Walleye Capital LLC

A. General Description of Advisory Firm Walleye Capital LLC provides discretionary investment management services to private pooled investment vehicles, the securities of which are offered to investors (“Fund Investors”) on a private placement basis (each, a “Fund” and collectively, the “Private Funds” or “Clients”). Formed in April 2005 as a Minnesota limited liability company, WC’s principal owner is William England. Nine other individuals also own minority interests in WC. WC conducts its advisory business from offices in New York, Minnesota, Massachusetts, Illinois, Connecticut, Florida, the United Kingdom, and Dubai. Our registration on Form ADV also covers affiliates of WC that are Relying Advisers (as that term is defined below) as well as affiliates of WC that may serve as the general partner of Private Funds that are U.S. or offshore partnerships (the “Fund General Partners”). The Fund General Partners’ facilities and personnel are provided by the Adviser. WC has organized the Office of the CIO (the “OCIO”) which is responsible for the strategic planning of investment activities, capital allocation across the four main investment verticals, evaluation and selection of business unit leaders, and prioritization of initiatives to support our investment activities. WC has also formed the Operating Committee (the “Operating Committee”) which is responsible for the oversight and management of all operational aspects of the firm, with a primary objective of running a business that is as efficient and effective as possible. The membership of the OCIO and Operating Committee can and will vary over time. This Brochure does not constitute an offer to sell or solicitation of an offer to buy any securities. The securities of the Funds are offered and sold on a private placement basis under exemptions promulgated under the Securities Act of 1933 and other applicable state, federal or non-U.S. laws. Any such offer or solicitation will be made only by means of a confidential private placement memorandum. B. Description of Advisory Services Overall, WC selects and delegates trading discretion to supervised persons of the Adviser (“Internal Portfolio Managers”), as well as third-party advisers (“Third-Party Managers”, and collectively “Portfolio Managers”). Certain international affiliates of WC may also serve as Portfolio Managers and “Relying Advisers” of WC which, in accordance with relevant SEC guidance, operate under the Adviser’s SEC investment adviser registration. WC principally conducts its advisory business through the Walleye

Opportunities Fund master-feeder complex (“WOF”). WOF is a multi-strategy Private Fund that invests globally across four main strategy groups: fundamental, volatility, quantitative and macro. WC also serves as the adviser to other Private Funds as disclosed in Part 1A. C. Availability of Customized Services for Individual Clients Our Clients are the Private Funds. Therefore, our services are tailored to the specific investment objectives and strategies as set forth in the applicable governing documents such as a limited partnership agreement or private placement memorandum (collectively “Fund Governing Documents”). The Private Funds and/or WC have entered into side letters or other similar agreements with certain investors primarily to accommodate particular legal, tax or regulatory requirements. Such side letter or similar agreements do not provide preferential liquidity or fees. D. Wrap Fee Programs

We do not currently participate in any wrap fee programs. E. Assets Under Management As of December 31, 2025, WC manages approximately $52.1 billion in regulatory assets under management on a discretionary basis. WC does not manage any Client assets on a non-discretionary basis.

A. Advisory Fees and Compensation We do not have a standard management fee or performance fee schedule. The fees applicable to each Private Fund are set forth in detail in the Fund Governing Documents. In general, the Adviser charges a “Management Fee” ranging from 0.30% and 1.5% per annum and a “Performance Allocation” ranging from 1% and 20%. Fund Investors in WOF do not pay a Management Fee and instead are allocated the overhead expenses of the Adviser and its affiliates in a pass-through expense arrangement (“PTE”). Management Fees and Performance Allocations will vary by Private Fund and by share class, and the Adviser may charge different fees or allocations and may waive or rebate a portion thereof. In addition to the Management Fees and Performance Allocations described above, Private Fund expenses also include the fees and performance-based compensation charged by or paid to Portfolio Managers who manage or trade such Client assets. Internal Portfolio Managers receive performance-based compensation (and in limited cases, salaries) and certain employees of the Adviser and its affiliates are compensated (including through bonuses) based on the returns and/or performance of investment strategies, the cost of which are borne by applicable Clients on a pro rata basis as set forth in the Fund Governing Documents. Third-Party Managers (including though sub-advisory relationships or direct investments in vehicles advised by such Third-Party Managers) also charge their own advisory fees and/or performance-based compensation, which are indirectly or directly borne by Clients (and if invested therein, such investments will also be subject to the expenses of such private investment funds managed by such Third-Party Managers). The Adviser believes that the use of Third-Party Managers enables the Private Funds to enhance performance by expanding the investment expertise available to the Private Funds, providing access to certain markets and providing access to strategies not otherwise deployed by the Adviser and/or other opportunities. Although various levels of discretion may be given to such Third-Party Managers, the Adviser remains responsible for monitoring the Third-Party Managers performance in the Private Funds’ portfolio.

B. Payment of Fees Fees and compensation paid to WC or its affiliates by the Funds are generally deducted from the assets of such Clients, with the timing of the fee deduction in accordance with the Fund Governing Documents. Management Fees and/or PTEs are generally calculated and payable monthly.

C. Additional Fees and Expenses Additional expenses borne by the Private Funds will be pursuant to the Fund Governing Documents including, but are not limited to:

Offering Expenses: all costs and expenses incurred by or on behalf of a Private Fund in connection with the continuing offering of Private Fund interests, including but not limited to trading vehicles, funds or accounts the Fund is invested in directly or via the applicable Private Fund’s master fund (if any), legal fees and the cost of preparing and distributing the Private Fund’s offering materials.

Professional Expenses: fees of accountants, auditors, attorneys, recruiters (including fixed and/or variable fees based on bonus pay-outs) and other professional expenses of a Private Fund or WC for the benefit of the Private Fund or any trading entities.

Trading Expenses: expenses related to the Private Funds’ trading and investment activities, including but not limited to brokerage fees, exchange and clearinghouse fees, payment for-order flow costs, regulatory fees, financing costs including debit financing fees and short stock financing fees, lending fees, custodial fees, SIPC fees, PCAOB fees, short stock and dividend expenses and similar expenses. Certain qualifying costs and expenses may be provided for through soft dollars generated by the Private Funds. Additional information on the Adviser’s soft dollar practices can be found in Item 12: Brokerage Practices.

Master-Feeder Structure Certain Private Funds managed by the Adviser utilize a master-feeder structure in which one fund invests (as a “feeder” fund) substantially all of its assets in another fund, acting as a “master” fund. To the extent a Private Fund’s capital is invested in a master fund, any or all of the fees and expenses payable by the Private Fund are typically paid by the Private Fund or the corresponding master fund, but are not duplicated (other than fees and expenses incurred by both the Private Fund and the master fund such as, without limitation, administration fees and auditing fees). Shared Expenses Allocated Among Clients WC will allocate shared expenses incurred by multiple Clients in its discretion in a fair and equitable manner and according to metrics that it determines to be reasonable. Expenses for more than one Client generally will be allocated to the applicable Clients on a pro rata basis based on a good faith methodology including, without limitation: (i) the total assets invested by each such Client and/or (ii) a percentage of shared personnel’s time devoted to each entity. WC has a conflict of interest related to allocation of shared expenses among Clients, in that allocation decisions may be impacted by Private Fund fee structures (such as when one Client pays WC a performance fee that is higher than another Client’s fee). To mitigate this conflict, we have organized an Expense Committee that meets on a regular basis to make fair and equitable decisions regarding allocation of shared expenses among Clients. Other Types of Direct and Indirect Fees or Client Expenses

To the extent that a Client is invested in an exchange-traded fund or mutual fund, the Client will bear, along with other shareholders, it’s pro rata portion of the exchange-traded fund’s or mutual fund’s fees and expenses (in addition to any WC fees and expenses).

To the extent that a Client is invested in other trading vehicles, such as special purpose vehicles (including affiliated special purpose vehicles) established to implement certain trading strategies, the Client will bear it’s pro rata portion of such trading vehicle’s management, trading and administrative fees and expenses.

Withdrawals of capital by a Fund Investor from a Client are typically subject to a lock-up period, compulsory notice period, and are subject to a gate or suspension as described in the relevant Fund Governing Documents. WC or an affiliate maintain discretion to waive or modify withdrawal restrictions if deemed appropriate.

D. Prepayment of Fees In general, WC’s fees are paid in arrears and Clients do not pay fees in advance.

E. Additional Compensation and Conflicts of Interest Walleye Trading LLC (“WT”) is an SEC-registered broker-dealer that was formed in 2005. WT is a trading vehicle utilized by WOF and specializes in the market-making of options on equities and futures. Various management persons as well as other employees of WC that perform trading and other functions for WT are registered representatives of WT. Certain trading employees of WC are also members of WT and receive a percentage of the net profits of WT related to their strategies. Clients receive services provided by WC affiliated entities as described further below in Item 10: Other Financial Industry Activities and Affiliations. The use of affiliated service providers by WC on behalf of Clients presents various conflicts of interest including conflicts associated with the selection, retention, and evaluation of the service provider; however, WC shall bear all expenses incurred in connection with the utilization of such affiliated service providers.

A. Method of Analysis and Investment Strategies The general objective of the Adviser’s investment strategy is to seek superior risk-adjusted rates of return. Private Funds advised by WC will principally invest in U.S. and non-U.S. financial instruments including, but not limited to, stocks, exchange-traded funds (“ETFs”), bonds, options, warrants, swaps, forwards, futures, currencies, commodities, repurchase agreements, partnership, limited liability company and other equity interests, money market instruments, and in equity and debt securities of unaffiliated private companies. The descriptions set forth in this Brochure of specific advisory services that we offer to Clients, and investment strategies pursued and investments made by us on behalf of our Clients, should not be understood to limit in any way our investment activities. We may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that we consider appropriate, subject to each Client’s investment objectives and guidelines. The investment strategies we pursue are speculative and entail substantial risks. Clients should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any Client will be achieved. B. Material, Significant or Unusual Risks Relating to Investment Strategies The following is a summary of the material risks associated with the Adviser’s core strategies. Investors in Private Funds advised by the Adviser must review the Fund Governing Documents for a description of the risks associated with a Fund and its investment strategy, including other risks such as general economic risks, regulatory risks, operational risks (including cybersecurity risks), tax risks, and other risks related to the Fund(s) Risk of Loss. Investing in securities involves risk of loss that Clients should be prepared to bear. All investments in securities and other financial investments involves substantial risk of volatility arising from numerous factors that are beyond the control of the Adviser and investment managers utilized by the Adviser, including market conditions, changing domestic or international economic or political conditions, changes in tax laws and government regulation and other factors. Illiquid Investment. An investment in a privately offered commingled fund can be highly illiquid, is speculative and is not suitable for all investors. Investment in privately offered commingled funds is only intended for experienced and sophisticated investors that are willing to bear the high economic risks of the investment. Certain of these risks may include: loss of all or a substantial portion of the investment due to

leveraging or other speculative practices; lack of liquidity (in that there may be no secondary market for the security and none expected to develop); volatility of returns; restrictions on transferring interests in the fund; potential lack of diversification and the resulting elevated risk; absence of information about valuations and pricing; complex tax structures and delays in tax reporting; and less regulation and higher fees than other types of investments including mutual funds. Counterparties and Brokers. The counterparties with which the trading entities trade or invest or that clear the trading entities trades may encounter financial difficulties and delay or default on their payment obligations. Any such default could result in material losses. Custody Risk. WC does not control the custodianship of their securities. The banks or brokerage firms selected to act as custodians may become insolvent, causing Clients to lose all or a portion of the funds or securities held by those custodians. Financing Arrangements; Availability of Credit. The use of leverage is integral to certain of WC’s strategies, and Clients depend on the availability of credit in order to finance their portfolio. There can be no assurance that Clients will be able to maintain adequate financing arrangements under all market circumstances. As a general matter, the banks and dealers that provide financing to Clients can apply essentially discretionary margin, haircut, financing, security and collateral valuation policies. Changes by banks and dealers in such policies, or the imposition of other credit limitations or restrictions, whether due to market circumstances or governmental, regulatory or judicial action, may result in large margin calls, loss of financing, forced liquidation of positions at disadvantageous prices, termination of swap and repurchase agreements and crossdefaults to agreements with other dealers. Any such adverse effects may be exacerbated in the event that such limitations or restrictions are imposed suddenly and/or by multiple market participants at or about the same time. The imposition of such limitations or restrictions could compel a Client to liquidate all or part of its portfolio at disadvantageous prices. Market-Making Strategies. Certain strategies involve market-making and seek to provide liquidity with respect to securities and derivatives. Market-making is dependent for its profitability on sufficient spreads between prices that can be “bid” and “asked” by market-makers. If bid-ask spreads shrink, the per trade profit decreases accordingly. Market-makers are also subject to regulatory risk. Options market-makers must be registered as broker-dealers with the SEC and members of the exchanges on which they quote. Similarly, futures market liquidity providers are members of the futures exchanges on which they trade. In such capacities, those entities are subject to audit and regulatory action, and must expend resources on compliance with applicable rules. Other factors that affect the profitability of market-making include: liquidity; the depth and breadth of an order book; suspensions of trading activity; exchange, regulatory and clearing fees; margin levels, collateral valuation policies and other financing policies of clearing brokers; and volume levels, among other things. Regardless of the ability of the Manager or the effectiveness of its strategies, an increase in fees, an adverse change in financing policies, and a lack of volume in the markets a trading entity quotes could each cause the Fund to experience substantial losses. Multiple-Strategy Approaches. The diversification of WC’s strategies may not be significant and, even if significant, may not provide meaningful risk control, while reducing a Client’s profit potential as a result of certain strategies being unprofitable while others are profitable. Certain of these strategies and markets may involve an unusually high degree of risk considered on a stand-alone basis, and combining multiple strategies inherently involves the opportunity cost of certain strategies’ losses offsetting the gains recognized by other strategies. Macro Strategies. Macro strategies are directional strategies that seek to profit from forecasting near- to medium-term price movements. The multitude of different factors which go into determining futures price levels makes any attempt at market forecasting inherently speculative and unexpected political, international,

weather and other events can cause major losses for strategies even if they correctly identified “true value” in the positions taken. Multiple Levels of Expense. As with most multi-manager investment platforms, in addition to fees and compensation charged by the Adviser and its affiliates, and expenses at one or more Fund levels, the Portfolio Managers charge and/or impose fees (including management fees and performance-based compensation) and expenses. Portfolio Managers may charge fees directly or through an underlying fund which they and/or their affiliate manage (at which level, such fund will also bear its own expenses). The multiple levels of fees and expenses will reduce the overall profitability of the Fund. Investors in the Fund are subject to higher aggregate fees and expenses than if they were able to invest with such Portfolio Managers or Portfolio Investments directly. Technical Strategies. Technical strategies implemented by WC will take multiple forms, including “technical investing” based on various historical price patterns and market indicia. Other technical methods are more related to supply and demand driven by corporate life cycle events or by changes in rules or regulations in the markets. In general, WC considers technical investing/trading not only to include the generic technical market factors used by most “technical” traders, but any approach based on identifying a “technical” reason why there will be an imbalance between investors moving in and out of a given financial instrument. There are many risks associated with this style of investing, including the non-consummation of the event that created the opportunity, particularly if many investors are making their investment decisions based on the assumption of consummation. Also, WC could be wrong in identifying the technical opportunity and/or in executing trades to exploit the opportunity. Relative Value Strategies. The success of WC’s relative value trades is dependent on WC’s ability to exploit relative mis-pricings among interrelated instruments. Although relative value positions are considered to have a lower risk profile than directional trades as the former attempt to exploit price differentials not overall price movements, relative value strategies are by no means without risk. Mis-pricings, even if correctly identified, may not converge within the time frame within which the Fund maintains its positions. Even pure “riskless” arbitrage—which is rare—can result in significant losses if the arbitrage is not able to be sustained (due, for example, to margin calls) until expiration. WC’s relative value strategies are subject to the risks of disruptions in historical price relationships, the restricted availability of credit and the obsolescence or inaccuracy of its or third party valuation models. Market disruptions may also force WC to close out one or more positions. Such disruptions have in the past resulted in substantial losses for funds employing relative value strategies. “Event Driven” Strategies. WC will invest in positions whose profitability depends on the result of some significant corporate event, for example, a merger, tender offer, exchange offer, initial public offering or liquidation. Corporate events are affected by numerous factors—including not only market movements but also regulatory intervention, shareholders’ consent and changes in interest rates and economic outlook—that can have a particularly adverse effect on even the most apparently safe risk arbitrage investments. The risk of non-consummation in such transactions is high, and unexpected outcomes can lead to substantial losses. Event Driven strategies generally incur significant losses when proposed transactions are not consummated. The consummation of anticipated event, such as mergers and acquisitions, bankruptcy announcements, proxy battles, corporate restructuring, spin-offs, litigation outcomes, leveraged buyouts, share buy-backs, tender offers, initial public offerings, rights offerings, and other significant corporate events can be prevented, denied or delayed by a variety of factors, including: (i) regulatory intervention; (ii) efforts by the target company to pursue a defensive strategy, including a merger with, or a friendly tender offer by, a company other than the offeror; (iii) failure to obtain the necessary shareholder approvals; (iv) adverse market or business conditions resulting in material change or termination of the pending transaction; (v) additional requirements imposed by law; and (vi) inability to obtain adequate financing.

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We provide investment advice to the Private Funds, as described above in Item 4: Advisory Business. Fund Investors may include high-net worth individuals, family offices, retirement plans, institutional investors and employees and/or related persons of WC. Details concerning applicable investor suitability criteria are set forth in the respective Fund Governing Documents and subscription materials. Each Fund

Investor is required to meet certain suitability qualifications, such as being an “accredited investor” within the meaning set forth in Regulation D promulgated under the Securities Act of 1933, as amended, a “qualified purchaser” or “knowledgeable employee” as defined in the Investment Company Act, as amended and, if charged a performance fee by WC, a “qualified client” as defined under the Investment Advisers Act of 1940. Fund Investors must also complete an investor questionnaire and must be able to represent that they do not fall into any of the categories outlined under Rule 506(d) of Regulation D. As a general matter, the minimum initial investment in Private Funds advised by WC is $1,000,000, which WC may waive in its discretion. Fund Investors are required to complete and execute a subscription agreement that, among other things, requires the investor to represent that it meets applicable legal and suitability requirements of the relevant fund.

As discussed under Item 5: Fees and Compensation, WC or its affiliates receive annual Performance Allocations or fees from certain Clients, which are based on a percentage of the net capital appreciation of their assets or other performance-based metrics as agreed with Clients. Because the amount of the fee or Performance Allocation is based on the assets, as the assets increase (or decrease) in value so do such fees. Performance-based compensation may create an incentive for the Adviser or a Portfolio Manager to cause the Private Funds to make investments that are riskier or more speculative than would be the case in the absence of performance-based compensation. In addition, because the performance-based compensation is calculated on a basis that includes unrealized appreciation of such Funds’ or Client’s assets, it may be greater than if such compensation were based solely on realized gains. Performance Allocations are subject to a loss recovery account or “high water mark,” and may be subject to certain other adjustments, as described in the Fund Governing Documents. Certain Portfolio Managers have been authorized to manage comparable investment portfolios across multiple Private Funds. WC has established order aggregation and allocation policies and procedures to mitigate potential conflicts of interest, as described in Item 12: Brokerage Practices.

Identification and Mitigation of Conflicts of Interest Mr. Irvin Kessler is a founding partner of WC and is involved in setting the strategic direction of WC. Mr. Kessler is a registered representative of WT. He is also an owner of WC. In addition, Mr. Kessler is an owner of Provident Real Estate Ventures LLC and sole owner and CEO of Deephaven, Inc., neither of which are SEC registered investment advisers. In addition, WC and affiliates (and their families) may, directly or through investments in other trading vehicles, investment funds or accounts (among other things), have personal or other interests in the securities or Third-Party Managers in which a Client invests as well as interests in investments in which a Client does not invest. WC and affiliates (and their families) also have personal or business relationships with brokers,

service providers, Fund Investors, corporate management, Third-Party Managers, directors or other parties with whom WC or the Clients themselves have relationships. Employees may also have personal investments with Third-Party Managers or their employees may have investments in our Clients. WC also employs family members of current and prior employees. As a result, WC may have conflicts of interest in allocating their time and activity between the Clients and other entities, in allocating investments among the Clients and other entities, in supervising employees, and in effecting transactions, evaluating investments or potential investments including allocating Client capital to Third-Party Managers, or retaining or evaluating services for the Clients and other entities, including ones in which WC employees (and their families) may be employed or have a greater financial or personal interest. Although WC will seek to limit any such conflicts and will act in a manner that is in accordance with their fiduciary duties to the Clients, these potential conflicts of interest may have an impact on an employee’s ability to perform his responsibilities on behalf of a Client. As discussed under Item 5: Fees and Compensation, WT is an SEC-registered broker-dealer that was formed in 2005 and specializes in the market-making of options on equities and futures. WT is a trading vehicle utilized indirectly and exclusively by WOF to trade certain of its investment strategies. Various management persons of WC, who are primarily responsible for Client trading and investment decisions, are registered representatives of WT. WC employees that perform trading and other functions for WT are also registered representatives of WT. Certain trading employees of WC are also members of WT and receive a percentage of the net profits of WT related to their strategies. Fund Investors of WOF may therefore pay additional PTEs, incentive fees and other fees in connection with WT. WC and Clients receive certain services provided by WC affiliated entities as described below. Deephaven Data Labs (“DDL”) is a data management systems provider that provides data management software and services. SafePark Commercial LLC (“SafePark”) and Fish Base LLC (“Fish Base”) are property management companies that own and manage office buildings from which WC leases space. The use of affiliated service providers by WC on behalf of Clients presents various conflicts of interest including conflicts associated with the selection, retention, and evaluation of the service provider. Expenses incurred in connection with DDL, SafePark, and Fish Base will be charged to Clients, as applicable per Fund Governing Documents. WC and affiliates of WC serves as the Fund General Partner to certain Private Funds. Each such Fund General Partner is exempt from registration with the CFTC as commodity pool operators pursuant to CFTC No-Action Letter 25-50 or the exemption available under CFTC Rule 4.13(a)(3). As well, WC is exempt from registration with the CFTC as a commodity trading adviser. Affiliated Businesses. Dockside LLC ("Dockside") is a wholly owned subsidiary of WC. Dockside provides front-to-back office platform services to institutional investors, primarily through customized private funds. WC's ownership of Dockside creates potential conflicts of interest, including with respect to the allocation of shared expenses between WC, its Clients, and Dockside. WC's CCO reviews conflicts arising from affiliated entity relationships pursuant to WC's conflicts of interest policies and procedures, and implements measures deemed necessary or appropriate to mitigate any such conflicts.

As an investment adviser, we stand in a position of trust and confidence with respect to our Clients. Accordingly, we have a fiduciary duty to place the interests of the Funds before our own interests. As such, and in accordance with Rule 204A-1 under the Advisers Act, we have adopted a Code of Ethics (the “Code”). The Code is designed to ensure that WC and supervised persons understand the need to act with competence, dignity, integrity, and in an ethical manner, when dealing with Clients, prospects, and fellow supervised persons. The Code requires compliance with all applicable laws and sets forth our policies and procedures

for our personnel (and, in some cases, certain family members) on (i) personal securities trading, (ii) gifts and entertainment, (iii) service on boards of directors and other outside activities, and (iv) conflicts of interest generally. All of our supervised persons receive training with respect to the Code upon commencement of employment and at least annually thereafter, including with respect to the prohibitions on insider trading. Fund Investors may request a copy of the Code by contacting WC at the address or telephone number listed on the first page of this Brochure. Supervised persons are generally prohibited from establishing new positions in “reportable securities” in a personal trading account or otherwise. The term “reportable securities” is broadly defined in the Code and covers, among other things, equity and debt securities of public companies, including, but not limited to, initial public offerings, private investments in public equity (i.e., PIPEs), and options on single-name securities. A supervised person who has positions in reportable securities that were established prior to joining WC (i.e. “grandfathered positions”) must receive compliance approval in order to reduce or close such positions. All of the foregoing transactions by our supervised persons are subject to review and supervision of the WC Compliance Department in order to mitigate any material conflicts that may arise as a result of such personal investments. Our affiliates and supervised persons (and their immediate family members) have the ability to invest in certain Private Funds (subject to applicable legal/suitability requirements); and some employees are required to invest in WOF through a dedicated private investment fund organized for the sole purpose of investing compensation earned by such employees. Investment advisers that manage accounts for multiple clients also have a number of obligations and limitations regarding their ability to effect transfers of securities from one client to another (each a “Cross Transaction”). To the extent that we determine that it would be in the best interests of certain clients to engage in a Cross Transaction (which can happen for a variety of reasons, including tax purposes, liquidity purposes, to rebalance client portfolios, or to reduce transaction costs that may arise in an open market transaction), any expenses will be allocated equitably in the discretion of WC between the applicable Clients. We (including our affiliates and personnel) do not engage in “Principal Transactions” with Clients (i.e. purchase or sell any securities from or to the Private Funds). To the extent that Cross Transactions may be deemed Principal Transactions (as such term is used under the Advisers Act), we will comply with the requirements of Section 206(3) of the Advisers Act. To the extent that we engage in any such deemed Principal Transactions, we will obtain approval from the applicable Client and/or from an independent Client representative to the extent permitted under the Fund Governing Documents. Neither the Adviser nor a Portfolio Manager (as applicable) will take brokerage commissions or otherwise be specially compensated for effecting Cross Transactions or deemed Principal Transactions. The Adviser and each Portfolio Manager (as applicable) intends that such transactions will, to the best of its ability, reflect the market value of the security or other instrument being purchased or sold, and the transaction will be subject to the Adviser’s or the Portfolio Manager’s duty of best execution, as applicable. Prior to effecting any such transaction, the Adviser or the Portfolio Managers (as applicable) will make a good faith determination that the transaction is in the best interests of the Private Fund. All such transactions will be approved by the Adviser’s compliance department. WC manages investments on behalf of a number of Clients. Certain Clients have investment programs that are similar to or overlap and may, therefore, participate with each other in investments. It is the policy of WC to allocate investment opportunities among all clients fairly, to the extent practical and in accordance with each Client’s applicable investment strategies. WC 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 Client solely because

WC purchases or sells the same security for, enters into a transaction on behalf of, or provides an opportunity to any Client if, in its reasonable opinion, such security, transaction or investment opportunity does not appear to be suitable, practical or desirable for the Client. WC allocates investment opportunities among the Clients based on relevant factors, determined in WC’s sole discretion, related to each Client, which may include but are not limited to:

Transaction sourcing; Each Client’s liquidity and reserves; Each Client’s diversification; Lender covenants and other limitations; Amount of capital available for investment by each Client as well as each Client’s projected future capacity for investment; Each Client’s targeted rate of return; Stage of development of the prospective investment; Anticipated holding period and/or liquidity of the investment; Composition of each Client’s portfolio; The availability of other suitable investments for each Client; Risk considerations; Cash flow considerations; Asset class restrictions; Industry and other allocation targets; Minimum and maximum investment size requirements; Tax implications; Legal, contractual or regulatory constraints; and Any other relevant limitations imposed by or conditions set forth in the applicable offering, investment advisory agreement and/or organizational documents of each Client.

WC will seek to make all allocations of investment opportunities in a fair and equitable manner, and will not favor or disfavor, consistently or consciously, any Client in relation to any other Clients. Further, WC will not allocate investment opportunities based, in whole or in part, on (i) the relative fee structure or amount of fees paid by any Client, (ii) the profitability of any Client or (iii) any person’s interest in offering or participating in co-investment opportunities outside of any Client. On occasion, Third-Party Managers may offer WC limited capacity to invest and allocate among Clients. In these cases, WC’s general policy and practice is to allocate limited investment opportunities fairly and equitably among Client accounts so as not to advantage any one Client over another over time. WC may employ various allocation methodologies to allocate investment opportunities among Clients including, but not limited to, pro rata by NAV of the participating Clients, pro rata by target quantity of the participating Clients as determined by WC, or in equal proportions among participating Clients in an effort to ensure fair and equitable allocations.

A. Factors Considered in Selecting or Recommending Broker-Dealers for Client Transactions Trading and Execution

WC has complete discretion in deciding which securities are bought and sold, the amount and price of those securities, the broker-dealers or counterparties to be used for a particular transaction, and commissions or markups and markdowns paid. Portfolio transactions for the Private Funds will be allocated to brokers on the basis of best execution and in consideration of relevant factors, including, but not limited to, price quotes; the size of the transaction; the nature of the market for the security; the timing of the transaction; the difficulty of execution; the broker or dealer's expertise in the relevant market or sector; the extent to which the broker or dealer makes a market in the security or has access to such market; the broker or dealer's skill in positioning the relevant market; the broker or dealer's facilities, reliability, promptness and financial stability; the broker or dealer's reputation for diligence and integrity (including in correcting errors); confidentiality considerations; the quality and usefulness of research products and services and investment ideas presented by the broker or dealer; and other factors deemed appropriate by WC. The commissions charged by brokers that we select may be higher or lower than those charged by other broker-dealers. The Private Funds may pay a commission to a broker that is higher than another qualified broker-dealer might charge to effect the same transaction when we determine, in good faith, that the commission is reasonable in relation to the value of the brokerage and research services that we receive. In seeking best execution for the Private Funds, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of the broker’s services. WC need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost or spread. Trade Errors Although WC exercises due care in making and implementing investment decisions, supervised persons may, from time to time, make errors with respect to trades made on behalf of Clients. WC has established order handling processes and procedures designed to reduce the likelihood of trade errors and, in its sole discretion, will determine what constitutes a trade error. Pursuant to the Fund Governing Documents, the Private Funds will be responsible for losses resulting from trade errors, except to the extent such losses result from WC’s bad faith, gross negligence, willful misconduct, fraud, criminal conduct or the material breach of the applicable investment management agreement. In all cases, gains from trade errors, if any, will be retained by the Private Funds, as applicable. Research and Soft Dollar Benefits Generally, the Adviser expects to use soft dollars, and engage Portfolio Managers whose use of soft dollars will be, within Section 28(e) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”). Section 28(e) establishes a safe harbor (the “Section 28(e) safe harbor” or “safe harbor”) allowing investment managers to use client funds, by way of commission dollars, to purchase certain “brokerage and research services.” WC may therefore pay higher commission prices for the purchase or sale of securities to receive research or other products or services other than execution from a broker-dealer and/or a third-party in connection with Client securities transactions. Research products and services provided by brokers through which portfolio transactions are executed, settled and cleared include research reports on particular industries and companies, economic surveys and analyses, recommendations as to specific securities, access to management and other products and services providing lawful and appropriate assistance to WC in the performance of its investment decision-making responsibilities. The Advisor, however, does not participate in any formal soft dollar arrangements, earn soft dollar credits or pay specific additional brokerage commissions for research or other types of soft dollar benefits. To the extent the receipt of research or brokerage by the Advisor or a Portfolio Manager are deemed to be soft dollar benefits, such benefits in connection with the trading of (i) securities, will fall within the safe harbor of

Section 28(e) of the Exchange Act, and (ii) futures or options on futures, will fall within the Section 28(e) safe harbor as if such benefits were being provided in connection with the trading of securities. The Adviser’s brokerage committee considers the amount and nature of research and research services provided by broker-dealers. Although the value of brokerage services cannot be readily determined, the Advisor or a Portfolio Manager determines in good faith that the amount of commissions charged by a broker is reasonable in relation to the value of the brokerage and research or investment management-related services provided by such broker. In addition, while commission rates charged by such brokers are generally deemed to not specifically reflect such additional benefits, the commission rates charged by such brokers may be higher or lower than other brokers. Also, consistent with Section 28(e), research products or services obtained with “soft dollars” generated by one or more Clients may be used by the Adviser to service one or more other Clients, including Clients that may not have paid for the soft dollar benefits. The Adviser does not seek to allocate soft dollar benefits to Client accounts in proportion to the soft dollar credits the Client accounts generate. Where a product or service obtained with soft dollars provides both research and non-research assistance to the Adviser (i.e., a “mixed use” item), the Adviser will make a good faith allocation of the cost which may be paid for with soft dollars. In making good faith allocations of costs between administrative benefits and research and brokerage services, a conflict of interest may exist by reason of the Adviser’s allocation of the costs of such benefits and services between those that primarily benefit the Adviser and those that primarily benefit the Clients. Client Referrals and Directed Brokerage From time to time, WC personnel may speak at conferences for potential investors interested in investing in hedge funds which are sponsored by broker-dealers that act as prime brokers and execution brokers to the Private Funds. These conferences may be a means by which WC can be introduced to potential investors in the Private Funds. Currently, neither WC nor the Private Funds compensate the brokers for organizing these “capital introduction” events or for investments ultimately made by prospective investors attending such events. WC does not believe that it pays any additional fees or higher commissions as a result of these introductions. However, WC may have an incentive to select or use a broker-dealer based on WC or an affiliate receiving Fund Investor referrals from that counterparty. As noted above, WC allocates portfolio transactions to brokers on the basis of best execution and does not generally consider whether we might receive Client referrals from such brokers. We do not recommend, request or require that a Client direct us to execute transactions through a specified broker-dealer. Order Aggregation At times, WC will execute transactions on an aggregated basis when a trade is executed at the same time in the same security across multiple Client accounts and aggregation is expected to be in the best interest of all participating Clients. When aggregating orders as well as allocating the executions, WC will treat all participating Clients in a fair and equitable manner taking into account all relevant factors, including, without limitation, each Client’s account size, diversification, cash availability, and investment objectives. In situations where orders among multiple Clients are not aggregated, WC will employ other methodologies to ensure fair and equitable treatment. WC also has procedures aimed to ensure that allocations do not involve a practice of appearing to favor or disadvantage any Client over another.

Neither WC nor any related person directly or indirectly compensates any person who is not a supervised person for Client referrals. However, WC currently uses the services of non-affiliated private placement agents to introduce potential Fund Investors to the Private Funds. From time to time, WC may enter into placement agent agreements with other third-party marketing firms, including third party consultants, solicitors, placement agents and others (“Solicitors”), whereby such Solicitors agree to solicit and refer prospective Clients or qualified investors. Any arrangements with Solicitors will be disclosed to the prospective Clients or investors involved prior to them becoming advisory Clients or admitting them as fund investors. Depending on the arrangement, the Solicitor may be compensated by a particular fund as permitted by the Fund Governing Documents, by the referred Client or investor, or by the Adviser (and/or its affiliate) by paying a portion of its management fees, performance-based compensation or otherwise.

On December 12, 2022, WC reached a settlement with the CFTC relating to charges brought in connection with a former trader. During December 2018 and May 2019, a trader who was at the time employed by WT entered orders in certain soybean complex futures contracts with the intent to cancel those orders before their execution—specifically, soybean futures, soybean meal futures, and soybean oil futures contracts traded on the Chicago Board of Trade. The trader’s conduct violated Section 4c(a)(5)(C) of the Commodity Exchange Act. WC was found to be derivatively (strictly) liable for the trader’s misconduct. In accepting WC’s settlement offer, the CFTC recognized the cooperation of WC with the Division of Enforcement’s investigation of the matter. The CFTC also acknowledged WC’s proposed remediation steps in connection with the matter. The CFTC press release and order related to this action can be found here: https://www.cftc.gov/PressRoom/PressReleases/8637-22

The OCIO is principally responsible for the ongoing review and risk management of WC strategies and portfolios. As set forth in the Fund Governing Documents, Fund Investors receive monthly account statements as well as an annual tax package including a Schedule K-1 and audited financial statements.

The Adviser and/or its affiliates have entered into agreements with qualified custodians to maintain custody of Client assets as required by Rule 206(4)-2 under the Advisers Act. While the Adviser does not maintain physical custody of any Client funds or securities, its affiliates will act as the manager of private investment funds advised by the Adviser, and, therefore, pursuant to the SEC’s custody rule (Rule 206(4)-2), the Adviser (through its affiliate) is deemed to have custody of such Client assets. Pursuant to the custody rule, audited financial statements will be delivered to each fund investor within 120 days of the end of each fiscal year. Clients should carefully review these statements. The Adviser is therefore exempt from certain other requirements of the SEC’s custody rule.

The Adviser provides discretionary advisory services to Private Funds. Under a discretionary advisory agreement, the Adviser has full power and authority to invest the assets of the Client on a discretionary basis and to act as the Client’s attorney-in-fact in furtherance of such advisory services. The Fund Governing Documents grant WC full discretionary authority to determine, without obtaining specific consent from it, the securities and the amounts to be bought or sold on behalf of a Client, to conduct the day-to-day investment operations of Clients, and to invest Clients’ assets as WC believes is appropriate and in the Client’s best interests. Clients do not have authority to impose restrictions on WC’s investment discretion.

To the extent the Adviser has been delegated proxy voting authority on behalf of its Clients, the Adviser will ensure that such proxies are voted in the best interests of the Clients. In WC’s overall judgment, the costs

associated with voting proxies usually outweighs the benefits to the relevant Clients; therefore, the Adviser will generally abstain from voting proxies. The Adviser’s Clients are not permitted to direct their votes in a particular solicitation. The Adviser’s Chief Compliance Officer will use his best judgment to address any such conflict of interest and ensure that it is resolved in accordance with his independent assessment of the best interests of the Client(s). A copy of WC’s proxy voting policies and procedures is available upon written request.

The Adviser 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.