Teng Yue Partners, L.P.

Teng Yue Partners, L.P. (“Teng Yue”, the “Firm”, “we”, “us”, or “our”) was formed in February 2011. Tao Li is the founder and Managing Partner of the Firm. Teng Yue is a limited partnership organized under the laws of the State of Delaware. Teng Yue is currently an investment adviser on a discretionary basis to the following private funds (collectively, the “Clients”): • • • • •

Teng Yue Partners Fund, L.P. (the “Onshore Fund”) Teng Yue Partners Offshore Fund, L.P. (the “Offshore Fund”) Teng Yue Partners Master Fund, L.P. (the “Master Fund”) Teng Yue Partners RDLT, LP (“PE Fund I”) Teng Yue Partners RDLT II, LP (“PE Fund II”)

The Onshore Fund and the Offshore Fund (together, the “Feeder Funds”) invest substantially all of their assets in the Master Fund. All Feeder Fund investments in securities are made through the Master Fund. Collectively, the Feeder Funds and the Master Fund are referred to as the “Hedge Funds” and are each individually referred to as a “Hedge Fund.” In managing the Hedge Funds, Teng Yue pursues the Hedge Funds’ investment objective by investing in a combination of long and short Asia-focused equity investments. In managing PE Fund I and PE Fund II (together, the “PE Funds,” and each individually a “PE Fund”), Teng Yue pursues each PE Fund’s investment objective by investing primarily in private Chinese companies. Teng Yue provides advice to the Clients based on their specific investment objectives and strategies. Teng Yue does not tailor advisory services to the individual needs of investors of the Clients. Teng Yue launched its fund operations in March 2011. The general partner of the Onshore Fund, the Offshore Fund and the Master Fund is Teng Yue Partners GP, LLC (the “HF General Partner”), a Delaware limited liability company controlled by Tao Li. The general partner of PE Fund I and PE Fund II is Teng Yue Partners RDLT GP, LLC (the “PE Fund General Partner,” and, together with the HF General Partner, the “General Partners”), a Delaware limited liability company controlled by Tao Li. As of December 31, 2025, Teng Yue managed U.S.$ $2,247,493,203 in regulatory assets under management, all on a discretionary basis.

The Hedge Funds The management fees paid to Teng Yue for advising the Hedge Funds are generally as follows: i.

if the aggregate net asset value of the Hedge Funds is less than or equal to $200 million, 2.0% (annually, paid quarterly in advance);

ii.

if the aggregate net asset value of the Hedge Funds is greater than $200 million but less than $500 million, 1.75% (annually, paid quarterly in advance); and

iii.

if the aggregate net asset value of the Hedge Funds is equal to or greater than $500 million, 1.5% (annually, paid quarterly in advance).

Fees are deducted from the Hedge Funds by submitting a detailed invoice to their administrator (the “Administrator”). The invoice is then processed and approved by the Administrator before being paid to the Firm at the discretion of the Administrator. Any management fees paid in advance by the Hedge Funds are refundable on a prorated basis if the relevant advisory contract is cancelled prior to the end of a payment period. In our sole discretion, we have waived in the past, and expect to waive in the future, all or any portion of the management fees or performance-based compensation (as described in Item 6) with respect to certain investors in the Hedge Funds. The PE Funds The management fees paid to Teng Yue for advising the PE Funds are generally as follows: i.

During a PE Fund’s investment period, 1.5% of aggregate capital commitments (annually, paid quarterly in advance); and

ii.

After a PE Fund’s investment period, 1.5% of the aggregate cost basis of such PE Fund’s investments (annually, paid quarterly in advance), less any permanent writedown to zero value.

Fees are deducted from the PE Funds by submitting a detailed invoice to their Administrator. The invoice is then processed and approved by the Administrator before being paid to the Firm at the discretion of the Administrator. Any management fees paid in advance by a PE Fund are refundable on a prorated basis if the relevant advisory contract is cancelled prior to the end of a payment period. In our sole discretion, we have waived in the past, and expect to waive in the future, all or any portion of the management fees or carried interest (as described in Item 6) with respect to certain investors in the PE Funds. Expenses Teng Yue and the General Partners will be responsible for their own general operating and overhead costs. Each Client will bear its own organizational and operating expenses including, as applicable, legal, accounting (including third party accounting services), audit, and other professional fees and expenses, costs of processing transfers and withdrawals to the extent not borne by the applicable investor(s), research expenses, expenses of third-party valuation agents (if any), fees and expenses related to portfolio investments or prospective investments (whether or not consummated) such as commissions, custodial fees, bank service fees, expenses of third-party trading services, fees and expenses of the Administrator, travel expenses in connection with investment activity, legal fees and expenses incurred in connection with investment activity, asset verification, appraisal and valuation fees and expenses, investment banking expenses and professional investigatory services, fees due to unaffiliated advisors, sub-advisors and consultants, specific expenses incurred in obtaining or maintaining technology and systems, finders and service companies, any individual computer or software product utilized with respect to a particular investment, information and information service subscriptions (including periodicals and similar research news or data subscriptions) utilized with respect to the Client’s investment program and other expenses related to the purchase, sale, preservation or transmittal of the Client’s assets. Expenses that are paid or payable by the Master Fund generally are borne pro rata by the Feeder Funds. For a complete enumeration

of the treatment of expenses, please refer to the operating fees and expenses section of each Feeder Fund’s Confidential Private Placement Memorandum and each PE Fund’s Confidential Private Placement Memorandum. For further details on the Firm’s brokerage practices, please refer to Item 12 of this Brochure. If any of the expenses listed above are incurred on behalf of more than one Client, such expenses will generally be allocated among such Clients either in proportion to the size of the investment made by each Client to which such expense relates (in respect of trading and investment-related expenses), based upon the capital in each respective Client (in respect of non-trading and investment related expenses), or in such other manner as the General Partners consider fair and equitable. From time to time, the Firm may permit certain investors to co-invest in investments alongside one or more of the Clients, subject to the relevant governing documents, as well as the considerations described in Item 8 below. Where a co-invest vehicle is formed, such entity generally will bear expenses related to its formation and operation, many of which are similar in nature to those borne by the Clients. For co-investments, the expense allocation may differ from pro rata but will be in line with disclosures in the governing documents for the relevant Clients.

As a general matter, the investment strategies utilized by the Firm are described in the Clients’ offering and governing documents, which are provided to such Clients’ investors. The information contained herein is a summary only, and investors should refer to the relevant Client’s offering and governing documents for a complete overview of the Firm’s investment strategies and the risks associated therewith. Investment Strategy The Hedge Funds The Hedge Funds seek to achieve significant capital appreciation with reduced market risk primarily through a combination of long and short Asia-focused equity investments. The Hedge Funds target non-correlated returns to relevant indices. The Hedge Funds’ investment strategy is driven by rigorous fundamental research, company analysis, disciplined investing, and a long-term focus. The Hedge Funds portfolio is currently concentrated in globally listed investments in Asia (including, but not limited to, Mainland China, Taiwan, Hong Kong, Japan, Korea, India, Southeast Asia, and Oceania) across a variety of sectors, market capitalizations, and listing locations, as disclosed to investors in periodic reporting provided by the Firm. As part of this strategy, the Hedge Funds have invested and will invest outside of Asia (including, but not limited to, North America and Europe) where the Firm’s research as described herein helps develop compelling theses for these investment ideas. For example, in pursuit of its investment objective, the Firm has in the past and expects in the future to identify attractive investments in global companies that are impacted by economic, social, or other trends or themes related to Asia. The Firm implements the Hedge Funds’ investment strategy through investments in equities and derivatives (including, but not limited to, common stocks and American Depository Receipts of publicly traded companies, shares in private companies, equity swaps, index swaps, forwards, options, and futures), and other instruments including convertible bonds. In certain circumstances, the Firm will also consider investments in corporate bonds or credit default swaps. The Firm may also use long or short investments to hedge positions or the overall portfolio from certain exposures or risks by utilizing any of the following instruments for hedging purposes in a variety of markets, including, but not limited to, single name equities, derivatives, currencies, indices, and baskets. The Hedge Funds are currently invested in unaffiliated investment funds. While the Hedge Funds will set no strict parameters for the balance of long and short positions in the portfolio, we expect that under normal market conditions the Hedge Funds’ net exposure (total long exposure minus total short exposure) will generally range from -25% to 75%, with gross exposure (total long exposure plus total short exposure) generally ranging from 150% to 250%. Under normal market conditions, the portfolio typically will have approximately 30-50 long positions and approximately 30-50 short positions ranging from 1%

to 10% of equity. The Hedge Funds, however, have at times and may in the future under certain circumstances have net and gross exposures which are outside these ranges, and invest a larger portion of their equity in one or more positions and each of the foregoing percentages and guidelines are expected to change over time. The investment strategy will generate a portfolio that is relatively concentrated. While the Hedge Funds invest primarily in accordance with the methodology discussed above, we maintain broad and flexible investment authority. For instance, from time to time, the Hedge Funds may make an investment that is subject to legal or contractual restrictions on transferability, unable to be fairly valued, or otherwise not readily marketable without impairing the value of such investment. To the extent that the HF General Partner determines that such circumstances apply to an investment, at the time of investment, the HF General Partner has the authority to designate such investment as a “Special Situation Investment,” but is not required to do so. Special Situation Investments may be held either directly by the Hedge Funds or transferred so that they are held indirectly, outside of the Hedge Funds, through alternative investment vehicles. The PE Funds The primary investment objective of each PE Fund is to make private equity investments by investing in and holding equity and equity-oriented securities of privately held companies organized in, or having substantial markets or operations in, China. Each PE Fund may also buy, sell or hold listed securities in connection with pursuing its investment objective. Each PE Fund aims to invest its capital in Chinese internet, healthcare companies (including biotechnology companies) and other sectors. Each PE Fund aims to provide investors the opportunity to participate directly in the growth opportunities present in Chinese private equity. Each PE Fund’s investment strategy is driven by rigorous fundamental research, company analysis, and disciplined investing. Note that the investment periods for both PE Funds have ended, and both funds are no longer making new investments. Risk of Loss Factors Investing in securities involves risk of loss that investors should be prepared to bear. The following list of risk factors does not purport to be a complete enumeration or explanation of the risks involved in an investment in the Clients. Please review each Feeder Fund’s Confidential Private Placement Memorandum and each PE Fund’s Confidential Private Placement Memorandum (as applicable) for a more detailed description of the risks of loss before deciding to invest in a Client. Risks Associated with Investments Generally Equity Securities Equity-related instruments are subject to various types of risk including market risk, liquidity risk, counterparty credit risk, legal risk and operations risk. In addition, equity-related instruments can involve significant economic leverage and may, in some cases, involve significant risks of loss. We believe that our investment program and research techniques moderate this risk through a careful selection of securities and other financial instruments; however, no guarantee or representation is made that the investment program will be successful. Certain Clients will invest capital in long and short positions in equities and other investments, which do not produce current income for them. The nature of the securities to be purchased and traded by the Clients and the investment techniques and strategies to be employed in an effort to increase profits may increase this risk. Equity prices are directly affected by issuer-specific events, as well as general market conditions. In addition, in many

countries, investing in equity is subject to heightened regulatory and self-regulatory scrutiny as compared to investing in debt or other financial instruments. Derivatives We use various derivative instruments as direct investments or for hedging purposes for certain Clients. Such instruments may be volatile, speculative and subject to wide fluctuations in market value resulting in potential losses to our Clients. The parties with which we enter into such derivatives are banks, broker-dealers and other financial institutions. Use of derivative instruments presents various risks, including the following: Tracking – When used for hedging purposes, an imperfect or variable degree of correlation between price movements of the derivative instrument and the underlying investment sought to be hedged may prevent us from achieving the intended hedging effect or expose the Clients to the risk of loss. Liquidity – Derivative instruments may not be liquid in all circumstances. We may not be able to close out a position at its fair value. Leverage – Trading in derivative instruments can result in leverage, which may magnify the gains and losses experienced by our Clients and could cause the value of our Clients’ accounts to be subject to wider fluctuations than would be the case if derivative instruments were not used. Over-the-Counter-Trading – Certain derivatives are not traded on an exchange. Such instruments are bilateral contracts with price and other terms negotiated between the buyer and seller. These contracts are not subject to the same type of government regulation as exchange-traded instruments. Many of the protections afforded to participants in a regulated environment may not be available in connection with such transactions. The risk of nonperformance by the obligor on such an instrument may be greater and the liquidity of such investment may be less than in the case of an exchange-traded instrument. Non-U.S. Securities The Clients invest the majority of their assets in the equity or other securities and instruments of issuers located outside the United States. In addition to the business uncertainties, such investments may be affected by political, social and economic uncertainty affecting a country or region. Many financial markets are not as developed or as efficient as those in the United States and the Clients are subject to fiscal and taxation policies, regulatory regimes, including securities regulations, market and settlement practices and sovereign and political risks of the countries in which they invest. As a result, liquidity may be reduced and price volatility may be higher. The legal and regulatory environments differ from that in the U.S., particularly as to bankruptcy and reorganization. Financial accounting standards and practices may differ, and there may be less publicly available information in respect of such companies. The Clients are subject to additional risks which include possible adverse political and economic developments, possible seizure or nationalization of non-U.S. deposits and possible adoption of governmental restrictions which might adversely affect the payment of principal and interest to investors located outside the country of the issuer, whether from currency blockage or otherwise. Furthermore, some of the securities or investments may be subject to brokerage taxes levied by governments, which has the effect of increasing the cost of such

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The Firm’s Clients are the Hedge Funds and the PE Funds. To invest in the Hedge Funds and the PE Funds, we generally require a minimum investment of $25,000,000 and $5,000,000, respectively, although we reserve the discretion to accept less. We may in the future advise additional private funds or separately managed accounts for institutional, non-retail investors.

The Hedge Funds The HF General Partner is entitled to an annual performance-based profit allocation at the end of each calendar year with respect to the Feeder Funds, generally equal to twenty percent (20%) of the Hedge Funds’ net profits, subject to a “loss recovery account.” The PE Funds The PE Fund General Partner is entitled to carried interest equal to twenty percent (20%) of the amount distributed to the investors in each PE Fund, after the return of capital contributions and subject to a preferred return. Carried interest is a performance-based form of compensation. Conflicts Related to Performance Based Fees The existence of performance-based compensation creates a possible incentive to cause us to make investments for the Hedge Funds and PE Funds that are more speculative than would otherwise be the case in the absence of such performance-based compensation. However, we believe this incentive is mitigated by the personal investment in such vehicles by our principal and the fact that losses will reduce the Hedge Funds’ and PE Funds’ performance and, thus, our principal’s returns as well. We make investments through the Master Fund and/or one or both of the PE Funds. Our allocation policy provides that transactions and investment opportunities will be handled on a fair and equitable basis over time. Performance-based compensation creates a potential incentive to favor accounts that are subject to higher compensation rates over other accounts in the allocation of investment opportunities. In addition, our related persons (including Tao Li) invest in one or more Clients. Such investments are generally substantial but investments in certain Clients are larger compared to other Clients. As a result, we have a possible incentive to favor the Client(s) in which our related persons have a greater economic interest and have a potential conflict of interest in allocating investment opportunities among those

Client accounts. In order to mitigate these potential conflicts, we will generally follow the allocation policy and procedures described in Item 12 below.

Services by the Firm’s Related Persons Tao Li is the primary owner and manager of the General Partners, each of which serves as the general partner of certain Clients. Management of Multiple Accounts The management of multiple pooled investment vehicles results in a potential conflict of interest when the Firm and its related persons allocate time and investment opportunities among them. For example, Tao Li and/or other related persons have a greater portion of their personal assets invested in certain Client accounts. In addition, the compensation earned by the Firm and its related persons from each Client is expected to differ from one another. The Firm will generally follow documented procedures in allocating trades among the Clients (see Item 12 below). A cross-trade occurs when an investment adviser effects a trade between two or more of its advisory clients. If the Firm causes a cross-trade between two Clients, it would potentially result in a conflict of interest because the transaction may result in benefits to one Client that may be greater than the benefits to the other Client. The Firm may effect cross-trades between Clients in the following situations, among others: (i) to rebalance investments between the Clients or (ii) for tax or regulatory reasons. All cross-trades between Clients require the prior approval of Teng Yue’s Chief Compliance Officer (the “CCO”) or his designee. Such transactions will be effected only when the Firm believes that they are in the best interests of, and are fair and equitable to, the participating Clients. Such transactions will generally be effected for cash consideration, generally at the closing price of the particular security or, if no closing price is available, at fair market value (in accordance with the Firm’s valuation policy). No brokerage commission, transfer fee or other commission will be paid to the Firm or its affiliates in connection with any such transaction. Service Providers as Investors Senior personnel at certain third parties that provide significant service to the General Partners, the Firm and/or the Clients (including providers of market research or similar services) are currently and may, from time to time in the future, become investors in the Clients. As such, the General Partners and/or the Firm, as applicable, are subject to potential conflicts of interest relating to their selection of any such investor service provider on behalf of the Clients. The General Partners and/or the Firm, as applicable, generally manage such conflicts of interest by (i) seeking to select service providers based on the level and quality of the services they provide to the Clients and (ii) making such decisions independent of such investor service providers’ senior personnel’s decision to invest in a Teng Yue Client. Services to Proprietary Account The Firm and its employees have provided, and are expected in the future to provide, limited services to proprietary accounts that are held by Mr. Li, his family or Mr. Li’s foundation (collectively, the “Proprietary Accounts”). As noted below, investments made by each Proprietary Account will at all times be subject to the Firm’s personal trading policy (see Item 11). Further, any trade-related expenses incurred by any Proprietary Account will be fairly allocated to such account.

The Proprietary Accounts maintain, and may in the future maintain, brokerage accounts with one or more of the brokers used by the Firm’s Clients and receive, and may in the future receive, certain benefits from such brokers that would likely not be available to them in the absence of such brokers' relationship with the Firm. The Firm will not commit to conduct any additional level of business with any broker on behalf of its Clients as a result of the Proprietary Accounts and will continue to periodically assess each broker to confirm that it continues to satisfy its best execution responsibilities to the Firm’s Clients (see Item 12 below).

Personal Trading Code of Ethics & Personal Trading Pursuant to Rule 204A-1 of the Investment Advisers Act of 1940, as amended (the “Advisers Act”), we have adopted a Code of Ethics, which is designed to ensure that we conduct our business in accordance with all applicable laws and regulations and in an ethical and professional manner. The Code of Ethics applies to all of our employees. The foundation of the Code of Ethics is based on the underlying principles that: -

Employees must at all times place the interests of the Clients first; Employees must make sure that all personal securities transactions are conducted consistently with the Code of Ethics; and Employees should not take inappropriate advantage of their positions at Teng Yue.

Among other things, our Code of Ethics governs all personal securities transactions by our employees (as further described below) and sets forth certain policies relating to gifts and entertainment, outside business activities, political contributions and the prevention of insider trading. Employees are provided with a copy of the Code of Ethics and, at least annually, are required to acknowledge that they will comply with its provisions. Under the Code of Ethics, all employees must pre-clear all personal securities trades with the CCO (or his designee) and Tao Li (subject to certain limited exceptions) and must ensure that the Firm can access brokerage statements (or transaction level automatic reporting via broker feeds containing the same information) for all covered accounts (as defined in the Code of Ethics). The CCO (or his designee) reviews the personal trading information submitted by employees. From time to time, Tao Li and certain employees buy or sell investments (including, in the case of Tao Li, a limited number of investments in public securities through the Proprietary Accounts) that are also being bought or sold by the Firm’s Clients. To mitigate associated potential conflicts, neither Tao Li nor the Firm’s employees will receive approval for proposed personal investments that are also being purchased or sold by, or that are held by, the Firm’s Clients unless the Firm has determined that its Clients have received their desired allocation of such investments. Further, participating employees will not receive better terms with respect to such investments than Teng Yue’s Clients. Investments by Tao Li in public securities through the Propriety Accounts shall at all times be subject to Teng Yue’s personal trading policy. Teng Yue and its employees may not trade for Clients or themselves in securities of a company while in possession of material non-public information or disclose material non-public information to any person not permitted to receive it. By reason of its investment activities, the Firm may have access to material non-public information and therefore may be restricted

from entering into transactions on behalf of its Clients. The Firm has adopted policies and procedures reasonably designed to prevent trading on material non-public information. Our Code of Ethics is available to Clients or prospective Clients upon request. Principal Transactions The Firm will not engage in any principal transaction unless it has determined that the transaction is in the relevant Clients’ best interests and has obtained Client consent in accordance with its written procedures and applicable law.

As an adviser and a fiduciary to our Clients, our Clients’ interests must always be placed first and foremost, and our trading practices and procedures prohibit unfair trading practices and seek to disclose and avoid any actual or potential conflicts of interests or resolve such conflicts in the Clients’ favor. We have adopted the policies and practices described below, among others, to meet our fiduciary responsibilities and to seek to ensure our trading practices are fair to all Clients and that no Client is advantaged or disadvantaged over any other. Best Execution As a fiduciary, we have an obligation, among other things, to seek best execution of Client transactions. Best execution is determined on a trade-by-trade basis, and should result in the best qualitative execution, not necessarily the lowest possible commission cost. When selecting a counterparty, we consider relevant factors that we deem reasonable under the circumstances. Generally speaking, when we seek to make a particular trade on behalf of a Client, we initially determine which brokers have access to the relevant securities. Other decisions regarding the type of transactions at issue (e.g., physical security versus swap) are considered as part of this determination. After we have determined which brokers have access to the relevant securities, we also consider such brokers’ prices for such securities (which is an important but not determinative factor for satisfying our best execution obligations), as well as transaction costs (e.g., commission rates) and the margin rates and financing rates of a broker. We also consider a number of qualitative factors when seeking to make a particular trade on behalf of a Client, including, but not limited to, the responsiveness of the broker for prompt and reliable executions, the financial responsibility and integrity of the broker, the financial strength of the broker, services as a prime broker, value of research provided, if any, and competitiveness of the transaction costs. In certain circumstances, however, we will not be able to select a counterparty because only a limited universe of dealers are in a position to offer investments in which we are currently interested. In some cases, the offering dealer is the only executing broker for such transaction and therefore, provides best execution by default. On a periodic basis, Teng Yue conducts formal best execution review meetings in order to review brokers for best execution. Trade Allocation The Firm seeks to allocate investment opportunities in a manner that is consistent with its fiduciary obligations and, accordingly, to allocate investment opportunities fairly and equitably among the Clients when and to the extent applicable, such that no Client will be systematically disadvantaged over time. A number of factors may be considered when multiple Clients are capable of purchasing or selling a particular security or other investment product based on their respective investment objectives, including, without limitation: (i) the amount of available

cash or margin, (ii) the impact that any such transaction may have on an existing portfolio’s diversification, risk and volatility characteristics, (iii) each Client’s overall portfolio composition, (iv) liquidity, (v) contractual commitments, (vi) each Client’s investment or risk guidelines, or (vii) tax, legal or regulatory considerations. The Firm is not obligated to purchase or sell for each Client every security which the Firm may purchase or sell for other Clients if such a transaction or investment appears unsuitable, impractical or undesirable for a Client; provided that the Firm, to the extent within its control, may not favor itself in any way to a Client’s detriment and will act in a manner that over the long term is fair and equitable to all of the Clients. When the amount available for a particular investment exceeds the relevant Clients’ intended allocation for the investment, the Firm, in its sole and absolute discretion, may provide certain persons or entities (including, among others, Tao Li, the Firm’s employees and certain other persons) with an opportunity to co-invest alongside the relevant Clients in such investment. There is no assurance that the Firm will offer these co-investment opportunities to every investor. No investor should have the expectation that it will have the opportunity to participate in such an investment. Aggregation of Orders Aggregation describes a procedure whereby an investment adviser combines the orders of two or more client accounts into a single order. Aggregation opportunities for the Firm would generally arise when more than one Client is capable of purchasing or selling a particular security based on the allocation factors described above. To the extent that a security is purchased or sold for more than one Client, the Firm will aggregate orders for such security (to the extent possible) unless aggregation is not consistent with the Firm’s duty to seek best execution. To the extent an aggregated order is only partially filled, the Firm will allocate the investment opportunity or partially filled order on a fair and equitable basis based on the criteria described above. Each Client that participates in an aggregated order will participate at the average price for all of the Firm’s transactions in that security on a given business day, with transaction costs shared pro rata based on each Client’s participation in the transaction. Trade Errors On occasion, errors may occur with respect to trades executed on behalf of the Clients. Trade errors can result from a variety of situations, including for example, when the wrong security is purchased or sold, when the correct security is purchased or sold but for the wrong Client, when the wrong amount is purchased or sold or when a misallocation among the Clients occurs. Trade errors may result in losses or may result in gains. We endeavor to detect trade errors prior to settlement and correct and/or mitigate them in an expeditious manner. Any losses, except for those due to gross negligence, willful misconduct or bad faith, will be borne by (and any gains will benefit) the relevant Client. To the extent an error is caused by a third party, such as a broker, we will strive to recover any losses associated with such error from such third party. We generally will reimburse losses suffered by a Client as a result of a trade error caused by the Firm as a result of gross negligence, willful misconduct or bad faith. In addition, we will not correct a trade error made for one Client by causing another Client to buy or sell the securities. We also will not directly or indirectly use soft dollars to correct trade errors.

Soft Dollar Policy We do not currently utilize soft dollar benefits but may do so in the future. Soft dollar benefits include research and related services furnished by brokers including written information and analyses (including specific market, financial and economic studies and forecasts), statistics and pricing services, discussions with research personnel and similar services used in the investment and trading process in return for an investment manager paying a broker a commission in excess of what another broker might have charged for effecting the same transaction, in recognition of the value of such services or facilities provided by the broker. To the extent we should decide to enter into soft dollar arrangement, we will do so in compliance with the safe harbor provided by Section 28(e) of the Securities Exchange Act of 1934, as amended. We receive (including during the Firm’s last fiscal year) bundled products or services from brokers (including, but not limited to: (i) research, such as proprietary research from brokers, (ii) research products, such as databases and quotation services, and (iii) research services and consultation with industry consultants concerning specific companies, industries or sectors). To our knowledge, such products and services are generally made available to all institutional clients doing business with these brokers.

Teng Yue does not currently utilize any third-party marketers or solicitors for client referrals.

Neither we nor any of our management personnel are subject to, or have in the past been subject to, any criminal or civil action in any domestic or foreign court; and neither we nor

any of our management personnel have been subject to any administrative proceedings before the SEC or any other state, federal or foreign financial regulatory authority.

Review of Accounts Tao Li, the Firm’s Chief Operating Officer and the Firm’s Chief Financial Officer (and their designees) review and reconcile Client portfolios on a daily basis to confirm conformity with investment objectives and guidelines. We engage in active management and frequent transactions for the Hedge Funds and, accordingly, review our transactions, positions, and cash balances on a daily basis. We have also engaged the Administrator to prepare unaudited reports reviewing each Hedge Fund’s performance for each month and each PE Fund’s performance for each quarter. Reporting Financial statements are prepared by Teng Yue, audited by an independent auditor and distributed to investors in the Clients on an annual basis. In addition, Teng Yue furnishes investors of the Hedge Funds with unaudited monthly reports showing the value of their capital accounts, periodic reports (generally quarterly) providing fund and market commentary, and certain other reports on the operations of the Hedge Funds as Teng Yue may determine in its sole and absolute discretion. Teng Yue furnishes investors of each PE Fund with unaudited quarterly reports showing the value of their capital accounts and periodic reports providing fund and market commentary.

While it is Teng Yue’s practice not to accept or maintain physical possession of any of our Clients’ assets (and our Clients’ assets are in the custody of one or more prime brokers and/ or banks), we are deemed to have custody of their assets under Rule 206(4)-2 of the Advisers

Act because we have the authority to access funds and deduct fees and expenses from Clients’ accounts. In order to comply with Rule 206(4)-2, we utilize the services of qualified custodians (as defined under Rule 206(4)-2) to hold all assets of our Clients (to the extent required by such rule). We also confirm that the qualified custodians maintain these assets in accounts bearing the relevant Client’s name that contain only assets of such Client. While Rule 206(4)-2 generally requires an investment adviser to provide for a qualified custodian to send quarterly account statements to all of its Clients that have assets held with the custodian, we are not subject to such requirement because our Clients are subject to an audit at least annually by an independent auditor that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board. We distribute each Client’s audited financial statements to all investors within 120 days of the end of the fiscal year of such Client.

As previously noted, we have full discretionary authority to manage the Clients, including authority to make decisions with respect to which securities are bought and sold, the amount and price of those securities, the brokers or dealers to be used for a particular transaction, and the commissions paid. These terms are set out in the governing documents for each Client.

The Firm has voting discretion over certain securities held by the Clients. When exercising such discretion, the Firm will do so in the best interests of the Clients. In the absence of specific voting guidelines from a Client or conflicts of interest, the Firm will vote all proxies in the best interests of each Client. In addition, the Firm may determine to abstain from voting a proxy if it believes that such action is in the best interests of a particular Client, if the Firm deems that the issue being voted upon is not material for the Firm and the Clients, or if the Firm determines that the cost of voting exceeds the benefit. A copy of our proxy voting policies and information about how Teng Yue voted securities is available to investors upon request.

Registered investment advisers are required in this Item to provide certain financial information or disclosures about their financial condition. Teng Yue has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to Clients, and has not been the subject of a bankruptcy proceeding.