Weiss Asset Management LP

Weiss Asset Management LP (“Weiss”), a Delaware limited partnership, was originally formed in June 2003 as Weiss Capital LLC, a Delaware limited liability company. In January 2010, Weiss changed its name and converted to a limited partnership. Weiss serves as the investment manager to two privately offered pooled investment vehicles (each a “Fund,” and together, the “Funds”). The Funds are operated with substantially similar investment strategies. Each of the Funds is exempt from registration as an investment company under the Investment Company Act of 1940, as amended (the “Investment Company Act”). Weiss may also serve as investment manager for additional funds or separate accounts in the future (together with the Funds, “Clients”). The investment strategy for each of the Funds is substantially similar, but each Fund was designed for different types of potential investors—specifically, the Fund that is a New York limited partnership (the “U.S. Fund”) was established primarily for U.S. taxable investors, while the Fund that is a Cayman Islands company (the “Cayman Fund”) is intended primarily for non-U.S. taxable investors. The overall objective of each Fund is to seek high risk-adjusted returns while attempting to control risk. Within that broad objective, the Funds are not limited by product, strategy or geographical region, and the Funds’ strategies employed, trades pursued and portfolios held from time to time are likely to vary along all of these dimensions as opportunities arise. Economic arbitrage trades are just some examples of a wide range of trading strategies that Weiss may employ on behalf of the Funds. The Funds have an intentionally broad investment mandate and Weiss expects to use a variety of strategies, financial instruments, assets and securities on their behalf. Weiss will often seek to identify mispriced assets—assets that are undervalued for purchase and overvalued assets for sale. Weiss believes that opportunities to invest in mispriced assets arise from market inefficiencies, or because of faulty analysis by market participants of the potential impact (positive or negative) that specific events or trends may have on the value of an asset. These assets might have the characteristics of derivatives; real estate interests; equity stakes of entities in liquidation; debt instruments that are expected to be highly covered by the value of underlying assets; securities that have assets or liabilities that Weiss believes are mispriced by the market; or other assets where Weiss believes the market price does not correctly reflect expected value. These opportunities may be coupled with short positions. For further details on the Funds’ investment strategies, please see Items 7 (“Types of Clients”) and 8 (“Methods of Analysis, Investment Strategies and Risk of Loss”) below. As the Manager of the General Partner of Weiss, Dr. Andrew M. Weiss has ultimate control over Weiss. The principal owners of Weiss, as set forth on Schedule A of Part 1A of Form ADV, are Andrew Weiss and WAM Employee LLC. Weiss is responsible for the management of each Fund’s portfolio pursuant to investment management agreements between Weiss and each Fund (each, an “Investment Management Agreement”). Weiss manages each Fund consistently with the investment strategies and objectives of that Fund, as set forth in the applicable offering documents of each Fund. Weiss manages the assets of the Funds on a discretionary basis. As of December 31, 2025, Weiss’ net assets under management were approximately $4,350,901,795.

In consideration for the investment management services that Weiss provides to the Funds, Weiss and its affiliates receive fees and other compensation from the Funds. This compensation generally takes the form of an asset-based management fee (the “Management Fee”) and/or performance-based compensation that is dependent on the investment performance of the portfolio under management for the relevant Fund (the “Performance-Based Compensation”), each paid to Weiss in accordance with its Investment Management Agreement with the relevant Fund. The Funds generally offer investors the opportunity to subscribe for two different types of shares (in the context of the Cayman Fund) or interests (in the context of the U.S. Fund). These two different types of investments that investors may make in the Funds are referred to as (1) “Funded Shares” or “Funded Interests,” and (2) “Commitment Shares” or “Commitment Interests,” as applicable. Funded Shares and Funded Interests are paid for by the investor up-front and participate in the gains and losses of the relevant Fund as of their subscription date. Commitment Shares and Commitment Interests, by contrast, are unfunded upon issuance and represent a commitment by the Investor to fund a certain amount (the “Conversion Amount,” as such term is defined in the applicable offering memorandum) at a later date, upon the receipt of notice from the applicable Fund. Investors that make aggregate subscriptions for Funded Shares and/or Funded Interests over a certain threshold specified in the respective offering memoranda of the Funds have the option to irrevocably elect for all of their Funded Shares and/or Funded Interests to be considered “Institutional Shares” or “Institutional Interests”, as applicable. With respect to Funded Shares and Funded Interests that are not Institutional Shares or Institutional Interests, a Management Fee is payable quarterly in arrears, in an amount generally equal to 0.125% (approximately 0.5% annualized) of the net asset value of (i) each series of shares in the context of the Cayman Fund, and (ii) each limited partner’s capital account in the context of the U.S. Fund, in each case as computed at the end of each quarter (before deducting the Performance-Based Compensation, as defined below), and is subject to modification for any particular investor as may be negotiated between the relevant Fund and the particular investor. No Management Fee is charged in respect of any Commitment Shares or Commitment Interests, or in respect of any Institutional Shares or Institutional Interests. Additionally, an investor in a Fund who subscribes for new Funded Interests or Funded Shares or converts Commitment Shares or Commitment Interests into Funded Shares or Funded Interests (by contributing the applicable Conversion Amounts) other than on the first day of a calendar quarter, or who withdraws from or redeems (as applicable) other than on the last day of a calendar quarter (and, in each case, who does not elect for such Funded Shares or Funded Interests to be considered Institutional Shares or Institutional Interests, as applicable) will be subject to a pro rata portion of the Management Fee paid for such quarter based upon the portion of the calendar quarter for which such Funded Shares or Funded Interests were outstanding in such Fund. The Management Fee is paid by the Funds to Weiss after the conclusion of each calendar quarter. In addition, Weiss or an affiliated entity receives Performance-Based Compensation from each Fund. Generally, at the end of each fiscal year (or other period when a calculation of performance compensation is required), each Fund will pay (or allocate) to Weiss or the U.S. Fund General Partner, as applicable, Performance-Based Compensation in an amount generally equal to 20% of the aggregate net profits during such fiscal year that (i) for the Cayman Fund are attributable to each series of Funded Shares and (ii) for the U.S. Fund are attributable to each capital account maintained for a limited partner in respect of any Funded Interests, subject in each case to a high watermark and as may otherwise be negotiated between the relevant Fund and any particular investor. No Performance-Based Compensation is paid or allocated, as applicable, in respect of any Commitment Shares or Commitment Interests. Net profits and net losses are calculated for a period by combining the aggregate net realized and unrealized changes in the value of each Fund’s assets with all other items of income and expenses of any kind for such period. In the event that any series of shares or any capital account of a limited partner has unrecovered net losses from any prior relevant accounting period, Weiss or the U.S. Fund General Partner, as the case may be, will not be paid or allocated Performance-Based

Compensation with respect to such series of shares or capital account until such net losses have been recovered (which net losses are proportionately reduced by any redemptions or withdrawals from such series of shares or capital account, respectively). In the event of a redemption or withdrawal by an investor in a Fund on any date other than the last day of a fiscal year, the Performance-Based Compensation in respect of the amount redeemed or withdrawn will be computed as of the date of such redemption or withdrawal. Unrealized appreciation and depreciation relating to investments segregated by a Fund as “Designated Investments” because they may be illiquid or difficult to value would generally not be allocated to a shareholder’s series of shares or a limited partner’s capital account, as applicable, for purposes of determining the Performance-Based Compensation until such Designated Investment is sold or the relevant Fund otherwise determines that it should no longer be treated as a Designated Investment. All fees and compensation are deducted from the relevant Fund’s assets and paid or allocated to Weiss or the relevant affiliate, as applicable. Weiss may, in its sole discretion, waive or reduce, in whole or in part, or otherwise negotiate a different Management Fee and/or Performance-Based Compensation with respect to any particular investor or group of investors. Further details regarding the calculation of Management Fees and Performance-Based Compensation are provided in each Fund’s respective offering documents. In addition to the Management Fees and Performance-Based Compensation described above, each Fund bears all costs and expenses related to its trading strategy and operations. Such costs and expenses borne by each Fund include, but are not limited to, brokerage and other transaction costs, clearing and settlement charges, costs of establishing subsidiary entities to help facilitate the making and settlement of certain trades, interest and commitment fees on debit balances or borrowings, borrowing charges on securities sold short, custody fees, the fees and expenses of professionals providing services to each Fund (e.g., legal, audit, accounting, valuation and appraisal, investment banking, due diligence, anti-money laundering, consulting, public relations, tax and administration), the costs of reporting and providing information to the investors of each Fund, filing fees, stamp duties, taxes, government and fiscal charges and foreign exchange costs. Each Fund also pays for applicable costs and expenses related to any litigation (including appraisal proceedings) or investigation arising out of the activities of such Fund and Weiss’ and/or its affiliates’ role in connection therewith. The Funds also bear their portion of all operational expenses and overhead incurred by Weiss and/or its affiliates except as specifically excluded in each Fund’s offering memorandum, unless Weiss, in its sole discretion, determines to not seek reimbursement for a particular expense. Operational expenses and overhead paid for by the Funds include, without limitation: the cost of office supplies, meals, data, communications infrastructure, computers, software, servers (including backup servers) and other information technology expenses; utilities and operating expenses of offices of Weiss and/or its affiliates; travel expenses and other fees and expenses incurred researching, investigating, and monitoring potential and existing investments of the Funds, including research publications and providers, expert fees and expenses, investment banking fees and expenses, costs, fees and expenses relating to attending and/or presenting at conferences, symposiums, meetings or similar gatherings; expenses incurred by Weiss and/or its affiliates in connection with marketing the Funds to prospective investors (except that Institutional Shares and Institutional Interests do not bear any such expenses); legal advice and expenses, compliance fees and expenses relating to the Funds and Weiss complying with applicable regulations, preparing and making regulatory filings, communicating with regulators in various jurisdictions, preparing for and responding to regulators in connection with examinations, investigations and inquiries, consultants (including without limitation, investment, operational, valuation, compliance and public relations consultants) and outside advisers relating to Weiss’ business and operations in addition to those of the Funds; expenses related to rent and furnishings for Weiss’ and its affiliates’ offices; and fees and expenses for directors of the Cayman Fund, including registration costs and directors’ and officers’ liability insurance. The Funds do not pay any compensation to Andrew Weiss (the “Principal”), other than that received through his participation in the

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The objective of each Fund is to seek high risk-adjusted returns while attempting to control risk. Weiss’ overall goal for the Funds is that trades should increase the risk-adjusted expected return to investors. Within that broad objective, the Funds are not limited by product, strategy or geographical region, and the Funds’ strategies employed, trades pursued, and portfolios held from time to time are likely to vary along all of these dimensions as opportunities arise. The Funds have intentionally broad investment mandates and Weiss expects to use a variety of strategies, financial instruments, assets and securities. Weiss will often seek to identify assets that are undervalued for purchase and overvalued assets for sale. Weiss believes that opportunities to invest in mispriced assets arise from market inefficiencies, or because of faulty analysis by market participants of the potential impact (positive or negative) that specific events or trends may have on the value of an asset. These assets might have the characteristics of derivatives; directly trading real estate interests; trading equity stakes of entities in liquidation; trading debt instruments that are expected to be highly covered by the value of underlying assets; trading in securities that have assets or liabilities that Weiss believes are mispriced by the market; or trades in any other assets where Weiss believes the market price does not correctly reflect expected value. These opportunities may be coupled with short positions. Weiss expects to be opportunistic in its trading strategies on behalf of the Funds. The Funds may trade assets in countries that are receiving unfavorable media coverage, that are in the midst of political changes or that are otherwise perceived as exceptionally risky. The Funds may also trade assets whose market value is expected to be meaningfully affected by future events including a debt repayment obligation; a management transition; changes, implementation or enforcement of legislation or regulations; market recognition of mispriced assets or liabilities; lawsuits; or a bankruptcy or financial restrictions. The Funds may utilize certain trading techniques that can, in certain circumstances, substantially increase the adverse impact to which the Funds may be subject. In addition, securities that Weiss believes are fundamentally undervalued or incorrectly valued may not ultimately be valued in the capital markets at prices and/or within the time frame that Weiss anticipates. Securities in which the Funds invest may also be subject to risks of fraud or other loss that Weiss does not anticipate. Material Risks Investors must recognize that investing in securities involves risk of loss that investors should be prepared to bear. The following describes certain risks involved with the trading strategies and the methods of analysis that Weiss considers to be material for each Fund. Investors and prospective investors in any Fund should carefully read the respective offering documents for the relevant Fund for a more detailed discussion of risks involved with investing in that Fund. Legal and Regulatory Environment for Private Investment Funds and their Managers. The legal and regulatory environment worldwide for private investment funds (such as the Funds) and their managers is constantly evolving. Changes in the regulation of private investment funds, their managers, and their trading and investing activities may have a material adverse effect on the ability of the Funds to pursue their investment programs and the value of investments held by the Funds. New laws and regulations or actions taken by regulators that restrict the ability of the Funds to pursue their investment programs or employ brokers and other counterparties could have a material adverse effect on the Funds and investments therein. In addition, Weiss may, in its sole discretion, cause the Funds to be subject to certain laws and regulations if it believes

that an investment or business activity is in the particular Fund’s interest, even if such laws and regulations may have a detrimental effect on one or more investors. Alternative Investment Fund Managers Directive. The AIFM Directive regulates: (i) alternative investment fund managers (each, an “AIFM”) based in the European Economic Area (the “EEA”) or the United Kingdom; (ii) the management of any alternative investment fund (“AIF”) established in the EEA or the United Kingdom (irrespective of where an AIF’s AIFM is based); and (iii) the marketing of any AIF, such as the Funds, to professional investors in the EEA or the United Kingdom. Under the AIFM Directive, certain conditions must be met to permit the marketing of the Funds to any potential and existing investors in the EEA or the United Kingdom. The ability of the Funds or Weiss to offer the investments in the Funds in the EEA or the United Kingdom will depend on the relevant state permitting the marketing of non-EEA or United Kingdom domiciled funds under the national private placement regimes implementing the AIFM Directive and the ability of the Funds and Weiss to comply with such national private placement regimes, where available. Compliance with the requirements of such regimes may increase the costs of the administration of the Funds significantly, including the costs of regulatory reporting and custody and prime brokerage services provided to the Funds. As such, the Funds’ ability to market the shares to EEA or United Kingdom investors may be limited. Financial System Systemic Risk. Systemic risk is the risk of broad financial system stress or collapse triggered by the default of one or more financial institutions, which results in a series of defaults by other interdependent financial institutions. Financial intermediaries, such as clearing houses, banks, securities firms and exchanges with which the Funds interact, as well as the Funds, are all subject to systemic risk. A systemic failure could have material adverse consequences on the Funds and on the markets for the securities in which the Funds seek to invest. Investment and Trading Risks. An investment in a Fund involves a high degree of risk, including the risk that the entire amount invested may be lost. The Funds trade in securities and other financial instruments using strategies and trading techniques with significant risk characteristics. No guarantee or representation is made that Weiss’ trading strategy will be successful. A Fund’s trading strategy may utilize such trading techniques as option transactions, margin transactions, short sales, forwards, leverage, and other derivatives trading; such techniques can, in certain circumstances, substantially increase the adverse impact to which a Fund may be subject. The past performance of a Fund’s trading strategy is not necessarily indicative of its future results. In addition, securities, instruments and other assets which Weiss believes are fundamentally mispriced may not ultimately be valued in the capital markets at prices and/or within the time frame that Weiss anticipates. Securities and other instruments in which the Clients invest may also be subject to risks of fraud or other loss that Weiss does not anticipate. As a result, each Client may lose all or substantially all of its investment in any particular instance. Weiss provides investment management services to each Fund but not to investors in the Funds individually. As a result, each investment made by a Fund may or may not be appropriate for a particular investor in a Fund. For example, in choosing among investments for the U.S. Fund, Weiss will often take into account the tax attributes from the point of view of a U.S. taxable investor; Weiss may also take into account how the timing of a disposition would affect the taxes payable by a U.S. taxable investor. Investors in the U.S. Fund likely have differing tax status, brackets, income and losses outside of the U.S. Fund, and therefore investment decisions will likely not optimize tax outcomes equally for all investors. External Funds. Weiss may determine from time to time that it could benefit from external expertise or sourcing capabilities, including when the Funds are entering a new market or market segment. In such cases, the Funds have

invested, and expect in the future to invest, through structures such as funds, entities or other types of commingled pools or joint ventures in which an unaffiliated third party with expertise in the particular strategy, market, jurisdiction, type of security, investment structure or other instrument, currency or sector advises or effectively manages a portion of a Fund’s assets dedicated to a particular investment or group of investments (“External Funds”). Investments in External Funds expose the Funds to numerous risks. The success of investments in External Funds depends, in part, on the ability of Weiss to select an appropriate third party with expertise and adequately conduct due diligence and analyze the External Fund and its manager. Weiss may not have any ability to negotiate the economic terms of the investment, adequately supervise the External Fund’s investments or exercise influence over the investment decision-making process. The expenses charged to a Fund as an investor in an External Fund and the fees payable to the manager and its affiliates of such External Fund (whether structured as management fees, incentive-based fees, allocation of profits, brokerage fees or otherwise) will reduce the returns of the relevant Fund with respect to such investments and will generally not be offset against fees payable by such Fund to Weiss. Weiss may have limited, if any, rights to withdraw, transfer or otherwise liquidate its investment in an External Fund. Each Fund generally expects to rely on the estimated valuations of such Fund’s investments in External Funds provided by the External Fund. There may be significant delays in a Fund’s receipt of such valuations, audited financial statements and tax information (see Risk Factors – Investment and Trading Risks above). General Economic and Market Conditions; Volatility. The success of the Clients’ activities will be affected by levels and changes in general economic and market conditions, such as interest rates, availability of credit, credit defaults, inflation rates, economic uncertainty, changes in laws (including securities laws and laws relating to taxation of the Clients’ investments), accounting standards, trade barriers, currency exchange controls and national and international political circumstances (including wars, terrorist acts or security operations). These factors may affect, among other things, the level and volatility of securities’ prices, the liquidity of the Clients’ investments and the availability of certain securities and investments, and may make investing in certain types of securities, including securities in which the Client may wish to invest, less profitable. Volatility or illiquidity could also impair the Clients’ profitability or result in losses. The Clients may maintain substantial trading positions that can be materially adversely affected by the level of volatility in the financial markets—the larger the positions, the greater the potential for loss. While volatility can create profit opportunities for the Clients, it also can create the specific risk that historical or theoretical pricing relationships will be disrupted, causing what should otherwise be comparatively low risk positions to incur losses. Inflation. Inflation and rapid fluctuations in inflation rates have had in the past, and may in the future have, negative effects on economies and financial markets. In an attempt to stabilize inflation, countries may impose wage and price controls or otherwise intervene in the economy. Governmental efforts to curb inflation often have negative effects on the level of economic activity. As such, inflation and rapid fluctuations in inflation rates can adversely affect the financial performance of the Funds. There can be no assurance that continued and more wide-spread inflation will not become a serious problem in the future and have an adverse impact on the performance of the Funds and their respective investments. Foreign and Emerging Market Securities. The Funds’ trading of securities and instruments in global markets involves substantial risks not typically associated with trading in U.S. securities. Trading in such foreign securities may be affected by changes in currency rates or exchange control regulations, changes in governmental administration or economic or monetary policy (in the U.S. and abroad) or changed circumstances in dealings between nations. To the extent not effectively hedged, changes in foreign currency exchange rates relative to the U.S. dollar may affect the

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As noted in Item 4, Weiss is an investment adviser to two pooled investment vehicles, the Funds, which are privately offered open-end hedge funds. The Funds are exempt from registration as investment companies under the Investment Company Act and are not publicly offered in any jurisdiction. At the time an investor makes an investment, each investor in the U.S. Fund and each U.S. investor in the Cayman Fund, must be (i) both an “accredited investor,” as defined in Regulation D under the Securities Act of 1933, as amended (the “Securities Act”) and a “qualified purchaser,” as that term is defined in Section 2(a)(51) of the Investment Company Act, or (ii) a “knowledgeable employee” as that term is defined in Rule 3c-5 of the Investment Company Act. Prior to April 1, 2019, the Funds relied on the exclusion from the definition of investment company in Section 3(c)(1) under the Investment Company Act; since that date, the Funds have instead relied on the exclusion in Section 3(c)(7). The U.S. Fund does not impose a minimum capital commitment for any investor. The minimum initial investment in the Cayman Fund is $50,000, or such other minimum amount as specified from time to time by the relevant authorities in the Cayman Islands. Weiss may serve as investment manager for additional funds, special purpose vehicles or separate accounts in the future (“Other Accounts”).

In the future, Weiss may have other clients that have different compensation structures than the Funds, leading to conflicts of interest. As disclosed in further detail in Item 5 (“Fees and Compensation”) above, Weiss and/or its affiliates are eligible to receive Performance-Based Compensation from the Funds. Other clients in the future may not pay any incentive-based compensation. As a result, Weiss may face certain conflicts of interest and in some circumstances has a financial incentive to favor incentive-paying accounts over those accounts that do not pay incentive compensation. Weiss seeks, however, to treat all of its funds and accounts fairly and equitably under the circumstances in all cases. Weiss seeks to resolve and control conflicts of interest through its policies and procedures. For example, in the first instance, Weiss seeks to typically allocate trades among the Funds pro rata based on an objective formula, generally subject to minimum lot sizes. Generally speaking, this formula is a function of the relative asset value of each of the Funds. By having a formula applicable on a strategy-wide basis, the conflict associated with any particular single investment is diminished. With respect to a specific security or transaction, however, Weiss may make an allocation in a different manner, but only if Weiss determines in its discretion that a different allocation structure would be more appropriate or if the foregoing formula would provide an unfair result. Adjustments may also be required when a formula would result in an allocation to one or more Clients of fractional shares, odd lots, less than a minimum trading size, or a position that is not economically meaningful given transaction or other costs. In such cases, a predetermined rotational system (i.e., a system by which Clients take turns as to which one will transact first for a particular transaction) or some other objective system designed to be fair to all applicable Clients may be used. The Compliance team at Weiss regularly monitors the allocation of trades among the Clients to enforce Weiss’ policy of not improperly favoring one Client over another.

Weiss, its affiliates, employees, and the Principal may engage in other activities, including providing investment management and advisory services to other accounts and investing directly, and are not required to refrain from any activity, to disgorge profits from any such activity or to devote all or any particular amount of time or effort of any of its officers, directors or employees to the Funds and their affairs. The U.S. Fund General Partner, which is an affiliate of Weiss, serves as the general partner of the U.S. Fund. Each of Fundamental Research Associates Inc. and Plover Cove Management Limited, affiliates of Weiss, do not directly advise any Clients of Weiss but provide research and ancillary services to Weiss in furtherance of Weiss’ management of client investments. Plover Cove Management Limited is also registered with the Securities and Futures Commission in Hong Kong to provide trade execution and asset management services to Weiss. Notwithstanding the fact that the Funds have substantially similar trading strategies, they have experienced, and are expected to continue to experience, different performance results from one another, which have been and may continue to be material. Such performance differences typically arise from particular investments that only one of the Funds is able to make for regulatory or other reasons, different proportions of available capital for new investments in each Fund from time to time, or due to tax rules that affect one Fund and not the other. Weiss currently serves as the investment manager to the Funds. As noted in Item 8, each of the Funds has a trading strategy substantially similar to that of the other. Weiss may also serve as investment manager for Other Accounts in the future. Such Other Accounts may pursue substantially similar strategies to the Funds. When it is determined by Weiss that it would be appropriate for the Funds and one or more such Other Accounts to participate in an investment opportunity, Weiss will seek to execute orders for all of the participating investment accounts, including the Funds, on an equitable basis under the circumstances, taking into account such factors as the relative assets, relative amounts of capital available for new investments, relative exposure to the particular type of assets in question and the investment programs and portfolio positions of the funds and the affiliated entities for which participation is appropriate. Weiss and its affiliates may give advice and recommend investments to Other Accounts which may differ from advice given to, or investments recommended or bought for, the Funds, even though their investment objectives may be the same or similar. Some issuers in which Clients may wish to invest may limit the percentage of outstanding shares that any one stockholder or group of stockholders, directly or indirectly, can own or exercise certain rights in corporate actions. Depending on the provisions applicable to the particular issuer, the Funds and Other Accounts may be considered part of a “group” with other entities managed by Weiss. In such cases, a Client may be forced to limit its investment in an issuer to a level below what it might otherwise wish to invest. Moreover, if one of such Clients already has a pre-existing investment in such issuer and the limit on ownership or corporate action rights has already been reached by the investment of such Client, a different Client in the “group” (including one of the Funds) may be precluded from investing in that issuer altogether. Weiss or its affiliates may provide investment management services to other collective investment vehicles (including closed-end funds) in which a Fund may invest; provided, however, that a Fund shall not be subject to additional layers of management and/or performance-based fees payable to Weiss or its affiliates with respect to such other collective investment vehicles. The officers, directors, partners and employees of Weiss and its affiliates may trade in securities for their own accounts, subject to restrictions and reporting requirements as may be required by law or otherwise determined from time to time by Weiss. A Client may engage in certain transactions with its affiliates provided the terms thereof are commercially reasonable, as determined by Weiss. Weiss has certain responsibilities with respect to valuing securities. A conflict may arise with respect to this responsibility given different Performance-Based Compensation and/or Management Fees to be earned by Weiss and/or the relevant affiliated general partner, as applicable, from the various Clients. Individual

representatives of Weiss and its affiliates serve, from time to time, on the board of directors of one or more entities which securities the Clients trade. In their capacity as board members, such individuals may become subject to fiduciary, reporting or other duties which may adversely affect the Clients.

Weiss has adopted a written code of ethics (the “Code”) pursuant to Rule 204A-1 under the Advisers Act. The Code sets out basic principles to guide the officers, partners and employees of Weiss in discharging their duties for Weiss. The Code has been adopted with the objectives of deterring wrongdoing and promoting, among other things: (1) honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships, (2) full, fair, accurate, timely and understandable disclosure in all public communications made by Weiss, (3) compliance with applicable laws, rules and regulations, (4) prompt internal reporting of violations of the Code, and (5) accountability for adherence to the Code. The Code includes policies and procedures related to personal securities transactions by officers and employees considered to be “access persons.” The Code requires access persons to obtain prior authorization from the Chief Compliance Officer of Weiss (or his designee) in order to buy or sell certain securities for their own account. The Code also requires access persons to provide periodic reports regarding transactions and holdings in all reportable securities. Access persons are required to submit quarterly reports regarding securities transactions and newly opened accounts, as well as annual reports regarding holdings and existing accounts. The partners, officers and employees of Weiss or its affiliates and their household members may invest in securities for their own accounts, or the accounts of foundations or trusts for which they are fiduciaries, subject to restrictions and reporting requirements as may be required by law or otherwise determined by the Code. Additionally, individual representatives of Weiss and its affiliates serve, from time to time, on the board of directors of one or more entities in which a Fund invests, subject to restrictions and reporting requirements as may be required by law or otherwise determined by the Code. Weiss will provide a copy of the Code to any client or prospective client upon request. Weiss and its employees may invest in the Funds, and in securities or other assets in which the Funds may invest, subject to applicable law, the Code, and to applicable investor eligibility requirements of each Fund. Weiss and its affiliates may cause a security to be traded between one of the funds or accounts and any of the other funds or accounts it (or any of its affiliates) manages (a “cross transaction”) where it believes such trade to be in the interest of each fund or account and otherwise in compliance with applicable laws and any contractual restrictions with particular Clients. Weiss’ and/or its affiliates’ duty to be fair to the Clients on both sides of a cross transaction may pose inherent conflict of interests. Weiss will seek to be fair and equitable to each Client in a cross transaction in determining the appropriateness of the transaction for each Client, and will determine market prices based on market quotations. A Fund may also engage in certain other transactions with affiliates of Weiss and/or the funds or accounts they manage, provided the terms thereof are commercially reasonable, as determined by Weiss and otherwise in compliance with applicable laws and any contractual restrictions with particular Clients.

Weiss is responsible for selecting broker-dealers to execute trades and negotiating any commissions paid on such transactions. Weiss’ primary consideration in placing transactions with particular broker-dealers is to obtain execution in the most effective manner possible, which generally includes factors of quantity purchased/sold and net execution price. Weiss will also take into account a variety of factors, including the availability and supply of buyers or sellers sourced by a broker-dealer, the commissions charged by the broker-dealer, the ability to enforce requested risk controls, and the perceived financial strength, integrity and stability of the broker-dealer. Weiss will also consider the quality, comprehensiveness and frequency of available research, ability of a broker-dealer to source certain hard-to-find securities or provide access to certain markets, public or private transactions, and other products and services considered to be of value. The products and services furnished by broker-dealers may include, among other things, written information and analyses concerning specific securities, companies or sectors; investment ideas; market, financial and economic studies and forecasts; statistics and pricing or appraisal services; discussions with research personnel; and special execution capabilities. Weiss is authorized to pay higher prices for the purchase of securities from, or accept lower prices for the sale of securities to, brokerage firms that provide it with such research products and execution services or to pay higher commissions to such firms if Weiss determines such prices or commissions are reasonable in relation to the overall services provided. Accordingly, a portion of expenses for research related products and services will sometimes be paid with “soft dollars” generated through Clients’ investment activities. However, Weiss has committed to the Funds that it will not use “soft dollars” generated by the Funds to pay for any type of product or service that the Funds would not otherwise pay for directly as a fund expense in accordance with the Funds’ governing documents. Weiss will also use soft dollars only if it believes it is in the best interest of its Clients. It is anticipated that any use of commissions or “soft dollars” to pay for research products or services will fall within the safe harbor created by Section 28(e) of the Exchange Act. While Weiss has committed to not use “soft dollars” generated by the Funds to pay for any type of product or service that the Funds would not otherwise pay for directly as fund expenses, and Weiss has further committed to use soft dollars only when Weiss believes such use is in the best interests of the Clients, the use of brokerage commissions to obtain research services can nonetheless create a conflict of interest between Weiss and the Funds. The use of “soft dollars” may result in Clients paying higher brokerage commissions than might be paid if transactions were effected through brokers that do not provide such services. To the extent that Weiss is able to acquire certain products and services at reduced prices or without spending money from each Client directly, Weiss’ use of “soft-dollars” may prevent Clients and investors in the Funds from seeing a complete picture of the composition of expenses. Moreover, while all Clients are eligible to benefit from products and services obtained with “soft dollars,” not all products and services obtained with “soft dollars” may benefit all Clients equally or in proportion to the “soft dollars” generated by each Client. Any new arrangements with broker-dealers regarding third-party “soft dollar” payments must be approved in advance by the Chief Compliance Officer. For example, and without limitation, Weiss currently receives a discount on certain electronic news and research services in recognition of brokerage commissions paid to an electronic broker affiliated with the news and research provider. This discount is deducted by the provider and thus passed along to the Clients in accordance with the Clients’ expense policies. In addition, from time to time, brokers may call Weiss with research regarding potential investment opportunities that the broker believes fit within the strategies of the Funds. If Weiss determines to pursue any such investment opportunity on behalf of a Client, Weiss may use the broker that brought the idea to Weiss to execute trades relating to that opportunity, and Weiss

may pay higher commissions to that broker for trades in those or other securities in recognition of the research provided. Any soft-dollar arrangement involving above-market commissions must be approved by a senior portfolio manager at Weiss. From time to time, Weiss may receive other research and/or execution services in accordance with Section 28(e). From time to time, representatives of Weiss may speak at conferences and programs for investors interested in investing in hedge funds or other investment opportunities that are sponsored by prime brokers and other brokers. These conferences and programs may provide opportunities by which Weiss is introduced to potential investors in the Funds or other investment vehicles it manages. The prime brokers are not generally compensated by Weiss, the Funds, or potential investors for providing such “capital introduction” opportunities. Prime brokers and other brokers may also provide financing and other services to the Funds and Weiss. Such additional services by a prime broker or other broker, including capital introduction services, may present a potential conflict of interest to Weiss in deciding whether to use the services of such prime broker or other broker in connection with the activities of the Funds. Weiss seeks to mitigate this conflict by adopting procedures to review best execution of trades, by having separate personnel responsible for trading and investor relations, and giving the traders and related personnel authority to decide which prime broker or other broker should be utilized for a particular service. In addition, at least annually Weiss holistically reviews the utilization of brokers, including the quality of execution based on the factors described above (including the availability and supply of buyers or sellers sourced by a broker-dealer, the commissions charged by the broker-dealer, the ability to enforce requested risk controls etc.) to confirm selection of brokers is consistent with Weiss objective of seeking best execution for its Clients. A Fund is not prohibited from engaging as a service provider any entity in which it, Weiss and their affiliates, employees and the Principal have an interest. Any transaction for which payment is not specified in the governing documents of the Fund is subject to the requirement that compensation therefore will be for fair value and for compensation no higher than would be charged by an unrelated third party for such services. However, conflicts of interest would arise if such entity failed to perform adequately its undertakings to a Fund. Weiss will seek to allocate securities transactions in a manner that is fair to each Client in light of each Client’s investment strategy, size, diversification, cash availability, tax or regulatory impact, and any other relevant factors. When the purchase or sale of a security is considered to be in the best interest of more than one of the Clients (which is typically the case), the securities to be purchased or sold may be aggregated in order to obtain superior execution and/or lower brokerage expenses. Furthermore, if Weiss or an affiliate manages other accounts or funds, such aggregation may also occur when the purchase or sale of a security is considered to be in the best interest of more than one fund or account (including a Client). Execution prices for identical securities purchased or sold on behalf of multiple accounts in any one business day are typically averaged. In such instance, allocation of prices, as well as expenses incurred in the transaction, shall be made in a manner Weiss considers to be fair and equitable to each participating Client.

No person that is not an investor in the Funds provides Weiss with an economic benefit for providing investment advice or other advisory services to the Funds. Neither Weiss nor any related person compensates any person for client referrals. However, the Funds and Weiss may enter into agreements with one or more third parties providing for, among other things, (i) payments to such third parties of a fully disclosed sales charge, which may be paid from the investments of certain investors that agree thereto, or (ii) payments by Weiss to one or more of such third parties of a one-time or ongoing fee based upon the capital contributions of certain investors.

In 2021, Weiss identified that it had inadvertently violated Rule 105 of Regulation M under the Securities and Exchange Act of 1934 in connection with several public offerings. Weiss promptly took remedial actions to prevent future violations of Rule 105 and voluntarily self-reported the violations to the SEC. Rule 105 generally prohibits purchasing an equity security from an underwriter, broker or dealer participating in a public offering if the purchaser sold short the security that is the subject of the offering during a restricted period (usually defined as five business days before the pricing of the offering), absent an exception. Rule 105 is a strict liability rule and thus applies irrespective of any intent to violate the Rule. On June 14, 2022, Weiss agreed to a settlement with the SEC of the self-reported inadvertent violations. Pursuant to the settlement, Weiss agreed to cease and desist from committing or causing any violations of Rule 105, disgorgement of profits on the relevant trades of $6,508,792.81, prejudgment interest of $190,210.84 and a civil money penalty of $200,000. The SEC order specifically notes that in determining the settlement, the SEC considered the remedial acts promptly undertaken by Weiss and the cooperation afforded the SEC staff.

Weiss provides continuous advisory services for the Funds. The Investment Committee and risk team review and monitor the portfolios and aggregate portfolio risk exposures of the Funds on a regular basis. Such review generally involves an examination of the current market value of portfolio investments, developments in portfolio companies, scenario-based and stress-test risk reporting, general market conditions, recent transactions and other factors affecting investment decisions with respect to the portfolio. The risk team produces portfolio and strategy-level risk reporting on a regular basis to review risks to which the Funds are exposed. The Investment Committee and risk team also review the liquidity requirements of the Funds and are informed of margin requirements at the various counterparties. The Compliance team regularly reviews positions and transactions for compliance with regulatory requirements. Weiss’ settlements group works to ensure that each trade is reconciled with the appropriate broker-dealer on a timely basis, and communicates with the Funds’ third-party administrator, who independently maintains the official records for the Funds and reconciles positions and activity. The settlements staff monitors and communicates with brokers and the administrators to detect trade breaks, improper allocations, or other potential trade errors. Investors in each Fund receive month-end unaudited statements of performance and net asset value from the Fund’s independent third-party administrator. Audited financial statements of each Fund are prepared and delivered to such Fund’s investors annually.

Weiss is deemed to have custody of the assets of the U.S. Fund because of the authority that the General Partner (which is an affiliate of Weiss) has over those assets. Weiss is also deemed to have custody over the Cayman Fund’s assets because Weiss has the authority to automatically deduct funds from the Cayman Fund to pay its fees in accordance with the relevant investment management agreement of the Cayman Fund. To satisfy the SEC’s custody rule requirements, the Funds provide each investor in the Funds with audited financial statements within 120 days of the end of each year.

Weiss has discretionary authority to manage the assets of each Fund. This discretionary authority is conferred on Weiss pursuant to an Investment Management Agreement between Weiss and each of the Funds. For each Fund, the applicable Investment Management Agreement provides that Weiss has complete discretion regarding the investment of the Fund’s assets in accordance with the investment objectives, policies and parameters set forth in the applicable agreement.

Weiss has authority to vote proxies on behalf of the Funds. Absent specific Fund instructions, Weiss has adopted proxy voting procedures designed to ensure that proxies are properly identified and voted and that any conflicts of interest are addressed appropriately. Weiss will generally seek to exercise its proxy voting authority in a way that seeks to maximize the value of the Funds’ assets. Weiss evaluates proxies to determine whether the vote is material in relation to the value of the investment, whether it has beneficial value to the Funds to vote, and if so, whether it requires special attention or handling. In connection with any vote that is material, Weiss’ operations staff consults with Weiss’ investment management staff for instructions on how to vote the upcoming proxy. In connection with any vote that either (i) Weiss determines is not material, or (ii) Weiss determines that it may have a material conflict of interest, then Weiss may choose to outsource the proxy voting decision to an outside proxy voting service or consultant. If Weiss does not outsource a proxy voting decision and Weiss identifies a material conflict of interest, Weiss’ Compliance Committee will review the relevant votes to monitor whether the votes are consistent with Weiss’ proxy voting procedures, including whether the votes are made in a manner that seeks to maximize the value of the applicable Fund’s assets. A client may obtain a copy of Weiss’ proxy voting policy, as well as information regarding how Weiss voted proxies on behalf the client, by sending a request to Weiss’ Investor Relations staff at info@weissasset.com or calling (617) 778-7780.

Weiss does not require or solicit prepayment of any fees six months or more in advance, is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to its clients, and has not been the subject of a bankruptcy petition at any time.