WHITEBOX ADVISORS LLC

The Advisor

Founded in 1999, Whitebox Advisors LLC (the “Advisor” or “Whitebox”), a Delaware limited liability company, manages and advises private investment funds (“Private Funds”), which are organized to be exempt from registration under the Investment Company Act of 1940, as amended, (the “Investment Company Act”) and their securities or interests are expected to be exempt from registration under the Securities Act of 1933, as amended (the “Securities Act”). Private Funds include funds organized as issuers of collateralized loan obligations (“CLOs, including the predecessor CLO warehouse in which case and where relevant herein, such a CLO is referred to as “CLO warehouse”).

Whitebox also offers advisory services to separately managed accounts (“Separately Managed Accounts”). The Private Funds and any Separately Managed Accounts advised by Whitebox are referred to collectively as “Clients.” In certain cases, the Advisor provides investment advice to the Private Funds through special purpose investment advisers controlled by the Advisor (the “Relying Advisors”). References herein to the “Advisor” or “Whitebox” include Relying Advisors unless otherwise required by the context. Whitebox provides investment advisory services to Clients pursuant to investment objectives, strategies and, as applicable, guidelines set forth in each Client’s governing documents, received by and agreed to by investors in Clients prior to their investment and includes, as applicable, an investment management agreement, organizational documents (such as limited partnership agreements or memorandum and articles of association), private placement memoranda (including any class supplements thereto), side letters, investment management agreements and other documentation relevant to an investment in the Client and together are collectively referred to as “Client Documentation”.

As of December 31, 2025, Whitebox managed approximately $15,739,565,705 in discretionary regulatory assets under management. Whitebox is majority owned by Partner and Chief Investment Officer, Robert Vogel (via Skagday, Inc.). The balance of Whitebox interests is held by affiliated persons as set forth in Schedules A and B of Part 1A, available on the SEC’s Investment Adviser Public Disclosure (IAPD) website at www.adviserinfo.sec.gov. Whitebox is headquartered at 3033 Excelsior Blvd, Suite 500, Minneapolis, Minnesota 55416. The Advisor’s website at www.whiteboxadvisors.com contains information that may be useful. See Item 10 Other Financial Industry Activities and Affiliations for additional information regarding Whitebox. Co-Investments

Whitebox can, but is not obligated, to offer co-investment opportunities to its affiliates and/or third parties (including existing and prospective Clients and investors either directly or through the formation of one or more co-investment vehicles). Whitebox has sole and complete discretion to determine whether and to whom a co-investment will be offered, and in doing so, will take into account its own interests. Unless provided to the contrary in Client Documentation, no Client or investor has any right, and should not expect, to participate in a co-investment. In Whitebox’s discretion, certain co-investors pay no or reduced fees and expenses, including management fees,

carried interest and administrative fees. In certain cases, co-investment vehicles or other coinvestors will evaluate a potential investment alongside existing Clients. If a potential co-investment is not consummated, the expenses relating to such unconsummated transaction are expected to be borne by those Clients expected to have participated and there is no assurance that Clients will not bear more than their pro rata share of such expenses; while potential third-party participants may bear a smaller portion or none of the related expenses. In the case of a consummated co-investment, eligible Clients will receive a smaller allocation of an investment than if there were no co-investors.

Whitebox generally receives a management fee (“Management Fee”, as defined below) and performance-based compensation (“Incentive Compensation”, as defined below) for advisory services. The description below is intended to provide a summary of the typical compensation received by the Advisor and is not intended to represent every scenario. Please refer to specific Client Documentation for details. To the extent there is a conflict between the general descriptions contained in this brochure and the disclosures in Client Documentation, the terms of the Client Documentation shall govern. Private Funds

Consistent with Client Documentation, Whitebox generally receives a periodic Management Fee based on assets under management in connection with its advisory services and is, typically, entitled to receive Incentive Compensation from eligible Clients, which is based on a percentage of net realized and unrealized profit of the portfolio.

With respect to Private Funds, the Incentive Compensation, when applicable, is generally determined for each investor at the end of each calendar year. Subject to Client Documentation, the Incentive Compensation will generally be equal to percentage amounts up to 20% of net profits allocated to each investor, subject to, when applicable, a net loss recovery account commonly referred to as a “high water mark” (pursuant to which a loss allocated to an investor must first be offset by profits earned in ensuing Incentive Compensation periods).

The Advisor has entered into placement agent agreements with unaffiliated promoters and registered broker dealers whereby certain series of interests/classes of shares (as applicable) in certain Private Funds are referred by such placement agents to its clients. The terms of these series/classes are generally consistent with the terms set forth in Client Documentation but can contain different terms including, among others, investment limitations, minimum initial investment amount, minimum additional investment amount, and Management Fee rates. Placement agents may charge their own fees to certain clients who become investors in Private Funds. Whitebox is not prohibited from rebating, reducing and/or waiving some or all of its Management Fee and/or Incentive Compensation with regard to any investor or sharing a portion of the Management Fee and/or Incentive Compensation with a placement agent in connection with a referred investor. Whitebox generally will rebate, reduce and/or waive some or all of its Management Fee and/or Incentive Compensation with respect to, but not limited to, current or former principals, employees, certain affiliates as well as certain Clients.

With respect to CLOs, Whitebox Capital Management LLC (the “CLO Relying Advisor”) is compensated for the performance of its obligations as collateral manager through a management fee which consists of a senior management fee as well as a subordinated management fee. Such fees are typically payable quarterly in arrears and are calculated and paid by the CLO trustee. In addition, performance compensation is payable to the CLO Relying Advisor as a percentage of excess cash flow available after paying liability costs and expenses and achieving a certain IRR for CLO equity, consistent with Client Documentation. CLO investors and prospective investors should refer to the relevant Client Documentation for information with respect to the fees associated with any CLO.

Subject to Client Documentation, Private Funds invest in the CLOs. To the extent a Client purchases CLO notes or equity of a Whitebox managed CLO, it is expected that Whitebox will reduce or rebate to the investing Private Fund all or a portion of the management fee that would have been paid indirectly by the Client to Whitebox as the collateral manager of the CLO.

Additionally, CLO Relying Advisor has entered into a staff and services agreement with Whitebox pursuant to which Whitebox provides certain services associated with the management of CLOs, including access to its full team of research analysts and portfolio managers employed by Whitebox, office space, back-office services such as loan settlement, legal and compliance services, and performance of trade executions upon instruction from Whitebox. Such services also include services provided through one or more of Whitebox’s affiliates. By way of compensation for these services, Whitebox receives a services fee from the CLO Relying Advisor. Separately Managed Accounts

The Advisor does not maintain a standard fee schedule for Separately Managed Accounts; thus, fees are negotiated on an individual basis and generally include both a Management Fee and Incentive Compensation. Additional Expenses

Each Client is responsible for bearing or reimbursing Whitebox, as the case may be, its operating and other expenses, to the extent permitted under applicable law and Client Documentation. These expenses typically include, but are not limited to, the below-listed expenses. Expenses are further detailed in relevant Client Documentation. In the event of a conflict between the Client Documentation and the following disclosure, the terms of the Client Documentation shall govern.

Cost and expenses (including legal fees and expenses) related to the formation, ongoing operation and liquidation or wind down of a Private Fund entity and any related alternative investment vehicles or special purpose vehicles; Costs and expenses in connection with purchasing, holding, selling, or exchanging securities and other assets (whether or not ultimately consummated), including brokerage fees, interest on borrowed money, real or personal property taxes on investments, costs, and expenses in connection with the registration of investments under applicable securities laws, and related legal, professional, accounting and other fees and expenses; Fees and expenses in connection with the maintenance of bank, brokerage or custodial accounts; Costs and expenses related to (1) the negotiation and preparation of side letters and Client

Documentation including or other service provider or counterparty agreements; and (2), the creation and/or offering of additional classes, sub-classes, series or sub-series of interests, the acceptance of capital contributions and the processing of withdrawals. Legal, accounting, administration, auditing, bookkeeping, tax compliance services and tax return preparation, performance verification, consulting, valuation, and other professional fees and expenses; Costs or expenses in connection with the maintenance or operation of an Oversight Committee/Board, including fees payable to independent members of the Oversight Committee/Board; Fees and expenses related to third party anti-money laundering officers; Premiums for insurance in which a Client is a named beneficiary, including, without limitation, errors and omissions, directors and officers and cybersecurity insurance; Costs and expenses in connection with meetings of and communications with investors and maintenance of online portals for the delivery of information, transparency and reports to investors, prospective investors, counterparties, and service providers (such reports and portals include, without limitation, third-party risk aggregation services and other client reporting tools); Costs of research (including, subject matter experts and other consultants), market data, data delivery systems, execution services and related software and hardware that are of benefit to the Private Funds and are not otherwise provided by brokers (e.g., systems and tools, such as, without limitation, Bloomberg, Thomson Reuters, Markit, IDC, Capital IQ, and similar tools and systems) utilized by Whitebox or a Client’s General Partner in connection with the following, without limitation: (1) the management and operation of Clients; (2) the evaluation and monitoring of investments and potential investments; (3) fundamental, qualitative and quantitative analysis; (4) risk oversight, including stress testing, monitoring risk thresholds and adherence to investment guidelines; (5) valuation of a Client’s investment portfolio, including the cost of data, tools and pricing services utilized by Whitebox; and (6) costs of the settlement of investment transactions (while the Clients bear such costs described in items (1) through (6) of this paragraph, Whitebox uses or benefits from certain of the foregoing and does not reimburse Clients for such use or benefit);

Costs and fees relating to preparation and filing of required regulatory filings and reports in the United States (including state-specific filings and reports) and foreign jurisdictions (including, without limitation, filings under the Securities Act such as Form SHO, Form D, filings under the Securities and Exchange of Act of 1934 (the “Exchange Act”) such as Section 13 and Section 16 filings, investment company related filings under the Investment Company Act and the U.S. Investment Advisers Act of 1940, as amended (the “Advisers Act”), such as Form ADV and Form PF, filings under the U.S. Commodity Exchange Act, state “blue sky” filings, filings in connection with International Swaps and Derivatives Association (“ISDA”) protocols, such as ISDA protocol adherences, filings and reporting in connection with AIFMD, such as Annex IV reporting), and tools and systems put in place to comply with the foregoing;

Costs and fees (including legal fees and expenses) incurred in connection with the preparation and provision of transparency, risk reporting, swap protocol and similar reports; Registered agent and office costs and expenses (including costs and expenses related to corporate services and administrative services) and other regulatory costs and expenses, including fees and expenses associated with investors and prospective investors in the United States and foreign jurisdictions;

Taxes applicable to Clients on account of its operations;

Costs and expenses arising out of Client indemnification obligations; and Investment-related travel expenses.

Further, Whitebox and other Clients will benefit from certain products and services paid for by Clients and thus, a specific Client will not necessarily be the direct or exclusive beneficiary of a service or product for which it bears an expense and Whitebox does not reimburse Clients for such use or benefits. Specifically, Whitebox uses for itself and other Clients, data and data delivery systems (such as Bloomberg terminals or similar systems and tools and order management systems) for settlement of investment transactions, maintenance of Whitebox’s restricted securities list, security pricing and other services paid for in whole or in part by Private Funds. In addition, Whitebox uses risk reporting, data and systems paid for in whole or in part by the Private Funds for the provision of investment management services to Clients and for purposes of investor or prospective investor reporting, including in connection with risk oversight and monitoring, stress testing and monitoring adherence to investment guidelines for the benefit of Clients. Whitebox benefits from using these services and products without having to pay for them at the expense of Clients.

Each Client bears its own expenses as set forth in its respective Client Documentation. As such, expenses borne by one Client can differ from the expenses borne by other Clients. In certain instances, one Client can bear its proportion of expenses that Whitebox and/or its affiliates have agreed to bear for other Clients. There can be circumstances when a Client or group of Clients would bear none of such expenses. When Whitebox incurs expenses on behalf of multiple Clients, it seeks to allocate expenses among relevant Clients consistent with its practices in effect from time to time. To the extent that Whitebox uses blocker entities or special purposes vehicles as a means of investing or co-investing, the expenses of forming, operating and maintaining such entities will be borne by the relevant Clients or in accordance with the formation documents of the blocker entity. Clients and investors should not expect to be able to negotiate the formation documents of such entities and will not be in a position to determine or influence the scope of the expenses payable by such entities. Whitebox has a conflict of interest in determining whether a service or product that it uses should be borne by a Client and to what extent. Additional Compensation

Whitebox and its employees do not accept cash compensation, including sales charges or service fees, from any person for the sale of interest in Private Funds securities or other investment products. Whitebox has no formal agreements, verbal or written, where it is paid cash by or receives some economic benefit (including commissions, equipment, or non-research services) from a nonClient in connection with giving advice to Clients. Certain Expense-Related Conflicts

Whitebox uses some of the same service providers as are retained for Clients, and is often responsible for recommending service providers to, or selecting service providers for, Clients and negotiating fees with service providers. In some cases, rates or discounts will be offered to Whitebox

that differ from those offered to Clients by such service providers. Where Whitebox is able to control the costs of services, it seeks to apply favorable rates or discounts extended to it to costs borne by Clients, to the extent such services are of a similar scope, type, and nature. There is no assurance that Whitebox will be successful in securing favorable rates or discounts for Clients.

General Investment Strategy and Methods of Analysis Overview

Whitebox’s disciplined approach combines bottom-up trade identification with a top-down view on markets and strategies. Each of the following principal investment strategies employed in furtherance of the investment objective are generally designed to capture alpha from systematic inefficiencies and idiosyncratic opportunities across asset classes and market cycles.

Convertible Arbitrage – Opportunistic approach to convertible investing Credit - Focused predominantly on distressed, restructuring and event-driven credit trades

Credit Arbitrage – Capital structure arbitrage with a credit focus

Equity Arbitrage – Relative value approach to equity event, predominantly in global markets

debt markets

Government – Fundamental and tactical trading within the municipal market and sovereign

Structured Credit - Opportunistic approach to structured credit including, among others, residential mortgage-backed securities and collateralized loan obligations.

SPECIAL CONSIDERATIONS AND RISK FACTORS

There are various risks, some substantial, associated with an investment in a Private Fund or the investment strategies employed by Whitebox. There are many market-related and other factors some of which may be beyond the control of the Advisor which could cause a Client or investor to lose some or all of its investment. No person should invest in a Private Fund or undertake such strategies unless fully able, financially and otherwise, to bear such a loss, and unless it or its agent has the background and experience to understand thoroughly the risks of investment. For risk factors and considerations and specific information about relevant risks, see the Client Documentation.

The returns realized under each Client’s investment strategy will be affected by many factors, including, but not limited to, the following:

General Risk Factors

No Guarantee of Investment Performance. The Advisor cannot guarantee that a given Client will achieve its stated investment objective or achieve its target return or generate positive or competitive investment returns. The Advisor cannot control market, regulatory, and other factors which will affect the performance of Clients. Clients and/or fund investors bear the risk that they could lose a portion or all of their investment.

Reliance on Key Investment Personnel; Passive Investment. Each Client is managed exclusively by the Advisor. Each Client’s future profitability will in large measure depend upon the business and investment acumen of key investment personnel of the Advisor and its affiliates. Should anything happen to key investment personnel of the Advisor, Client performance could be adversely affected. There is no assurance that the business and operations of any Client will not be adversely affected. Moreover, certain management agreements contain key man provisions and can be terminated in the event of a key person event or departure. The Advisor and its personnel intend to devote such time as they deem necessary to perform its duties. However, the Advisor and its personnel will be involved from time to time with other investment management activities and will not devote all of their time to any single Client. There is no assurance that the Advisor will not experience changes in investment personnel and that the Advisor personnel involved with Clients may change over time.

Uncertain Economic, Social and Political Environment. General business, consumer and financial confidence, including in the credit markets, may be adversely affected by local, regional, or global health crises including, but not limited to, the rapid and pandemic spread of novel viruses and by the measures taken in relation thereto. Such health crises could exacerbate political, social, and economic risks mentioned below, and result in significant breakdowns, delays, and other disruptions to important global, local and regional supply chains affected, with potential corresponding results to affected borrowers or counterparties of the Private Funds. In addition, current or future tensions around the world, fear of terrorist activity and/or military conflicts, localized or global financial crises or other sources of political, social or economic unrest may also adversely affect such confidence. Such erosion of confidence may lead to or extend a localized or global economic downturn which could result in losses to the Fund and its investors. Events in connection with the global spread of COVID-19 in particular, including protective measures taken by governments and the private sector, created significant, or even extreme, volatility in the securities and credit markets. Market uncertainty increased and, in the event of similar situations, may further increase dramatically. Such adverse market conditions could expand to a variety of markets, and various sectors of the global financial markets could experience an extended period of adverse conditions that may result in reduced liquidity, greater volatility, general widening of credit spreads and a lack of price transparency. A climate of uncertainty may reduce the availability of potential investment opportunities, and increases the difficulty of modeling market conditions, potentially reducing the accuracy of financial projections. This may slow the rate of future investments by Clients and result in longer holding periods for investments. Market Disruption and Geopolitical Risk; Sanctions. Clients are subject to the risk that war, terrorism, and related geopolitical events lead, to increased short-term market volatility and have adverse long-term effects on the U.S. and world economies and markets generally, as well as adverse effects on issuers of securities and the value of Clients’ investments. Those events as well as other changes in U.S. and non-U.S. economic and political conditions also could adversely affect individual issuers or related groups of issuers, securities markets, interest rates, credit ratings, inflation,

investor sentiment, and other factors affecting the value of the Clients’ investments. At such times, Clients’ exposure to risk can increase. Government imposed sanctions on individuals or investments can have an adverse effect on Clients, investors and related performance. Such governmental action can compel the Advisor to take certain actions, such as freezing investor or Client assets, disposing of investments prematurely, or avoiding investments or counterparties it would otherwise have pursued or made. Sanctions affecting individual investors can, under some circumstances adversely affect unsanctioned investors. For example, if sanctions mandated a redemption or liquidation the investment of a Client or a sanctioned investor. Further, sanctions can create an overall adverse effect to markets in general causing a loss for Clients which would otherwise be unaffected directly by such sanctions. Government imposed sanctions are difficult to predict and beyond the control of the Advisor. If an investment made by a Client subsequently becomes subject to applicable sanctions, it may be required, without notice to Clients or investors, to divest from or freeze such investment or otherwise cease any further dealings in that investment until the applicable sanctions are lifted or a license is obtained under applicable law to continue such dealings. Any such sanctions could have an adverse effect on the value or liquidity of such investments. In certain cases, the imposition of sanctions may require the Advisor to liquidate investments at disadvantageous prices or result in the Fund being unable to liquidate its investments.

No Market for Shares/Interests – Although the shares/interests of the Private Funds that are structured as open-end funds can be redeemed on a periodic basis (unlike shares/interests in the closed-end funds which cannot be redeemed periodically), the shares/interests cannot be assigned, pledged or otherwise transferred without prior written consent as set forth in Client Documentation. There is no market for the shares/interests, and none is expected to develop. Shares/interests are not expected to be registered under the securities law of any jurisdiction and will be subject to strict restrictions on resale and transferability. Therefore, investors must be prepared to bear the risk of their investment for a substantial period of time.

Restrictions on Transferability and Withdrawal – Closed-End Funds. Interests will not be registered under the Securities Act or any state securities laws and will not be transferred unless registered under applicable United States federal and state securities laws or unless an exemption from such laws is available. The Interests are not transferable, divisible, or otherwise encumberable, except with the prior written consent of the General Partner which can be withheld in its sole and absolute discretion, and investors may not make full or partial withdrawals from a closed-end fund.

Legal Proceedings. Clients and the Advisor, as independent legal entities, are and in the future are expected to be subject to lawsuits or proceedings by government entities or third parties which can be costly and divert significant portions of staff time and resources. Litigation does and will occur in the ordinary course of the management of the investment portfolio of Clients. Certain legal proceedings result in recoveries for a Client, but the outcome of any legal proceeding is uncertain, and the expenses of the legal proceedings will reduce or even outweigh the ultimate recovery. The risk of litigation will increase if the Advisor on behalf of a Client exercises control or significant influence over a company or invests in restricted or closely held securities or other assets. Litigation risk will also arise because of defaults, bankruptcies and/or other reasons. Except in the event of a lawsuit or proceeding arising from the Advisor’s intentional misconduct, bad faith, fraud, gross negligence, material breach of an Investment Management Agreement or the Advisor’s violation of U.S. federal securities law as determined in a final order by a court of competent jurisdiction, expenses or liabilities of a Client arising from any legal proceeding shall be borne by the Client. The costs and expenses associated with these legal proceedings reduces the net investment performance of a Client and Whitebox personnel may

spend a significant amount of time in connection with such lawsuits or proceedings, preventing them from focusing on the management of a Client’s portfolio

Service on Boards of Issuers of Securities in Client Portfolios. As a result of a Client’s investment in portfolio companies, a representative of the Advisor, usually an employee will, from time to time serve on the board of directors or as a board observer of the issuers of securities in Client portfolios or on creditor committees of such issuers. As a consequence, there will often be certain restrictions on a Client’s ability to purchase or sell securities of such portfolio companies at certain times and such representative of Advisor has and is likely to in the future be sued because of their service on such committees or boards for claims of breach of duty of loyalty, securities claims and other director- or insider-related claims. In general, Clients will indemnify the Advisor and their representatives from such claims. As a matter of general practice, the Advisor typically declines to receive compensation offered in connection with such service. To the extent compensation is not declined, such compensation would be credited to the Clients participating in such investment, via a rebate or credit, as determined in the discretion of the Advisor. Private Funds - No Trading Guidelines; Changes in Trading Strategies and Instruments. The investment strategies described herein are a summary of those that are currently employed by the Advisor and are subject to change without notice in the discretion of Whitebox. The Advisor expects that, from time to time, its Private Funds will invest in a wide range of strategies and instruments, and such strategies may differ materially from the strategies described herein. Further, the trading strategies employed by the Advisor are continually developing. Accordingly, there is generally no limitation on the positions that the Advisor may acquire, the instruments it may trade, the markets in which it may trade or strategies that it may employ, except as may be determined in the sole discretion of the Advisor or as set forth in the applicable Client Documentation. Changes in the investment strategies employed by the Advisor may increase the risk profile of the Private Funds.

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Clients.

The Advisor offers and/or provides investment management services for the following

Private Funds and Separately Managed Accounts

Generally, investors in Private Funds must be eligible as “Accredited Investors” as defined as the Securities Act and must also be “Qualified Purchasers” as defined under the Investment Company Act or a “knowledgeable employee” as defined under the Investment Company Act. Separately Managed Accounts would also be required to meet eligibility requirements.

Clients subject to Incentive Compensation will also be required to be a “Qualified Client” within the meaning of the Advisers Act and otherwise eligible as required by applicable law.

Subject to Client Documentation, minimum initial investment for investors in Private Funds ranges from $1 million to $10 million. Investors in a CLO must also meet certain eligibility requirements under the Securities Act and the Investment Company Act. The minimum initial investment amount for investors in a CLO is generally at least $250,000. Minimum initial investment amounts for Separately Managed Accounts are subject to negotiation and is often driven by the requirements of the underlying strategy. Lower investment minimums can be established by the Advisor or General Partner, in its discretion, unless prohibited by law or otherwise.

Side Letter Agreements. Private Funds have and will from time to time enter into a side letter or similar agreement which, subject to applicable law, has the effect of establishing rights under or altering or supplementing the terms of the Client Documentation with respect to the investors party to the side letter. For example, when permitted under applicable law, such terms and conditions could provide for special redemption-related rights (the aggregation of related investor capital in the calculation of the Withdrawal Fees, and limitations on mandatory withdrawals from a Private Fund); capacity rights, a reduction or rebate in the management fee or incentive compensation; confirmation of reporting and notice rights that are generally provided to Private Fund investors; rights to receive risk aggregation reports from third-parties and additional or more frequent information from Whitebox regarding the Private Fund’s portfolio; representations and warranties by the General Partner and Whitebox; and such other rights as negotiated by the Private Fund and such Private Fund investors. The modifications will, among other things, in the discretion of Whitebox, be based on the size of the Private Fund investor’s investment in the Private Fund or affiliated investment entity, an agreement by a Private Fund investor to maintain such investment in the Private Fund for a

significant period of time, or other similar commitment by a Private Fund investor to the Private Fund. Any information or data in any report or notice provided to side letter recipients will generally be available to any other Private Fund investor upon request, or available from third parties at the expense of the requesting Private Fund investor.

Subject to applicable law, the Advisor can create Classes of shares or series of interests in Private Funds which contain different economics terms or different strategies which could have an adverse impact on existing investors in such Private Funds.

The Advisor receives Incentive Compensation from eligible Clients, as set forth in relevant Client Documentation and as permitted by applicable law. Additionally, the Advisor will have, from time to time, other pecuniary interests in Private Funds or Clients, such as General Partner interests and personal or proprietary investments. The amount, nature and percentage of personal or proprietary investments by the Advisor or its principals will differ, with some Clients having significant investment while others will have no investment. Each of these arrangements create a variety of risks and conflicts, including but not limited to, those described below. Where the timing or amount of Incentive Compensation is impacted by decisions to buy, hold or sell an investment, Whitebox has an incentive to sell in order to realize a gain (or minimize a loss) when doing so could accelerate or increase fees, even though the Client might have benefitted from continuing to hold the investment. Conversely, Whitebox might have an incentive to increase, decrease or hold an investment, when it believes that doing so could benefit it, even if it might have benefitted the Client to take different or no action. In the case of CLOs, Incentive Compensation is paid as a percentage of available cash flow, not net unrealized appreciation of assets, and only after equity holders have achieved a specified internal rate of return consistent with the terms of Client Documentation.

Receipt of Incentive Compensation from Clients, differences in the manner in which such compensation is determined, differences among Client positions with regard to return hurdles or thresholds and the presence of affiliates’ and employees’ ownership interests in Clients creates a potential conflict of interest between Whitebox’s interest to generate revenue for itself, its personnel and affiliates, and the interests of Clients and investors. Specifically, Incentive Compensation and other pecuniary interests create an incentive for Whitebox to make investments that are riskier or more speculative than those that might otherwise be made under a different fee arrangement. Client Documentation which contains specific investment guidelines and restrictions constrain the Advisor’s discretion and mitigate this conflict. This is particularly relevant for CLOs where the Client Documentation limits the portfolios to certain types of investments as well as imposing diversification, credit quality and concentration tests by industry issuer and other metrics. Clients organized as Private Funds generally do not have the same limitations and Whitebox relies on internal risk management to monitor for speculative activity and mitigate the conflict. Further, not all Clients are subject to the same level of Incentive Compensation and Whitebox can therefore potentially earn higher fees from accounts with a higher Incentive Compensation than others. For example, Whitebox could have an incentive to direct profitable investment ideas to Clients that pay a higher Incentive Compensation or allocate a sequence of trades in favor of the higher performance fee account. Such “side-by-side management” generally refers to the simultaneous management of multiple types of Clients. Whitebox manages investments for a variety of Clients who pursue similar, competing or complementary investment objectives, policies or strategies. Side-by-side management gives rise to a variety of conflicts for Whitebox and its personnel and affiliates including the incentive to favor Clients with performance-based

compensation or to allocate investment opportunities to proprietary accounts or Clients where the Advisor or its principals have a pecuniary interest. Whitebox has implemented trade allocation policies and procedures designed to mitigate conflicts by seeking to allocate investment opportunities among eligible Clients and proprietary accounts in a manner deemed by Whitebox in its sole discretion to be fair and equitable over time, subject to and consistent with Client Documentation. See Item 11. Code of Ethics, Participating or Interest in Client Transactions and Personal Trading for more information regarding Whitebox’s allocation policy, including the section entitled “Allocation of Investment Opportunities.”

The Private Funds

In certain cases, the Advisor provides investment advice and other services to its Clients through its Relying Advisors. The Relying Advisors, which are controlled by the Advisor, are set forth below:

Whitebox Advisors London, LLP Whitebox Advisors Australia Pty Ltd. Whitebox Capital Management LLC

Whitebox is also affiliated through common control with Whitebox General Partner LLC, the General Partner to all of the Private Funds with the exception of Whitebox Caja Blanca Fund, LP (where separate affiliates, Whitebox Caja Blanca GP LLC for Whitebox Caja Blanca Fund LP serve as General Partner). Many of the Whitebox Private Funds are structured utilizing a “master-feeder” style structure, pooling assets from individual investors (limited partners or shareholders) through the use of onshore and offshore feeder funds.

Shared Personnel and Services Arrangements

Whitebox and its Relying Advisors have entered into a shared staffing and services arrangement whereby the Advisor provides certain services such as accounting and other support to the Relying Advisor. The Relying Advisor bears its proportionate share of the cost of such services and does not allocate any such related costs to Clients. Although fees incurred and paid for such services generally are expected to be competitive with the market, there is an incentive for Relying Advisors to employ Whitebox rather than third parties even though a third-party could provide the same or higher quality services.

The Advisor manages proprietary capital on behalf of affiliated persons. Such proprietary accounts are not prohibited from holding the same positions as Clients or taking actions which are different from those for Clients. Accordingly, proprietary trading could adversely affect the Clients’ performance and affect Clients’ trading activity.

Trading Code of Ethics

Whitebox has adopted a Code of Ethics (the “Code”) pursuant to Rules 204A-1 and 204-2 under the Advisers Act. The Code sets out expected standards of conduct from its employees and is designed to address conflicts of interest related to personal trading. A copy of Whitebox’s Code of Ethics is available, at no cost, to Clients and investors upon request at the contact details listed on the cover page of this brochure.

In order to seek to mitigate conflicts of interest with Whitebox investment activities on behalf of its Clients, personal securities trading by Whitebox personnel are generally permitted in certain exempt securities, through accounts as to which the employee has ceded influence and control, or as otherwise set forth in the Code. Additionally, subject to the conditions of the Code, Whitebox and its personnel can invest in Private Funds and other vehicles managed by the Advisor or other managers that invest in assets, employ strategies or have investment objectives substantially similar to strategies and investment objectives offered by Whitebox.

In addition to the Code, Whitebox has other policies and procedures reasonably designed to address conflicts of interest with respect to, among other things, gifts and entertainments, outside business activities and political contributions. The Advisor also has policies reasonably designed to prohibit its personnel from trading securities for Clients or themselves or recommending to others trading in securities while in possession of material, non-public information (“MNPI”) or disclose MNPI to any person not entitled to receive it. By reason of its various investment activities, Whitebox will have access to MNPI. When in possession of MNPI, the Advisor and its personnel will generally be unable to take action or effect transactions in certain investments even when such investments benefit a Client. While the Advisor has designed and implemented policies and procedures reasonably designed to address those situations; there can be no assurance that such policies and procedures will prevent Whitebox from receiving MNPI and becoming subject to trading restrictions.

Conflicts of Interest relating to Client Transactions Allocation of Investment Opportunities

Whitebox advises multiple Clients with similar investment strategies and overlapping investments, which creates conflicts of interest in, among other things, allocating investment opportunities. If an investment opportunity is appropriate for more than one Client or proprietary account, Whitebox determines in its sole discretion which Clients and accounts participate in the investment opportunity and to what extent. This could result in a Client receiving no allocation of a particular investment or receiving an allocation of an investment that is more or less than it would have received if Whitebox did not have other Clients eligible to invest. Accordingly, allocations often result in non-pro rata allocations.

Whitebox has policies and procedures reasonably designed to allocate investment opportunities to Clients and proprietary accounts in a manner it deems in its sole discretion to be fair and equitable over time consistent with the Client’s investment strategy, guidelines and objectives. Under this policy, Whitebox has significant discretion in applying and weighing factors it deems relevant when determining which Client portfolios receive an investment allocation and to what extent. Such factors include, among others, target returns/yields, concentration, market conditions, internal risk policies, regulatory concerns, expected duration of an investment, maturity constraints, cash positions or cash needs, risk limits and profiles, and any other factor, to the extent relevant to each eligible Client as determined by Whitebox in good faith. When launching a new Client portfolio or taking in significant subscription flows, Whitebox expects to allocate a larger portion to such portfolio during such ramp up period, with existing Clients receiving potentially less than they otherwise would have. Clients with targeted investment strategies, objectives or risk parameters (“Limited Mandates”) have less flexibility to invest across multiple asset classes. In cases where there is a limited offering that Whitebox determines, in its discretion, aligns with such Client’s Limited Mandates, these Clients are likely to receive a larger allocation or the entire allocation of an investment opportunity. While Whitebox believes that making allocations to Clients with a Limited Mandate results in more equitable allocations over time, application of these considerations will often result in non pro rata allocation, when other Clients receive a smaller allocation or none at all.

Where Whitebox is allocating an investment opportunity in or relating to an existing investment (“Follow On”), it generally will be allocated in the same proportion as the original investment. However, due to consideration of other factors or Whitebox’s good faith belief that it would not otherwise be appropriate for a Client to participate (or fully participate) then the remainder of such Follow-On investment would be allocated in a manner deemed fair and equitable over time. In certain circumstances, when allocating opportunities, Whitebox’s focus on constructing fully invested CLO portfolios results in: (i) allocating more or all of an opportunity to new or ramping CLOs, (ii) allocating certain investments to accounts or vehicles for purposes of improving applicable portfolio tests or satisfying applicable risk retention requirements, or (iii) allocating one or more investment to CLO warehouses or other proprietary or Client accounts that maintain such investments temporarily in anticipation of contributing such investments to a newly organized CLO or other pooled investment vehicle.

Whitebox can, but is not obligated to, offer co-investment opportunities to its affiliates and/or third parties (including existing and prospective Clients and investors) for investment either directly or through the formation of one or more co-investment vehicles. Whitebox has sole and complete discretion to determine whether and to whom a co-investment will be offered and, in doing so, will likely take into account its own interests. Unless provided to the contrary in Client Documentation, no Client or investor has any right, and should not expect, to participate in a co-investment. In the Advisor’s sole discretion, certain co-investors pay no or reduced fees and expenses, including management fees, carried interest and administrative fees. In addition, in certain cases, such coinvestment vehicles or other co-investors will evaluate a potential investment alongside existing Clients. If the potential investment is unconsummated, it is possible that the full amount of any expenses relating to such potential, but unconsummated investment is borne entirely by those Clients which Whitebox expects would have made such investment, and not the Advisor, the coinvestment vehicle or a particular co-investor. In the case of a consummated co-investment opportunity, eligible Clients will receive a smaller allocation of an investment opportunity than if there were no co-investor(s).

From time to time, there could be Clients (“Overflow Clients”) with the objective of receiving an allocation of investments only when Whitebox receives an allocation from an underwriter, syndication agent or issuer which exceeds the amount otherwise deemed appropriate for Clients, as determined by the Advisor in its sole discretion. It is expected that such opportunities are generally allocated first to eligible Clients and then allocated by Whitebox in its sole discretion to co-investors and Overflow Clients. Accordingly, there can be no assurance Overflow Clients or co-investors will be allocated the excess of any appropriate opportunities not taken by the eligible Clients or co-investors. Principal and Cross Trades

When consistent with Client Documentation, Whitebox from time-to-time effects cross trades between Clients (i.e., where a Client buys an asset from or sells an asset to another Client). In such cases, Whitebox’s interests and those of participating Clients can conflict. Whitebox has policies and procedures reasonably designed to address the conflicts which arise in the context of cross trades and to comply with the applicable requirements of the Advisers Act. Transactions between the same Clients or Clients owned directly or indirectly by the same investors are not considered to be cross trades as there is no change in beneficial ownership.

Principal Transactions. To the extent not prohibited by Client Documentation, Whitebox engages in principal transactions (i.e., transactions between Clients accounts and those of Whitebox or affiliates). A conflict arises in these cases because Whitebox and the Client each have an interest in the transaction proceeding at a price favorable to it. This is expected to occur when an entity or Client owned substantially by Whitebox, or an affiliate is a party to the transaction. When Whitebox engages in principal transactions, it will seek to comply with the applicable requirements of the Advisers Act.

Pricing of Cross transactions or Principal Transactions. Whitebox seeks to transfer assets in a cross or principal transaction at a price that is fair to all participants. In determining the price, Whitebox will act in accordance with its relevant policies and procedures.

Selection of Broker-Dealers

Subject to Client Documentation, Whitebox generally has the authority to select trading counterparties, investment amounts, timing and prices when making investment decisions on behalf of its Clients. In doing so, the Advisor is not obligated to choose the counterparty with the lowest possible execution cost but primarily considers whether the transaction represents the best qualitative execution under the circumstances.

Due to the nature of certain illiquid markets, there can be a limited universe of counterparties offering or making a market in instruments for Clients. Often, there is only one counterparty offering an investment and the Advisor frequently does not have multiple counterparties to select from when making a “best execution” determination. From time to time, in order to increase the universe of potential counterparties, Whitebox will seek to transact not only with banks and broker-dealers but transacts with other participants in the financial markets, such as, but not limited to, other private funds and fund managers. This, however, is not always an available option.

For liquid strategies and on those occasions when Whitebox can select from more than one counterparty, it does not solicit competitive bids, seek the lowest trading costs or document the factors considered when determining “best execution.” The Advisor seeks to negotiate and execute Client transactions in a reasonably efficient manner to seek the best overall qualitative execution taking into account factors it deems relevant including, among others, timing, breadth of the market, market conditions, assignment/transfer fees, price, financial stability and execution capability of counterparty, the value of research or market color provided and financing rates, when applicable. Therefore, when selecting trading counterparties, the Advisor does not focus on a single factor; rather, it often, but not always, considers the full range and quality of the services of a counterparty. Transaction cost will be considered but it is not the sole factor used by Whitebox to evaluate execution, even when selecting from multiple counterparties. As such, Whitebox need not and does not solicit competitive bids and does not have an obligation to seek the lowest available commission cost. Moreover, while certain factors can be considered on a trade-by-trade basis, determinations of best qualitative execution are a complex and ongoing process based upon practices unique to a particular market, relationship and market conditions. Whitebox gives consideration to placing transactions with counterparties who provides research and other services to the Client or the Advisor. Research published by counterparties can be provided to and used by the Advisor in providing its advisory services to Clients. Such research and information are sometimes free of charge and not available for sale. Such research includes written or verbal information about specific borrowers, or sectors, market and financial commentary, economic studies, forecasts, pricing services as well as discussions with research personnel and borrower management. Further, the Advisor has an incentive to select counterparties based on a desire to continue receiving such information and services, as doing so saves Whitebox the time and expense of developing such research internally or paying for such research with its own “hard dollars”. Therefore, when the Advisor uses commissions to obtain research or services, it receives a benefit because it does not have to use its own hard dollars to pay for such research or services.

Brokerage arrangements will not be uniform across all Clients. Certain Clients have custodial, clearing or financial arrangements (including ISDA agreements, margin or lending agreements) with counterparties that do not have similar arrangements or terms with other Clients.

Whitebox personal are sometimes offered gifts and entertainment from counterparties with whom it conducts business. This can include tickets to sporting events, meals and other items of value. Whitebox has a gifts and entertainment policy designed to address conflicts of interest related to the receipt of gifts and entertainment from Whitebox trading counterparties.

The Advisor utilizes multiple broker-dealers as "prime brokers." Prime brokers provide various services to the Advisor and its Clients, including centralized administration, capital introductions to prospective Clients or investors, custody, and consolidation of all trading activities into a single account, with all trades cleared and settled at the prime broker. Prime brokers also provide financing in connection with client transactions. Research and Other Soft Dollars Benefits

Where best price and execution may be obtained from more than one broker or dealer, the Advisor will purchase and sell securities through brokers or dealers who provide research and execution-related products and services, although Clients may not necessarily be the direct or indirect beneficiaries of the research and/or services provided. Such information, research, products, or services are used to service all Clients and are not exclusive to the Clients participating in a particular trade. Accordingly, research and services are not used solely for the particular Client which generated the soft dollars but are used to service other Clients (including proprietary accounts or Clients where the Advisor or its principals have a pecuniary interest) even when those Clients did not generate any soft dollars.

When the Advisor determines it is in the best interest of Clients to obtain certain products or services using “soft dollars”, such use of commissions or “soft dollars” generated by the Clients will fall within the safe harbor created by Section 28(e) of the Exchange Act.

Whitebox has entered into a commission sharing arrangement (“CSA”). The CSA permits Whitebox to enhance the quality of execution and consolidate payments for research services using accumulated Client commissions from securities transactions with certain executing brokers whereby the executing broker agrees to an “execution only” commission rate to be subtracted from the “full service” commission rate. The executing broker retains the execution only commission portion as payment for execution services and the balance of the commission will be redirected to one or more third parties, determined by Whitebox, as payment for research services that they have provided. Pursuant to the CSA, the broker-dealer sponsoring the CSA program maintains the balance of commissions in a consolidated account (commission credits) on behalf of Whitebox. Upon Whitebox’s instruction, the broker-dealer directs commission credits to providers of research services. Whitebox makes a good faith determination as to the value of the research services obtained through the commission sharing program and may obtain input as to the value of such research services from the service providers participating in the program. The research service providers are compensated directly by the broker-dealer sponsoring the CSA from a pool of commissions that are set aside by the broker-dealer for use by Whitebox to obtain the research services.

Eligible products or services provided to the Advisor or an affiliate pursuant to these “soft dollar” arrangements include, among others, research reports on industries and companies, economic surveys and analyses, recommendations as to specific securities and other eligible execution-related products and services providing assistance to the Advisor in the performance of its investment decision making responsibilities. The Advisor can also utilize these “soft dollar” arrangements for non-research assistance, such as execution services.

Trade Errors

Trade errors will occasionally occur. Whitebox seeks to detect and correct errors promptly and in accordance with its trade error policy. Consistent with Client Documentation and its trade error policy, unless Whitebox determines in its discretion that an error resulted from its gross negligence, bad faith or willful misconduct, any gains or losses from trade errors will be borne by Clients. As a result, Clients and not Whitebox, will generally bear losses from trade errors.

Pending Regulatory Rulemaking

The SEC currently has multiple rule proposals pending which affect the activities of investment activities, including Whitebox. Should these proposals become effective, Whitebox expects that its policies will be amended in order to comply with such finalized rules. Accordingly, to the extent that the disclosures describing the Advisor’s policies cease to be accurate, Whitebox plans to update the related disclosures as required.

Other than the compensation described in Items 5 and 6 herein, and the “Research and Soft Dollar Benefits” discussed in Item 12, Whitebox does not receive an economic benefit from anyone other than its Clients.

Whitebox has entered into solicitation agreements or placement agent agreements to identify and solicit investors in its Private Funds. Subject to the terms of these agreements, the placement agent or solicitor will receive compensation from the Advisor for introducing investors to the Advisor based generally on a percentage of the Management Fee and/or Incentive Compensation generated from the investment from such investors in Private Funds. In the event that the investor or Private Fund is responsible for compensation to the placement agent, the fee arrangement is disclosed to investors. Generally, the placement agent is not a current client of the Advisor and is not an investor in a Private Fund, although it is possible that one or more affiliates of the placement agent or

employees of the placement agent or solicitor or its affiliates may be, or may subsequently become, a Client of the Advisor or an investor in a Private Fund. The placement agent and its affiliates can have additional relationships with the Advisor or other Private Funds managed by the Advisor which may create conflicts of interest because the Advisor could have an incentive to select the placement agent or solicitor as a service provider to the Fund, i.e., prime broker or trading counterparty, because it is raising assets for the Advisor by referring investors. The placement agents for the relevant Private Fund are identified on Item 7B of Part 1A of the Advisor’s Form ADV. Certain placement agents for Clients will also, among other things, act as prime broker or trading counterparty to Clients, execute transactions at the direction of Whitebox, provide financing and securities on loan, hold cash and short balances, as well as provide other customary services such as capital introduction, marketing assistance, consulting with respect to technology, operations, and equipment, commitment of capital, access to company management and access to deal flow. This creates a conflict of interest in that Whitebox can be incentivized to place an increased number of transactions through affiliates of such placement agents or finance a larger portion of the Client assets, as compensation for solicitation activities. Notwithstanding the above, Whitebox has implemented controls designed to seek “best execution” of Client transactions as set forth in Section 12. Brokerage Practices. Whitebox utilizes the services of broker-dealers who execute transactions, provide financing and securities on loan, or hold cash or short balances, provide capital introduction, marketing assistance, consulting with respect to technology, operations, and equipment, commitment of capital, access to management, and access to deal flow.

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

Generally, Client portfolios are reviewed by a portfolio manager and Whitebox risk management on an ongoing basis to monitor, among other things, performance, position sizing, market exposure and strategy analysis. Typically, such reviews are informal and undocumented in the discretion of Whitebox. Settlement specialists, an independent third-party administrator and Whitebox Fund Accounting reconcile cash and securities and resolve trade breaks on an ongoing basis. Counterparty margin requirement, collateral posted, and excess cash are monitored. An independent third-party administrator performs a periodic accounting review and reconciliation.

Whitebox is deemed to have custody of Client assets pursuant to Rule 206(4)-2 of the Advisers Act (the “Custody Rule”) as a result of its affiliate serving as general partner to the Funds. In such instances, Whitebox seeks to comply with the applicable requirements of the Advisers Act. For CLOs, Whitebox does not have access to CLO assets which are custodied with the CLO trustee and does not consider that it has custody of CLO assets. For Private Funds which are not CLOs, Whitebox expects to comply with the custody rule by providing on an annual basis, audited financial statements to Fund investors in relevant Private Funds, as required under the Custody Rule.

Whitebox urges Clients and investors to carefully review the custodian statements, and to the extent such Clients and investors also receive statements from Whitebox, such Clients and investors should also compare Whitebox statements with those from the applicable custodian. Clients should contact Whitebox if they have not received custodian statements or have any questions about their statements.

In general, and consistent with Client Documentation, Whitebox has full discretion to make investment decisions on behalf of Clients, including authority to make decisions with respect to the amount, price, counterparties, and when permitted, hedging decisions. Such discretion is exercised in a manner consistent with the stated investment objectives for the Client, and not individually to investors in Private Funds or to CLO note or equity holders.

Whitebox has adopted proxy voting policies and procedures designed to be consistent with the requirements of the Advisers Act. Pursuant to these policies, where Whitebox is authorized, consistent with Client Documentation, to vote proxies, Whitebox votes in a manner it believes serves the best economic interest of its Clients or avoids a negative impact. Generally, but not always, Whitebox will vote in accordance with recommendations received from a third-party research provider. Notwithstanding, Whitebox is not required to vote in line with management recommendations or the recommendations of a proxy research when it believes these recommendations do not serve the best economic interests of relevant Clients. Likewise, Whitebox abstains from voting specific proxies, if it believes that doing so serves the best economic interests of its Clients or avoids a negative impact. Further, Whitebox can determine not to vote proxies under other circumstances, including, where it no longer holds a position, it has a short position or the position is subject to stock loan, the position is the result of a hedge or where the expense or administrative burden of voting a proxy is prohibitive or outweighs the benefits of the proxy vote, as determined by Whitebox in its sole discretion. Further, Whitebox generally does not permit Clients or investors to direct its proxy voting decisions, subject to Client Documentation. The Advisor does not anticipate conflicts of interest between the Advisor and its Clients in terms of proxy voting. If it is determined, however, that a conflict of interest or potential conflict of interest is material, Whitebox will seek to resolve or mitigate such conflict.

Whitebox has engaged a third-party to process its votes based on recommendations from a separate third-party research provider. Such third-party fees and expenses, if any, are expected to be paid by Clients, to the extent consistent with Client Documentation. Clients and investors can obtain a copy of Whitebox’s proxy voting policy or a record of Whitebox’s proxy votes with respect to their account free of charge at the contact details listed on the cover page of this brochure. With respect to its credit strategies, the Advisor is often asked to consent to waivers or amendments to credit agreements or to make elections with respect to corporate restructurings. Such actions do not constitute proxy votes. When evaluating such requests, Whitebox generally acts in a manner designed to serve the best economic interests of its Clients or to avoid a negative impact on Clients, taking into account, as relevant, the impact on the value of the investment, anticipated costs and benefits, amendment fees, industry standards and practices and conflicts of interest. Amendment fees are for the account of the relevant Clients, and not the Advisor.

With respect to class actions, Whitebox has appointed an unaffiliated third-party, to monitor and file class action settlements on behalf of Clients. Any compensation received as the result of participation in a class action settlement shall be paid to relevant Clients in proportion to its holdings. For its services, the third-party is paid based on a percentage of the proceeds recovered from a class action filing. As such, Clients bear the cost (i.e., receive a reduced amount of the class action proceeds) of any third-party used for class action recovery services.

In certain circumstances, registered investment advisers are required to provide financial information or disclosures about their financial condition in this Item 18. Whitebox has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to Clients and has not been the subject of a bankruptcy proceeding.

Privacy Notice

WHAT DOES WHITEBOX DO WITH YOUR PERSONAL INFORMATION? Financial companies choose how they share your personal information. Federal law gives our clients the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. We do not disclose nonpublic personal information about our clients or former clients to third parties other than as described below. INFORMATION WE COLLECT.

We collect personal information about you in connection with our providing advisory services to you. For purposes of this policy “Personal information we collect. We collect personal information about you in connection with our providing advisory services to you. This information includes your social security number and other information, including but not limited to:

Assets;

Investment experience;

Transaction history;

Income; and

Wire transfer instructions.

HOW WE COLLECT THIS INFORMATION. We collect this information from you through various means,

for example when you give us your contact information, enter into an investment advisory contract with us, buy securities (i.e., interests in a fund) from us, tell us where to send money, or make a wire transfer. We also may collect your personal information from other sources, such as our affiliates or other nonaffiliated companies.

HOW WE USE THIS INFORMATION. All financial companies need to share customers’ personal information to run their everyday business, and we use the personal information we collect from you for our everyday business purposes. DISCLOSURE TO OTHERS. We provide your personal information to our affiliates and to firms that assist

us in servicing your account and have a need for such information, such as a broker or fund administrator. We also disclose such information to service providers and financial institutions with whom we have joint marketing arrangements (i.e., a formal agreement between nonaffiliated financial companies that together market financial products or services to you, such as placement agents). We require third-party service providers and financial institutions with which we have joint marketing arrangements to protect the confidentiality of your information and to use the information only for the purposes for which we disclose the information to them. These sharing practices are consistent with Federal privacy and related laws, and in general, you may not limit our use of your personal information for these purposes under such laws. We note that the Federal privacy laws only give you the right to limit the certain types of information sharing that we do not engage in (e.g., sharing with our affiliates certain information relating to your transaction

history or creditworthiness for their use in marketing to you, or sharing any personal information with nonaffiliates for them to market to you). HOW WE PROTECT YOUR PERSONAL INFORMATION. To protect your personal information from unauthorized access and use, we use security measures designed to comply with Federal law. These measures include computer safeguards and secured files and buildings. WHO IS PROVIDING THIS PRIVACY NOTICE. This Privacy Notice relates to Whitebox Advisors LLC, together with its affiliated entities, and the funds that are managed by them. WHO TO CONTACT WITH QUESTIONS. If you have any questions about this Privacy Notice, contact Investor Relations at invrelations@whiteboxadvisors.com.