dealer to be used for each securities transaction on behalf of the Clients. In selecting brokers and determining commission rates, Sona Asset Management complies with best price and execution requirements. In seeking best execution, the - 25 -

determining factor is not always the lowest possible per security price or fee but whether, in Sona Asset Management’s view, the transaction represents the best overall execution for Sona Asset Management’s Clients. In placing orders, Sona Asset Management considers such factors as: quality of execution, speed of execution, likelihood of execution and/or settlement, size, complexity and other characteristics of the order, and other execution factors identified in Sona Asset Management’s Best Execution Policy, all in light of Sona Asset Management’s overall responsibilities to each Client. In no instance does Sona Asset Management seek to obtain research or other soft dollar benefits in exchange for directing Clients to the broker or bank producing such materials. Sona Asset Management may, from time to time, receive unsolicited market and industry research made generally available by broker-dealers and agent banks for loan syndications to their counterparties. Sona Asset Management does not recommend, request, or require Clients to direct Sona Asset Management to execute transactions through specified broker-dealers. Best Execution Sona Asset Management addresses the potential conflicts of interest in connection with its brokerage practices through its best execution review process. The Firm’s best execution review process, led by the Firm’s Chief Compliance Officer (or their designee), periodically monitors the effectiveness of the policies and ability to achieve best execution. To the extent the Firm determines that the amount of business directed to a particular broker-dealer is inconsistent with the overall performance of such broker-dealer, the Firm will work towards scaling back the amount of business directed to the broker-dealer unless there is a compelling reason for such allocation, including, but not limited to, the availability of a particular security or their expertise in a particular sector. The Paloma Fund’s general partner reviews, approves and monitors the prime brokers, executing brokerdealers and counterparties used by Sona Asset Management. Executing broker-dealers and counterparties are chosen from those that have been reviewed and approved by the Paloma Fund’s general partner. Aggregation In an effort to minimize costs and obtain best execution for Client transactions in marketable securities, Sona Asset Management may consider it appropriate to aggregate orders for Clients to enable the Firm to obtain a more favorable price or a better commission rate for Clients based upon the volume of particular transaction. This is subject to Sona Asset Management’s obligations to act in a fair and equitable manner in allocating investment and trading opportunities among its Clients, and the Firm will act in the best interests of its Clients, not itself. It reviews the investment strategy and current portfolio of each Client and evaluates a number of factors in order to determine how much of a particular investment is appropriate for each Client. Allocation Sona Asset Management has adopted written policies and procedures in connection with ensuring that investment opportunities are allocated fairly to each Client. In accordance with the Firm’s Allocation Policy, the Firm will allocate a particular investment opportunity to Clients based on its consideration of various factors, including the investment objectives, guidelines and restrictions of the Client and an analysis of the risk and return profile of such investment opportunity (which analysis may include a review of the expected yield, the expected yield to maturity and the convexity or interest rate sensitivity of the investment opportunity). If, after consideration of such factors, the Firm determines an investment opportunity is appropriate for multiple Clients, then such investment opportunity will be allocated among such Clients based on their relative target percentages (the “Target Allocation”), unless the Manager, acting in the best interest of such Clients and after its consideration of a number of factors, determines that such Target Allocation will not result in a fair and equitable allocation of the investment opportunity. Any alternative methodology utilized will be subject to review and approval by the Allocation Committee. Examples of the - 26 -

factors that the Allocation Committee will consider when determining whether any alternative methodology utilized is appropriate include, but are not limited to, the following: the availability of cash of a Client account, the Client account’s liquidity requirements and whether the Client account is already at the target position size for such investment opportunity. Target Allocations are subject to change, with the approval of the Allocation Committee, and this will generally be done at month-end based on upcoming subscriptions and/or redemptions. Principal and Cross Transactions Sona Asset Management and its personnel do not purchase or sell any securities for their own accounts (or other accounts with a significant ownership interest – more than 25% – by Sona Asset Management or its personnel) to or from Clients (principal transactions), except with the prior approval of the Firm’s Compliance department and in compliance with the written notice and consent requirements of Section 206(3) of the Advisers Act. On occasion, subject to applicable Client fund investment guidelines and restrictions, Sona Asset Management may affect “cross” transactions, through unaffiliated broker-dealers in which one Client will purchase an investment held by another Client. If Sona Asset Management decides to engage in a cross transaction, Sona Asset Management will determine that the trade is in the best interests of each Client involved and take steps to ensure that the transaction is consistent with the duty to obtain best execution for each of those Clients. Trade Errors in the Managed Account With respect to the Managed Account, the Paloma Fund (and not Sona Asset Management) will bear the cost of any losses (and reap the benefits of any gains) resulting from trading errors and similar human errors, absent gross negligence or intentional misconduct. Trade errors might include, for example, keystroke errors that occur when entering trades into an electronic trading system or typographical or drafting errors related to derivatives contracts or similar agreements. Trade Errors in Sona Funds Unintended errors in the communication or administration of trading instructions may, from time to time, arise. Except in certain cases, losses (if any) arising from such errors are attributable to the Sona Funds on the basis that profits from such errors (if any) are also attributable to the Sona Funds. The Firm may on occasion experience errors with respect to trades executed for the Sona Funds. Trade errors may result in losses or gains. The Firm will endeavour to detect booking errors and trade errors prior to settlement and correct and/or mitigate them in an expeditious manner. To the extent an error is caused by a counterparty, such as a broker, Sona Asset Management will take commercially reasonable steps to attempt to recover any loss associated with such error from such counterparty, but generally will not undertake litigation on behalf of Clients unless otherwise agreed. The Firm may use gains and losses on these transactions to determine the net impact of a trade error. Calculating the exact amount owed to the Client involves discretion and Sona Asset Management will seek to calculate the amount owed in good faith. Sona Asset Management has adopted a formal Trade Error Policy covering its practices.

We do not receive economic benefits, directly or indirectly, from non-clients for providing investment advice and other advisory services. Neither we nor any of our related persons, directly or indirectly, compensate any person who is not a supervised person for client referrals. If, in the future, the Firm enters into such arrangements, this Brochure will be appropriately amended.

Neither Sona Asset Management nor its management personnel have been involved in or are the subject of any legal or disciplinary events that would be material to a current or prospective Client’s or Investor’s evaluation of Sona Asset Management’s advisory business or the integrity of Sona Asset Management or its management personnel.

The Managed Account’s transactions and positions are reviewed on a daily basis by Sona Asset Management and the Paloma Fund’s general partner. Investors in Sona Funds may receive a monthly or quarterly capital statement and one-page transparency discussing the performance and positioning of the Sona Fund. Typically, Investors in Sona Funds are provided with written quarterly unaudited financial reports and annual audited financial statements. The Sona Funds’ transactions and positions are reviewed on a daily basis by Sona Asset Management and the Sona Funds’ administrator. All Firm investment and operational staff participate in the ongoing monitoring of the Clients’ portfolios, - 27 -

although responsibilities vary by individual. These individuals perform daily reviews of the Clients’ positions regarding performance, risk, volatility, and other statistical analysis. In monitoring the Clients’ positions, they ensure (i) the management of investments and capital actions are consistent and comply with attainment of each Client’s investment objectives, and strategy goals and (ii) each Client’s portfolio is in compliance with legal and regulatory requirements. The directors of the Sona Funds receive the fund newsletter disclosing performance, risk and other performance metrics and performance and operational matters are reviewed regularly via the Sona Funds’ quarterly board meeting.

The Firm does not serve as the qualified custodian of any of the assets owned by Clients and does not maintain physical custody of any securities or cash owned by the Clients (other than certain privately offered securities to the extent permitted by the Advisers Act and related SEC interpretive guidance). We do not have custody (and are prohibited under the Agreement from having custody) over the Managed Account’s assets. We are deemed to have custody of the funds and securities in the Sona Funds because we have the authority to obtain such funds or securities, for example, by deducting advisory fees from the Sona Fund’s account or otherwise withdrawing funds from the Sona Fund’s account. Account statements related to the Sona Funds are sent by qualified custodians to the Firm. We will comply with Rule 206(4)-2 of the Advisers Act (the so-called “custody rule”) by meeting the conditions of the pooled vehicle annual audit approach. Upon completion of the relevant Sona Fund’s annual audit by an independent auditor that is registered with, and subject to inspection by, the Public Company Accounting Oversight Board, we will distribute the Sona Funds’ audited financials to Investors within 120 days of such Sona Fund’s fiscal year end.

The Agreement sets forth certain guidelines and restrictions related to our investment activities with respect to the Managed Account, which may be modified from time-to-time in consultation with the Paloma Fund’s general partner. In addition, the Paloma Fund general partner may impose restrictions on our ability to invest in certain securities or types of securities. We have full discretionary investment authority with respect to the Sona Funds including authority to make decisions with respect to which securities to buy or sell, as well as the amount and price of those securities. This discretionary authority is subject to terms set forth in the governing documents of each Sona Fund. Additionally, our discretionary authority with respect to the Sona Funds is subject to the investment objectives, policies, and restrictions as set forth in their governing documents.

Clients managed by the Firm, in certain instances, are entitled to vote in connection with amendments or waivers to their rights or in connection with other corporate actions. The Firm has adopted and implemented a Proxy Voting Policy and will vote proxies and act on corporate - 28 -

action notifications that it receives, unless a Client has reserved such right. The policy provides that, where the Firm is authorized to vote Client securities, the Firm will seek to vote or exercise rights in the best interest of its Clients, taking into account relevant factors. In voting proxies and corporate actions, the Firm will act in a manner that it believes will (i) maximize the economic benefits to Clients and (ii) promote sound corporate governance by the issuer. Conflicts of interest may arise from time to time in relation to proxy voting requirements. The Firm’s Proxy Voting Policy is designed to ensure that, if a material conflict of interest is identified in connection with a particular proxy vote, the vote is not improperly influenced by the conflict. In these instances, the Firm will determine what is in the best interests of the relevant Client and will seek to take appropriate steps to eliminate any such conflict, in accordance with the Proxy Voting Policy. Paloma has retained the authority to vote proxies on behalf of the Managed Account. Prior to voting, Paloma will consult Sona Asset Management for a voting preference to ensure that votes are cast in a manner consistent with fiduciary duty and in the best interest of the Managed Account. Absent any conflict, Paloma will vote in accordance with this preference or if voting instructions aren’t received by Paloma, a proxy vote will be placed in accordance with company management’s recommendations. Existing Clients and Investors may obtain a copy of our Proxy Voting Policy or voting record by written request to the Firm. Sona Asset Management generally does not provide proxy or corporate action recommendations to Clients who have not granted Sona Asset Management voting authority over their securities.

The Firm does not require or solicit prepayment of fees greater than $1,200 six months in advance. There exists no financial condition of which Sona Asset Management is currently aware that would impair its ability to meet contractual commitments to its Clients. The Firm has not been the subject of a bankruptcy petition at any time during the past ten years.

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