WL ROSS & CO LLC

This Item 4 requires an investment adviser to describe its advisory business, including the types of services offered, whether the investment adviser specializes in a particular type of advisory service and the amount of assets managed by the investment adviser. WLR, a Delaware corporation formed in 2000, was acquired in 2006 by Invesco Ltd. (“Invesco”), a publicly held global investment management company with offices throughout the world that trades on the New York Stock Exchange (NYSE: IVZ). WLR is directly owned by Invesco Private Capital, Inc. (“IPC”), a subsidiary of Invesco, and has been registered with the SEC since 2007. WLR is headquartered in Dallas, Texas. WLR provides investment advisory services to institutional investors through private investment funds (each, a “Fund,” and collectively, the “Funds”) and co-investment vehicles (the Funds and other vehicles are collectively referred to herein as “Client” or “Clients”). WLR’s primary investment strategy is Private Equity (referred to herein as “Invesco Private Equity” or “IPE”) which is described in Item 8 in this brochure. Effective March 31, 2021, WLR entered into two sub-advisory agreements (the “Agreements”) with BPGC Management, LP (“BPGC”) (formerly known as Broadpeak Global, LP), an SEC registered investment adviser. BPGC was engaged to provide nondiscretionary advisory and other services with respect to certain of its Client accounts. In connection with providing these services, BPGC monitors and continues to provide day-today oversight of such Client accounts and participate on the investment committees formed by WLR and other governance bodies controlling portfolio investments as approved by WLR. In addition, BPGC assists WLR in monitoring and servicing legacy assets by performing due diligence on any prospective dispositions in coordination with WLR. In the first half of 2025, WLR terminated one of the Agreements with BPGC in light of the continued winddown of the WLR business. WLR Funds. WLR provides investment advisory services to Funds structured as pooled investment vehicles excepted from SEC registration under the Investment Company Act of 1940, as amended (the “Investment Company Act” or “1940 Act”). These Funds’ securities are also exempt from registration with the SEC under the Securities Act of 1933, as amended (the “Securities Act”). Investment advisory services are provided directly to the Funds, subject to the direction and control of the affiliated general partner of each Fund. Investment guidelines and restrictions, if any, for each Fund managed by WLR are based upon the investment objectives and limitations of each Fund as stated in the Fund’s offering materials, disclosure documents, management agreements and/or other governing documents (each, a “Governing Document,” and collectively, the “Governing Documents”). WLR does not tailor its investment management to the individual needs of any Fund investor. Co-Investment Opportunities. WLR has provided co-investment opportunities to existing Clients, or other strategic investors, subject to certain terms and conditions.

WLR also provides investment advisory services to an employees’ securities company, which is an employer-sponsored investment company, the beneficial owners of which include certain current and former employees. The employees’ securities company is offered as a parallel vehicle to a Fund. Certain Clients have entered into advisory arrangements with WLR whereby investment discretion is not exercised by WLR. As of December 31, 2025, WLR managed $224,585,127 of Client assets on a discretionary basis.

This Item 5 requires an investment adviser to describe how it is compensated for its advisory services, as well as what other costs are borne by an advisory client.

Management Fees. Management fees are no longer charged to Clients but were previously charged to Clients consistent with governing documents and generally paid in arrears. Carried Interests. In addition to management fees, WLR or the general partners of the Funds are permitted to receive, if earned, distributions of carried interests or profits of up to 20% of profits earned on investments typically above a preferred return hurdle. Typically, carried interest distributions are also subject to a catchup on the preferred return and a clawback if such distribution exceeds the stated rate. Other Fees or Expenses. WLR and its affiliates were entitled to additional fees that were offset against management fees as permitted by Client governing documents. WLR’s ability to receive fees (and related expense reimbursements) from portfolio companies for performing consulting and other services for, or serving as directors (or similar positions) of, such portfolio companies represents a potential conflict of interest to the extent that the Fund and/or Client account has or will have control or significant influence over such portfolio companies, although this potential conflict of interest is mitigated by the fact that the amounts of such transaction fees are typically negotiated with the applicable portfolio company’s management team and/or any roll-over equity holders, as well as the fact that a portion of the Fund’s and/or Client account’s proportionate share of any such fees (net of unreimbursed expenses and excluding any expense reimbursements), will be credited against future management fees (or previously-charged management fees, if applicable) in accordance with the applicable Fund’s and/or Client account’s Governing Documents. Co-investors will typically bear their pro rata share of fees, costs and expenses related to the discovery, investigation, development, acquisition or consummation, ownership, maintenance, monitoring, hedging and disposition of their co-investments and may be required to pay their pro rata share of fees, costs and expenses related to potential investments that are not consummated, such as breakup fees or broken deal expenses. WLR endeavors to allocate such fees, costs and expenses on a fair and equitable basis. In some instances, co-investors may not agree to pay or otherwise bear fees, costs and expenses related to unconsummated coinvestments (and in certain circumstances, co-investors may not bear such fees, costs and expenses because they have not been identified as of the time such potential investment ceases to be pursued). In such event, such fees, costs and expenses will be considered operating expenses of and be borne by the relevant Fund. In addition to the various fees above, Clients, specifically the Funds, could bear certain other fees and expenses, as permitted by the Governing Documents, which are incidental or related to the management and operation of the Funds and are permitted under the Governing Documents. These Fund fees and expenses include, but are not limited to: all costs and

expenses relating to their operations, activities, investments and business that are not reimbursed by a portfolio company or portfolio fund (which reimbursements may be for travel, including, in certain circumstances, meal and entertainment expenses, and other expenses incurred in connection with such Fund investment) or applied to reduce transaction fees (as defined by the relevant Fund’s Governing Documents), including, but not limited to: (a) legal, auditing, consulting, expert network, and accounting fees and expenses (including costs of reports to the partners, financial statements, tax returns, tax estimates and Schedule K-1s and any other Fund related reporting, and all costs associated with the Funds’ administration or filing obligations (including (i) expenses incurred in connection with the payment to a third party administrator, if applicable, for the performance of services including administrative and back-office services and (ii) expenses and costs associated with any software or online data portal used in connection with the maintenance of the Funds’ books and with such reporting)); (b) any taxes, fees or other governmental charges levied against the Funds or on their income or assets in connection with their business or operations and all expenses incurred in connection with any tax audit, investigation, settlement or review of the Funds, in each case, except to the extent such amounts are (i) allocable to, or subject to indemnification by, a partner and (ii) actually borne or paid by such partner; (c) all expenses and costs incurred in connection with compliance with any applicable regulatory regimes as may be required by applicable laws, rules and regulations, including the Dodd-Frank Wall Street Reform and Consumer Protection Act, any applicable Commodity Futures Trading Commission Rules, and any regulatory filings required to be made in respect of the Funds or any Alternative Investment Vehicle or Feeder Fund (including FATCA, Form PF and those relating to the Alternative Investment Fund Managers Directive (the “AIFM Directive”), but excluding Form ADV); (d) custodial fees, commissions, other fees and expenses arising from its operations; (e) expenses and fees incurred in connection with the identification, investigation, structuring, acquisition, holding, organizing, managing, operating, valuing, winding up, liquidating, dissolving and disposition of the Funds’ proposed or actual portfolio investments, whether or not consummated (including due diligence in connection therewith and refinancing thereof), including, but not limited to, interest on money borrowed by or on behalf of the Fund, legal, accounting, audit, consulting, travel, meals, entertainment, hedging, attendance at conferences in connection with the evaluation of potential portfolio investments or specific sectors or industries to the extent such conferences are in furtherance of the Funds’ business, and other expenses (to the extent not subject to reimbursement); (f) appraisal fees and expenses, including, but not limited to, the cost of obtaining from an independent appraisal firm a valuation of the portfolio investments held by the Funds as of the end of each fiscal year and expenses incurred in connection with other third party valuations; (g) any expenses and costs incurred in connection with a proposed portfolio investment that would have been allocable to co-investors had such proposed transaction or investment been consummated, if the amount allocable to such co-investors is not paid by such parties; (h) commissions, brokerage fees, custody fees, legal fees and expenses or similar charges incurred in connection with the purchase and sale of securities; (i) distressed loan servicing fees; (j) reasonable expenses of the members of the advisory board earned, charged or incurred in their capacity as such; (k) all fees, expenses and settlements related to hedging transactions; (l) all expenses relating to litigation and threatened litigation, investigation, indemnifications, settlements or reviews or other extraordinary events involving the Funds and the amount of any judgments or

settlements paid in connection therewith (except for legal expenses related to litigation, investigation settlements or reviews or other extraordinary events arising from acts or omissions of the general partner, its agents or employees as to which it has been determined that the Fund’s general partner, its agents or employees has engaged in disqualifying conduct as defined by the applicable Funds’ Governing Documents); (m) fees and expenses of independent accountants for formal accounting systems and the preparation and review of financial statements, other reports and filings to or for partners; (n) fees and expenses for banking, investment banking, legal, accounting and/or custodial services, and other services supplied by independent collateral agents and other specialized professional service firms, in each case provided to the Funds at the request of its general partner or members of its advisory board; (o) all insurance premiums or similar expenses incurred in connection with the activities and management of the Funds (including directors and officers, errors and omissions liability and other insurance); (p) fees incurred by the Funds for special advisory or consulting services; (q) expenses for the operations and maintenance of any other entity formed as an affiliate of the Funds for the purpose of making portfolio investments or conducting other permitted activities of the Funds; (r) the cost of forming and maintaining alternative investment vehicles and any holding vehicles formed in connection thereto; (s) expenses incurred for the holding of general meetings of the limited partners and related meal and entertainment expenses, if any; (t) all expenses incurred in connection with any indebtedness of the Funds; (u) all expenses of liquidating the Funds; and (v) all other costs incurred in connection with the administration of the Funds or otherwise that may be authorized by the Funds’ limited partnership agreement or Governing Documents or approved by a majority in interest of the limited partners or the advisory board. WLR provides personnel, office space and facilities to the Funds, and assumes all routine expenses (such as salaries, support services, rent, telephone, utility and travel expenses) of conducting the Funds’ investment activities. In certain instances, the Firm has appointed service companies to act as service providers to portfolio companies owned by those Clients. Such Clients are charged fees on an arm’s length basis. Similarly, WLR may provide certain fund administration services to a Fund rather than engage a third-party administrator to perform such services. The costs for providing these fund administration services performed by WLR employees to various Funds are not included in the management fee and are charged to the relevant Funds. These relevant Funds currently reimburse WLR for accounting services provided by WLR’s accounting personnel. These charges for fund administration services performed by WLR employees to various Funds are only applied as permitted by the respective Client’s Governing Documents. WLR’s ability to determine the fund administration fee it receives from such Funds creates a conflict of interest. WLR addresses this conflict by reviewing its fund administration fee at least annually to ensure that it is comparable and fair with regard to equivalent services performed by nonaffiliated third-party administrators at a rate negotiated on an arm’s length basis. Whether an expense is a Client or Firm expense is memorialized in the respective Client’s Governing Documents. Expense allocation determinations are made in accordance with the Firm’s Fees and Expenses Processing and Allocation Policy and the applicable Clients’ Governing Documents. In general, expenses are allocable pro rata to each Client that receives

the benefit of such expense. At times, certain expenses, such as board of directors’ travel, litigation or research, are reimbursed by portfolio companies.

This Item 8 requires an investment adviser to describe its investment strategy and methods of analysis, including risks associated with such strategy and methods of analysis. In addition, an investment adviser must disclose that investing in securities involves risk of loss that clients should be prepared to bear. The investment strategies, methods of analysis, and risks associated with each strategy are described below. The specific investment strategy and corresponding method of analysis for each Client will be specified in more detail in Governing Documents of such Client. Investing in each strategy involves risk of loss that Clients should be prepared to bear. The summary of risks below may not be applicable to all Funds or Clients and does not purport to be a complete list or explanation of all risks involved. Methods of Analysis. WLR advises private equity funds and other investment vehicles that invest capital for long-term appreciation, primarily either through control or significant influence of companies or minority positions. As discussed in Item 4 of this brochure, WLR and BPGC entered into an Agreement whereby BPGC provides non-discretionary advisory services to WLR in respect of certain WLR-managed Client accounts. In connection therewith, BPGC personnel, affiliates and representatives participate in investment committees and other decision-making bodies for certain Client accounts as approved by WLR. WLR is in the process of winding down certain Clients and otherwise manages existing portfolios and is not intending to launch new vehicles nor make new acquisitions. Investment Strategies. WLR is in the process of winding down certain existing portfolios and is not intending to launch new vehicles or new investment strategies. Risks. Any investment includes the risk of loss and there can be no guarantee that a particular level of return will be achieved. While WLR seeks to mitigate risks so that they are appropriate to the return potential for a Client or strategy, it is usually not possible or desirable to fully mitigate risks. Prospective investors should carefully consider the following risks, along with those risk factors described in the applicable Client’s Governing Documents. There can be no assurance that investment strategies will be carried out successfully. Investors in fund Clients should understand that they could lose some or all of their investment and should be prepared to bear the risk of such potential losses. WLR may invest in securities and obligations of domestic and foreign companies that are experiencing significant financial or business difficulties. Although such investments may result in significant returns, they also involve a high degree of risks. Any or all investments may be unsuccessful and therefore result in complete loss of committed capital. Client investments may not show a return for a considerable period of time. There is no assurance that WLR will correctly evaluate the value of a company’s assets or the prospects for a successful reorganization or similar action. The risk factors briefly summarized below may not be applicable to all Funds or Clients. This summary does not purport to be a complete list or explanation of the risks involved in an investment in a Fund or Client. The Governing Documents for each Client typically include

a more detailed summary of material risks applicable to that Fund’s or Client’s investment strategy and structure and should be read in conjunction with the risks below. Investments made by the Funds and Clients, including private equity investments, involve a number of material risks including, but not limited to, the following: General Risks Relating to the Sub-Advisory Arrangement. The effective operation and disposition of certain WLR Funds and legacy investments was highly dependent on the cooperation and consensus of WLR and BPGC. Disputes between WLR and BPGC or the inability or refusal of any one party to perform its obligations under the Agreements could have an adverse effect on WLR’s ability to perform such services with respect to certain of its Client accounts. Illiquid and Long-Term Investments. Most Fund and Client investments are highly illiquid, and there can be no assurance that a Fund or Client will be able to realize these investments in a timely manner. The realizable value of a highly illiquid investment at any given time may be less than its intrinsic value. Although certain of these investments may generate current income, the return of capital, and the realization of gains, if any, with respect to these investments will occur only upon the partial or complete disposition of the investment. While an investment may be sold at any time, typically this will occur a number of years after the investment is made and there can be no assurance that a Fund or Client will be able to dispose of an investment at the price and time it wishes to do so. Certain private equity investments may be in securities that are or become publicly traded. Valuations. As most Client investments are highly illiquid, there are no readily ascertainable market prices for such investments. For these investments, the fair value of the investment represents the value, as determined by the Firm in good faith, at which the investment could be sold in an orderly disposition over a reasonable period of time between willing parties other than in a forced or liquidation sale. There is no single standard for determining fair value in good faith and in many cases fair value is best expressed as a range of fair values from which a single estimate may be derived. When making fair value determinations for private equity investments, the Firm generally follows the procedures set out in its Valuation Policy. Because there is significant uncertainty in the valuation of, or in the stability of the value of, illiquid investments, the fair values of investments reflected in a Client’s net asset value, or NAV, do not necessarily reflect the prices that would actually be obtained by the Firm on behalf of such Client when such investments are realized. For example, there may be liabilities such as unknown or uncertain tax exposures with respect to investments, especially those outside the United States, which may not be fully reflected in valuations. Realizations at values significantly lower than the values at which investments have been reflected in prior NAVs would likely result in losses for the applicable Client. The exercise of discretion in valuation by the Firm may give rise to conflicts of interest, including in connection with determining the amount and timing of distributions of carried interest and the calculation of management fees.

Global Market and Economic Risks. Client investment strategies have been materially affected by global market, economic and political conditions particularly in the jurisdictions and sectors in which WLR invests. Interest rates, credit availability, currency exchange rates, illiquidity and volatility in the global financial markets could have material adverse effects on WLR investments. WLR and its Clients are subject to the risk that geopolitical events and instability will disrupt securities markets and adversely affect global economies and markets. Due to the increasing interdependence among global economies and markets, conditions in one country, market, or region might adversely impact markets, issuers and/or foreign exchange rates in other countries, including the U.S. War, terrorism, global health crises and pandemics, and other geopolitical events have led, and in the future may lead, to increased market volatility and may have adverse short- or long-term effects on U.S. and world economies and markets generally. Inflation Risk. Client investments may be exposed to inflation risks. Market prices generally fall as inflation increases because the purchasing power of the future income and repaid principal is expected to be worth less when received by WLR. Investments that pay a fixed interest rate are especially vulnerable to inflation risk as opposed to variable-rate securities that may be able to participate, over the long term, in rising interest rates which have historically corresponded with long-term inflationary trends. Most high yield investments pay a fixed rate of interest and are therefore vulnerable to inflation risk. Interest Rate Risk. Client investments may be exposed to interest rate risks. Changes in prevailing market interest rates could negatively affect the value of such investments. Market interest rates may be affected by inflation, slow or stagnant domestic and global economic growth or recession, unemployment, money supply, governmental monetary and fiscal policies, international disorders and instability in domestic and foreign financial markets. Clients may periodically experience imbalances in the interest rate sensitivities of their assets and liabilities and the relationships of various interest rates to each other. In a changing interest rate environment, WLR may not be able to manage this risk effectively and as a result performance could be adversely affected. Non-U.S. Investments. WLR made non-U.S. investments on behalf of its Clients. Investments in businesses operating and/or organized outside of the United States, including in emerging markets, involve risks not typically associated with investments in the securities of U.S. companies. For instance, investments in non-U.S. businesses may be subject to certain additional risks due to, among other things, potentially unsettled points of applicable governing law, possible significant government approvals, the risks associated with fluctuating currency exchange rates, capital repatriation regulations (as such regulations may be given effect during the term of a Client), the application of complex U.S. and non-U.S. tax rules to cross-border investments, international sanctions and conflicts, possible imposition of non-U.S. taxes on a Client and/or the Partners with respect to a Client’s income, and possible non-U.S. tax return filing requirements for a Client and/or the Partners. Investments made in businesses operating in emerging market countries will involve additional risks because the

economies of such countries are volatile and affected by political and social change and instability. The foregoing factors are likely to increase transaction costs and adversely affect the value of a Client’s investments. Currency Risk. Client investments and income received from such investments may be denominated in currencies that are not the base currency of the relevant Client account. Changes in currencies may adversely affect the base currency value of portfolio investments, interest, dividends and other revenue streams received by a Client, gains and losses realized on the sale of portfolio investments, and the amount of distributions, if any, to be made to a Client. A Client may also incur costs in converting investment proceeds from one currency to another. Where practicable, we may enter into hedging transactions on behalf of our Clients designed to reduce such currency risks or may determine not to enter into such hedging transactions. Furthermore, the portfolio companies in which a Client invests may be subject to risks relating to changes in currency values, as described above. If a portfolio company suffers adverse consequences as a result of such changes, a Client may also be adversely affected as a result. Carried Interest; Distributions in Kind. Carried interest may create an incentive for WLR to make riskier or more speculative decisions on behalf of a Client than would be the case in the absence of this arrangement, although WLR’s commitment of capital to the Funds and/or Client accounts should somewhat reduce this incentive. If distributions are made of assets other than cash, the amount of any such distribution will be accounted for at the fair market value of such assets as determined by the Firm in accordance with procedures set forth in the applicable Governing Documents of the Fund and/or Client account. Possession of Material Non-Public Information; Other Restrictions. To the extent WLR or its affiliates become privy to material non-public information (“MNPI”), it may be restricted in its ability to make an investment in or withdraw on behalf of a Fund or other Client account. Additionally, in certain instances, WLR might become restricted in its ability to make an investment in or withdraw from a particular portfolio fund on behalf of a Fund or other Client account even though it may not be privy to any MNPI; such restrictions could be derived from contractual obligations and/or confidentiality obligations, applicable law and/or internal policies and procedures. In such instances, a Fund or other Client account’s ability to make an investment in or withdraw from a particular portfolio fund may be significantly restricted, which may adversely impact such Fund or other Client account, including by preventing the execution of an otherwise advisable transaction (including, a withdrawal, closing or windingdown of a position). Without limiting the above, it should be noted that from time to time, WLR and its affiliates may be subject to contractual “stand-still” obligations and/or confidentiality obligations that alone or in light of applicable law and/or internal policies and procedures adopted by WLR and its affiliates may restrict the Firm’s ability to make an investment in or withdraw from a particular portfolio fund on behalf of a Fund or Client account. Side Letters. WLR has entered into side letters with specific investors supplementing or altering the terms, rights, or provisions of, the applicable Governing Documents of an

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This Item 7 requires an investment adviser to disclose the types of clients that it generally advises and any minimum requirements for opening an account. WLR provides investment advisory services to Funds and through co-investment vehicles. WLR manages assets for its Funds and offered its Funds, either directly or through its affiliate, Invesco Distributors, Inc. (“IDI”), to persons who are “qualified purchasers” as defined in the Investment Company Act, “accredited investors” as defined in Regulation D under the Securities Act, and “knowledgeable employees” as defined in Rule 3c-5 under the Investment Company Act (largely for its employees’ securities companies). Investors in Funds and other Client accounts may include, but are not limited to, a range of U.S. and non-U.S. institutional investors, governmental and corporate pension and profit sharing plans (including investors regulated under the U.S. Employee Retirement Income Security Act of 1974, as amended (“ERISA”), endowments and foundations, financial institutions, insurance companies, private wealth and other third party distribution platforms and certain high net worth individuals and family offices, and sovereign wealth funds. Additionally, WLR and/or its employees and affiliates may make capital contributions to the Funds, the general partners of the Funds and/or employees’ securities companies. For Funds, the minimum investment is $5 million. WLR has the discretion to waive these minimums.

This Item 6 requires an investment adviser that charges performance-based fees to disclose how the investment adviser addresses any conflicts that arise from managing accounts sideby-side where one account bears performance-based fees and the other account does not. Consistent with the provisions of Rule 205-3 under the Advisers Act and as discussed in Item 5, WLR or its affiliated Fund general partners are entitled to performance-based fees in connection with certain of their Fund and/or Client accounts, depending upon the nature and investment strategy of the Fund or Client account. Notwithstanding the fact that the Firm is in the process of winding down certain Clients, each of the Funds’ and/or Client accounts’ investment approach, strategy and focus are defined in the Funds’ and/or Clients’ respective Governing Documents, and the Firm has adopted allocation policies and procedures, subject to certain investment considerations, to handle potential conflicts of interest in relation to investment overlaps among Client accounts, including those with different fee structures. The Firm’s policies and procedures and Code of Ethics are designed to address potential conflicts of interest. WLR, guided by its fiduciary duties, seeks to manage potential conflicts of interest in good faith with the goal of ensuring that during the wind down of the business, dispositions are allocated on a fair and equitable basis subject to the investment guidelines and other relevant provisions of the affected Clients’ Governing Documents.

This Item 10 requires an investment adviser to disclose any material relationship or arrangement that the investment adviser (or any of its management persons) has with any related financial industry participant, any material conflicts of interest that such relationships or arrangements may create, and how the investment adviser addresses these conflicts. Invesco Ltd. WLR is affiliated with Invesco and the many entities within the Invesco global structure, including broker-dealers registered with the Financial Industry Regulatory Authority, Inc. (“FINRA”), as well as SEC-registered investment advisers and non-U.S. investment advisers. For a complete list of all related financial industry affiliations, see Section 7.A. of Schedule D to WLR’s Form ADV Part 1. WLR and Affiliates. WLR also relies on affiliates in providing investment advisory services to its Clients. As a result, certain WLR personnel are also officers, employees, or conduct work for its affiliates. The fact that WLR personnel devote portions of their time and efforts to the activities of affiliates may pose a conflict of interest. This support could also be viewed as creating a conflict of interest in that the time and effort of officers, managers, and employees will not be devoted exclusively to the business of WLR. IPC, WLR, ISSM and the Invesco Ltd. global direct real estate business (together, the “Invesco Private Entities”), are situated on the “private side” of Invesco’s information barrier and share a single restricted list. See Item 11 for a discussion of restricted lists and information barriers governing the activities of WLR’s investment strategies. Some WLR personnel are also officers, employees, or conduct work for, one or more affiliates or joint ventures. The fact that WLR personnel devote portions of their time and efforts to the activities of affiliates may pose a conflict of interest. Board Participation. This is unlikely to be applicable as WLR winds down private positions and real assets; however, employees or officers of WLR have from time to time been members of the boards of directors of companies which resulted from permitted investments of various strategies offered by the Firm. In these cases, WLR has taken steps such as establishing information barriers or placing the security in question on a restricted list, which limited or precluded the purchase or sale of such securities for Clients and Firm employees.

Trading This Item 11 requires an investment adviser to briefly describe its code of ethics and state that a copy is available upon request. An investment adviser is also required to disclose certain conflicts of interest that may arise if an investment adviser has an interest in client transactions or interests along its clients. Code of Ethics and Personal Trading. WLR is subject to a written Code of Ethics (the “Code”), as required under Rule 204A-1 of the Advisers Act, that sets forth standards of ethical conduct for WLR employees and is designed to address and avoid potential conflicts of interest. The Code requires WLR employees to act in a manner consistent with their fiduciary duty to Clients, abide by all applicable rules and regulations, and pre-clear and report personal securities transactions. WLR maintains policies and procedures to avoid insider trading and the appearance of insider trading. Personal trading restrictions apply to all WLR employees as well as certain family members. WLR employees are required to report all brokerage accounts subject to the Code in which they and any immediate family member sharing the same household have a direct or indirect beneficial ownership interest. Further, such persons must generally pre-clear covered securities transactions, including IPOs and private placements, and provide copies of periodic account statements, or have them sent directly by their broker, to the compliance department. The compliance department maintains restricted lists, which include securities that Clients have or are considering purchasing. WLR will provide a copy of the Code to any client or prospective client upon request. Participation or Interest in Client Transactions. WLR employees and affiliates made capital contributions to the Funds and/or the general partners of the Funds and/or coinvestment vehicles. While such investment generally aligns the interests of WLR and such persons with the interests of the Clients, situations could arise in which WLR, or such persons have interests which conflict with the interests of the Clients notwithstanding such commitment. Principal Transactions. In accordance with the anti-fraud provisions of the Advisers Act and with the Firm’s compliance policies and procedures, WLR will not, as principal, sell a security to, or buy a security from, any Client, without providing appropriate disclosure and obtaining the informed consent of such Client prior to the settlement of such transaction. In these cases, a Client may, for example, require that (i) the transaction price be determined to be fair by an independent valuation expert (the cost of which would be borne by the applicable Client) or be calculated in accordance with a formula provided for in the Governing Documents of that Client and (ii) the consent of the respective Client’s advisory board or limited partners be obtained prior to the completion of the relevant transaction or in connection with the limited partners’ subscriptions to that Client’s account. Additionally, prior to the receipt by a Client of capital contributions from its investors for which a capital call notice has been given, a WLR general partner entity may fund such amounts on a temporary basis in order to permit

that Client to make an investment. Such amounts will be reimbursed to that general partner at cost as and when such capital contributions are made by the investors in that Client account. WLR does not consider such temporary arrangements to be principal transactions. Cross Transactions, Co-Investments and Adviser-Led Secondaries. Cross transactions are transactions in which the Firm arranges for a Client to buy a security from, or sell a security to, another Client. In addition, the Firm may cause different Clients to invest at different times in a single portfolio company, for example where a Client that made an initial investment in a portfolio company does not, when an opportunity to make a follow-on investment in the company subsequently arises, have sufficient capital for such investment. From time to time, WLR may determine that a cross transaction between Clients is in the best interest of the relevant Clients. Accordingly, WLR has adopted compliance policies and procedures designed to properly manage such potential conflict of interests. In addition, the Governing Documents of each such Client may impose certain restrictions on the ability of the Firm to effect these transactions. These may include a requirement for the transaction price to be determined by independent valuation sources, approved by an independent valuation expert, determined to be fair to Clients by an independent third party or otherwise calculated in accordance with such Governing Documents. In respect of adviser-led secondaries whereby WLR offers Fund investors the option to sell all or a portion of their interests or convert those interests into a new vehicle, WLR generally will secure a fairness opinion or similar third-party valuation unless otherwise determined by WLR based on the facts and circumstances. Where such transactions are not practical to avoid, such transactions can only be consummated if they are approved by the relevant Clients and/or their advisory board to the extent required by the applicable Clients’ Governing Documents and/or applicable law. Allocation of Fees and Expenses. Fee and expense allocations will be made in good faith in accordance with the Firm’s Fees and Expenses Processing and Allocation Policy and the applicable Clients’ Governing Documents considering all factors deemed relevant. Any expenses shared by more than one Client in connection with evaluating and making consummated portfolio investments of such Clients or broken deals are generally allocated pro rata based on each Client’s invested capital (or, in the case of broken deals, the amount that would have been invested by each Client), as determined by WLR in good faith and in accordance with each Client’s Governing Documents. Allocation of Investment Opportunities. Notwithstanding the fact that the Firm is in wind down, WLR has adopted allocation policies and procedures. In accordance with its fiduciary duty, WLR has sought to allocate investment opportunities to its Clients on a fair and equitable basis in accordance with the Firm’s Allocation of Investment Opportunities Policy and all relevant guidelines and restrictions as outlined in the applicable Clients’ Governing Documents. If a particular investment opportunity fell within the investment objective of more than one Client, WLR has allocated such opportunity (including, any related co-investment opportunities) among such entities taking into account a number of considerations, including

the sourcing of the transaction, the nature of the investment focus of each Client, the relative amounts of capital available for investment, any diversification limitations and restrictions, portfolio diversification, target rates of return, expected hold periods, the possibility that other Clients invested in the same issuer or entered into a buy/sell transaction with such issuer and other considerations deemed relevant by WLR. In light of a shared restricted list and personnel, WLR may experience conflicts of interest among and between itself and the other Invesco Private Entities. WLR personnel are subject to policies and procedures designed to help identify, mitigate and address such conflicts of interest. Outside Business Activities. WLR employees may engage in outside business activities unrelated to their role at WLR, including serving as directors, officers, or employees of unaffiliated public, private or government entities, whether for profit or non-profit, which can give rise to certain conflicts of interests. The Firm’s policies require outside business activities to be pre-cleared and Compliance reviews certain employee certifications to identify such conflicts of interest. Additionally, WLR has adopted a Material Nonpublic Information and Restricted List Policy for the handling of confidential information to prevent the misuse of such information and to avoid situations that may create an appearance of misuse with applicable laws and regulations. Restricted List; Information Barriers. To address instances where WLR may be in possession of MNPI, WLR has adopted certain policies and procedures. These procedures include the establishment of a restricted list where securities are placed on the restricted list upon receipt of MNPI by Invesco Private Entities personnel. One restricted list is maintained among the Invesco Private Entities although, since WLR is in wind down, this has had a minimal impact on its ability to conduct investment activities. The Invesco Private Entities are walled off both physically and virtually from the public side of Invesco Ltd.

This Item 12 requires an investment adviser to describe its brokerage selection, soft dollar, directed brokerage and trade aggregation policies. Broker Selection and Best Execution. To the extent required by applicable law, it is the Firm’s policy to seek best execution of trades (if any) in public equity and other marketable securities traded on behalf of the Clients by a selected broker- dealer. In seeking best execution, goals include timely, fair and cost-effective executions, fairness to Clients, both in priority of order execution and in the allocation of the price obtained in execution of trades, and compliance with Client trading-related mandates and investment restrictions. When appropriate under the Firm’s discretionary authority and consistent with the Firm’s duty to seek best execution, WLR may execute through broker-dealers who provide brokerage and unsolicited research services. Transactions are not always executed at the lowest available commission, and the Firm may effect transactions which cause the Clients to pay more than another broker-dealer would have charged if WLR determines that the additional cost is reasonable in relation to the value of the services provided to the Firm and its Clients. Trading and Brokerage. WLR prohibits the directing of commissions generated from Clients’ brokerage transactions to pay for Client referrals, and the making of any recommendation that “credit” be given to particular individual brokers within a brokerage firm. The Firm generally conducts trading with those broker-dealers that have been vetted through and approved by Invesco. In selecting brokers or dealers, WLR considers various factors, including, without limitation: the reputation, experience and financial stability of the broker-dealer; the ability to maintain WLR’s anonymity; the ability to provide competitive pricing; the size and timing of the transaction; the ability and willingness to commit capital and provide prompt and accurate execution and settlement; whether the broker-dealer makes a market in a security and/or finds sources of liquidity; the nature of the market for the security and the difficulty of execution; the broker- dealer’s trading expertise, including its ability to minimize total trading costs and to trade without unduly impacting the market; the belief that the broker-dealer charges a fair and reasonable fee for each trade, and that the Clients have been treated fairly and honestly in prior trades; and the quality of execution, quality of the broker-dealer relationship, quality of service rendered by the broker-dealer in prior transactions, and quality of any proprietary research and investment ideas. Trade Errors. WLR is subject to Invesco Ltd.’s Global Incident Management Policy (the “Incident Management Policy”) governing the resolution of Incidents, including trade errors. The Incident Management Policy establishes guidelines to ensure trade errors are detected, communicated and corrected appropriately. WLR will reimburse a Client’s account timely for any loss due to a trade-related error. In the event that the error results in a gain, a Client generally will retain the proceeds. Soft Dollars. WLR does not currently have any third-party soft dollar arrangements. WLR’s affiliates that place orders with brokers for the execution of public securities on behalf of WLR’s Clients may occasionally receive brokerage and research services from various firms,

including third parties that provide research or other services in return for directing WLR Client account’s brokerage business to them. These services include quantitative and qualitative research information and recommendations for investments, as well as analyses and reports covering a broad range of economic factors, markets and trends. WLR believes this practice is in the long term best interest of its Clients; however, because the Invesco affiliated trading desk does place some transactions with brokers in recognition of the usefulness of their research or other products or services provided, Clients may pay commission rates that are higher than rates charged by another broker-dealer, if no research was provided. On an ongoing basis, WLR’s affiliates monitor and evaluate the performance and execution capabilities of the firms that provide research and brokerage services and also the levels of commission costs in comparison to those commissions paid by other institutional investment managers. Research services received from brokers and dealers are generally supplemental to WLR’s own research efforts. To the best of WLR’s knowledge, these services are generally made available to institutional investors doing business with such broker-dealers. WLR does not separately compensate such broker- dealers for the research and such services. Directed Brokerage. WLR generally does not recommend, request or require that a Client direct WLR to execute transactions through a specific broker-dealer. Order Aggregation. The same investment decision may be made for more than one Client account managed by WLR or an affiliate. In these circumstances, should purchase and sell orders of the same class of security be in effect at the same time, the orders may be combined to seek best execution. Orders partially filled will be allocated pro-rata in proportion to each account's original order or account, although exceptions may be made to avoid odd lots and de minimis allocations. Execution prices for a combined order will be averaged so that each participating account receives the average price paid or received. Where aggregation is not possible, the inability to aggregate the trade could result in an increase in client transaction costs. This matter is unlikely to impact activity of WLR going forward in light of its intention to wind down.

This Item 14 requires an investment adviser to describe any arrangement under which it (or a related person) compensates another for client referrals and other compensation it receives. Other Compensation. It is WLR’s policy that if a portfolio manager, employee or a related person serves as a director on a board of directors (or in a similar capacity) of a portfolio company in which WLR has invested on behalf of a Client account, compensation is either refused or credited to WLR (for existing holdings by WLR employees, such director compensation is tracked in accordance with the Firm’s policies). WLR will then use such fees to offset a portion of the management fees charged to the relevant Client accounts as described in the relevant Governing Documents. Additionally, portfolio companies may reimburse certain expenses such as board travel, litigation or research expenses. As WLR disposes of Client investment positions, this conflict will be less applicable.

This Item 9 requires an investment adviser to disclose information about any legal or disciplinary event that is material to a client’s evaluation of the integrity of the investment adviser or its personnel. Except as described below, neither WLR nor any of its executive officers, members of its investment committees or other “management persons” as defined in Form ADV has been subject to legal or disciplinary events related to this Item. On August 24, 2016, without admitting or denying the findings, WLR consented to the entry of an order to cease and desist from committing or causing any violations and any future violations of Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-8 thereunder and agreed to pay a civil monetary penalty of $2.3 million to the SEC. According to the order, WLR failed to adequately disclose its fee allocation practices to certain private equity funds it advised (the “WLR Funds”) and their investors and that ambiguous language in its private equity funds limited partnership agreements resulted in certain WLR Funds paying higher management fees between 2001 and 2011. The order also states that in determining to accept the settlement offer, the SEC considered remedial acts promptly undertaken by WLR and cooperation afforded to the SEC staff, including WLR self-reporting of the transaction fee allocation issue to the SEC staff, WLR’s voluntary determination to revise its fee allocation methodology, and WLR’s voluntary reimbursement, with interest, of $11,873,571 in management fee credits resulting from its retroactive application of the revised allocation methodology to the inception of the WLR Funds. On May 31, 2021, Invesco Ltd., the ultimate parent company of WLR, agreed to a settlement with the Federal Financial Supervisory Authority (“Bafin”) in the amount of 260,000 Euros (approximately $309,595 USD) for a matter related to ownership filings with the German regulator in relation to German listed companies. BaFin alleged Invesco Ltd. and AIM international mutual funds failed to submit voting rights notifications to BaFin and issuers by the required deadline. BaFin issued a Notice of Hearing on July 30, 2020 to Invesco Ltd. alleging that violations of the voting rights requirements occurred on 26 occasions related to the voting rights notifications of Invesco Ltd. and on 28 occasions relating to the voting rights notifications of AIM international mutual funds between 05/2019 and 10/2019. Invesco Ltd. paid the administrative fine on June 30, 2021. On September 24, 2024, Invesco Advisers, Inc. (“IAI”), an investment advisory affiliate of WLR, and IDI, an affiliated broker-dealer (together, with IAI, “Invesco”) entered into a settlement with the SEC in connection with the agency’s industry-wide investigation into the maintenance and preservation of electronic communications pursuant to applicable recordkeeping provisions of federal securities law. The settlement censures Invesco and requires that Invesco cease and desist from any existing and future violations, pay a civil monetary penalty of $35,000,000 and retain an independent compliance consultant, following the format for all other recent electronic communications settlements. Invesco cooperated with the government’s inquiry and has already taken significant steps to further strengthen the

firm’s compliance environment as it relates to electronic communications, including by enhancing its policies and procedures, implementing increased training regarding the use of electronic communications, and beginning to implement changes to the technology available to employees. On November 8, 2024, IAI entered into a settlement with the SEC regarding IAI’s environmental, social and governance (“ESG”) policies and procedures. The SEC found that IAI lacked comprehensive policies and procedures to determine the percentage of companywide assets under management (“AUM”) that was ESG integrated. The SEC also found that IAI made misleading statements concerning the company-wide percentage of AUM that was ESG integrated. IAI was censured and ordered to cease and desist from violating Sections 206(2) and 206(4) of the Advisers Act and Rules 206(4)-1, 206(4)-7 and 206(4)-8 thereunder. IAI agreed to pay a penalty of $17.5 million.

This Item 13 requires an investment adviser to disclose how often the investment adviser reviews client accounts and who conducts the review. Oversight and Monitoring. Client investments are generally private, illiquid and long-term; accordingly, WLR’s review of them is not directed toward a short-term decision but rather an ongoing review of the portfolio of each Client to monitor performance and gauge the market for an optimal exit strategy, a focus for most of WLR’s clients in wind down. Client Reporting. WLR distributes written Client account statements and financial reports quarterly or annually as required by each Client’s Governing Documents. WLR also furnishes Fund investors with annual audited financial statements or requested financial information upon request, relevant tax forms, and detailed capital call and distribution statements. WLR also provides Clients with periodic conference calls and holds investor meetings.

This Item 15 requires an investment adviser with custody of client funds or securities to explain to clients that they will receive account statements directly from a qualified custodian or that the investment adviser is relying on the annual audit exception to delivery of account statements under Rule 206(4)-2 and will distribute such audited financial statements to all limited partners annually within 120 days of the end of its fiscal year (or 180 days for fund of funds). Because WLR and its affiliates serve as general partner for certain Funds, WLR is deemed to have “custody” over those Funds within the meaning of Rule 206(4)-2 under the Advisers Act. Generally, Clients’ cash and securities are held by Qualified Custodians such as banks and/or broker-dealers. Audited financial statements are distributed to Fund investors within 120 days from the end of each Funds’ fiscal year. In the event an investor has not received its audited financial statements timely, please contact the Firm at 972-715-7400 or at the address appearing on the cover page of this brochure. Should there be Clients for which WLR does not rely on the audit exception, such clients will receive statements directly from the Client’s qualified custodian at least quarterly and such Clients’ accounts will be subject to a surprise examination at least annually by an independent public accountant registered with and subject to inspection by the PCAOB. Further, in such cases, Clients will be notified of the establishment of such bank accounts and any changes thereto. All investors should carefully review these financial statements.

This Item 16 requires an investment adviser with discretionary authority over client accounts to disclose such authority and any limitations clients may place on an investment adviser’s authority. WLR has discretionary authority for most Clients for which it is the investment adviser. Investment decisions and advice, with respect to Clients’ accounts are subject to a Clients’ investment objectives and guidelines, as established by the Clients and set forth in the applicable Clients’ Governing Documents. For WLR to assume such discretionary authority, each investor must complete the appropriate subscription documents or an investment advisory agreement granting such authority.

This Item 17 requires an investment adviser to disclose its proxy voting practices, including whether a client may direct the investment adviser to vote in a particular solicitation, how the investment adviser addresses potential conflicts of interest and how clients can obtain information from the investment adviser about how the investment adviser voted securities and that clients may obtain a copy of the investment advisers proxy voting policies and procedures upon request. WLR has adopted and implemented written proxy voting policies and procedures pursuant to Rule 206(4)-6. In general, Clients are primarily invested in privately-held portfolio companies which typically do not issue proxies. However, previously, WLR has received proxies in connection with its publicly traded portfolio companies, in which case it was WLR’s policy to exercise the proxy vote in the best interest of the Clients, taking into consideration all relevant factors, including acting in a manner that WLR believes will maximize the economic benefits to the Clients and promote sound corporate governance by the issuer. WLR retained ultimate voting discretion with respect to voting proxies. Funds are not able to direct the vote of their general partner. WLR’s proxy voting policy is designed to ensure that if a material conflict of interest arises, that the vote is not improperly influenced by the conflict. WLR representatives that serve on the board of directors of a portfolio company on behalf of Clients will typically, but not always, vote in favor of board recommendations. In situations where WLR is required to vote the proxy for a company in which employees of WLR serve on the board of directors, WLR has determined that this does not inherently present a conflict of interest, as the sole purpose of this representation is to maximize the return on the Clients’ investment in such portfolio company. In all cases where there is deemed to be a material conflict of interest, WLR will seek the advice of Compliance and Legal to resolve the conflict in a Clients’ best interests. WLR, in its sole discretion, may elect not to vote a proxy. Clients may obtain a copy of WLR’s proxy voting policies and procedures and information on how WLR voted proxies on behalf of such Client upon request.

Item 18: Financial Information This Item 18 requires an investment adviser to disclose certain financial information about itself that is material to clients if it requires or solicits prepayment of more than $1,200 in fees per client, six months or more in advance, has discretionary authority or custody of client funds or securities, or the investment adviser has been the subject of a bankruptcy petition at any time during the past ten years.

advance, 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 at any time during the past ten years.

Item 19: Requirements for State-Registered Advisers This Item 19 requires certain responses from investment advisers registered with state securities authorities.