VIKING GLOBAL INVESTORS LP

A. General Description of Advisory Firm. Viking Global Investors LP, a Delaware limited partnership (“VGI”), was founded in 1999. VGI serves as investment adviser or management company to private investment funds pursuing long/short equity, long-only equity, hybrid public/private, private equity, and structured capital strategies. VGI manages the following private investment funds (together with any other fund or vehicle VGI may advise in the future, collectively, the “Funds”): the Viking Global Equities Funds (the “VGE Funds”), long/short hedge funds launched on October 1, 1999; the Viking Long Funds (the “VLF Funds”), long-only funds launched on January 1, 2009; the Viking Global Opportunities Funds (the “Hybrid Funds”), public/private hybrid funds launched on January 1, 2015; the Viking Global Drawdown Funds (the “Drawdown Funds”), private equity funds launched on October 1, 2021; the Viking Structured Capital Funds (the “Structured Capital Funds”), credit and structured capital funds launched on March 1, 2023; and the Viking Global Vintage IV Funds (the “Vintage IV Funds” and together with the Drawdown Funds, the “Vintage Funds”), private equity funds launched on October 1, 2025. O. Andreas Halvorsen is the principal owner and a co-founder of VGI. Mr. Halvorsen owns interests in VGI directly, as a limited partner, and indirectly, as a member of Viking Global Partners LLC, a Delaware limited liability company that is the general partner of VGI. B. Description of Advisory Services. 1. Advisory Services. VGI serves as the management company of the Funds. The VGE Funds include (1) Viking Global Equities LP, a Delaware limited partnership, (2) Viking Global Equities II LP (the “VGE Employee Fund”), a Delaware limited partnership offered only to VGI’s principals, certain qualified employees, and other VGI-related persons, such as family investment vehicles, charitable organizations, and estate planning vehicles associated with VGI’s principals and qualified employees (collectively, “Viking Affiliates”), and (3) Viking Global Equities III Ltd., a Cayman Islands exempted company. The VGE Employee Fund is classified as an “employees’ securities company” pursuant to Section 2(a)(19) of the Investment Company Act of 1940, as amended. In addition, VGI serves as management company to Viking Partners Fund LP, a Delaware limited partnership offered only to Viking Affiliates. Viking Global Equities III Ltd. invests substantially all of its assets in VGE III Portfolio Ltd., which in turn invests substantially all of its assets in Viking Global Equities Master Ltd. Viking Partners Fund LP, which is offered only to Viking Affiliates, invests substantially all of its assets in Viking Global Equities LP, Viking Global Equities II LP, and VGE III Portfolio Ltd. Viking Global Equities LP invests substantially all of its assets in Viking Global Equities Master Ltd. Viking Global Performance LLC (“Viking Performance”), a Delaware limited liability company affiliated with VGI, serves as either general partner or investment manager of each VGE Fund. The VLF Funds include (1) Viking Long Fund LP, a Delaware limited partnership, (2) Viking Long Fund III Ltd., a Cayman Islands exempted company, and (3) Viking Partners Long Fund LP, a Delaware limited partnership. Viking Long Fund III Ltd. invests substantially all of its assets in Viking Long Fund Intermediate LP, which in turn invests substantially all of its assets in Viking Long Fund Master Ltd. Viking Long Fund LP also invests substantially all of its assets in Viking Long Fund Master Ltd. Viking Partners Long Fund LP, which is offered

only to Viking Affiliates, invests substantially all of its assets in the VLF Funds. Viking Long Fund GP LLC (“VLF GP”), a Delaware limited liability company affiliated with VGI, serves as the general partner or investment manager of each of the VLF Funds. The Hybrid Funds include (1) Viking Global Opportunities LP, a Delaware limited partnership and (2) Viking Global Opportunities III LP, a Cayman Islands exempted limited partnership. Viking Global Opportunities III LP typically invests substantially all of its assets in Viking Global Opportunities Intermediate LP, which in turn typically invests a substantial portion of its assets in Viking Global Opportunities Master LP, a Cayman Islands exempted limited partnership (the “Hybrid Master Fund”). Viking Global Opportunities LP also typically invests a substantial portion of its assets in the Hybrid Master Fund. The Hybrid Funds may, and from time to time do, make investments other than through the Hybrid Master Fund, including through special purpose vehicles. The Hybrid Master Fund typically invests substantially all of its assets in Viking Global Opportunities Liquid Portfolio Sub-Master LP and Viking Global Opportunities Illiquid Investments Sub-Master LP. Viking Global Opportunities GP LLC (“Hybrid GP”), or its wholly owned subsidiary, Viking Global Opportunities Portfolio GP LLC (“Hybrid Portfolio GP”), each a Delaware limited liability company affiliated with VGI, serves as the general partner of each of the Hybrid Funds. The Vintage Funds include (1) Viking Global Opportunities Drawdown (Onshore) LP, a Delaware limited partnership, (2) Viking Global Opportunities Drawdown (Offshore) LP, a Cayman Islands exempted limited partnership, (3) Viking Global Opportunities Vintage IV (Onshore) LP, a Delaware limited partnership, and (4) Viking Global Opportunities Vintage IV (Offshore) LP, a Cayman Islands exempted limited partnership. Viking Global Opportunities Drawdown GP LLC (“Drawdown GP”), a Delaware limited liability company affiliated with VGI, serves as the general partner of the Drawdown Funds. Viking Global Opportunities Vintage IV GP LLC (“Vintage IV GP”), a Delaware limited liability company affiliated with VGI, serves as the general partner of the Vintage IV Funds. The Vintage Funds and the Hybrid Funds are referred to herein, collectively, as the “Opportunities Funds.” Viking Partners Opportunities Fund LP, which is offered only to Viking Affiliates, invests a substantial portion of its assets in the Opportunities Funds. The Structured Capital Funds include (1) Viking Structured Capital (Onshore) LP, a Delaware limited partnership, (2) Viking Structured Capital (Offshore) LP, a Cayman Islands exempted limited partnership, and (3) Viking Structured Capital (Offshore 2) LP, a Cayman Islands exempted limited partnership. Viking Partners Structured Capital Fund LP, which is offered only to Viking Affiliates, invests substantially all of its assets in Viking Structured Capital (Onshore) LP. Viking Structured Capital GP LLC (“Structured Capital GP”) or Viking Structured Capital Portfolio GP LLC (“Structured Capital Portfolio GP”), each a Delaware limited liability company affiliated with VGI, serves as the general partner of each of the Structured Capital Funds and the Structured Capital Sidecars (as defined below). References to the Structured Capital Funds generally also apply to the Structured Capital Sidecars except as otherwise described in this Brochure or as the context otherwise requires. VGI has established the Structured Capital Sidecars and may in the future establish additional investment vehicles, SMAs, or other accounts or arrangements through which one or more persons invest alongside one or more Funds (each, a “Co-Investment Vehicle”). CoInvestment Vehicles may be formed on a transaction-by-transaction basis or to pursue multiple investments, whether on an opportunistic or systematic basis. For purposes of this Brochure, where appropriate and as the context permits, references to “Funds” also include any CoInvestment Vehicles.

VGI has engaged its affiliates located in the United Kingdom (“UK”) and Hong Kong to provide investment research, analysis, recommendations and advice, and trade execution services. 1 VGI and its affiliates assume full responsibility for any fees payable to such affiliates in connection with their provision of services. Viking Global Investors Europe LLP, the UK affiliate (“Viking Europe”), and Viking Global Hong Kong Limited, the Hong Kong affiliate (“Viking Hong Kong”), are each authorized to exercise discretionary investment authority over a portion of the assets of certain Funds. References herein to “VGI” shall be deemed to include Viking Europe and/or Viking Hong Kong where applicable. References herein to “Viking” shall be deemed to include VGI and its affiliates, including Viking Performance, VLF GP, Hybrid GP, Hybrid Portfolio GP, Drawdown GP, Vintage IV GP, Structured Capital GP, and Structured Capital Portfolio GP. This Brochure generally includes information about VGI and its relationships with its clients and affiliates. While much of this Brochure applies to all such clients and affiliates, certain information included herein only applies to specific clients or affiliates. For purposes of this Brochure, references to “including” (and similar terms) mean “including, without limitation.” 2. Investment Strategies and Types of Investments. VGI leverages its core competencies, which include analyzing industry dynamics and business models, evaluating the strength of management teams, and assigning company valuations, to select investments in equity securities and in credit and other financial instruments. VGI typically causes the Funds to invest in companies located around the world that operate in a wide range of industries. The VGE Funds seek to achieve maximum capital appreciation commensurate with reasonable risk. VGI seeks to increase the performance of the VGE Funds while mitigating general market risk by employing a hedged approach, taking short positions as well as long positions. VGI uses leverage to magnify the effects of its investment selections. VGI expects the leverage of the VGE Funds’ equity portfolio, as measured by its “gross exposure” 2, generally to remain below 250%. VGI expects that the VGE Funds’ equity portfolio will generally maintain “net exposure” 3 below 60%, and, consequently, believes that the performance of the VGE Funds over sustained periods of time will be more a function of investment selection than of movements in broad market averages. Long and short credit positions may cause the aggregate gross exposure or net exposure of the VGE Funds’ portfolio to exceed these levels. The VLF Funds’ investment program generally replicates the long equity positions held in the VGE Funds’ portfolios.

In addition, a wholly owned subsidiary of each of Viking Performance and VLF GP acts as an administrative general partner of certain Cayman exempted partnership entities with the authority to submit filings in the Cayman Islands.

A Fund’s “gross exposure” is the value of its long positions plus the value of its short positions, if any, divided by the Fund’s net assets (excluding such Fund’s cash and treasuries). For example, if a Fund has net assets of $100 and has long positions valued at $120 and short positions valued at $80, such Fund would have a gross exposure of 200% ([$120+$80] / $100).

A Fund’s “net exposure” is the value of its long positions less the value of its short positions, if any, divided by the Fund’s net assets (excluding such Fund’s cash and treasuries). Using the example provided above for the definition of gross exposure, such Fund would have a net exposure of 40% ([$120-$80] / $100).

Read the rest in the brochure

A. Advisory Fees and Compensation. The principal forms of compensation received by Viking or its affiliates from the Funds are Management Fees, Incentive Allocation, and, for certain legacy Hybrid Funds investments, a Priority Profits Allocation (each as defined below). The applicable fee structure differs by Fund. Viking receives asset-based fees from the VGE Funds, the VLF Funds, and the Hybrid Funds, and receives invested capital-based fees from the Hybrid Funds, the Drawdown Funds, the Vintage IV Funds, and the Structured Capital Funds (collectively, “Management Fees”). Certain Viking affiliates receive performance-based compensation (“Incentive Allocation”) from the Funds. Viking also receives an asset-based allocation of profits from illiquid investments acquired or designated as such prior to January 1, 2024 in the Hybrid Funds (the “Priority Profits Allocation”). Effective as of January 1, 2024, Viking discontinued the Priority Profits Allocation for illiquid investments acquired or designated as such on or after January 1, 2024; Viking instead receives Management Fees in respect of such illiquid investments, as described below. Except as otherwise described in this Item 5, each of the Funds is subject to a Management Fee and Incentive Allocation. Only the Hybrid Funds are subject to the Priority Profits Allocation. Investors in the Funds who are Viking Affiliates do not bear a Management Fee, a Priority Profits Allocation, or an Incentive Allocation during the term of their employment or affiliation with Viking and, in some cases, for a period thereafter. Certain CoInvestment Vehicles do not pay Management Fees or Incentive Allocation. The Management Fee, Priority Profits Allocation, and Incentive Allocation, as applicable, are not negotiable. However, Viking may, in its discretion, (a) waive or reduce all or any portion of the Management Fee, Priority Profits Allocation, or Incentive Allocation with respect to any investor in any Fund, (b) cause all or any portion of the Management Fee, Priority Profits Allocation, or Incentive Allocation, as applicable, to be paid from, or on behalf of, the applicable Fund or any other entity through which such Fund invests directly or indirectly, including from a pass-through entity below an investment vehicle treated as a corporation for United States (“U.S.”) federal income tax purposes, and (c) cause all or any portion of the Management Fee, Priority Profits Allocation, or Incentive Allocation, as applicable, to be paid to any affiliate of Viking. Generally, Viking earns: VGE Funds:

at the beginning of each month, a Management Fee equal to 0.125% (1/12th of 1.5%) of the net asset value of each capital account or each series of shares (as applicable) of each VGE Fund.

at the end of each fiscal year or upon the redemption of an investor, an Incentive Allocation equal to a percentage (20% for investors with a one-year lock-up; 17.5% for investors with a three-year lock-up) of the net capital appreciation allocated to each investor in a VGE Fund during such period. The Incentive Allocation is taken only on net capital appreciation in excess of the prior losses of such investor (a “high water mark”); however, Viking (or, for the non-U.S. domiciled VGE Fund, its Board of Directors), may reset the high water mark for certain classes of investors, which triggers an early right of redemption for any affected investors. In addition, the Incentive Allocation with respect to investors who initially agreed to be subject to a three-year lock-up period (and thus had been subject to an Incentive Allocation rate of 17.5%) will

be recalculated on the entire interest at a 20% rate retroactive to the beginning of the lock-up period and then crystallized and reallocated to Viking. VLF Funds:

at the beginning of each month, a Management Fee equal to 0.125% (1/12th of 1.5%) of the net asset value of each capital account or each series of shares (as applicable) of each VLF Fund.

at the end of each fiscal year or upon the redemption of an investor, an Incentive Allocation equal to a percentage (20% for investors with a one-year lock-up; 17.5% for investors with a three-year lock-up) of the excess of the net return for each investment made by an investor in a VLF Fund over the performance of the MSCI World Index (as defined below). 4 The Incentive Allocation is taken only on net return in excess of any prior underperformance of each investment made by such investor relative to the MSCI World Index; however, Viking (or, for the non-U.S. domiciled VLF Fund, its Board of Directors), may reset the underperformance recovery amount for certain classes of investors, which triggers an early right of redemption for any affected investors. In addition, the Incentive Allocation with respect to investors who initially agreed to be subject to a three-year lock-up period (and thus had been subject to an Incentive Allocation rate of 17.5%) will be recalculated on the entire interest at a 20% rate retroactive to the beginning of the lock-up period and then crystallized and reallocated to Viking. The above references to the “MSCI World Index” refer to the Morgan Stanley Capital International World Index (dividends reinvested net of withholding taxes) measured in local currency terms (Bloomberg symbol: NDDLWI). 5

Hybrid Funds:

at the beginning of each month, a Management Fee equal to 0.125% (1/12th of 1.5%) of the net asset value of each capital account of each Hybrid Fund attributable to liquid investments.

upon the realization of an illiquid investment acquired or designated as such prior to January 1, 2024 (a “Pre-Election Investment”), a Priority Profits Allocation of gains from the realized Pre-Election Investment up to, but not exceeding the accrued priority profits balance for such Pre-Election Investment. The priority profits balance for each Pre-Election Investment increases at the beginning of each month by 0.125% (1/12th of 1.5%) of the value of the Pre-Election Investment’s capital account (based on the lower of the cost and fair value of the Pre-Election Investment), plus imputed interest on any previously accrued and unpaid priority profits balance. The priority profits balance ceases accruing upon the sooner of (a) the complete realization of the Pre-Election Investment or (b) the seventh anniversary of the creation of the illiquid capital account

If Viking does not receive an Incentive Allocation from the VLF Funds because insufficient net capital appreciation was allocated to an investor during an applicable period, then Viking will receive such Incentive Allocation at the end of the next fiscal year (and any subsequent fiscal years, as necessary) to the extent there is net capital appreciation in such year(s) (or as of the next date the applicable investor makes a redemption, to the extent there is any net capital appreciation at such time).

As of March 16, 2026, the MSCI World Index aggregated indices from the following 23 developed market countries: Australia, Austria, Belgium, Canada, Denmark, Finland, France, Germany, Hong Kong, Ireland, Israel, Italy, Japan, Netherlands, New Zealand, Norway, Portugal, Singapore, Spain, Sweden, Switzerland, the United Kingdom, and the United States. (Source: https://www.msci.com/world)

relating to that Pre-Election Investment. Effective as of January 1, 2024, Viking discontinued the Priority Profits Allocation for illiquid investments acquired or designated as such on or after January 1, 2024 (“Post-Election Investments”) and instead charge a monthly Management Fee equal to 0.125% (1/12th of 1.5%) on the lower of cost or fair value of a Post-Election Investment. Upon a partial realization of an illiquid investment by way of a sale or other disposition, its cost generally will be reduced proportionately relative to the portion of the illiquid investment so realized, whereas distributions made (or deemed to be made) in the ordinary course from portfolio companies (e.g., interest payments, dividends, tax distributions) generally will not reduce the cost of an investment for purposes of calculating the Priority Profits Allocation or Management Fee, as applicable.

at the end of each fiscal year or upon the redemption of an investor, an Incentive Allocation equal to 20% of the net returns of the investor’s liquid pool, taking into account any net depreciation or net appreciation (in each case, based on the lower of cost or fair value) of any unrealized illiquid investments. The Incentive Allocation is taken only on net capital appreciation in excess of the prior losses of such investor. In addition, an Incentive Allocation is made following the realization of each illiquid investment of 20% of the net profits from such illiquid investment (without duplication for any net depreciation or net appreciation previously taken into account in calculating the Incentive Allocation on the investor’s liquid pool). 6 The Incentive Allocation from gains on illiquid investments is subject to “true-up,” which may cause Incentive Allocation amounts preliminarily allocated to Viking to be returned to the investor to the extent there are subsequent losses through the end of the applicable calendar year.

Drawdown Funds:

at the beginning of each month, a Management Fee equal to 0.125% (1/12th of 1.5%) of the capital contributions (as of the end of each month) for investments (including, for this purpose, the principal amount of any borrowings by the Drawdown Funds for investments, but without duplication of capital contributions used to repay such borrowing), plus any expenses related to such investments (as determined by Drawdown GP in good faith), less any such contributions (or borrowings) attributable to investments subject to a complete write-off, as adjusted for partial realizations on a pro rata basis.

upon the distribution of proceeds, 20% of the net proceeds from the Drawdown Funds as an Incentive Allocation once investors have received from such distribution proceeds and all prior distributions a return of their capital contributions to the Drawdown Funds.

Vintage IV Funds:

at the beginning of each month, a Management Fee equal to 0.125% (1/12th of 1.5%) of (a) with respect to Series 1 Interests, the capital contributions (as of the end of each month) for investments (including, for this purpose, the principal amount of any borrowings by the Vintage IV Funds for investments, but without duplication of capital contributions used to repay such borrowing), plus any expenses related to such investments (as determined by Vintage IV GP in good faith), less any such

In certain circumstances, the balance of an investor’s liquid capital may not be sufficient to satisfy the Incentive Allocation to which Viking is entitled. Any portion of an Incentive Allocation that is not reallocated to Viking may be reallocated as of the next month-end (and any subsequent month-end) to the extent of the investor’s liquid capital account balance or any proceeds from realized illiquid investments.

contributions (or borrowings) attributable to investments subject to a complete writeoff, as adjusted for partial realizations on a pro rata basis (“invested capital”) and (b) with respect to Series 2 Interests, (i) until and including the earlier of (1) expiration or early termination of the investment period and (2) the day preceding the commencement of the investment period of a subsequent fund, an investor’s capital commitment and (ii) following the investment period, invested capital.

upon the distribution of proceeds, 20% of the net proceeds from the Vintage IV Funds as an Incentive Allocation once (a) with respect to Series 1 and Series 2 interests, investors have received from such distribution proceeds (and all prior distributions) a return of their aggregate capital contributions to the Vintage IV Funds and (b) with respect to Series 2 interests, investors have also received an 8% preferred return, compounded annually, on such capital contributions and the Vintage IV GP has received a 100% GP catch-up.

Structured Capital Funds:

at the beginning of each month, a Management Fee equal to 0.125% (1/12th of 1.5%) of the capital contributions (as of the end of each month) for investments, including any expenses related to such investments (as determined by Structured Capital GP in good faith), plus the aggregate outstanding borrowings incurred by the Structured Capital Funds or any special purpose vehicle for investments, less any such capital contributions (or borrowings) attributable to investments subject to a complete write-off, as adjusted for partial realizations on a pro rata basis; provided that any aggregate outstanding borrowings shall not, when added to the capital contributions in respect of such investments, cause the sum to exceed the cost of such investments.

upon the distribution of proceeds, 20% of the net proceeds from the Structured Capital Funds as an Incentive Allocation once (a) investors have received from such distribution proceeds (and all prior distributions) a return of their aggregate capital contributions to the Structured Capital Funds and a 7% preferred return, compounded annually, on such capital contributions and (b) Structured Capital GP has received a 100% GP catch-up.

Read the rest in the brochure

A. Methods of Analysis and Investment Strategies. Viking seeks to maximize the VGE Funds’ performance while mitigating general market risk by employing a hedged approach, taking short positions as well as long positions. Viking expects to maintain a relatively low net exposure (as defined in Item 4 above) for the VGE Funds, and, consequently, Viking believes that over sustained periods of time performance will be more a function of investment selection than of movements in broad market averages. Over the long term, Viking aims to achieve returns for the VGE Funds that are higher than those implied by broad market indices while assuming overall portfolio risk that is less than that inherent in a market portfolio. Short positions constitute an integral component of the VGE Funds’ investment program. These positions are generally intended to contribute positively to the performance of the VGE Funds. In addition, they may lessen the impact on the VGE Funds of a major stock market decline. Over the long term, Viking aims to achieve returns for the VLF Funds that exceed those of the broad market indices, including the MSCI World Index. The VLF Funds’ investment ideas are drawn predominantly from the universe of long equity positions in which the VGE Funds invest, although Viking may determine that certain investments not contained in the VGE Funds’ portfolio are appropriate for the VLF Funds and vice versa. Viking believes that its investment staff is capable of identifying long opportunities that, on a consistent basis, exceed the capacity of the VGE Funds to make long investments in light of the VGE Funds’ mandate to hedge long exposure with profitable short positions. Viking established the VLF Funds to take advantage of such opportunities. The VLF Funds generally replicate the long equity positions in the portfolio of the VGE Funds, with certain exceptions. Historically, the VLF Funds have replicated the majority of the VGE Funds’ long positions, with the VLF Funds’ exposure to each position typically matching its proportional capital weighting within the VGE Funds. However, Viking may adjust this methodology in its sole discretion, including by investing on behalf of the VLF Funds in some or all of the VGE Funds’ long positions based on factors other than capital weighting—such as the VGE Funds’ net exposure to specific sectors—or in such other proportions and amounts as it determines. The VLF Funds typically do not use leverage, although they are permitted to do so. Viking seeks to maximize the Hybrid Funds’ risk-adjusted returns primarily by making attractive liquid and illiquid investments globally. The Hybrid Funds’ illiquid portfolio may include a wide variety of illiquid investments, but has historically been concentrated in private equity investments. Investor capital contributions are initially fully invested in a liquid capital account, which is generally invested in liquid, public securities and used to fund illiquid opportunities as they are identified. When these illiquid investments are realized, the proceeds generally are reinvested in the investor’s liquid capital account and made available for subsequent illiquid opportunities. The proportion of an investor’s capital that is invested in illiquid investments will vary over time and relative to that of other investors in the Hybrid Funds. At any given time, nearly all of an investor’s capital may be allocated to illiquid investments and not liquid investments, or vice versa. The Hybrid Funds’ liquid portfolio generally replicates the “most liquid” long and short positions in the VGE Funds and uses leverage in that portfolio to magnify the effects of its investment selections. The Hybrid Funds’ illiquid investments may include securities in privately held companies, privately issued or restricted securities of public companies (including PIPEs), and other investments. Viking seeks to maximize the Vintage Funds’ risk-adjusted returns by making what it deems are attractive illiquid investments in companies that operate in a wide range of industries

globally. During their respective investment periods, the Vintage Funds will generally pursue the same illiquid investment opportunities as the Hybrid Funds. The Hybrid Funds’ illiquid investment decisions generally drive capital deployment by the Vintage Funds, thereby providing a structural link between Viking’s public and private investment efforts. This should ensure that any potential illiquid investment opportunity of the Opportunities Funds is implicitly assessed against Viking’s public market opportunity set. Viking seeks to generate attractive risk-adjusted returns for the Structured Capital Funds by investing in instruments that Viking believes offer significant upside potential with meaningful downside protection. Viking expects the Structured Capital Funds to focus on primary, structured financings in hybrid, credit, and credit-like investments, although the Structured Capital Funds may also make secondary investments in hybrid and credit instruments, including in periods of market dislocation, and may pursue other adjacent opportunities. Structured capital investments target capital appreciation, contractual returns, or any combination thereof. The Structured Capital Funds pursue structured capital investments in private and public companies that operate across industries globally. In employing its fundamental approach to investment selection for the Funds, Viking generally performs a number of tasks that may include the following: detailed review of a company’s products and services; market analyses to estimate the size of the future market for such products and services; analyses of a company’s financial information; evaluations of the effectiveness of a company’s management team; discussions with a company’s potential customers and competitors; consultations with industry experts; reviews of alternative data; quantitative analyses and reviews of other quantitative inputs, including through artificial intelligence; and reviews of the macroeconomic, regulatory, and technological dynamics affecting a company’s prospects. Viking also seeks to incorporate environmental, social, and governance (“ESG”) considerations into its investment process to the extent it believes they are material to a company’s business model, management practices, or intrinsic value. Viking believes that ESG issues have the potential to impact the operations and valuation of a company, and it seeks to incorporate material ESG considerations into its analysis to manage risks, identify opportunities, and facilitate well-informed decision-making. Viking places a particular emphasis on governance by evaluating the quality of management and a company’s ability to formulate and execute strategy, allocate capital, align management’s interests with those of its shareholders, and create and maintain independent boards with appropriate oversight. Viking may also hold discussions with and provide feedback to companies on a broad range of topics, including their material ESG issues and sustainability practices and disclosures. Viking’s ESG integration efforts are evolving; Viking does not necessarily identify all material ESG factors, nor does Viking identify ESG factors for all investments. Viking approaches each investment individually, and the types of inputs assessed, as well as the importance assigned to each, are specific to each investment. While Viking views ESG integration as an important element of its fundamental research, ESG factors are not necessarily determinative factors in its investment decisions, it does not invest with the goal of obtaining specific ESG impacts or outcomes, nor does it apply any ESG-related exclusions to its investible universe. Viking employs a Head of Investigative and ESG Research to assist the investment team on deeper dives into the material ESG issues that are identified for further analysis. Viking encourages, trains, and provides its investment team members with various resources to identify and incorporate ESG issues that they believe are material into their research; however, each of them determines whether and how to do so in any particular case. Viking aspires to continue to evolve its integration of material ESG issues over time. In evaluating investments, Viking may place greater emphasis on certain criteria depending on the nature of the relevant company and the associated investment terms. For

instance, Viking will typically focus on different factors when evaluating a potential investment in an early-stage company as compared to a late-stage investment in an established business. In addition, to evaluate liquid investments, Viking typically develops multi-year financial models forecasting a company’s earnings, cash flow, and prospective growth rates, which are then used to forecast a target price for that company’s securities. The duration of the holding period for liquid investments is generally determined by how quickly the security’s price approaches Viking’s target price and any new or changed data points that call the original thesis into question. Other factors may include Viking’s view of the effectiveness of the company’s management, the company’s potential growth trajectory, and market liquidity. Viking reevaluates the Funds’ liquid investment positions frequently as circumstances change and resizes positions due to factors such as changes in fundamental performance or outlook, stock price, market news, or macroeconomic conditions. Moreover, each position is consistently evaluated not only on its own merits, but relative to other opportunities; accordingly, positions may be resized or closed out based on changes in Viking’s broader investment universe. An investment in a Fund is speculative and involves a significant degree of risk. The Funds are designed for sophisticated investors that are able to bear a substantial loss of capital and for which an investment in the Fund is not a complete investment program. B. Material, Significant, or Unusual Risks Relating to Investment Strategies. The following is a non-exhaustive summary of certain material, significant, or unusual risks associated with the Funds’ significant investment strategies and Viking’s methods of analysis. Investment and Trading Risks. The Funds’ investment programs carry significant inherent risks. Investors may lose all or part of their investments in the Funds. Viking believes that the Funds’ investment programs and research techniques moderate this risk through a careful selection of securities and other financial instruments. No guarantee is made that the Funds’ investment programs will be successful. The Funds’ investment programs employ investment techniques that may include short sales, leverage and options on securities, swaps, futures, and forward contracts, the use of which can, in certain circumstances, increase the investment losses to which the Funds may be subject. The risks of these various techniques may be cumulative, potentially resulting in greater losses than might result from any single technique used in isolation. Moreover, the risk exists that despite its best efforts, Viking will make mistakes in investment selection. This risk is heightened in the case of “thematic” investments. From time to time, Viking may make a series of investments, long or short, in a particular geography, industry, or asset class, and there is a risk that the overall “theme” on which such investments are based may prove to be wrong. These investments generally will not be hedged. If, for example, Viking developed the investment thesis that a particular product was in “secular” decline (meaning sales would decline over a long period, regardless of general economic activity), Viking might take significant short positions in the stocks of several companies that sell such products, or certain components of such products. If that thesis proved wrong, the applicable Funds could suffer significant losses in connection with those investments. Viking is not limited in the types of investment strategies it may pursue or the types of instruments in which it may cause the Funds to invest. Moreover, the Funds’ investments may be concentrated at various points in time in a particular segment of an industry or geography. Any new investment strategies, risk management techniques, and investment tactics used by Viking for the Funds may not be thoroughly tested before being employed and may involve

Read the rest in the brochure

Viking’s clients are the Funds to which it provides investment advice. The Funds are not subject to any requirements for opening or maintaining an account. Investors in the Funds include charitable foundations, endowments, pension plans, sovereign entities, funds of funds, investment companies, trusts, and individuals. Investors in the Funds must meet certain suitability requirements as set forth in each Fund’s offering memorandum and/or operative documents. The offering memorandum for each Fund sets forth the required minimum amounts for investment by investors in such Fund. These minimum investment amounts do not apply to investors who are Viking Affiliates and may be waived or reduced for any investors in Viking’s sole discretion.

Item 5, above, describes the Incentive Allocations received by Viking. Viking and its supervised persons do not receive any additional performance-based compensation from clients. As discussed in Item 5, Viking Affiliates and certain Co-Investment Vehicles are not subject to an Incentive Allocation. Performance-based compensation may create an incentive for Viking to make investments for the Funds that are riskier or more speculative than would be the case if Viking (or its affiliates) did not receive performance-based compensation. A. Allocation of Investment Opportunities. Considering the differences in the portfolios, Management Fees, and Incentive Allocation mechanisms of the Funds, Viking is incentivized to allocate investment opportunities among the Funds in a manner that maximizes the amount and/or expedites the receipt of compensation for Viking. Furthermore, if Viking Affiliates comprise a greater percentage (or all) of certain Funds, then Viking has an incentive to preferentially allocate investment opportunities to such Funds. Viking and Viking Affiliates could also enter into arrangements to provide financing to certain Funds, similarly giving Viking an incentive to preferentially allocate opportunities to, or manage investments so as to favor its interests in, such Funds. Potential conflicts of interest with respect to the allocation of investment opportunities are addressed by Viking’s allocation policy (as described below in this Item 6 and in Item 11). While each Fund’s investment program provides Viking with broad discretion in determining the types of investments in which such Fund may invest, Viking anticipates that each Fund’s portfolio (other than potentially the portfolios of the Structured Capital Funds) will be predominantly concentrated in investments that comprise such Fund’s “Core” investment mandate. Each Fund may also make investments, including substantial investments, that are “Non-Core” to such Fund (i.e., outside of such Fund’s Core investment mandate). While the portfolios of the Structured Capital Funds are expected to be concentrated in “Core” investments, the Structured Capital Funds may invest a majority or all of their capital in NonCore investments. This means that other Funds may have priority over the majority of the investments that the Structured Capital Funds wish to make, and there are no assurances that other Funds will not exercise their priority with respect to Non-Core investments the Structured Capital Funds would otherwise wish to pursue. Additionally, any Fund may decline to pursue investments within its Core investment mandate, in which case such investments may be made available to other Funds. Viking may launch funds or vehicles in the future that receive equal or higher allocation priority of Non-Core investments of a Fund, or may, for any reason or no reason, cause a Fund to discontinue making investments that are within such Fund’s Non-Core investment mandate for a finite or indefinite period of time. Certain Funds currently have, and any existing or new Fund may be given, priority investment allocations with respect to any category of investment within a Fund’s Non-Core investment mandate (and vice versa), even if similar investments were previously made by such Fund. Furthermore, Viking may allocate investment opportunities that are within a Fund’s Non-Core investment mandate to co-investors with priority over the Funds (and vice versa). Viking may also use the Funds to incubate a Non-Core investment strategy and thereby test the viability of such strategy. For example, in 2021, prior to the launch of the Structured Capital Funds, Viking began to expand Viking’s credit investing capabilities, with credit investments

generally allocated to the VGE Funds as Non-Core investments. Then, in 2023, Viking launched the Structured Capital Funds, which generally have priority over the VGE Funds with respect to certain credit investments. In the future, Viking may again use existing Funds to develop new investment strategies or expand existing investment strategies and later seek to form new Funds based on the success of the investment strategies deployed in the existing Funds. In the event any such strategies are unsuccessful in the existing Funds, the relevant Funds may bear negative returns. In the event any such strategies are identified as successful in the existing Funds, such strategies may become Core to new Funds, in which case the new Funds would generally have priority over the relevant Funds with respect to investments in such strategies. Viking may also establish additional Funds that have, or grant to an existing Fund, equal allocation priority as the Funds, including for investments that are within the Core investment mandate of any of the Funds. Such Funds may invest in all or a subset of the investments within an existing Fund’s Core investment mandate. For example, Viking may establish sector-, industry-, or geography-focused funds to make investments in such specific sectors, industries, or geographies. Viking’s allocation policy currently provides that fundamental research-driven investments in illiquid equity securities issued by operating companies (and related follow-on investments and hedges) are generally allocated with priority to the Opportunities Funds relative to other existing Funds. Similarly, the Structured Capital Funds generally receive priority allocation of credit investments, including liquid and illiquid credit instruments, as well as “hybrid” investments that are predominantly credit-like in nature and hedging positions related to any of the Structured Capital Funds’ investments. Such priority allocation methodologies are subject to (a) Viking’s discretion to make appropriate exceptions, for instance, when another Fund has a legal right of first refusal to a follow-on investment pursuant to the terms of its original investment and (b) Viking’s ability to grant other Funds equal priority with respect to investments within a Fund’s Core investment mandate. When it is determined that an investment opportunity is appropriate for one or more Funds that have the same allocation priority (including in the case in which no priority is given), then Viking will generally allocate the investment opportunity among such Funds in a fair and equitable manner over time, taking into account factors that it determines, in its sole discretion, to be appropriate. Such factors may include the relative amounts of capital available for new investments at the relevant Funds, the expected holding period and liquidity of the investment, the relative periods of time during which capital can be called or deployed for new investments by the relevant Funds, the expected duration of the relevant Funds, portfolio diversification, risk management, relative exposure to market sectors or investment themes of the relevant Funds, anticipated risk and return profiles of the investment, the current or anticipated availability of other suitable investment opportunities for the relevant Funds, any legal, tax, regulatory and other considerations, the decisions of the portfolio manager(s) assigned responsibility for making, managing, and disposing of the investment opportunity for the relevant Funds, and the investment programs and portfolios of the relevant Funds, as appropriate. These allocation decisions allow Viking to use a significant amount of discretion in determining appropriate allocations of investment opportunities among the Funds. Determinations made by Viking regarding a Fund’s capacity with respect to certain investments will require Viking to make allocation decisions using analysis that is, in part, inherently subjective. Although certain Funds may pursue investment objectives that are substantially similar to other Funds, the portfolios of such Funds may differ as a result of purchases and redemptions being made at different times and in different amounts, differences in investment programs and guidelines, and/or tax, regulatory, and liquidity considerations. Viking will have no obligation

to purchase or sell a security for, enter into a transaction on behalf of, or provide an investment opportunity to any Fund solely because Viking purchases or sells the same security for, enters into a transaction on behalf of, or provides an opportunity to any other Fund if it believes such security, transaction, or investment opportunity would not be suitable, practical, or desirable for the Fund. Please see Item 6 above and Item 11 below for additional disclosure regarding Viking’s allocation policy. Viking also has the ability to establish “Independent Advisory Committees” or “Limited Partner Advisory Committees” to consider and, on behalf of the Funds and their investors, approve or disapprove of certain matters involving potential or actual conflicts of interest. When Viking determines that an investment opportunity is within a Fund’s Core investment mandate and is otherwise appropriate for such Fund and one or more other Funds, Viking generally expects to allocate such investment opportunity among such Funds in a fair and equitable manner over time, taking into account factors that it determines, in its sole discretion, to be appropriate. Viking makes sizing and allocation decisions among Funds for investments in its sole discretion. Determinations as to whether any particular investment, including any follow-on investment, is Core or Non-Core to any Fund, as well as exceptions to such framework, are also made in Viking’s sole discretion in accordance with its allocation policies, which may give rise to certain conflicts of interest and, as applicable, are subject to approval by Viking’s Conflicts Committee. From time to time, Viking expects one Fund to make investments in the same company or issuer as one or more other Funds. While often Funds would make and exit any such investment on the same general terms, differences between such Funds, including their respective terms, investment periods, structures, regulatory and compliance obligations, jurisdictions, investor base, and investment strategies, could result in one Fund making or exiting its investment at a different time, at a different effective price, or with differing costs or terms than the other Funds. For example, a Fund may invest in the publicly traded securities of a company or issuer in which another Fund has previously invested, including by purchasing these securities in an initial public offering (“IPO”), in a secondary offering, or in the open market. Such investments may, and sometimes do, give rise to conflicts of interest and may influence Viking’s investment decisions, as different investment decisions could impact the different Funds unequally. For instance, in light of the different economic terms among the Funds, Viking may be incentivized to allocate investment opportunities to one Fund and not to other Funds to maximize the amount it or its affiliates receive in Management Fees or Incentive Allocation, or as a return on invested capital. A Fund may also make follow-on investments in another Fund’s portfolio companies by exercising pre-emptive rights, options, warrants, and other contractual rights obtained and negotiated for by such other Fund (or a different Fund) in connection with a previous investment in the applicable company or issuer, and vice versa. Such follow-on investments may create conflicts of interest, including where Funds have the opportunity to benefit from rights and options that were negotiated by another Fund, in some cases in exchange for consideration. Additionally, one Fund could have influence on a company or issuer, as applicable, through its ownership stake or the terms of its investments and influence the company or issuer, as applicable, or to make decisions that disadvantage another Fund. Viking might also be incentivized to cause one Fund to make an investment in a company or issuer that it would not have otherwise made unless another Fund was also invested in that company or issuer, for example, in a situation where such company or issuer requires liquidity or a cash infusion.

Read the rest in the brochure

A. Broker-Dealer Registration Status. Neither VGI nor any VGI management person is registered, or has an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. B. Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Adviser Registration Status. VGI is not registered, nor does it have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. C. Material Relationships or Arrangements with Industry Participants. Viking Performance serves as the general partner or investment manager of each of the VGE Funds; VLF GP serves as the general partner or investment manager of each of the VLF Funds; Hybrid GP or Hybrid Portfolio GP serves as the general partner of each of the Hybrid Funds; Drawdown GP serves as the general partner of each of the Drawdown Funds; Vintage IV GP serves as the general partner of each of the Vintage IV Funds; and Structured Capital GP or Structured Capital Portfolio GP serves as the general partner of each of the Structured Capital Funds. Each of Viking Performance, VLF GP, Hybrid GP, Hybrid Portfolio GP, Drawdown GP, Vintage IV GP, Structured Capital GP, and Structured Capital Portfolio GP is exempt from registration as a commodity pool operator. VGI’s relationship with each of Viking Performance, VLF GP, Hybrid GP, Hybrid Portfolio GP, Drawdown GP, Vintage IV GP, Structured Capital GP, and Structured Capital Portfolio GP does not create a conflict of interest for VGI with its clients. VGI engages certain of its affiliates to provide investment research, analysis, recommendations, and/or advice to VGI with respect to the Funds. VGI assumes full responsibility for any and all fees payable to its affiliates in connection with their provision of services. Such affiliates include Viking Europe and Viking Hong Kong. Viking Europe is registered with the Financial Conduct Authority in the UK and Viking Hong Kong is registered with the Securities and Futures Commission in Hong Kong. Viking Europe and Viking Hong Kong are each authorized to exercise discretionary investment authority over a portion of the assets of certain Funds. VGI’s relationships with Viking Europe and Viking Hong Kong do not create a material conflict of interest for VGI with its clients. D. Material Conflicts of Interest Relating to Other Investment Advisers. VGI does not recommend or select other investment advisers for its clients.

A. Code of Ethics. Viking has adopted a Code of Ethics that incorporates principles that all employees are obligated to uphold. These principles are designed not only to help Viking fulfill its fiduciary obligations, but also to instill Viking’s commitment to honesty, integrity, and professionalism in its employees. The Code of Ethics incorporates the following general principles that all employees are expected to uphold at all times:

employees must place the interests of the Funds first;

employees must avoid any business, financial, or other relationship with any individual or entity that might impair or even appear to impair the independence of Viking and the Funds;

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

employees may not take inappropriate advantage of their positions. This means that employees may not personally take opportunities that are discovered through the use of corporate property, information, or position for personal gain, or compete with Viking or the Funds.

The Code of Ethics includes, among other things, provisions relating to conflicts of interest, acceptance of significant gifts, reporting of certain gifts and business entertainment items, political contributions, charitable contributions, and personal securities trading. All employees at Viking must acknowledge annually that they understand and agree to the terms of the Code of Ethics. Certain other individuals, such as Viking’s principals and certain consultants, have also agreed to comply with the Code of Ethics as if they were Viking employees. Throughout this Item 11, the term “employees” shall be deemed to include such other individuals. Clients and prospective clients may request a copy of Viking’s Code of Ethics by contacting Viking Investor Relations at (212) 672-7000 or inquiries@vikingglobal.com. B. Securities In Which Viking or a Related Person Has a Material Financial Interest. Cross Trades. Viking routinely rebalances the Funds’ liquid portfolios in proportion to their respective net asset values or to maintain exposure levels consistent with each Fund’s objectives. Rebalancing may result in cross trades, which are transactions in which the buyer and seller are managed by the same investment manager. Viking determines in its discretion whether rebalancing should be performed. None of Viking, its affiliates or any related party receives any compensation in connection with these rebalancing transactions. Except as described below, these cross trades are made without brokerage commissions being charged. Viking’s policy is to avoid cross trades involving the VGE Employee Fund and to execute trades for the VGE Employee Fund in the public market whenever possible (and thus brokerage commissions are generally charged). If Viking determines to rebalance the Funds’ portfolios at the start of a given month in response to subscription and redemption activity, this will generally be accomplished by means of a journal entry with the applicable prime broker or swap counterparty on the first business day of the month, at the close-of-day prices from the last day of the prior month. Positions are

transferred amongst the Funds (other than the VGE Employee Fund) in this manner to reduce transaction costs. If the VGE Employee Fund is involved in a rebalancing of this kind, Viking will generally seek to execute the VGE Employee Fund’s portion of the rebalancing transaction in the public market on the first business day of the given month. If Viking determines at any time to rebalance a Fund’s portfolio to adjust its exposure levels, this will generally be accomplished by executing trades in the public market on the first business day following the day Viking determines to conduct such rebalance. If there is an offsetting portfolio manager order for another Fund (other than the VGE Employee Fund), these transactions will generally be executed as cross trades in the public market. If there is an offsetting portfolio manager order for the VGE Employee Fund, Viking will generally seek to execute such order in the public market following the execution of the rebalancing transactions for the other Funds. If trading is restricted in a security that would be part of a rebalancing, the position will be rebalanced as soon as practicable after the restriction is lifted. In addition, Viking may occasionally cause the Funds to enter into cross trades on equity swap positions other than as part of a rebalancing in order to correct for shifting allocations over time, usually when closing out a position. Principal Transactions. A principal transaction occurs when an investment adviser, acting for its own account (or the account of an affiliate), buys a security from, or sells a security to, a client’s account. Viking generally does not expect to cause the Funds to enter into principal transactions, but it is possible given the investment strategy and investor base of the Funds, in particular the Structured Capital Funds, that the Funds may enter into one or more principal transactions. If the Funds were to enter into any principal transactions, Viking would satisfy the requirements of Section 206(3) of the Investment Advisers Act of 1940, as amended (the “Advisers Act”), to the extent required by law, which require an investment adviser to provide written disclosure to a client and obtain the client’s consent prior to settlement of any principal transaction. When calculating a Fund’s internal ownership percentages for this purpose, Viking is not required to include accrued, but unrealized, Incentive Allocation and Priority Profits Allocation amounts. Viking may also cause the Funds to engage in transactions that pose potential conflicts of interest similar to principal transactions. For example, Viking has previously caused a Fund to make an investment that involved providing a loan to a company that is controlled by another Fund. In this case, Viking elected to provide written disclosure to, and obtained the consent of, the lending Fund’s board of directors prior to consummating the transaction. Viking may take similar steps if and when it identifies similar potential conflicts in the future, although Viking does not undertake to do so in cases where it is not required by law or the Funds’ organizational documents. Additionally, Viking may cause a Fund to invest alongside another Fund in which Viking Affiliates hold more than 25% of the interests in circumstances where such Fund would not have been able to participate but for the Fund’s participation (e.g., due to investment size), or determine that the Fund will pass on an investment opportunity to which it has priority (e.g., a follow-on opportunity that Viking does not believe is appropriate for the Fund) and then allocate all or a portion of such opportunity to such Fund. From time to time, an investment by a Fund may be sold or otherwise disposed to another Fund. For example, a portfolio company of one Fund could evolve into a company with a lower risk and return profile and/or longer expected holding period targeted by another Fund, or a Fund may sell their post-IPO shares in a portfolio company to another Fund. In such cases, Viking could effect a purchase or sale of an investment between the Funds. Consent of the investors or an Independent Advisory Committee may not be required for such a transaction, even though such transactions involve conflicts of interest.

C. Investing in Securities That Viking or a Related Person Recommends to Clients. Viking’s Code of Ethics generally prohibits Viking individuals from investing in singlename, publicly traded stocks, or corporate bonds. Exceptions to this prohibition require preclearance by Viking. Nonetheless, there have been circumstances in which, for a variety of reasons, Viking individuals, including members of the investment staff, have acquired investments in securities and other assets in which the Funds were, or could have been, invested. Other such circumstances may arise in the future. Thus, there is a possibility that Viking individuals will benefit from market or investment activity by the Funds. Viking’s Code of Ethics requires each Viking individual to notify VGI’s Chief Compliance Officer if the individual is, or is considering, evaluating, or recommending, on behalf of the Funds: (a) securities of an issuer in which the individual has an existing personal investment; or (b) securities of an issuer that, to the individual’s knowledge, has a material business arrangement with an issuer in which the individual has an existing personal investment. However, there can be no assurance that Viking will be aware of all apparent or actual conflicts of interest involving an individual’s personal investments and the individual’s activities on behalf of the Funds. Viking has established policies and procedures to monitor, mitigate, and/or disclose conflicts with respect to investment opportunities in a manner it deems fair and equitable, including the restrictions placed on personal trading in the Code of Ethics, as described above, and regular monitoring of individual transactions. D. Conflicts of Interest Created by Contemporaneous Trading. Viking manages investments on behalf of six types of pooled investments funds: the VGE Funds, the VLF Funds, the Hybrid Funds, the Drawdown Funds, the Vintage IV Funds, and the Structured Capital Funds. As further described in Item 8, the investment programs of the VGE Funds, the VLF Funds, the Hybrid Funds, the Drawdown Funds, the Vintage IV Funds, and the Structured Capital Funds overlap and therefore, the Funds may participate with each other in investments. In addition, the Funds may co-invest alongside non-clients, including Viking personnel and/or certain Fund investors. Viking’s investment allocation and co-investment policies are detailed in Item 6. E. Other Conflicts of Interest. Expenses. When allocating expenses, Viking must first determine whether such expenses are a Fund’s “own” expenses and therefore are to be borne by such Fund (or a portfolio company) or whether such expenses are expenses of a portfolio company, another Fund, or Viking, to be borne by them, as applicable. Determining whether to engage a third party or an employee of Viking to provide certain services to the Funds gives rise to potential conflicts of interest since Viking typically bears the compensation costs of its employees who render such services, whereas amounts paid to third parties are typically a Fund expense borne by all partners. Viking therefore has an incentive to retain third parties rather than hire additional employees of Viking and to outsource to third-party service providers’ functions that employees of Viking could perform or have previously performed. Furthermore, Viking will be required to determine whether expenses of the Funds should be allocated pro rata to all investors or only to certain investors, and investors can be allocated a portion of certain expenses even if they did not directly benefit from the relevant expense. For instance, interest and expenses associated with borrowings by a Fund, including borrowings for Management Fees and investments, can be allocated pro rata to all investors even if the underlying use for the borrowing does not benefit all investors proportionately, for example, due to differing management fee terms and/or an investor’s excuse or exclusion from an investment. Expenses

Read the rest in the brochure

A. Factors Considered in Selecting or Recommending Broker-Dealers for Client Transactions. Portfolio transactions for each Fund will be allocated to broker-dealers on the basis of numerous factors and not necessarily lowest available commission cost. Viking seeks to achieve best execution in its dealings with the brokerage community. Viking considers a variety of factors in evaluating the services provided by broker-dealers and determining with which broker-dealers to execute transactions. Factors that Viking has historically considered and which it may in the future consider include:

Reputation, financial viability, and regulatory compliance;

Confidentiality of trading activity;

Accuracy and timeliness of execution, clearance, and settlement;

Block trading capabilities;

Market insight and sector expertise;

Ability to execute difficult transactions;

Low-cost trading algorithms;

Access to underwritten offerings, private investment opportunities, and secondary market liquidity;

Reliability and strength of salespeople;

Commissions, mark-ups, mark-downs, or spreads;

Ability to manage market impact and trading costs;

Value of brokerage or research services;

Provision or payment (or rebate to Viking for payment) of costs of brokerage or research products or services;

Willingness to correct mistakes;

Size and volume of the broker’s order flow;

Responsiveness of the broker-dealer;

Accommodation of special needs;

Frequency and amount of price improvement;

Stability of borrow and financing access and costs;

Ability to generate and maintain balance sheet efficiency; and

Robustness of operational process.

1. Research and Other Soft Dollar Benefits. In connection with a portion of its trading, Viking agrees on behalf of its Funds to pay brokerage commission rates that are more costly than “execution only” rates. In doing so, Viking pays commissions, in part, to obtain research and other products and services to be used for the benefit of Viking and/or its other Funds, a practice referred to as “soft dollar”

expenditure. Viking has an incentive to select or recommend a broker-dealer based on its interest in receiving the research or other products or services (whether for Viking’s own benefit or for the benefit of its other Funds) rather than the interest of the applicable Fund in receiving most favorable execution. Broker-dealers may provide research or other products or services in exchange for such “soft dollar” expenditure that are beneficial to Viking and/or certain Funds, but not necessarily beneficial to all Funds. Viking may also engage in “soft dollars” arrangements through “commission sharing,” which is a practice whereby Viking pays a broker-dealer for trade execution and requests that the broker-dealer allocate a portion of the commissions to third-party providers of research or other products or services. Viking endeavors to use soft dollars to pay for eligible research or brokerage products or services to the extent such products or services fall within the safe harbor created by Section 28(e) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”). Under Section 28(e), eligible research or brokerage products or services obtained with soft dollars generated by one Fund may be used by Viking to service other Funds. Section 28(e) does not provide a “safe harbor” with respect to transactions effected on a principal basis (with the exception of certain riskless principal transactions), or transactions effected in futures, currencies, or certain derivative instruments. Where a product or service obtained with “soft dollars” is “mixed-use” to Viking, Viking will make a reasonable allocation of the cost which may be paid for with “soft dollars.” Viking seeks to ensure that its use of soft dollars results in a fair and equitable allocation among its Funds over time. However, the amount of soft dollars generated by a Fund may not necessarily be commensurate with the benefits derived by such Fund. Moreover, Viking and one or more Funds are expected to derive substantial direct or indirect benefit from these services, particularly to the extent Viking uses soft dollars to pay for expenses which it would otherwise be required to pay, or a Fund does not generate “soft dollars” during a period through its own activities. The investment information and soft dollar benefits received from brokers may be used by Viking in servicing Funds, and not all such information and soft dollar benefits may be used by Viking in connection with a particular Fund, including research and brokerage services obtained by the use of commissions arising from a Fund’s investments. Accordingly, a Fund will not necessarily, in any particular instance, be the sole direct or indirect beneficiary of the research or brokerage services provided. Likewise, Funds may receive benefits from the use of commissions arising from other Funds’ investments without compensation or other benefit to the other Fund whose information is being used. This practice gives rise to conflict of interest in allocating brokerage business and benefits received from such allocation, including an incentive to cause the Funds to effect more transactions than they might otherwise do to obtain those benefits. Research products or services provided to Viking may include data services (such as those providing stock quotes, last sales price, and trading volumes), research reports on particular industries and companies, alternative data (i.e., “big data”), economic surveys and analyses, recommendations as to specific securities, and other products and services related to investment decision-making. Brokerage services provided to Viking must be sufficiently related to the execution, clearing, and settlement of securities transactions effected on behalf of Viking’s Funds to satisfy the SEC’s temporal standard for brokerage. As a general matter, direct connectivity services between an adviser and an executing broker will satisfy this temporal standard, but any products or services provided by an executing broker that are part of an adviser’s overhead, including administrative and marketing expenses, would not satisfy this standard. Even if Viking determines an expense is not eligible to be paid with soft dollars, such expense may be allocated to the Funds to the extent otherwise permitted under the Funds’ organizational documents.

With respect to Viking Europe, the rules of the UK Financial Conduct Authority (“FCA”) require charges for third-party investment research and related products and services provided by executing brokers to be identified and paid for separately from execution costs. In order to comply with the FCA rules, Viking Europe pays for research and related products and services it consumes using a research payment account or one or more other methods permitted under FCA rules, such as under a commission sharing arrangement. In general, these research expenses represent operating expenses of the Funds. Investment personnel evaluate Viking’s broker-dealers that provide research products or services through a “broker vote” twice a year. The “broker vote” is a qualitative and quantitative assessment of the value of research services the broker-dealers provide and determines amounts paid for this research. In addition, there are other providers of research or brokerage services payable with soft dollars who are paid amounts that are agreed upon prior to the provision of services. 2. Brokerage for Client Referrals. Neither Viking nor any related person receives client referrals from any broker-dealer or third party. However, from time to time, brokers may assist the Funds in raising additional funds from investors, and representatives of Viking may speak at conferences and programs sponsored by such brokers for prospective investors. Through such “capital introduction” events, prospective investors have the opportunity to meet with representatives of Viking. Neither Viking nor the Funds compensate any broker for organizing such events or for any investments ultimately made by prospective investors attending such events. The Funds may accept subscriptions from investors who also provide services to the Funds, including brokers and their affiliates. Relationships such as these could be viewed as creating a conflict of interest that potentially could affect Viking’s ability to seek best execution. Viking conducts periodic best execution reviews in an effort to identify and mitigate compliance risks associated with brokerage relationships, and to determine that Viking is obtaining best execution for the Funds. 3. Directed Brokerage. Viking does not recommend, request, or require that a client direct Viking to execute transactions through a specified broker-dealer. Further, Viking does not permit any client to direct brokerage. B. Order Aggregation. Viking generally executes transactions on an aggregated basis in light of the fact that the VGE Funds generally trade pari passu. To the extent the VLF Funds, Opportunities Funds, or the Structured Capital Funds purchase or sell the same position as the VGE Funds, Viking executes orders for the Funds concurrently. Each Fund participates in an aggregated order at the average price of the execution and shares the transaction costs pro rata based on its participation in the transaction. When Viking encounters limited investment opportunities that are appropriate for more than one Fund or when an aggregated order is only partially filled, then Viking generally allocates the filled portion of the order pro rata in proportion to the size of the order placed for each Fund. Viking generally combines subsequent orders placed during the same trading day with orders that have not yet been executed or completed. C. Trade Errors. Absent fraud, wilful misconduct, or gross negligence, the Funds generally will bear losses resulting from trade errors, human errors, or other similar errors. Viking has a conflict of interest in determining whether losses resulting from an error will be borne by the Funds, since any losses not borne by the Funds will be borne by Viking.

A. Economic Benefits for Providing Services to Clients. Except as described in Item 12, no persons other than the Funds provide an economic benefit to VGI for providing investment advice or other advisory services to the Funds. B. Compensation to Non-Supervised Persons for Client Referrals. Neither VGI nor any related person directly or indirectly compensates any person who is not a VGI supervised person for client referrals, though VGI could enter into such arrangements in the future.

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

A. Frequency and Nature of Review of Client Accounts or Financial Plans. VGI’s Chief Executive Officer, portfolio managers, and analysts review the accounts of the Funds, or the portfolios contained therein, on a frequent and regular basis. In making risk management decisions, VGI’s Chief Executive Officer, who also serves as the firm’s Risk Manager, is supported by one or more risk management professionals who assist with analyzing risks in our portfolios using, among other tools, advanced risk analytics software. The Chief Executive Officer/Risk Manager is responsible for determining capital allocation, setting applicable risk limits, and monitoring and managing aggregate portfolio risks, including increasing or decreasing liquid portfolio risk with respect to specific positions or portfolios. Private investments generally must be approved by an investment committee comprising the Chief Executive Officer, the Head of Private Investments, and one or more other investment team members. VGI’s Chief Executive Officer may delegate approval authority for investments to others within certain constraints and conditions, as VGI’s Chief Executive Officer deems appropriate. The investment staff structure, personnel, roles, responsibilities, and coverage areas may change from time to time. B. Factors Prompting Review of Client Accounts Other than a Periodic Review. A review of a client account may be triggered by any unusual activity or special circumstances. C. Content and Frequency of Account Reports to Clients. All investors in the Funds currently receive quarterly investor letters and an annual report including audited financial statements with a report thereon by the independent auditors. Depending on the specific Fund in which they are invested, investors also receive additional periodic reporting. Investors in Funds that are treated as partnerships for U.S. federal income tax purposes receive annual Schedule K-1s, and tax estimates are made available once a year.

VGI is subject to Rule 206(4)-2 under the Advisers Act (the “Custody Rule”). VGI is deemed to have custody of client funds and securities where, for example, it has the authority to deduct advisory fees from a client’s account or otherwise cause the movement of client funds. The funds and securities owned by the Fund are maintained with qualified custodians. VGI is not required to comply with, or is deemed to have complied with, certain requirements of the Custody Rule with respect to each Fund because it relies on the so-called “Pooled Vehicle Annual Audit Exception,” which, among other things, requires that each such Fund be subject to an annual audit by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, and that each such Fund distribute its audited financial statements to all investors within 120 days of the end of its fiscal year.

VGI has discretionary authority over the securities accounts of the Funds pursuant to investment management agreements between VGI and the Funds. The limitations on VGI’s discretionary authority are described in each Fund’s offering memorandum.

In accordance with Advisers Act Rule 206(4)-6, Viking has adopted proxy voting policies and procedures reasonably designed to ensure that proxy proposals, amendments, consents, resolutions, and similar voting matters are voted on (or abstained from, if appropriate) in the best interests of the applicable Funds. In making voting determinations, Viking considers the facts and circumstances it deems relevant, which may include (a) the impact on the value of the securities; (b) the anticipated costs and benefits associated with the proposal; (c) the effect on liquidity; (d) customary industry and business practices; and (e) material ESG issues. In order to facilitate the proxy voting process with respect to publicly traded issuers, Viking has retained an independent proxy voting service (the “Proxy Service”) to provide recommendations and manage the process of voting proxies in a timely manner for the Funds. For publicly-listed securities, the relevant investment team member(s) receive the Proxy Service Benchmark recommendation, Proxy Service Global Board-Aligned recommendation, and Proxy Service Sustainability recommendation, along with the relevant issuer’s feedback and recommendation. The relevant investment team member(s) are responsible for reviewing the recommendations and ensuring that each vote is cast in the best interests of the Funds. Viking operations-side professionals generally further engage with the investment team in instances where the Proxy Service Benchmark, Global Board-Aligned, and/or Sustainability recommendations do not align. Viking investment team member(s) maintain the responsibility to cast each vote in the best interests of the applicable Fund(s). For operational ease, within the Proxy Service’s system, votes are “preset” to the Proxy Service Benchmark recommendation, and Viking effects an “override” when deviating from the Proxy Service Benchmark recommendation. The investment team member(s) will override any Proxy Service Benchmark recommendation (including, where appropriate, by abstaining from voting) that, in the investment team member’s discretion, is determined not to be in the best interests of the Funds. In order to effect an override, the investment team member(s) must document in advance in writing to VGI’s Chief Compliance Officer the analysis supporting the override and must certify to VGI’s Chief Compliance Officer that the investment team member is aware of nothing that would suggest the existence of an actual or potential conflict of interest. The investment team member(s) responsible for the position also must make such a certification regarding actual or potential conflicts of interest. For private securities, Viking manages the process without use of the Proxy Service. The relevant investment team member(s) will review each vote and reach a determination whether and how to vote in the best interests of the Fund(s), and also will certify that the investment team member(s) is (or are) not aware of anything that would suggest the existence of an actual or potential conflict of interest. If an investment team member seeks to override an individual recommendation by the Proxy Service where voting a proxy this way may also benefit, or be perceived to benefit, the investment team’s or VGI’s own interest, then (a) the voting decision for such proxy proposal may be delegated to an independent third-party or an independent committee of partners, members, shareholders, directors, or other representatives of the Funds, as applicable; (b) the investors in the investing Funds may be informed of the conflict of interest and provide majority consent to vote the proxy as recommended by VGI; or (c) approval of the decision must be obtained from VGI’s Chief Compliance Officer or designee.

The Proxy Service discloses to Viking information regarding its conflicts of interest. Such a conflict may arise, for example, if the Proxy Service or one of its affiliates receives compensation from the issuer for providing advice on corporate governance issues. If Viking determines that the Proxy Service is not sufficiently independent with respect to any proxy, Viking will engage another independent proxy service to provide voting recommendations for such proxy. If Viking is unable to identify an independent proxy service for such proxy (or determines that such a substitute would be impractical), Viking will vote such proxy according to investment team members’ recommendations, provided that, in advance, such investment team members document their reasons in writing and certify their lack of awareness of an actual or potential conflict of interest. Viking also conducts periodic due diligence to confirm that the Proxy Service has the expertise, staffing, and technology needed to analyze proxy voting matters and support Viking’s fiduciary duties. This review includes the Proxy Service’s policies, methodologies, use of information sources, issuer engagement, conflict management, data accuracy procedures, responsiveness to identified deficiencies, and communication of business or methodology changes. Investors in the Funds may not direct Viking’s vote on any proxy solicitation. Clients and prospective clients may request information about specific proxy votes or a copy of Viking’s proxy voting policies and procedures by contacting Viking Investor Relations department at (212) 672-7000 or inquiries@vikingglobal.com.

VGI is not required to include a balance sheet for its most recent fiscal year, is not aware of any financial condition reasonably likely to impair its ability to meet contractual commitments to clients, and has not been the subject of a bankruptcy petition at any time during the past ten years.