Twin Lions Management LLC

Twin Lions Management LLC (“Twin Lions”, the “Investment Manager”, or the “Firm”), is a Delaware limited liability company formed in 2018. Timothy Abbott is the Managing Member (the “Principal”) of Twin Lions. Twin Lions provides investment advisory services to a private fund, Twin Lions Partnership LP (the “Twin Lions Fund”), a Delaware limited partnership. The general partner of the Fund is Twin Lions GP LLC (the “General Partner”), a Delaware limited liability company. Mr. Abbott is the Managing Member of the General Partner. The General Partner has ultimate responsibility for decisions relating to management and operations made on behalf of the Fund and has ultimate responsibility for the investment decisions made on behalf of the Fund but has delegated certain responsibilities to Twin Lions. In addition to advising the Fund, Twin Lions also provides investment advice to Twin Lions SPV II LP and Cassini Partners, L.P. – Twin Lions Management LLC Series. Twin Lions GP LLC is the general partner of Twin Lions SPV II LP. The Twin Lions Fund, Cassini Partners, L.P. – Twin Lions Management LLC Series, and Twin Lions SPV II LP are referred to individually as a “Fund” and collectively as the “Funds”. Additional detailed information about Twin Lions is provided below, including information about Twin Lions’ advisory services, investment approach, personnel, affiliations and brokerage practices. Twin Lions’ principal place of business is in Stamford, CT. Twin Lions manages each Fund pursuant to the investment guidelines set forth in the relevant governing and offering documents of each Fund, including any limited partnership agreement, term sheet, private placement memorandum, investment advisory agreement, and/or subscription agreement (each an “Offering Document,” and collectively, the “Offering Documents”). The Offering Documents for each Fund contain more detailed information about each Fund, including a description of the investment objective and strategy or strategies employed by Twin Lions in advising the Fund, and related restrictions that serve as a limitation on Twin Lions’ advice or management. Twin Lions will not generally tailor its advisory services to the individual investors or limited partners in the Funds (each an “Investor” and collectively the “Investors”) or provide Investors with the right to specify or restrict each Fund’s investment objectives or any investment or trading decisions. Accordingly, an investment in any of the Funds does not create a client-adviser relationship between such Investors and Twin Lions. Twin Lions’ investment objective in advising the Funds is to achieve a high long-term rate of return while maintaining prudent risk management. Twin Lions will invest primarily in equity securities. Each Investor is strongly encouraged to undertake appropriate due diligence on Twin Lions and the Funds prior to making an investment decision. This inquiry may include, but is not limited to, a review of the relevant Offering Documents for each Fund and the additional details about Twin Lions’ investment strategies, methods of analysis and related risks (as discussed in Item 8 of this Brochure and each Fund’s Offering Documents). In considering whether Twin Lions’ advisory services or an investment in a Fund is appropriate to the Investor’s own circumstances, such determination should be based on all relevant

factors including, but not limited to, the Investor’s own investment objectives, liquidity requirements, tax situation, and risk tolerance before making an investment decision. Additional detailed information about Twin Lions is provided below, including information about Twin Lions’ advisory services, investment approach, brokerage practices, personnel, and affiliations. Twin Lions does not participate in wrap fee programs. As of June 1, 2026, Twin Lions advises approximately $215,869,723 on a discretionary basis.

Management Fee As the investment adviser to the Twin Lions Fund, Twin Lions will receive a Management Fee calculated at a blended rate that is determined at the beginning of each quarter based on the aggregate net assets in management-fee-paying accounts that are overseen by Twin Lions (“Total Management Fee Paying AUM”). The management fee rate is generally 1.5% per annum (0.375% per quarter) on the first $100 million of Management Fee Paying AUM and 0.75% per annum (0.1875% per quarter) on Management Fee Paying AUM in excess of $100 million. For example, if Total Management Fee Paying AUM were $500 million at the beginning of a quarter, the Management Fee rate for that quarter would be 0.9% per annum (20% x 1.5% + 80% x 0.75%). The $100 million threshold was established as of April 2018 and has been indexed to inflation subsequent to April 2018. For simplicity, the foregoing example does not reflect the impact of such indexation. The Management Fee (if any) for each Fund is deducted on a quarterly basis in advance based upon the value of each Investor’s capital account as of the first day of each calendar quarter. The Management Fee will be prorated for any period that is less than a full calendar quarter. Fees are deducted from each Fund’s custodial or Prime Brokerage account(s). Twin Lions may reduce, waive, or calculate differently the Management Fee for certain Investors in the Funds, including but not limited to, members, employees, affiliates, or relatives of Twin Lions, or for certain strategic and/or large Investors. Operating Expenses of the Funds The Funds will bear all expenses relating to their ongoing structure and operation (either directly or indirectly by reimbursing Twin Lions or the General Partner for amounts incurred by either of them on behalf of the Funds), including: the Management Fee; all investment-related costs and expenses (i.e., expenses that, in Twin Lions’ sole discretion, are related to the investment of the Funds’ assets, whether or not such investments are consummated), including commissions and charges, interest on margin accounts and other indebtedness, expenses relating to short sales, clearing and settlement charges, option premiums and custodial and service fees, research-related expenses (including research-related travel expenses) and expenses relating to consultants, attorneys, brokers or other professionals or advisors who provide research, advice or due diligence services with regard to investments; fees and expenses related to portfolio exposure and performance management systems, risk management services and software related to trade reconciliation, treasury, margin, financial and counterparty management, risk monitoring, performance reporting, valuation quotation services (e.g., Bloomberg terminals, historical and live financial data and other similar services and data feeds) and trade order management systems (including systems

that facilitate trade compliance, commission management, stock locates and transaction cost analysis, and third party service providers used for implementation, custom reporting, updates, consultations, support, maintenance, monitoring and data extracts); each Fund’s legal, accounting, tax preparation and other taxrelated expenses (including preparation and mailing costs of financial statements, tax returns and other reports to Investors), auditing, consulting and other professional expenses; third-party administration costs, fees and expenses (including any costs, fees and expenses related to investor communications, relations, reporting or other investor materials, performance information, data extraction and other types of reporting and any audit or accounting services provided by a third-party administrator); compliance and reporting expenses and expenses attributable to regulatory filings that are made with respect to the Funds or their assets (including Section 13, Section 16, Form D, Form PF, Form N-PX the Foreign Account Tax Compliance Act, anti-money laundering compliance, state security filings, general regulatory compliance and non-U.S. position reporting filings, if applicable, and any other non-U.S. filings) and all compliance costs and expenses associated with the Funds in complying with the rules related to private fund advisers under the Advisers Act; each Fund’s pro rata share of Fund-related insurance costs (including the pro rata portion of director’s and officer’s insurance, errors and omissions insurance, fidelity insurance and other similar policies covering Twin Lions, the General Partner, and/or the members of any advisory committee); any taxes (including, without limitation, any withholding taxes, transfer taxes, stamp duties and other governmental or self-regulatory agency-related charges or duties); all costs and expenses incurred in attempting to protect and enhance the value of the Funds’ investments (including any fees and expenses associated with any pending or threatened litigation, audit, investigation, administrative or other proceeding, as well as any settlement costs); fees and expenses related to any activist-related activities; fees and expenses of any independent advisory committee members and any independent Fund representative; any fees and expenses related to a Fund’s liquidation, if applicable; fees paid to proxy and securities class action advisory firms; expenses relating to the offer and sale of a Fund interest and withdrawals and transfers thereof; other reasonable expenses related to the purchase, sale, preservation or transmittal of the Funds’ assets; and any extraordinary expenses (e.g., indemnification expenses). The Funds do not have their own separate employees or offices, and do not reimburse Twin Lions for salaries or office rent. Twin Lions is responsible for all of its overhead expenses of an ordinary and recurring nature, such as rent, supplies, secretarial expenses, its direct compliance expenses, stationery, charges for furniture and fixtures, salaries, and bonuses of its employees. Organizational Expenses The Funds will generally bear all costs and expenses relating to: (a) the organization of the Funds; and (ii) the offer and sale of interests in the Funds (including government filing fees, stamp duties or other taxes, legal and accounting fees, printing and mailing expenses and any other organizational costs) (collectively, “Organizational Expenses”). To the extent that Twin Lions or the General Partner incur any Organizational Expenses payable by the Funds, Twin Lions or the General Partner will be reimbursed by the Funds for the applicable amounts unless such reimbursement is waived by Twin Lions or the General Partner. The Funds may amortize their Organizational Expenses over a period of up to 60 months from the date each Fund commences operations, although, if deemed to be appropriate, amortization of such amounts may be accelerated as determined by the General Partner in its sole discretion.

Investment Objective Twin Lions’ investment objective in advising the Twin Lions Fund is to achieve a high long-term rate of return while maintaining prudent risk management. Investment Strategy In advising the Twin Lions Fund, Twin Lions will invest primarily in equity securities. Twin Lions will seek common stock investments where Twin Lions believes that the following characteristics are present: (1) an underlying business that earns attractive returns on the resources it employs; (2) a capable and trustworthy management team whose interests are aligned with shareholders’; and (3) a purchase price that represents a substantial discount from the business’s intrinsic value. Twin Lions believes that opportunities meeting all three criteria are rare, so capital will be concentrated in Twin Lions’ best ideas. Twin Lions feels strongly that volatility and beta are not accurate measures of true investment risk. Rather, Twin Lions believes that investment risk is best defined as “the probability and potential severity of permanent capital loss.” To mitigate the risk of permanent capital loss, Twin Lions seeks to invest in businesses that it understands well and that are available at a substantial discount from its estimate of intrinsic value. Twin Lions believes that purchasing securities well below intrinsic value creates a margin of safety which acts as a buffer against adverse developments. In addition to requiring a substantial margin of safety for each investment, Twin Lions seeks to mitigate risk by maintaining adequate diversification so that a bad outcome on one or two investments will not cause inordinate damage to the overall portfolio. Under normal conditions, Twin Lions expects the Twin Lions Fund’s portfolio to consist of approximately 8-15 positions. The Twin Lions Fund will rarely, if ever, use leverage as part of its investment strategy. From time to time, Twin Lions may cause the Twin Lions Fund to sell securities short for hedging purposes or in pursuit of profit. Twin Lions has observed that attractive value can present itself in a variety of asset classes and geographies. Therefore, Twin Lions believes it would be counterproductive to restrict the Twin Lions’ investment universe (other than to industries and businesses Twin Lions can understand). In advising the Twin Lions Fund, while Twin Lions intends to invest primarily in publicly traded equity securities, Twin Lions will consider investments in other asset classes if and when it sees compelling opportunities. For example, Twin Lions may evaluate a variety of special situations such as merger securities, spinoffs, liquidations, privatizations, distressed credit instruments, thrift conversions, rights offerings, warrants, etc. Under normal circumstances, Twin Lions expects to invest the majority of the Twin Lions Fund’s capital in companies based in the United States, although it will consider investments in any geography so long as the risk/reward relationship is attractive. Flexibility In advising the Twin Lions Fund, Twin Lions intends to pursue the investment strategy described above as long as such strategy is in accordance with the Twin Lions Fund’s investment objective. In addition, it may also formulate and implement new approaches to carry out the investment objective of the Twin Lions Fund. While it is anticipated that in advising the Twin Lions Fund, Twin Lions will invest primarily in equities, Twin Lions has broad and flexible investment authority. Accordingly, Twin Lions’ investments may at any

time include, without limitation, long or short positions in U.S. or non-U.S. publicly traded or privately issued or negotiated common stocks, preferred stocks, stock warrants and rights, corporate debt, bonds, notes, participations, convertible securities, fixed income securities, swaps, options (purchased or written), futures contracts, commodities, forward contracts, foreign exchange (including but not limited spot transactions, forwards, futures on currencies and non-deliverable forwards) and other derivative instruments, partnership interests and other securities or financial instruments including those of investment companies and cash and cash equivalents. Twin Lions may create or organize (alone or in conjunction with others, including Twin Lions, the General Partner or other affiliates) or otherwise utilize special purpose subsidiaries, co-investment vehicles, feeders or other special purpose investment vehicles, particularly in instances where Twin Lions, in its sole discretion, determines that there is a potential strategic, tax, regulatory or similar advantage to such structure. There can be no assurance that the Funds will realize their investment objectives. Key Risk Factors The following are material risks involved in Twin Lions’ investment strategy in relation to advising the Funds. There can be no assurance that Twin Lions’ investment objective in managing the Funds will be achieved, and that the Investors in the Funds will not incur losses. The risks described below are not meant to be a comprehensive collection of all risks with which Investors in the Funds will be confronted. Each Investor in the Funds is also encouraged to consult with Twin Lions to review the specific risk parameters of, and assets that comprise, each Fund’s portfolio at any given time and from time to time. Investors should also read the Offering Documents in their entirety for a more detailed discussion of the risks of investing in the Funds and consult with their own legal, tax and accounting advisors prior to undertaking an investment in the Funds. Risk of Loss. Investing in securities involves risk of loss that Investors should be prepared to bear. All investments in securities and other financial investments involve substantial risk of volatility arising from numerous factors that are beyond the control of Twin Lions, including market conditions, changing domestic or international economic or political conditions, changes in tax laws and government regulation and other factors. Dependence on Twin Lions. Twin Lions has discretion to select investments for the Funds. All management decisions will be made by Twin Lions. Accordingly, no potential Investor should invest in a Fund advised by Twin Lions unless it is willing to entrust all aspects of the management of the Funds to Twin Lions, who will have considerable discretion in the types of securities in which each Fund will invest. Investments for the Funds will be dependent upon the skill, judgment and expertise of Timothy Abbott, the Principal of Twin Lions, and if Mr. Abbott was no longer able to perform such function, the Funds could be adversely affected. Reliance on the Principal. As discussed, Twin Lions relies heavily on the expertise and efforts of Timothy Abbott, the Principal of Twin Lions. The Principal is responsible for all of the major decisions affecting the Funds. Should the Principal determine to discontinue managing the affairs of, or withdraw from, Twin Lions, or should the Principal die, become incapacitated or, for some other reason, be unable to effectively manage the affairs of Twin Lions, the business and results of the operations of the Funds may be adversely affected. Lack of Liquidity of the Funds’ Investments. The Funds’ assets may include securities and other financial

instruments or obligations that are thinly-traded or for which no market exists and/or which are restricted

as to their transferability under applicable securities laws. The sale of any such investments may be possible only at substantial discounts, and it may be extremely difficult to accurately value any such investments. Nature of Investments. In accordance with the Funds’ investment objectives, Twin Lions has broad discretion in making investments for the Funds. Investments will consist of assets that may be affected by business, financial market or legal uncertainties and are subject to a number of risks. There can be no assurance that Twin Lions will correctly evaluate the nature and magnitude of the various factors that could affect the value of and return on the Funds’ investments. Prices of investments may be volatile and are inherently difficult to predict. Any of these factors may significantly affect the results of the Funds’ activities and the value of its investments. No guarantee or representation is made that the investment objective of the Funds will be achieved. Equity-Related Securities in General. In advising the Funds, Twin Lions will invest in equity securities, which represent ownership interests in their respective issuers and generally carry the most risk associated with a specific issuer’s capital structure. The value of equity securities fluctuates in response to issuer, political, market and economic developments. Fluctuations can be dramatic over the short as well as long term, and different parts of the market and different types of equity securities can react differently to these developments. For example, large cap stocks can react differently from small cap stocks, and “growth” stocks can react differently from “value” stocks. Issuer, political, or economic developments can affect a single issuer, issuers within an industry or economic sector or geographic region, or the market as a whole. Changes in the financial condition of a single issuer can impact the market as a whole. Terrorism and related geo-political risks and public health emergencies have led, and may in the future lead, to increased short-term market volatility and may have adverse long-term effects on world economies and markets generally. Lack of Diversification of Positions. Twin Lions’ investment program for the Funds will not necessarily be widely diversified. Accordingly, the investment portfolio of the Funds may be subject to more rapid changes in value than would be the case if the Funds maintained a wide diversification among companies, securities and types of securities. Micro to Medium Capitalization Companies. In advising the Funds, Twin Lions may invest in companies with micro- to medium-sized market capitalizations. These types of securities, particularly the securities of smaller-capitalization companies, involve higher risks in some respects than do investments in securities of larger companies. For example, prices of such securities are often more volatile than prices of securities of large-capitalization companies. Smaller companies often lack the management experience, financial resources, product diversification, and competitive strength of larger companies. Additionally, due to thin trading in some such securities, an investment in these securities may be more illiquid than those of larger capitalization companies. High Growth Industry Related Risks. The Funds may have investments in the securities of high growth companies. These securities may be very volatile. Certain of the high growth companies in which the Funds may invest, may allocate, or may have allocated, greater than usual amounts to research and product development. The securities of such companies may experience above-average price movements associated with the perceived prospects of success of the research and development programs. In addition, companies in which the Funds may invest could be adversely affected by lack of commercial acceptance of a new product or products or by technological change and obsolescence. Some of these companies may have limited operating histories. As a result, these companies may face undeveloped or limited markets, have limited products, have no proven profit-making history, may operate at a loss or with substantial variations in operating results from period to period, have limited access to capital and/or be in the developmental stages of their businesses.

Read the rest in the brochure

Twin Lions’ clients are the Funds. The initial subscription minimum is generally US $100,000, as disclosed in the Offering Documents for each Fund. The Offering Documents provide the eligibility criteria and minimum investment requirements to be an Investor in the Funds. Each prospective Investor will be required to represent, among other things, that it is: (i) an “accredited investor”, as such term is defined in Rule 501 of Regulation D under the Securities Act of 1933 (the “Securities Act”), as amended; and (ii) a “qualified client”, as defined in the Investment Advisers Act of 1940 (the “Advisers Act”).

Subject to a loss carryforward provision (as described below), at the end of each fiscal year, the General Partner will receive at the Fund level an incentive allocation (the “Incentive Allocation”). When calculating

the Incentive Allocation at the Fund level, the Management Fee and all items of income, loss and expense incurred at the Fund level will be considered. For the avoidance of doubt, the Incentive Allocation will be determined separately with respect to each Investor. As described in detail in the Offering Documents for the Twin Lions Fund, the General Partner will receive an Incentive Allocation from the Twin Lions Fund in an amount equal to 20% of the Twin Lions Fund’s outperformance (if any) over a 6% per annum hurdle return, allocated over a three-year period and subject to reduction for underperformance during such period. In the event that an Investor makes a partial or complete withdrawal of its interests or its interests are mandatorily withdrawn at any time other than the end of a fiscal year, the General Partner will be entitled to the Incentive Allocation with respect to the withdrawn amount, calculated as though the date of such withdrawal were the last day of the fiscal year. The General Partner may, in its sole discretion, waive or modify the Incentive Allocation for Investors that are members, partners, principals, employees or affiliates of the General Partner or Twin Lions, relatives or entities of such persons, and for certain strategic and/or large Investors. In addition, the General Partner may, in its sole discretion, cause all or a portion of the Incentive Allocation otherwise allocable to it to be allocated to one or more other persons or entities. Performance-based allocation and fee arrangements may create an incentive for Twin Lions to recommend investments which may be riskier or more speculative than those which would be recommended under a different arrangement. As described herein, Twin Lions advises the Funds (and may advise other private funds or client accounts in the future), and this would, in turn, require Twin Lions to allocate investments amongst multiple client accounts. Such an allocation arrangement may also create an incentive to favor higher performance allocation or performance fee accounts over other accounts in the allocation of investment opportunities. Twin Lions has procedures designed and implemented to ensure that the Funds (and any future private fund or client accounts) are treated fairly within the limits of the investment constraints and objectives of each Fund, and to prevent this potential conflict from influencing the allocation of investment opportunities among multiple client accounts. These procedures include, to the extent orders are aggregated, that orders are average priced.

Neither Twin Lions nor the General Partner are registered or have an application pending to register as a broker-dealer or a registered representative of a broker-dealer. Twin Lions GP LLC has filed a notice of exemption from registration as a commodity pool operator and operates the Funds in accordance with the requirements of Commodity Futures Trading Commission Regulation 4.13(a)(3).

Trading Twin Lions has adopted a Code of Ethics pursuant to Rule 204A-1 of the Advisers Act (the “Code”) that establishes certain standards of conduct and rules for its employees and/or access persons (as applicable). A summary of the Code is provided below. All access persons of Twin Lions must acknowledge annually that they understand and agree to the terms of the Code. The Code incorporates the following general principles that all employees are expected to uphold at all times: •

Employees must place the interest of clients first;

•

Employees must conduct all personal securities transactions in a manner consistent with the Code and seek to avoid both actual conflicts of interest and the appearance thereof, and;

•

Employees may not take inappropriate advantage of their own positions with Twin Lions for their own personal benefit.

Personal Trading The Code provides that access persons must obtain pre-approval from the CCO prior to buying or selling a Reportable Security in a Covered Account (as such terms are defined in the Code). Reportable Securities generally include stocks, bonds, and derivatives relating thereto, as well as interests in limited partnerships and other private funds, with certain limited exceptions (e.g. for U.S. government obligations, mutual funds, and exchange-traded funds that track a broad-based index such as the S&P 500). Covered Accounts generally include accounts that an access person controls or in which an access person may be deemed to have beneficial ownership (such as the account of a spouse or minor child), but exclude accounts over which the access person has no direct or indirect influence or control (such as accounts over which the access person has granted full investment discretion to an unaffiliated investment adviser).

Twin Lions believes that these policies put client interests first and will mitigate inherent conflicts of interest with access persons trading for their personal accounts or accounts that the access person controls or in which the access person may be deemed to have beneficial ownership. Exceptions to the personal trading policy are handled on a case-by-case basis. However, Twin Lions will maintain a restricted list, and personal trading requests to trade in securities on the restricted list will be denied. Gifts and Entertainment, Political Activities and Outside Activities The Code provides that gifts and entertainment must be reasonable in light of industry practices and should never be given or received if the purpose is to influence the recipient. Twin Lions requires access persons to report or receive approval for the receipt or giving of gifts and entertainment under certain circumstances. The Code also generally requires access persons to obtain prior approval before the access person, a spouse or certain other immediate family members makes a political contribution or engages in certain campaign-related fundraising activities. This policy is intended to prevent scenarios whereby an access person may make a contribution or engage in an activity to influence the selection of Twin Lions as an investment adviser for a governmental entity. Finally, the Code provides that, without prior approval, access persons are generally not permitted to engage in certain types of outside business activities. This policy is intended to prevent material conflicts of interest that could arise from an access person’s personal activities. Cross Trades From time to time, Twin Lions may engage in cross trades for portfolio rebalancing or other purposes. In the event that Twin Lions executes such a trade, it generally will instruct the custodian for the Funds participating in the trade to book the transaction at the closing price on the day of the transaction (or at a price determined in accordance with Twin Lions’ Valuation Policy if an official closing price is not available). Twin Lions will not receive any fee or commission in connection with any cross trade. Twin Lions does not intend to engage in principal transactions. Additional Considerations From time to time, various potential and actual conflicts of interest may arise from the overall advisory, investment and other activities, partners and personnel in connection with client transactions. Twin Lions has established written policies and procedures, which contain procedures to monitor and resolve conflicts and will endeavor to resolve conflicts in a manner it deems equitable to the extent possible under the prevailing facts and circumstances. Further, the Code includes policies and procedures designed to prevent insider trading and facilitate the protection of material, non-public information, including non-public information about the activities of Funds. Twin Lions’ Code of Ethics is available to clients upon request.

Factors Considered in Selecting or Recommending Broker-Dealers for Client Transactions In selecting brokers for execution, Twin Lions will assess the reasonableness of their compensation and commissions charged based on the range and quality of a broker’s services, including execution capability, trading expertise, accuracy of execution, commission rates, research, reputation and integrity, fairness in resolving disputes, financial responsibility, and responsiveness. In selecting a broker-dealer to execute transactions and determining the reasonableness of the brokerdealer’s compensation, Twin Lions need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost. It is not Twin Lions’ practice to negotiate “execution only” commission rates, thus the Funds may be deemed to be paying for research, brokerage or other services provided by a broker-dealer which are included in the commission rate. Twin Lions may, from time to time, speak at conferences and programs for investors interested in investing in hedge funds which are sponsored by Prime Brokers. These conferences and programs may be a means by which Twin Lions can be introduced to potential investors or clients. Prime Brokers normally are not compensated for providing such "capital introduction" opportunities. In addition, Prime Brokers or custodians may provide financing and other services to the clients. Twin Lions may place portfolio transactions for the Funds with such firms, if Twin Lions determines that it is otherwise consistent with seeking best execution. In no event will Twin Lions select a broker-dealer as a means of remuneration for recommending Twin Lions or the Funds or affording Twin Lions with the opportunity to participate in capital introduction programs. Research and Other Soft Dollar Benefits Twin Lions may use "soft dollars" generated through brokerage transactions for research and brokerage and research-related products and services. Usage of soft dollars will fall within the safe harbor provided under Section 28(e). Twin Lions will evaluate the execution of broker-dealers on an ongoing basis as they are used and periodically conduct a review of the execution performance of broker-dealers executing its clients’ transactions to make a good faith determination that the value of research and brokerage services received is reasonable in relation to the amount of commissions paid. Research services within Section 28(e) for which Twin Lions may use soft dollars can include, without limitation, access to research reports (including market research); certain financial newsletters and trade journals; software providing analysis of securities portfolios; corporate governance research and rating services; attendance at certain seminars and conferences; discussions with research analysts; meetings with corporate executives; consultants’ advice on portfolio strategy; data services (including services providing market data, company financial data and economic data); advice from brokers on order execution and certain proxy services. Brokerage services within Section 28(e)’s safe harbor for which Twin Lions uses soft dollars can include: services related to the execution, clearing and settlement of securities transactions and functions incidental thereto. These services may include, among other things, order management systems, electronic trading platforms, trade analytics, and data and analytics services used in connection with trading and investment decision-making.

Trade Order Aggregation Twin Lions may aggregate purchase and sale orders of investments held by Funds with similar orders being made simultaneously for other accounts if, in Twin Lions’ reasonable judgment, such aggregation is reasonably likely to result in an overall economic benefit to such Fund based on an evaluation that the Fund will be benefited by relatively better purchase or sale prices, lower commission expenses or beneficial timing of transactions, or a combination of these and other factors. In some instances, the purchase or sale of investments for a Fund may be effected simultaneously with the purchase or sale of like investments for another Fund(s). Such transactions may be made at slightly different prices due to, among other factors, the volume of investments purchased or sold. In such event, the average price of all investments purchased or sold in such transactions may be determined, in Twin Lions’ sole discretion, and the Fund(s) may be charged or credited, as the case may be, with the average transaction price. Allocation of Trades Twin Lions may determine that certain investments are suitable for acquisition by multiple Funds. If Twin Lions is not able to acquire the desired aggregate amount of such securities on terms and conditions which Twin Lions deems advisable, Twin Lions will endeavor in good faith to allocate the limited amount of such securities acquired among the various Funds for which Twin Lions considers them to be suitable on a pro rata basis. Pursuant to Twin Lions’ policy related to the allocation of trades, Twin Lions may deviate from allocating trades on a pro rata basis for a variety of reasons, including, but not limited to, (i) differences in brokerage relationships between the Funds, (ii) differences in the investment policies and strategies of the Funds, and (iii) differences in the Funds’ cash flows, liquidity, and existing portfolio exposures. Cross Trades and Principal Transactions From time to time, Twin Lions may engage in cross trades for portfolio rebalancing or other purposes. In the event that Twin Lions executes such a trade, it generally will instruct the custodian for the Funds participating in the trade to book the transaction at the closing price on the day of the transaction (or at a price determined in accordance with Twin Lions’ Valuation Policy if an official closing price is not available). Twin Lions will not receive any fee or commission in connection with any cross trade. Twin Lions does not intend to engage in principal transactions. Trade Errors Pursuant to the exculpation and indemnification provided by the Funds to Twin Lions and its affiliates and personnel, Twin Lions and its affiliates and personnel will generally not be liable to the Funds for any act or omission, absent bad faith, gross negligence, willful misconduct or actual fraud of such person, and the Funds will generally be required to indemnify such persons against any losses they may incur by reason of any act or omission related to the Funds, absent bad faith, gross negligence, willful misconduct or actual fraud of such person. As a result of these provisions, the Funds (and not Twin Lions) will benefit from any gains resulting from trade errors and other errors and will generally be responsible for any losses (including additional trading costs) resulting from trade errors and other errors, absent bad faith, gross negligence, willful misconduct or actual fraud of the relevant person. Twin Lions will not offset any such gains and losses resulting from trade errors and other errors unless the underlying transactions constitute a single transaction or closely related series of transactions.

Twin Lions does not currently compensate, either directly or indirectly, persons for client referrals or referrals of Investors in the Funds.

Twin Lions has not been subject to any disciplinary action, whether criminal, civil or administrative (including regulatory), in any jurisdiction. Likewise, no persons involved in the management of the Firm have been subject to such action.

Twin Lions conducts daily reviews of the Funds’ portfolios to ensure conformity with investment objectives and guidelines. In addition, Twin Lions reviews transactions, positions, and cash balances daily, along with conducting various other periodic reviews. Investors in the Funds generally receive monthly account statements. Twin Lions may, in its discretion, provide certain Investors with additional information on a more frequent basis upon request. Investors also receive copies of audited financial statements and Schedules K-1 on an annual basis.

Twin Lions is subject to Rule 206(4)-2 under the Advisers Act (the "Custody Rule"). Twin Lions GP LLC is deemed to have custody of Twin Lions Partnership LP’s and Twin Lions SPV II LP’s assets by virtue of its status as general partner of those Funds. Twin Lions GP LLC maintains the Funds’ assets in accounts with “qualified custodians” pursuant to Rule 206(4)-2 under the Advisers Act (the “Custody Rule”). The qualified custodians presently utilized by the Funds are disclosed in Twin Lions’ Form ADV Part 1. While Twin Lions is subject to the Custody Rule, it is not required to comply (or is deemed to have complied) with certain requirements of the Custody Rule with respect to each Fund because it complies with the “Pooled Vehicle Annual Audit Exception,” which, among other things, requires that each Fund be subject to audit at least annually by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, and requires that each Fund distribute its audited financial statements, prepared in accordance with U.S. generally accepted accounting principles, to all investors within 120 days of the end of such Fund’s fiscal year. Investors should carefully review the audited financial statements of the Funds upon receipt.

Pursuant to the Offering Documents for the Funds, Twin Lions has discretionary authority to manage and to make purchase and sale decisions for the Funds. As explained in Item 4 above, individual Investors in the Funds generally do not have the ability to impose limitations on Twin Lions’ discretionary authority. Prospective Investors are provided with Offering Documents prior to their investment in a Fund and are encouraged to carefully review such documents with their legal, tax and accounting advisers. All Investors must execute a subscription agreement.

Proxy Voting Policy Twin Lions has established proxy voting policies and procedures designed to ensure that proxies, to the extent Twin Lions has been delegated authority to vote such proxies on behalf of the Funds and elects to vote, are voted in the best interest of the Funds. When voting proxies, Twin Lions must identify and

address material conflicts that may arise between Twin Lions’ interests and those of the Funds. Specifically, Twin Lions monitors the potential for conflicts of interest that might arise from personal relationships that Twin Lions or its employees may have with parties involved in the vote, significant Investor relationships with those parties, and other special circumstances. Twin Lions will vote proxies as it deems necessary or appropriate, on a case-by-case basis. Prior to voting, Twin Lions will determine whether a conflict of interest exists that is material to the vote. If such a conflict exists, Twin Lions will either resolve the conflict or refer the proxy vote to an outside service for its independent consideration. In certain circumstances, Twin Lions may refrain from voting proxies where Twin Lions believes that voting would not be in the best interest of the Funds, taking into consideration the time required to vote the proxies and the anticipated benefit to the Funds. If you have any questions about Twin Lions’ proxy policy, its proxy record-keeping procedures or if you would like any further information about how proxies are voted, please contact the CCO.

Twin Lions is not currently aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients.