Squadron Capital Management LLC

General Information

Squadron Capital Management LLC, a Delaware limited liability company, was formed in October 2022. Principal Owners

William Blank and Matthew Sesterhenn are the Managing Members of SCM. Investment Advisory Services

SCM currently provides investment advisory services to Squadron Master Fund LP (the “Fund”) and Squadron Offshore Fund (the “Offshore Fund”), collectively (the “Funds”) all of which are private investment vehicles. SCM may provide investment management services to one or more separately managed account clients (“SMAs”) and may serve as investment adviser and/or sub-adviser to various other advisory clients, including SMAs and other private investment funds (each a “Client”, collectively, “Clients”).

The investments of the Funds are managed in accordance with their investment objectives, strategies and guidelines applicable to the Funds and are not tailored to any particular Investor in the Funds (an “Investor”). SCM does not provide individualized investment advice to such Investors with respect to their investment in the Funds; therefore, Investors should consider whether the Funds meet their investment objectives, risk tolerance and financial situation. Please see Item 5 – Fees and Compensation for more information. Wrap Fee Programs

SCM does not participate in wrap fee programs. Type and Value of Assets Currently Managed

As of March 31, 2026, SCM manages approximately $385,685,000 on a discretionary basis and $0 on a non-discretionary basis.

Fees with respect to the Funds

SCM’s compensation is negotiable and varies, but typically, it charges an annual fee of 1.50% of assets under management, depending on investor share class, which amount is payable in quarterly installments at the beginning of each calendar quarter based on the net market value of each client’s account on the date the fee accrues and becomes payable. Squadron Partners LLC also typically is allocated from each limited partner in the Funds an incentive allocation generally equal to 20%, depending on investor share class. SCM complies with Rule 205-3 under the Investment Advisers Act of 1940, to the extent required by applicable law.

A limited partner may generally withdraw all or any portion of the balance in its capital account as of the last day of each calendar quarter. Requests for withdrawal must be in writing at least sixty (60) calendar days prior to the request withdrawal date.

The capital account of an investor admitted to the Funds other than on the first calendar day of a calendar quarter will be subject to a pro rata portion of the management fee charged for such quarter based upon the portion of the quarter for which it is an investor. No portion of the management fee will be refunded if an investor is permitted to withdraw on a date other than the end of a calendar quarter.

Each account is responsible for its own costs and expenses related to investments and operations, including trading costs and expenses (such as brokerage commissions, expenses related to short sales, and clearing and settlement charges), and research related expenses. Each Fund is responsible for its own ongoing legal and regulatory filings, administrative, valuation, auditing and accounting, entity-level taxes, insurance, bookkeeping fees and expenses, and the fees and expenses charged by any fund administrator for its accounting, bookkeeping and other services. SCM bears its own operating, general, administrative and overhead costs and expenses, other than the expenses described above. SCM and its supervised persons do not receive a brokerage commission or any other compensation attributable to the sale of securities or investment products.

Methods of Analysis The objective of the Funds is to achieve capital appreciation through long and short investments in US publicly-traded micro to mid capitalization development-stage and early commercial therapeutic equities.

Investment Strategy The investment strategy will focus on fundamental long and short investments in publicly-traded micro- to mid-cap (<$10B market capitalization) development-stage and early commercial therapeutic companies.

Risk of Loss While Squadron Capital Management LLC seeks to diversify the assets of the Funds consistent with its strategy in an effort to reduce risk of loss, the Funds are subject to risks. Accordingly, there can be no assurance that the Funds will be able to fully meet its investment objectives and goals, or that its investments will not lose money. Below is a description of several of the principal risks that the Funds face. However, each prospective Investor should carefully review the applicable offering and other governing documents before deciding to invest in a Fund.

General Economic Conditions. The success of the Funds’ activities will be affected by general economic and market conditions, such as interest rates, availability of credit, inflation rates, economic uncertainty, changes in law, tax considerations and tax treatment, trade barriers, currency exchange controls and national and international political circumstances (including wars, terrorist acts and security operations). These factors may affect the level and volatility of the prices and liquidity of the Funds and could impair the Funds’ profitability or result in losses. SCM may consider some or all of these factors when making trading decisions. The Funds could incur material losses even if SCM reacts quickly to difficult market conditions, and there can be no assurance that the Funds will not suffer material losses and other adverse effects from broad and rapid changes in market conditions in the future. Even a well-analyzed approach may not protect the Funds from significant losses under certain market conditions.

Business and Regulatory Risks of Alternative Investment Funds. The financial services industry generally, and the activities of alternative investment funds and their managers in particular, have been subject to intense and increasing regulatory scrutiny. Such scrutiny may increase the Funds’ exposure to potential liabilities and to legal, compliance and other related costs. Increased regulatory oversight may also impose additional administrative burdens on the General Partner and/or the Adviser, including, without limitation, responding to examinations, investigations, and document requests, implementing new policies and procedures and complying with recordkeeping and reporting obligations. Such burdens may divert such parties' time, attention and resources from portfolio management activities. The regulatory environment for alternative investment funds is evolving, and changes in the regulation of private funds and their investing activities may adversely

affect the ability of the Funds to pursue its investment program, the value of the investments held by the Funds and the Funds’ ability to obtain leverage. There has been an increase in governmental, as well as self-regulatory, scrutiny of the alternative investment industry in general. It is impossible to predict whether changes in regulations may occur, but any regulations that restrict the Funds’ activities could have a material adverse effect on the Funds’ investments. In addition, such regulatory scrutiny may increase the Funds’ exposure to potential liabilities and to legal, compliance and other related costs.

Catastrophic Risks. The Funds may be subject to the risk of loss arising from direct or indirect exposure to a number of types of catastrophic events, including without limitation (i) public health crises or the threat or fear thereof; or (ii) major events or disruptions, such as hurricanes, earthquakes, tornadoes, fires, flooding and other natural disasters (which may be caused, or enhanced in frequency and severity, by climate change factors); acts of war, military conflicts, social or political unrest or terrorism, including cyberterrorism; or major or prolonged power outages or network interruptions. Such events could exacerbate political, social and economic risks previously mentioned and result in significant breakdowns, delays and other disruptions on a local, regional and global scale, which may have adverse effects on the operating performance of the Funds and its portfolio companies. The extent of the impact of any such catastrophe or other emergency on the Funds’ and its portfolio companies' operational and financial performance will depend on many factors, including the duration and scope of such emergency, the extent of any related travel advisories and restrictions, the impact on overall supply and demand for goods and services, investor liquidity, consumer confidence and levels of economic activity, and the extent of its disruption to important global, regional and local supply chains and economic markets, all of which are highly uncertain and cannot be predicted. In particular, to the extent that any such event occurs and has a material effect on global financial markets or specific markets in which the Funds participates (or has a material effect on any Fund portfolio companies or locations in which such portfolio companies or the Investment Manager operates or on any of their respective personnel), the risks of loss could be substantial and could have a material adverse effect on the Funds or the ability of SCM to fulfill its investment objectives. Market Disruption and Geopolitical Risk. Military conflicts can cause (and have caused) significant disruptions to the global financial system as well as a displacement of millions of people, causing an acute refugee crisis. Conflicts such as these increase the threat of nuclear accidents or attacks, cyberattacks and further regional or global conflicts (including a potential expansion of the conflicts to other countries), among other potentially dire consequences. Armed conflicts, military strikes, retaliatory actions, or political instability in key regions may cause significant market volatility, disruptions to global trade, and commodity price spikes. In addition, the impacts of military conflicts on the supply chain and commodity prices can be profound and may result in substantial inflation in one or more countries (or globally). However, the ultimate impact of the conflicts and their effects on global economic and commercial activity and conditions, and on the operations, financial condition and performance of the Funds, their investments or any particular industry, business, currency or country and the duration and severity of those effects, is impossible to predict. Global geopolitical events may have a significant adverse impact on, and result in significant losses to, the Funds and their investments, which could result in a partial or total loss of investment for investors.

Cybersecurity Breaches and Identity Theft. The information and technology systems of the General Partner, the Adviser, their affiliates, the Funds and their service providers and their portfolio companies may be vulnerable to damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons, other security breaches and/or usage errors by their respective professionals. The techniques used to obtain

unauthorized access to data, disable or degrade service or sabotage systems change frequently and may be difficult to detect for long periods of time. Hardware or software acquired from third parties may contain defects in design or manufacture or other problems that could unexpectedly compromise information security. Although the General Partner, the Adviser and/or their affiliates have implemented, or expect to implement, measures to manage risks relating to these types of events, if these systems are compromised, become inoperable for extended periods of time or cease to function properly, the General Partners the Investment Adviser, their affiliates, one or more of the Funds, their service providers and/or their portfolio companies may have to make a significant investment to fix or replace them. The failure of these systems for any reason could cause significant interruptions in such parties' operations and/or a failure to maintain the security, confidentiality or privacy of sensitive data, including personal information relating to investors (and the beneficial owners of investors). Such a failure could harm the reputation of the General Partner, the Adviser, their affiliates, the Funds and/or their portfolio companies, subject any such entity and their respective affiliates to legal claims and/or otherwise affect their business and financial performance. Specifically, cyberattacks and the failure of such systems may interfere with the processing of investor subscriptions or withdrawals, impact the Funds’ ability to value its assets, cause the release of confidential information and/or subject the Funds to regulatory fines, penalties or financial losses, reimbursement or other compensation costs, and/or additional compliance costs. The Funds also may incur substantial costs for cyber-security risk management to prevent any cyber incidents in the future. The Funds and the investors could be negatively impacted as a result.

Business Continuity and Disaster Recovery. The business operations of the General Partner, the Adviser, their affiliates, the Funds and their portfolio companies may be vulnerable to disruption in the case of catastrophic events such as fires, natural disaster (e.g., tornadoes, floods, hurricanes and earthquakes), terrorist attacks or other circumstances resulting in property damage, network interruption and/or prolonged power outages. Although the General Partner, Adviser and/or their affiliates have implemented, or expect to implement, measures to manage risks relating to these types of events, there can be no assurances that all contingencies can be planned for. These risks of loss can be substantial and could have a material adverse effect on the Funds and the investors’ investments therein.

General Investment and Trading Risks. All securities investments present a risk of loss of capital. Volatile financial markets increase that risk. If the Adviser’s evaluation of an investment opportunity should prove incorrect, the Funds could experience losses as a result of a decline in the market value of securities in which the Fund holds a long position. The risk management techniques that may be used by the Adviser do not provide any assurance that the Funds will not be exposed to a risk of significant investment losses. No guarantee or representation is made that the Funds’ investment programs will be successful, that the Fund will achieve its targeted returns or that there will be any return of capital to investors. In addition, investment results may vary substantially over time.

Equity Securities. The Fund may invest in equity and equity-related securities, including, without limitation, equity investments acquired in connection with restructured debt securities or instruments, or in connection with reorganizations and/or restructurings of debt securities, equity securities or other obligations and assets of undervalued, operationally challenged and/or financially troubled companies or institutions. A risk of investing in the Funds is that equity securities held by the Fund may decline in value. Equity securities fluctuate in value in response to many factors, including the activities and financial condition of individual companies, the business market in which individual companies compete, industry market conditions, interest rates, general economic environments and/or certain geo-political events. In addition, equity securities that the Adviser

believes are undervalued or incorrectly valued may not ultimately be valued by the markets in the manner that the Adviser anticipates.

Biotechnology and Pharmaceutical Sectors. Investing in securities and other instruments of biotechnology and pharmaceutical companies involves substantial risks, including (but not limited to) the following: certain companies in the portfolio of the Fund may have limited operating histories, scarcity of management and marketing personnel with appropriate scientific or medical training may result in slow or impeded growth of a company, the possibility of lawsuits related to patents or products, obsolescence of products, change in government policies, changes in investor sentiments and preferences with regard to biotechnology and pharmaceutical sectors investments (some of which are generally perceived as risky), volatility in the U.S. stock markets that affects the prices of healthcare company securities resulting in substantial volatility in the performance of the Funds and the fact that many companies in the biotechnology and pharmaceutical sectors are subject to extensive government regulation.

Short Sales. The Adviser may engage in short selling on behalf of the Fund. Short selling involves selling securities that are not owned by the Fund. A short position is established when the Fund borrow securities from securities brokers or other institutions and sells them in an open market transaction with an obligation to return the borrowed securities at a later date. Short selling allows the Fund to profit from the decline in the price of the securities by purchasing the securities at a price that is lower than the price at which they were initially sold, in each case, to the extent such decline exceeds the transaction costs and cost of borrowing the securities. In addition, the short sales may act as a hedge against long positions in the same or related securities in the Fund’s portfolio in the event that the price of the securities decline.

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Squadron Capital Management LLC’s Clients (and Investors therein) may include endowments, sovereign wealth funds, public or private pensions, foundations, institutions, and private funds. SCM does not provide investment advice individually to the Investors of the Fund.

Interests in the Funds are offered pursuant to applicable exemptions from registration under the Securities Act and the 1940 Act.

The minimum investment requirement for the Funds is $250,000. However, the General Partner of the Funds, in its sole discretion, may permit investments that are less than the required minimum investment requirement. In addition, legal eligibility requirements must be met to invest in the Funds.

SCM currently manages only accounts that pay performance-based compensation as described in Item 5 – Fees and Compensation. It does not manage accounts that do not pay performance-based compensation. Certain internal personnel and the General Partner ("GP"), including their respective affiliates, may not be charged management fees, administrative fees, or other similar expenses in accordance with the applicable governing documents and internal policies. The Adviser (or an affiliate of the Adviser) is paid performance-based compensation by its private pooled investment vehicle clients. Such performance-based compensation may create an incentive for the Adviser to make investments that are riskier or more speculative than would be the case in the absence of such arrangements. The Adviser's investment personnel are also typically compensated on a basis that includes a performance-based component.

Certain investors in the Fund may have negotiated higher asset-based fees or more favorable performance-based compensation arrangements than other investors. This may create an incentive for the Adviser to favor investors with more favorable arrangements. The Adviser mitigates this conflict by applying a consistent investment strategy across all investor accounts within the Fund, with any fee differences governed solely by the terms of each investor's subscription agreement or side letter.

Squadron Capital Management LLC has relationships that are material to its advisory business or its clients, as further described below.

The General Partner Squadron Partners LLC (the “General Partner”) serves as the General Partner to the Fund. Mr. Blank and Mr. Sesterhenn, the principal owners of SCM, are the principal owners of the General Partner. SCM may also serve as an investment adviser to an SMA client. SCM does not recommend or select other investment advisers for clients. As the sponsor/investment manager of the Fund, SCM receives management fees or allocations from Funds which creates a conflict of interest. All fees will be disclosed to the clients in advance of their investment in a Fund. Please see Item 5 – Fees and Compensation for more information.

SCM’s employees, affiliates or their related persons may also invest directly in the Funds or another fund managed in the future by SCM. In addition, if SCM manages multiple funds, it may have conflicts of interest in allocating time and resources to such other funds. As a result of the foregoing, SCM and its personnel may have conflicts of interest in allocating their time and activity between clients, in allocating investments among funds and other entities, and in effecting transactions between funds and other entities, including ones in which SCM or its personnel may have a greater financial interest. To address these potential conflicts of interests in its material relationships, SCM has adopted policies and procedures, including a Code of Ethics (the “Code”). For a more detailed discussion of the Code and conflicts of interest policies, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.

Trading

Code of Ethics and Personal Trading Squadron Capital Management LLC has adopted a Code of Ethics (the “Code”). SCM’s Code has several goals. First, the Code is designed to assist SCM in complying with applicable laws and regulations governing its investment advisory business. Under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), SCM owes fiduciary duties to its clients. Pursuant to these fiduciary duties, the Code requires SCM’s associated persons to act with honesty, good faith and fair dealing in working with clients. In addition, the Code prohibits associated persons from trading or otherwise acting on insider information.

Next, the Code sets forth guidelines for professional standards for SCM’s associated persons (managers, officers and employees). Under the Code’s professional standards, SCM expects its associated persons to put the interests of its clients first, ahead of personal interests. In this regard, SCM’s associated persons are not to take inappropriate advantage of their positions in relation to SCM’s clients.

Third, the Code sets forth policies and procedures to monitor and review the personal trading activities of associated persons. SCM’s associated persons may not invest in the same securities or

the same sector recommended to the Funds. Any proposed employee transaction involving reportable transactions including making an investment in a private placement, requires preclearance. It is SCM’s policy that if a conflict arises, the instance will be resolved in the favor of the Client to the full extent that is possible given the specific circumstances, and that appropriate measures will be taken to document the issue, add new policies and procedures when relevant, and enforce the matter with all employees of SCM. These policies are designed to discourage and prohibit personal trading that would disadvantage the Funds. The Code also provides for disciplinary action as appropriate for violations.

Recommending, or Buying or Selling for Client Accounts, Securities in which SCM or its Related Persons Have Material Financial Interests

SCM does not act as principal in any transactions. SCM has adopted a personal trading policy and procedures to protect against these material conflicts. No employee of SCM is permitted to transact in any security to the detriment of any Client or Investor. Recommending or Buying or Selling for Client Accounts, Securities at or about the Same Time SCM or its Related Persons Buy or Sell the Same Securities for Their Own Accounts.

SCM and its related persons do not enter into securities transactions with Clients. Employees are encouraged to invest side by side with Clients and in SCM’s strategy by investing in its Funds.

Under the Code, SCM’s associated persons are prohibited from trading in securities on the basis of material, non-public information or communicating material, non-public information about the issuer of any security to any other person.

The General Partner As disclosed above, William Blank and Matthew Sesterhenn, the principal owners of SCM, are also the Managers of Squadron Partners LLC, the General Partner of the Fund. Please see Item 10 – Other Financial Industry Activities and Affiliates for more information on the conflicts of interests presented when SCM recommends an investment in the Funds.

Best Execution and Benefits of Brokerage Selection In selecting the brokerage firm that will execute orders for the Funds, Squadron Capital Management LLC seeks “best execution” for client’s trades, which is a combination of a number of factors, including, without limitation, quality of execution, net price, reliability and financial stability, clearance and settlement, size of the transaction, difficulty of transaction, general reputation, custodial and other services provided by the broker/dealer that are expected to enhance general portfolio management capabilities, block trading coverage of a particular security, research (including economic forecasts, investment strategy advice, fundamental and technical advice on individual securities, valuation advice and market analysis). Therefore, SCM may use brokers who do not charge the lowest available commission in the recognition of research and securities transaction services, or quality of execution. Research services received with transactions may include proprietary or third-party research (or any combination) and may be used in servicing any or all of SCM’s clients. Therefore, research services received may not be used for the account for which the particular transaction was effected.

Section 28(e) of the Securities Exchange Act of 1934, as amended, is a “safe harbor” that permits an investment manager to use commissions or “soft dollars” to obtain research and brokerage services that provide lawful and appropriate assistance in the investment decision‐making process. SCM will limit the use of “soft dollars” to obtain research and brokerage services to services which constitute research and brokerage within the meaning of Section 28(e). Research services within Section 28(e) may include, but are not limited to, research reports (including market research); certain financial newsletters and trade journals; software providing analysis of securities portfolios; corporate governance research and rating services; attendance at certain seminars and conferences; discussions with research analysts; meetings with corporate executives; consultants’ advice on portfolio strategy; data services (including services providing market data, company financial data and economic data); advice from brokers on order execution; and certain proxy services. Brokerage services within Section 28(e) may include, but are not limited to, services related to the execution, clearing and settlement of securities transactions and functions incidental thereto (i.e., connectivity services between an investment manager and a broker‐dealer and other relevant parties such as custodians); trading software operated by a broker‐dealer to route orders; software that provides trade analytics and trading strategies; software used to transmit orders; clearance and settlement in connection with a trade; electronic communication of allocation instructions; routing settlement instructions; post trade matching of trade information; and services required by the Securities and Exchange Commission or a self‐regulatory organization such as comparison services, electronic confirms or trade affirmations.

In some instances, SCM may receive a product or service that may be used only partially for functions within Section 28(e) (e.g., an order management system, trade analytical software or proxy services). In such instances, SCM will make a good faith effort to determine the relative proportion of the product or service used to assist SCM in carrying out its investment decision making responsibilities and the relative proportion used for administrative or other purposes outside Section 28(e). The proportion of the product or service attributable to assisting SCM in carrying out its investment decision‐making responsibilities will be paid through brokerage commissions generated by client transactions and the proportion attributable to administrative or other purposes outside Section 28(e) will be paid for by SCM from its own resources. Research and brokerage services obtained by the use of commissions arising from the client's portfolio transactions may be used by SCM in its other investment activities and thus, a client may not necessarily, in any particular instance, be the direct or indirect beneficiary of the research or brokerage services provided.

Because many of those services could benefit SCM, it may have a conflict of interest in allocating client brokerage business. In other words, SCM could have an incentive to execute client transactions through a broker or dealer that provides valuable services or products and pay transaction commissions charged by that broker or dealer which may be higher than SCM might otherwise be able to negotiate. SCM could also have an incentive to cause clients to engage in more securities transactions than would otherwise be optimal in order to generate soft dollars with which to acquire research products and services.

Although SCM will make a good faith determination that the amount of commissions paid is reasonable in light of the products or services provided by a broker, commission rates are generally negotiable and thus, selecting brokers on the basis of considerations that are not limited to the applicable commission rates may result in higher transaction costs than would otherwise be obtainable. The receipt of such products or services and the determination of the appropriate

allocation in the case of “mixed use” products or services creates a potential conflict of interest between SCM and its clients. SCM does not currently use soft dollars but may use soft dollars in the future.

In selecting brokers and negotiating commission rates, SCM will take into account the financial stability and reputation of brokerage firms, and the research, brokerage or other services provided by such brokers. SCM may place transactions with a broker or dealer that refers potential Investors to the Funds advised by SCM (or an affiliate), if otherwise consistent with seeking best execution; provided SCM is not selecting the broker‐dealer in recognition of the referral of potential Investors.

When appropriate, SCM may, but is not required to, aggregate client orders to achieve more efficient execution or to provide for equitable treatment among accounts. Clients participating in aggregated trades will generally be allocated securities based on the average price achieved for such trades. More specifically, each client that participates in an aggregated order will participate at the average share price for all of SCM’s transactions in that security or other instrument on a given business day and transaction costs will be shared pro rata based on each client's participation in the transaction. No client will be favored over any other client as a result of such aggregation. Brokerage commission rates will not be reduced because of such aggregation. In some instances, average pricing may result in higher or lower execution prices then otherwise obtainable by a single client. SCM believes that its aggregation policy is lawful and consistent with its duty to seek best execution for all its clients. During the last fiscal year, SCM directed Client transactions to particular brokers based on each broker’s reputation, financial strength and stability, efficiency of execution and error resolution, the size of the transactions and the market for the security, and the comprehensiveness and frequency of available research services and products provided by the broker.

SCM’s authority may be subject to conditions imposed by a client, examples of which may include: (i) where the client restricts or prohibits transactions in a certain industry, issuer or security and/or (ii) where the client directs that some or all account transactions be effected through specific brokers or dealers. In the latter case, the client is responsible for negotiating the terms and conditions (including, but not limited to, commission rates) relating to all services to be provided by such brokers. SCM will assume no responsibility for obtaining the best prices or any particular commission rates for transactions with or through any such broker for such client’s account. A client must recognize that it may not obtain rates as low as it might otherwise obtain if SCM had discretion to select brokers or dealers other than those chosen by the client. Any client providing instructions to SCM regarding direction of brokerage transactions must notify SCM in writing if the client desires SCM to cease executing transactions with or through any such broker or dealer. SCM is independently owned and operated and is not affiliated with any broker-dealer.

From time to time, Squadron Capital Management LLC may enter into arrangements with third parties (“Solicitors”) to identify and refer potential clients to SCM and/or to serve as placement agents for the Funds. Consistent with legal requirements under the Advisers Act, SCM enters into written agreements with Solicitors under which, among other things, Solicitors are required to disclose their compensation arrangements to prospective clients before clients enter into an agreement with SCM. To address potential conflicts of interest, SCM generally requires Solicitors to provide details, or SCM provides details, of any referral fees relating to a particular potential client or potential investor to that client or investor at the time of solicitation activities. Any compensation paid to such placement agents that SCM may engage, will not impact the fees paid by investors in the Funds.

Squadron Capital Management LLC has no disciplinary events to report.

Fund Reporting, Oversight, and Monitoring Squadron Capital Management LLC continuously reviews holdings across client accounts. An account-by-account review is conducted quarterly or more frequently as necessary. These reviews will focus on appropriateness of the investments for the Funds’ portfolios and the performance of the Funds. Investors in the Funds generally receive, among other things, a copy of audited financial statements within 120 days after the fiscal year end of the Funds. In addition, Investors in the Funds

will typically receive unaudited investor statements regarding their investment in the Funds on a monthly basis.

Rule 206(4)-2 promulgated under the Advisers Act (the “Custody Rule”) (and certain related rules and regulations under the Advisers Act) imposes certain obligations on registered investment advisers that have custody or possession of any funds or securities in which any client has any beneficial interest. An investment adviser is deemed to have custody or possession of client funds or securities if the adviser directly or indirectly holds client funds or securities or has the authority to obtain possession of them (regardless of whether the exercise of that authority or ability would be lawful).

SCM (through the General Partner) is deemed to have custody of certain assets of the Funds. SCM is required to maintain the funds and securities (except for securities that meet the privately offered securities exemption in the Custody Rule) over which it has custody with a qualified custodian. Qualified custodians include banks, brokers, futures commission merchants and certain foreign financial institutions.

The Custody Rule imposes on advisers with custody of clients’ funds or securities certain requirements concerning reports to such clients (including underlying investors) and surprise examinations relating to such clients’ funds or securities. However, an adviser need not comply with such requirements with respect to pooled investment vehicles subject to audit and delivery if each pooled investment vehicle (i) is audited at least annually by an independent public accountant and (ii) distributes its audited financial statements prepared in accordance with generally accepted accounting principles to their investors, all limited partners, members or other beneficial owners within 120 days (180 days in the applicable case of a fund of fund adviser) of its fiscal year-end. SCM relies upon this audit exception with respect to the Fund.

Squadron Capital Management LLC provides investment advisory services to the Funds pursuant to the Fund Agreements. SCM has discretionary authority to determine the investments to be bought or sold and the amounts to invest for the Funds. Investment advice is provided by SCM directly to the Funds, subject to the direction and control of the General Partner and not individually to the Investors. Any restrictions on investments in certain types of securities are established by the

General Partner of the Funds and are set forth in the documentation received by each Investor prior to investment in the Funds.

As described in Item 4 - Advisory Business, SCM may also provide SMA clients advice on a discretionary basis. For discretionary accounts, SCM is appointed by the SMA Client, giving SCM the authority to carry out various activities in the account, generally including the following: (i) trade execution and (ii) the withdrawal of advisory fees directly from the account. SCM then directs investment of the client’s portfolio using its discretionary authority. The client may limit the terms to the extent consistent with the client’s investment advisory agreement with SCM and the requirements of the client’s custodian.

Squadron Capital Management LLC has the authority to vote proxies on behalf of the Funds. The Adviser has adopted proxy voting policies and procedures designed to further the best interests of the Funds, in accordance with ERISA (as applicable), its fiduciary duties, and Rule 206(4)-6 under the Advisers Act.

In general, our policy is to vote proxy proposals, amendments, consents or resolutions in a manner that serves the best interests of the Funds, as determined in our discretion, and avoid any conflicts of interest in voting proxies. The Adviser may consider multiple factors when determining whether or how to vote a proxy, including the size of the position and whether the Adviser’s vote will make a difference in the vote, the perceived significance of the issues addressed in such proxy vote, and other factors as deemed relevant by the Adviser. SCM may also elect to take no action with respect to a proxy if it is in the best interest of the Funds not to vote a proxy. Investors may not direct or otherwise influence our vote with respect to any particular proxy solicitation.

SCM will review proxy materials to identify potential conflicts of interest. A conflict of interest will be considered material to the extent that such conflict has the potential to influence our decisionmaking in voting a proxy. If a material conflict of interest is identified, SCM may abstain from voting or use other methods to resolve or otherwise mitigate such conflict, which may include disclosing the conflict and obtaining consent from Fund investors before voting; engaging a third party to recommend a vote on the proxy based on our proxy voting guidelines; suggesting to the client that it engage another party to vote the proxy on its behalf; or such other method as is deemed appropriate under the circumstances given the nature of the conflict. SCM will maintain a written record of the method used to resolve or otherwise mitigate any material conflict of interest. The Adviser utilizes the services of third-party proxy voting service, Institutional Shareholder Services Inc. (“ISS”), to furnish proxy voting research and execution services on behalf of the Funds. This includes researching proxy proposals and voting proxies consistent with guidelines approved by the Adviser and consistent with our Proxy Voting Policy. If SCM determines that the ISS recommendation is not in the best interest of the Funds or in cases where ISS does not provide a vote recommendation, the Adviser’s investment team will make an independent determination, consistent with our Proxy Voting Policy, as to whether and how to vote the proxy. SCM periodically reviews the proxy voting policies, procedures and methodologies, conflicts of interest, and competency of ISS. Investors may obtain copies of our Proxy Voting Policy, together with information regarding how SCM have voted past proxies, by contacting us at 214-478-3862 or by sending an email to jgandy@squadroncap.com.

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