WestRiver Management, LLC

WestRiver Management, LLC is an investment advisory firm organized as a Delaware limited liability company. The Firm has been providing investment advisory services since 2002 and is principally owned by Erik J. Anderson. The Firm conducts its advisory business through affiliated entities. Specifically, Loan Manager, LLC, , VSF Manager, LLC, , WRG HCD2 GP, LLC, WRG HCD3 GP, LLC, WRG HCD4 GP, LLC, WRG TD1 GP, LLC, WRG EFI Manager, LLC, WRG Tech Fund II GP, LLC, WRG IEF GP, LLC, WRG Equity Manager, LLC and WRG EIC II Manager, LLC, (together, the “Firm,” “WestRiver,” “we,” “us,” or “our”) and various other entities serve as general partners of or advisers to private investment funds. Advisory Services The Firm provides discretionary and non-discretionary investment management services to affiliated private funds (each a “Fund” or “Funds”), as well as charitable organizations, endowments, and unaffiliated investment managers (together with “Funds”, collectively referred as “Clients”). The Firm’s services to the Clients consist of (i) investigating, identifying and evaluating investment opportunities; (ii) structuring, negotiating and making investments on behalf of the Clients; (iii) managing and monitoring the performance of such investments; and (iv) exiting such investments on behalf of the Clients. The Firm’s services to each Client are subject to the specific investment objectives and restrictions applicable to such Client, as set forth in such Client’s operating agreement and other governing documents (collectively, the “Governing Documents”).

The Funds with nondiscretionary assets have an investment committee consisting of representatives of the investors in the Fund, and sometimes a representative of the Firm. All decisions concerning approval of new investments, allocations of capital to specific investments, and dispositions of investment securities must be approved by majority vote of the investment committee. As a result, the Firm does not exercise investment discretions and does not have final approval, with respect to the selection of Fund investments, and does not determine the amount of each Fund(s) capital committed to each investment. Funds with discretionary assets (the “Equity Platform”) have an investment committee consisting of Firm representatives. Decisions concerning approval of new investments, allocations of capital to specific investments, and dispositions of investment securities must be approved by majority vote of the investment committee. In addition, the Firm’s Advisory Committee, comprised of representatives of the investors in the Equity Platform funds, will have the ability to review and advise on materials presented to it related to certain decisions. WestRiver’s institutional Clients (charitable organizations, endowments, and unaffiliated investment managers) retain investment authority. The Firm’s services consist of conducting due diligence and sourcing and recommending potential new investments to the respective investment committees of each client. Each client makes investment decisions based on the Firm’s recommendations, but WestRiver is not responsible for the management of, and does not exercise discretion with respect to, the assets of such clients. Tailored Services Investors and prospective investors in each Fund should refer to the Governing Documents of that Fund for information on the investment objectives and investment restrictions with respect to that Fund. There can be no assurance that any of the Funds’ investment objectives will be achieved, and the Firm’s services are generally not tailored to the individualized needs of any particular investor of the Fund. Since WestRiver does not provide individualized advice to investors (and an investment in the Fund does not, in and of itself, create an advisory relationship between the investor and the Firm), investors must consider whether a particular Fund meets their investment objectives and risk tolerance prior to investing. With respect to separate investment mandates and nondiscretionary Funds, the investment committee of each such Client exercises final approval over the selection of investments and determines the amount of capital committed to each investment. Wrap Fee Programs We do not provide portfolio management services to wrap fee programs. Management of Client Assets As of December 31, 2025, the following assets are under the Firm's supervision: Discretionary Basis

$ 95,216,678

Non-Discretionary Basis

$ 349,160,440

Total: Assets Under Management (or “RAUM”, $ 444,377,118 as defined for purposes of Form ADV)

Management Fees

Pursuant to the operating agreements of all our Fund(s), we offer investment advisory services and are compensated through management fees as described below: Fixed Fee We charge fixed investment management fees that are generally based on either a budget agreed to by the investment committee of the applicable Client, or a percentage of the capital invested in the Fund by our investors. The fixed investment management fees are payable quarterly in advance. If the investment management agreement between the Firm and the client is terminated, the client will be responsible for paying a pro-rated fee for the quarter in which the account was terminated. If an agreement with a client that pays fees in advance is terminated, the Firm is not required to refund any portion of any prepaid fee. Performance-Based Fees (Carried Interest Distributions) The Firm and its affiliates act as the managing member of each of the Fund(s). We are entitled to receive carried interest distributions from each Fund in accordance with the terms of the Fund's operating agreement. Typically, the carried interest is structured as a right to receive a specified percentage of any additional distributions after the Fund's investors have received back their capital contributions plus a preferred return. In some contexts, after the investors have received their capital contributions and preferred return, we may be entitled to catch-up distributions commensurate with the preferred return paid to our investors. Following the catch-up (if applicable), any additional distributions are split between the investors, on the one hand, and the Firm, on the other hand, in accordance with the carried interest percentage as specified in each Fund(s) operating agreement. Alternative Fee Arrangements The Firm may, at our discretion, be willing to consider and negotiate fee arrangements that are different than those described above (e.g., basis points assessed on percentage of assets under management). B.

Additional Fees and Expenses

Unless otherwise agreed to with a client, our fees do not include transaction charges (more information regarding our transaction practices can be found under Item 12 - Brokerage Practices), custodial fees, transfer taxes, exchange fees, interest charges, electronic fund and wire transfer fees, or any charges, taxes or other fees mandated by any federal, state or other applicable law or otherwise agreed to with the client. In addition, if we acquire a mutual fund, pooled fund or similar investment vehicle for a client account, the client will be responsible for the fees and expenses charged by the underlying fund. The Firm’s general policy is not to charge portfolio companies any additional fees. However, the Firm’s affiliates may receive compensation as officers, directors or consultants for some of the portfolio companies of the Funds. Generally, these fees are not offset against the fees described above.

In addition to the management fees described above, the individual Fund(s) are responsible for a number of expenses that are incurred by or on behalf of the Fund(s). WestRiver will charge fees and allocate and expenses to each Fund strictly in accordance with (a) its fiduciary obligation to treat each Fund fairly and equitably and (b) the guidelines disclosed in Fund offering documents and any other applicable agreements. Below is a list of general expenses and fees that could be expected to be incurred by a Fund: Fees and expenses associated with the organization of the Fund and the offer/sale of interests; Costs of selecting, acquiring, holding, monitoring and disposing of investments; All expenses relating to litigation and threatened litigation involving the Fund; Legal, auditing, tax and accounting services, brokerage, travel, marketing and other fees, commissions and expenses incurred by the Fund;  Taxes, insurance, and any costs incurred from dissolving and liquidating the Fund.    

Generally, all expenses payable by Fund(s) are negotiated in advance and approved by respective investment committees of the applicable Fund in the form of a budget. Thus, the above list is not allencompassing and only provides a sampling of the fees and expenses that may be incurred in running an investment Fund. For more information, please refer to each Fund’s operating agreement. C.

Compensation for Sale of Securities or Other Investment Products

Neither the Firm nor any of its supervised persons accepts compensation for the sale of securities or other investment products.

Methods of Analysis & Investment Strategies

WestRiver is an investment firm that provides debt and equity financing to technology, life science, experiential, and healthcare service companies. The Firm’s investment platforms focus on the technology, life science, energy, and experiential sectors, with flexibility to invest in a variety of asset classes and capital structures. As the managing member or general partner of each of the private investment Fund(s), we have developed proprietary investing strategies to identify potential investment opportunities, as described below in more detail. The WestRiver Funds Platform is designed to make capital allocations through underlying fund managers whose strategy is to make investments in private, venture capital-type investments, including seed, start-up and other early-stage venture capital, later-stage venture capital, expansion capital, and technology-related growth capital investments. The WestRiver Equity Platform is designed to invest in technology, life science, and experiential companies. The technology sector generally invests in private early and growth stage B2B technology companies which leverage Machine Learning and Artificial Intelligence across large datasets. The life science sector makes investments in early and late-stage private and early-stage public company opportunities of biotech, pharma, digital health and tech enabled health services. The experience sector is designed to invest in private early and growth stage companies participating in the consumer experiential economy which includes a focus on social sports, games, travel, augmented and virtual reality experiences, and experiential social commerce.

The WestRiver Debt Platform is designed to make loans and other debt-like investments to, and acquire warrants to purchase equity in, emerging growth, technology, life sciences, FinTech, hardware-as-a-service, and private investment companies with growth potential. The Firm and its affiliates will not exercise final approval with respect to the selection of investments and capital allocations for nondiscretionary funds. Such approval will be vested in the investment committee of each Fund. We will conduct due diligence to screen potential investments, negotiate the terms of each investment, and make recommendations to the applicable Fund investment committee on investment decisions. Each investment prospect will be selected based on our judgment and investment experience. On the other hand, for the Equity Platform funds, the Firm and its affiliates will exercise discretion with respect to the selection of investments and capital allocations. Each Fund may, from time to time, invest cash on hand in short-term money market instruments, U.S. Treasury obligations, bank certificates of deposit, and other instruments having short maturities or call features, until such time or times when capital contributions are needed to fund a Fund’s unpaid committed capital contributions to any portfolio investment or to pay Fund expenses (including management fees). In providing investment advisory services to the other Clients, WestRiver employs substantially similar due diligence, screening and recommendation methods and strategies as we do in providing investment advisory services to the Fund(s). B.

Risk Factors

Potential investors should be aware that an investment in any of the Fund(s), or in any other investment we recommend, involves a significant degree of risk. There can be no assurance that the Fund(s) investment objectives will be achieved, or that an investor will receive a return of capital. Risks associated with an investment in the Fund(s), or in any other investment we recommend, may include, but are not limited to, the following, and should be carefully evaluated before making an investment in a Fund or in any other investment we recommend. General The private equity class of investments, including investments in venture capital Fund(s), is highrisk and subject to loss, including the loss of part or all of an investor’s investment. The success of private equity investment vehicles in general is subject to risks related to: (1) the quality of the management of the respective portfolio companies; (2) the ability of the management of the portfolio companies to execute and grow their businesses; (3) general economic conditions; and (4) the ability of the portfolio companies to achieve liquidity for the investment. There is no assurance that the investments will be profitable or that distributions will be made to the investors. Any return on investment to the investors will depend upon the success of the investments. Suitability of Investors An investment in the Fund(s), and in certain other investment recommended by the Firm, is suitable only for sophisticated investors with substantial other assets who are capable of making an informed independent decision as to the risks involved in such an investment. Because of the risks involved, the lack of a public market for the interests and restrictions on transfer of interests, such investments are only suitable for sophisticated investors who are willing to hold their interests to term and who understand that they may lose all or a significant portion of their invested capital. We expect the Fund(s) to hold their investments for a number of years. In addition, in some cases,

the Fund(s) may be prohibited by contract or applicable laws from selling certain securities for a period of time. Highly Competitive Market for Investment Opportunities The activity of identifying, completing and realizing private equity investments is highly competitive and involves a high degree of uncertainty. The Fund(s) and other investors following our recommendations will be competing for investments with other private equity investment vehicles, as well as individuals, financial institutions and other institutional investors. Further, over the past several years, an ever-increasing number of private equity investment vehicles, including those that invest in other investment vehicles, have been formed (and many such existing investment vehicles have grown in size). Additional investment vehicles with similar investment objectives may be formed in the future by other unrelated parties. No assurance can be given that the Fund(s) and other investors following our recommendations will be able to identify investment opportunities that satisfy their investment objectives and desired diversification goals or, if they are successful in identifying such investment opportunities, that they will be permitted to invest, or invest in the amounts desired, in such opportunities. Taxation Risks Certain risks relating to tax matters are discussed below, which prospective investors should read carefully. We endeavor to structure the Fund(s) investments in a manner that is intended to achieve the Fund(s) investment objectives and, notwithstanding anything contained herein to the contrary, there can be no assurance that the structure of any investment will be tax efficient for any particular investor or that any particular tax result will be achieved. In addition, tax reporting requirements may be imposed on investors under the laws of the jurisdictions in which investors are liable to taxation or in which the Fund(s) make portfolio investments. Furthermore, the Fund(s) returns in respect of their investments may be reduced by withholding or other taxes imposed by jurisdictions in which the Fund(s) portfolio companies are organized. Finally, the tax rules, or their interpretation in relation to an investment in the Fund(s), may change during the life of the Fund(s). Prospective investors should consult their own professional tax advisors with respect to the tax consequences to them of an investment in the Fund(s) in light of their particular tax situations. Changes Changes in legal, fiscal and regulatory regimes may occur during the life of the Fund(s), which may have an adverse effect on them or the portfolio investments. Changes in economic conditions may occur during the life of the Fund(s) that may have an adverse effect on their investments, such as rising interest rates, downturns in the economy or deteriorations in the condition of the industry sector in which a portfolio investment operates or invests. Illiquidity of Investments A limited market exists for the sale of the Fund(s) investments in portfolio companies and the transferability of such investments is generally restricted. There are no assurances that the Fund(s) will be able to liquidate a particular interest in a portfolio company at the time and upon the terms they desire. Other investments we recommend may face similar or identical liquidity issues. 10 | P a g e

Lack of Liquidity of the Interests in the Fund(s) Prospective investors should be aware of the long-term nature of their investment in the Fund(s). There is not now and likely will not be a public market for the interests. The interests may not be assigned, transferred or encumbered without the prior written permission of the Firm. Accordingly, an investor may not be able to liquidate their investment and must be prepared to bear the risks of owning their interest for an extended period of time. The interests are not likely to be registered under the securities laws of the country, state or jurisdiction of residence of any investor. Dependence on Senior Professionals The Fund(s) will be managed by the Firm, and accordingly will be dependent on the personnel of the Firm (particularly Erik J. Anderson) for investment sourcing, management, analysis, and administrative services. The loss of Erik J. Anderson or other WestRiver key personnel could have a significant adverse impact the Firm’s ability to perform its duties as the Managing Member of the Fund(s). Investors must rely on the ability of the Firm to source appropriate investments. With respect to investments that are approved by the Fund's investment committee, the investors are dependent on the Firm to manage the investment execution appropriately. Accordingly, no person should purchase an interest in any Fund unless such person is willing to rely on the Firm for the above matters and day to day responsibilities associated with managing the Fund's investment portfolio. Difficulty of Locating Suitable Investments The Fund(s) may be unable to find a sufficient number of attractive opportunities to meet their investment objectives. The investment performance of prior Fund(s) managed by the Firm cannot be relied on as an indicator of the Fund(s) future performance or success. Penalty for Failure to Make Capital Contributions to the Fund(s) Upon failure to make any installment payment of its capital commitment, a Fund investor’s interest will be subject to substantial or total reduction Establishment of Additional Fund(s) WestRiver and our related persons may organize new Fund(s) substantially similar to the Fund(s). Any such new fund may be interested in the same investment opportunities as the Fund(s) and other investors following our recommendations. There is no assurance that investors in the Fund(s) will be offered the opportunity to participate in any subsequent Fund(s). Value of Investment The value of an investment in the Fund(s), or in other investments we recommend, may fluctuate. A Fund investor’s capital commitment will be allocated to investments over a fixed period of time specified in the Fund operating agreement. Historically, private equity returns have varied greatly over time, depending on the conditions at the time investments were made and when investments were exited by the partnerships. No assurance can be given that the Fund(s), or other investments we recommend, will return to investors all or any part of their contributed capital commitment. Indemnification Obligations of the Fund(s) 11 | P a g e

Read the rest in the brochure

The Firm provides investment advisory services to the privately offered pooled investment Funds, and various institutional clients such as endowments, other investment advisers and charitable organizations, as discussed above in Item 4 - Advisory Business. Certain Fund(s) may require investors to make a specified minimum investment as specified in each Fund(s) operating agreement. The terms and amount of each investment in each of the Fund(s) are privately negotiated. Fund investors may include pension and other Fund(s) subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). Each Fund may require certain customary representations or assurances from Benefit Plan Investors (as defined in 29 C.F.R. §251 0.3-1 01) to determine the Fund’s compliance with legal provisions applicable to them. Interests in the Funds are currently offered on a private placement basis, and where applicable, in reliance on Section 3(c)(1) and 3(c)(7) of the Company Act, to persons who generally are “accredited investors” as defined under the Securities Act of 1933, as amended (the “Securities Act”), and “qualified purchasers” as defined under the Company Act, and who are subject to certain other conditions, which are fully set forth in the Offering Documents of each of the Funds. In order to invest in a Fund that is subject to a performance fee, an investor must be a “qualified client” as defined by Section 205 of the Advisers Act, and Rule 205-3 thereunder.

As described in Item 5 – Fees and Compensation above, in addition to fixed management fees, we are entitled to receive carried interest distributions from each Fund in accordance with the terms of the Fund's operating agreement. Typically, the carried interest is structured as a right to receive a specified percentage of any additional distributions after the Fund's investors have received back their capital contributions plus a preferred return. In some contexts, after the investors have received their capital contributions and preferred return, we may be entitled to catch-up distributions commensurate with the preferred return paid to the investors. Following the catch-up (if applicable), any additional distributions are split between the investors, on the one hand, and the Firm, on the other hand, in accordance with the carried interest percentage as specified in each Fund(s) operating agreement. Conflicts of interest may exist where an adviser and its related persons manage more than one private investment fund. The Firm or a related person may give advice to a Fund which differs from the advice given to another Fund, even though the Fund(s) investment objectives may be the same or similar. Conflicts of interest also may exist in our allocation of an investment opportunity among the Fund(s). In addition, conflicts of interest may occur as to the allocation of our time among the various Fund(s). Potential conflicts of interest are expected to be limited because the Fund(s) generally employ different investment objectives. Because of differing objectives or other factors, the members, managers, employees, and related persons of the Firm and the Fund(s) we manage may take investment positions in securities that are different from, or opposite to, the positions taken by a Fund. Generally, the Firm, its members, managers, employees, or related persons, if any, become aware of, and can participate in, business opportunities in which a fund investor and/or Fund will not be given an opportunity to participate, even if such opportunity is of a character that, if presented to the investor and/or Fund, would be desirable to an investor and/or Fund.

The Firm is not registered, and does not have an application pending to register, as a broker-dealer or registered representative of a broker-dealer. Currently, no employees of the Firm are registered representatives of a broker-dealer. Neither the Firm nor any of its management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of the foregoing entities. The Firm’s affiliates act as general partner or adviser of the Funds. The Firm does not believe that these relationships create any material conflicts of interest with the Funds. WestRiver or its affiliates are the general partner or managing member of the Fund(s). As part of our advisory activities, WRM is not compensated for, nor do we recommend or select other investment advisers.

and Personal Trading A.

Code of Ethics

WestRiver has adopted a Code of Ethics (the “Code”) that sets forth standards of ethical conduct and requires compliance with federal securities laws. The Code requires generally, that designated personnel preclear initial public offerings, secondary offerings and private placements, and all personnel report personal securities holdings and transactions. We have also adopted an Insider Trading Policy that restricts the use and communication of material nonpublic information. We will provide a copy of the Code (and Insider Trading Policy) to clients and prospective clients upon request. Requests should be directed to: Chief Compliance Officer, WestRiver Management, LLC, 920 Fifth Avenue, Suite 3450, Seattle, WA 98104 or via email: info@wrg.vc. Related persons of the Firm (i.e., officers and other employees, if any) may periodically buy or sell securities for their own accounts that are also purchased and/or sold for the accounts of the Firm’s clients. This has the potential to create a conflict of interest between these Related Persons of the Firm and clients. In order to address this potential conflict of interest, our Code establishes policies and procedures relating to trading by the Firm and our related persons (i.e., officers and other employees, if any). The Code is based on the principle that our related persons (i.e., officers and other employees, if any) owe a fiduciary duty to clients and must avoid activities, interests and relationships that might interfere with making decisions in the best interests of any client. Among other things, the Firm’s Code generally requires that related persons (i.e., officers and other employees, if any):  are prohibited from trading, either personally or on behalf of others, in securities while in possession of material non-public information regarding these securities or communicating material non-public information to others; 17 | P a g e

 are required to preclear securities transactions involving initial public offerings, secondary offerings, private placements and capital commitments;  report personal securities holdings and transactions;  are required to place the interest of clients above the interests of the Firm or other employees whenever a conflict may be present;  are required to certify annually that they have complied with the Firm’s Code of Ethics;  may not give or accept gifts or entertainment that are inappropriate or could be seen as overly generous or which could influence Employee decision-making;  that become aware of any violation of the Code are required to report such violation to the CCO and have it logged by the Firm. B.

Conflicts of Interest

Due to the nature of its business activities, the Firm and its related persons may experience times where a conflict of interest might arise between certain parties. Erik Anderson, WestRiver’s principal, personally invests in certain Funds, in certain opportunities alongside the Funds, or in opportunities that may or may not be presented to Clients or investors depending on investment strategy. Therefore, the Firm may be deemed to recommend to Funds or buy or sell for the Funds, investments in which the Firm’s principal has a material financial interest. The Firm is a fiduciary and will at all times act in accordance with all regulatory compliance. Refer to the descriptions below where possible conflicts of interest are identified and the course of action the Firm takes to mitigate these conflicts is explained. Investment Committee The Funds with nondiscretionary assets have an investment committee consisting of representatives of the investors in the Fund, and sometimes a representative of WestRiver. All decisions concerning approval of new investments, allocations of capital to specific investments, and dispositions of investment securities must be approved by majority vote of the investment committee. As a result, there is risk of conflict and potential misalignment between the interests of external investment committee members and those of a Fund. The role of each Fund’s investment committee is outlined in Fund offering documents and provided to investors for due diligence and risk assessment prior to investing in a Fund. External investment committee members are not subject to the Firm’s Code of Ethics. The Firm requires external investment committee members to disclose any actual or potential material conflicts of interest impacting the external investment committee member’s investment decision(s) relating to a Fund to ensure we are aware of material conflicts of interest. External investment committee members must refrain from voting on an investment recommendation if there is an actual material conflict of interest that cannot be eliminated or resolved fairly and equitably. Limitation and Waiver of External Investment Committee Member Fiduciary Duties No external investment committee member shall be obligated to recommend or take any action in its capacity as an external investment committee member that prefers the interests of the Fund, on the one hand, over the interests of such external investment committee member or its Affiliates or their respective employees, employers, agents or representatives, on the other hand, as set forth in Governing Documents. Other Business Activities

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WestRiver and our related persons (i.e., officers and other employees, if any) are required to devote as much of their time to the business of the Fund(s) and our other clients as is reasonably required in their sole and absolute discretion. The Firm and its affiliates engage or have an interest in other business ventures or activities and may engage in other business activities even if such ventures or activities are competitive with the business of a Fund or client. We generally have no obligation or responsibility to disclose or refer any particular investment or other opportunity of any kind whatsoever to a Fund, even if such opportunity is of a character that, if presented to a Fund, would be desirable to the Fund. The Firm and our related persons also serve as directors, officers or committee members of the various portfolio companies of the Funds. In performing their roles, such persons may face conflicts of interest between discharging their duties as directors, officers or committee members, as the case may be, of such companies and must act in the best interest of the applicable Funds. Moreover, certain Firm affiliates serve as directors of public companies and their activities on behalf of those other companies may present actual and/or potential conflicts of interest (including conflicting fiduciary duties). The Firm’s affiliates receive compensation from companies in their capacities as directors, officers or committee members and this compensation generally will not be shared with the Funds. Outside Investment Opportunities Employees of WestRiver may invest in the same areas of investment opportunity as those in which the Fund(s) may invest and which may be recommended to other clients. Because of differing objectives or other factors, the employees and clients of WestRiver and our affiliates may take investment positions in securities that are different from, or opposite to, the positions taken by the Fund(s) and/or our other clients. Moreover, the Firm, or its affiliates, may become aware of, and participate in, business opportunities in which the Fund(s) or other clients will not be given an opportunity to participate. Managing Multiple Investment Fund(s) Conflicts of interest may exist where an adviser and its affiliates manage more than one private investment fund. The Firm or an affiliate may give advice to a Fund or other client which differs from the advice given to another Fund or client, even though the Fund(s) or other clients’ investment objectives may be the same or similar. Potential conflicts of interest are expected to be limited among the Fund(s) because they have different investment objectives. Interaction Between Managed Fund(s) Fund(s) managed by the Firm may invest in similar companies and / or other investment opportunities.

Fundraising Assistance The Firm and/or the Fund(s) may enter into arrangements with SEC-registered broker-dealers pursuant to which the broker-dealers will provide the Fund(s) with fundraising assistance for a fee. These fundraising activities will be conducted in accordance with applicable rules and regulations. 19 | P a g e

Managing Member Capital Commitment The Firm may from time to time make capital commitments to Fund(s) based upon terms to be negotiated with the investment committee for the Fund and may co-invest in Fund portfolio investments. As a result, WestRiver will co-invest with the Fund(s) underlying investors. WestRiver, from time to time may offer (but shall in no event be required to) co-investment opportunities to some or all Fund investors, subject to any terms or limitations relating to offering of co-investments as described in the Fund’s Governing Documents. The terms of any coinvestment shall be agreed to by the Firm and the participating co-investors, which terms may include provisions for management fees and “carried interest” for the benefit of WestRiver or its affiliates, which shall not offset the management fee. All expenses associated with a consummated co-investment in a Fund’s portfolio investment (whether incurred prior to or following the consummation of such portfolio Investment) will be allocated between the applicable Funds and the relevant co-investment vehicle(s) managed by the Firm or its affiliates on the basis of their respective direct or indirect participation in the relevant portfolio company. Such expenses reasonably attributable to such portfolio investment consummated as a co-investment and one or more other portfolio investments in which the Funds own an interest will be allocated among the Funds as the Firm reasonably determines to be applicable on the basis of a methodology reasonably selected by the Firm in its discretion (which may include an assessment of the relative capital commitments, relative capital contributions, investment phase or other determining factors reasonably applicable to the participating Funds). The Firm expects, however, to allocate all of the organization costs including, without limitation, broken deal expenses in respect of the entirety of any unconsummated co-investment transactions, to the advisory clients participating in such co-investment unless such costs are paid for by the proposed portfolio investment. For the avoidance of doubt, certain expenses attributable to a coinvestment may be borne by some Funds and not by others. In the event that a transaction in which a co-investment was planned ultimately is not consummated, all broken deal expenses relating to such proposed transaction are likely to be borne entirely by the advisory clients participating in such co-investment for which the given investment opportunity was originally intended, and not any Fund organized exclusively to co-invest in the given investment opportunity. Carried Interest Distribution The existence of the carried interest paid to WestRiver may create incentives for the Firm to invest in more speculative or risky investments than we would otherwise make or allocate should such arrangements be absent.

WestRiver is responsible for the day-to-day management of each Fund and therefore has the authority to select brokers or dealers to be used and commission rates paid, where applicable. If selecting brokers to execute transactions, WestRiver would seek to obtain the best price and execution for transactions. Factors such as price, size of order, difficulty of execution and operational facilities of a brokerage firm will be taken into account. Additional considerations will be given to the scope and quality of brokerage services provided, and our potential risk in positioning a block of securities. Subject to our duty to obtain best

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execution, the Firm may execute transactions through brokers that provide the Fund(s) with fundraising assistance. WestRiver may receive research from a number of broker-dealers, which could include, among other things, market data, technical analysis, and economic commentary. This research in each case could be provided to the Firm because of personal relationships of our managing principal with persons at the broker-dealers and is not the result of soft dollar arrangements or any other arrangements with the broker-dealers. The research that we obtain may be used to service, support, and advise all of our Fund(s). WestRiver will continue to receive the free research regardless of whether we choose to execute Fund transactions with any of the broker-dealers providing the research. The value of research received by the WestRiver is not considered when selecting brokers for execution of transactions in Fund accounts, but nevertheless could be perceived to create the potential for a conflict of interest under certain circumstances. The Firm does not consider investor referrals from a broker-dealer or third parties when selecting brokerdealers.

We have entered into written agreements with parties not affiliated with us pursuant to which this party introduces potential investors to us. We pay fees to the referring parties on an ongoing basis, based upon a percentage of the management fees we receive with respect to each client that the referring parties referred to us. The referring parties disclose the compensation arrangement between WestRiver and the referring 21 | P a g e

parties to a prospective client before the client enters into an investment advisory relationship with the Firm. We do not charge clients referred to us by referring parties any fees or costs greater than the fees or costs we charge clients with similar portfolios who were not referred to us by referring parties.

We are required to disclose any legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. We do not have any information to disclose in response to this Item.

WestRiver generally reviews all client accounts monthly and distributes client investment reports quarterly. In addition, the firm endeavors to communicate with clients on a periodic basis to provide a detailed review of their accounts. Review of Accounts Each Fund’s managing member or general partner reviews all accounts monthly or more frequently as deemed appropriate. This review includes, among other things, analyzing portfolio investments in light of each Fund’s investment objectives, and recommending changes to each portfolio as deemed appropriate. Reporting to the Fund(s) Each of the Fund(s), other than the Equity Platform Funds, maintain an investment committee consisting of representatives of the investors in the Fund. Each investment committee has the responsibility to (1) approve new investments, (2) determine the amount of each Fund(s) capital allocation to such investment, and (3) approve the disposition of investment securities. Each Fund(s) investment committee reviews and monitors investments on a periodic basis. Investors in the Fund(s) will receive quarterly or semiannual unaudited reports on the results of a Fund(s) investments, as well as all necessary tax reporting information (based upon reports). Investors in non-audited Fund(s) will also receive a quarterly account statement. Investors in the Fund(s) subject to annual audit will receive audited financial statement within 120 days of such Fund(s) fiscal year-end (see Item 15 – Custody below).

The Firm is not a custodian, and our practice is not to have physical custody of investor assets. Notwithstanding the foregoing, WestRiver recognizes that we may be deemed to have custody under certain circumstances. In circumstances where the Firm is deemed to have custody, we will comply with the requirements of Rule 206(4)-2 under the Investment Advisers Act of 1940. The Firm and its affiliates serve as general partner or managing member for the Fund(s). In situations where a Fund is not subject to an annual audit, we will use our reasonable best efforts to ensure that account statements are sent to each limited partner or member of a limited partnership or limited liability company, at least quarterly. In circumstances where a Fund is subject to an annual audit, the Firm will ensure that audited financial statements are prepared in accordance with generally accepted accounting principles (by an independent public accountant that is registered with and subject to regular inspection by the Public Company Accounting Oversight Board) and distributed to all limited partners (or members or other beneficial owners) within 120 days of such Fund’s fiscal year-end. Investors should carefully review all account statements received. In accordance with the SEC’s custody rule, certain accounts over which we have custody are subject to an annual surprise examination.

The Firm or its affiliates are the general partner or managing member of the Fund(s). The Fund(s), with the exception of the Equity Platform Funds, each have their own investment committee consisting of representatives of the investors in the Fund, and sometimes a representative of the Firm. All decisions concerning approval of new investments, allocations of capital to specific investments, and dispositions of investment securities must be approved by majority vote of the investment committee. As a result, WestRiver does not exercise investment discretion, and does not have final approval, with respect to the selection of Fund investments, and does not determine the amount of each Fund’s capital commitment in each investment. However, WestRiver and its affiliates do exercise investment discretion with regard to the Equity Funds and has final approval with respect to the selection of Equity Platform Fund investments and determining the amount of each Equity Platform Fund’s capital commitment in each investment.

If at any time applicable and unless reserved by a client, WestRiver would be responsible for voting proxies in a timely manner and for the exclusive purpose of providing benefits to the applicable Fund(s). In this regard, the Firm generally will, consistent with its fiduciary role, seek to enhance the value of the affected Fund(s) portfolio by voting each company proxy in a manner that is designed to maximize the company’s stock price. However, the Firm may refrain from voting in certain circumstances. For instance, we may refrain from voting a proxy if we conclude the potential impact on shareholders’ interests is insignificant while the cost associated with analyzing and voting the proxy may be significant. Given the nature of the Firm’s business and its investment in private companies and private investment funds, proxy voting generally does not apply.

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As a general proposition, WestRiver will support proposals that (i) preserve and expand the power of shareholders in areas of corporate governance and (ii) allow responsible management teams to run their company in the way that is most likely to maximize value for owners. A copy of WestRiver’s proxy voting policies and procedures, as well as information with respect to how we voted specific proxies, is available upon written request. Such request can be made by mail directed to the attention of: Chief Compliance Officer, WestRiver Management, LLC, 920 Fifth Avenue, Suite 3450, Seattle, WA 98104 or via email: info@wrg.vc.

The Firm is not required to include a balance sheet for the most recent fiscal year. We do not require or solicit prepayment of fees from any investor, six months or more in advance. The Firm has never filed for bankruptcy and is not aware of any financial condition reasonably likely to impair its ability to meet contractual and fiduciary commitments to its clients.

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