Tetragon Financial Management LP

Tetragon Financial Management LP, or TFM, serves as the investment manager of Tetragon Financial Group Limited, or Tetragon, a Guernsey closed-ended investment company traded on Euronext Amsterdam N.V. under the ticker symbol “TFG.NA” and on the Specialist Fund Segment of the main market of the London Stock Exchange under the ticker symbols “TFG.LN” and “TFGS.LN”. Tetragon’s investment objective is to generate distributable income and capital appreciation. It aims to provide stable returns to investors across various credit, equity, interest rate, inflation and real estate cycles. To achieve this objective, Tetragon’s investment strategy is to invest primarily in alternative assets and strategies, both by partnering with asset managers who offer differentiated expertise and by making direct, idiosyncratic investments. Tetragon invests in a broad range of assets, including public and private equities and credit (including distressed securities and structured credit), convertible bonds, real estate, venture capital, infrastructure, bank loans and Tetragon Partners L.P., or Tetragon Partners, a diversified alternative asset management business, which is also separately registered with the SEC as an investment adviser. Tetragon invests with and in the managers on its diversified asset management platform, Tetragon Partners. Through the platform, Tetragon invests in a range of underlying strategies – often alongside other investors – and, when appropriate, also aims to realize the value of its ownership stakes, or GP stakes, in these businesses. TFM provides investment supervisory services to Tetragon in accordance with Tetragon’s Memorandum and Articles of Incorporation. TFM has been appointed as the investment manager of Tetragon under an investment management agreement, or the Investment Management Agreement, and collectively with Tetragon’s Memorandum and Articles of Incorporation, Tetragon’s Governing Documents. TFM’s general partner, Tetragon Financial Management GP LLC, or Tetragon Financial Management GP, is responsible for all actions of TFM. Tetragon Financial Management GP is ultimately controlled by Reade Griffith, who also controls the holder of Tetragon’s voting shares. Reade Griffith and Paddy Dear are the voting members of TFM’s Investment and Risk Committees. Reade Griffith acts as the authorized representative of Tetragon Financial Management GP and TFM. Under the terms of the Investment Management Agreement, TFM has full discretion to invest the assets of Tetragon in a manner consistent with the investment objective of Tetragon. TFM has the authority to determine the investment strategy to be pursued in furtherance of the investment objective, which strategy may be changed from time to time by TFM in its discretion. TFM is authorized to delegate its functions under the Investment Management Agreement. TFM’s responsibilities with respect to Tetragon include, inter alia:

investing and reinvesting the assets of Tetragon in securities, derivatives and other financial instruments and other investments of whatever nature and committing the assets of Tetragon in relation to agreements with entities, issuers and counterparties;

holding cash balances or investing them directly in any short-term investments, and reinvesting any income earned thereon in accordance with Tetragon’s investment strategy;

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purchasing, holding, selling, transferring, exchanging, mortgaging, pledging, hypothecating and otherwise acting to acquire and dispose of and exercise all rights, powers, privileges and other incidents of ownership or possession with respect to investments held or owned by Tetragon, with the objective of the preservation, protection and increase in value thereof;

exercising any voting or similar rights attaching to investments purchased on behalf of Tetragon;

borrowing or raising monies from time to time without limit as to amount or manner and time of repayment;

engaging consultants, attorneys, independent accountants or such other persons as TFM may deem necessary or advisable; and

entering into any other contracts or agreements in connection with any of the foregoing activities.

Tetragon invests in various funds and other vehicles managed by Tetragon Partners businesses. It also provides financial support to various funds managed by Tetragon Partners businesses (such as a “seeding” arrangement), and provides equity, loans or other financial support to Tetragon Partners and its asset management businesses. TFM is responsible for any decision to invest cash into any fund or other vehicle managed by a Tetragon Partners business (TFM is also responsible for selecting third-party managers who invest in asset classes appropriate for Tetragon) and is also responsible for decisions regarding financial support for Tetragon Partners. In addition to investments in funds or vehicles managed by third-party asset managers and investments in funds or vehicles managed by Tetragon Partners asset managers, the investments of Tetragon may include investments that are held directly on its “balance sheet” and, as such, are directly managed by TFM. TFM does not participate in wrap fee programs. The amount of client net asset value that TFM manages on a discretionary basis is approximately U.S. $3.9 billion (as of December 31, 2025). TFM does not currently manage any client assets on a non-discretionary basis. Tetragon Partners is Tetragon’s diversified alternative asset management platform. Tetragon Partners manages, oversees and supervises Tetragon’s private equity investments in asset management companies. Tetragon Partners, as a unified business, seeks to enhance the value of each individual investment and the entity as a whole through a shared strategic direction and operating infrastructure - encompassing critical business management functions such as risk management, investor relations, financial control, technology, and compliance/legal matters while at the same time giving entrepreneurial independence to the managers of the underlying businesses. In light of the strategy to continue to grow and diversify Tetragon Partners, the combination of a number of relatively uncorrelated businesses across different asset classes and at different stages of development under Tetragon Partners is also intended to create a collectively -5-

more robust and diversified business and income stream. At the same time, Tetragon Partners may seek to realize the enhanced value of its individual asset management companies. This may be through transactions relating to individual businesses within Tetragon Partners, that would take advantage of this value enhancement, or a strategic transaction at the Tetragon Partners level. Although transactions relating to individual businesses could shrink Tetragon Partners’ portfolio of relatively mature market-leading businesses – thereby possibly delaying progress toward a strategic transaction at the Tetragon Partners level – they would enable it to monetize the benefits of its success in growing asset management businesses. In any event, Tetragon Partners will continue to leverage its operating infrastructure and shared strategic direction with Tetragon looking to support investments through co-investment and working capital. Tetragon Partners’ subsidiaries include the following entities: Banyan Square (Banyan Square), Contingency Capital (Contingency Capital), Equitix (Equitix), Hawke’s Point (Hawke’s Point), Tetragon Credit Partners (Tetragon Credit Partners), TCICM (TCICM), Tetragon Life Sciences (Tetragon Life Sciences) and Westbourne River Partners (Westbourne River Partners). Stephen Prince is the Chief Executive Officer of Tetragon Partners and a member of the Investment Committee and Risk Committee of TFM, and Reade Griffith is the Chief Investment Officer of Tetragon Partners and is responsible for the investment management of Tetragon Partners’ private equity investments in asset management companies. Tetragon Partners is registered as an investment adviser under the U.S. Investment Advisers Act of 1940 and two of its investment management affiliates, Tetragon Partners UK LLP and Equitix Investment Management Limited, are authorized and regulated by the United Kingdom Financial Conduct Authority (FCA). Management Structure and Governance As stated earlier, TFM has been appointed the investment manager of Tetragon pursuant to the Investment Management Agreement. TFM’s general partner, Tetragon Financial Management GP LLC, is responsible for all actions of TFM. The general partner is ultimately controlled by Reade Griffith and Paddy Dear, who also control the holder of Tetragon’s voting shares and are the voting members of TFM’s Investment and Risk Committees. Reade Griffith acts as the authorized representative of the general partner and TFM. Pursuant to an agreement between Reade Griffith and Paddy Dear, Reade Griffith is the controller of Tetragon’s voting shares and TFM. TFM’s Investment Committee is responsible for the investment management of Tetragon’s portfolio and currently consists of Reade Griffith, Paddy Dear and Stephen Prince. The Investment Committee determines the investment strategy of Tetragon and approves each significant investment by them. TFM’s Risk Committee is responsible for the risk management of Tetragon’s portfolio and performs active and regular oversight and risk monitoring. The Risk Committee has the same composition as the Investment Committee.

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TFM’s Executive Committee oversees all key non-investment and risk activities of TFM and currently consists of Reade Griffith, Paddy Dear, Stephen Prince, Paul Gannon, Sean Côté and Greg Wadsworth. Key Provisions of the Investment Management Agreement The Investment Management Agreement continues in full force and effect unless terminated (i) by TFM at any time upon 60 days’ notice or (ii) immediately upon Tetragon giving notice to TFM or the investment manager giving notice to Tetragon in relation to such entity in the event of (a) the party in respect of which notice has been given becoming insolvent or going into liquidation (other than a voluntary liquidation for the purpose of reconstruction or amalgamation upon terms previously approved in writing by the other party) or a receiver being appointed over all or a substantial part or of its assets or it becoming the subject of any petition for the appointment of an administrator, trustee or similar officer, (b) a party committing a material breach of the Investment Management Agreement which causes a material adverse effect to the non-breaching party and (if such breach shall be capable of remedy) not making good such breach within 30 days of service upon the party in breach of notice requiring the remedy of such breach or (c) fraud or willful misconduct in the performance of a party’s duties under the Investment Management Agreement. The Investment Management Agreement provides that none of TFM, its affiliates or their respective members, managers, partners, shareholders, directors, officers and employees (including their respective executors, heirs, assigns, successors or other legal representatives) (each, as an indemnified party) will be liable to Tetragon or any investor in Tetragon for any liabilities, obligations, losses (including, without limitation, losses arising out of delay, misdelivery or error in the transmission of any letter, cable, telephonic communication, telephone, facsimile transmission or other electronic transmission in a readable form), damages, actions, proceedings, suits, costs, expenses (including, without limitation, legal expenses), claims and demands suffered in connection with the performance by TFM of its obligations under the Investment Management Agreement or otherwise in connection with the business and operations of Tetragon in the absence of fraud or willful misconduct on the part of an indemnified party, and Tetragon has agreed to indemnify each indemnified party against any such liabilities, obligations, losses, damages, actions, proceedings, suits, costs, expenses, claims and demands, except as may be due to the fraud or willful misconduct of the indemnified party. TFM may act as investment manager or advisor to any other person, so long as its services to Tetragon are not materially impaired thereby, and need not disclose to Tetragon anything that comes to its attention in the course of its business in any other capacity than as investment manager. The investment manager is not liable to account for any profit earned or benefit derived from advice given by TFM to other persons. TFM will not be liable to Tetragon for any loss suffered in connection with TFM’s decision to offer investments to any other person, or failure to offer investments to Tetragon. Tetragon Partners is an investment of Tetragon, and, as such, TFM, as Tetragon’s investment manager, is responsible for exercising any of Tetragon’s voting or similar rights with respect to Tetragon Partners as an investment and is responsible for the management, oversight and/or supervision of such investment. As with any other category of investments, TFM is also responsible for decisions with respect to acquisitions of asset management businesses to be added -7-

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Management Fees As compensation for investment supervisory services rendered to Tetragon, TFM is entitled to receive management fees calculated as the net asset value of Tetragon payable monthly in advance prior to the deduction of any accrued incentive fees. The precise amount of, and the manner and calculation of, the management fees for Tetragon are set forth in Tetragon’s Governing Documents. Where TFM receives management fees in advance and its services are terminated prior to the end of the billing period, TFM would refund to the relevant client an amount of management fees prorated from the date of its termination to the end of the period covered by the advance fee. TFM’s compensation is subject to waiver or reduction in its discretion. TFM, its affiliates and certain of its professionals can invest in investment vehicles advised by TFM (as of the date of this brochure, TFM’s only client is Tetragon). Certain of TFM’s principals and employees are subject to reduced or no management fees and/or incentive fees on their direct or indirect investment in Tetragon. TFM Expenses To the extent provided in the Governing Documents and except as described herein as an expense of Tetragon, TFM will bear certain expenses and costs associated with the performance of its services, including expenses on account of rent, utilities, office supplies, office equipment, the compensation and expenses of certain of its partners, officers and employees and other normal and routine administrative expenses relating to the services and facilities provided by TFM to Tetragon. Tetragon Fees and Expenses Consistent with the Governing Documents, Tetragon generally bears its own expenses, including, without limitation, (i) the charges and expenses of all legal advisers, auditors, accountants -9-

(including out-sourced accounting) and other professional expenses; (ii) brokers' commissions (if any), borrowing charges on securities sold short and any issue or transfer taxes' chargeable in connection with any securities transactions; (iii) all taxes and corporate fees payable to governments or agencies; (iv) directors' fees (if any) and expenses; (v) interest on debt financings of Tetragon, including borrowings from any prime broker; (vi) such expenses as may be reasonably incurred in connection with any offering or sale of shares or interests or debt instruments in the public or private markets; (vii) communication expenses with respect to investor services and all expenses of meetings of shareholders and of preparing, printing and distributing financial and other reports, proxy forms, prospectuses and similar documents; (viii) the cost of insurance (if any) for the benefit of the directors, TFM or its affiliates; (ix) litigation and indemnification expenses and extraordinary expenses not incurred in the ordinary course of business; (x) custodial fees (if any); (xi) bank service fees; (xii) research expenses; (xiii) marketing and investor relations costs, including production and distribution of investor relations materials and travel and other incidental expenses; (xiv) travel expenses related to investments of Tetragon whether consummated or not; (xv) other expenses related to the potential or actual acquisition or disposition of assets of Tetragon; (xvi) all other organizational and operating expenses; (xvii) the management fee; and (xviii) expenses associated with Tetragon, and other similar fees and expenses, as well as any other fees or expenses incurred by TFM or Tetragon in connection with Tetragon’s operations that are not specifically set forth above as being paid by TFM. Tetragon generally bears all costs and expenses directly related to its investments or prospective investments, such as brokerage commissions, interest on debt balances or borrowings, custodial fees and legal and consultant fees. Tetragon also generally bears all out-of-pocket costs of administration including accounting, audit, administrator and legal expenses, costs of any litigation or investigation involving its activities, costs associated with reporting and providing information to existing and prospective investors and the costs of liability insurance. Brokerage Fees When a broker is used in connection with an investment by Tetragon, Tetragon will incur brokerage and other transaction costs. For more information on brokerage transactions and costs, please see Item 12 Brokerage Practices. Incentive Fees Please see Item 6 below regarding incentive fees that Tetragon pays. Allocation of Expenses Pursuant to a services agreement with Tetragon Partners, TFM relies on Tetragon Partners for a broad range of services to support its activities that include, but are not limited to, infrastructure services such as operations, financial control, trading, marketing and investor relations, legal, compliance, office administration, payroll and employee benefits, services relating to the dealing in and management of certain investments, arrangement of deals and advising on certain investments and other services.

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These service arrangements present potential conflicts of interest because the costs associated with providing services for the benefit of TFM, to the extent they are not borne by TFM, would be borne by Tetragon Partners and therefore Tetragon, as the owner of Tetragon Partners. From time to time TFM and its affiliates (including Tetragon Partners) will be required to decide whether certain fees, costs and expenses should be borne by TFM, its affiliates (including Tetragon Partners), Other Funds (as defined below), a portfolio investment of Tetragon or an Other Fund, co-investors and/or a third party (each, an Allocable Party) and if so, how such fees, costs and expenses should be allocated among the relevant Allocable Parties. Certain fees, costs and expenses may be the obligation of one particular Allocable Party and may be borne by such Allocable Party, or fees, costs and expenses may be allocated among multiple Allocable Parties. TFM and its affiliates allocate fees, costs and expenses to Tetragon in accordance with Tetragon’s Governing Documents and the services agreement. To the extent not addressed in Tetragon’s Governing Documents and the services agreement, TFM and its affiliates will make allocation determinations among Allocable Parties in a fair and reasonable manner using their good faith judgment, notwithstanding their interest (if any) in the allocation. These determinations may include pro rata allocation based on the respective investment (or anticipated investment) of an Allocable Party in an investment, relative benefit received by an Allocable Party, allocation of professionals’ time, or such other equitable method as determined by TFM and its affiliates in their sole discretion. The particular methodology used to allocate such amounts where services are provided are expected to vary depending on the types of services provided and could, in certain circumstances, change from one period to another. TFM and its affiliates will make any corrective allocations and take any mitigating steps if it determines in its sole discretion that such corrections are necessary or advisable. Notwithstanding the foregoing, the portion of an expense allocated to Tetragon for a particular service may not reflect the relative benefit derived by Tetragon from that service in any particular instance and Tetragon will bear more or less of a particular expense based on the methodology used. Any methodology chosen by TFM and its affiliates involves inherent conflicts of interest and could result in a greater expense to Tetragon than would be the case if such services were provided by third parties. Certain affiliates of TFM, as well as Tetragon indirectly by virtue of its ownership interest in such affiliates, also bear their allocable portion (as determined by TFM and its affiliates in their good faith discretion) of the compensation (including, without limitation, salary, bonus, payroll taxes, pension, benefits (including vacation time and sick leave)), expenses and overhead (including, without limitation, rent, property taxes and utilities allocable to the workspaces) attributable to certain employees, partners, members, or officers of TFM and its affiliates including for activities that include, but are not limited to, infrastructure services such as operations, financial control, trading, marketing and investor relations, legal, compliance, office administration, payroll and employee benefits, services relating to the dealing in and management of certain investments, arrangement of deals and advising on certain investments and other services. It is expected that the services provided by TFM employees and those of its affiliates will expand over time. The allocation of such compensation and expenses between TFM, its affiliates, Tetragon and Other Funds require judgments as to methodology that TFM and its affiliates makes in good faith but in their sole discretion. These allocation methodologies include requiring personnel to periodically record and allocate their time (which is commonly expressed as Full Time Equivalents (FTEs)) with respect to Tetragon and TFM’s affiliates. On a monthly basis, employees, directly or via their -11-

team head, provides a breakdown of the approximate percentage of time spent supporting Tetragon or TFM’s affiliates for the previous month (this excludes certain functions such as office management and technology that are charged to business users on a standard basis (e.g., space used or global headcount) which removes any need on the part of those teams to allocate their FTEs). Once allocated percentages are determined and agreed, an FTE is derived, subject to adjustments for items determined by contractual arrangements. Core personnel costs, including salary, bonus, pension and healthcare, are charged on an actual employee cost basis to each business line based on the FTE allocation described above. In addition to FTE costs, there are a number of other costs that reflect the use of resources by TFM personnel or those of its affiliates on behalf of Tetragon and TFM’s affiliates, including real property costs, technology, travel and entertainment and market data. A standard cost methodology is used to allocate these costs to Tetragon and TFM’s affiliates. The setting of standard costs is designed to reflect what those costs would be on an arm’s-length basis. The methodology is designed to create consistency in order to provide a fair allocation of resource costs to all businesses. TFM and its affiliates may also utilize any other methodology determined by them to be appropriate under the circumstances. The particular methodology used to allocate such amounts where services are provided are expected to vary depending on the types of services provided and could, in certain circumstances, change from one period to another. Any methodology chosen by TFM and its affiliates involves inherent conflicts of interest and could result in a greater expense to Tetragon and the Firm’s affiliates than would be the case if such services were provided by third parties. Tetragon Partners’ cost allocation methodology is documented and updated annually by Tetragon Partners’ finance group in consultation with its Legal, Regulatory and Compliance team and is approved each year by Tetragon Partners’ Executive Committee. Tetragon Partners’ auditors, reporting directly to Tetragon’s Audit Committee, are currently engaged to periodically test that the costs allocated to (and therefore recovered from) TFM have been properly calculated in accordance with the approved cost allocation methodology. Tetragon’s Board of Directors has adopted procedures for related-party transactions that require approval of a majority of disinterested directors. Accordingly, Tetragon’s independent directors are required to approve the methodology for allocating costs and in their sole discretion the application of that methodology as part of their oversight processes. The annual cost allocation methodology update and the actual annual cost allocations that result based on these cost methodology policies and procedures are separately approved by the independent directors.

Below is a general summary of TFM’s investment strategies, methods of analysis and material risks. More information on each of the below can be found on the Tetragon website (www.tetragoninv.com). Methods of Analysis and Investment Strategies Tetragon’s investment objective is to generate distributable income and capital appreciation. To achieve Tetragon’s investment objective of generating distributable income and capital appreciation, Tetragon’s current investment strategy is:

To identify attractive asset classes and investment strategies.

To identify asset managers it believes to be superior.

To use TFM’s market experience to negotiate favorable terms for Tetragon’s investments.

To own, where appropriate, all, or a portion of, asset management companies with which Tetragon invests in order to enhance the returns achieved on its capital.

In addition, the current investment strategy is to continue to grow and diversify Tetragon Partners, as Tetragon’s diversified alternative asset management business, as well as to enhance the value of its asset management companies with a view to realizing value from the enterprise. As part of this investment strategy, TFM may employ hedging strategies and leverage in seeking to provide attractive returns while managing risk. TFM seeks to identify asset classes that offer excess returns relative to their investment risk, or “intrinsic alpha.” It analyses the risk/reward, correlation, duration and liquidity characteristics of each potential capital use to gauge its attractiveness and incremental impact on Tetragon. TFM then seeks to find high-quality managers who invest in these asset classes; selects or structures suitable investment vehicles that optimize risk-adjusted returns for Tetragon’s capital; and/or seeks for Tetragon (via Tetragon Partners) to own a share of the asset management company. TFM aims to not only produce asset-level returns for Tetragon, but also to enhance these returns with capital appreciation and investment income from its investments in asset management businesses that derive income from external investors. Certain considerations when evaluating the viability of a potential asset manager typically include performance track records, reputation, regulatory requirements, infrastructure needs and asset gathering capacity. Potential profitability and scalability of the asset management business are also important considerations. Additionally, the core capabilities, investment focus and strategy of any new business should seek to offer a complementary operating income stream to Tetragon Partners’ existing businesses. TFM looks to mitigate potential correlated risks across Tetragon Partners’ investment managers by diversifying its exposure across asset classes, investment vehicles, durations and investor types, among other factors. -13-

Tetragon’s investment strategy leads the Firm to invest in three primary ways: (i) Limited Partner investments in managed funds; (ii) Ownership stakes in asset managers (or General Partnership stakes); and (iii) Direct investments. Limited Partner investments in managed funds. Funds Managed by Tetragon Partners The Firm invests as an LP in a range of specialized strategies managed by Tetragon Partners asset managers, with a view to obtaining diversified returns on favored terms. In so doing, Tetragon aims to not only produce asset-level returns, but also to enhance these returns with fee income from external investors through its GP ownership stakes in these businesses. Tetragon is also the only, or the lead LP investor in a number of these strategies. Externally-managed funds Tetragon invest with third-party managers – without taking a GP ownership stake – to access asset classes and investment strategies beyond those on the Tetragon Partners platform, using our experience to select managers and invest on favorable terms. Ownership stakes in asset managers – GP stakes One of Tetragon’s largest investments is Tetragon Partners, which manages, oversees and supervises the Firm’s majority and minority GP stakes in asset management companies. In addition to investing as an LP in some of the strategies managed by Tetragon Partners asset managers, Tetragon aims to realize, where appropriate, the value of its GP stakes in these businesses, whether through strategic transactions or dispositions. Through Tetragon Partners, Tetragon buys, launches and builds asset management businesses. Depending on the circumstances, Tetragon can provide working capital, co-investment capital and/or operating infrastructure – encompassing critical business management functions such as risk management, business development, investor relations, financial control, technology and compliance/legal matters – supporting long-term value creation while enabling entrepreneurial independence for the CIOs of these businesses. Direct Investments Tetragon makes direct investments from its balance sheet, targeting idiosyncratic opportunities that are typically single-strategy ideas, opportunistic and catalyst driven. These range from listed instruments to private investments and cover a broad range of assets. The breadth and diversity of the Firm’s LP investments in managed funds, including through Tetragon Partners, also creates co-investment opportunities and ideas which Tetragon may develop as direct investments. Risks Relating to Investment Strategies Investing in securities involves a substantial degree of risk. Tetragon may lose all or a substantial portion of its investments, and investors must be prepared to bear the risk of a complete loss of their investments. -14-

In addition, material risks relating to the investment strategies and methods of analysis described above, and to the types of securities typically purchased by Tetragon, include the following: Risks Relating to Market Disruption, Health Crises, Terrorism and Geopolitical Risk Investments are subject to the risk that war, terrorism, global health crises or similar pandemics, other related geopolitical events, extreme weather and climate-related events and other events affecting the financial markets may lead to increased short‐term market volatility and have adverse long‐term effects on world economies and markets generally, as well as adverse effects on issuers of securities and the value of investments. The Funds are also subject to the risk that war, terrorism, social unrest and related and unrelated geopolitical and other new or novel market disrupting events could lead to increased short-term market volatility and have adverse long-term effects on world economies and markets generally, as well as adverse effects on issuers of securities and the value of a Fund’s investments. Global geopolitical instability arising from armed conflicts, military interventions, and significant political events presents material uncertainty and risk with respect to the Funds, the performance of portfolio companies, and the ability of the Funds to achieve their investment objectives. These conflicts include, but are not limited to: (i) the ongoing military conflict between Russia and Ukraine, which has caused disruptions to global financial systems, trade, transport and food security, and has resulted in extensive international sanctions on Russian individuals, entities, and exports, with the potential for broader escalation given the involvement of the international community; (ii) the conflict between Israel and Hamas and other Palestinian militant groups, which commenced following the October 7, 2023 Hamas attack and has created significant unrest in the Middle East, with the potential to expand into a broader regional conflict involving additional nations; (iii) the January 2026 United States military intervention in Venezuela, which resulted in the capture of incumbent Venezuelan President Nicolás Maduro and has caused significant regional instability, with potential implications for global oil markets given Venezuela’s substantial crude oil reserves; and (iv) the February 2026 joint United States and Israel strikes against, and ensuing conflict with, Iran. Given the ongoing and evolving nature of these conflicts and events and their continued escalation or uncertainty, it is difficult to predict their ultimate impact on global economic and market conditions. Escalation of any of the foregoing conflicts or political events, or the emergence of new geopolitical tensions or conflicts, could potentially have a significant adverse impact and result in significant losses to the Fund and/or its portfolio companies. Geopolitical instability can adversely affect global financial markets (including credit markets), commodity prices, supply chains, currency exchange rates and investor confidence, and any resulting displacement of populations can further destabilize affected regions. The imposition or modification of sanctions regimes may affect the Fund’s ability to transact with certain counterparties or in certain jurisdictions, and these and/or other changes in the geopolitical landscape may limit the ability of the Fund to manage, finance, and exit its investment in portfolio companies as well as the price at which any such exit could occur. The inherent unpredictability of these situations, including the potential for conflicts to spread to additional regions or draw in additional nations, presents material uncertainty with respect to the Fund, the operations, financial condition, and performance of portfolio companies, and the ability of the Fund to achieve their investment objectives. TFM’s key vendors and service providers, such as providers of outsourced accounting services, consultants and external counsel, are also subject to these risks. -15-

Risks Relating to Trade Policy Trade conflicts between the U.S. and certain foreign countries have intensified in recent periods. The U.S. government has altered its approach to international trade policy, indicating its intent to renegotiate, or potentially terminate, certain existing bilateral or multilateral trade agreements and treaties with foreign countries and imposing, or threatening to impose, tariffs on certain foreign goods. Some foreign governments, including the Chinese government, have instituted, or threatened to institute, retaliatory tariffs on certain U.S. goods. The continuation or further intensification of such conflicts may lead to the introduction of additional barriers to trade, an increase in the cost of certain goods, a decrease in trade volume, supply chain disruptions, shifts in consumer sentiment and/or a general decrease in corporate profits and securities prices in both public and private markets, any of which could have an adverse impact on the performance of investments and returns to investors. Custody and Banking Risks Tetragon will hold cash and other assets in accounts with one or more banks, custodians or depository or credit institutions, collectively, Banking Institutions, which may include both U.S. and non-U.S. Banking Institutions from time to time. The Fund may also enter into credit facilities and have other relationships with Banking Institutions as contemplated elsewhere in this filing. The distress, impairment, or failure of, or a lack of investor or customer confidence in, any of such Banking Institutions may limit the ability of each of the Investment Manager and the Fund to access, transfer or otherwise deal with its assets, draw upon a credit facility, or rely upon any of such other relationships, in a timely manner or at all, and may result in other market volatility and disruption, including by affecting other Banking Institutions. All of the foregoing could have a negative impact on the Fund. For example, in such a scenario, the Fund could be forced to delay or forgo an investment or a distribution, including in connection with a withdrawal, or generate cash to fund such investment or distribution from other sources (including by disposing of other investments or making other borrowings) in a manner that it would not have otherwise considered desirable. Furthermore, in the event of the failure of a Banking Institution, access to a depository account with that institution could be restricted and U.S. Federal Deposit Insurance Corporation (FDIC) protection may not be available for balances in excess of amounts insured by the FDIC (and similar considerations may apply to Banking Institutions in other jurisdictions not subject to FDIC protection). In such a case, the Investment Manager or the Fund, as applicable, may not recover all or a portion of such excess uninsured amounts and could instead have an unsecured or other type of impaired claim against the Banking Institution (alongside other unsecured or impaired creditors). The Investment Manager does not expect to be in a position to reliably identify in advance all potential solvency or stress concerns with respect to its or the Fund’s banking relationships, and there can be no assurance that the Investment Manager or the Fund will be able to easily establish alternative relationships with and transfer assets to other Banking Institutions in the event a Banking Institution comes under stress or fails. Risks Resulting from the United Kingdom’s Exit from the European Union The United Kingdom withdrew from the European Union on January 31, 2020. This is referred to as Brexit. In connection with Brexit, the United Kingdom and the European Union agreed the Trade and Cooperation Agreement, or TCA, that governs the future trading relationship between -16-

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TFM currently provides investment supervisory services to Tetragon. Investment advice is provided directly to Tetragon and not individually to Tetragon’s shareholders.

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With respect to Tetragon, subject to the Governing Documents, TFM receives an incentive fee calculated as a percentage increase in the net asset value for each calculation period.

TFM is affiliated with Tetragon Partners which is separately registered as an investment adviser with the Securities and Exchange Commission (see SEC File number 801-74150; CRD number 156040). Tetragon may from time to time participate in transactions alongside clients of Tetragon Partners. For a description of material conflicts of interest created by the relationship among TFM and Tetragon Partners, as well as a description of how such conflicts are addressed, please see Item 11 below. Pooled Investment Vehicles and Regulated Subsidiaries and Sponsors of Limited Partnerships Tetragon Partners and certain of its respective affiliates serve as sponsors or syndicators of a number of limited partnerships, including those related to Westbourne River Partners, Hawke’s Point, Banyan Square, Contingency Capital, Equitix, Tetragon Life Sciences and Tetragon Credit Partners funds. In addition, Tetragon Partners and its affiliates, serve as investment advisers of investment vehicles and accounts (e.g., Equitix and Tetragon Credit Partners funds) that are, for the most part, pooled investment vehicles. While primarily unregulated, certain such pooled investment vehicles may be registered with regulatory authorities in their home jurisdiction such as the Cayman Islands or in jurisdictions in which interests in such pooled investment vehicles are marketed, such as Denmark, Sweden or Switzerland. As discussed more fully in Item 11, Tetragon and clients of Tetragon Partners may engage in transactions with or alongside each other that have and may in the future give rise to material conflicts of interest. As discussed in Item 11, TFM has adopted policies and procedures designed to address conflicts of interest arising between TFM and its affiliates. Services Agreements between TFM and Certain Subsidiaries of Tetragon Partners Since the 2015 inception of the Tetragon Credit Partners business as part of Tetragon Partners, TFM has provided certain services to the general partners of the Tetragon Credit Partners vehicles. These services are limited to the participation by the TFM Principals (Reade Griffith and Paddy Dear) in the Investment & Management Committees and Risk Committees of such general partners. TFM does not charge any fees for such services. Personnel who provide services to Tetragon Credit Partners vehicles will have a conflict in allocating their time and services. See Item 11 Management of Tetragon for additional information.

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Futures Commission Merchant, Commodity Pool Operator or Commodity Trading Adviser Registration Status As a result of providing investment advisory services to certain clients that invest in commodity futures and other commodity interests, TFM and certain affiliated and related entities may from time to time constitute commodity trading advisors and/or commodity pool operators for the purpose of the rules and regulations issued by the U.S. Commodity Futures Trading Commission (CFTC) under the U.S. Commodity Exchange Act (Commodity Exchange Act) and as such, will rely on certain exemptions from registration with the CFTC under the Commodity Exchange Act or, in the event that such exemptions cease to apply, register under the applicable regulatory regime. TFM and its management persons are not registered, and do not have any application to register as a futures commission merchant or associated persons of futures commission merchant. TFM and its management persons are not registered, and do not have any application to register as a commodity pool operator with the CFTC.

Code of Ethics TFM has adopted a written Code of Ethics (the Code) that is applicable to all employees of TFM and any other persons who are subject to its supervision and control, or collectively, TFM Personnel. The Code, which is designed to comply with Rule 204A-1 under the Investment Advisers Act of 1940 as amended, (the Advisers Act), establishes guidelines for professional conduct and personal trading procedures, including certain pre-clearance and reporting obligations. Under certain limited circumstances, subject to the terms of the Code, TFM Personnel and their families and households may purchase investments for their own accounts, including the same investments as may be purchased or sold for the Clients. Under the Code, TFM Personnel are also required to file certain periodic reports with TFM’s Chief Compliance Officer as required by Rule 204A-1 under the Advisers Act. The Code helps TFM detect and prevent potential conflicts of interest. TFM Personnel who violate the Code may be subject to remedial actions, including, but not limited to, profit disgorgement, fines, censure, demotion, suspension or dismissal. TFM Personnel are also required to promptly report any violation of the Code of which they become aware. TFM Personnel are required to annually certify compliance with the Code. A copy of the Code will be provided to clients and their existing or prospective investors upon request. To request a copy, please email TFM’s Legal, Regulatory and Compliance team at legal@tetragoninv.com. Participation or Interest in Client Transactions TFM and certain employees and affiliates of TFM are shareholders of Tetragon. TFM is authorized to enter into transactions on behalf of Tetragon with persons who are affiliates of TFM, provided that in connection with any such transaction that exceeds $5 million of aggregate investment, TFM obtains either (i) the approval of a majority of the members of the Board -41-

Directors of Tetragon that do not have a material interest in such transaction (whether as part of a Board of Directors resolution or otherwise) or (ii) an opinion from a recognized investment bank, auditing firm or other appropriate professional firm substantively to the effect that the financial terms of the transaction are fair to Tetragon from a financial point of view. For further details regarding these arrangements, as well as conflicts of interest presented by them, please see “Conflicts of Interest” immediately below. Due in part to the fact that potential investors in Tetragon may ask different questions and request different information, TFM in certain circumstances provides certain information to one or more prospective investors that it does not provide to all of the prospective investors or shareholders. Conflicts of Interest TFM and its related entities engage in a broad range of activities, including investment activities for their own account and for the account of other investment funds, and providing transactionrelated, investment advisory, management and other services to funds and operating companies. In the ordinary course of conducting its activities, the interests of Tetragon will, from time to time, conflict with the interests of TFM, Other Funds or their respective affiliates. Certain of these conflicts of interest, as well as a description of how TFM addresses such conflicts of interest, can be found below. The material conflicts of interest encountered by Tetragon include those discussed below, although the discussion below does not necessarily describe all of the conflicts that may be faced by Tetragon. Other conflicts may be disclosed throughout this brochure and the brochure should be read in its entirety for other conflicts. For the purposes of the conflicts of interest described below TFM Personnel shall also include members of Tetragon’s Board of Directors. Resolution of Conflicts In the case of all conflicts of interest, TFM’s determination as to which factors are relevant, and the resolution of such conflicts, will be made using TFM’s best judgment, but in its sole discretion. In resolving conflicts, TFM considers various factors, including the interests of Tetragon with respect to the immediate issue and/or with respect to its longer-term courses of dealing. Certain procedures for resolving specific conflicts of interest are set forth below. When conflicts arise, the following factors generally mitigate, but will not eliminate, conflicts of interest: (1)

TFM will consider the appropriateness of an investment from the viewpoint of Tetragon;

(2)

Many important conflicts of interest will generally be resolved by set procedures, restrictions or other provisions contained in Tetragon’s Governing Documents;

(3)

On any issue involving actual conflicts of interest, TFM will be guided by its good faith discretion;

(4)

Where TFM deems appropriate, unaffiliated third parties may be used to help resolve conflicts, such as the use of an investment banker to opine as to the fairness of a purchase or sale price; -42-

(5)

TFM has adopted and implemented certain policies and procedures designed to reduce certain conflicts of interest;

(6)

Tetragon’s shareholders receive information relating to significant potential conflicts of interest arising from the proposed activities of Tetragon; and

(7)

TFM and certain of its affiliates have adopted written policies establishing information “walls” designed to limit communication between certain business units investing in equity securities and debt securities of companies. These policies restrict the transfer of confidential information between these business units, subject to certain exceptions provided in the policies. These policies also establish procedures for communications among employees of different business units to guard against unlawful and inappropriate disclosure of material, nonpublic information.

While TFM endeavors to resolve all conflicts in a fair and impartial manner, there can be no assurance that its own interests will not influence its conduct and decisions. There can be no assurance that TFM will identify or resolve all conflicts in a manner that is favorable to Tetragon and Tetragon’s shareholders may not be entitled to receive notice or disclosure of the actual occurrence of conflicts or have any right to consent to them as they arise. Allocation of Investment Opportunities In connection with its investment activities, TFM may encounter situations in which it must determine how to allocate investment opportunities (including follow-on investments) among various clients and other persons, which may include, but are not limited to, the following:

Tetragon;

Funds and accounts that are managed by related advisers of Tetragon, including those of Tetragon Partners and its affiliates, as well as proprietary accounts of TFM and its affiliates (collectively, the Other Funds);

Any co-investors or co-investment vehicles that have been formed to invest side-by-side with Tetragon in all or particular transactions entered into by Tetragon (the co-investors or investors in such co-investment vehicles which may include employees, business associates and other “friends and family” of TFM, its affiliates or their personnel (including any related entity established by any of the foregoing, such as trusts, charitable programs, endowments or related programs, family investment vehicles and other estate planning vehicles) (collectively, TFM Related Parties) and/or individuals and entities that are not shareholders of Tetragon (Third Parties));

TFM Related Parties and/or Third Parties that wish to make direct investments (i.e., not through an investment vehicle) side-by-side with one or more Funds in particular transactions entered into by such Fund(s); and

TFM Related Parties and/or Third Parties acting as “co-sponsors” with TFM with respect to a particular transaction. -43-

TFM makes allocation determinations consistent with Tetragon’s Governing Documents and the organizational or offering documents of any applicable Other Funds, advisory agreements and/or side letter agreements negotiated with investors in the applicable Other Fund (such documents collectively, an Other Fund’s Organizational Documents) and in accordance with its written policies and procedures. Tetragon and the Other Funds are generally subject to investment allocation requirements (collectively, Investment Allocation Requirements). Investment Allocation Requirements are generally set forth in Tetragon’s Governing Documents or the Other Fund’s Organizational Documents. To the extent the Investment Allocation Requirements of Tetragon or an Other Fund do not include specific allocation procedures and/or allow TFM discretion in making allocation decisions among Tetragon and the Other Funds, TFM will follow the process set forth below. TFM must first determine if Tetragon and/or the Other Funds and/or other parties are eligible to participate in an investment opportunity. TFM assesses whether an investment opportunity is appropriate for Tetragon or a particular Other Fund(s), based on Tetragon’s or the Other Fund’s investment objectives, strategies and structure, which are typically reflected in Tetragon’s Governing Documents or such Other Fund’s Organizational Documents. Prior to making any allocation to Tetragon or an Other Fund of an investment opportunity, TFM determines what additional factors may restrict or limit the offering of an investment opportunity to Tetragon or an Other Fund. Possible restrictions include, but are not limited to:

Obligation to Offer: TFM may be required to offer an investment opportunity to Tetragon or to one or more Other Funds.

Related Investments: TFM may offer an investment opportunity related to an investment previously made by Tetragon or an Other Fund(s) to Tetragon or such Other Fund(s) to the exclusion of, or resulting in a limited offering to, Tetragon or other Other Funds.

Legal and Regulatory Exclusions: TFM may determine that Tetragon or certain Other Funds or investors in such Other Funds should be excluded from an allocation due to specific legal, regulatory and contractual restrictions placed on the participation of such persons in certain types of investment opportunities.

Once TFM identifies that Tetragon and/or an Other Fund or Other Funds are eligible to participate in a particular investment, TFM, in its discretion, decides how to allocate such investment opportunity among Tetragon and/or the identified Other Funds. In allocating such investment opportunity, TFM may consider some or all of a wide range of factors, which include, but are not necessarily limited to, one or more of the following:

the potential for the proposed investment to create an imbalance in Tetragon’s or an Other Fund’s portfolio;

cash balances, liquidity requirements of Tetragon or Other Funds or anticipated cash flows (including as a result of subscriptions and redemptions or withdrawals, as applicable);

any need to re-size risk in Tetragon’s or an Other Fund’s portfolios; -44-

investment strategy or objective;

the respective investment programs;

account size and gross portfolio size;

available capital;

relative exposure to short-term and long-term market trends;

existing portfolio positions;

existing portfolio liquidity;

other factors known to the relevant portfolio manager that may affect Tetragon’s or an Other Fund’s trading ability;

current or prospective tax burdens or other tax considerations;

regulatory or accounting rules or treatment;

other regulatory restrictions that would or could limit Tetragon’s or an Other Fund’s ability to participate in the proposed investment opportunity;

hedging needs;

risk tolerance and risk capacity;

general current financial market liquidity;

regulatory and tax status;

concentration of investments;

applicable investment restrictions;

available transaction terms;

available financing;

execution costs;

anticipated capital outflows or inflows due to upcoming quarter end or month end redemptions or commitments;

requested order size;

real time net asset value and/or commitment amounts; -45-

percentage of assets under management (AUM) that the particular investment represents and percentage of AUM that the particular investment represents as compared to Tetragon or an Other Fund, using the most current AUM information as may be practicably obtained;

minimum allocation criteria;

round lots;

requested allocation or trade amount, or other relevant investment criteria or investment limitations as determined by the applicable portfolio manager or any of TFM’s senior management committees; or

any other investment factors TFM believes in its sole discretion to be relevant.

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Factors Considered in Selecting or Recommending Broker-Dealers for Client Transactions TFM is responsible for choosing the brokers, dealers and counterparties (each for purposes of this section, a broker) used to execute securities transactions on behalf of TFM’s clients, subject to TFM’s obligation to obtain the best commission price and execution on any particular transaction. In selecting brokers, the determinative factor is not always the lowest possible price or commission, but whether TFM believes that the transaction represents the best execution for the client. In making such determination, TFM may weigh a combination of the following factors, which include, but are not limited to:

financial stability and capital adequacy (e.g., satisfaction of Financial Industry Regulatory Authority’s (FINRA) minimum net capital requirements, etc.);

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whether the broker is a wholly owned subsidiary of a larger financial institution and/or whether its trades are cleared through a stronger third party (i.e., a party with significant financial backing); regulatory and disciplinary history (e.g., FINRA’s Central Registration Depository Disclosure Reporting Page, monetary fines or settlements); execution capability (e.g., speed of execution, history of securing best price and competitive transaction charges); the broker’s operational efficiency including its ability to complete the transaction satisfactorily through to clearance, confirmation and delivery; the value of the research provided and other research assistance first calls and providing useful ideas and market color; access to underwritten offerings and secondary markets; responsiveness and qualifications, professionalism and diligence of personnel (e.g., responsiveness to TFM); direct telephone lines from TFM to broker-dealers; institutional references from senior traders; trading experience (e.g., the broker’s expertise in effecting difficult trades in less liquid, smaller capitalized and more closely held issues); a broker’s willingness to enter into difficult transactions, including transactions in which the broker’s capital is put at risk; providing access to issuers; whether the broker possesses special abilities that have been demonstrated to add value to Tetragon’s portfolios (e.g., broker-dealer provides anonymity and has a reputation for integrity when handling transactions and maintaining confidentiality); and the facilities that the broker makes available (including trading networks, access to multiple floor brokers and markets and significant resources for positioning as principals).

TFM will seek competitive commissions and spreads; however, it does not necessarily obtain the lowest possible per transaction rate. TFM will only consider factors relevant to a specific transaction in determining best execution. Broker commissions are monitored on an ongoing basis by portfolio managers, TFM’s Finance Group and the TMSCC. Prime Brokers TFM engages the services of certain prime brokers. The services provided by prime brokers to TFM include custody, execution, stock borrowing, clearing, financing, settlement, banking, foreign exchange, reporting and other related services. TFM reserves the right to change the prime brokerage and custodian arrangements and/or, in its discretion, to appoint additional or alternative prime brokers from time to time.

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As a custodian, a prime broker is responsible for the safekeeping of all investments and other assets of TFM that are delivered to it in accordance with applicable rules and regulations and the terms of its respective prime brokerage agreement. Custodied assets are held in a manner such that they can be identified at any time by the prime broker as belonging to Tetragon) and as separate from such prime broker’s own assets. Custodied assets held as collateral or on margin are generally not segregated from the prime broker’s own assets and in the event of the prime broker’s insolvency may not be recoverable in full. Cash held for Tetragon by a prime broker generally will not be treated as client money and will not be segregated from the cash of the prime broker. As a consequence, TFM ranks as a general creditor of such prime broker in the event of its insolvency with respect to such cash. Furthermore, in the event that any of the custodied assets are registered in the name of a prime broker where, due to the nature of the law or market practice of that jurisdiction, it is in TFM’s best interests to do so or it is not feasible to do otherwise, such custodied assets will also not be segregated from the prime broker’s own securities and in the event of the prime broker’s default may not be as well protected. TFM may agree to indemnify each of the prime brokers against any expenses, costs, losses, damages and liabilities which a prime broker may sustain in providing these services, except where the same are incurred as a direct result of the fraud, willful default, negligence of, or breach of the relevant prime brokerage agreement by the prime broker. Trade Management Supervisory and Compliance Committee (TMSCC) In addition to the continuous supervision of assigned portfolios and accounts by relevant persons, TFM has also established a TMSCC to provide additional supervision and monitoring of trading activities. The TMSCC generally meets quarterly and is comprised of representatives from the following groups: investment professionals, operations, legal, compliance, risk and finance. The TMSCC has the following responsibilities:

establish and maintain TFM’s list of approved traders;

approve broker-dealers through which TFM’s traders may execute client trades, authorizing the removal of brokers from the list of approved brokers (Approved Broker List) and maintain the current Approved Broker List;

evaluate the performance of broker dealers on the Approved Broker List including commission rates, execution services, reliability and coverage;

review brokerage allocation;

review and approve any soft dollar arrangements;

review proxy voting;

review trade errors and determine whether any remedial actions are required;

review allocation of investment opportunities and aggregation of client trades;

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review securities regulations, or changes and amendments thereto, related to trading;

review trade errors, trade breaks and failed trades;

review of research usage;

review of relevant legal, regulatory and compliance matters; and

ensure adequate internal controls are maintained over TFM’s trades and trading activities and general compliance infrastructure.

Research and Other “Soft Dollars” An investment adviser or its related persons may receive products and services in addition to brokerage services from a broker-dealer only in a manner consistent with (i) the safe harbor created by Section 28(e) of the Securities Exchange Act of 1934, as amended, and (ii) the firm’s duty to seek best execution for its clients. Services that an investment adviser may receive from such broker-dealers may include research, general market commentary, economic information, trading advice, industry and company commentary, technical data, recommendations, general reports, quotations and other market data or information and the arrangement of meetings with the management of issuers. An investment adviser benefits from these arrangements because it does not have to produce or pay for the research, products or services received. The investment adviser may have an incentive to select or recommend a broker-dealer based on its interest in receiving soft dollar benefits rather than on clients’ interest in receiving most favorable execution. As a result of an investment adviser’s soft dollar practices, clients may be required to pay higher commissions than those charged by other broker-dealers in return for soft dollars. The services received from broker-dealers and paid for by a client may be used by an investment adviser’s related persons, including in servicing other clients. Research and other soft dollar benefits may not always be utilized for the specific client that generated the soft dollar benefits, or in direct proportion to the value paid by each client. Additionally, it may not be possible to place a dollar value on the quality of executions or the soft dollar benefits that the firm receives from brokerdealers effecting client transactions. Accordingly, broker-dealers selected by a firm may be paid commissions for effecting portfolio transactions for client accounts in excess of amounts other broker-dealers would have charged for effecting similar transactions, if a firm determines in good faith that such amounts are reasonable in relation to the value of the soft dollar benefits provided by those broker-dealers, viewed either in terms of a particular transaction or the firm’s overall duty to discretionary accounts. TFM does not currently enter into “soft dollar” arrangements with its broker-dealers, including for mixed-use products and services. To the extent TFM considers use of “soft dollar” arrangements TFM would amend its policies to ensure compliance with the applicable rules and regulations pertaining to these arrangements, and will only enter into arrangements within the Section 28(e) safe harbor requirements.

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Aggregation of Orders From time to time, TFM and/or its affiliates may purchase or sell the same security for several clients at approximately the same time. On such occasions, TFM can (but is not obligated to) combine or “bunch” such orders in order to secure certain efficiencies and results with respect to execution, clearance and settlement of orders. When a bunched order is completely filled, each participating account will generally participate at the average price paid or received on that day for the bunched order, and share in any associated transaction costs, based upon the initial amount requested for the account. When a bunched order is only partially filled, the securities purchased are allocated on a pro rata basis to each client participating in the bunched order based upon the initial amount requested for the client, subject to certain exceptions, and each participating client participates at the average share price for the bunched order on the same day. Furthermore, TFM and its affiliates will bunch orders in a manner designed to ensure that no particular client or account is favored and that participating clients are treated in a fair and equitable manner over time. Additionally, in bunching orders, TFM will act in a manner it believes is equitable for clients.

For details regarding economic benefits provided to TFM by non-clients, including a description of related material conflicts of interest and how they are addressed, please see Item 11 above.

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Although currently there are no such arrangements in place, TFM may in the future engage one or more persons to act as a placement agent for Tetragon in connection with the offer and sale of interests to certain potential investors. Item 15

Custody

TFM’s Investment Committee is responsible for the investment management of Tetragon’s portfolio. The investment committee currently sets forth the investment strategy and approves each significant investment by Tetragon. The Investment Committee meets periodically and has an extended meeting monthly. TFM’s Risk Committee is currently responsible for the risk management of the portfolio and the business and performs active and regular oversight and risk monitoring. The Risk Committee meets periodically and has an extended meeting monthly. Tetragon’s portfolio is reviewed on a regular basis by our investment and risk committee, as discussed above, and the Chief Financial Officer and the Chief Compliance Officer, among others who also review the portfolio on a regular basis. These reviews are designed to, among other things, monitor and analyze transactions, positions, investment levels and portfolio risk. The firm’s investment professionals meet regularly to review, among other things, global market conditions, potential risks in the capital markets as well as country, sector, industry or firm level risk factors. Investors in Tetragon are furnished with annual financial statements examined by independent auditors. Tetragon also generally furnishes such investors (via a press release) with written monthly and quarterly reports describing Tetragon’s performance.

TFM has discretionary authority to manage Tetragon based on the Governing Documents. TFM has the authority to determine the investment strategy to be pursued in furtherance of the investment objective, which strategy may be changed from time to time by TFM in its discretion.

Rule 206(4)-6 under the Advisers Act requires registered investment advisers that exercise voting authority over client securities to implement proxy voting policies. Because TFM may be deemed to have authority to vote proxies relating to the companies in which it may invest on behalf of our clients, it has adopted a set of policies and procedures in compliance with such rules. To the extent that TFM exercises or is deemed to be exercising voting authority over its clients’ securities, the policy is designed and implemented in a manner reasonably expected to ensure that voting with respect to proxy proposals, amendments, consents or resolutions, or collectively proxies, is exercised in a manner that seeks to serve the best interest of TFM’s clients. From time to time, conflicts may arise between the interests of a client, on the one hand, and TFM’s (or of its affiliates’) interests, on the other hand. If TFM determines that it has, or may be perceived to have, a conflict of interest when voting a proxy, it will seek to address matters involving such conflicts of interest on a case-by-case basis in a fair and equitable manner, subject to legal, regulatory, contractual or other applicable considerations. TFM, in its sole discretion, may elect not to vote a proxy if unduly burdensome. The TMSCC reviews all proxies relating to client accounts as a part of its evaluation and meeting process. Records relating to proxy voting and copies of TFM’s proxy voting policies are available to investors upon request. To request a copy, please email the Legal, Regulatory and Compliance team at legal@tetragoninv.com. Item 18

Financial Information

Item 19

Requirements for State-Registered Advisers