Troluce Capital Advisors LLC

Troluce Capital Advisors, LLC (the “Firm”) is a Puerto Rico (USA) limited liability company that was formed in January 2021. The Firm is principally owned and controlled by Jared Dubin, the Firm’s Chief Investment Officer (the “Principal”). The Firm provides discretionary investment advice to the following private funds (together, the “Private Funds”): (i) Troluce Master Fund, LP (the “Master Fund”), (ii) Troluce Offshore Fund, LTD (the “Offshore Fund”), (iii) Troluce Onshore Fund, LP (the “Onshore Fund”), (iv) Troluce Nexus Fund LP. The Firm also provides discretionary investment advice to Troluce Special Opportunities II, LP and the Troluce Veridian Onshore Fund, LP (the “Special Opportunity Funds” and collectively with the Private Funds, the “Funds”). The Firm also provides sub-advisory services to private funds (the “Sub-Advised Funds”) and separately managed accounts for institutional, non-retail investors (the “SMAs”) which pursue strategies similar to the Funds. References throughout this document to “Clients” refer to the Funds, Sub-Advised Funds, and SMAs, and any other funds or accounts that the Firm may advise in the future. Client accounts are managed in accordance with their own investment and trading objectives, as described in their respective offering documents, investment advisory agreements and governing agreements (collectively, the “Governing Documents”). The Firm generally will not permit investors in the Funds to impose limitations on the investment activities described in the Funds’ Governing Documents. Under certain circumstances, the Firm may contract with a client to adhere to limited risk and/or operating guidelines imposed by that client. The Firm would negotiate such arrangements on a case-bycase basis. (See Item 16 - Investment Discretion.) Troluce Funds GP, LLC, Troluce Funds GP II, LLC, and Troluce Opportunities GP II, LLC (collectively “Troluce GPs”) are three of the Firm’s related persons) serves as the general partners to certain Funds. The Firm does not participate in wrap fee programs. As of December 31, 2025, the Firm managed $2,242,396,280 of regulatory assets on a discretionary basis. The Firm does not manage any assets on a non-discretionary basis.

Fees Generally The Firm’s fees and compensation are described in each client’s Governing Documents. All of the Firm’s clients are expected to be “qualified purchasers” (as defined in Section 2(a)(51) of the Investment Company Act of 1940, as amended). The Funds The Firm is paid management fees from the Funds, typically, quarterly in advance. The management fee generally ranges from 1.00% - 1.75%. Management fees are prorated in the case of a partial calendar period. The Firm deducts such management fees from each Fund. The Firm may waive or modify the management fee payable with respect to any investor and has done so for the Firm’s related parties and the Firm’s employees.

Troluce GPs receive performance-based allocations from their respective Funds, as further described in Item 6 – Performance-Based Fees and Side-By-Side Management. The Firm’s compensation schedule with respect to any future client account will be contained in the Governing Documents relating to such account. The SMAs The SMAs pay the Firm management fees on a monthly basis. Generally, management fees would be prorated if the advisory agreement with an SMA were terminated. The SMAs’ management fees are invoiced to, and paid by, the SMAs. The Firm is also entitled to receive performance-based fees from the SMAs, as further described in Item 6 – Performance-Based Fees and Side-By-Side Management. The Sub-Advised Funds The Sub-Advised Funds pay the Firm a management fee equal to a percentage of the dollar amount of trading capacity allocated to the Sub-Advised Fund and is paid on a monthly basis. Management fees would be prorated if the advisory agreement relating to the Sub-Advised Fund were terminated. The SubAdvised Funds’ management fees are invoiced to, and paid by, the Sub-Advised Fund. The Firm is entitled to receive performance-based fees from the Sub-Advised Funds, as further described in Item 6 – Performance-Based Fees and Side-By-Side Management. Expenses Generally The Funds bear their own organizational and operating expenses, including, without limitation: (a) organizational and offering expenses; (b) expenses associated with all investments and transactions considered, evaluated and/or consummated by the Funds, or any such trading vehicles, including subsidiaries, intermediate funds and/or special purpose vehicles, as well as overall consideration and evaluation of such entities’ portfolio, including, without limitation, those expenses incurred before the initial closing of the Funds, including, without limitation, expenses associated with sourcing, negotiating, investigating, researching, financing and structuring of investments and potential investments, whether or not consummated, including, without limitation, data and research on-boarding, ingestion, aggregation, and analysis, third-party research, data, analytics, modeling, risk, structuring, pricing, execution and other third-party information, technology, hardware, software or other technology systems, including, without limitation, installation and maintenance, software and service fees (including, without limitation, the expenses with respect to data, data feeds, subscriptions, expert networks, political intelligence providers and reports); (c) the costs of research-related computer hardware and software expenses, including, without limitation, Bloomberg terminals and subscriptions and other market information systems, as well as the costs of research management systems and corporate access tracking systems; (d) the costs of the Firm’s portfolio management system and any other software used for accounting and/or monitoring of the portfolio, including, without limitation, subscriptions relating to, among other things, trading and order management systems and services; (e) expenses associated with holding, financing, monitoring, hedging, maintaining and disposing of all investments and all transaction and other costs associated therewith, including, without limitation, expenses associated with proxy research and voting services; (f) travel and related expenses associated with investments and potential investments; (g) professional fees associated with investments and potential investments, including,

without limitation, consulting, due diligence, accounting, valuation, financial, legal and other advisory fees and expenses; (h) transaction fees, brokerage commissions, custodial fees, clearing and settlement charges and similar fees and expenses associated with the acquisition, disposition and settling of investments and potential investments, including, without limitation, fees, expenses and commission paid in connection with outsourced trading; (i) expenses associated with legal and regulatory filings of the Funds or such trading vehicles, including subsidiaries, intermediate funds and/or special purpose vehicles in the United States, the Cayman Islands, or in any other jurisdiction, including, without limitation, pursuant to Sections 13 and 16 of the U.S. Securities Exchange Act of 1934, as amended (the “Exchange Act”), as well as the expenses associated with preparation and filing of the Firm’s Form 13F, Form 13H, and Form PF, if applicable, and any other similar filing in any other U.S. or non-U.S. jurisdiction; (j) administrative, custodial, appraisal, valuation, legal, regulatory, compliance, consulting, advisory and similar fees, and expenses associated with the Funds’ or such trading vehicles’, including subsidiaries’, intermediate funds’ and/or special purpose vehicles’ operations, investments and transactions, including, without limitation, fees and expenses of the Fund administrator; (k) expenses incurred in connection with responding to requests or inquiries from any U.S. federal, state, local or non-U.S. governmental entity or authority, regulatory body or self-regulatory organization with respect to the Funds or such trading vehicles, including subsidiaries, intermediate funds and/or special purpose vehicles; (l) broken-deal, failed transaction, break-up and similar fees, costs and expenses (if any); (m) costs and expenses of leverage or any other borrowings of the Funds, or such trading vehicles, including subsidiaries, intermediate funds and/or special purpose vehicles, including, without limitation, interest charges and fees; (n) expenses incurred in the collection of monies owed to the Funds, or such trading vehicles, including subsidiaries, intermediate funds and/or special purpose vehicles, as applicable; (o) auditing and accounting expenses, including, without limitation, expenses associated with the preparation of financial statements, tax returns, and Schedules K-1, and the fees and expenses of the auditor; (p) any taxes, fees or other governmental charges; (q) directors’ fees and expenses; (r) costs and expenses associated with investor communications and reports and the delivery thereof to investors; (s) the costs of service providers or software to measure or monitor risk metrics, to aggregate positions and/or to provide reporting with respect to risk metrics and/or positions; (t) costs and expenses associated with meetings of the investors, including, without limitation, the reasonable costs of the Firm’s travel to such meetings; (u) insurance expenses, including, without limitation, general partner liability insurance and other policies, if any, including directors’ and officers’ liability insurance and errors and omissions insurance; (v) costs and expenses (including, without limitation, taxes, fees or other governmental charges) associated with the formation, organization and operation of any trading vehicles, including subsidiaries, intermediate funds and/or special purpose vehicle, alternative investment vehicle, holding company or similar entity formed with respect to investments, credit facilities or other transactions entered into for the benefit of the Funds or such trading vehicles, including subsidiaries, intermediate funds and/or special purpose vehicles; (w) wind-up, liquidation, termination and dissolution expenses; (x) costs, fees, and expenses related to registration, qualification and/or exemption under any applicable U.S. federal, state, local or non-U.S. laws, rules or regulations, including, without limitation, blue sky fees, Form D, Form 8.3, CFTC filings and notices and other securities and/or investment related filing expenses; (y) costs related to any transfers of interests, unless otherwise charged to or borne by the applicable transferor and/or transferee; (z) expenses incurred in connection with the preparation of, and any amendment to the Governing Documents, as well as the preparation of, compliance with, and amendment to any side letter entered into by the Funds; (aa) expenses incurred in connection with pursuing, defending or participating in any litigation, arbitration, mediation or similar proceeding by the Funds, the Master Fund or any such trading vehicles, including subsidiaries, intermediate funds and/or special purpose vehicles; (bb) any extraordinary expenses (including, without limitation, all litigation-related and indemnification and contribution expenses, including, without limitation, the amount of any judgment or settlement paid in

connection therewith); (cc) fees of the independent members of any advisory committee or governance board; (dd) fees of the independent members of any advisory committee; (ee) the management fee; and (ff) all other fees, costs, charges and expenses associated with the business, affairs and/or operations of the Funds, or such trading vehicles, including subsidiaries, intermediate funds and/or special purpose vehicles, including, without limitation, any other cost that may otherwise be paid with soft dollars pursuant to Section 28(e) of the Exchange Act. Generally, all expenses borne by the Funds, other than the management fee and any expenses that the respective board of directors, Investment Manager, or governing documents (collectively, the “Governing Body”) determines should be allocated to a particular investor or investors (e.g., investor-related taxes), will be charged to all the investors on a pro rata basis. The Governing Body may, however, allocate expenses on another basis, including by allocating certain expenses to certain (which may be less than all) investors, if the board of directors determines that such an allocation is more equitable or otherwise required by applicable law, rule or regulation. In addition, any Fund expenses attributable solely to investments in “new issues” will be allocated solely to those investors who participate in the relevant investments with respect to their relative interest in such investments. Further, the Governing Body will have the right to charge any investor, and not treat as a Fund expense, any expense attributable to a single investor a group of investors. Certain Funds do not have a pre-determined limit on its ordinary or extraordinary operating expenses. The Funds’ actual annual operating expenses are disclosed in the Funds’ year-end audited financial statements, which are provided to each Investor. However, certain Funds are subject to an annual expense cap, which are set as either a fixed dollar amount or a percentage of the Fund’s monthly gross asset value. If a Fund’s ordinary expenses exceed the expense cap, the Investment Manager will absorb the excess amounts. To the extent that expenses to be borne by the Funds are paid by the Troluce GPs or the Firm, the Funds will reimburse such party for such expenses. To the extent that Fund expenses are attributable to multiple clients of the Firm, such amounts are allocated in accordance with the Firm’s expense allocation policy, pursuant to which the Firm generally allocates such expenses pro rata based upon the respective net asset values of such applicable clients. Notwithstanding the foregoing, the Firm may make non-pro rata allocations as it determines in its good faith discretion. To the extent that a client benefits from an item that is chargeable to other clients, but is not permitted to incur such expense under its Governing Documents, the Firm will bear such client’s pro rata portion of the expense. The Firm may also allocate a portion of certain clients’ capital to money market funds or exchange-traded funds. In addition to the fees and expenses discussed above, clients will indirectly incur similar fees and expenses if the Firm invests their capital in such funds, as these funds in turn pay similar fees and expenses to their investment managers and other service providers. For a more detailed discussion of brokerage and transaction costs, see Item 12 - Brokerage Practices.

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Methods of Analysis and Investment Strategies Generally The Private Funds The investment objective of the Private Funds is to seek to generate superior risk-adjusted absolute returns through the combination of a deep, quantitative, research process coupled with risk-controlled portfolio construction. The Firm employs global, low beta, long/short equity, long/short credit, and special situations strategies, pursuant to which it invests, long and short, in publicly-traded equities, equity-related instruments, and credit instruments, across all market capitalizations, though the Private Funds intend to invest

predominantly in U.S. and European-listed mid-and large capitalization companies. Capital is invested across the different strategies and products based on the perceived alpha potential of the opportunity set. The broad mandate allows the Investment Manager to take an opportunistic approach to investing, including by adjusting the size of the portfolio to reflect prevailing market conditions. Quantitative models, which are abstract descriptions of computer codes that process price and securities data from public markets exchanges and other sources, identify investments in products with attractive risk-reward profiles. Outputs of quantitative models may be combined with the Principal’s investment judgment to select the final constituents of the portfolio. The purchase and sale of investment products are predominantly executed through electronic channels, though human involvement in soliciting bids and offers for specific instruments may be used when trading larger notional positions, or for trading instruments derivatively priced or otherwise unavailable for purchase through electronic means. Special situations are the set of investment opportunities presented by corporate actions and changes in companies’ capital structures. The Firm regularly invests in companies undergoing such processes, with the goal of identifying mispricings in one or more related securities. The Firm employs strategies that cause the Private Funds to frequently buy and sell investment products. Decisions on the frequency with which to buy and sell are done commensurate with the Firm’s goal of producing superior risk-adjusted absolute returns. The Special Opportunity Funds The investment objective of the Special Opportunity Funds is to invest in a single investment thesis. Investments in the Special Opportunity Funds involve significant risks. Since the Special Opportunity Funds will have (direct or indirect) exposure to only one core investment and no other investments will be pursued, losses incurred in connection with the investment would have a material adverse effect on the Special Opportunity Funds. Absence of diversity could expose the Special Opportunity Funds to losses disproportionate to general market movements if there are disproportionately greater adverse price movements in the investment. The Special Opportunity Funds would therefore be subject to a significantly greater degree of risk with respect to the failure or downturn of the investment than it would be if it maintained a more diversified portfolio. It is possible that in some cases such a downturn will result in the Special Opportunity Funds losing its entire investment in the investment. Future Client Accounts The Firm expects that future client accounts would pursue various strategies, some of which could be the same or similar strategies as the Private Funds, as set forth above. The above description of the Firm’s investment strategies, techniques, methods and processes is intended only as a general overview and is subject to the specific terms of the written agreements with clients. Investing in securities involves risk of loss that clients and investors should be prepared to bear. Risk Factors An investment with the Firm will be speculative and will involve a high degree of risk. There can be no assurance that the investment objectives of any client account will be achieved or that a client account

will generate positive returns. Prospective clients and investors are strongly urged to review the applicable Governing Documents carefully and consult with their own financial, legal and tax advisers before investing with the Firm. A discussion of the material risks is provided below. Risks Relating to Operations, Investing, and Trading Activities of the Clients The Client accounts are managed in accordance with their respective investment and trading objectives, as set forth in their Governing Documents. As the Clients pursue different investment strategies, the risks relating to its operations and investment activities may vary. While certain of the risks described below may apply to all Clients, others may be more specific to particular Clients, strategies, or investment programs. The risks described herein are not intended to be exhaustive. Legal and Regulatory Environment for Private Investment Funds and their Managers. The legal and regulatory environment worldwide for private investment funds (such as the Clients) and their managers is evolving. Changes in the regulation of private investment funds, their managers, and their trading and investing activities may have a material adverse effect on the ability of the Clients to pursue its investment program and the value of investments held by the Clients. There has been an increase in scrutiny of the private investment fund industry by governmental agencies and self-regulatory organizations. New laws and regulations or actions taken by regulators that restrict the ability of the Clients to pursue its investment program or employ brokers and other counterparties could have a material adverse effect on the Clients and the Investors’ investments therein. In addition, the Firm may, in its sole and absolute discretion, cause the Clients to be subject to certain laws and regulations if it believes that an investment or business activity is in the Clients’ interest, even if such laws and regulations may have a detrimental effect on one or more Investors. Regulatory Risks Applicable to High-Frequency Trading Strategies. A recent increase in governmental and regulatory scrutiny has focused on investment funds that operate high-frequency trading strategies and automated or computer-based trading. Such scrutiny has and can in the future lead to costly investigations, litigation, legislative testimony, loss of reputation, fines and settlements, and could also result in additional severe consequences. Systems and Operational Risks Generally. The Clients depend on the Firm to develop and implement appropriate systems for the Clients’ activities. The Clients relies heavily and on a daily basis on financial, accounting and other data processing systems to execute, clear and settle transactions across numerous and diverse markets and to evaluate certain securities, to monitor its portfolio and capital, and to generate risk management and other reports that are critical to oversight of the Clients’ activities. In addition, the Clients rely on information systems to store sensitive information about the Clients, the Firm, their affiliates and the Investors. Certain of the Clients’ and the Firm’s activities will be dependent upon systems operated by third parties, including prime brokers, the administrator, market counterparties and other service providers, and the Firm may not be in a position to verify the risks or reliability of such third-party systems. Failures in the systems employed by the Firm, prime brokers, the administrator, counterparties, exchanges and similar clearance and settlement facilities and other parties could result in mistakes made in the confirmation or settlement of transactions, or in transactions not being properly booked, evaluated or accounted for. Disruptions in the Firm and/or Clients’ operations may cause the Clients to suffer, among other things, financial loss, the disruption of its business, liability to third parties, regulatory intervention or reputational damage. Any of the foregoing failures or disruptions could have a material adverse effect on the Clients and the Investors’ investments therein.

Cybersecurity Risk. As part of its business, the Firm processes, stores and transmits large amounts of electronic information, including information relating to the transactions of the Clients and personally identifiable information of the Investors. Similarly, service providers of the Firm or the Clients, especially the administrator, may process, store and transmit such information. The Firm has procedures and systems in place that it believes are reasonably designed to protect such information and prevent data loss and security breaches. However, such measures cannot provide absolute security. The techniques used to obtain unauthorized access to data, disable or degrade service, or sabotage systems change frequently and may be difficult to detect for long periods of time. Hardware or software acquired from third parties may contain defects in design or manufacture or other problems that could unexpectedly compromise information security. Network connected services provided by third parties to the Firm may be susceptible to compromise, leading to a breach of the Firm’s network. The Firm’s systems or facilities may be susceptible to employee error or malfeasance, government surveillance, or other security threats. Online services provided by the Firm to the Investors may also be susceptible to compromise. Breach of the Firm’s information systems may cause information relating to the transactions of the Clients and personally identifiable information of the Investors to be lost or improperly accessed, used or disclosed. The service providers of the Firm or the Clients, are subject to the same electronic information security threats as the Firm. If a service provider fails to adopt or adhere to adequate data security policies, or in the event of a breach of its networks, information relating to the transactions of the Clients and personally identifiable information of the Investors may be lost or improperly accessed, used or disclosed. The loss or improper access, use or disclosure of the Firm’s or the Clients’ proprietary information may cause the Firm or the Clients to suffer, among other things, financial loss, the disruption of its business, liability to third parties, regulatory intervention or reputational damage. Any of the foregoing events could have a material adverse effect on the Clients and the Investors’ investments therein. Dependence on the Firm. The success of the Clients is dependent upon the ability of the Firm to manage the Clients and effectively implement the Clients’ investment program. The Clients’ Governing Documents do not permit the Investors to participate in the management and affairs of the Clients. If the Firm were to lose the services of the Principal, or the Clients managed by the Firm were to incur substantial losses, the Firm might not be able to provide the same level of service to the Clients as it expects to provide or continue operations. The loss of the services of the Firm could have a material adverse effect on the Clients’ investments therein. Use of Systems. The Firm relies extensively on the use of computer systems, hardware, software and telecommunications equipment. The Firm makes use of its own models as well as systems that are publicly available or provided by third parties. Accordingly, the Clients are exposed to the risk that computer hardware, software, electronic equipment and other services used by the Firm may cease to be available, for example, due to the insolvency of the provider or the discontinuation of services or software updates. In such circumstances, the Firm would seek to obtain equivalent hardware, software and services from an alternative supplier. System Failure. As the Firm makes extensive use of computer hardware, systems and software, the Clients are exposed to risks caused by failures of information technology infrastructure and data. In addition, outright failure or a partial impairment (whether due to external situations or internal file corruption) of the underlying hardware, operating system, software or network may leave the Clients unable to trade either generally or in certain of its strategies, and this may expose it to risk should the outage coincide with turbulent market conditions. To mitigate this risk, backup and failover plans have been put in place by the Firm. Nevertheless, in the worst case, the Firm may have to liquidate the Clients’ entire portfolio as the only safe way to proceed should a crippling system outage occur.

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Investors in the Funds are generally institutional investors and high net worth individuals that qualify as “accredited investors” (as defined in Rule 501 under the Securities Act of 1933, as amended) and qualified purchasers. The minimum initial investment in the Funds will be determined by the Firm and set forth in the Funds’ Governing Documents. The Firm has waived such minimum and may, in its discretion, do so in the future under certain circumstances. If the Firm determines to require a minimum investment for any future client account, it makes that determination on a case-by-case basis.

The Funds Troluce GPs are entitled to receive performance-based fees from their respective Funds on an annual basis and upon withdrawals by investors. The amount and calculation of such performance-based compensation is as set forth in each Fund’s Governing Documents.. The Firm or its affiliates have the right to waive or modify the performance-based fees with respect to any investor and has done so for the Firm’s related parties and the Firm’s employees. The Firm’s compensation schedule with respect to any future client account will be contained in the Governing Documents relating to such account. The SMAs and the Sub-Advised Funds The Firm is entitled to receive performance-based fees from the SMA and the Sub-Advised Funds on an annual basis, subject to a loss carryforward provision. Side-by-Side Management Performance-based compensation arrangements create an incentive for the Firm to recommend investments that may be riskier or more speculative than those that would be recommended under a different compensation arrangement. Performance-based compensation arrangements could also create

an incentive for the Firm to favor accounts with higher performance-based compensation rates over other accounts when allocating investments. The Firm adopted procedures designed and implemented to seek to ensure that all clients are treated fairly and equitably, and to prevent this conflict from influencing the allocation of investment opportunities among client accounts. When participation in a specific investment is deemed to be appropriate for more than one client account, the Firm will seek to allocate such investment opportunities between such accounts on a fair and equitable basis under the circumstances existing at such time based upon a number of factors, which may include one or more of the following: its clients’ investment programs and investment objectives, investment capacity, amount of deployed and undeployed capital, fixed investment periods (if any), available leverage, desired leverage or available cash, tax, legal and regulatory considerations, overall portfolio composition, tolerance for volatility and risk, desired concentration, exposure and diversification targets, liquidity needs, different terms governing the client accounts, risk profile, investment guidelines and restrictions, depending on the accessible counterparty for each Client and the availability and inventory of positions, to avoid odd-lots, the desire to avoid de minimis allocations, and/or such other factors that the Firm determines are consistent with fair and equitable treatment of its clients over time. All investment opportunities will, to the extent practicable, be allocated among client accounts on a basis that over time is fair and equitable to each client account relative to other accounts, taking into account all relevant facts and circumstances. In addition, because clients’ management fees and performance-based compensation are based on the net asset values of their accounts, the Firm could potentially have a conflict of interest in valuing assets held by such accounts. To mitigate this conflict, the Firm implemented and follows documented valuation policies and periodically consults with auditors and the administrator to each Fund.

Services by the Firm’s Related Person As noted above, Troluce Funds GP, LLC, Troluce Funds GP II, LLC, and Troluce Opportunities GP II, LLC serve as the general partner to certain Funds. The Firm’s only affiliates are the General Partners of the funds. Management of Multiple Client Accounts The management of multiple client accounts results in a potential conflict of interest when the Firm and its related persons allocate time and investment opportunities among such accounts. For example, the Principal and/or other related persons are expected to have more of their personal assets invested in certain client accounts than in others. In addition, the compensation the Firm earns from each client account differs from the compensation earned from other client accounts. In order to mitigate associated conflicts, the Firm follows documented procedures regarding the allocation of investment opportunities among its clients. (See Item 6 – Performance‐Based Fees and Side‐By‐Side Management) A cross-trade occurs when an investment adviser affects a trade between two or more of its advisory clients. If the Firm were to cause a cross-trade between two clients, it may 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 does not generally expect to engage in cross trades. In the event that the Firm determines to make a cross-trade, it will only do so if it determines that it is in the best interests of, and is fair and equitable to, the participating clients. All cross-trades between clients require the prior approval of the Firm’s Chief Compliance Officer (the “CCO”). Cross-trades, if any, would generally be made at the closing price for the applicable security on such day or, if no closing price is available, at a price for the relevant security that is determined in accordance with the Firm’s valuation policies. No brokerage commission, transfer fee or other commission will be paid to the Firm or its affiliates in connection with any such transaction.

Code of Ethics Overview The Firm has adopted a Code of Ethics which is designed to help ensure that it conducts its business in accordance with all applicable laws and regulations and in an ethical and professional manner. In addition,

the Firm’s Code of Ethics sets forth standards of conduct for its employees to ensure that they conduct their business on the Firm’s behalf in a manner that enables the Firm to fulfill its fiduciary duty to its clients. Among other things, the Firm’s Code of Ethics: (i) governs personal trading by the Firm’s employees, (ii) contains the Firm’s policies with respect to gifts and entertainment, (iii) contains the Firm’s policies regarding certain outside activities of its employees, and (iv) sets forth the manner in which employees may report violations of law or the Firm’s policies and procedures. The Firm will provide a copy of its Code of Ethics to any client or prospective client upon request. Personal Trading Policy Employees are generally prohibited from engaging in personal trading without obtaining prior written consent from the Firm’s CCO, but are able to transact in municipal bonds, exchange-traded funds and mutual funds without obtaining prior approval from the Firm’s CCO. Additionally, employees are required to provide the CCO with periodic reporting relating to their trading activity and personal accounts. The Firm’s policies relating to personal trading also generally apply to an employee’s spouse or minor child, or an immediate family member of an employee living in the same household as such employee. Participation or Interest in Client Transactions The Firm makes available to qualified prospective investors the opportunity to invest in the Funds. The Firm’s Principal has significant personal investments in the Funds. In addition, Troluce GPs, its affiliates, receives performance-based allocations from the Funds. The Firm does not engage in a principal transaction unless it has determined that the transaction is in the relevant clients’ best interests and have obtained client consent in accordance with the Firm’s written procedures and applicable law.

Selection of Brokers The Firm has an obligation to seek to obtain “best execution” for clients with respect to their trading activity. While not defined by statute or regulation, best execution generally means the execution of client trades at the best net price considering all relevant circumstances. The Firm seeks best execution with respect to all types of client transactions, taking into account various factors. Such factors include, among others: price, the ability of a broker to affect the transactions, a broker’s reliability and financial responsibility and the range and quality of services provided and products offered (e.g., research services, news and quotation services, publications and corporate access), quality and timeliness of market information provided. Brokers sometimes suggest a level of business they would like to receive in return for the various services they provide. The Firm does not commit to provide any level of brokerage business to any broker, and actual brokerage business received by any broker may be less than the suggested allocations but can (and often does) exceed the suggestions, because total brokerage is allocated based on all the considerations described above.

The Firm periodically evaluates, among other things, the execution that it is receiving from brokers. In conducting its analysis, the Firm may consider the factors listed above, among others, and reviews gifts and entertainment received, and any known conflicts of interests (e.g., directing commissions to a broker that employs a family member of one of the Firm’s employees). Outsourced Trading The Firm has engaged one or more broker-dealers on behalf of its clients to execute and/or direct a portion of client trades on an outsourced basis (each, an “Outsourced Trading Desk”). The Firm believes that such engagement (i) may benefit clients and investors by providing access to each Outsourced Trading Desk’s knowledge and experience, connectivity to execution venues, proprietary and third-party trading technology and other services and (ii) is consistent with the Firm’s duty to seek best execution. However, such an arrangement differs from the practices of certain asset managers, which rely on their employees to perform certain of these trading functions. Under the terms of its engagement, an Outsourced Trading Desk — unless directed by the Firm to do otherwise — will have discretion on matters such as price, execution timing, venue, broker, and other aspects of trade execution. While the Firm will review the services performed by any Outsourced Trading Desk on a periodic basis, it is possible that, in the exercise of its discretion, an Outsourced Trading Desk will execute and/or direct trades under sub-optimal conditions or make trading-related errors that will negatively impact clients. Use of an Outsourced Trading Desk, and the manner in which the Firm compensates the Outsourced Trading Desk, exposes clients to potential conflicts of interest that would be different than the conflicts of interest posed if the Firm employed its own trading desk personnel. Specifically, when using an Outsourced Trading Desk, clients will bear the fees paid to such desk, which would not be the case if the Firm traded internally. As a result, client expenses are expected to be higher than if the Firm traded with brokers directly. The Firm will only engage an Outsourced Trading Desk on what it considers to be “arm’slength” and commercially reasonable terms. In addition, any Outsourced Trading Desk has, and is expected to continue to have, clients other than the Firm and its clients. Other client demands could place limitations on, or reduce the responsiveness of, an Outsourced Trading Desk, which may adversely affect the Firm’s clients. Arrangements with Outsourced Trading Desks may expose client transactions to information leakage similar to trading with other executing brokers. The Firm will evaluate and monitor any Outsourced Trading Desk in a manner similar to other brokers and may incorporate additional elements to such review process. Research and Other Soft Dollar Benefits The Firm does not currently have any formal soft dollar arrangements, but it may enter into such arrangements in the future. Nonetheless, the Firm executes transactions on behalf of its clients with brokers that provide the Firm with access to bundled services, including access to proprietary research reports (such as standard investment research and credit reports). To the best of the Firm’s knowledge, these services are generally made available to all institutional investors doing business with such broker. These bundled services are made available to the Firm on an unsolicited basis and without regard to the rates of commissions charged or paid by client accounts or the volume of business that the Firm directs

to such brokers. If we engage in soft dollar transactions in the future, the Firm intends to comply with the safe harbor provided by Section 28(e) of the Exchange Act, as amended. The Firm also executes transactions on behalf of its clients with brokers that may provide the Firm with access to bundled services, including access to proprietary research reports (such as standard investment research and credit reports) and invitations to attend conferences. To the best of the Firm’s knowledge, these services are generally made available to all institutional investors doing business with such brokers. These bundled services are made available to the Firm on an unsolicited basis and without regard to the rates of commissions charged or paid by clients or the volume of business that the Firm directs to such brokers. Brokerage for Client Referrals Subject to applicable law, the Firm may direct client brokerage business to brokers that refer prospective investors to the Firm. Because such referrals, if any, are likely to benefit the Firm but may not provide a benefit to the Firm’s clients, the Firm would have a conflict of interest with its clients when allocating brokerage business to such brokers. To mitigate this potential conflict, the Firm will not allocate brokerage business to a referring broker unless it determines that such allocation is consistent with its best execution duties. Trade Errors The Firm may on occasion experience errors with respect to trades made on behalf of client accounts. The Firm reimburses each client account for losses resulting from trade errors in accordance with the terms of the exculpation provision in such client’s Governing Documents. Aggregation of Orders Aggregation, or “bunching,” describes a procedure whereby an investment adviser combines the orders of two or more clients into a single order for the purpose of obtaining better prices and lower execution costs. Aggregation opportunities for the Firm generally arise when more than one client account is capable of purchasing or selling a particular security at the same time. To the extent that a security is purchased or sold for more than one client account, the Firm generally aggregates orders for such security unless aggregation is not consistent with its duty to seek best execution or the terms of the investment guidelines and restrictions applicable to client accounts. Each client that participates in an aggregated order participates 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. When an aggregated order is only partially filled, the Firm allocates the investment opportunity pro rata in accordance with its intended allocation.

Other than the products and services that the Firm receives from broker-dealers (described above in Item 12), the Firm does not expect that it will receive any economic benefits from third parties in connection with the provision of investment advice to the Funds. The Firm does not compensate any third-party marketers for introductions to potential investors or clients.

There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of the Firm’s advisory business or its management.

Review of Accounts Client portfolios are reviewed, and their performance analyzed, by the Principal on a regular basis. In addition, the Principal regularly reviews client portfolios to confirm that the securities held by them remain consistent with their investment strategies, objectives and guidelines.

Reporting In addition to the reporting below, clients and investors may be provided with certain information about the Firm and the accounts that it manages in response to questions and requests. This information may not be distributed to other clients, investors or prospective investors. Each client and investor is responsible for asking such questions as it believes are necessary in order to make its own investment decisions and must decide for itself whether the limited information provided by the Firm is sufficient for its needs. The Funds The Firm furnishes investors in the Funds with periodic written unaudited performance reports as set forth in their Governing Documents. In addition, on an annual basis, the Firm provides investors with a copy of the relevant Fund’s annual audited financial statements and, if applicable, a statement of taxable income (Schedule K-1). Pursuant to “side letter” or other agreements, the Firm may provide certain investors with access to more frequent and/or more detailed information regarding the Funds’ securities positions, performance, finances, and management and/or other information about the Funds or the Firm (including notifications of redemptions from a Fund by the Firm and/or its personnel), possibly enabling such investors to better assess the prospects and performance of the Funds. The Sub-Advised Funds and the SMAs The Firm provides the owners of the Sub-Advised Funds and the SMAs with periodic reports at such times as have been agreed upon with such owners as set forth in the relevant account’s Governing Documents. The owner of each Sub-Advised Fund and SMA receives account statements from the Sub-Advised Fund’s and SMA’s custodian on such periodic basis as is agreed to between such owner and custodian. In addition, any such owner may have full, real‐time transparency as to all transactions and holdings in the relevant account and will be better able to assess the future prospects of a portfolio that may be substantially similar to that of the Funds.

For purposes of Rule 206(4)-2 under the Advisers Act (the “Custody Rule”), the Firm is deemed to have custody over the Funds’ assets. In accordance with the Custody Rule, a qualified custodian is not required to deliver quarterly account statements to the Funds or their respective investors as long as: (i) the Funds are audited by an independent public accountant that is registered with, and subject to inspection by, the Public Company Accounting Oversight Board, (ii) the Funds’ audited financial statements are prepared in

accordance with U.S. generally accepted accounting principles, and (iii) the Firm delivers such annual audited financial statements to investors within 120 days after the end of each Fund’s fiscal year. The owners of the Sub-Advised Funds and the SMAs should carefully review the account statements that they receive from the custodians to such accounts and are urged to compare these account statements to the reports provided by the Firm directly to them or to their financial advisors.

The Firm has discretionary authority to manage securities and other investments on behalf of client accounts. The investors in the Funds generally cannot place any limits on the Firm’s authority beyond the limitations set forth in their respective Governing Documents. Under certain circumstances, the Firm may contract with a client to adhere to limited risk and/or operating guidelines imposed by the client. The Firm negotiates such arrangements on a case-by-case basis.

The Firm generally has voting discretion over client securities. Clients generally are not able to direct their votes in a particular situation. The Firm has adopted proxy voting policies and procedures, which are summarized below. In light of its investment strategy, the Firm generally believes that proxies will not have a material impact on the value of the Clients’ investments. Therefore, in the absence of specific voting guidelines mandated by a particular Client, the Firm generally intends to abstain or not vote a proxy if it believes that such action is in the best interests of a particular Client or if the proposal will not have a material effect on a Client’s investment strategy. If the Firm decides to vote in a particular circumstance, the Firm will vote all proxies in accordance with its fiduciary duty to each Client, and it will adhere to the policies and procedures set forth herein. The Firm expects few, if any, proxy votes will occur because of the Firm’s investment strategy. In determining whether a specific proposal is in the best interests of a particular Client, the Firm may take into account the following factors, among others, in determining if a specific proposal is in the best interests of a particular client: (i) management of the issuer’s views and recommendations on such proposal, (ii) whether the proposal may have the effect of entrenching existing management and/or making management less responsive to shareholders’ concerns (e.g., instituting or removing a poison pill, classified board of directors and/or other anti-takeover measure), and (iii) whether the Firm believes that the proposal will fairly compensate management for its and/or the issuer’s performance. If the Firm deems that the issue being voted upon is not material for the Firm and its clients or it determines that the cost of voting a proxy would exceed the expected benefit to the Firm’s clients, the Firm will not be obligated to vote on such matter. Conflicts of interest may arise between the interests of clients on the one hand and the Firm or its affiliates on the other hand. If the Firm determines that it may have, or is perceived to have, a conflict of interest when voting proxies, the Firm will vote in accordance with its proxy voting policies and procedures. Upon the request by a client, the Firm will disclose to such client how it voted proxies for securities owned by such client. The Firm will also provide a copy of its proxy voting policies and procedures to clients upon request.

The Firm is not required to include its balance sheet for its most recent fiscal year with this Brochure.