Squarepoint Ops LLC

Squarepoint OPS LLC (“OPS”) is a Delaware limited liability company, with its principal place of business in New York, New York, and was formed in April 2014. OPS together with its affiliated entities, including Squarepoint Capital LLP (“UK OpCo”), Squarepoint Operations Private Limited (“Singapore OpCo”), Squarepoint (DIFC) Limited (“Dubai OpCo”) and certain non-advisory affiliates form the “Squarepoint Group” or “Squarepoint”. UK OpCo, Singapore OpCo, and Dubai OpCo are relying advisers to OPS and therefore are parties to this brochure, and all four collectively referred to as “the OpCos”. On December 16, 2014, OPS, along with certain affiliated entities, was acquired from Barclays Bank PLC (“Barclays”) by entities owned by key management personnel who previously had operated a systematic global trading business within Barclays. The Squarepoint Group’s majority owners are Olivier Durantel, Antoine Fillet, Maxime Fortin and Grégoire Schneider. The Squarepoint Group has its main offices in New York, London, Singapore, and Dubai. The Squarepoint Group provides investment advisory services to certain privately offered pooled and nonpooled investment vehicles (the “Funds”) as well as research and advisory services to corporate clients. Non-advisory affiliates, including Squarepoint Services UK Limited, Squarepoint Services International Limited (UK), Squarepoint Operations GP (DIFC) Limited, Squarepoint Services Singapore Pte. Ltd, Squarepoint Services US LLC and Squarepoint Services Jersey Limited (together “SGS”), provide treasury, accounting, legal, tax, risk, compliance, operations, technology, human resources, quantitative research and development, and other corporate consultancy services (collectively “Non-Advisory Services”) across entities within the Squarepoint Group as well as to the Funds and to corporate clients pursuant to one or more written agreements. The Funds, with respect to which the Squarepoint Group provides investment advisory services, are each managed according to the investment objectives and policies set forth in their respective offering materials using models to trade a variety of asset classes and financial instruments globally. Aside from non-pooled investment vehicles, OPS does not tailor the Funds’ investment programs for any particular Fund investor. The investment management agreements of the Funds, the private placement/offering memoranda and other governing documents of the Funds are collectively referred to in this document as “Governing Documents”. The Funds are formed as either standalone structures, master-feeder structures, or similar structures and investment activities are primarily conducted at the master fund or equivalent level. For tax, regulatory or other reasons, Funds can effect their investment activities indirectly by investing through one or more trading vehicles operated by the Squarepoint Group from time to time. Further, certain standalone funds, non-pooled funds and master funds invest in other commingled funds managed by one or more of the OpCos or other approved managers. Please see Item 6 for details covering additional related potential conflict disclosures including cash management practices. OPS is appointed as the investment manager of the Funds and has overall responsibility for the discretionary investment management of the Funds’ portfolio. OPS has appointed UK OpCo, Singapore OpCo, and Dubai OpCo as sub-managers to conduct discretionary investment management functions on behalf of the Funds during European, Asian and Middle Eastern business hours and/or when a strategic opportunity exists. In such circumstances, investment activities of UK OpCo, Singapore OpCo, and Dubai OpCo in relation to the investment management of the Funds are subject to the overall control and responsibility of OPS. OPS monitors and has the right to instruct UK OpCo, Singapore OpCo, and Dubai OpCo in relation to their management of the portfolios of the Funds. OPS also monitors the risk profiles of the Funds’ portfolios against global parameters and has the power to require UK OpCo, Singapore OpCo, and Dubai OpCo to take remedial action if needed.

UK OpCo is authorized and regulated by the Financial Conduct Authority of the United Kingdom. Singapore OpCo is authorized and regulated by the Monetary Authority of Singapore and is also registered with the Kanto Local Finance Bureau in Japan as a “high speed trade operator”. Dubai OpCo is authorized and regulated by the Dubai Financial Services Authority of the Dubai International Financial Centre in the United Arab Emirates. Each of OPS, UK OpCo, Singapore OpCo, and Dubai OpCo performs its functions primarily by placing investment orders with counterparties. The resources of each master fund form a single pool of collateral available to the OpCos for purposes of their trading activities. Rather than making a defined amount of the collateral pool available to each OpCo, each OpCo is subject to the global position and risk limits determined by OPS. OPS does not manage any assets on a non-discretionary basis. As of December 31, 2025, OPS had approximately USD 226,980,317,646 of regulatory assets under management. This figure does not disregard Funds’ investments in other Funds.

Fees and expenses payable to the Squarepoint Group for management and advisory services are set out in the applicable Governing Documents, and investors should refer to these Governing Documents for a full description of relevant fee calculation methodologies and expense mechanisms. These will generally include a Management Fee (as defined below), a performance-based fee and can also include advances or re-imbursements for expenses incurred by the Squarepoint Group. Management Fees For certain Funds, Squarepoint Group receives a management fee based on the gross asset value (being the net asset value before taking into account any estimated accrued performance allocation) of that particular Fund (the “Management Fee”). Management Fees are generally paid quarterly in advance. Performance-Based Compensation Squarepoint Group receives performance-based compensation, which is compensation that is based on a share of income, capital gains or capital appreciation of the assets of a particular fund, over a specified period and can also be subject to a high-water mark as well as other adjustments, some of which are detailed below. Investors should note that performance allocations where OPS is entitled to receive a proportion of the income generated (“Income Performance Allocation” or “IPA”) by certain assets held by a Fund (the “Shared Income Funds”, or “SI Funds”) can create a conflict of interest for the OpCos in managing these SI Funds. The OpCos have the authority to allocate more of the Funds capital to assets that qualify for the shared income performance allocation as opposed to investing in other assets that do not pay this performance allocation. To manage this conflict, IPA’s are subject to sliding scales and reduce as a proportion of the income received, the more income is generated. For certain Funds, the performance-based fees are subject to a floor based on a percentage of the assets under management for those funds. Any compensation received due to the fee floor that is over and above the performance achieved by the manager for a specified period can be recouped from future performance fees. Additionally, performance-based fees are generally paid annually, whereas AUM based fee floors are paid quarterly. As a consequence of this feature, should an investor in the fund redeem or be redeemed during periods when the floor has been in force and prior to any amounts being recouped, any such amounts would not be reimbursed to the investor. As noted further below, when sub-delegation agreements have been entered into with unaffiliated parties, any incentive and management fees agreed with the third-party adviser will be borne by relevant Funds. For all such Funds, the performance-based fees due to OPS will be based on the performance of the thirdparty adviser net of any such agreed incentive and management fees. Squarepoint Group has, and may in the future, waive, reduce, or modify the performance-based compensation for a Fund (or any investor therein, as applicable). Please see Item 6 for additional disclosures with respect to performance-based compensation and associated conflicts. Expenses Passed Through As compensation for services provided in respect of certain Funds (“EPT Funds”), OPS is entitled to receive certain advances and reimbursements of Squarepoint Group operating expenses that have been agreed between those EPT Funds and the Squarepoint Group. Operating expenses that qualify for this treatment are related to the operations of the Squarepoint Group and may or may not be of benefit to the EPT Funds. Payments in respect of these amounts will be made by such Funds to OPS (or another

member of the Squarepoint Group as directed by OPS) and distributed amongst the Squarepoint Group as determined by OPS. In such circumstances, and as described in their Governing Documents, most expenses incurred by OPS shall be borne by the EPT Funds and allocated to some but not all classes of shares issued by each EPT Fund. Share classes that are not allocated such expenses include management shares, and any holders of any such class of share will not indirectly bear these costs (see also Item 7). Determinations of such expense allocations across applicable share classes and Funds are made by OPS acting in its good faith and reasonable discretion. Notwithstanding the foregoing, certain shares restricted to Squarepoint Group staff will at times bear expenses related to other investment products of the Squarepoint Group and on a greater than pro rata basis. This results in certain resources utilized by those Funds that are not EPT Funds (“NonEPT Funds”) being subsidized by the EPT Funds. These expenses can be paid initially by the EPT Funds or the Squarepoint Group. To the extent that such amounts are paid by the Squarepoint Group they will be reimbursed by the EPT Funds as described below. Such reimbursement payment will be made to OPS or such other member(s) of the Squarepoint Group at the direction of OPS. Payments by the EPT Funds in respect of Squarepoint Group expenses are collected up to 6 months in advance. Certain unanticipated or non-ordinary course Squarepoint Group operating expenses and the full amount of Squarepoint Group capital expenditure attributable to the EPT Funds’ investment-related activities will be advanced by EPT Funds on request by OPS in advance of becoming due or as soon as practicable after incurrence. Advances by the EPT Funds of amounts in respect of Squarepoint Group capital expenditure will only be deducted from the assets of the EPT Funds as they are amortized by the Squarepoint Group. As described in the relevant Governing Documents, certain Funds’ operating expenses are subject to a per annum cap. The EPT Funds will also advance to the Squarepoint Group and other service providers from time to time, on an interest-free basis, such amounts as they may require to make deposits (whether in cash, by providing a letter of credit or otherwise) or to provide for office fit outs in connection with real estate used or to be used in their operations. In addition, the EPT Funds will pay to the Squarepoint Group and other Squarepoint Service Providers such amounts as they may require to ensure that they at all times maintain sufficient regulatory capital as required by applicable law and regulation in relation to their businesses. Investors should note that differing fee structures between EPT Funds and Non-EPT Funds have the potential to create a conflict of interest for Squarepoint in managing the Funds. Squarepoint has the right to pass expenses created by the implementation of a strategy through to investors of EPT Funds but is not able to perform such a pass-through if strategies are allocated to Non-EPT Funds. Therefore, Squarepoint is incentivized to allocate higher expense strategies to the EPT Funds over the Non-EPT Funds. For efficiencies and other purposes, Squarepoint has the right to use the assets of one Fund to invest in the shares of a separate Fund. In such circumstances, the management and performance fees associated with the invested Fund might be waived. Incentive and Management Fees Paid to Third Party Advisers OpCos have the right to enter into sub-delegation agreements with unaffiliated parties. Compensation to these third-party advisers can include both incentive and management fees. The incentive fee for managing each separately managed account is a percentage of the net profits for each fiscal year less any management fees or other expenses occurring during the period; provided, however, that for the purposes of calculating incentive fees, net profits for any fiscal year shall be reduced by any applicable loss carryforward.

In addition to an incentive fee described above, the third-party advisers may be entitled to receive a periodic management fee, payable in advance or arrears (in each case as agreed with each external adviser), calculated at an annual rate (as agreed with each external adviser) of the notional value managed by the third-party adviser. Other Fees and Expenses As laid out in the Governing Documents of the Funds, in addition to paying performance-based compensation to the Squarepoint Group, Funds typically pay all of their own operating and investment expenses including, but not limited to fees and expenses related to the below items. 

Organizational and Offering Costs The organizational and ongoing expenses in connection with the offer, issuance and placement of the investments; explanatory and other memoranda; costs relating to obtaining investor identity information or investor licenses in various countries, as required; costs relating to the preparation, execution and amendment of legal documentation constituting the Funds and legal documentation entered into by the Funds, including with service providers; costs of stationery; fees of the general partner and board of directors of the Funds; costs of meetings of the general partner and meetings of the board of directors of the Funds and travel expenses to such meetings and any other reasonable expenses approved by the general partner or the board of directors of the Funds.

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Trading Expenses Professional fees (including, without limitation, fees and expenses of consultants, finders, financial advisers, investment bankers, attorneys, accountants and other experts) relating to the investments of the Funds and other fees and expenses relating to the acquisition, holding and disposition of investments of the Funds including, without limitation, exchange listing and securities licensing fees, as applicable; third-party research (including Investment Research, corporate access fees, data feeds, alternative data and any computer hardware and connectivity hardware (e.g., telephone and fibre optic lines)); portfolio pricing services; travel related to management of investment activities; expenses relating to the Funds’ borrowings, including, without limitation, borrowings of cash or securities; expenses relating to prime brokerage and other margin facilities to the Funds; custodial and depositary fees and expenses; expenses relating to short sales; clearing and settlement charges; expenses relating to reorganizations and restructurings involving the Funds' investments; extraordinary expenses; expenses relating to operating investment arrangements including, without limitation, subsidiary companies necessary for accessing certain markets or instruments; expenses relating to investor and public relations; expenses of registering or qualifying the investments for sale or purchase; exchange memberships; exchange fees, transaction fees, brokerage fees and commissions or other costs of acquiring or disposing of investments of the Funds, including, without limitation, legal and accounting costs; bank service fees and interest expenses; any other costs related to the purchase, sale, transfer or processing of investments of the Funds.

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Market Data, Other Data and Other Technology Related Expenses Market data and other data costs (whether or not the data is used and whether the data is used for trading, research, or other purpose) including, without limitation, real-time, non-real-time and historical market data licensing fees, fees for third party databases and news services and payments for alpha capture strategies; costs attributable to certain software including, without limitation, database, middleware, mathematical, statistical and analytics software license fees and associated consulting, installation and maintenance fees; costs attributable to hardware, including, without limitation, computers, specialized hardware, connectivity hardware such as network equipment (e.g., telephone and fiber optic lines) and storage space and related consulting, installation and maintenance fees; costs associated with custom development; data center costs including, without limitation, leasing space, power and installation costs; costs of servicing,

maintaining and operating hardware, software and networks including, without limitation, recovery services; depreciation costs associated with production hardware; technology costs associated with connecting to trading venues, trading counterparties, prime brokers of the Funds, and similar service providers. 

Administration Fees

(i) The Funds administrators and their affiliates receive monthly fees from the Funds. The fee is equal to a percentage of the relevant net asset value based on a per annum rate subject to a minimum dollar amount; and (ii) Certain other one-off transaction fees at rates and out-of-pocket expenses specified in the relevant Administration Agreement. 

Accounting, Tax and Related Expenses Auditing, accounting, and tax preparation expenses; any value added taxes; costs relating to preparing Schedule K-1 and passive foreign investment company information statements and other documents necessary to reasonably assist investors in their tax affairs; and fees and out-of-pocket expenses of any service company retained to provide accounting and bookkeeping services to the Funds; taxes and regulatory fees, including, without limitation, taxes linked to hosting hardware in some countries and financial transaction taxes.

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Investment Strategy and Methods of Analysis The principal objective of the Funds is to provide investors with consistent risk-adjusted returns by means of capital appreciation by making investments primarily in financial instruments. Squarepoint Group is permitted to implement various trading approaches on behalf of the Funds reflecting both quantitative and systematic trading methods and/or discretionary trading approaches. When pursuing a systematic trading approach, the Funds employ a multi-asset systematic global strategytrading approach combining a collection of independent strategies, each focusing on a limited number of signals having their own risk parameters. Squarepoint Group’s research team uses statistical and other techniques to forecast movements in the value of financial instruments at various time horizons. In order to develop these proprietary forecasting tools, Squarepoint Group will leverage large historical datasets, either compiled in-house over time, or licensed or purchased from third parties. The underlying data can be of various kinds, including, but not limited to, market data (e.g., prices, volumes), accounting data, regulatory filings, economics releases, alternative data, and media sources. Various forecasts will then be combined with risk management and trading modules to form a trading strategy. Such a strategy will usually be tested against historical data (“back testing”) to optimize its expected future performance which involves striking a balance between expected returns and risk, while taking other considerations such as available liquidity and market impact into account. After the back testing phase, a strategy will be implemented and orders generated on relevant instruments, such as equities, derivatives or foreign exchange. Some strategies will be executed manually by traders. Squarepoint Group investment professionals reserve the right to override model outputs and strategy trading intentions to reflect their perception of prevailing market conditions. Squarepoint Group can also employ certain non-systematic discretionary trading strategies. The individual judgment and discretion of Squarepoint Group’s personnel will be fundamental to the implementation of such strategies. Investment decisions will be based on fundamental and technical analysis conducted by the Squarepoint Group’s personnel. The strategies cover a wide spectrum of holding periods and boundaries are clearly defined. Fund portfolios may utilize a combination of low frequency trading with higher frequency trading. Back-testing environments may be used to focus on issues key to each category of strategy. Many different datasets are used to design, improve and run strategies that are often cross validated using different but overlapping datasets. Risk management processes have been implemented and, Squarepoint Group has the right to intervene and alter risk parameters to respond to changing market conditions from time to time. While there is no limit on the portion of any Fund’s portfolio that will be allocated to systematic or discretionary approaches at any time, ordinarily it is anticipated that the majority of investments will be made on a systematic or semi-systematic basis. The global portfolio of the Funds is spread across three major regions: EMEA, APAC and the Americas, with asset allocation to each region managed by OPS. OPS retains overall responsibility for the management of the global portfolio during US business hours, UK OpCo and Dubai OpCo manage the global portfolio during European and Middle Eastern business hours and Singapore OpCo manages the portfolio during Asian business hours. The global portfolio itself consists of a number of strategies with different turnovers. Funds do not have any fixed guidelines with respect to diversification, to achieve its investment objective, the Funds generally seek to maintain a diversified portfolio of instruments spread across countries, sectors,

and asset classes. Notwithstanding the foregoing, the Funds’ portfolio could become significantly concentrated in any one industry, sector, strategy, or geographic region. The investment policies and strategies (but not the investment objective and overall trading approach) of a Fund can be changed by the board of directors of such Fund in consultation with OPS without the consent of the shareholders. Potential Risks The following considerations should be evaluated carefully by any potential investor before making an investment in the Funds. Such considerations do not purport to be a complete discussion of all the risks and other factors and considerations which relate to or might arise from investing in the Funds or from their investments. Potential investors are advised to consult their own advisors regarding additional potential risks. Risk of Loss All investments involve the risk of loss of a part, or all, of the capital invested. Investing in the Funds involves a high degree of risk. There can be no assurance that the Funds’ investment objective will be achieved or that they will not incur a loss. An investment in any of the Funds is suitable only for sophisticated investors for whom the investment does not represent a complete investment program and who fully understand and are capable of assuming the risks of such investment. Investors should be aware that past performance of the members of the Squarepoint Group is not necessarily indicative of future performance of the Funds. Investment Risks in General Investing in the Funds will involve certain considerations in addition to the risks normally associated with making investments in securities. The net asset value of the Funds, and any income generated, may fluctuate and is not guaranteed. Investors may not recover the amount originally invested upon redemption, sale, or otherwise, and there can be no assurance of any return of capital. Investment performance may vary from month to month, quarter to quarter, and year to year. Any investment in the Funds is at risk of a total loss of invested capital. Squarepoint cannot predict, measure, or hedge all market or other risks linked to the Funds’ investment strategy. Squarepoint may choose, or may determine that it is economically appropriate, to not hedge certain risks, instead relying on diversification in an attempt to mitigate the risks. However, the Funds are not limited by any specific policies or requirements for diversification or risk mitigation. As a result, the Funds may become concentrated in a single issuer, industry, market or sector and the concentration of risk may increase losses suffered by the Funds. Limited diversification may cause greater volatility than would otherwise be the case and could expose the Funds to losses disproportionate to market movements in general. Risks associated with different assets held by the Funds may become correlated in unexpected ways, with the result that the Funds become exposed to unforeseen risks. Delegation of Investment Discretion and Selection of Third-Party Investment Advisors From time to time, OPS may delegate some or all of its role as adviser to its clients to third party advisers. In connection with the selection of potential sub-advisers or advisers, OPS makes recommendations or selections of underlying investment managers for such clients. OPS performs due diligence on third party potential sub-advisers or advisers before selecting them. In selecting external advisers, Squarepoint relies on a variety of both quantitative and qualitative factors, including but not limited to, analysis of the adviser’s investment process and results, such as the length of

their track record, operational controls, compliance policies and procedures, consideration of the assets under management, and interviews with members of the adviser's senior management and investment teams, management style, number and continuity of investment professionals, and client servicing capabilities. There can be no assurance as to adequacy of the factors considered in selecting third-party advisers, and no guarantee against material losses as a result of such delegation. No Formal Investment Restrictions The Funds have not adopted any specific investment restrictions or limitations of any kind and does not currently otherwise voluntarily observe any specific fixed internal investment guidelines or principles, including, without limitation, with respect to diversification, geographic scope, or the credit quality of its investments. The Funds generally seek to maintain a diversified portfolio of investments spread across countries, sectors, and asset classes. No Formal Diversification Policies Although diversification is an important part of OPS portfolio management process, and OPS generally seeks to maintain a diversified portfolio of instruments spread across countries, sectors and asset classes, OPS does not have any formal diversification policy or any fixed limits, guidelines, or requirements for diversifying the investments of the Funds. As a result of the foregoing and the fact that risks associated with different assets may be correlated in unexpected ways, the Funds could become subject to more concentrated issuer, industry, market, sector, or other exposures than expected. Most of OPS portfolio management activities are done on a strategy-by-strategy basis, while each Fund generally employs more than one strategy. Therefore, the overall portfolio of a particular Fund may have more exposure to a particular asset, asset class, market factor, or risk scenario than would be expected had those portfolio management activities occurred at such Fund’s overall portfolio level. If OPS fails to identify and therefore manage any of these risks, the Funds may suffer losses. Bid and Offer Spread of Investments The bid and offer spread of financial instruments, including those in which the Funds invest, usually widens during periods of market decline or reduced liquidity, and this may adversely impact the valuation of investments held by the Funds or the ability of the Funds to dispose of financial instruments at a previously quoted price or at the currently quoted price. Compulsory Redemption The Funds and/or the Feeder Funds have the right to compulsorily redeem the shares of a shareholder in certain circumstances. Such compulsory redemption can create adverse economic or other consequences for the shareholder depending on the timing thereof and the shareholder’s personal circumstances. Suspensions of Redemptions The directors of the Funds have the right to suspend the calculation of the net asset value of the Funds and the net asset value per share of each class in certain circumstances. No issue or redemption of shares at the option of the shareholders will take place during any period when such calculations are suspended and the Funds reserve the right to withhold payments of redemption proceeds to persons whose shares have been redeemed prior to such suspension until after the suspension is lifted. This could materially extend the period required for shareholders to realize their investments in the Funds.

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The Squarepoint Group operates an independent asset management business and provides discretionary investment advisory services to certain privately offered pooled and non-pooled investment vehicles, the Funds, as described in Item 4. Investors in the Funds are generally required to make a minimum initial investment that can range from USD 100,000 to USD 10,000,000 depending on the specific share class. Investors in the Funds are also generally required to be “qualified purchasers” or “knowledgeable employees” and meet other investor qualification criteria required by applicable securities and commodities laws and regulations. The Squarepoint Group also provides Advisory, and Non-Advisory Services to third-parties.

OPS simultaneously manages assets for multiple Funds, and as outlined in Item 5 above, the Funds are charged performance-based fees. The performance-based fees vary from Fund to Fund, and/or share classes, and may incentivize the Squarepoint Group to make riskier investments than would be the case in the absence of such fees. Additionally, as certain Funds have higher performance-based fees or performance allocations than other Funds, in percentage terms or in absolute dollar amounts, and Squarepoint staff have significantly more capital invested in those Funds (the “Higher Fee Funds”) than in other Funds, there is an incentive to favor the Higher Fee Funds over other Funds, including, for example, in the allocation of management time, resources, and investment opportunities. OPS allocates investment opportunities and strategies amongst its Funds according to the target return, risk and trading profile for each Fund and considering multiple factors including but not limited to: existing portfolio composition, liquidity requirements for each Fund, tax considerations, regulatory considerations, informal diversification requirements, anticipated research and development expenditure, turnover, investment horizons and optimization frequency. This generally leads to investment opportunities being allocated to a single Fund, or adaptations being made so that separate instances of a model or signal can be allocated to different Funds, each aligning with that specific Fund’s profile. The Higher Fee Funds have access to shorter-term signals that are not made available to other Funds because the signals are believed to be capacity constrained, and their capacity has been reserved for the Higher Fee Funds. The Higher Fee Funds were designed with these shorter-term signals in mind and have the technical infrastructure and exchange connections required to make optimal use of these shorter-term signals. Because the Higher Fee Funds utilize shorter-term signals than the other Funds, the Higher Fee Funds have generally experienced, and are expected to continue to experience, higher Sharpe ratios and higher gross returns than the other Funds. The Higher Fee Funds have priority with respect to new strategies, methods, signals, and other opportunities (including, without limitation, order working opportunities) going forward. Even when it is ultimately determined to use a new strategy, method, or signal for the benefit of Funds other than the Higher Fee Funds, it is likely to be first used for the benefit of the Higher Fee Funds, as the Higher Fee Funds generally have a higher risk tolerance and so are generally used to test new strategies, methods, and signals. From time to time, OPS will deploy in certain Funds an investment strategy that generates trading signals derived in whole or in part from the trading activity of personnel who trade on behalf of one or more of the Higher Fee Funds or of other Funds in which Squarepoint Group personnel have substantial proprietary capital invested. Conversely, in some circumstances, Higher Fee Funds or other Funds in which Squarepoint Group personnel have substantial proprietary capital invested will utilize signals derived in whole or in part from the trading activity of personnel who trade on behalf of one or more other Fund(s). In either direction, the Fund(s) supplying the trading signal is the Source Fund, and the same conflicts of interest and execution disadvantages described below may apply to the Fund receiving the replicated signals. Under this strategy, the signals used to generate trades in a Fund are not independently developed through the quantitative research process described in Item 8 but are instead derived from the observed trading decisions made by human traders whose primary responsibility is the management of the Source Fund’s capital. Such observed activity is used as an input, in whole or in part, and potentially in

combination with other quantitative or discretionary inputs, to generate trade signals for the replicating Fund. This arrangement gives rise to conflicts of interest. Because the Source Fund will generally execute trades before the generation of signals for the Funds employing the replicating strategy, the Source Fund’s trading activity may adversely affect the execution quality available to those Funds, including through market impact and the depletion of available liquidity. The replication strategy is expected to underperform, and in some circumstances materially underperform, the Source Fund. The performance of a replication strategy is inherently constrained by various factors, including execution latency, capacity limitations, market impact caused by the Source Fund’s own trading, the loss of contextual judgment that informed the original trading decisions, alignment of the interests of traders for the Source Fund with the interests of the Funds employing the replicating strategy, and changes in market conditions between the time of the source trade and the time of the replicated trade. In some cases, the performance differential between the Source Fund and the Funds employing a replication strategy may be material. OPS is under no obligation to discontinue a replication strategy that underperforms the Source Fund or to take corrective measures to reduce any performance differential. OPS will continue to charge performance-based fees and management fees on the capital allocated to a replication strategy, notwithstanding the derivative nature of the signals and the potential for inferior returns relative to the Source Fund. OPS does not expect to disclose to investors the specific proportion of a Fund’s capital allocated to the replication strategy at any given time, and such proportion may vary materially over time. In general, and as noted in Item 12, Squarepoint's various trading programs independently generate orders, which are routinely directed to brokers and counterparties for execution; with respect to trade allocations, these orders are generally executed without regard for other instructions generated for the account of the same or a different Fund of Squarepoint and orders are generally filled independently. Since the Higher Fee Funds generally trade with more urgency than the other Funds (due to their shorter-term forecasting horizon) and since they have access to lower-latency order working strategies, the Higher Fee Funds generally reach the market ahead of the other Funds. This is likely to result in the other Funds having their orders filled at less favorable prices than they would have in the absence of this more-urgent trading by the Higher Fee Funds. In some cases, the impact of one Fund on another Fund may be material. It is likely that working orders independently will cause the Funds to have a greater impact on each other than they would have if their trading were coordinated. If the correlation among Funds increases and/or the amount of capital invested in correlated Funds increases, this impact will increase. Even among highly correlated Funds, OPS will not always purchase (or sell) the same securities at the same time, or in the same proportionate amounts, particularly if the different Funds have materially different amounts of capital or trade timing considerations. From time to time, highly correlated Funds will have opposing views as to whether to buy or sell a particular security at a particular time. As a result, one Fund may experience a loss on a security while a highly correlated Fund experiences a gain on the same security. For these and related reasons, the trading and performance of highly correlated Funds have diverged and may diverge even further in the future. It is frequently the case where a Fund (or a strategy within a particular Fund) seeks to buy an asset at the same time as another Fund (or strategy within that other Fund) seeks to sell the same asset. It may be beneficial to cross these transactions to minimize or eliminate transaction costs, obtain better pricing, and to limit the market impact of the transaction. In addition, by not exposing such buy and sell transactions to market forces, a Fund may not receive the best price otherwise possible, or OPS might have an incentive to improve the performance of one Fund by selling underperforming assets to another Fund in order, for example, to earn fees. In connection with such transactions, OPS, its affiliates and/or their professionals (i) will, from time to time, have investments, or intentions to invest, in the Fund that is selling and/or purchasing such an investment or (ii) otherwise have a direct or indirect interest in the investment (such as through certain other participations in the investment). Depending on the transaction structure, these transactions may disproportionately benefit the purchasing or selling Fund (or OPS, an affiliate or personnel because of interests in a particular Fund), and one Fund may incur expenses or forego gains

that would have been obtained had it not entered into such transaction. Determining the valuation or other terms of such transactions also creates a conflict of interest due to OPS’ consideration of the particular terms (including the fee terms) of the Funds and the Squarepoint Group’s interest in such Funds. Trades between certain Funds would have heightened conflict profiles as they would be considered “principal transactions” (given the significant ownership of Squarepoint Group employees and controlling persons in certain Funds). OPS has implemented policies and procedures designed to ensure these transactions are carried out in a manner that complies with applicable regulatory requirements. We do not place cross trades for Funds that are subject to the US Employee Retirement Income Security Act of 1974, as amended. Because of the overlap in trading conducted on behalf of the Funds, OPS must manage the supply of shares available for borrowing by the Funds with short positions and/or OPS’ remaining position limit capacity across multiple Funds. In general, we allocate such finite resources on a first-come-first-served basis. Given that the Higher Fee Funds trade in greater volume and with more urgency than the other Funds, it is likely that, from time to time, the Higher Fee Funds will deplete the supply of shares available for borrowing by the Funds with short positions and/or cause OPS to reach our remaining position or other limits and therefore prevent the other Funds’ from entering into particular positions. Squarepoint has the authority to aggregate orders of multiple Funds which may result in orders of certain Funds being aggregated with orders placed for Higher Fee Funds. Please see Item 12 for additional details concerning Squarepoint’s approach to trade aggregation, netting, and allocation. As noted in Item 4, the Funds are formed as master-feeder, or similar, structures. The feeder funds, or their equivalents (collectively “Feeder Funds"), invest substantially all of their capital in the master funds, and in the vast majority of circumstances, trading and investing activity of the Funds takes place at the master level of the Fund. For tax, regulatory or other reasons, Funds will from time to time, effect their investment activities indirectly by investing through one or more trading vehicles operated by the Squarepoint Group. For certain Funds (“MFC Funds”), OPS has the authority to transfer cash that is in excess of the amount needed to support MFC Funds’ trading activities to its respective Feeder Funds, and vice versa should the MFC Funds incur a need for cash or funding (the “Cash Transfers”). These Cash Transfers are the main source of funding for a sub population of the MFC Funds (“CTF Funds”). As OPS manages multiple MFC Funds and investment opportunities present themselves for each MFC Fund at different times, this can affect the manner in which OPS manages MFC Funds as a whole. In the event a material conflict were to arise, it may not be possible to resolve these transfers in an equitable manner. If this occurs, OPS will act in a manner that favors the MFC Funds at the expense of the CTF Funds. OPS may invest in other funds or accounts managed by the Squarepoint Group ("Squarepoint Funds") or in which OPS and its affiliates have an ownership or other economic interest, which gives rise to potential conflicts of interest. Further, it is possible that such Squarepoint Funds may in turn invest in other Squarepoint Funds. OPS has an incentive to prioritize Squarepoint Funds, including in the allocation of management time, resources, and investment opportunities, or maintain an existing investment in a Squarepoint Fund despite adverse performance results, since OPS or its affiliates has a direct or indirect financial interest in the success of such funds. OPS and its affiliates will endeavor to manage any potential conflicts arising from this in a fair and equitable manner, subject to legal, regulatory, contractual, or other applicable considerations. As noted in Item 4 and Item 10, a number of entities within the Squarepoint Group do not conduct any investment advisory services. Some of these non-advisory entities provide research services (“Affiliate Research Company”) to the Squarepoint Group and its affiliates, as well to corporate clients. Affiliate Research Companies may own specific intellectual property connected to the research they produce and

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OPS was registered as a commodity pool operator with the CFTC until March 31, 2025. After this time, registering was not required as all OpCos and Funds are eligible for the CFTC 25-50 No-Action relief from registration. In addition, as mentioned previously in Item 4, OPS is one entity in a family of entities which together will comprise the Squarepoint Group. In addition to UK OpCo, Singapore OpCo, and Dubai OpCo, the Squarepoint Group also includes other entities that are primarily responsible for IT, research and development activities specialized in quantitative finance (especially in the fields of trading software), largescale computing and data management, statistical financial research, and financial analytics dedicated to financial institutions, and provide the benefits of their expertise to other Squarepoint Group companies. The number and make-up of such entities can change from time to time. The interests of the Squarepoint Group and entities under common control may conflict with the interests of the Funds. The following discussion details certain potential or existing conflicts of interest; however, the following does not purport to be a complete list or description of all such potential or existing conflicts of interest. Squarepoint Group has established policies and procedures designed to address certain of the conflicts addressed below and discussed herein; however, such policies and procedures will not necessarily eliminate or mitigate all effects that such conflicts (and any other conflicts) may have on the Funds, and there can be no assurance that any conflicts of interest discussed herein will be resolved in favor of the relevant Funds. Squarepoint Group or individuals engaged in the Squarepoint Group’s business may from time to time invest, or have one of their affiliates invest, in funds or firms that pursue trading strategies, including funds or firms that trade the same products in the same markets as Squarepoint Group. Investment in such funds or firms may require substantial time and effort, which time and effort would otherwise be expended on managing the Funds. Individuals engaged in the Squarepoint Group’s business are not obligated to devote any specific amount of their business time to the affairs of the Squarepoint Group. In addition, each such person, including principals of the Squarepoint Group, may perform services for others and may sponsor or establish a variety of investment funds or managed accounts, including investment funds and managed accounts that trade the same or substantially similar strategies, markets and/or instruments. Therefore, each of these persons may have conflicts of interest in allocating management time, services and functions among the various entities and accounts for which they provide services. By reason of the other business or investment activities of the Squarepoint Group, from time to time, the Squarepoint Group may acquire confidential information or otherwise become restricted in their investment activities and are not free to act upon such confidential information. As a result, the OpCos may be restricted from initiating a transaction for a Fund which the OpCos otherwise might have initiated, and such Fund may, as a result, be required to maintain a position that it otherwise might have liquidated, or be required to refrain from acquiring a position that the Squarepoint Group otherwise might have acquired on behalf of such Fund. Certain of the Squarepoint Group and the STG Group (as defined below) personnel from time to time are active in and serve on, or may in the future be active in and serve on, the management committees or Boards of various exchanges, clearing houses, self-regulatory organizations and trade associations in which a Fund is a member. Certain Squarepoint Group personnel from time to time serve on the board of directors of, or a creditors’ committee in respect of, an issuer in which a Fund invests or is contemplating investing. Such personnel have an inherent conflict of interest between discharging their obligation in such capacities and acting in the interest of such Fund. The Squarepoint Group or the Funds which it advises may, from time to time, hold investments in vendors or other service providers that provide services of the type utilized by or in connection with the Funds. The investments may incentivize the Squarepoint Group and its affiliates to engage such vendors or service

providers to provide services to the Funds, as such engagement may directly or indirectly benefit the Squarepoint Group. Potential vendors or service providers, or their affiliates are, in certain circumstances, investors or prospective investors in a Fund, or affiliates of such investors or prospective investors. The engagement of any such service provider or vendor may be concurrent with an investor’s admission to a Fund, or during the term of such investor’s investment in the Fund. This creates a conflict of interest, as the Squarepoint Group may give such investor preferred economics or other terms with respect to its investment in a Fund or enhanced information. In addition, the Squarepoint Group will have a conflict of interest in recommending the retention or continuation of a service provider or a vendor to a Fund, or an investment, if such recommendation, for example, is motivated by a belief that the service provider or vendor (or related parties) will continue to invest in a Fund or will provide the Squarepoint Group information about markets and industries in which the Squarepoint Group operates, will provide other services that are beneficial to the Squarepoint Group and/or will provide financial sponsorship of events held by the Squarepoint Group. The Squarepoint Group generally has an incentive to recommend the products or services of certain investors or prospective investors (and related parties) in the Funds to the Funds or their investments for use or purchase, even though the products or services recommended may not necessarily be the best available to the Funds or the investments. In addition, the Squarepoint Group has an incentive to engage a service provider that is an investor or prospective investor in a Fund, or a related party, to, among other things, maintain goodwill with the Squarepoint Group. The Squarepoint Group or the Funds which it advises hold minority ownership stakes in certain trading venues or physical commodity-related businesses including mines, transportation companies, warehouses, vessels, and marketplaces and, in connection therewith, stand to benefit from the profits such venues derive from orders or other activity routed to such venues. This can incentivize the Squarepoint Group to route the Funds’ transactions to such venues. Notwithstanding the foregoing, the Squarepoint Group will only route the Funds’ transactions to such venues if doing so is otherwise consistent with its obligation of seeking to obtain best execution. The Squarepoint Group expects from time to time to enter into lending arrangements, including providing bridge financing, revolving credit facilities or other financing arrangements, between Higher-Fee Funds and other funds managed by the Squarepoint Group and entities affiliated with the Squarepoint Group, including the STG Group (as defined below). Such transactions give rise to conflicts of interest, including with respect to loan terms, interest rates, the use of proceeds, the design of and compliance with covenants, the determination of whether a default has occurred, the exercise of remedies, and the timing of any exit. Because the Squarepoint Group and its affiliates, and certain principals and related persons of the Squarepoint Group, have interests in the affiliated borrowers, including the STG Group, the Squarepoint Group may have an incentive to agree to terms that are more favorable to the affiliated borrower, or to forbear from exercising remedies, in a manner that is not in the best interests of the Higher-Fee Funds. Further, the use of the Higher-Fee Fund's capital in such lending arrangements will prevent it from deploying such capital in other investment strategies or require it to seek financing for its own operations. The Squarepoint Group will seek to ensure that any such financing is provided on terms it believes to be fair and reasonable under the circumstances. However, no assurance can be given that all conflicts will be resolved in a manner favorable to the Higher-Fee Funds or, as only certain investors in the Higher-Fee Funds have interests in such affiliated funds or entities, all of the investors in the Higher-Fee Funds.

The STG Group A number of the Squarepoint Group’s principals and their related persons own, directly or indirectly, a substantial majority of a separate commercial trading business, STG group (together with STG Securities (as defined below), for purposes of this Brochure, the “STG Group”). Although the STG Group and the Squarepoint Group generally operate as separate businesses that have their own investment staff, they both utilize SGS for Non-Advisory Services and share other resources, service providers and non-investment personnel. Overlap may occur and increase over time. This may create

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The Squarepoint Group has adopted a Code of Ethics (the “Code”) pursuant to Rule 204A-1 under the Advisers Act. Each of Squarepoint Group’s permanent employees, officers, directors, partners, and members and most temporary employees and consultants who have worked for the Squarepoint Group for more than three months, (collectively, “employees”), receive training in the Code and are required to acknowledge their receipt and understanding of the Code on an annual basis. The Code contains provisions requiring employees to act in the best interests of OPS’s clients and to comply with the federal securities laws which govern OPS’s activities. The Code also contains OPS’s personal trading policies and procedures which govern the personal investing activities of its access persons. OPS’s Code requires access persons to disclose all their “covered accounts” (which includes all securities accounts over which employees and certain family members exercise any control or retain a beneficial interest in non-exempt products) to OPS’s Compliance department. Squarepoint Group’s personal investment policies permit employees to invest in their personal accounts, subject to certain guidelines and restrictions. All personal securities transactions by employees, by certain members of their family, and in accounts in which this population have a beneficial interest, must be conducted in accordance with the requirements of Squarepoint Group’s personal investment policies. Among other things, Squarepoint Group’s policies require that certain personal securities transactions by employees or certain of their family members be reported and cleared in advance by the compliance department. Certain personal securities transactions are subject to a minimum holding period while other products may be outright prohibited from trading. Employees must report certain personal securities holdings upon employment and periodically thereafter, and arrange for certain duplicate confirmations and account statements to be sent to Squarepoint Group’s compliance department. The Funds from time to time invest in securities of companies in which Squarepoint Group personnel and other related persons and affiliates have previously invested for their own accounts. Furthermore, Squarepoint Group personnel, other related persons and affiliates (including any related entity established by any of the foregoing, such as trusts, charitable programs, endowments or related programs, family investment vehicles, family offices and other estate planning vehicles) from time to time invest for their own accounts in securities of companies in which the Funds have previously invested. While the interests of the Squarepoint Group personnel generally align the interest of such persons with the Funds, such persons may have differing interests from the Fund with respect to such investments (for example, with respect to the availability and timing of liquidity), creating conflicts of interest. The potential exists for personal securities transactions by Squarepoint Group personnel, including those that have pre-cleared or approved in advance, to generate significantly higher investment returns to such personnel than a Fund’s investment transactions generate for their own investors. There can be no assurance that the return of a Fund participating in a transaction would be equal to and not less than another Fund participating in the same transaction or that it would have been as favorable as it would have been had such conflicts not existed. It is also possible that an OpCo, in its sole discretion, later determines that such a company is a suitable investment for a Fund due to developments with respect to the securities, or a Fund’s portfolio or, subject to the terms of the Governing Documents, changes to the OpCo's investment approach. In such a circumstance, a Fund may invest in the company even though Squarepoint Group personnel already hold interests in it, and, subject to the Code, Squarepoint Group personnel will be permitted to buy additional interests, maintain their interests, either concurrently or subsequently, even if such investment limits a Fund’s desired allocation, or sell their interests, in each case without regard to the actions of a Fund. Squarepoint Group personnel holding an investment for their own account in an investment that is later determined to be suitable or appropriate for a Fund may also participate in making such determination and may and frequently will be involved in recommending the investment to a Fund. This presents various actual and potential conflicts of interest, including without limitation because the Squarepoint Group

personnel would have independent financial, relationship-driven or other interests in causing a Fund to invest in that opportunity (potentially at a higher price or with worse terms than in the absence of such conflicts), and the Squarepoint Group personnel's investment or relationships may be enhanced as a result of such Fund’s investment. The OpCos, affiliates, and officers, principals and employees of the OpCos and their affiliates may buy or sell securities or other instruments that an OpCo has recommended to a Fund. Squarepoint Group personnel may also buy securities in transactions offered to but rejected by a Fund. A conflict of interest may arise because such investing Squarepoint Group personnel will, for some investments, benefit from the evaluation, investigation, and due diligence undertaken by an OpCo on behalf of a Fund. In such circumstances, Squarepoint personnel will not share or reimburse the relevant Fund(s) and/or the Squarepoint Group for any expenses incurred in connection with the investment opportunity. In addition, Squarepoint Group personnel also buy securities and hold interests as passive investors in other investment vehicles (including private equity funds, venture capital funds, hedge funds, real estate funds and other similar investment vehicles) which may include potential competitors of the Funds and/or which may invest in similar industries and sectors as the Funds (including investments for purposes of sourcing future investment opportunities). Such Squarepoint Group personnel have a conflict of interest with respect to their personal investment holdings. There could be situations in which such investment vehicles invest in the same investments as the Funds, and there may be situations in which such investment vehicle purchases securities from, or sells securities to, a Fund. The investment policies, fee arrangements and other circumstances of these investments may vary from those of the Funds. In the event Squarepoint Group personnel make an investment with the intent to source future investments for the Funds, there is a greater likelihood that the Funds will make investments in the same investments in which Squarepoint Group personnel hold an interest as described above. Such personnel may be incentivized to cause a Fund to act in a manner that benefits such other investment vehicles and, indirectly, themselves as investors in such investment vehicles. Investors and prospective investors in the Funds may obtain a copy of the Code upon request. As an investment adviser with respect to the Funds, the Squarepoint Group may be subject to additional potential conflicts of interest between the Squarepoint Group or its related persons and the Funds beyond those posed by personal trading. The Advisers Act imposes certain requirements designed to decrease the possibility of conflicts of interest between an investment adviser and its clients. Therefore, in addition to the Code, the Squarepoint Group has also implemented policies and procedures aimed at mitigating conflicts which may arise from participation in outside business activities by employees, political and charitable contributions, and gifts and entertainment that may be received and/or given by employees. OPS has also adopted policies designed so that any potential conflicts of interest which are identified are mitigated and resolved in a manner that is consistent with the Squarepoint Group’s fiduciary duty to its clients and in compliance with applicable laws and regulations. Squarepoint Group personnel are themselves and/or have family members that are actively involved in industries and sectors in which the Funds invest or have business, personal, financial or other relationships with companies in such industries and sectors (including service providers) or other industries, which gives rise to conflicts of interest. For example, such personnel or family members might be officers, directors, personnel or owners of companies which are actual or potential investments of the Funds or other counterparties of the Funds and investments. Moreover, in certain instances, the Funds or the investments may purchase or sell companies or assets from or to or otherwise transact with companies that are owned by such personnel or family members or in respect of which such personnel or family members have other involvement. The fees for services provided by such service providers may or may not be at the same rate charged by other third-party service providers and the Squarepoint Group is not required to select service providers who may have lower rates (or to engage in any benchmarking of such fees). In most circumstances, the Governing Documents will not preclude Funds from undertaking any of these investment activities or transactions. From time to time, Squarepoint Group personnel invest in funds or

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Counterparty Selection OPS currently has prime brokerage arrangements in place with the brokers enumerated in Item 7.A of Form ADV Part 1A. In addition, OPS maintains an “approved broker list” of trading and execution counterparties. In selecting trading and other counterparties, and evaluating the performance of those counterparties, Squarepoint may review numerous factors as part of its mandate, including, without limitation, commission and financing rates, trading and technology infrastructure (including speed and reliability of execution), stock lending supply and rates, ability to execute and process transactions with appropriate levels of confidentiality, quality of trade ideas received from desk-based analysts, operational processes, and the financial strength, integrity, and stability of the broker or counterparty. In no event will Squarepoint Group select a broker-dealer or will the Funds pay a higher commission than would otherwise be paid as a means of remuneration for the referral or affording Squarepoint Group with the opportunity to participate in any capital introduction program. Trade Aggregation and Allocation Squarepoint has the authority to aggregate orders of multiple clients and net orders of multiple clients in certain circumstances. Such aggregating of orders might facilitate overall execution and reduce brokerage and other costs. Squarepoint has sole discretion when determining that a particular set of orders should or should not be aggregated. In the circumstances where orders are aggregated or netted, the firm has implemented procedures designed to ensure that aggregated resulting transactions (i) are allocated on a fair basis, (ii) do not systematically advantage one fund over another, (iii) are carried out in an manner that complies with applicable regulatory requirements, (iv) are done consistent with this, and any other, client disclosure and (v) receive client consent when required by rule or regulation. Positions purchased or sold in an aggregated or netted transaction are allocated to the participating clients (which may include Higher Fee Funds) using methods determined by Squarepoint in our sole discretion. These methods may include, but are not limited to, pro rata by order size, pro rata by assets under management, fixed proportion per client determined prior to the execution of the trade, and allocation to a client that is furthest from meeting a risk metric that can be satisfied by the position. Additionally, Squarepoint may, on a case by case basis, increase or decrease the transaction amount allocated to each client to avoid holding odd lots or small numbers of positions for particular clients, to meet liquidity requirements, to satisfy macro risk parameters set by investment personnel, to avoid a misallocation of fills, or for legal/regulatory reasons (including a desire to avoid or minimize a regulatory filing, disclosure or other obligation). If we are unable to or do not fully execute an aggregated transaction or we determine that it would be impractical to allocate a small number of positions among all of the accounts initially intended to participate in the transaction, we may allocate such positions in a manner determined in good faith to be an appropriate allocation. In addition, Squarepoint may charge or credit clients participating in any resulting transaction with i) prices applicable to any filled orders allocated to a client, ii) the average price of various prices received for that order, or iii) with a price determined to be an appropriate price. While it is anticipated that, over time, aggregating orders will benefit each client overall, such an approach may disadvantage certain clients, including without limitation by resulting in share allocations of filled orders or worse execution prices for client orders. Alternatively, not bunching or aggregating orders may disadvantage certain clients, including without limitation by resulting in higher costs or worse execution prices for such orders. When aggregating orders for multiple clients, Squarepoint will determine which entity will face the external counterparty. If one of Squarepoint’s clients is chosen to execute the aggregated order, that client will bear the risk that one of the other clients will default on its portion of any trade and that the client this is party to the contract will be liable for the defaulted obligation. Where one of our clients is not the party to the contract

and expects to be allocated a portion of the trade, it bears the risk that the client that is party to the contract will default, which may result in the cancellation of trades made on behalf of the client that is not party to the contract. Soft Dollars Squarepoint Group currently only uses commissions to obtain research and brokerage services to the extent permitted by local regulations, such as permitted research and brokerage services within the meaning of Section 28(e) of the Securities Exchange Act of 1934, as amended. 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; software that provides trade analytics and trading strategies; corporate governance research and rating services; investment and economic recommendations; 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 used to transmit orders; clearance and settlement in connection with a trade; electronic communication of allocation instructions; access to hardware that cannot otherwise be accessed in certain markets; technological solutions relating to data distribution, data center space; routing settlement instructions; post trade matching of trade information; and services required by the SEC or a self-regulatory organization such as comparison services, electronic confirms or trade affirmations. In those situations, the commissions paid on transactions with those broker-dealers or merchants providing such services may exceed the amount another broker- dealer or merchant would have charged for effecting such transactions. Should Squarepoint Group elect in the future to use commissions arising from a Fund’s investment transactions for services other than research and brokerage, such usage will be limited to services that would otherwise be a Fund expense. The use of commissions to obtain such other services would be outside the parameters of Section 28(e). Research and brokerage services obtained by the use of commissions arising from a Fund’s portfolio transactions are used by Squarepoint in their investment activities and may provide benefit to other Funds. Squarepoint does not seek to allocate soft dollar benefits proportionately based on the Fund which generated such soft dollar credits. The use of commissions (or certain mark-ups or markdowns) to obtain research and brokerage products and services can raise other conflicts of interest. For example, Squarepoint Group will not have to pay for the products and services itself. This creates an incentive to select or recommend a broker-dealer based on Squarepoint Group’s interest in receiving those products and services (or the ability to instruct such a broker dealer to pay a third-party vendor for these products and services). With regards to MiFID II and as it relates to UK OpCo, to the extent that UK OpCo uses third party investment research, as defined by MiFID II, it will do so consistent with requirements regarding acceptable methods to pay for investment research. Investment research is received in return for direct payments made by UK OpCo out of its own resources or by payments from a separate research payment account funded by clients and controlled by UK OpCo.

The Squarepoint Group may receive certain services (including, without limitation, capital introduction and hedge fund consulting) from prime brokers or other counterparties with whom the Squarepoint Group conducts business at no additional cost. This could present a conflict of interest with respect to the selection of such counterparties, though the Squarepoint Group understands that the benefits received through these relationships generally do not depend on the volume of transactions directed to a particular counterparty.

From time to time, and in the ordinary course of business, OPS has in the past and may, in the future, be subject to routine, formal or informal regulatory examinations or other inquiries, claims or litigation. Additional disciplinary disclosure information can be found in Part 1 of Squarepoint’s Form ADV within Item 11 and any related DRP pages.

OPS will monitor the trading activity and portfolio holdings of the Funds on an ongoing basis to ensure that trading activity is consistent with the general investment objectives of the Funds as outlined in the Governing Documents. The review process will address the risk limits across regions, strategies, and asset classes as well as updating the overall risk limits for the portfolio. The Funds’ administrator will provide monthly reports on shareholder accounts in the Funds and certain other information. Each investor in the Funds will also be furnished with a set of audited financial statements for each relevant fiscal year and, where applicable, a Schedule K-1 indicating such investor’s share of the Funds’ income, gain, loss, deductions, and credits relevant for U.S. federal income tax purposes.

OPS does not maintain physical custody over the Fund’s assets. However, under the provisions of Rule 206(4)-2 of the Advisers Act (the Custody Rule), OPS is deemed to have custody over the assets of the Funds. In accordance with the annual audit requirements of the Custody Rule, OPS has engaged an independent public accounting firm to audit each fund. The audits will be performed in accordance with United States Generally Accepted Accounting Principles (US GAAP) and the audited financial statements for each Fund will be distributed to all investors within 120 days of the relevant Fund’s fiscal year end.

OPS has discretionary authority to manage the assets of the Funds. OPS’ discretion is exercised in a manner consistent with the stated investment objectives and guidelines of each Fund. The procedures followed in assuming this authority are outlined in the Governing Documents. When OPS or the Funds grant discretion to a sub-adviser, that sub-adviser makes the trading and investment decisions pursuant to the terms of the sub-advisory agreement and consistent with the stated objectives, guidelines, and restrictions of the particular account for which discretion has been granted.

The investment strategy employed by the Squarepoint Group is generally not influenced by the outcome of proxy contests or voting, and OPS has determined that expected benefits that would accrue to the clients from proxy voting are typically outweighed by the costs, including opportunity costs, associated with voting proxies. Therefore, OPS will generally abstain from voting proxies in client accounts, as it is seen as being in their best interests. OPS may choose to proxy vote when certain events occur or in instances where it has received information about a proxy vote and determines that voting is potentially in the overall benefit of the relevant client accounts. Third party sub-advisers that have been granted discretion over the management of client accounts will also have the authority to vote client securities. This raises the potential conflict of voting being exercised in opposing directions by different third-party sub-advisers for the same client account or Fund. Copies of relevant proxy logs, identifying how proxies were voted in connection with a client and copies of proxy voting policies are available to any client or prospective client upon written request to the Squarepoint Group’s investor relations department.

A balance sheet is not required to be provided as OPS (i) does not solicit fees more than six months in advance, (ii) does not have a financial condition that is likely to impair its ability to meet contractual commitments to clients or (iii) has not been subject to any bankruptcy proceeding during the past 10 years