Tudor Investment Corporation

The Tudor Group is a group of affiliated entities engaged in the management of client and proprietary assets and the investment advisory business on a global basis for an international clientele. Within the Tudor Group, TIC serves as the primary advisory entity, and together with its Relying Advisers, acts as investment adviser, on a discretionary basis, to Tudor’s Clients. TIC was formed in 1980 by Paul Tudor Jones and, together with its Relying Advisers, is privately owned by certain current and former Personnel. Mr. Jones is the sole controlling principal of Tudor and is the Co-Chairman and Chief Investment Officer of TIC. As of December 31, 2025, Tudor had $106,842,033,000 in regulatory assets under management, all of which is managed on a discretionary basis. Tudor is a multi-strategy investment adviser focused primarily on discretionary and quantitative investment strategies, including but not limited to discretionary global macro, long/short equity, event driven equity, quantitative global macro, statistical arbitrage and other quantitative strategies, as more fully described in Item 8 below. Tudor employs trading strategies across a broad range of securities and derivative instruments in the fixed income, currency, commodity and equity asset classes, on both a long and short basis, for varying investment horizons. Tudor provides discretionary investment advisory services to its Clients, which include the Tudor Funds (some of which are Proprietary Accounts) and Managed Accounts. Certain Tudor Funds and Managed Accounts focus on a single investment strategy while others focus on multiple strategies. The investment objective, strategy and restrictions (if any) of each Tudor Fund are set forth in the applicable Offering Materials, and are generally not tailored to the individualized investment needs of any particular Investor. However, the terms applicable to Managed Accounts are tailored based on the individual needs of the Managed Account holder. Further information about these strategies and investments, as well as a discussion of associated material risks, can be found in Item 8 of this brochure.

Tudor is generally compensated for its services through the receipt of management fees and performance-based allocations (see also Item 6, below). Additionally, for certain Tudor Hedge Funds as described in the relevant Offering Materials, Tudor may receive a fee payment intended to reimburse Tudor for certain costs and expenses incurred (an “Expense Pass Through”). Tudor may waive management fees, performance-based allocations or an Expense Pass Through in certain instances that Tudor deems appropriate, in its sole and absolute discretion. Tudor Hedge Funds The investment advisory agreements entered into between Tudor and each Tudor Hedge Fund govern the compensation to be paid to Tudor. Generally, Tudor Hedge Funds pay an asset-based management fee and are subject to a performance allocation or fee (collectively referred to as “performance-based allocations”) based on fund performance. The table below sets out the range of management fees and performance-based allocations for each of the Tudor Hedge Funds. While management fees and performance-based allocations for each class or sub-class of shares or interests in the Tudor Hedge Funds are generally not negotiated, Tudor has in the past created different classes or sub-classes of shares or interests, which vary the management fees and performance-based allocations paid by certain Tudor Hedge Fund Investors. Tudor Hedge Fund Investors that are or were related persons of Tudor may not be required to pay management fees or make performance-based allocations.

Tudor Hedge Fund The Tudor BVI Global Fund L.P. The Tudor BVI Global Fund Ltd. Tudor Riverbend Crossing Partners L.P. Tudor Riverbend Crossing Partners Ltd. Xantium Partners Fund L.P. Xantium Partners Fund Ltd. TPIP Investments LLC1 Tudor Global Investment Fund US L.P. 1 Tudor Global Investment Fund LLC2 Tudor Family Fund II LLC 2 Tudor Employee Investment Fund LLC 3 Vortex Street Fund L.P. 4 Vortex Street Fund Ltd.4

Annual Management Fee 1.75%-2.25%

Performance-Based Allocation 25%

0.75%-1.25%

10%-15%

1.0%; Expense Pass Through Expense Pass Through 1.75%-2.25%

0%-10%

0.5% 0% Expense Pass Through

2% 0% 0%

25% 25%

Management fees and performance-based allocations for the Tudor Hedge Funds are calculated and approved by an affiliate of Citco Fund Services (Curaçao) B.V. (with its affiliates, the “Administrator”) and verified by Tudor. Once verified and approved, Tudor requests the appropriate payments or allocations be made from fund assets. Management fees are payable monthly in arrears based on net assets before the deduction of management fees and performance allocations, and performance-based allocations are allocated annually in arrears, subject to the recovery of prior losses, as provided in the relevant Offering Materials. Performance-based allocations are based on increases in the net assets of a fund or account due to performance, subject to the recovery of prior losses, and are calculated following the deduction of management fees. In the event that a Tudor Fund (an “Investor Fund”) invests in another Tudor Fund (an “Investee Fund”), Tudor will generally deduct from its management fee the amount of any operating expenses (including any management and performance fees or allocations, if applicable) allocated by the Investee Fund to the Investor Fund’s investment, unless otherwise disclosed in the Investor Fund’s Offering Materials. Certain Tudor Hedge Funds are subject to an Expense Pass Through, whereby such Tudor Hedge Funds pay a fee, directly or indirectly, to Tudor in an amount necessary to pay/reimburse Tudor for certain costs and expenses as more fully described in the Offering Materials of the relevant Tudor Hedge Funds. The Expense Pass Through generally covers all administrative and operating expenses incurred in connection with the applicable Tudor Hedge Funds, including, without limitation, recruiting fees and related costs and expenses for hiring personnel, reasonable out-ofpocket expenses incurred by Tudor, including, without limitation, travel expenses, consulting fees and reasonable attorneys’ fees arising in connection with trading and marketing activities, and certain expenses relating to office space, utilities, supplies, furniture, fixtures and equipment. The Expense Pass Through also pays/reimburses Tudor for all portfolio-related compensation of Portfolio Managers and their team members as well as any applicable management and support staff. Such compensation includes but is not limited to salary, bonuses (including sign-on and other guaranteed bonuses), payroll taxes, insurance and benefits, severance payments and other compensation, including such equivalents in foreign jurisdictions for Tudor’s affiliates, all as provided by Tudor in its sole discretion; provided that certain of such compensation may be accounted for through an allocation or a fee (rather than as an expense). Such compensation accrues regularly and will be payable whether or not the applicable Tudor Hedge Fund experiences positive trading results, which may give rise to certain conflicts of interest and negatively impact such Tudor Hedge Fund’s returns. With respect to certain Tudor Hedge Funds, the Expense Pass Through may be: (i) in addition to management fees and performance-based allocations or fees, or (ii) subject to a cap. Expense Pass Through payments are generally made monthly (provided that certain compensation expenses or allocations may be paid other

Only available to Tudor, Mr. Jones, certain of his related persons and certain current and former Personnel. Only available to Mr. Jones and certain of his related persons. Only available to certain current and former Personnel. Management fees and performance-based allocations are paid indirectly with respect to investments in underlying funds, including, without limitation, investments in certain Tudor Hedge Funds. Only available to certain current Personnel.

than monthly) and the amount shall be determined by Tudor in its sole discretion in accordance with Tudor’s Expense Policy (as defined below). Managed Accounts Management fees and/or performance-based allocations for Managed Accounts, including rates, calculation methodologies, and the timing of payments, are individually negotiated with each Managed Account holder. OTHER COSTS AND EXPENSES Tudor Funds Tudor generally seeks to pay, without reimbursement by the Tudor Funds, substantially all of its own ordinary administrative and operating expenses, including, without limitation, office space, utilities and employee compensation and benefits (excluding any costs or expenses, including any Expense Pass Through, that are otherwise borne by the Tudor Funds in accordance with the applicable Offering Materials). In addition to the fees described above and in the Tudor Funds’ Offering Materials, each Tudor Fund, where applicable, pays all of its organizational, offering, operating and investment expenses. Organizational expenses include, without limitation, the expenses incurred in connection with the organization or re-organization of a Tudor Fund. Operating expenses include, without limitation, administration (including the fees of the Administrator), legal and regulatory compliance, accounting, auditing, escrow, recordkeeping, technology, clerical expenses, expenses incurred in connection with board of director meetings and periodic events held for Investors in a Tudor Fund, directors’ fees and reimbursable expenses (including travel expenses incurred by directors for Tudor Fund related matters), insurance costs, expenses for administrative services, printing and duplication expenses, mailing costs, filing fees, taxes and expenses for preparation of reports prepared by external consultants and auditors, and other operating expenses. Such expenses also include expenses relating to risk management, technology, data management, market data and pricing. Each Tudor Fund will also pay certain costs associated with third party computer and data centers and co-location facilities, including the costs of communications systems, computing equipment, data (including but not limited to market data, alternative data and data used to generate trade signals) and other costs related to generating information that Tudor may utilize to identify trading opportunities and certain other infrastructure costs. Such costs include costs relating to back-up facilities or services. In addition, the amount paid to certain data vendors may be tied to the profitability of the trading systems utilizing such data. Tudor generally allocates to a Tudor Fund certain third-party costs and expenses in connection with the purchase, implementation and maintenance of third-party software, systems and platforms, including order and execution management systems, used by Tudor in furtherance of the administration and operation of such Tudor Fund and in order to ensure compliance by such Tudor Fund with applicable rules and regulations. The operating expenses allocated to a Tudor Fund include, without limitation, costs related to certain compliance and regulatory filings and obligations of Tudor, such as position reporting and the preparation of Form PF, Form CPO-PQR and AIFMD Annex IV transparency reporting. Each Tudor Fund also pays the expenses incurred in connection with the continuing offering of its shares or interests, including, without limitation, costs related to registering or making such securities available for sale in certain jurisdictions, costs related to specific jurisdictional reporting related to any or all Investors, costs related to the preparation and printing of constituent documentation, offering memoranda, promotional material, and contracts. Each Tudor Fund is also obligated to pay any extraordinary expenses, including without limitation, the expenses incurred in connection with any non-recurring litigation. Expenses as a percentage of net assets of a Tudor Fund may rise or fall substantially if the net assets of a Tudor Fund change. Investment expenses include, without limitation, execution, give-up, brokerage, floor, exchange and clearing fees and commissions, other transaction costs and expenses, custody expenses, taxes, bank and broker-dealer service fees, interest on margin accounts, consulting fees and legal fees relating to investments (including legal fees related to performing due diligence, communicating and negotiating with issuers and other stakeholders, documenting investments and dispositions, and otherwise protecting or enhancing the value of investments). Brokerage commissions, margin interest, exchange transaction fees, and other transaction costs and fees are subject to change from time to time as mutually agreed between Tudor and the applicable broker, dealer or counterparty. Please see Item 12 of this brochure for further details on Tudor’s brokerage practices. In addition, interest expense varies

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Tudor uses a number of investment strategies and related methods of analysis, which it characterizes broadly as (i) discretionary (where trading is based on qualitative purchase and sale criteria as determined by the analysis of the relevant discretionary Portfolio Manager and which may be informed by quantitative methods); and (ii) quantitative (where trading is based, wholly or substantially, on Systems). It should be noted that not all Clients participate in all of the investment strategies described in this Item 8, and that Tudor, in its sole discretion, determines the investment strategies and instruments that are appropriate in achieving the investment objective of each Client. It should further be noted that Tudor trades certain strategies in its Proprietary Accounts at substantially higher leverage than in the comparable Client accounts. Tudor’s products are not intended to represent a complete investment solution and it is expected that Investors and Managed Account holders maintain assets other than those advised by or invested through Tudor. Investors and Managed Account holders are responsible for appropriately diversifying their assets to mitigate the inherent risk of loss. INVESTMENT STRATEGIES General descriptions of the principal investment strategies employed by Tudor in advising Clients and certain Proprietary Accounts and explanations of the primary material risks associated with those strategies, are provided below; however, Investors and Managed Account holders are strongly encouraged to consider the more detailed

descriptions that are included in the relevant Offering Materials. There is no guarantee that any particular strategy or group of strategies will be effective or yield particular results or levels of return. Tudor Hedge Funds The principal investment objective of the Tudor Hedge Funds is to seek capital appreciation through discretionary and quantitative trading and investing on a global basis, both long and short, across a broad range of securities and derivative instruments in the fixed income, currency, commodity and equity asset classes, both exchange-traded and OTC. Tudor employs one or more of the following principal investment strategies in managing each of the Tudor Hedge Funds. Please note that the list below only provides the principal investment strategies employed by Tudor at the date of this brochure; other strategies may be employed from time to time or may be elevated to principal status without prior notice. Directional Global Macro: Directional global macro Portfolio Managers trade and invest on global macroeconomic themes through both fundamental and technical analysis, both long and short, in various types of financial instruments that may include, without limitation, fixed income, currency, commodity, and equity asset classes and related derivative instruments. Portfolio Managers may focus on specific asset classes or trade and invest across asset classes and global markets depending on their specific expertise and perception of trading and investment opportunities. The trades initiated by Portfolio Managers focused on this strategy range from short-term to long-term time horizons, with a typical focus on liquid instruments. These trades are initiated primarily in developed countries and in some emerging economies. Certain Portfolio Managers may employ quantitative models and other analytical tools in connection with their portfolio management. Portfolio Managers may use either or both of fundamental and technical analysis in formulating trading and investment decisions. When using fundamental analysis, Portfolio Managers may use forecasts and analysis of various underlying macroeconomic themes, such as interest rate movements, global capital flows, political changes, government policies, inter-government relations and other broad economic factors. From a technical analysis standpoint, Portfolio Managers may, among other things, study historical market data or perform surveys to assist in idea generation and develop views on investment opportunities. Orthogonal: Certain Portfolio Managers specialize in other strategies referred to as “orthogonal strategies” that are differentiated from, and generally non-correlated with, Tudor’s directional global macro strategy. These strategies may include but are not limited to fixed income relative value, global macro relative value, emerging markets, tactical/short term FX, volatility and correlation-based strategies, commodity, equity strategies, including long/short equity and event driven equity. Portfolio Managers may employ quantitative and other analytical tools in connection with these strategies. Hybrid: Hybrid strategies employ elements of both directional global macro and orthogonal strategies. In addition to directional global macro, certain Portfolio Managers will utilize other discretionary trading and investing strategies, including relative value trading, basis trading and volatility trading on an opportunistic basis. Such Portfolio Managers will allocate varying amounts to such strategies including, at times, a majority of their allocated capital to either directional global macro or orthogonal approaches. Portfolio Managers employ quantitative and other analytical tools in connection with this strategy. Event Driven: Event driven trading and investing is both long and short, primarily in U.S. and European equity securities and using a strategy that is primarily focused on corporate events, including, without limitation, mergers, spin-offs, tender offers, exchange offers, liquidations, changes in management, structural changes in the marketplace, asset transfer, leaving or entering new business lines, changing capital structure, corporate reorganization, bankruptcies, significant litigation and certain other hard and soft catalysts. Instruments traded consist principally of publicly listed equity securities (including New Issue Securities) and related corporate or derivative securities. Exchange-traded funds and equity indices may be used to hedge portfolio exposures or to otherwise express an investment view. The investment portfolio is then constructed based on a number of factors, with sizing based on the Portfolio Manager’s expected probability

of success and volatility of the underlying investment opportunity after adjusting for relevant hedging. Individual trade structure and hedging is generally based on fundamental and statistical analysis. Quantitative: Quantitative investment and trading strategies vary by assets traded, strategic approach, risk profile and other characteristics. They include, but are not limited to, (i) statistical arbitrage strategies that are primarily equity strategies with horizons ranging from short-term to medium-term, (ii) credit strategies, including but not limited to credit default swap and U.S. corporate bond strategies, (iii) volatility strategies, (iv) other strategies focused primarily in futures, foreign exchange and cryptocurrency utilizing a variety of technical, fundamental and other data inputs and (v) strategies based on bespoke research infrastructure that are automated and utilize machine learning techniques. Certain quantitative Portfolio Managers may also engage in investment and trading activities that are largely opportunistic. Managed Accounts Investment advisory services are provided to Managed Accounts in accordance with investment guidelines and restrictions developed in consultation with the Managed Account holder, or in accordance with a particular mandate selected by the Managed Account holder at the outset of Tudor’s relationship with the Managed Account holder. These investment guidelines and restrictions are set out in the relevant Offering Materials. Managed Accounts generally employ one or more of the principal investment strategies implemented by the Tudor Hedge Funds. Proprietary Accounts Proprietary Accounts generally employ one or more of the principal investment strategies implemented by the Tudor Hedge Funds, some of which trade and invest on a parallel, “side-by-side” and levered basis (utilizing a lower funding level). However, certain Proprietary Accounts also currently trade certain investment strategies that are not currently employed by any Client accounts but may be employed by Client accounts in the future. For example, Tudor may engage in strategic initiatives currently or in the future that may or may not be allocated to Client accounts or solely to Proprietary Accounts. The leverage utilized by Proprietary Accounts is typically substantially higher than that used in comparable Client accounts. Tudor continually develops and evaluates new and evolving investment and trading strategies, techniques and Systems. Tudor may test new Systems in its Proprietary Accounts. Systems that meet Tudor’s criteria over the testing period and that Tudor, in its sole discretion, deems advisable under applicable guidelines and procedures may then be utilized for appropriate Client accounts, but Tudor is under no obligation to do so and such Systems may be allocated to Proprietary Accounts in Tudor’s sole discretion. Please see Item 10 for a further discussion of certain conflicts of interest that arise in connection with the Proprietary Accounts. Principal Instruments Associated with the Investment Strategies In effecting its investment strategies, Tudor may cause a Client to invest in a variety of securities and other financial instruments, including but not limited to financial and commodity futures, currencies, bonds, equities, commodities, forwards, options, swaps and other derivative, credit and financial instruments and cryptocurrencies. Such securities and financial instruments are often used in connection with multiple strategies and Tudor’s advice may differ as to, among other factors, limits, durations and leverage based on the nature of the Client and the strategy or strategies being used. Determination of Investment Strategies and Instruments Tudor, in its sole discretion, determines the investment strategies and instruments that are appropriate in achieving each Client’s investment objective. Tudor regularly reviews such investment strategies and instruments and the investment strategies and instruments that it utilizes may change or evolve over time. Among the criteria considered by Tudor in determining investment strategies and instruments are liquidity, capacity, volatility, expenses associated with developing certain strategies, costs associated with employing Personnel with the necessary skills to run such strategies, regulatory matters and reputational risk. Accordingly, Tudor presently does not allocate certain investment strategies or instruments to Clients, including the following, which may, for the avoidance of doubt, be allocated solely to Proprietary Accounts: (i) mortgages (provided, however, that certain Tudor Funds may trade mortgage-backed

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Tudor’s Clients include the Tudor Hedge Funds and the Managed Accounts. Additionally, Tudor advises Proprietary Accounts. The Tudor Hedge Funds are privately-placed pooled investment vehicles exempt from registration under the Investment Company Act of 1940 Act, as amended, typically pursuant to Section 3(c)(1) or Section 3(c)(7) of that Act. Investors in these funds generally include high net worth individuals and related entities, sovereign entities, pension funds, non-financial corporates, financial institutions, endowments and foundations, fund-of-fund vehicles, family offices and proprietary capital from certain current and former Personnel and related entities. Managed Account holders generally can include funds-of-funds, investment banks, asset management firms, financial institutions, and/or certain clients thereof. Tudor or the board of directors, as applicable, generally imposes an initial investment minimum to establish an investment through a Tudor Fund or Managed Account, but may waive or change any such minimums in its discretion. These minimums vary by Tudor Fund, as set forth in the applicable Offering Materials, but generally range from $25,000 to $40 million. Initial investment minimums for Managed Accounts are generally higher and vary by account type, investment type and/or investor type. Tudor also requires Investors to meet additional qualifications based on, among other things, legal or regulatory requirements associated with the relevant Tudor Fund or Managed Account or the investment strategies thereof. Investors must consider whether a particular Tudor Fund or Managed Account is appropriate to their own circumstances based on all relevant factors, including but not limited to the Investor’s own investment objectives, ERISA considerations, liquidity requirements, tax situation and risk tolerance. Prospective investors are strongly encouraged to undertake appropriate due diligence, including but not limited to a review of the relevant Offering Materials and the additional details about Tudor’s investment strategies, methods of analysis and related risks of loss in Item 8 of this brochure, before making an investment decision.

As noted in Item 5 above, Tudor’s compensation may include performance-based allocations and an Expense Pass Through, and Tudor compensates Portfolio Managers based on the performance of accounts that the Portfolio Managers manage, which could lead to conflicts of interest. To help mitigate the potential conflicts of interest related to these fee structures, Tudor has a Code of Ethics (the “Code”), a Conflicts Committee and a Trade Allocation Policy (the “Trade Allocation Policy”).

The Code provides that Personnel should always act in the best interests of Clients and avoid situations that could give rise to even the appearance of a conflict of interest. The Code is discussed in greater detail in Item 11.

The Conflicts Committee is a committee of certain members of the Board of Directors of TIC and other senior Personnel. The Conflicts Committee assists Tudor in the oversight of any potential conflicts of interest that may arise: (i) between or among Tudor and any Tudor Fund(s) or Managed Account(s); and (ii) in assessing whether adequate resources are in place and effectively allocated to properly administer the policies, procedures and controls that comprise Tudor’s conflict management process. The Conflicts Committee reports to the Board of Directors of TIC.

Tudor’s Trade Allocation Policy, which is overseen by Tudor’s Brokerage Committee, provides predetermined allocation guidelines among the various Tudor Funds, Managed Accounts and Proprietary Accounts that Tudor manages and that may employ the same or similar trading strategies. The purpose of this policy is to promote non-preferential treatment among Clients (as well as Proprietary Accounts and those where Tudor or its related persons are Investors) and to ensure that, wherever possible and over time, trades are allocated in a fair and equitable manner. For Client allocations, trades are generally programmatically allocated based upon predetermined allocation rules, which are governed by the Trade Allocation Policy and based on the relative size of the individual Portfolio Manager’s allocation with respect to the particular Client. Non-standard allocations are determined, monitored, approved and recorded as such by a supervisor in the Operations Department and by the Legal and Compliance Department pursuant to the Trade Allocation Policy and any other policies applicable to such allocation. The Brokerage Committee reviews the Trade Allocation Policy at least annually to assess its effectiveness.

CONFLICTS OF INTEREST ASSOCIATED WITH PERFORMANCE-BASED ALLOCATIONS AND SIDE-BY-SIDE MANAGEMENT OF ACCOUNTS INCLUDE:

Tudor has an incentive to allocate time, resources and investment opportunities based on its pecuniary interest. Tudor and its Personnel face a conflict of interest when considering how to allocate limited time, resources and investment opportunities among accounts having different fee structures or pecuniary interests, including Proprietary Accounts. Through its Trade Allocation Policy, capital allocation process, the Code, the Conflicts Committee, and other compliance policies and procedures, which undergo periodic review by Tudor’s Internal Audit department and/or third-party compliance consultants, Tudor seeks to promote fair and equitable treatment of accounts, over time, based on considerations that are unrelated to pecuniary interests. Please see the section titled “Capital Allocation Process” in Item 8 for a further discussion of Tudor’s capital allocation process. Where possible and in accordance with the relevant investment mandate, Tudor seeks to mitigate conflicts related to the allocation of investment opportunities by (i) investing into, or alongside certain Tudor Funds, which places Tudor (and/or its Proprietary Accounts) alongside Client accounts; (ii) allowing certain current Personnel and other related persons to invest directly into the Tudor Funds; and/or (iii) using the same or similar strategies for Managed Accounts as it does for certain of the Tudor Hedge Funds. Tudor has a substantial pecuniary interest in the Tudor Funds and its Proprietary Accounts, some of which trade and invest on a parallel, “side-by-side” and levered basis (utilizing a lower funding level) with certain Tudor Hedge Funds. Certain Proprietary Accounts also currently trade certain investment strategies that are not currently employed by any Client accounts but may be employed by Client accounts in the future. As a result, Tudor is generally subject to substantially similar types of market risks as the Managed Accounts and the Tudor Funds. However, the leverage utilized by each Proprietary Account is typically substantially higher than that used in the Tudor Funds. Please see Item 12 for a further discussion of aggregated transactions. It should also be noted that certain Proprietary Accounts employ trading strategies and/or invest in asset classes that are not currently available to Investors through the Tudor Funds or Managed Accounts. Certain of these trading strategies and/or asset classes may be subject to testing in Proprietary Accounts. Once testing is completed, Tudor may, in its sole discretion, determine to utilize such trading strategies for appropriate Tudor Funds or Managed Accounts, but it is under no obligation to do so. Please see Item 10 for a further discussion of allocation of investment opportunities and the Proprietary Accounts.

Tudor, its Personnel and/or investment strategies have limited investment capacity. Tudor has discretion over how and when to allocate capital and trading strategies among Client accounts and Proprietary Accounts. All allocations are influenced by various objective and subjective factors, including but not limited to the mandate for a Client account’s investment strategies relative to other Client accounts and Proprietary Accounts. Portfolio Managers may have limited investment capacity that could constrain the exposure to certain trading strategies that Client accounts and Proprietary Accounts might otherwise utilize. As a result Tudor has a conflict of interest in allocating such capacity among different accounts. Conflicts of interest arising from allocating limited investment capacity among Client accounts and/or between Client accounts and Proprietary Accounts, to the extent they may arise, will be reviewed initially by Tudor’s Capital Allocation Committee. If a conflict persists, a final determination will be made by a subset of the Tudor Management Committee, in consultation with other Tudor Personnel including senior members of the Risk Management and Legal and Compliance Departments.

Tudor and its Personnel have an incentive to take on more risk in accounts when compensation is based on performance. The receipt of performance-based compensation creates an incentive to make riskier investments than might be made in the absence of performance-based compensation as such compensation generally allows participation in gains in excess of losses. This conflict is mitigated by a number of checks embodied in the Tudor risk management framework. This risk management framework includes VaR limits, monitoring of VaR statistics that incorporate both tail risk and shorter-term volatility, stress tests at both the Portfolio Manager and Tudor Fund level, continuous monitoring of Portfolio Manager drawdown plans and adherence thereto, a documented risk charter setting out key responsibilities and meetings to identify and address hidden tail risks. Tudor’s Risk Management Department also establishes and actively monitors both the risk profile and investment universe of each Portfolio Manager. Please see Item 13 for further details of account reviews. These controls are further enhanced by Tudor’s policy of deferring a portion of each Portfolio Manager’s compensation over a multi-year period and subjecting the deferral to a claw-back mechanism for negative performance. This encourages an alignment of long-term investment interests between the Client, Tudor and/or the Portfolio Manager.

Tudor frequently engages in rebalancing transactions designed to facilitate Tudor’s parallel investing approach, which includes the use of principal transactions. Tudor frequently engages in rebalancing transactions among Client accounts and between Client accounts and Proprietary Accounts in connection with ordinary course subscriptions, redemptions and capital allocation changes, which will generally be effected through either (i) reflecting changes in the beneficial ownership percentage of the applicable trading vehicle(s) owned by the applicable Clients and Proprietary Accounts or (ii) by conducting market transactions. In addition, Tudor may also effect a rebalancing through principal trades, giving rise to potential conflicts of interest that would not exist if rebalancings were effected through market transactions. When Tudor causes a Proprietary Account to buy assets from, or sell assets to, Client accounts, a conflict exists whereby Tudor has an incentive to effect such trades at artificially low or inflated prices designed to maximize its own financial gain. The risk that a principal trade may be effected at a price that is disadvantageous to a Client account may be magnified where the trade involves over-the-counter instruments with limited pricing transparency. Tudor seeks to mitigate this conflict by disclosing its principal trading activity in the Offering Materials and to the boards of directors of the Tudor Funds, by conducting transactions using the closing price as published by the relevant exchange for the relevant instrument and by subjecting its rebalancing transactions to review and approval by the Client.

When compensation is based on the value or performance of investments, Tudor has an incentive to value a position at a price higher than it might otherwise be valued or to accelerate or defer realizations. Performance-based allocations are based on increases in the net assets of a fund or account due to performance. Tudor’s compensation generally is based upon both unrealized gain/loss and realized gain/loss. This means that Tudor may be compensated on performance that is ultimately not realized if positions decrease in value and are subsequently closed out at a loss. The potential for inflated valuation of positions is increased when such positions are illiquid or otherwise lack a readily ascertainable market value. Tudor seeks to mitigate this conflict through its Valuation Policy and Procedures (the “Valuation Policy”) and the valuation processes of its Middle Office Department, which is independent of Portfolio Managers. Tudor’s Valuation Policy governs how Tudor’s autonomous Middle Office Department (which reports

directly to the Chief Operating Officer and not to any Portfolio Managers) conducts the various aspects of portfolio valuation and is designed to ensure that instruments are valued fairly, consistently, and to the extent practicable, using reliable and recognizable independent sources. The Valuation Policy describes the process for valuing and verifying the valuation of the wide variety of instruments in which Tudor trades and invests. Additionally, in the case of the Tudor Funds, Tudor’s valuations are independently verified by the Administrator. Please see Item 13 for further discussion of valuation.

TIC is registered with the U.S. Commodity Futures Trading Commission (“CFTC”) as a commodity pool operator (“CPO”) and a commodity trading advisor (“CTA”) and is a member of the National Futures Association (“NFA”). Certain of TIC’s principals and Personnel are registered with the NFA as “associated persons” of TIC. Tudor’s offices in New York, New York, Palm Beach, Florida and Brookline, Massachusetts are each registered with the NFA as a branch office of TIC. Certain other members of the Tudor Group are registered with the financial regulatory bodies of their operating jurisdictions. These include Tudor Capital Europe LLP, a Relying Adviser, which is authorized and regulated by the United Kingdom’s Financial Conduct Authority (“FCA”), Tudor Capital (DIFC) Limited, which is authorized and regulated by the Dubai Financial Services Authority, Tudor Capital Jersey Limited, which is authorized and regulated by the Jersey Financial Services Commission, and Tudor Capital Singapore Pte. Ltd., a Relying Adviser, which is authorized and regulated by the Monetary Authority of Singapore. MATERIAL BUSINESS RELATIONSHIPS Tudor has arrangements that are material to its advisory business with related persons that are investment advisers and private investment funds. Investment Advisers and Related Management Entities The Tudor Group includes, in addition to TIC, a number of other investment advisers under common control with TIC including Tudor Capital Europe LLP, Tudor Capital (DIFC) Limited, Tudor Capital Jersey Limited, and Tudor Capital Singapore Pte. Ltd. These Relying Advisers provide investment management and other services to TIC that will ultimately be for the benefit of certain Clients. A number of other entities under common control with TIC serve as management entities, typically as a general partner or managing member, of certain Tudor Clients and trading vehicles, including Tudor BVI GP Ltd., Xantium Partners GP Ltd., Tudor Pipeline GP Ltd., Tudor Trading I GP Ltd., Tudor Trading II GP Ltd., Tudor Trading VII GP Ltd., Vortex Street Fund GP Ltd., and Kid Shelleen Ltd. Resources may be shared across the Tudor Group. This sharing of resources will not increase the management fees and/or performance-based allocations charged to Clients. Please see Item 8 of this brochure for additional details regarding Tudor’s global platform. Proprietary Investment Activities; Other Accounts

Tudor acts as investment adviser to a number of separate Clients, including the Tudor Funds and Managed Accounts. Tudor also actively trades proprietary capital in the financial markets, and serves as sponsor, general partner (or a similar capacity), and/or investment adviser to Proprietary Accounts that are owned or controlled by Tudor’s principals and partners. Tudor’s direct and indirect interests in the Tudor Funds and Proprietary Accounts are material to Tudor, and Tudor’s role as investment adviser to multiple Clients and Proprietary Accounts gives rise to actual and potential conflicts of interest. Although the majority of Tudor’s proprietary capital is invested in or alongside Client accounts, Tudor devotes a substantial amount of its time and resources to the portfolio management and development of investment vehicles and accounts (including Proprietary Accounts) other than Client accounts. Tudor has discretion over how and when to allocate certain trading strategies among its Clients and Proprietary Accounts. Additionally, because Portfolio Managers have limited investment capacity, Tudor has a conflict of interest in allocating such capacity among accounts. Tudor allocates certain investment capacity and trading strategies solely to certain Clients and/or Proprietary Accounts. In the event Tudor does determine to allocate a portion of a trading strategy or investment capacity to a Client, such allocation may be different than the standard allocation as described in Item 6 of this brochure. In some cases, Tudor employs comparable trading approaches (including the same strategy) and instruments for a number of different Clients or Proprietary Accounts and, in such cases, such accounts invest on a parallel and “sideby-side” basis. Exceptions to parallel and “side-by-side” investing are made where a Client account is legally, contractually or otherwise prohibited from purchasing a particular asset or is limited in the size of its position or for hedging purposes. In addition, Portfolio Managers that trade Systems for Proprietary Accounts generally will not act as Portfolio Managers for Clients even to the extent that such Portfolio Managers utilize discretionary elements in their trading or utilize similar instruments to those traded for Clients. Certain Clients and/or Proprietary Accounts have different cash funding requirements than other Clients and typically invest on a levered basis (utilizing a lower funding-level than such other Clients). Because of such different cash funding requirements, Tudor may invest excess cash of such levered Client and/or Proprietary Accounts in different ratios to other Clients and may also utilize different instruments for cash management purposes due to different levels of unencumbered cash. This may cause such levered Client and/or Proprietary Accounts to experience different returns for such excess cash investments to other Clients. Therefore, where a levered Client and/or Proprietary Account shares a similar strategy with another Client, Tudor has a conflict of interest between making investment decisions that benefit the levered Client and/or Proprietary Account (e.g., by minimizing or decreasing risk) and that maximize returns for the other Client. Similarly, because the account size of a particular Client may be smaller than the account size of other Clients and/or Proprietary Accounts that pursue similar trading strategies, when a Portfolio Manager makes an investment on behalf of such Client, a majority of such investment will be allocated to the other, larger Clients and/or Proprietary Accounts. Accordingly, when making such investment, Tudor faces a conflict of interest in determining whether such investment is being made in the best interests of certain Clients and/or Proprietary Accounts or in the best interest of all such Clients. Tudor has a similar conflict of interest in determining when and at what price to enter and exit investments. This includes drawdown periods whereby the pre-established “drawdown plans” for Portfolio Managers do not distinguish between the accounts for which Portfolio Managers trade, and thus it is possible that liquidations or hedges resulting from such “drawdown plans” may not be in the best interests of all Clients. In addition, it is possible that a Client together with a Proprietary Account may approach certain speculative position limits or encounter liquidity constraints. In any such case, both the Client and Proprietary Account may be required to modify their trading instructions and either liquidate certain of their investments or effect their investments using other instruments, such as swaps, in order to avoid exceeding such position limits or investing in less liquid investments. There is no guarantee that the Client will be able to enter into these other derivative instruments to effect the desired investment or that the terms of such other derivative instruments will replicate the desired instrument. These types of regulatory position limits and liquidity constraints could adversely affect the operations and profitability of a Client. Tudor faces conflicts of interest in allocating available capacity under speculative position limits and liquidity among accounts and may allocate all or any portion of such capacity to certain Clients or Proprietary Accounts. In other cases, Tudor allocates certain transactions, Systems and/or trading strategies solely to certain Clients and/or Proprietary Accounts. Tudor similarly allocates solely to its Proprietary Accounts securities issued by certain private investment funds or their managers (including strategic or other investments or revenue interests or providing seed

capital) or may allocate its proprietary capital directly to such third party managers for management. Such funds and managers may utilize the same or similar strategies utilized by Tudor on behalf of Clients. Tudor reserves the right to re-allocate investment and trading strategies, techniques and Systems among its Clients and/or Proprietary Accounts. Furthermore, certain Proprietary Accounts employ Systems that are not utilized by Tudor in connection with its management of Client accounts but may be employed by Client accounts in the future. For example, Tudor may engage in strategic initiatives currently or in the future that may or may not be allocated to Client accounts or solely to Proprietary Accounts. In addition, Tudor continually develops and evaluates new and evolving investment and trading strategies, techniques and Systems. Tudor typically tests new Systems in its Proprietary Accounts. Systems that meet Tudor’s criteria over the testing period and that Tudor, in its sole discretion, deems advisable under applicable guidelines and procedures may then be utilized for appropriate Client accounts, but Tudor is under no obligation to do so. Tudor is subject to a conflict of interest in determining whether to allocate such trading strategies among its Clients or solely to its Proprietary Accounts. They may employ trading and execution methods that have higher costs of development and operation. In many cases, although such Clients may realize some related benefits as a result of these strategies being traded for Proprietary Accounts, such as lower trading commissions from higher overall trading volume or better shared execution platforms as they are developed, these Clients will not benefit from the returns of these Systems, if any. Tudor is also subject to a conflict of interest because certain Tudor Personnel that develop, or oversee the development of, Systems for one or more Clients also develop, or oversee the development of, Systems allocated solely to Proprietary Accounts. Similarly, Tudor Personnel that develop, or oversee the development of investment and trading strategies, techniques and Systems for use by one or more Clients may subsequently utilize such trading strategies, techniques and Systems solely for certain other Client accounts or Proprietary Accounts. Distinct investment and trading strategies, techniques and Systems that trade in similar instruments or markets may also be independently developed of each other and may be allocated to Client accounts or Proprietary Accounts in Tudor’s sole discretion. Tudor is subject to a conflict of interest in determining how to allocate among Client accounts and Proprietary Accounts such similar investment and trading strategies, techniques and Systems. From time to time, Tudor establishes specialty funds to pursue specific trading strategies or business lines. Such specialty funds, which generally will be initially launched solely with proprietary capital, may trade on a parallel and “side-by-side” basis with a Client or may utilize trading strategies not allocated to a Client. Such specialty funds may, at a later date, be available for investment by investors not affiliated with Tudor. Trading strategies and Systems traded by a particular Client that are also traded by other Client accounts and/or Proprietary Accounts will trade with a different mix of Systems and instruments, are subject to different allocations of capital among Systems and trading strategies, utilize different levels of leverage and are subject to different risk parameters, including different volatility profiles, than other Client accounts or Proprietary Accounts. As a result of these differences, the returns of such trading strategies and Systems traded by a particular Client differ from the returns of such trading strategies and Systems in other Client Accounts and/or Proprietary Accounts. Tudor also initiates hedges for a Client and/or Proprietary Account in order to bring such Client and/or Proprietary Account to a risk level that it deems appropriate. In addition, Tudor initiates portfolio overlays to increase or reduce investment positions and market exposures of a Client and/or Proprietary Account in its sole discretion. Such hedges and overlays may be initiated solely for certain Clients and/or Proprietary Accounts, in Tudor’s sole discretion. Tudor considers a number of factors in determining how trading capacity, opportunities and strategies are allocated, including diversification, ability to sustain loss, volatility, liquidity and cost, among other factors. Tudor addresses any conflicts of interest among itself, the Proprietary Accounts and its Clients in accordance with applicable law, the Code and Tudor’s policies and procedures. Conflicts of interest are considered by Tudor’s senior management, including the Conflicts Committee, in consultation with other Tudor Personnel including senior members of the Risk Management and Legal and Compliance Departments. For further discussion of the Code and the Conflicts Committee please see Item 6 of this brochure.

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Tudor’s guiding principle is to achieve excellence in performance and provide Clients with exceptional service while at all times maintaining the highest degree of personal and professional integrity and ethical conduct. Tudor has adopted the Code based on this guiding principle which applies to all Tudor Personnel. The Code requires that, without exception, Client interests are a priority in resolving any conflict that arises between Tudor and a Client. Through the Code, Tudor seeks to avoid not just the occurrence of improper activities but also the appearance of

improper activities. Among the specific potential conflicts addressed by the Code are personal account trading, private investments, outside business activities and giving or receiving gifts and entertainment. Additionally, Tudor has implemented a Global Whistleblowing Policy that is designed to protect and encourage the good faith reporting and disclosure by Tudor Personnel of known or suspected violations of the Code and/or Tudor’s policies and procedures. A copy of the Code will be made available to current and prospective Clients and Investors upon request. PERSONAL TRADING Personal account trading in securities or private investments that may also be purchased, held or sold by a Client may create conflicts of interest. To address the conflicts that arise in connection with personal account trading, Tudor has a Personal Account Trading Policy and Procedures (the “Personal Account Trading Policy”). The Personal Account Trading Policy permits long-term investing, not short-term trading, by placing comprehensive restrictions on the ability of Tudor Personnel to trade for their own personal accounts. The Code and the Personal Account Trading Policy contains several specific requirements designed to mitigate conflicts of interest surrounding personal account trading and private investments, including: • pre-approval from Tudor’s Legal and Compliance Department for most purchase and sale transactions of securities and other instruments; • a minimum holding period requirement of one month for exchange-traded funds and cryptocurrencies and three months for all other purchases subject to pre-approval; • a prohibition against front-running, trading in parallel, or “piggybacking” off of proprietary or Client trading and/or strategies; • pre-approval from Tudor’s Legal and Compliance Department for all private investments; • quarterly filings of reportable securities transactions; and • filing of initial and annual holdings reports. Tudor monitors the personal trading accounts of its Personnel on an ongoing basis. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS Tudor faces potential conflicts of interest where it: (i) offers to Clients, or buys or sells for Clients instruments in which it or a related person has a material financial interest; (ii) invests in the same (or related) instruments that are recommended to, or bought or sold by Clients; or (iii) offers instruments to Clients, or buys or sells instruments for Client accounts at or about the same time as those securities are bought or sold for personal or Proprietary Accounts. From time to time, Tudor may offer to Clients investments in investment vehicles that Tudor manages or in which Tudor or its related persons have an ownership or other pecuniary interest either in the investment vehicle or the adviser to that vehicle. Generally, Tudor believes the investment by Tudor or its related persons in vehicles also held by Clients helps to align its interests with those of its Clients, but recognizes that conflicts of interest (e.g., as to compensation, trade allocation and best execution) could result from these shared investments. Tudor has policies and procedures whereby Tudor’s Legal and Compliance Department must approve and/or monitor personal trading and outside business activity. In certain cases, such conflicts are also reviewed by Tudor’s Conflicts Committee. As disclosed in Items 6 and 8 and in the Offering Materials, certain Proprietary Accounts trade on a parallel and “sideby-side” basis with Client accounts. As a result Tudor may buy or sell the same instruments as Clients at or about the same time as those instruments are bought or sold by Clients. Tudor will make allocations of investments among Clients and Proprietary Accounts in accordance with their respective investment strategies, policies, procedures, restrictions, then-existing portfolio composition, concentration, diversification, liquidity, capacity, risk/reward, and leverage considerations and/or restrictions and then-existing market and trading conditions. Please see Items 6 and 8 for further discussion of Tudor’s allocation of investments among Client accounts and Proprietary Accounts. Such market and trading conditions may include the timing of the transaction, the liquidity of the instrument, the size of the position and other market considerations. As described in Item 12 of this brochure, such trading is generally done on an aggregated basis or in a manner such that no Client should be disadvantaged.

Tudor frequently effects rebalancing transactions among Client accounts and between Client accounts and Proprietary Accounts primarily in connection with subscriptions, redemptions and capital allocation decisions. Although intended to facilitate Tudor’s approach to parallel and “side-by-side” investing, rebalancing transactions may reduce the liquidity of a Client’s positions and increase the liquidity of Proprietary Accounts or other Client accounts, or may increase the risk profile of a Client’s account, or vice versa, and, for certain positions that are rebalanced, there will be limited pricing transparency. In the event that Tudor determines to effect a rebalancing, it will generally be effected through either (i) reflecting changes in the beneficial ownership percentage of the applicable trading vehicle(s) owned by the applicable Clients and Proprietary Accounts or (ii) by conducting market transactions. In addition, for instruments that are eligible under Tudor’s written policies and procedures, Tudor may also effect a rebalancing by causing Client and/or Proprietary Accounts to purchase instruments directly from, or sell instruments directly to, other Client and/or Proprietary Accounts (“Cross Trades”), which frequently include the use of principal transactions (as defined in Section 206(3) of the Advisers Act). Tudor has specific policies governing rebalancing trades to ensure that all relevant Clients are treated fairly and equitably and in accordance with applicable regulatory requirements. These policies require, among other things, that any cross-transaction be reviewed and approved by the Client. In addition, Tudor’s policies establish the pricing mechanism to be used and provide that Tudor will not receive any compensation in connection with such transactions.

Prime brokers and other clearing brokerage decisions for Client accounts, to the extent discretion has been granted to Tudor, are made by Tudor’s Credit and Brokerage Committees with the assistance of certain departments and with input from various Portfolio Managers. Subject to the Offering Materials and applicable policies described below, Tudor has full discretionary authority to trade on behalf of the Tudor Funds, including the selection of executing, prime and clearing brokers and OTC counterparties. Although Tudor generally does have discretion with respect to the selection of executing brokers for Managed Account transactions, certain Managed Account holders may require the use of specific prime or clearing brokers. Approval of Broker-Dealers and other Counterparties Each prime broker, OTC counterparty, clearinghouse/exchange, FCM, custodian and (for fixed income products) executing broker used on behalf of a Client must be approved by Tudor’s Credit Committee. Trading terms and conditions are negotiated and agreed to prior to the commencement of trading. The Credit Committee evaluates the financial strength of counterparties during the initial approval process, and its ability to provide the desired services in a manner consistent with industry practice and Tudor’s expectations (except to the extent that a Managed Account has mandated the use of a particular broker to act as a prime or clearing broker) and on an ongoing basis as financial information is available. Members of Tudor’s Credit Committee monitor and regularly share relevant developments in counterparties’ creditworthiness and may recommend certain exposure management actions as appropriate. From time to time, the Credit Committee may restrict trading with certain counterparties. The approved counterparty list is accessible by Portfolio Managers and execution personnel at all times. Portfolio Managers are only permitted to trade through approved executing brokers. Portfolio Managers who wish to establish a new relationship with an executing broker must submit a request to management in the Operations Department. The Operations Department, in consultation with various functional departments within the Tudor Group, ultimately determines the approval of the executing broker and provides the broker access to the Tudor platform. Where required by applicable regulation, the executing broker due diligence process includes the performance of Anti-Money Laundering, criminal and adverse regulatory action checks and the confirmation of a broker’s registration status, all of which is conducted by Tudor’s Legal and Compliance Department. Seeking Best Execution of Trading Decisions Tudor defines “best execution” as achieving the best possible trading result with respect to cost and quality of execution, taking into account the size, nature, price and complexity of the order. In selecting brokers or other venues and counterparties, Tudor seeks best execution of Client transactions. Consistent with the duty to seek best execution, Tudor’s policies and procedures, and applicable law, Client transactions may be directed to electronic or alternative

trading systems (including “dark pools”) or brokers or dealers that participate in such systems and can provide Tudor with direct market access. Tudor seeks best execution across a variety of financial instruments and markets on which it executes client orders, irrespective of whether such trading is discretionary or Systems-based. The diversity in these financial instruments and markets requires that different factors be taken into account and different weights to those factors in assessing the quality and costs of transactions. Tudor, in its discretion, will decide which of the execution factors provides for best execution. When determining how to execute transactions, Tudor considers the following factors, among others:

costs, including explicit external costs such as brokerage, exchange or clearing fees, as well as implicit costs such as spreads and slippage; likelihood of execution and settlement: the probability that the trade order will be successfully completed either in whole or in part; nature of the order and any other relevant considerations, which covers any other factor not listed in the regulations that Tudor may wish to prioritize in order to achieve the best results for its accounts; price: the cash equivalent or rate at which a transaction is executed; size: the quantity of the instrument being bought or sold; and speed: the amount of time that elapses between the order and the successful execution.

Where consistent with Tudor’s duty to seek best execution and applicable policies and procedures, Tudor may execute transactions through brokers, dealers or other trading venues in which Tudor has a non-controlling interest or with whom Tudor has other dealings, including with those who invest in Tudor Funds, have a Managed Account with Tudor or introduce Investors or Clients to Tudor (see Item 14 of this brochure for further information). Additionally, as discussed below, Tudor may consider research and other soft dollar services provided by broker-dealers in making execution decisions; provided, that doing so is consistent with Tudor’s duty to seek best execution. Tudor’s brokerage policies include provisions to mitigate potential conflicts resulting from these relationships. Broker Review Tudor’s Brokerage Committee oversees the service levels of brokers used to execute Client transactions, taking into account both qualitative and quantitative factors such as commissions and quality of execution. Tudor’s objective is to exercise reasonable, good faith judgment in implementing investment strategies through transactions in securities and other financial instruments through responsible counterparties that can provide services commensurate with Tudor’s expectations, to the extent practicable, at reasonable costs while minimizing risks. Tudor generally executes trades within its internal standardized commission ranges, by product, across broker-dealer relationships. However, commissions can vary based on trading platform and trade complexity as well as whether research was provided. Research/Soft Dollars Tudor may “pay up” or otherwise use soft dollars to acquire proprietary research and brokerage services (i.e., items that are produced or developed and provided by the broker-dealer, including tangible research as well as access to analysts and traders) or third-party research (i.e., items that are produced or developed by an independent source but provided by the broker-dealer). While research received from broker-dealers pursuant to these arrangements is supplemental to Tudor’s own research efforts, proprietary and third-party research received through soft dollar arrangements relieves Tudor from having to produce, or otherwise pay for, such research itself. This may create an incentive for Tudor to select broker-dealers based on its interest in receiving research or other services rather than on any particular Client’s interest in receiving best execution. Tudor intends that its use of soft dollars will fall within the safe harbor for soft dollar transactions found in Section 28(e) of the Securities Exchange Act of 1934, as amended. Tudor may use soft dollars: (i) when acquiring eligible “research or brokerage” items or services within the meaning of the safe harbor; (ii) that provide lawful and appropriate assistance to Tudor in carrying out its relevant responsibilities to Client accounts; and (iii) at a cost that is reasonable in relation to the value of the research or brokerage items or services. As noted above, research is one of the factors

Tudor considers in selecting brokers and determining the reasonableness of commissions paid, along with other qualitative and quantitative factors. It is often not possible to place a precise dollar value on execution quality or the value of research or brokerage services offered by various broker-dealers. Therefore broker-dealers selected by Tudor may be paid commissions in excess of amounts another broker-dealer would have charged for executing a transaction. The Section 28(e) safe harbor allows Tudor to consider the reasonableness of commissions in light of a particular transaction or generally in respect of Tudor’s overall duty to its discretionary accounts. Research and brokerage services obtained with soft dollars will not always be used by Tudor in servicing the specific account that generated the related commissions. The value of many soft dollar items cannot be measured precisely and commissions paid for such items cannot always be allocated to Clients in direct proportion to the value of the items to each Client. Tudor generally aggregates transactions on a firm-wide basis, as such commissions attributable to one or more accounts may be allocated to brokers who provide soft dollar items used by Tudor in managing the accounts of other Clients, and vice versa. In addition, unless inconsistent with Tudor’s duty to seek best execution, Tudor may direct a broker to execute a trade and “step out” a portion of the commission in favor of another broker that provides brokerage or research related services to Tudor. Although it is inevitable (at least in the short-term) that commissions paid by one account may, in effect, subsidize services that benefited another account, Tudor expects that distortions will balance out over time as Tudor’s various sources of research and brokerage services enable Tudor to make more effective investment and trading decisions. As a result, Tudor does not attempt to allocate the relative costs or benefits of the research and brokerage services among Client accounts. Research products or brokerage services received by Tudor may also be used by Tudor for functions that are not research or brokerage related. Where a research product or brokerage service has a mixed use, Tudor will make a reasonable allocation according to its use. For example, Tudor Group members may use a mixture of soft dollars and hard dollars in acquiring services such as Bloomberg terminals. Tudor’s Brokerage Committee oversees, and Tudor’s Legal and Compliance Department monitors, Tudor’s use of soft dollars. Over the prior 12-month period, soft dollars accrued by Tudor have been used to purchase research and brokerage services from third-party vendors. Research services may include information related to economic trends or conditions, political developments, industries, groups of securities, individual countries and individual companies. Brokerage services may include post-trade brokerage services or communication services related to the execution, clearing and settlement of transactions. Aggregated Transactions Where two or more Client accounts seek to trade in the same manner in an instrument contemporaneously, Tudor will generally aggregate those orders into one or more “aggregated” orders for execution, although Tudor is not required to do so and may, when deemed appropriate, execute each Client’s transactions on an individualized basis. As a result, any benefits that might be achieved by aggregating orders would not be available to those Clients. Subject to the foregoing, Tudor primarily makes determinations as to whether or not to aggregate orders based on any legal or account restrictions on aggregate trading associated with an account or account type. In accordance with its policies and procedures, including the Trade Allocation Policy, Tudor seeks to execute aggregated orders and allocate the resulting executions among participating Client accounts in a manner that is fair and equitable over time and which promotes best execution. Aggregate transactions may allow Clients to receive more favorable prices, obtain more timely or equitable executions, manage market impact of trades and/or reduce overall commission charges. Please see Items 6 and 10 of this brochure for further discussion of allocation of investments. When an aggregated transaction is filled in its entirety, the proceeds or instruments obtained are generally allocated to participating accounts at the average price per share or unit traded and costs are allocated based upon the initial amount requested for each account (subject to certain size-related or cost-related exceptions). When it is not possible to allocate an aggregated transaction among participating accounts at the average price per share or unit traded, Tudor will utilize a high-to-low methodology to allocate filled orders among the participating accounts. When Tudor is unable to fill an entire order, “partial fills” are generally allocated pro rata. In cases where pro rata allocation is deemed inappropriate or less efficient, such as where different counterparties are used to work an order, other methods

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Tudor does not currently use paid solicitors for client referrals but retains the ability to do so in the future. Tudor may participate in events hosted by third-party financial institutions to promote awareness of the hedge fund industry, including funds managed by or strategies traded by Tudor. However, such third-party financial institutions are not compensated by, nor act as agent on behalf of, Tudor with respect to such events. In addition, Tudor Capital Europe LLP, a Relying Adviser operating in the United Kingdom, may engage in client referrals for certain of the Tudor Hedge Funds and Managed Accounts from time to time.

On September 20, 2023, the Cboe Futures Exchange, LLC (the “Exchange”), pursuant to an offer of settlement in which TIC neither admitted nor denied that a violation of exchange rules had been committed, found that TIC inadvertently submitted to the exchange an incorrect customer type indicator code for one of the accounts operated by TIC. As part of the settlement TIC consented to the imposition of a $35,000 fine (Exchange File No. URE-201-09.).

Tudor Hedge Funds Tudor monitors and performs various reviews of the Tudor Hedge Funds. Most of these reviews are either ongoing or occur at pre-determined periodic intervals. Non-periodic reviews may be undertaken because of, among other things, changes in market conditions, change of positions, changes to the investment objective or material changes to Tudor’s policies and/or legal obligations. Positions and Valuation Review: Tudor and the Administrator conduct a number of ongoing checks related to valuation including:

Trade and Position Reconciliation: Tudor’s Operations Department is overseen by Tudor’s Chief Operating Officer who reports to Tudor’s Chief Executive Officer. The Operations Department reconciles positions between Tudor’s books and the relevant broker statements on a daily or monthly basis depending on the investment. The Administrator, under the supervision of Tudor, also performs certain trading-related back office functions on behalf of the Tudor Hedge Funds. Such trading-related back office functions include, but are not limited to, certain reconciliations, trade confirmations, settlements and collateral movements.

Middle Office Review: Tudor’s Middle Office Department is overseen by the Head of Middle Office who reports to Tudor’s Chief Operating Officer. The Middle Office Department assesses proper valuations for such positions and measures overall performance on each business day. Tudor’s Middle Office Department verifies pricing data used to value each position within the daily process.

Portfolio Manager Review: Portfolio Managers, or their authorized designees, are responsible for reviewing and affirming the accuracy of their respective portfolios daily. At the end of each business day, Portfolio Managers and their authorized designees receive one or more of the following automated reports, as determined appropriate for the Portfolio Manager’s strategy by the Middle Office and Operations Departments: (i) a blotter consisting of trade activity for that day, (ii) a position and performance report for that day, and (iii) a daily performance report, including daily, monthly and year-to-date returns. Portfolio Managers, or their authorized designees, are required to approve or reject the information contained in the reports, with comments to be addressed by the Middle Office Department and/or the Operations Department, as applicable. Issues are investigated and resolved with updated reports distributed for sign-off. Portfolio Managers, or their authorized designees, who receive only the daily report described in (iii) above are also required to perform

daily reconciliations to verify the positions reflected in their databases match the positions in the database maintained and independently controlled by the Middle Office Department. Such Portfolio Managers, or their authorized designees, are also required to perform daily reconciliations of the positions in their portfolios to the positions reflected in Tudor’s books and records.

Third-Party Administrator: The Administrator carries out a wide variety of daily and monthly checks for each Tudor Hedge Fund that it services. The principal ongoing checks focus on valuation reviews for all of the vehicles’ assets, cash reconciliations, broker-provided valuations and net asset value (“NAV”) calculations. The Administrator follows its own internal procedures for verification of Clients’ portfolios and utilizes its own database of market data, independent market data vendors and industry standard pricing models for verification and comparison. Investors in each Tudor Hedge Fund receive a monthly NAV statement directly from the Administrator.

Restricted List and Regulatory Review: Tudor’s Legal and Compliance Department is overseen by Tudor’s General Counsel who reports to Tudor’s Chief Executive Officer. The Legal and Compliance Department controls Tudor’s restricted list process. Instruments can be restricted for a variety of reasons, including where Tudor has material nonpublic information (which may result from Tudor’s investment advisory activity with respect to its Clients and/or Proprietary Accounts) or where the instrument is subject to short sale, position limit or sanction restrictions. Risk Review: Tudor’s Risk Management Department is overseen by the Chief Risk Officer & Head of Portfolio Oversight who reports to Tudor’s Chief Investment Officer and Chief Executive Officer and is a member of Tudor’s Capital Allocation Committee. The Risk Management Department manages guidelines that seek to maintain tolerable risk levels for each Tudor Hedge Fund. These guidelines are normally tailored specifically for each Tudor Hedge Fund and, within the multi-Portfolio Manager funds, to each Portfolio Manager. Portfolio Oversight Manager. Tudor’s Portfolio Oversight Manager reports to Tudor’s Chief Risk Officer & Head of Portfolio Oversight. This role focuses on overall portfolio construction, risk and optimization. The Portfolio Oversight Manager works with Tudor’s Risk Management Department and the Portfolio Managers to identify and quantify tail and other risks. The Portfolio Oversight Manager works with various resources throughout Tudor on specific trading and overall portfolio analytics projects. Quantitative Strategies Oversight Group. The Quantitative Strategies Oversight Group (the “QSOG”), in its capacity as an independent oversight function to Tudor’s quantitative strategies, is responsible for establishing, coordinating and enforcing the portions of the governance framework covered by the QSOG Charter for such strategies globally. Key components of the governance framework include (a) policies and procedures regarding strategy research, development, testing, validation and deployment; (b) independent review and approval of new Systems and significant changes to existing ones; (c) requirement of version control of production source code; (d) oversight of kill switch functionality and protocols; and (e) coordination of ongoing independent oversight of Quantitative Strategies by relevant management and control personnel, including Tudor’s Director of Quantitative Strategies Oversight, Risk Management and Legal and Compliance Departments. Managed Accounts The frequency and nature of reviews for Managed Accounts are set out in the relevant Offering Materials and may differ from Managed Account to Managed Account. However, all Managed Accounts are subject, at a minimum, to the following reviews, each of which is set out in greater detail above: (i) trade reconciliation; (ii) positions and valuations; and (iii) restricted list and regulatory review. CLIENT OR INVESTOR REPORTS Reporting content and frequency varies based on Client type. Further details of the reports provided to Clients and Investors can be found in the relevant Offering Materials. Written reports are generally provided via email or made accessible through Tudor’s or the Administrator’s password protected websites. Clients and Investors in a Tudor Fund

may also request additional information and general updates from Tudor’s Investor Relations and Product Development Department. Tudor Hedge Funds Investors in each Tudor Hedge Fund receive the following reports:

annual audited financial statements, prepared in accordance with GAAP, within 90 days after the fund’s fiscal year end (or 180 days if the fund is a fund of funds); and monthly and/or quarterly account statements, containing information relating to both Investor and Client equity, changes in NAVs, final monthly and/or quarterly NAV and performance.

Investors in certain Tudor Hedge Funds also have access to one or more of the following reports:

weekly and monthly estimated performance; monthly or quarterly attribution and exposure reports; quarterly investor letters; and a counterparty balance and exposure report.

Investors in U.S. domestic funds also receive U.S. federal income tax information on an annual basis. Managed Accounts Tudor may provide Managed Account holders with custom reports to the extent indicated in the relevant Offering Materials and/or as agreed upon with the Managed Account holder. The content and frequency of the custom reports vary from Managed Account to Managed Account.

Client assets are generally held in custody by qualified custodians that are unaffiliated with Tudor; however, because Tudor, member(s) of the Tudor Group and/or Personnel serve as general partner or managing member of a Tudor Fund, Tudor is deemed to have “custody” of the assets of the Tudor Funds as that term is defined under Rule 206(4)2 under the Advisers Act. Each year, Investors in these Tudor Funds receive audited financial statements, prepared in accordance with GAAP, within 90 days or 180 days for funds-of-funds following the vehicle’s fiscal year end. Investors who have not received audited financial statements in a timely manner should contact Tudor immediately. Tudor generally is not deemed to have “custody” of the assets of the Managed Accounts since it does not have the authority to hold, directly or indirectly, funds or securities of the Managed Accounts or have the authority to obtain possession of them.

Tudor has investment discretion over each Tudor Fund, subject to that Tudor Fund’s stated investment objectives and restrictions (if any), as set forth in the relevant Offering Materials. The Tudor Funds are collective investment vehicles and Tudor will not tailor its advisory services to such funds for any particular Investor. The scope of Tudor’s investment discretion over a Tudor Fund is set forth in an investment advisory agreement, pursuant to which, Tudor typically has the authority to determine both the securities or other financial instruments to be purchased or sold for a Tudor Fund (subject to the investment objectives and restrictions (if any), stated in the relevant Offering Materials) and the amount of such securities or other financial instruments to be purchased or sold for such Tudor Fund. Tudor also has discretion over Proprietary Accounts. Tudor will accept, and generally is granted, discretionary authority over the Managed Accounts, pursuant to an investment advisory agreement which typically contains a power of attorney or similar authorization to carry out transactions, subject to the investment guidelines and restrictions that are developed in consultation with the Managed Account holder, and/or in accordance with the relevant Offering Materials.

Tudor typically has authority to vote Client securities. Tudor votes these securities in accordance with its written proxy voting policies and procedures, which are summarized below and available to Clients on request. Tudor will also provide, to a Client, information about how that Client’s securities or securities held by the relevant Tudor Fund, as applicable, were voted. Managed Account holders can request copies of Tudor’s proxy voting policies and relevant voting records by contacting Tudor’s Investor Relations and Product Development Department. Tudor’s policy generally is to vote Client proxies in a manner that Tudor believes is in the Client’s best interest. To minimize potential conflicts of interest among Tudor, Personnel, Clients and Investors and to ensure that proxies are voted in a timely manner, Tudor has retained Broadridge Financial Solutions Inc. (“Broadridge”) and instructed Broadridge to generally vote proxies in accordance with the Glass Lewis Recommendations. Moreover, if Tudor determines that a specific proxy proposal poses an actual conflict of interest, but believes that voting is necessary to serve the Client’s best interests, Tudor will vote solely in accordance with the Glass Lewis Recommendations. In extraordinary circumstances and only upon prior written approval from Tudor’s Legal and Compliance Department, Tudor may vote proxies against the Glass Lewis Recommendations. In such cases, the Legal and Compliance Department and the relevant Portfolio Manager(s) will prepare and maintain memoranda describing the rationale for such vote. In some cases, Tudor may determine that it is in the Client’s best interest to refrain from voting a proxy (e.g., if the cost of voting exceeds the expected value of the vote or where voting would preclude Tudor from selling the security for a specified time period). In addition, Tudor does not vote securities which are being loaned as part of a securities lending program. When Tudor has been granted discretionary voting authority, it will exercise that authority consistently in accordance with the proxy voting policies described above. As a result, Tudor will not accept requests from Clients or Investors to direct voting as to a particular solicitation.

Tudor has never filed for bankruptcy and is not aware of any financial condition that is expected to affect its ability to manage Client accounts.

GLOSSARY Clients

means collectively the Tudor Funds and Managed Accounts. Unless the context otherwise requires, references to Clients do not include Proprietary Accounts.

Investors

means persons holding ownership interests in a Tudor Fund. Except as separately agreed with Tudor, Investors are not clients of Tudor.

Managed Accounts

means an account advised by Tudor on behalf of a third-party account holder.

Offering Materials

means, as applicable and without limitation, (i) with respect to Tudor Funds, the private placement memoranda, advisory agreements, limited partnership agreements, limited liability company agreements, memoranda and articles of association, subscription documents and other governing documents setting forth the terms under which Tudor provides services or a person may invest; and (ii) with respect to Managed Accounts, the investment advisory agreement, other agreements or governing documents and any supplemental information regarding Tudor’s services or the terms and conditions of such relationships provided in connection therewith.

Personnel

means all Tudor personnel including all employees, active partners, members, agents or such other classes of persons acting on behalf of Tudor as the Legal and Compliance Department may deem appropriate to be covered, and all agents and other third-parties acting on behalf of Tudor, including consultants, temporary workers, interns, non-employee agents and contractors, wherever located. As appropriate, the term Personnel also includes persons associated with another company within the Tudor Group but who are providing services to or on behalf of Tudor. For purposes of the Personal Account Trading Policy, the term Personnel (1) excludes certain Tudor personnel who (a) work for Tudor on a limited basis each month, (b) perform their duties entirely offsite, and (c) perform functions unrelated to Tudor’s investment advisory business; and (2) includes family household members of Personnel.

Portfolio Managers

means Personnel who are allocated funds through the capital allocation process or the relevant portfolio manager or investment oversight committee and given investment discretion (subject to Tudor’s oversight and internal policies guidelines, including applicable risk rules) to invest those funds.

Proprietary Accounts

means accounts holding proprietary investments which Tudor manages on its own behalf, on behalf of certain current/former Personnel (including personnel of Tudor Group members) and on behalf of the Tudor Group and their respective affiliates. Unless the context otherwise requires, references to Tudor Funds include such Proprietary Accounts. For the avoidance of doubt, Tudor Employee Investment Fund LLC, Tudor Family Fund II LLC, Tudor Global Investment Fund LLC, Tudor Global Investment Fund US L.P., TGF, TPIPI, Vortex Street Fund L.P., and Vortex Street Fund Ltd. are included in the definition of Proprietary Accounts.

Relying Adviser

means each of Tudor Capital Europe LLP, Tudor Capital (DIFC) Limited, Tudor Capital Jersey Limited, and Tudor Capital Singapore Pte. Ltd.

System

means a computer algorithm that makes investment decisions, and can include the determination of individual order parameters, with limited or no human intervention.

TIC

means Tudor Investment Corporation.

Tudor

means TIC and each of the Relying Advisers.

Tudor Funds

means the Tudor Hedge Funds and, unless the context otherwise requires, also includes the Proprietary Accounts.

Tudor Group

means TIC together with the Relying Advisers and certain other entities that are either controlled by or under common control with TIC.

Tudor Hedge Funds

means each private pooled vehicle set forth in the table under the heading “Tudor Hedge Funds” in Item 5.