TWO SIGMA INVESTMENTS, LP

The Adviser commenced operations as an investment adviser in April 2002 and has been registered with the SEC since August 21, 2009. The Adviser’s principal place of business is in New York, New York. Two Sigma Management, LLC is the general partner of the Adviser (“General Partner”). Trusts established by Two Sigma’s co-founders, John A. Overdeck and David M. Siegel, are the principal owners of the General Partner and the Adviser and thus the indirect control entities of the Adviser. A two-person management committee of the General Partner oversees management of the Adviser and its affiliates (“Management Committee”), and each of Two Sigma’s co-founders has the authority to appoint or remove his designated executive manager (“Executive Manager”) on the Management Committee. Mr. Overdeck and Dr. Siegel currently serve as the Co-Chairmen of the General Partner (“Co-Chairmen”). Since March 31, 2025, Mr. Overdeck has also served as one of the Executive Managers. As of March 16, 2026, Dr. Siegel designated Seth Platt as his Executive Manager to replace Scott Hoffman, who resigned citing ongoing governance challenges since Mr. Overdeck’s return to the Management Committee. The Management Committee is heavily engaged with the Adviser’s senior executives regarding the Adviser’s investment management business. The Adviser provides discretionary advice to private investment funds, consisting of both commingled vehicles (including employees’ securities companies and funds that are only available to owners, and/or current or former employees of the Adviser and/or its affiliates) and funds of one, and separately managed accounts. The Adviser also provides discretionary advice as one of many sub-advisers to an investment company registered under the U.S. Investment Company Act of 1940, as amended (“Investment Company Act”) and as investment manager to a sub-fund organized in accordance with the European Union’s Undertakings for Collective Investment in Transferable Securities (“UCITS”). The private investment funds, separately managed accounts, investment company, and UCITS are referred to herein collectively as “Clients”, and each as a “Client”. The Adviser provides advisory services to Clients pursuant to the investment objectives and restrictions in each Client’s offering memorandum, investment management agreement, subadvisory agreement, prospectus and supplemental disclosure document or other governing documents, as applicable (“Applicable Governing Documents”). Clients may also enter into side letters or similar agreements with certain prospective or existing investors whereby such investors are subject to terms and conditions that are different and/or more advantageous than those set forth in the relevant Client offering memorandum or other agreement and which may be considered preferential. Other than any restrictions in the Applicable Governing Documents or such side letters, Clients have broad investment objectives and generally do not impose restrictions on investing in certain types of Instruments. The Adviser specializes in process-driven, systematic investment management using quantitative analysis to build mathematical strategies that rely on patterns inferred from historical prices and other data in evaluating prospective investments. These systematic strategies are implemented by employing various risk management, investment, optimization and execution techniques (collectively, “Techniques”). In addition to systematic strategies and Techniques, the Adviser

utilizes certain non-systematic and/or discretionary strategies and Techniques often based, at least in part, on quantitative analysis. In certain cases, the Adviser expects to rely primarily or solely on human discretion, including for the purpose of pursuing what are viewed by its investment professionals as opportunistic trade ideas or discretionary strategies. The Adviser provides advisory services with respect to a broad range of securities and other financial instruments, which include or may include U.S. and non-U.S. equity and equity-related securities, bonds and other fixed income securities, exchange traded products, debt instruments, futures, warrants, listed and over-the-counter (“OTC”) options, insurance-related instruments (including insurance-linked securities and reinsurance-related securities), SPACs, repurchase agreements, reverse repurchase agreements, swaps (of any and all types), convertible instruments, inflation protection instruments, mortgage and asset-backed instruments (including collateralized loan obligations), swaptions and other complex or exotic derivatives, currencies and currency contracts (including options, forwards and non-deliverable forward contracts), commodities, derivatives on virtual currencies and/or other digital assets, U.S. and non-U.S. money market funds, money market instruments, and other cash equivalents, and any derivatives or financial instruments that are hereafter created (collectively, “Instruments”). Due to the global nature of its activities, the Adviser receives certain support services from some of its subsidiaries that are organized as separate legal entities with their own personnel and applicable foreign licenses or registrations and whose primary activity is to provide services to the Adviser. The Adviser’s other affiliates engage in a wide range of investment and other financial activities, pursuing their own separate businesses even if in some instances they also provide certain services to the Adviser. For more information relating to the Adviser’s affiliates, please see Item 10 of this brochure. In addition, as part of its supervisory structure, the Adviser maintains committees that are assigned specific functions related to various aspects of the Adviser’s business. These functions and the membership, scope and/or existence of committees will likely vary and evolve over time along with the Adviser’s business and applicable regulations, and new committees may be established from time to time. For example, the Investment Review Committee (“IRC”) was formed in 2025 as an oversight body with cross-functional expertise to monitor and address investment management policies, decisions, and risks. As of January 31, 2026, the Adviser managed approximately $232,818,912,899 in client assets, all on a discretionary basis. The method used for determining the Adviser’s client assets is the same method used for determining the Adviser’s regulatory assets under management for purposes of Item 5.F of Form ADV Part 1A.

Asset-Based Compensation Many Clients pay the Adviser management fees (“Management Fees”). For the substantial majority of private investment funds that pay Management Fees, such fees are deducted by the Client’s custodian from the Client’s account under the Adviser’s instructions. In its capacity as a sub-adviser to a registered investment company and as an investment manager to UCITS, the Adviser receives Management Fees from the primary investment adviser (or in the case of the UCITS, the management company) of each such entity. The Management Fees are typically based on the Client’s assets under management and are determined based on an annualized rate. Currently, such fees have annualized rates of up to 4%, as described in each such Client’s Applicable Governing Documents (though, as noted below, such rates are higher or lower for certain investors in Clients). The Management Fees are generally payable monthly or quarterly in advance or in arrears, depending on the Client. The Adviser has waived the Management Fees for most Proprietary Funds (as defined below), and has reduced and/or modified the Management Fees for certain investors in other Clients, including for Proprietary Capital (as defined below), and may do so in the future. Similarly, the Adviser (and/or its affiliate, as applicable) has substituted the Management Fees in whole or in part with incentive allocations or incentive fees as agreed with investors in Clients and may do so in the future. Performance-Based Compensation The Adviser or its affiliate, Two Sigma Principals, LLC (“TSP”), serves as the general partner, member, allocation shareholder or similar entity, as applicable, of many Clients, and is entitled to receive performance-based compensation from certain Clients based on a share of capital gains or capital appreciation of the assets of a Client, in some cases as measured above an applicable benchmark. Performance-based compensation may be in the form of incentive fees paid to the Adviser, or an incentive allocation paid to TSP (“Incentive Compensation”). Incentive Compensation generally ranges from 12.0% to 42.5% of the net profits (in certain cases, above an applicable benchmark) for each calendar quarter or year. Incentive Compensation is generally subject to adjustment for unrecovered net losses (or underperformance relative to an applicable benchmark), subject to certain other adjustments and provisions. Where applicable, the Incentive Compensation is paid to the Adviser from such Client, or deducted from the Client’s account by the Client’s custodian, generally as of the close of each such calendar quarter or year. Incentive Compensation is allocated from investor accounts at Clients to the account of TSP following the Adviser’s instructions. The Adviser or TSP, as applicable, has waived the Incentive Compensation for all Proprietary Funds, and has reduced and/or modified the Incentive Compensation for certain investors in other Clients, including for Proprietary Capital.

Other Fees and Expenses Clients typically are responsible for their own operating and investment expenses, including: fees, costs and out-of-pocket expenses incurred in connection with the formation of a Client; external legal, auditing, accounting, administration, registered office, trustee, tax return preparation and other professional fees and expenses; fees and expenses of the Client’s directors, where applicable, including the costs associated with meetings; fees and expenses of the Client’s administrator; outof-pocket costs of the Client’s reporting to regulatory authorities; taxes, fees and governmental charges or filing fees (including foreign marketing registration and filing fees and expenses); fees and expenses of prime brokers, futures commission merchants, dealers, custodians, subcustodians, transfer agents and registrars; expenses of registering or qualifying securities and other investments; brokerage commissions and dealer collateral and other fees, charges, payments, expenses and other costs of trading, acquiring, monitoring or disposing of any investments of the Client (including, for the avoidance of doubt, exchange membership fees and expenses related to trading, acquiring, monitoring or disposing of any investments in preparation for an inflow or outflow of capital); research expenses, including fees and expenses of any third-party research, data, recommendations and/or services used by the Adviser in its investment decision-making process (e.g., in connection with the use, implementation and support of alpha capture systems and/or any other contributor platforms, including those developed by third parties, the Adviser and/or its affiliates); fees and expenses of valuation and/or pricing services and software; interest expenses; expenses of preparing and distributing reports, financial statements and notices to investors in the Client; litigation and other extraordinary expenses; certain insurance expenses (including fees for directors’ and officers’ liability insurance); and other expenses as detailed in the Client’s Applicable Governing Documents. Where applicable, Clients also pay their pro rata share of the expenses of the underlying investment vehicles in which they directly or indirectly invest. Please refer to Item 8 of this brochure for further discussion of conflicts of interest with respect to Client expenses. Please refer to Item 12 of this brochure for further discussion of the Adviser’s brokerage practices, including the use of soft dollars to pay for research.

Strategies & Risk of Loss Methods of Analysis and Investment Strategies The Adviser utilizes a variety of methods and strategies to make investment decisions. The Adviser integrates information, computing power and human skill to attempt to systematically (and, in certain cases, non-systematically) extract alpha. All of the investment methods and strategies used by the Adviser involve the risk of loss that Clients and investors in Clients should be prepared to bear. The Adviser primarily combines multiple hedged and leveraged investment strategies with Techniques to make investment decisions for Clients. The investment strategies that the Adviser employs include the following: statistically-based strategies; merger (or risk) arbitrage; fundamentally-driven strategies; event-driven strategies; spread-based and long/short strategies; relative value strategies; volatility arbitrage and trading strategies; structured credit trading strategies; and contributor-based and sentiment-based strategies (e.g., strategies based on the Adviser’s proprietary alpha capture system). The specific strategies utilized on behalf of any given Client are described in greater detail in such Client’s Applicable Governing Documents. In general, the Adviser primarily uses quantitative mathematical models to implement its strategies and to seek to achieve the investment objectives of each Client. Such quantitative mathematical models are highly complex and rely on patterns inferred from historical prices and large amounts of financial and other data to evaluate prospective investments. These models are typically implemented using high-powered computers that generate buy or sell indications to assist the Adviser in the purchase and sale of Instruments. The Adviser also employs strategies and Techniques that focus more on fundamental analysis and research (rather than computer-based quantitative and technical analysis) and/or strategies that combine two or more types of analysis in varying degrees. Fundamental analysis and research explore, among other things, issuers, industries, current market and financial conditions and an understanding of the drivers of change within these areas. Such fundamental analysis and research are generated by internal personnel and substantial numbers of external investment professionals, data vendors, market participants, experts, other consultants to the Adviser and/or licensors as augmented from time to time by the Adviser. The Adviser has discretion to apply systematic mathematical formulae to such analysis and research, or to use such analysis and research alone, without further quantitative analysis to assist in the Adviser’s investment decision-making process. The Adviser has and expects to continue to authorize the sharing or discussion of certain investment ideas, theses, strategies or derived data, including as they relate to current holdings or strategies of the Adviser or Clients, with other investors, financial professionals or more broadly. Given the differences among Clients and their respective investment objectives and restrictions, the sharing or discussion of these investment ideas, theses, strategies or derived data by the Adviser may not reflect the forecasts and/or investment activity of all Clients. To the extent that other investors or financial professionals use such investment ideas, theses, strategies or derived data to

buy (or sell) certain Instruments while one or more Clients are buying (or selling) the same Instruments, there is potential for Clients’ returns to be impacted to varying degrees. Discretionary Strategies In addition to systematic investment strategies and the application of systematic strategies to human-driven fundamental research, the Adviser engages in various forms of discretionary and less-systematic methods of analysis and portfolio management on behalf of Clients that, while often aided by quantitative analysis, are typically based primarily or solely on human discretion. Discretionary strategies and Techniques utilized by Clients seek, among other things, to express views based on fundamental research, market sentiment, to take advantage of perceived or predicted events, opportunities or market conditions, and/or to help manage certain risks. Discretionary strategies and Techniques often rely on manual processes and do not benefit from the full range of tools and systems used by the Adviser for systematic portfolio management, risk management and trading. While the Adviser believes that discretionary strategies present certain opportunities, discretionary strategies and Techniques are more susceptible to certain risks, errors and/or behavioral biases that could adversely affect Clients. Certain of such strategies and Techniques are expected to be materially reliant on human discretion and in many cases will not utilize optimization processes and/or other systematic Techniques as described elsewhere in this brochure. While such strategies are often aided by quantitative analysis, the investment and risk management decision-making for such strategies is directly dependent upon human judgment. Discretionary decision-making will likely result in a different evaluation of the nature and magnitude of various factors that affect the value and risk of investments, as compared to a more systematic approach. There can be no assurance that such discretionary decisions will perform comparably with a more systematic process or that such discretionary decisions will not result in material losses. Further, the performance of discretionary strategies is dependent to a material degree on the individuals exercising human discretion. See “Reliance on Individuals.” In many cases, discretionary strategies, and the investment opportunities pursued by such strategies, will not be made available to all Clients due to, among other things, their dependence on the expertise of portfolio-specific personnel, mandate constraints, implementation challenges, regulatory considerations and resource limitations. In addition, the Adviser has previously opted, and may in the future decide, to make available certain discretionary strategies exclusively to certain Proprietary Funds while those strategies are newly deployed, or undergoing testing or incubation. See Item 6. “Performance-Based Fees & Side-by-Side Management—Certain Conflicts of Interest Associated with Side-by-Side Management—Allocation of Systematic and Discretionary Strategies and Techniques” for more information on the Adviser’s practices of testing, incubating and/or trading Experimental Strategies and Techniques with Proprietary Capital. Overview of Risk Management Risk management is an integral part of the Adviser’s investment process and maintaining a controlled overall level of risk is part of the Adviser’s objective in managing Client assets, though

there can be no assurance that risks will be effectively managed or mitigated. The Adviser generally seeks to control risk systematically through the use of its proprietary portfolio management and risk management systems and Techniques. However, the Adviser also employs certain non-systematic strategies to manage risk. Portfolio managers, working together with other personnel, evaluate various risks related to a given Client’s underlying portfolios and work to develop techniques for measuring, managing, and mitigating those risks. The Adviser’s Chief Risk Officer serves as an independent check on the risks taken across the platform and the Chief Risk Officer’s team runs various stress tests to measure those risks. As applicable, the Risk Management department liaises with the portfolio managers to understand and potentially mitigate sources of risk. Except where otherwise noted, the discussion of risk management processes below applies to the Adviser’s systematic strategies. In the case of systematic strategies, the Adviser primarily seeks to control risk for a given Client through a combination of strategy weightings, position limits, and other controls that are programmed into each optimizer, and seeks to mitigate unwanted risk and factor other risks into the decision-making process when deciding which positions to hold in a given portfolio. This process is generally automated, but remains under the oversight of the portfolio managers, the Adviser’s Co-Chief Investment Officers and the Chief Risk Officer (and their respective teams). The Adviser at times also employs certain manual, discretionary and/or non-systematic processes and/or methodologies to seek to manage certain risks. To seek to better control aggregate risk and to obtain efficiency in execution, multiple strategies are often traded together in combined, quantitatively-optimized portfolios within Clients’ systematic portfolios. Another goal of strategy weighting is to prevent any single strategy or set of strategies from unintentionally dominating a portfolio, although, for the avoidance of doubt, portfolios do employ heavily weighted strategies or sets of strategies in the Adviser’s discretion. The Adviser primarily relies upon the portfolio optimization process to determine such a portfolio’s “target goal position” in a given Instrument. The optimization process incorporates certain risk parameters and factors that, combined with other metrics, shape the final “target goal position” value. These risk constraints and metrics are developed, in part, in an effort to seek to ensure that the Client stays within its investment objectives and restrictions. When a Client’s systematic portfolio seeks to buy or sell an Instrument, the applicable optimizer measures certain known risks that would result from trading in such an Instrument and adjusts the target goal positions accordingly. An optimizer makes target goal position adjustments based on risks related to size, liquidity, sector exposure and certain other factors. Hedging trades can also be used as a mechanism to seek to limit or offset certain risk-taking orders generated by an optimizer on behalf of a Client. Additionally, at any given time, the strategies and Techniques employed on behalf of a Client may involve significant systematic and non-systematic risks. With respect to both systematic and discretionary strategies, portfolio managers, the Co-Chief Investment Officers and the Chief Risk Officer (and their teams) monitor risk on an ongoing basis, and the portfolio managers or the Co-Chief Investment Officers may take action. The Risk Management teams may also advise portfolio managers or the Co-Chief Investment Officers to take action, if unwanted risk is detected. Such actions could include reducing strategy weights, lowering optimizer risk limits, adjusting other optimizer parameters and/or managing exposure through trading including hedging. The monitoring and surveillance tools available include Value

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The Adviser provides advisory services to Clients that are private investment funds, consisting of commingled vehicles and funds of one, as well as sub-advisory or investment management services, as applicable, to various entities, including a registered investment company and a UCITS. Clients are typically organized as Delaware limited partnerships and Delaware limited liability companies, Cayman Islands exempted companies or other similar structures. Certain of the Adviser’s Clients rely on the exemption set forth in Section 3(c)(7) or, in the case of “employees’ securities companies,” the exemption set forth in Section 6(b) of the U.S. Investment Company Act of 1940, as amended (“Investment Company Act”). Clients organized as private investment funds are generally organized in master-feeder structures wherein each feeder fund invests all or a portion of its assets into a master fund. Most master funds, and certain Clients not set up in master-feeder structures, then invest all or a portion of their assets into investment trading vehicles managed by the Adviser. Other than for cash management purposes, the vast majority of investment activities on behalf of the Clients are currently through the trading vehicles. Further, certain stand-alone funds and master funds invest, directly or indirectly, in commingled funds, trading vehicles and/or cash management vehicles. The structure of any given Client is described in further detail in the Applicable Governing Documents. With respect to Clients, initial and additional subscription minimums, if any, are disclosed in the Applicable Governing Documents referencing such Client. The Adviser is typically authorized to waive, reduce or modify such subscription minimums, subject to certain limitations in accordance with applicable law or regulation.

Side-by-Side Management Investment Services to Multiple Clients The Adviser provides services to many Clients, certain of which are primarily or entirely comprised of capital from the Adviser, its owners and current or former employees, and their related individuals or entities (such capital, “Proprietary Capital,” and such Clients, “Proprietary Funds”), whereas other Clients are primarily or entirely comprised of third-party capital (“Client Funds”). Certain Proprietary Funds invest, directly or indirectly, in trading entities that are owned primarily or entirely by Proprietary Capital (such trading entities, “Proprietary Trading Vehicles”). For the avoidance of doubt, however, certain Proprietary Trading Vehicles include third-party capital and, conversely, certain Client Funds include Proprietary Capital. The Proprietary Funds often have the most attractive risk-reward profiles, utilize a higher degree of leverage than Client Funds and, in certain cases, utilize strategies and Techniques that have not been made available to Client Funds or, if they are available, Proprietary Funds place significantly greater weight on certain strategies and Techniques than Client Funds. Likewise, certain Client Funds utilize a higher degree of leverage than others, or utilize investment strategies and Techniques that generally are not offered to others. Further, Two Sigma affiliates (as well as their respective principals and certain personnel) engage in a wide range of investment and other financial activities, many of which are not offered to Clients. The Adviser or TSP, as applicable, has waived Management Fees for most Proprietary Funds and has waived Incentive Compensation for all Proprietary Funds, whereas certain Client Funds, and certain investors in certain Client Funds, have higher Management Fees and/or Incentive Compensation than others. Certain Conflicts of Interest Associated with Side-By-Side Management There are actual and potential conflicts of interest associated with side-by-side management of the Proprietary Funds and Client Funds that result from the organizational structure and operation of the Adviser and certain of its affiliates. The discussion below does not purport to be a comprehensive discussion of all such conflicts. Each Client’s Applicable Governing Documents contains additional information with respect to the actual and potential conflicts associated with an investment in such a Client. Please also see Item 10 of this brochure for more information regarding conflicts of interest relating to the Adviser’s affiliates. General The primary conflict for the Adviser from side-by-side management is the financial incentive to favor its own interests or those of Proprietary Funds above those of Client Funds in the allocation of investment opportunities, strategies, Techniques, human capital and other finite resources. The Adviser and its investment personnel have a greater incentive to favor Clients that are expected to contribute more, at least on a relative basis, to overall firm profitability (i.e., the earnings that accrue to the Adviser’s owners and certain employees from Management Fees, Incentive Compensation, the performance of the Proprietary Funds and/or other factors that are expected to contribute to the long-term success and enterprise value of the Adviser and its affiliates) (“Firm Profitability”).

The Adviser seeks to balance the following conflicts and challenges: (i) decisions related to the amount of Proprietary Capital invested in Clients and their allocations to trading vehicles; (ii) variation in the investment objectives and fee structures of Clients, which have a diverse and numerous investor base; (iii) allocating a large, diverse and complex set of strategies and Techniques between and among Clients; (iv) establishing weights and other implementation parameters for strategies and Techniques in a manner consistent with the investment objectives and restrictions of Clients; (v) allocating human capital and other finite resources; and (vi) a continuously evolving regulatory and commercial landscape. The Adviser is not and cannot be free from inherent conflicts of interest in balancing these and related considerations. Shared Research Platform The Adviser maintains a research and data platform that serves its investment activities on behalf of both Proprietary Funds and Client Funds, as well as for certain affiliates (“Shared Research Platform”), as opposed to maintaining a separately staffed team for each portfolio. Utilization of the Shared Research Platform creates conflicts of interest between and among Clients. Research and portfolio management personnel develop and refine strategies and Techniques (often via systematic processes) that are deployed within the Adviser (i) for Proprietary Funds alongside Client Funds, (ii) exclusively for Proprietary Funds and not Client Funds, or (iii) exclusively for certain Client Funds and not Proprietary Funds. In addition, certain affiliates of the Adviser may deploy these strategies and Techniques alongside the Adviser or exclusively. Research developed and/or utilized on the Shared Research Platform is often based on a representative, typically less constrained, portfolio that is configured to facilitate research and, in many cases, is not tailored to each of the specific portfolios in which it is implemented, which could result in suboptimal results in such portfolios. While the Adviser sets broad research objectives, personnel working on the Shared Research Platform have a potential conflict of interest to focus more heavily on research efforts that are more likely to result in benefits to Firm Profitability. The Adviser’s trading and portfolio management personnel have similar conflicts of interest as they participate in research, trading and portfolio management activities on behalf of Proprietary Funds and Client Funds. Notwithstanding the fact that the Adviser maintains the Shared Research Platform, certain strategies and Techniques will be used exclusively by certain Clients and/or affiliates, and will not be made available to other Clients that use the Shared Research Platform. This occurs, for example, with strategies that are more reliant on human discretion or research that is developed by dedicated personnel and is typically utilized exclusively on behalf of the portfolio(s) managed by such dedicated personnel. Similarly, certain business units of the Adviser and certain affiliates use research from the Shared Research Platform, but do not share their research on the Shared Research Platform. The Adviser retains full discretion to share, license, select, move, exclude, reweight or otherwise limit the use of strategies and Techniques across Clients and its affiliates (in each case, whether or not developed and/or utilized on the Shared Research Platform), as discussed in “Allocation of Systematic and Discretionary Strategies and Techniques” below. Please refer to Item 10 for a discussion of sharing arrangements between the Adviser and certain affiliates.

Allocation of Systematic and Discretionary Strategies and Techniques Through its extensive research, the Adviser has developed, and expects to continue to develop, strategies and Techniques that it believes could offer certain Clients meaningful excess returns but cannot be fully utilized by certain Clients or are not available to certain Clients (or any Clients). These strategies and Techniques generally include (i) certain lower latency, higher turnover strategies and Techniques, trading capabilities and related monetization modalities (i.e., the different modes the Adviser employs to monetize such lower latency, higher turnover strategies, which currently include distinct approaches to execution algorithms and infrastructure, brokers, trading venues and sources of liquidity), (ii) testing, incubating and/or trading a range of new asset classes, strategies and/or Techniques, which can be experimental and/or represent departures to varying degrees from approaches and methodologies that the Adviser has historically deployed on behalf of Clients (though, for the avoidance of doubt, such activity is also conducted within certain portfolios utilized by Client Funds) (“Experimental Strategies and Techniques”), and/or (iii) strategies and Techniques that cannot be fully utilized (or in some cases utilized at all) by certain Clients because of the investment objectives and restrictions of such Clients (as set forth in each Client’s Applicable Governing Documents), and/or because they have lesser capacity than can be optimally used in such Clients or they involve the use of monetization modalities that are less amenable to implementation for shared use among Clients. In some instances, the Adviser will choose to deploy strategies and/or Techniques differently (or not at all) for certain Clients, for example, with respect to specific Instruments, execution desks, monetization modalities, geographical regions, and tax-aware strategies. The Adviser also has the discretion to deploy any of these strategies and Techniques for certain Clients to trade any asset class using the Shared Execution Desk, a separate execution desk and/or any monetization modality. Proprietary Capital is invested in Proprietary Funds, Client Funds and other entities in which Clients do not participate. Proprietary Funds are often invested in the same underlying investment trading vehicles that are also utilized by the Client Funds (in most cases utilizing higher leverage). Strategies and Techniques employed for Proprietary Capital and/or certain affiliates may not be shared with Clients, in the Adviser’s sole discretion. In the future, the Adviser may, in its sole discretion and without notice to or consent from any Client or investor in such Clients, (i) add strategies and/or Techniques for utilization on behalf of any Client, (ii) remove strategies and/or Techniques from utilization on behalf of any Client without replacement or (iii) materially increase or decrease a Client’s exposure to any strategies and/or Techniques (whether or not such strategy or Technique was developed and/or utilized on the Shared Research Platform or by a dedicated portfolio management team). For the avoidance of doubt, the decisions listed above apply to strategies and Techniques used to generate investment forecasts for Clients, as well as strategies and Techniques that are used to inform portfolio optimization, trade execution and other key investment management-related decisions. Decisions Relating to Systematic Portfolio Management; Specialized Research Teams Subject to the oversight and control of the Adviser, portfolio managers are responsible for a variety of duties to oversee their respective portfolios. Among other things, portfolio managers monitor and adjust optimizer settings, including with respect to leverage, turnover, position limits, certain exposures and overall risk. Portfolio management decisions are often not themselves automated despite the highly automated nature of the Adviser’s investment process in which strategies and

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Activities & Affiliations The Adviser and its affiliates engage in a wide range of investment and other financial activities. These activities result in actual and certain potential conflicts of interest. Many of the opportunities presented by these investment and other financial activities are not offered to Clients and, with respect to Instruments traded on behalf of Clients, participation in such investment and other financial activities by the Adviser or its affiliates could have an adverse impact on Clients. In addition, the Adviser’s affiliates and companies in which they invest may enter into agreements, transactions or other arrangements with the Adviser and/or its affiliates. Such agreements, transactions or other arrangements may involve fees, commissions, servicing payments, discounts, rebates and/or other benefits to such portfolio companies, the Adviser or its affiliates, as applicable. The Adviser has a conflict of interest in allocating the time and activity of its employees among the Clients and certain of its affiliates. The Adviser will from time to time share employees and other resources among the Adviser and its affiliates. Certain employees of the Adviser will devote time (including full-time support for certain employees) to providing services to affiliates that could potentially be spent in support of Clients. Such services include engineering, data strategy and data science services, investment research, and the development and maintenance of systematic models and strategies, and the Adviser’s affiliates will pay the Adviser for such services. In addition, such activities present a risk that the Adviser will receive material non-public information through relationships maintained by its affiliates, which could adversely affect Clients as discussed in more detail in Item 8 and Item 11 of this brochure. In addition, certain related persons of the Adviser are affiliated with and/or own interests in Two Sigma Principals, LLC which, as the general partner, member or allocation shareholder (or similar entity) of various Clients, is entitled to receive the performance-based compensation from certain Clients as discussed in Item 5 hereof. Investment Advisers The Adviser’s affiliates include three active investment advisers registered with the SEC: TSPI, LP (“TSPI”); Two Sigma Real Estate, LP (“TSRE”); and Two Sigma Ventures, LP (“TSV”). The brochures for each of TSPI, TSV and TSRE are available through the SEC’s Investment Adviser Public Disclosure website. TSPI, a Delaware limited partnership, changed its name from “Sightway Capital, LP” as of August 18, 2020 and generally focuses on private equity-style investments. TSRE, a Delaware limited partnership, focuses on real estate and real estate-related investments. TSV, a Delaware limited partnership, focuses on venture capital investments, including negotiated transactions in operating entities that utilize advanced science, technology, computing, engineering, and/or mathematics to innovate in their selected market.

In addition, the Adviser is the owner of Two Sigma International Limited (“TSIL”), which is authorized and regulated by the Financial Conduct Authority of the United Kingdom and provides a number of services for the Adviser and certain affiliates. Among other things, the Adviser relies on personnel employed by TSIL for certain trading and advisory services for certain Clients. Specifically, TSIL serves as a “participating affiliate” of the Adviser, and such personnel as “affiliate associated persons,” as such terms are used in no-action relief granted by the SEC for purposes of permitting the sharing of investment advisory personnel and services of a non-U.S. affiliate of a registered investment adviser. Pursuant to these arrangements, TSIL and the affiliated associated persons will be subject to certain oversight requirements by the Adviser, as well as certain conditions and undertakings prescribed by the SEC. Services provided by TSIL to the Adviser for the benefit of Clients are considered to be services provided by the Adviser directly. Accordingly, any operating expenses of Clients will remain payable by Clients if incurred by TSIL to the same extent as if they had been incurred by the Adviser. The Adviser is also affiliated with Two Sigma China Co., Ltd. (“TSC”), which is licensed as a Private Fund Manager with the Asset Management Association of China. TSC, a Chinese Wholly Foreign-Owned Enterprise incorporated as a limited liability company, manages Chinese private investment funds that trade a broad range of instruments in China. There is overlap between certain of the Instruments traded by TSC on behalf of its managed funds, and those traded by the Adviser on behalf of certain Clients. Commodities and Futures The Adviser is registered as a commodity pool operator and a commodity trading adviser with the CFTC under the Commodity Exchange Act. In connection with the Adviser’s registration as a commodity pool operator and commodity trading adviser, certain of the Adviser’s management persons and personnel are registered as associated persons of and/or as principals of the Adviser. Broker Dealers The Adviser is also affiliated with Two Sigma Securities, LLC (“TSS”) and Two Sigma Execution Services, LLC (“TSES”), broker-dealers registered with the SEC and members of the Financial Industry Regulatory Authority, Inc. (“FINRA”). TSS is currently a member of various U.S. selfregulatory organizations and exchanges, and is licensed as a “High Speed Trader” in Japan. TSS trades for its own account and generates substantial trading volume in equities, options and futures, and expects such trading volume to grow. TSES provides agency brokerage services to the Adviser, serving as an introducing broker for one or more Proprietary Funds. In addition, the Adviser is affiliated with Two Sigma Securities UK Limited (“TSS UK”), which is authorized as an investment firm with the United Kingdom’s Financial Conduct Authority and trades for its own account. Certain of the Adviser’s employees are registered representatives or principals of TSS, TSS UK and/or TSES (collectively, “Affiliated Brokers”). In addition, the Adviser and the Affiliated Brokers engage in a significant degree of resource and research sharing activities and may draw upon shared strategies and Techniques. Certain research or technology collaborations between the Adviser and the Affiliated Brokers result in the development of strategies and Techniques that are deployed in the Affiliated Brokers but not on behalf of Clients. Sharing arrangements and

collaborations are subject to a range of supervisory and compliance controls that seek to ensure the activity is appropriately governed and performed in a manner consistent with the applicable regulatory obligations of the Adviser and the Affiliated Brokers as applicable. There can be no guarantee, however, that such controls and oversight functions will fully mitigate the adverse effects to Clients from these activities. The Adviser and the Affiliated Brokers also share personnel, technology and trading infrastructure. This sharing is governed by licensing and/or certain expense-sharing arrangements. While there are benefits to the Adviser’s Clients and to the Affiliated Brokers of such resource and technology sharing, certain conflicts of interest arise. Certain personnel of the Adviser dedicate part of their time and expertise to the Affiliated Brokers, while certain other personnel of the Adviser fully dedicate their time and expertise to the Affiliated Brokers, instead of focusing on the Adviser’s activities on behalf of Clients. Certain TSS business lines indirectly interact with one or more Proprietary Trading Vehicles utilized by certain Clients. Currently, the TSS agency brokerage business provides order routing and agency crossing services in equity securities for TSES, which in turn receives orders from the Adviser on behalf of such Proprietary Trading Vehicles. Additionally, TSS’s Wholesale Market Making business (“WMM”) has in the past and could in the future receive orders in equity securities from TSES, which in turn receives orders from the Adviser on behalf of a Proprietary Trading Vehicle, and such orders would be directed for crossing with orders WMM handles for non-affiliated broker-dealers. TSS also operates certain other proprietary trading businesses. Neither TSES nor TSS currently custodies assets or self-clears trades for the Adviser or its Clients, but they may do so in the future. TSES charges commissions and other fees to the Proprietary Trading Vehicles that utilize its services, which are then borne by the Clients that utilize such Proprietary Trading Vehicles. Such commissions and fees are not the result of arms’ length negotiations and not necessarily the lowest commission rates or fees available as compared to similar services offered by other firms. Certain of the Adviser’s employees also have a conflict of interest arising from the additional compensation they receive based upon, in large part, the amount of commissions, fees and other revenues received or derived by the Affiliated Brokers, including in respect of orders from Proprietary Trading Vehicles. Thus the Adviser may be deemed to have a financial conflict of interest as it is incentivized to cause a Client to execute trades directly or indirectly through TSES and/or TSS, rather than through an unaffiliated entity and/or to engage in more transactions than it would if such trades were executed through an unaffiliated entity. The Adviser and the Affiliated Brokers have adopted policies and procedures that seek to mitigate many potential conflicts of interest intrinsic to Clients executing transactions directly or indirectly with TSES and/or TSS, including the following: (i) TSES and TSS will not trade as principal with Clients; (ii) TSES and TSS currently do not custody assets or clear trades for the Adviser or its Clients; (iii) all TSES and TSS trades will be cleared through third-party clearing brokers that TSES and TSS believe to be reputable; (iv) the Adviser seeks to ensure that market-competitive commission rates are paid by Clients to TSES and TSS; and (v) the Adviser incorporates TSES (and indirectly TSS) in its review of execution quality provided by executing broker-dealers. Separately, the Adviser and each of TSES and TSS have executed an information protection

agreement to ensure appropriate treatment is provided to confidential information, including orders, that the Adviser sends to TSES and/or indirectly TSS. Licensing The Adviser currently licenses, and intends to continue to license, a significant number of strategies and Techniques to certain affiliates, including TSS and TSC, to, among other things, enhance overall Firm Profitability. The Adviser has the sole discretion to select the strategies and Techniques that it licenses. Please see Item 8. “Methods of Analysis, Investment Strategies & Risk of Loss—Material Risks (Including Significant or Unusual Risks) Relating to Investment Strategies—Adverse Effects of Certain Continued Licensing.”

Client Transactions & Personal Trading The Adviser has adopted a Code of Ethics (“Code”) and certain other policies and procedures that obligate its “access persons” (e.g., employees and certain temporary workers) to put the interests of the Clients before their own personal interests and to act honestly and fairly in all respects in their dealings with Clients. The Adviser will supply a complete copy of its Code to any Client or prospective Client or any investor or prospective investor in a Client upon request. The Adviser’s access persons and its affiliates effect transactions for their own accounts in the same or other Instruments purchased and sold for Clients. These activities create conflicts of interest between such persons and Clients with regard to, among other matters, the allocation of limited investment opportunities and the timing of purchases and sales, particularly where trading by the Adviser’s access persons and its affiliates may have an impact on the price of Instruments traded by Clients. To ensure trading by the Adviser’s access persons is conducted in a manner that (i) does not adversely affect the Adviser’s trading on behalf of the Clients and (ii) is consistent with the fiduciary duties owed by the Adviser to the Clients, the Code and attendant policies and procedures govern, among other things, transactions by the Adviser’s access persons and other “covered persons” (e.g., any such access person’s spouse, immediate family members who share the same household, any person to whom an access person provides primary financial support, partnerships and corporations in which access persons maintain a certain level of beneficial interest, and any person with whom access persons share common financial support). The Code and such policies and procedures contain provisions designed to, among other things, (i) prevent improper personal trading by the Adviser’s access persons and other covered persons; (ii) identify actual or potential conflicts of interest; and (iii) provide guidance in resolving certain actual or potential conflicts of which the Adviser is aware in favor of the Clients. The Code and such policies and procedures, among other things, generally (i) require pre-clearance of personal trades in “reportable securities” (as defined in the Code) and certain other assets by the Adviser’s access persons and covered persons, subject to certain exceptions; (ii) restrict the number of such trades by the Adviser’s access persons and covered persons in a given month; (iii) prohibit certain trading by the Adviser’s access persons and covered persons in securities of issuers listed on any applicable restricted list; (iv) require a certain minimum holding period; and (v) prohibit the Adviser’s access persons and covered persons from participating in “new issues” and engaging in short sales. All accounts that have the ability to hold securities and all holdings in reportable securities must be disclosed upon joining the Adviser and confirmed and/or updated periodically, subject to certain exceptions. The Adviser has also adopted policies and procedures regarding the exchange of gifts and entertainment by access persons with certain third parties. Specifically, access persons must report the exchange of gifts and entertainment in excess of pre-established de minimis thresholds and preclear the exchange of gifts and entertainment in excess of pre-established thresholds. Gifts and entertainment reports are reviewed for potential conflicts of interest.

The Code and the Adviser’s other policies and procedures also address the following key areas: (i) recordkeeping; (ii) oversight of the Code; (iii) conflicts of interest; (iv) the treatment of confidential information; (v) compliance with applicable rules and regulations; (vi) reporting misconduct; (vii) political contributions; and (viii) outside activities. The Adviser provides periodic training to access persons regarding the Code and the Adviser’s other policies and procedures. The Adviser from time to time comes into possession of certain information that it believes may be confidential or material non-public information. The Adviser from time to time receives such information directly as a result of its investment advisory activities for any individual Client, indirectly as a result of its relationship with affiliates, or through other activities such as strategic partnership negotiations or an access person’s board or credit committee service. The Adviser will often be prohibited from using such information for a Client’s benefit. The Adviser’s policies and procedures prohibit the communication of such information outside of the Adviser and typically prohibit the communication of such information internally within the Adviser to persons other than the General Counsel and/or the Chief Compliance Officer or their designees. The Adviser will have no responsibility or liability to the Client for not disclosing such information to a Client (or the fact that the Adviser possesses such information), or not using such information for a Client’s benefit. While not anticipated in the ordinary course of business operations, the Adviser and/or its affiliates have engaged, and may in the future engage, in principal transactions with Clients. Any such transactions will be effected in accordance with the notice and consent requirements of Section 206(3) of the Advisers Act, to the extent applicable. Further, the Adviser and/or its affiliates may, in their discretion and without further notice, engage in cross trading between and among Clients (i.e., non-agency cross trades where the Adviser or its affiliates do not act as broker or dealer to the transaction). Such cross transactions are not subject to the notice and consent requirements of Section 206(3) of the Advisers Act. As noted in Item 6. “Performance-Based Fees & Side-by-Side Management,” certain of the Clients are owned in large part or entirely by Proprietary Capital. Item 6 also summarizes the Adviser’s allocation of trades.

The Adviser executes client orders via the Adviser’s order and execution management systems or through similar third-party platforms. Order execution varies across the Adviser’s execution desks. On the Shared Execution Desk, for example, the execution of liquid, exchange-traded Instruments is generally either fully automated or effected with limited employee assistance, while execution of orders for less liquid and/or non-exchange-traded Instruments (e.g., OTC derivatives) is generally handled manually. For more information regarding the Adviser’s execution management system, see Item 6. “Performance-Based Fees & Side-by-Side Management— Certain Conflicts of Interest Associated with Side-by-Side Management—Trading and Execution; Use of Multiple Execution Desks.” The Adviser’s traders enter orders and monitor trading activity through one or more user interfaces. Interfaces vary by execution desk. The relevant user interface(s) allow a trader to determine the appropriate means for handling an order and to choose automated or manual order handling. Orders are executed through trading systems maintained with a broker-dealer and/or other market intermediary (each, a “Market Intermediary”) for execution. The Adviser chooses Market Intermediaries based primarily on their execution capabilities, nonexecution services provided, research, financial stability, reputation, access to relevant markets and expertise in trading particular types of Instruments. In providing services to the Clients, the Adviser accesses a variety of Market Intermediaries’ brokerage services, including order execution by a particular Market Intermediary, direct market access and third-party algorithms. The Adviser, in its discretion, may exercise significant control over the brokerage process or rely more heavily on the trading decisions of Market Intermediaries. The nature of specific markets, limited means of market access and/or the limited counterparty availability for Clients in certain geographical regions, may require that the Adviser obtain exposure to certain Instruments through a single Market Intermediary swap provider. Using one or a limited number of Market Intermediaries exposes the Client to concentrated counterparty risk. Please see Item 8. “Methods of Analysis, Investment Strategies & Risk of Loss—Material Risks (Including Significant or Unusual Risks) Relating to Investment Strategies—Derivative Risk, Settlement Risk and Credit and Concentration Risk of Market Intermediaries and Custodians.” The Adviser has discretion as to how these exposures are acquired through Market Intermediaries and may therefore enter or forego from entering into arrangements with other swap providers and/or trade directly on various exchanges. As part of its best execution responsibilities, the Adviser reviews and monitors, among other things, data regarding trade executions and Market Intermediaries. The Adviser analyzes whether trades executed through the Shared Execution Desk are consistent with the Adviser’s best execution policies and procedures. Consistent with seeking overall best execution, the Adviser, rather than pay a rate for execution only, may pay higher rates (“Commissions”) to obtain research and other services provided by a Market Intermediary (or provided by third parties to whom the Adviser directs payment from the Market Intermediaries). The Adviser may also pay higher commissions to a Market Intermediary that also: (i) provides the Adviser (or an affiliate) with the opportunity to participate in capital

introduction events; (ii) refers investors to the Adviser or to other products advised by the Adviser (or an affiliate); and/or (iii) provides the Adviser (or an affiliate) with the opportunity to participate as appropriate in securities offerings or privately negotiated securities transactions. Accordingly, a Client may pay higher commissions to Market Intermediaries that provide these services and benefits (or that are provided by third parties to whom the Adviser directs Market Intermediaries to pay) than such Client would pay to other Market Intermediaries that do not provide these services and benefits (or the ability to direct payments to other third parties), based on the Adviser’s recognition of the value of the research, brokerage and other services that would otherwise be an expense of a Client. Please refer to Item 6. “Performance-Based Fees & Side-by-Side Management—Certain Conflicts of Interest Associated with Side-By-Side Management—Trading and Execution; Use of Multiple Execution Desks” for further information regarding the procedures adopted by the Adviser for allocating trades among its Clients including procedures for order aggregation. The Adviser currently only uses Commissions, referred to as “soft dollars,” to obtain research and brokerage services within the scope of Section 28(e) of the Securities Exchange Act of 1934, as amended. Section 28(e) is a safe harbor that permits an adviser to pay a higher commission rate without breaching its fiduciary duty if it determines in good faith that “the amount of the commission was reasonable in relation to the value of brokerage and research services provided” by a Market Intermediary. The Adviser received brokerage and research services paid for with soft dollars during its last fiscal year. The Adviser used, and expects to continue to use, soft dollars for brokerage and research products and services that provide lawful and appropriate assistance to the Adviser in carrying out its investment decision-making responsibilities, as permitted under Section 28(e). While the Adviser currently does not do so, the Adviser is also permitted under its Clients’ offering documents to use soft dollars to pay certain Client expenses that are outside of the scope of Section 28(e). The Adviser acknowledges and understands that it has an obligation to seek “best execution” for its Clients’ transactions under the circumstances of the particular transaction. Consequently, notwithstanding the Adviser’s soft dollar policy, the Adviser will direct transactions to a Market Intermediary only if it reasonably believes that doing so is consistent with its best execution obligation. The use of Commissions (or certain mark-ups or mark-downs) to obtain research and brokerage products and services raises conflicts of interest because the cost of such products and services will be included in Commissions that the Client pays rather than a cost paid by the Adviser. This creates an incentive for the Adviser to use Market Intermediaries that provide soft dollars. The Adviser, however, will make a good faith determination that the amount of Commissions paid is reasonable in light of the research and brokerage services obtained. In some instances, the Adviser receives a product or service that may be used only partially within the Section 28(e) safe harbor. The receipt of benefits and the determination of the appropriate allocation in the case of such “mixed use” products or services creates an additional potential conflict of interest between the Adviser and the Clients. In such instances, the Adviser will make a good faith effort to determine the portion of the “mixed use” product or service that is within the scope of Section 28(e) and that portion that is outside of the scope of Section 28(e). The Adviser may pay for the portion of the product or service that is within Section 28(e) with soft dollars generated on Commissions paid for Client transactions, and the proportion used for other purposes will be paid for by the Adviser from its own resources. The Adviser negotiates with Market Intermediaries to set the commission

mark-ups for soft dollar transactions and such mark-ups may differ based on factors including the asset classes and geographic regions traded, Market Intermediaries, commission structures, and whether the Client pursues a high-turnover strategy. Commission mark-ups are updated from time to time as the Adviser seeks to cover its expected soft-dollar eligible research expenses pursuant to objective criteria. Notwithstanding the application of objective criteria, the total soft dollar payments will differ among Clients, and some trading entities (including Proprietary Trading Vehicles) that exclusively utilize Market Intermediaries without soft dollar arrangements or solely trade Instruments ineligible for soft dollar Commissions will not contribute to soft dollar accruals. The Adviser has a conflict of interest because it has greater incentive to set mark-ups with Market Intermediaries that ultimately reduce the total soft dollars paid by Clients expected to contribute more, at least on a relative basis, to Firm Profitability. There can be no assurance that such conflict will be effectively managed or mitigated. The Adviser uses research and brokerage services for which a Client has paid Commissions in its other investment activities, including for the benefit of other Clients. While soft dollar credits are generated by certain Clients, soft dollar credits are not allocated for use by the specific Clients that generated the soft dollar credits; rather, the credits are used to benefit Clients collectively. Research and brokerage services paid with soft dollars generated by one Client have in the past and may in the future be used to benefit one or more other Clients, including Clients that did not pay for the soft dollar benefits. Additionally, soft dollar balances are likely to be treated as unsecured claims in a bankruptcy of a Market Intermediary, meaning that the Adviser and its Clients would likely lose some or all of the value of such soft dollars in the event of a bankruptcy. During the Adviser’s last fiscal year, as a result of client brokerage commissions (or mark-ups or mark-downs), the Adviser and/or its related persons acquired: research reports (including market research); brokerage services, corporate governance research and rating services; inputs from traders, analysts, experts on selected subjects, and other market participants (e.g., in connection with the use, implementation and support of the alpha capture systems, including those developed by the Adviser and/or its affiliates); and data services (including services providing market data, news data, company data (including financial data), trade analytical software, certain valuation and pricing data and economic data). In selecting or recommending broker-dealers, the Adviser may consider whether a broker-dealer provides client referrals or opportunities to participate in capital introduction programs. To address this conflict of interest, the Adviser may execute trades through broker-dealers that refer clients or provide access to capital introduction opportunities to the Adviser or a related person only if the Adviser determines that executing trades with such broker-dealers are consistent with the Adviser’s obligation to seek best execution and not a means of remunerating the broker-dealer for referrals and capital introduction opportunities.

The Adviser does not currently compensate any person for Client referrals. However, the Adviser has entered into arrangements with certain third parties to refer investors in certain Clients, and such third parties are entitled to compensation from such investors and from the Adviser in connection with such referrals. The Adviser’s arrangements with third parties to refer investors in certain Clients can and do vary. Any compensation paid pursuant to these arrangements creates an incentive for such third parties to recommend the Adviser, resulting in a material conflict of interest. Moreover, the Clients may engage the third parties (or their affiliates) to provide additional services, and any such relationship could create an additional conflict of interest. Additionally, in accordance with applicable law, the Adviser compensates certain third parties for assistance in connection with soliciting Canadian and Japanese investors in certain Clients. Additionally, the Adviser may compensate broker-dealers that provide referrals, to the extent consistent with best execution as discussed in Item 12. The Adviser has developed extensive relationships through a lengthy and continued course of dealing with certain third-party investment consultants (“Investment Consultants”) that are neither affiliated with nor compensated by the Adviser. Investors and prospective investors in Clients retain these same Investment Consultants from time to time to advise them on the selection and review of investment managers and investment products, including in respect of the Adviser and its Clients. Such Investment Consultants do not act on behalf of the Adviser, and their services are generally outside the scope of any offering of securities by the Adviser and/or its Clients. Further, the Adviser does not participate in the advisory services offered by such Investment Consultants to their clients and generally seeks to ensure that Clients and investors in Clients rely solely on the Client’s Applicable Governing Documents. The Adviser receives certain research or other products or services from broker-dealers through “soft dollar” arrangements, which are discussed in greater detail in Item 12.

proceeding relating to alleged violations of the Advisers Act and Securities Exchange Act of 1934, as amended (the “Exchange Act”), without admitting or denying, pursuant to an order under Section 21C of the Exchange Act and Sections 203(e) and 203(k) of the Advisers Act (the “Order”). The Order provided that, between March 2019 and October 2023 (the “Relevant Period”), the Adviser recognized significant vulnerabilities to certain of its computer-based algorithmic investment models (“Models”) that could materially adversely impact Clients’ investment returns. According to the Order: beginning in at least March 2019, Two Sigma employees expressed concern that numerous Two Sigma personnel had unfettered read and write access to a firm database that stored Model “parameters”—variable inputs that impact the stock predictions generated by Models—used by certain of Two Sigma’s live-trading Models; these employees expressed concern that such personnel could make changes to these Model parameters without review or approval and that such changes could materially impact Two Sigma’s investment decisions for its Clients; despite Two Sigma employees identifying and providing senior management with proposed solutions, the Adviser failed to reasonably address these vulnerabilities for years and, despite also knowing about these vulnerabilities, the other Two Sigma Affiliate also failed to take reasonable steps to address them; between November 2021 and August 2023, a Two Sigma employee, who had read and write access to the database, changed Model parameters without approval for fourteen Models that Two Sigma was using in live trading; the employee’s unauthorized changes caused these Models to perform differently than expected such that Two Sigma made investment decisions that it otherwise would not have made for Clients; and the employee’s changes resulted in certain Clients overperforming by more than $400 million and other Clients underperforming by approximately $165 million. According to the Order: Two Sigma breached its fiduciary duty of care in violation of Section 206(2) of the Advisers Act; Two Sigma failed to adopt and implement written policies and procedures reasonably designed to address the recognized access control vulnerabilities to the Models described above, resulting in violations of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder; and the Adviser failed reasonably to supervise the employee, within the meaning of Section 203(e)(6) of the Advisers Act, with a view to preventing and detecting the employee’s violations of the federal securities laws. Two Sigma voluntarily repaid the negatively impacted Clients approximately $165 million starting in December 2023 and January 2024. Separately, according to the Order, between at least April 2019 and February 2024, Two Sigma entered into separation agreements with employees that required these employees to represent to Two Sigma that they had not filed a complaint with any governmental agency in order to receive certain post-separation payments and benefits. Two Sigma’s use of the separation agreements, according to the Order, violated Rule 21F-17(a) of the Exchange Act, which prohibits any person from taking any action to impede an individual from communicating directly with the SEC staff about a possible securities law violation. The Order provided that the SEC staff is not aware of specific instances in which Two Sigma took any action against any departing employee for

breaching the separation agreements, in which a current or former Two Sigma employee was prevented from communicating with the SEC staff about potential violations of securities laws, or in which Two Sigma took action to otherwise prevent such communications, including with respect to the events described herein. The Order required that Two Sigma cease and desist from committing or causing any violations and any future violations of Rule 21f-17(a) under the Exchange Act and Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereof. Additionally, the Order required that Two Sigma be censured and that each of the Adviser and the other Two Sigma Affiliate pay a civil money penalty of $45,000,000 to the SEC. Two Sigma paid the civil money penalty on January 23, 2025. On March 28, 2017, a Panel of the Business Conduct Committee of the Chicago Board of Trade (“CBOT”) accepted an offer of settlement from the Adviser in connection with a CBOT position limit rule. The CBOT Notice relating to this matter stated that on February 22nd and February 23rd, 2016, certain Clients and clients of another Two Sigma Affiliate held aggregated wheat futures positions in excess of the CBOT standard all month limit. Upon discovery, the overage was liquidated to bring the aggregate position into compliance with the CBOT limits. As part of the settlement, the Adviser agreed to pay a fine of $25,000, while neither admitting nor denying any rule violation.

Frequency and Nature of Review. The IRC and the Adviser’s Co-Chief Investment Officers (or their delegates) periodically review the trading activity conducted on behalf of Clients in conjunction with the relevant portfolio management personnel responsible for such trading activity. These reviews consist of a review and analysis of (i) various trading data, (ii) internally-generated risk reports and (iii) an evaluation of such other information the Adviser deems appropriate. Content and Frequency of Regular Account Reports. A Client’s investor(s) receives written reports from the Adviser as described in the Applicable Governing Documents of the Client. Investors in Clients that are private investment funds are provided with audited annual financial statements typically within one hundred twenty (120) days of the end of the fund’s fiscal year. In addition, such investors are provided with unaudited statements typically within thirty (30) days of the end of each month. In the case of certain subadvisory relationships, the Adviser provides reports to the primary adviser for inclusion, as applicable, in such adviser’s reports to investors as may be described in the applicable sub-advisory agreement or prospectus and supplemental disclosure document of the Client. Clients and/or the Adviser may enter into and have entered into agreements with certain investors to provide such investors with additional (or more frequent) reports, including detailed information regarding portfolio positions.

The Adviser and certain of its affiliates are generally deemed to have custody of Client assets and, where applicable, intend to comply with Rule 206(4)-2 under the Advisers Act by meeting the conditions of the pooled investment vehicle annual audit provision. Accordingly, investors in Clients do not receive account statements directly from qualified custodians holding Clients’ assets, though audited financial statements are distributed to such investors. Please refer to Item 13 of this brochure for further discussion of the Adviser’s reporting practices.

The Adviser provides investment advisory services on a discretionary basis to the Clients. Other than those restrictions set forth in the Applicable Governing Documents, the Clients generally may not impose restrictions on investing in certain securities or certain types of securities. Prior to assuming full discretion in managing a Client’s assets, the Adviser enters into an investment management agreement or other agreement with the Client that sets forth the scope of the Adviser’s discretion. The Adviser generally has the authority to determine (i) the Instruments to be purchased and sold for Clients (subject to restrictions on its activities set forth in the Applicable Governing Documents and any written investment guidelines), and (ii) the amount of Instruments to be purchased or sold for Clients. See Item 6 for a discussion of the Adviser’s allocation and aggregation practices. The Adviser, directly or indirectly, from time to time, causes certain of the Clients to purchase equity securities that are part of IPOs (under FINRA rules, referred to as “New Issues”). The Adviser will determine those Clients that are eligible to participate in the IPOs and will allocate such IPO securities in a manner consistent with applicable law and the Adviser’s fiduciary duties among such Clients. Subject to any restrictions in a Client’s Applicable Governing Documents, the Adviser is authorized to determine, among other things the (i) manner in which New Issues are directly purchased, held, transferred and sold and any adjustments (including interest) with respect thereto; (ii) manner in which the investors will participate in the profits and losses from New Issues; (iii) investors who are eligible and ineligible to participate in the profits and losses from New Issues; (iv) method by which profits and losses from New Issues are to be allocated among the investors in a manner that is permitted under the FINRA rules; and (v) time at which New Issues are no longer considered as such under the FINRA rules. Investors in Clients may elect to be treated as either eligible or ineligible to participate in the profits and losses from New Issues (if any).

The Adviser has the authority to vote proxies with respect to the securities of certain Clients. When the Adviser votes proxies with respect to the securities of a Client, the Adviser employs guidelines and procedures that are reasonably designed to ensure that such proxies are voted in the best interest of its Clients. Certain Clients, pursuant to the Client’s Applicable Governing Documents, may instruct the Adviser not to vote proxies on behalf of the Client. The Adviser may choose to cease voting proxies, or not vote proxies, on behalf of certain of its Clients. The Clients are not permitted to direct their votes in a particular solicitation. When voting proxies, the Adviser generally utilizes the services of a third-party proxy agent that votes pursuant to guidelines agreed upon with the Adviser in advance. Such services of a thirdparty proxy agent are believed to mitigate certain conflicts of interest between the Adviser and Clients. However, there can be no assurance that this practice will eliminate all potential conflicts of interest with respect to proxy voting. If a material conflict of interest between the Adviser and a Client is brought to the Adviser’s attention, the Adviser will determine whether voting in accordance with the guidelines set forth in the proxy voting policies and procedures is in the best interests of the Client or take some other appropriate action. An investor in a Client can obtain a copy of the Adviser’s proxy voting policies and procedures, which include information as to how the Adviser voted proxies for each applicable Client in which the investor is invested, by contacting the Adviser’s Investor Relations Department at (212) 6255700.

This Item is not applicable.