Lexington Advisors LLC: investment adviser

(together with its affiliates (but excluding Lexington), “Franklin Templeton”) acquired 100% of the equity in Lexington Partners L.P. (the “FT Transaction”). Franklin Resources, Inc.’s common stock is traded on the New York Stock Exchange under the ticker symbol “BEN.” In addition, Lexington partners and employees hold a 25% profit interest in Lexington Partners L.P. indirectly through Lexington Partners MIP L.P., which is a limited partner of Lexington Partners L.P. Lexington Partners L.P. is the direct owner of Lexington Advisors LLC. Franklin Templeton has agreed to irrevocably delegate the authority to manage the day-to-day business and affairs of Lexington to the Lexington Operating Committee, currently composed of Lexington’s President and Chief Financial Officer, until March 31, 2033, subject to limited exceptions. However, Franklin Templeton has sole ultimate control of Lexington Partners L.P. and Lexington Advisors LLC (including Lexington and the Lexington Funds) and may, under certain circumstances, terminate the employment of any or all of the current personnel of Lexington. Private Investment Fund Advisory Services Lexington and/or its affiliates provide financial, investment and portfolio analysis services as required for the benefit of Lexington’s “secondary” private equity funds (including, for the avoidance of doubt, funds pursuing a “continuation vehicle” strategy), co-investment funds and managed accounts (collectively, the “Lexington Funds”) whose securities are not registered under the Securities Act of 1933, as amended, and the rules and regulations promulgated thereunder (the “Securities Act”). Lexington’s primary investment focus on behalf of the Lexington Funds is to seek capital appreciation by acquiring diversified portfolios of private investment fund interests (generally through secondary market purchases) and, in certain circumstances, directly or indirectly, privately held portfolio company interests, and holding and realizing upon such interests. Lexington also advises the Lexington Funds with respect to making “primary market” commitments to private investment funds that have recently been formed or are otherwise still fundraising, and participating in co-investment and other transactions, including “continuation vehicle” transactions, that are sponsored by managers or general partners of private investment funds and/or other associated management teams. The Lexington Funds generally seek capital appreciation through investments in private investment funds and privately held portfolio companies, but also make investments in publicly traded securities.

The investments made by Lexington for the Lexington Funds are subject to compliance with such Lexington Funds’ investment strategies and restrictions and applicable law. Lexington tailors its advisory services to the specific investment objectives and restrictions of each Lexington Fund pursuant to the investment guidelines and restrictions set forth in such Lexington Fund’s confidential private placement memorandum, limited partnership agreement, advisory agreement and other governing documents, as applicable (collectively, the “Governing Documents”). Investors of each Lexington Fund (generally referred to herein as “investors,” “partners” or “limited partners”) should refer to the Governing Documents of such Lexington Fund for complete information on the investment objectives and investment restrictions with respect to such Lexington Fund. Investment advice is provided directly to the Lexington Funds, subject to the discretion and control of the general partner of the relevant Lexington Fund, and not individually to the investors in the Lexington Funds. There can be no assurance that any of the Lexington Funds’ investment objectives will be achieved. The Lexington Funds generally are offered exclusively to “accredited investors,” as such term is defined in Section 501(a) of Regulation D under the Securities Act, and/or “qualified purchasers,” as such term is defined in Section 2(a)(51)(A) of the Investment Company Act of 1940, as amended, and the rules and regulations promulgated thereunder (the “Investment Company Act”), and are eligible to rely on Section 3(c)(1) or Section 3(c)(7) of the Investment Company Act. Therefore, the Lexington Funds are not required to register as investment companies under the Investment Company Act in reliance upon certain exceptions applicable to private investment funds whose securities are not publicly offered. A related entity of Lexington generally acts as general partner of each Lexington Fund, and Lexington or its affiliate Lexington Partners L.P. (which is also an SEC-registered investment adviser) is the investment adviser of each Lexington Fund. Investment advisory services are provided to the Lexington Funds in accordance with the Governing Documents of the applicable Lexington Fund. In accordance with common industry practice, one or more of the Lexington Funds’ general partners have entered (and/or expect to enter) into “side letters” or similar agreements with certain investors pursuant to which the general partner grants the investor specific rights, benefits, or privileges that are not made available or disclosed to investors generally except as required under the Governing Documents of the applicable Lexington Fund. Additional details regarding the types of side letters that may be entered into with certain investors generally are described in the Governing Documents with respect to a Lexington Fund. To the extent Lexington or a Lexington Fund incurs third-party expenses in connection with compliance with a side letter provision, such expenses may be, in the sole discretion of Lexington, borne either by the investors that have the benefit of such provision or by all investors in the relevant Lexington Fund. Sub-advisory Services to Registered Funds In addition to advising the Lexington Funds, Lexington Advisors LLC currently serves as an investment sub-adviser with respect to the following funds:

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U.S. Registered Fund. Pursuant to written sub-advisory agreements, Lexington serves as sub-adviser to a Delaware statutory trust registered under the Investment Company Act as a non-diversified, closed-end management investment company (the “U.S. Registered Fund”). Franklin Templeton Fund Adviser, LLC (the “U.S. Registered Fund Manager”), a wholly-owned subsidiary of Franklin Templeton, serves as the investment manager of the U.S. Registered Fund. Franklin Advisers, Inc. (“FAV”), a wholly-owned subsidiary of Franklin Templeton, also serves as a sub-adviser to the U.S. Registered Fund with respect to certain of its assets and allocating its assets across its portfolio.

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Offshore Registered Fund. Lexington provides investment sub-management services to a Luxembourg-domiciled Part II UCI (the “Offshore Registered Fund,” and, together with the U.S. Registered Fund, the “Registered Funds”). The Offshore Registered Fund is managed on a primary basis by Waystone Management Company (Lux) S.A., which serves as the Offshore Registered Fund’s alternative investment fund manager (“AIFM”) and is responsible for overall regulatory oversight and risk management. The AIFM has delegated portfolio management responsibility to Lexington to act as investment sub-adviser with respect to the private assets portfolio while Franklin Advisers, Inc. is responsible for managing the liquidity sleeve.

The Registered Funds seek long-term capital appreciation primarily through investments in private equity secondary transactions, with the ability to make co-investments and, to a lesser extent, primary commitments. The Registered Funds invest globally across private equity sponsors and strategies and typically hold diversified portfolios of secondary interests, coinvestment interests, and other private assets (collectively, “Private Assets”). As described above, Lexington acts as investment sub-adviser with respect to the Private Assets portions of the Registered Funds’ portfolios. The Registered Funds are offered to professional and eligible retail investors and provide limited liquidity through periodic redemption mechanisms subject to applicable limitations. With respect to the U.S. Registered Fund, although shares are registered under the Securities Act, they are offered only to eligible investors that are “qualified clients”, as such term is defined in Rule 205-3 under the Investment Advisers Act of 1940, as amended, and the rules promulgated thereunder (the “Advisers Act”). In order to be an eligible investor in the U.S. Registered Fund’s U.S. public offering, an investor must also be an “accredited investor”, as such term is defined in Section 501(a) of Regulation D under the Securities Act. Additional information about the Registered Funds, including but not limited to their investment objectives and strategies, fees and expenses, other key terms, and relevant risks and potential conflicts of interest, can be found in their prospectuses and related offering documents, which are publicly available on the Franklin Templeton website. For the avoidance of doubt, unless specifically indicated, the discussions in this brochure of Lexington-advised investment funds and associated activities of Lexington relate to the Lexington Funds (i.e., the private investment funds managed by Lexington) and not to the Registered Funds. Lexington does not participate in any wrap fee programs.

Lexington manages all assets of the Lexington Funds and its allocated portions of the Registered Funds’ assets on a discretionary basis in accordance with the terms and conditions of each Lexington Fund’s Governing Documents and the governing documents of the Registered Funds. As of September 30, 2025, the amount of assets Lexington manages on a discretionary basis is $2,656,573,224.1

contributions (including outstanding borrowings by such Lexington Fund) for unrealized portfolio investments, with respect to such Lexington Fund, in each case as set forth in the Lexington Funds’ Governing Documents. Lexington also receives performance-based compensation from the Lexington Funds as described further in the section titled “Performance-Based Fees and Side-by-Side Management”. The precise amount, and the manner and calculation, of the Advisory Fees for each Lexington Fund are established by Lexington and are set forth in such Lexington Fund’s Governing Documents, which are received by each investor prior to making an investment in such Lexington Fund. In certain circumstances, the Advisory Fees payable to Lexington by individual investors in a Lexington Fund will vary among such investors (e.g., based on size and aggregation of commitment, timing of admission or otherwise) and may be negotiable. Lexington also has discretion in determining whether size-based commitments will be aggregated for purposes of determining certain Advisory Fee rates, and treatment among investors is expected to vary. Moreover, personnel and certain business associates and “friends and family” of Lexington or its personnel (collectively, “Adviser Investors”) typically will not pay or bear any Advisory Fees with respect to their direct or indirect investments in the Lexington Funds. Notwithstanding that Adviser Investors will generally not pay or bear Advisory Fees, Adviser Investors will bear their pro rata share of certain Lexington Fund expenses or such Adviser Investors’ pro rata portion of such expenses will be allocated to Lexington. Advisory Fees paid by a Lexington Fund are indirectly borne by investors in such Lexington Fund. Investors and prospective investors in each Lexington Fund should note that similar

Discretionary assets under management include the Lexington Funds’ asset values and uncalled commitments as of September 30, 2025, Lexington’s assets under management related to the Registered Funds as of September 30, 2025, and additional investor commitments accepted by the Registered Funds between October 1, 2025 and November 30, 2025.

advisory services may (or may not) be available from other investment advisers for similar or lower fees and that fees may differ among investors in the same Lexington Fund. With respect to the U.S. Registered Fund, Lexington receives a sub-advisory fee (the “SubAdvisory Fee”) from the U.S. Registered Fund Manager. With respect to the Offshore Registered Fund, Lexington receives an annual management fee, which is paid by the Offshore Registered Fund out of its assets. Lexington also receives performance-based compensation with respect to the Registered Funds as described further in the section titled “PerformanceBased Fees and Side-by-Side Management”. All clients of Lexington (and all Lexington Fund limited partners) are “qualified purchasers” as defined in Section 2(a)(51) of the Investment Company Act and, therefore, Lexington has not included specific fee information in this brochure. Deduction of Fees; Timing of Payments; Termination Lexington is authorized under the Governing Documents to charge and deduct Advisory Fees directly from the Lexington Funds. Payments of Advisory Fees are generally made quarterly in advance and in accordance with the terms of the Governing Documents of the applicable Lexington Fund. As a general matter, Advisory Fees will be payable during term extensions unless otherwise agreed with investors. Please refer to the Governing Documents of each of the Lexington Funds for complete information on the timing of Advisory Fee payments. Upon termination of any Lexington Fund’s advisory relationship with Lexington, any prepaid, unearned fees will be promptly refunded to such Lexington Fund, and any earned, unpaid fees will be due and payable. With respect to the U.S. Registered Fund, the Sub-Advisory Fee is payable quarterly in arrears from the U.S. Registered Fund Manager. With respect to the Offshore Registered Fund, the management fee is paid by the fund out of its assets in accordance with its governing documents and is accrued and charged on an ongoing basis as part of the fund’s operating expenses. Additional information relating to the Registered Funds’ advisory fees can be found in their respective prospectuses and related offering documents. Other Fees and Expenses Consistent with the Governing Documents of the Lexington Funds, in addition to the Advisory Fees and performance-based compensation payable to Lexington, each Lexington Fund (and indirectly, the investors thereof) will incur and/or bear certain charges, including, but not limited to: fees, costs and expenses of any administrators (including administrators that perform anti-money laundering or “know your customer” diligence and investor verification services in connection with the ongoing participation of investors in the Lexington Funds), independent appraisers, custodians, depositaries, attorneys, accountants, auditors, tax advisors, “tax matters partners” or “partnership representatives,” consultants, brokers, agents, researchrelated data providers, independent appraiser and valuation firms or experts or other professionals (including advisors to Lexington); costs associated with preparing, printing, and distributing communications and reports to investors and monitoring investor portfolio activity (including, without limitation, accounting or financial management software and other

expenses (including third party expenses) incurred in connection with secure communications to the limited partners, the preparation of financial statements, tax returns, Schedules K-1 and other accounting or similar administrative functions); out-of-pocket costs and expenses, if any, incurred in connection with developing, negotiating, structuring, monitoring, custodying, or, to the extent applicable, disposing of, portfolio investments of the Lexington Fund (whether or not consummated), including, without limitation, any financing, legal, tax, accounting, advisory, consulting, software or other professional expenses in connection therewith, any liquidated damages, reverse termination fees or similar payments, and expenses incurred in connection with organizing the Lexington Fund and its related entities (including, for example, any entities used to acquire, hold, or dispose of any one or more investments or otherwise to facilitate investment activities), and the offering of interests in the Lexington Fund (including expenses relating to organizational and governing documents, prospectuses, diligence responses, disclosure documents, legal opinions, side letters and similar agreements, printing fees, filing fees, meetings with prospective investors and travel related thereto), as well as attending meetings related to portfolio investments and portfolio companies, including, without limitation, any related legal, tax and accounting fees and expenses, travel expenses, costs and expenses of meetings with representatives thereof, maintenance and formation and/or filing fees; the costs and expenses (including travel, set-up, room and board, honorarium, dining, entertainment and related expenses) of holding meetings or conferences with one or more of the Lexington Fund’s investors and/or advisory board(s) (including observers); outof-pocket costs and expenses, if any, incurred by or on behalf of the Lexington Fund in developing, negotiating and structuring prospective or potential portfolio investments which are not ultimately made, including, without limitation, any legal, accounting, advisory, financing, broken-deal, travel, consulting and other professional costs, fees and expenses in connection therewith (to the extent not otherwise reimbursed); investment banking, brokerage commissions, prime brokerage fees, registration fees and expenses, custodial expenses, other bank service fees and other investment costs, fees and expenses actually incurred in connection with actual portfolio investments; expenses incurred in connection with compiling and complying with provisions in side letter agreements (including the process of distributing and implementing applicable elections pursuant to any “most-favored-nations” clauses in side letters) or in connection with any amendments to any partnership agreement of such Lexington Fund or certain related entities; extraordinary expenses of the Lexington Fund, including, without limitation, the costs of any pending or threatened litigation, audit, investigation, administrative or other proceedings (including out-of-pocket costs and expenses, if any, associated with any third-party examination or audits (including similar services) of the Lexington Fund or Lexington that are attributable to the operation of such Lexington Fund or requested by one or more investors in the Lexington Fund (but, for the avoidance of doubt, excluding any SEC or similar regulatory examination)), settlement or review of the business or activities of the Lexington Fund, D&O liability, fidelity bonding or other insurance and any indemnification or extraordinary expense (including judgments, fines, other awards and settlements paid in connection therewith) or liability relating to the affairs of the Lexington Fund; all out-of-pocket fees, costs and expenses, if any, incurred in connection with the Lexington Fund’s legal and regulatory compliance with U.S. federal, state, local, non-U.S. or other law, rule or regulation (including, for example and without limitation, Form PF, filings with CFIUS or other matters related to the U.S. Defense Protection Act or CFIUS or similar U.S. or non-U.S. regulations, FATCA and related foreign account reporting regimes (including,

without limitation, the OECD Standard for Automatic Exchange of Financial Account Information in Tax Matters – the Common Reporting Standard and any associated guidance), rules or regulations relating to the foregoing or the implementation thereof in any relevant jurisdiction, similar filings required in other jurisdictions, all costs incurred in complying with local rules and regulations, including the engagement, organization or maintenance of any entity used in connection with compliance by the Lexington Fund with local rules and regulations, applicable anti-money laundering and “know your customer” procedures, laws and/or regulations, Swiss representatives and paying agents, foreign depositaries, and any registration of Lexington, its affiliates or the Lexington Fund under applicable law in connection with the offering of interests in the Lexington Fund or expenses relating to clearing or distributing subscriptions of the Lexington Fund through a local broker-dealer or agent under applicable law), the preparation and administration of any reports, disclosures, filings or notifications prepared in accordance with the foregoing, and third party expenses incurred in connection with the preparation and administration of filings in connection with any such laws or regulations; all costs and expenses related to the presence of the Lexington Fund’s general partner or its affiliates (including vehicles formed to facilitate portfolio investments) in jurisdictions in which such Lexington Fund or an alternative investment vehicle maintains subsidiary or related acquisition vehicles, including rent, domiciliation fees, directors fees and other similar costs; all expenses in connection with distributions to limited partners, including the managed distribution of freely tradable securities; expenses relating to defaults by any limited partner in the payment of any capital contributions and any expenses relating to the payment of amounts to any withdrawing limited partners; the costs and expenses of third-party service providers in connection with the administration of limited partners not controlled and/or managed by Lexington that are formed for the purpose of aggregating the commitments of unaffiliated investors for purposes of investing in the Lexington Fund and the preparation and distribution of reports and communications by such limited partners; technology-related expenses, including, without limitation, costs and expenses of and related to technology and software implementation and maintenance, service providers or consultants (including external consultants and related costs and expenses to implement, develop or maintain software, artificial intelligence, including machine learning technology and generative artificial intelligence and other technology, including in connection with the ongoing maintenance of “digital” subscription agreements) and related subscriptions/software/hardware/hosting/server infrastructure (including, without limitation, with respect to accounting, financial, legal and/or compliance, document and client management software, sending secure communications to the Lexington Fund’s partners and the preparation of financial statements, tax returns, and Schedule K-1s) and market data and research utilized in connection with investment and operational activities; interest on, and fees and expenses arising out of, all borrowings made by the Lexington Fund and entities formed to facilitate investments, including the costs and expenses incurred in arranging, negotiating, structuring, entering into and amending any credit facility; the costs of negotiating, structuring, entering into and amending any agreements or arrangements relating to hedging (whether entered into for currency or other purposes), derivative transactions and other financial instruments; expenses incurred in connection with an investor’s actual or proposed transfer of its interest in the Lexington Fund (including legal fees, which may be subject to minimum amount) that are not recouped from the assignor or assignee; expenses incurred in connection with tax filings related to the Lexington Fund’s activities (including in foreign jurisdictions); the costs and expenses of dissolving the

Lexington Fund and liquidating such Lexington Fund’s assets; certain expenses incurred by the Lexington Fund’s advisory board members and observers (if any); any taxes, fees or other governmental charges levied against the Lexington Fund and all expenses incurred in connection with any tax audit, investigation, settlement or review of the Lexington Fund; and any other expenses permitted under the Lexington Fund’s Governing Documents or duly approved by such Lexington Fund’s advisory board. For the avoidance of doubt, any travel expenses described herein may include expenses associated with the use of private aircraft, business class or first class travel (including ground transportation) and/or lodging, meals (including closing dinners), closing “deal tokens,” late night cars and dinners, social and entertainment events with portfolio investment management teams, customers, clients, borrowers, brokers, and service providers. Similar expenses incurred in connection with the organization and offering of interests in a Lexington Fund, parallel funds, feeder funds, and any general partner or similar entity thereof will be part of “Organizational Expenses” that are to be borne by the limited partners of a Lexington Fund, subject to the limits set forth in such Lexington Fund’s Governing Documents. As further discussed in the section titled “Methods of Analysis, Investment Strategies and Risk of Loss,” Lexington reserves the right to offer co-investment opportunities alongside a Lexington Fund to certain investors and/or third parties in its sole discretion. In the event that a proposed co-investment opportunity is not consummated but certain costs and expenses have been incurred by a Lexington Fund, Lexington or its affiliates in pursuit of such investment opportunity (including, without limitation, legal, financial, travel and other business diligence costs and expenses, including of the type described above), such costs and expenses generally will be paid solely by such Lexington Fund and it is expected that any potential co-investors (including committed co-investment vehicles) will generally not bear any portion of such “broken deal” costs and expenses. In addition, Lexington forms certain acquisition vehicles or similar “special purpose vehicles” (“SPVs”) for the purpose of facilitating investments (including secondary transactions) by one or more Lexington Funds, investors and/or other third parties. In the event Lexington creates an SPV, the SPV, and indirectly the investors of the Lexington Funds participating in such SPV, will typically bear all expenses related to its organization and formation and other expenses incurred solely for the benefit of the SPV. Expenses associated with any feeder fund or similar vehicle organized to facilitate the participation of certain investors in a Lexington Fund (including, without limitation, expenses of accounting and tax services) generally will be borne by such Lexington Fund. Further, each private investment fund in which a Lexington Fund acquires an interest will generally pay advisory fees, performance-based compensation and/or other fees and expenses to an investment adviser and/or general partner that is not affiliated with Lexington. Compensation and expenses paid to Lexington for investment advisory services to the Lexington Funds are separate and distinct from the advisory fees, performance-based compensation, and expenses charged by the independent investment advisers or general partners of the private investment funds in which the Lexington Funds invest.

The section titled “Brokerage Practices” describes the factors Lexington considers in selecting or recommending broker-dealers and determining the reasonableness of their compensation. Timing of Payments Please refer to the subsection titled “Deduction of Fees; Timing of Payments; Termination” described above. Transaction-Based Compensation Lexington does not receive any compensation as broker or agent for the sale of securities or other investment products to any Lexington Fund. Please refer to the subsection titled “Economic Benefits Received from Third Parties” below for information on other types of compensation that Lexington in certain circumstances expects to receive with respect to investments by the Lexington Funds. Allocation of Expenses Lexington will be required to decide whether certain fees, costs and expenses should be borne by a Lexington Fund, on the one hand, or Lexington, on the other hand, and/or whether certain fees, costs and expenses should be allocated between or among the Lexington Funds and/or other parties. Certain expenses will be the obligation of one particular Lexington Fund and are expected to be borne by such Lexington Fund, and other expenses will be allocated among multiple Lexington Funds and entities. In exercising its discretion to allocate investment opportunities and fees and expenses, Lexington is faced with a variety of potential and actual conflicts of interest. Lexington will generally allocate fees and expenses incurred in the course of evaluating and making portfolio investments in which multiple Lexington Funds participate (or are expected to participate) in accordance with the applicable Lexington Funds’ Governing Documents or, to the extent not addressed in such Governing Documents, in its sole discretion, using good faith and its best judgment considering those factors and policies Lexington deems relevant and appropriate, and in a manner that is fair and equitable to each applicable Lexington Fund. Lexington will make similar determinations with respect to the allocation of relevant fees and expenses among Lexington and its affiliates and the Lexington Funds. Lexington expects to encounter conflicts of interest in allocating certain expenses among a Lexington Fund and any other Lexington Funds (including managed accounts, co-investment vehicles and other vehicles) investing alongside it (and in certain circumstances, among the partners of a Lexington Fund). Lexington in many cases will allocate all expenses (organizational or otherwise) related to a Lexington Fund (including fees, costs and expenses related to marketing in local jurisdictions and complying with regulations related thereto (which may include the engagement, organization and/or maintenance of certain entities)) among such Lexington Fund and other relevant Lexington Funds, accounts and vehicles on a pro rata basis based on capital commitments, invested capital or available capital, as applicable, but in certain instances will do so in a different manner if Lexington determines in good faith that doing so is more equitable or appropriate under the circumstances. Notwithstanding the foregoing, in certain instances (e.g., where Lexington allocates the cost of a service provider’s retainer pro rata to all actively investing Lexington Funds, regardless of the amount of services actually received

by each such Lexington Fund during the relevant period) the portion of an expense allocated to a Lexington Fund for a particular service will not reflect the relative benefit derived by such Lexington Fund from that service. In some cases, investors will bear a greater share of expenses than they would if a different allocation methodology were utilized. Lexington Funds are also expected to benefit from services previously performed on behalf of Lexington and/or certain actual or proposed other Lexington Funds, including negotiations that resulted in “form” documents and advice regarding structuring, tax or other similar matters. To the extent similar negotiations occur or such prior advice is relevant in connection with the subsequent organization or activities of a Lexington Fund, it can be expected that such Lexington Fund will enjoy material cost savings, synergies and other benefits as a result of such past work, the cost of which is likely to have been borne, in whole or in part, by one or more other Lexington Funds. Lexington Funds incur certain fees, costs and/or expenses that are not always directly related to a specific potential investment and may be more general in nature, for example any yearly subscription retainer for consultants, including any expert network and/or consulting group with relationships across industries and/or geographies, and/or any service providers that provide assistance with diligence projects on an annual or periodic basis. Such fees, costs and/or expenses are expected to be allocated to the applicable Lexington Fund(s), notwithstanding the fact that such fees, costs and/or expenses or related services could directly or indirectly inure to the benefit of other Lexington Funds and their portfolio entities, in addition to or in lieu of the Lexington Fund(s) to which such fees are allocated. Lexington endeavors to allocate such fees, costs and/or expenses, to the extent that such fees, costs and/or expenses are specific to a particular investment (such as due diligence), to the Lexington Fund(s) that participate or are expected to participate in such investment, although it is possible that other Lexington Funds will benefit from such services. Conflicts exist in the allocation of the costs and benefits of these arrangements, and there can be no assurance that Lexington will resolve such conflicts of interest in a manner that is favorable to any particular Lexington Fund. To the extent not reimbursed by a third party, all third-party expenses incurred in connection with a proposed portfolio investment that is not ultimately made or a proposed realization that is not actually consummated, including legal, tax, accounting, advisory, and consulting expenses and any liquidated damages, reverse termination fees or similar payments generally will be borne by the relevant Lexington Fund(s) (and allocated pro rata to all limited partners without taking into account any applicable excuse or exclusion rights of any limited partner). If multiple Lexington Funds evaluate a potential investment that is not consummated, Lexington generally allocates fees and expenses generated in the course of evaluating such investment among such Lexington Funds based on the anticipated investment of each such Lexington Fund or such other method as Lexington deems appropriate. Such expenses typically are not allocated to prospective co-investors. Lexington pays expenses on behalf of the Lexington Funds, and such expenses are thereafter allocated to, and reimbursed by, the relevant Lexington Funds in a manner consistent with the allocation procedures described above and generally without interest. In addition, in certain circumstances one Lexington Fund will pay an expense or obligation common to multiple Lexington Funds (including, without limitation, legal expenses for a transaction in which all

such Lexington Funds participate, or other fees or expenses in connection with services the benefit of which are received by other Lexington Funds over time), and in such cases Lexington will cause such other Lexington Funds to reimburse the paying Lexington Fund for their share of such expenses or obligations.

With respect to the Offshore Registered Fund, Lexington receives a performance participation allocation. Arrangements regarding performance-based fees received by Lexington, or related persons of Lexington, can create an incentive for Lexington to cause a Lexington Fund or, as applicable, a Registered Fund, to make investments that are riskier or more speculative than those that Lexington would have caused such fund to make, or to time purchases or sales differently than Lexington would have caused such fund to do, under a different fee or compensation arrangement. However, Lexington generally considers performance-based compensation to better align its interests with those of investors, and Lexington’s commitments to the Lexington Funds and the existence of a general partner clawback, each where applicable, should somewhat reduce these incentives. Side-by-Side Management Each Lexington Fund is subject to its own performance-based compensation arrangements, and, in certain cases, Lexington or an affiliate may not be permitted to take a performancebased allocation or may only be permitted to take a performance-based allocation from a Lexington Fund after the investors in such Lexington Fund have received a preferred return on their contributed capital or realized capital (subject to clawback). The potential for Lexington and its affiliates to receive different fees or allocations from performance-based accounts creates a potential conflict of interest with respect to the allocation of investment opportunities and Lexington’s time and resources because Lexington has an incentive to direct the best investment ideas and/or resources to, or to allocate investments and/or resources in favor of, the account that pays a more favorable performance fee or allocation. In addition, where a Lexington Fund has a clawback, the clawback should reduce the incentives to make more speculative investments but potentially creates other misalignments of interests between Lexington and investors, such as an incentive for Lexington to defer disposition of an

investment that would result in a realized loss, or delay the dissolution and liquidation of a Lexington Fund if doing so would trigger a clawback obligation. Please refer to the Governing Documents of each Lexington Fund for complete information on the specific performance-based compensation arrangements of such Lexington Fund. Additional information relating to the Registered Funds’ incentive fees can be found in their prospectuses and related offering documents.

Investors in the Lexington Funds and/or the Registered Funds include, without limitation, corporations, endowments, foundations, trusts, estates, sovereign wealth funds, banks and other financial institutions, insurance companies, family offices, high net worth individuals and public and private retirement and pension plans and profit sharing plans. In connection with the formation and management of certain Lexington Funds, Lexington or its related entities establish certain vehicles (“Feeder Funds”) to address tax, legal, regulatory, and/or other similar issues or requirements of certain investors in the Lexington Funds. Each Feeder Fund is a limited partner (or equivalent) of a Lexington Fund and interests in such Feeder Fund are held by the investors who participate in the Lexington Fund through such Feeder Fund. In addition, Lexington forms other parallel funds, alternative investment vehicles and/or similar investment vehicles to address tax, legal, regulatory, and/or other business considerations. Investors are requested to refer to the Governing Documents of the applicable Lexington Fund for complete details on any Feeder Funds or other investment vehicles established in connection with such Lexington Fund and such Lexington Fund’s ability to make investments through any such vehicles. Minimum Investment Requirements Lexington and its related entities generally require that each investor in the Lexington Funds be an “accredited investor” as defined in Regulation D promulgated under the Securities Act. In addition, Lexington and its related entities generally require that each investor in the Lexington Funds be a “qualified purchaser” as defined in the Investment Company Act. In general, the minimum investment commitment required of an investor to participate in a Lexington Fund is $5,000,000; however, the general partner of each Lexington Fund has discretion to increase or reduce the minimum investment commitment and such minimum investment requirement does not apply to all Lexington Funds.

Investors are requested to refer to the Governing Documents of the applicable Lexington Fund for complete information on minimum investment requirements for participation in such Lexington Fund. The U.S. Registered Fund offers four separate classes of shares designated as Class S, Class D, Class I and Class M Shares.2 The minimum initial investment in the U.S. Registered Fund by any investor is $25,000 with respect to Class S Shares, Class D Shares and Class M Shares, and $1,000,000 with respect to Class I Shares. The minimum additional investment in the U.S. Registered Fund by any investor is $10,000, except for additional purchases pursuant to the U.S. Registered Fund’s dividend reinvestment plan. Investors subscribing through a given broker-dealer or registered investment adviser may have shares aggregated to meet these minimums, so long as initial investments are not less than $25,000 and incremental contributions are not less than $10,000. The Offshore Registered Fund is available to non-U.S. Professional Investors and Eligible Retail Investors, with a minimum subscription amount of $25,000. Complete information on minimum investment amounts for participation in the Registered Funds can be found in their prospectuses and/or related offering documents.

Lexington’s principal sources of information (i) with respect to investments in private investment funds, include private offering memoranda, quarterly and annual reports of the underlying private investment funds, personal interviews with the underlying private investment funds’ managers, and reference checks on the underlying private investment funds’ managers, and (ii) with respect to investments in equity and quasi-equity securities of an entity, include private offering memoranda, quarterly and annual reports, personal interviews with directors and officers of such entities and visits to such entities, SEC filings (if available) and general industry knowledge. Lexington provides investment advice on various types of private investments. As described above, Lexington’s primary investment strategy is to seek capital appreciation by acquiring diversified portfolios of private investment fund interests (generally through secondary market purchases) and, in certain circumstances, privately held portfolio companies, and holding and

The U.S. Registered Fund Manager has received an exemptive order from the SEC that permits the U.S. Registered Fund to offer multiple classes of shares.

realizing on such interests. Lexington also provides advice with respect to making “primary market” commitments to private investment funds that have recently been formed or are otherwise still fundraising, and participating in co-investment and other transactions, including continuation vehicle transactions, that are sponsored by managers or general partners of private investment funds and/or other associated management teams. The task of identifying investment opportunities and managing private equity investments is difficult. There can be no assurance that a Lexington Fund will be able to make and/or realize any particular investment or that the Lexington Funds will be able to generate returns for their investors. The marketability and value of any such investments will depend upon many factors beyond the control of Lexington and the Lexington Funds. In addition, there can be no assurance that any investor will receive any distribution from a Lexington Fund. Investing in the Lexington Funds involves a risk of loss that investors should be prepared to bear. Investors in the Lexington Funds should carefully consider, among other factors, the following material risks involved with Lexington’s investment strategies. Investors in the Lexington Funds are requested to refer to the Governing Documents of the applicable Lexington Fund for complete information on investment strategies employed by such Lexington Fund and the corresponding risks associated with such investment strategies. The disclosures in this Item 8 relate primarily to the Lexington Funds (i.e., the private investment funds advised by Lexington) and Lexington’s associated activities, and not, unless specifically indicated, to the Registered Funds. While certain of the Lexington Fund investment strategy discussions above and risk disclosures below have some relevance to the Registered Funds, the Registered Funds’ prospectuses and related offering documents should be consulted for detailed information on their investment strategies and corresponding risks. Risks Inherent in Investments in the Lexington Funds A successful program of investing is subject to risks related to (i) the quality of the management of the respective private investment funds in which the Lexington Funds invest (the “Investment Funds”); (ii) the ability of the management of the Investment Funds to select successful investment opportunities; (iii) general economic conditions; and (iv) the ability of the Lexington Funds and the Investment Funds to liquidate their investments. There can be no assurance that the investments made by the Investment Funds will result in rates of return to the Lexington Funds that are equal to or better than the average rate of return on investments in other partnerships, or that the performance of any Investment Fund will equal or exceed the performance of past investments made by Lexington. Historically, private equity returns have varied greatly over time, depending on the conditions at the time investments were made and when the private equity partnerships exited such investments. In addition, each private equity subclass may exhibit considerable volatility of returns. The Lexington Funds may not be successful in meeting their respective performance objectives. Investors should not subscribe to a Lexington Fund unless they can bear the risk of a complete loss of their committed capital. Market Risks Recent volatility in the global financial markets and political systems of certain countries may have adverse spill-over effects into the global financial markets generally. Moreover, a

recession, slowdown and/or sustained downturn in the global economies (or any particular segment thereof) or weakening of credit markets will adversely affect the Lexington Funds’ profitability, impede the ability of the Lexington Funds’ portfolio investments (or their underlying portfolio companies) to perform under or refinance their existing obligations, and impair the Lexington Funds’ ability to effectively exit portfolio investments on favorable terms. The extent and duration of such environment, to the private equity industry and global markets as a whole, is currently unknown. Any of the foregoing events could result in substantial or total losses to the Lexington Funds in respect of certain portfolio investments, which losses will likely be exacerbated by the presence of leverage in the capital structure of a particular portfolio company of an Investment Fund. For this reason, valuations are generally subject to heightened uncertainty and numerous subjective judgments, any or all of which could turn out to be incorrect with the benefit of hindsight. Furthermore, traditional valuation approaches that have been used historically may need to be modified in order to effectively capture fair value of private investments in the midst of significant volatility or market dislocation. Undervalued Investments The investment strategy of the Lexington Funds is based, in part, upon the premise that certain potential investments will be available for purchase by a Lexington Fund at “undervalued” prices. However, purchasing interests at what may appear to be “undervalued” or “discounted” levels is no guarantee that these investments will generate attractive risk-adjusted returns to such Lexington Fund, and it is possible that such investments will be subject to further reductions in value. No assurance can be given that any Lexington Fund will be able to acquire investments at favorable prices or that the market for such interests will continue to improve. Highly Competitive Market for Investment Opportunities The activity of identifying, completing, and realizing private equity investments is highly competitive and involves a high degree of uncertainty. In addition, developing and maintaining relationships with sponsors of private funds, joint venture partners or management teams, on which some of the Lexington Funds’ strategies depend, is highly competitive. The Lexington Funds and the Investment Funds will be competing for investments with other private equity investment vehicles, as well as individual third-party investors, including, without limitation, other investment partnerships and corporations, business development companies, sovereign wealth funds, domestic and international public pension plans, individuals, financial institutions and other investors investing directly or through affiliates. Some of these competitors may have more relevant experience, greater financial and other resources and more personnel than Lexington. Furthermore, over the past several years, an increasing number of private equity funds, including secondary, co-investment funds, and sponsor solutions funds and other capital pools targeted at the secondary, co-investment and sponsor solutions sectors, have been formed (and certain of such existing funds have grown substantially in size), and additional capital will likely be directed at these sectors in the future. Additional funds with similar investment objectives may be formed in the future by other unrelated parties. The supply and consequently the pricing of secondary investments (including continuation vehicle investments) is dependent on a number of factors that may be adversely impacted by general conditions in the global financial markets, including the rate at which such underlying sponsors

are able to deploy capital, the performance and value of investments held by funds managed by such underlying sponsors and the ability for such investment funds to realize, recapitalize and/or refinance their own investments in order to return capital to their investors. Higher valuations and increased liquidity and return of capital in the private equity investment market may result in fewer attractive investment opportunities. No assurance can be given that the Lexington Funds will be able to identify investment opportunities that satisfy their investment objectives and desired diversification goals, or if the Lexington Funds are successful in identifying such investment opportunities, that they will be permitted to invest, or invest in the amounts desired, in such opportunities. Additionally, there is a significant amount of capital available in the industry for secondary investments. Accordingly, it is possible that a Lexington Fund’s capital commitments will not be fully utilized if sufficient attractive investments are not identified and consummated by such Lexington Fund during its investment period. Certain Risks Particular to Secondary Investments The market for secondary investments has been evolving and is likely to continue to evolve. It is possible that competition for appropriate investment opportunities will increase, thus reducing the number of investment opportunities available to the Lexington Funds and adversely affecting the terms upon which investments can be made by such Lexington Funds. Accordingly, there can be no assurance that the Lexington Funds will be able to identify sufficient investment opportunities or that they will be able to acquire sufficient secondary investments on attractive terms. In addition, in the cases where a Lexington Fund acquires an interest in an Investment Fund or directly held security in a secondary transaction, including a “tender offer” transaction, such Lexington Fund typically will acquire certain contingent liabilities of the seller of such interest. More specifically, where the seller has received distributions from the relevant Investment Fund, and subsequently, such Investment Fund recalls one or more of these distributions, such Lexington Fund (as the purchaser of the interest to which such distributions are attributable), and not the seller, likely will be obligated to return monies equivalent to such distributions to the Investment Fund. While such Lexington Fund may, in turn, be able to make a claim against the seller for any such monies so paid to the Investment Fund, there can be no assurances that such Lexington Fund would have the ability to make such a claim or, if such a claim were made, that such Lexington Fund would prevail. Finally, in some instances, the Lexington Funds have the opportunity to acquire a portfolio of Investment Fund interests or directly held securities from a seller on an “all or nothing” basis. Certain of the Investment Funds or directly held securities in such a portfolio are often less attractive than others, and certain of the sponsors of such Investment Funds or directly held securities are often more familiar to Lexington than others, or are more experienced or highly regarded than others. In addition, the Lexington Funds sometimes have the opportunity to participate in “linked secondaries” (e.g., a secondary market purchase of an existing interest and corresponding portfolio investment in a separate vehicle sponsored by the same investment manager). In certain instances, the corresponding portfolio investment may be less attractive than the secondary market purchase of an existing interest. In such cases, it may not be possible for the Lexington Funds to exclude from such purchases those investments which Lexington considers (for commercial, tax, legal, or other reasons) less attractive. Moreover, with respect to linked secondaries relating to secondary transactions in which more than one Lexington Fund participates, a Lexington Fund may be allocated a greater or lesser proportional share of commitments to corresponding portfolio investments than its proportional share of the

secondary transaction. Similarly, with respect to secondary transactions in which multiple Lexington Funds participate, there can be no guarantee that agreements with counterparties regarding allocations of purchase price among secondary portfolio interests, deferred purchase price payment mechanics, and/or other terms of the transaction will not be more or less advantageous to one or more specific Lexington Funds than to other participating Lexington Funds. Certain Risks Particular to Co-Investments Certain Lexington Funds make “co-investments” in transactions sponsored by the general partners or managers of the Investment Funds. Typically, co-investments are structured as investments in special purpose vehicles established and controlled by the sponsor Investment Fund’s general partner or manager or an affiliate thereof, which in turn invest in an underlying transaction. Special purpose vehicles are typically structured so that all decision making with respect to the underlying investment transaction is made mutatis mutandis with the sponsor’s Investment Fund. Thus, a Lexington Fund’s investment in any co-investment will be largely controlled by the sponsor Investment Fund’s general partner or manager or an affiliate thereof. Co-investment opportunities are sometimes in high demand and over-subscribed. Accordingly, sponsor Investment Fund general partners and managers are generally reluctant or unwilling to negotiate the terms of co-investments and at times insist on flexibility to deviate from strict mutatis mutandis decision making. This flexibility could cause the underlying investment to be less successful for the co-investors than for the sponsor’s Investment Fund. In addition, the sponsor’s Investment Fund typically receives or otherwise benefits from transaction, monitoring, and other fees and remuneration in connection with co-investment transactions. These fees are often not shared with co-investors, thus making investments less attractive for co-investors than for the sponsor’s Investment Fund. The sponsor’s Investment Fund is typically responsible for break-up fees if the underlying transaction is ultimately not consummated for certain reasons attributable to such Investment Fund. Some co-investment opportunities require co-investors to bear their pro-rata portion of any such break-up fees. In these situations, a Lexington Fund could be required to pay a portion of a break-up fee if a coinvestment transaction is not consummated. Certain Risks Particular to Sponsor Solutions Investments Certain Lexington Funds are focused on “continuation vehicle” or other sponsor solutions transactions sponsored by the general partners or managers of private investment funds. Such investments are expected to be purchased on an opportunistic basis indirectly from existing investors of the underlying sponsors and Lexington expects all (or a large portion of) underlying sponsors to seek consent of their respective existing investors or the limited partner advisory committees or boards thereof in connection with the transactions, and such existing investors may be less motivated to sell their interests and/or consent to such transactions during periods when the performance of such portfolio companies or funds is perceived to be improving. In addition, even upon a successful bid, legal or contractual transfer restrictions, including restrictions related to publicly traded partnership and other tax-related transfer restrictions, rights-of-first-refusal or an underlying sponsor’s failure to obtain the applicable consent from its limited partners or limited partner advisory committees or boards, change-ofcontrol and other similar provisions applicable to such investment, may prevent a Lexington

Fund from making such investment. For example, private companies may provide pre-emptive rights in certain circumstances triggered by such transactions or the participation of such Lexington Fund, which may create competition from existing investors with respect to investments in such companies. In addition, typically these transactions are negotiated by one or two lead investors that will negotiate the terms of such transactions, including price, structure, sponsor economics, alignment, governance, and information rights. The lead investor(s) will also negotiate the transaction documents and governing agreements on behalf of the continuation vehicle (with the sponsor representing the selling fund). The length of time it takes to close a continuation vehicle transaction depends upon a number of factors including the complexity of the transaction and its structure, the consent process of the selling fund, and any other required consents/approvals (regulatory or otherwise) that may be necessary in order to consummate the transaction. In the event Lexington is not the lead investor or it is one of multiple lead investors, Lexington’s ability to negotiate the terms will be limited. This dynamic of a handful of influential investors in a continuation vehicle will continue for the duration of the investment holding period. Even where such continuation vehicle has a limited partner advisory committee, such committee can be expected to be led by one or two large investors who may have weighted votes or otherwise have veto rights that may affect important strategic decisions (e.g., strategy, capital structure, management) as well as the timing/means of exit with respect to the underlying asset. While legal risks similar to those described above for secondary investments and co-investments exist here generally, the risk of not acquiring clear title to an underlying portfolio company will be mitigated where the sponsor becomes a large investor on the “buy-side” of the transaction through its commitment to the continuation vehicle (including “rolling” any crystallization of its carried interest). Certain Risks Particular to the Registered Funds Investments in the Registered Funds will be primarily illiquid, and the Registered Funds are designed principally for long-term investors. Unlike most traditional U.S. registered funds, the Registered Funds do not provide shareholders with the ability to readily liquidate their investments. The Registered Funds are not open-end funds (commonly known as mutual funds), whose shareholders generally are entitled to redeem shares on a daily basis, and Registered Fund shares are not traded on any securities exchange. Instead, investments in the Registered Funds should be considered illiquid, and are appropriate only for investors who are comfortable with investment in less liquid or illiquid portfolio investments within an illiquid fund. Investments in the Registered Funds are not suitable for investors who need access to the money they invest. Shareholders generally will not have the right to redeem their shares on demand, and the Registered Funds do not expect a secondary market to develop. Liquidity will be provided only through periodic, non-guaranteed repurchase offers made by the Registered Funds, typically on a quarterly basis, subject to the terms and limitations of each repurchase offer. Shares of the Registered Funds are also subject to limitations on transferability, and transfers may otherwise occur only by operation of law – such as in the case of death, divorce, insolvency, bankruptcy, or adjudicated incompetence – or, for shareholders of the U.S. Registered Fund, with the prior written consent of the board of trustees of the U.S. Registered Fund, which may be withheld in its sole discretion. Certain provisions of the Investment Company Act, including Section 17(a), prohibit the U.S. Registered Fund from engaging in affiliate transactions with Franklin Templeton, Lexington,

or their affiliates, except as permitted under applicable exemptions or regulatory relief. The Lexington Funds and the Offshore Registered Fund are not subject to Section 17(a), and therefore are eligible to participate in certain transactions that would be prohibited for the U.S. Registered Fund. Separately, Section 17(d) of the Investment Company Act and Rule 17d-1 thereunder impose additional limitations on joint transactions involving the U.S. Registered Fund and its affiliated persons, including affiliated funds. These joint-transaction restrictions apply only to U.S. registered investment companies and do not apply to the Lexington Funds or the Offshore Registered Fund, which may participate in co-investment or other joint transactions with affiliated funds subject to the Advisers Act, fiduciary obligations, and contractual requirements. The U.S. Registered Fund has received an exemptive order from the SEC that permits it to participate in certain joint transactions or co-investment transactions alongside Lexington’s private fund clients, subject to specified conditions and requirements (the “Section 17(d) and Rule 17d-1 Exemptive Order”). Lexington reserves the right to revise its investment allocation policies and procedures at any time without notice to, or consent from, the shareholders of the Registered Funds. Allocation of Investment Opportunities Among Lexington Funds; Co-Investment Allocations Lexington expects to be presented with investment opportunities that fall within the investment objectives or strategies of more than one Lexington Fund and/or Registered Fund. Unless the context otherwise requires, references to the “Lexington Funds” in this “Allocation of Investment Opportunities Among Lexington Funds; Co-Investment Allocations” section include the Registered Funds. Lexington has adopted written policies and procedures relating to the allocation of investment opportunities and will make allocation determinations consistently therewith. If Lexington concludes that an investment opportunity is appropriate and advisable for more than one Lexington Fund, it then determines which of such Lexington Funds will participate in that investment opportunity. The factors Lexington typically considers at this stage include, but are not limited to: whether Lexington has an obligation, pursuant to the Governing Documents of the applicable Lexington Funds or otherwise, to offer some or all of the investment opportunity to one or more particular Lexington Funds; whether, if the opportunity relates to an investment previously made by one or more eligible Lexington Funds, Lexington has the obligation or right to allocate the entire opportunity to such Lexington Fund(s), or otherwise prioritize such Lexington Fund(s) in allocating the opportunity; and whether legal, regulatory, tax, liquidity, and/or contractual restrictions would prohibit or limit the participation of certain Lexington Funds or investors within certain Lexington Funds in the investment opportunity, or whether, based on legal, regulatory, tax, and/or liquidity implications of the investment opportunity for a Lexington Fund’s portfolio as a whole, the participation of such Lexington Fund is not advisable. If Lexington determines that multiple Lexington Funds will participate in a particular investment opportunity, Lexington will allocate such opportunity among such Lexington Funds in accordance with its policies and procedures and on a basis that Lexington reasonably

determines in good faith to be fair and reasonable taking into account relevant facts and circumstances including (without limitation): the specific investment guidelines and investment focus, strategy, objectives, size, geographical limitations, risk profile, legal, regulatory and tax constraints, life cycle and pacing, and capital available for investment of each applicable Lexington Fund; projected future capacity for investment of each applicable Lexington Fund; diversification needs and prudent concentration levels, including exposure of the applicable Lexington Funds to specific underlying portfolio funds and/or sponsors; the composition of each applicable Lexington Fund’s portfolio; availability of other suitable investments for each applicable Lexington Fund; the applicable Lexington Funds’ liquidity; the size of the applicable investment opportunity; each applicable Lexington Fund’s targeted rate of return; in the case of a portfolio of interests, the ability to allocate the interests to more than one Lexington Fund; specific underlying fund investment objectives and restrictions, and the level of unfunded commitments of the applicable underlying funds; legal and contractual restrictions applicable to the transfer of the applicable interests; tax implications applicable to the investment opportunity; risk considerations of each applicable Lexington Fund; cash flow considerations of each applicable Lexington Fund; industry and other allocation targets of each applicable Lexington Fund; lender covenants and other limitations applicable to the investment opportunity and/or any applicable Lexington Fund; any investment limitations, restrictions or other obligations in the applicable Governing Documents, including for the avoidance of doubt the governing documents of the Registered Funds (including whether the applicable Lexington Funds are permitted to syndicate portions of investments); potential conflicts of interest, including whether any applicable Lexington Fund has an existing investment in the security in question or the issuer of such security and whether any “right of first refusal” or similar right exists with respect to a specific Lexington Fund; whether the investment opportunity requires additional consents or authorizations from applicable Lexington Funds, investors, Lexington Fund boards or third parties; the nature of the investment opportunity, including minimum and/or maximum investment amounts, expected holding periods, the source of the opportunity and the involvement of specific deal teams in sourcing the opportunity; whether an investment opportunity would enable any applicable Lexington Fund to qualify for certain programmatic benefits or discounts (e.g., the ability to enter into credit arrangements with certain financial or governmental institutions) that are not readily available to other applicable Lexington Funds; whether applicable laws, regulations or administrative interpretations or guidance make the investment inadvisable or prohibit the investment for a particular Lexington Fund; current and anticipated market conditions; the presence of a potential co-investor (A) who has provided value by assisting in sourcing, establishing relationships, or participating in diligence and/or negotiations with respect to the applicable investment opportunity, or (to the extent applicable to the relevant investment) is expected to provide value to the business or operations of a portfolio company, or otherwise in relation to the investment, post-closing, (B) who has the ability (to the extent relevant to the applicable investment) to aid in operating or monitoring a portfolio company or enterprise, or possesses certain expertise or (as applicable) chemistry with the management team of the potential portfolio company or enterprise, or has existing positions in the portfolio company or enterprise, or (C) whose participation Lexington believes, in its sole discretion, will help establish, recognize, strengthen and/or cultivate relationships that may provide, indirectly, longer-term benefits (including strategic, sourcing or similar benefits) to Lexington, the Lexington Funds and/or future funds managed by Lexington; and such other considerations as Lexington deems relevant in good faith. When Lexington

determines that only one Lexington Fund will participate in an investment opportunity, Lexington assesses the amount of the available opportunity that is advisable for such Lexington Fund. In making this assessment, Lexington is permitted to consider any of a number of factors, which typically include certain of the factors described above for allocations of investment opportunities among multiple Lexington Funds. Lexington does not allocate investment opportunities based, in whole or in part, on (i) the relative fee structure or the amount of fees paid by any Lexington Fund, or (ii) the profitability of any Lexington Fund. Investors and prospective investors should be aware that Lexington’s entitlement (relative to Franklin Templeton) to retain carried interest generated by the privately-offered Lexington Funds is higher than its entitlement to retain incentive fees generated by the Registered Funds. This difference in relative entitlements to compensation can create an incentive for Lexington to prioritize the private Lexington Funds over the Registered Funds when allocating certain investment opportunities. Despite this potential incentive to act otherwise, Lexington is committed to acting in the best interests of its clients, and to allocating investment opportunities to, and among, the private Lexington Funds and the Registered Funds in a manner that is fair and equitable to all such funds over time, consistent with the allocation policies, procedures, and practices described in this Item 8, and compliant with the governing documents of all relevant funds and all applicable legal and regulatory requirements. Lexington makes good faith determinations for allocation decisions based on expectations that will, in certain circumstances, prove inaccurate. Such determinations involve elements of subjective judgment, and there can be no assurance that subjective judgments made by Lexington will prove correct in hindsight. In addition to the processes described above, potential negotiated investments that may be allocated to the U.S. Registered Fund are further evaluated using procedures related to compliance with the terms and conditions of the U.S. Registered Fund’s exemptive order. The Registered Funds participate alongside other Lexington Funds in many or most of their portfolio investments. The Registered Funds’ participation will likely result in other Lexington Funds participating in investment opportunities to a lesser extent than would otherwise be the case, or not at all. The laws and regulations applicable to the Registered Funds may influence which investment opportunities Lexington pursues. The Registered Funds also may not be permitted to participate in all portfolio investments alongside applicable Lexington Funds as a result of such laws and regulations, which will result in a greater share of such opportunities being allocated to such Lexington Funds. In certain circumstances, an investment opportunity will be deemed to be inappropriate (in whole or in part) for a Lexington Fund for reasons that may include one or more of the foregoing allocation factors. As a result, certain Lexington Funds sometimes will invest in opportunities that other Lexington Funds with similar investment strategies have declined (in whole or in part), and likewise, certain Lexington Funds sometimes will decline to invest in opportunities (in whole or in part) in which other Lexington Funds have invested. Furthermore, the application of the investment allocation requirements and factors set forth above will often

result in allocation on a non-pro rata basis and there can be no assurance that a Lexington Fund will participate in all investment opportunities that fall within its investment objectives. In addition, principal executive officers and other personnel of Lexington invest in Lexington Funds (either directly or indirectly through the general partner of the applicable Lexington Fund), and therefore, participate indirectly in investments made by the Lexington Funds in which they invest, consistent with the Governing Documents of the applicable Lexington Fund(s). Such interests will vary and can create an incentive to allocate particularly attractive investment opportunities to the Lexington Fund(s) in which such personnel hold greater interests. The existence of these varying circumstances presents conflicts of interest in determining how much, if any, of certain investment opportunities to offer to a Lexington Fund. In addition, to the extent an investment opportunity is received that Lexington determines is unsuitable for the Lexington Funds, in Lexington’s sole discretion, Lexington and its personnel reserve the right to refer such opportunity to third parties. In certain limited circumstances, subject to Lexington’s compliance policies, Lexington personnel will or may be permitted to make personal investments in an investment opportunity that Lexington has declined on behalf of one or more Lexington Funds. Although the following discussion of the allocation of co-investment opportunities, structuring of co-investments, and related matters, is relevant to the Registered Funds, certain technical aspects discussed in the following paragraphs apply primarily to the private investment funds managed by Lexington, and not to the Registered Funds, whose prospectuses and related offering documents include disclosures on co-investment matters as they relate to the Registered Funds and their investors. Lexington often has discretion with respect to the investment of co-investment capital. Lexington has formed, and will form in the future, committed co-investment vehicles or managed accounts both during and following a Lexington Fund’s fundraising period to participate alongside such Lexington Fund in investment opportunities, and certain of such vehicles likely will receive priority with respect to co-investment allocations. Such committed co-investment vehicles or managed accounts are in some cases allocated investment opportunities based on available capital (as determined by Lexington), or the ratio of capital commitments to such vehicles or accounts and the total or target capitalization of the applicable Lexington Fund, and in other cases are allocated investment opportunities on a different basis as agreed to by Lexington and the investor(s) in such vehicles or accounts. Lexington shall offer opportunities to invest in such vehicles to investors in its sole discretion. The capital committed to such co-investment vehicles or managed accounts would generally not be included in the overall size limitations on a Lexington Fund’s investment program. In addition to committed co-investment vehicles and managed accounts, in certain circumstances Lexington determines that the amount of a specific investment opportunity exceeds the amount Lexington believes would be appropriate for the participating Lexington Fund(s) and, in such event, Lexington reserves the right to offer co-investment opportunities alongside the Lexington Fund(s) in such specific investment opportunity. Lexington generally does not, and does not expect to, offer co-investment opportunities with respect to all of a Lexington Fund’s investments. Subject to any investment allocation requirements set forth in

the Governing Documents of the applicable Lexington Fund(s), in general (i) decisions regarding whether and to whom to offer co-investment opportunities are made in the sole discretion of Lexington, (ii) co-investment opportunities typically will be offered to some investors and not to other investors, and (iii) Lexington reserves the right to offer coinvestment opportunities to certain persons other than investors in the Lexington Funds (e.g., third parties). It is expected that many investors who may have expressed an interest in coinvestment opportunities will not be allocated any co-investment opportunities or will receive a smaller amount of co-investment opportunities than the amount requested. Subject to the relevant Governing Documents and Lexington’s policies and procedures relating to co-investment allocation, Lexington allocates each specific co-investment opportunity in its sole discretion to potential co-investors, which may include but are not limited to investors in Lexington Funds and third parties, and typically considers some or all of a wide range of factors, including (without limitation): Lexington’s evaluation of the size and financial resources of the potential co-investment party and Lexington’s perception of the ability of that person or entity (in terms of, for example, staffing, expertise and other resources) to efficiently and expeditiously participate in the investment opportunity with the relevant Lexington Fund(s) without harming or otherwise prejudicing such Lexington Fund(s), in particular when the investment opportunity is time-sensitive in nature, as is often the case; Lexington’s evaluation of whether the potential co-investment party has a complicated tax structure that would require particular structuring implementation or covenants that would not otherwise be required; any confidentiality concerns Lexington has or believes may arise in connection with providing the potential co-investment party with specific information relating to the investment opportunity in order to permit such person or entity to evaluate the investment opportunity; Lexington’s evaluation of whether the investment opportunity may subject the potential coinvestment party to legal, regulatory, competitive, confidentiality, reporting, public relations, media or other burdens that make it less likely that the potential co-investment party would act upon the investment opportunity if offered; Lexington’s evaluation of whether a particular potential co-investment party has provided value in sourcing, establishing relationships, or participating in diligence and/or negotiations with respect to the investment opportunity or (to the extent applicable to the relevant investment) is expected to provide value to the business or operations of a portfolio company, or otherwise in relation to the investment, post-closing; to the extent applicable to the relevant investment, the ability of the potential co-investment party to aid in operating or monitoring a portfolio company or enterprise, or the possession of certain expertise by the potential co-investment party and (as applicable) the potential coinvestment party’s chemistry with the management team of the potential portfolio company or enterprise and whether the potential co-investment party has any existing positions in the portfolio company or enterprise; Lexington’s evaluation of whether the profile or characteristics of the potential co-investment party may have an impact on the viability or terms of the proposed investment opportunity and/or the ability of the applicable Lexington Fund(s) to take advantage of such opportunity; the character and nature of the investment opportunity and/or the co-investment portion of such opportunity (including the potential coinvestment amount, structure, geographic location, tax characteristics and relevant industry); the level of demand for participation in the investment opportunity; whether the potential coinvestment party has indicated a desire to participate in investments of the type offered; any requirements or restrictions concerning co-investments in the Governing Documents and/or

side letters of the applicable Lexington Fund(s); whether Lexington believes, in its sole discretion, that allocating the co-investment opportunity to the potential co-investment party will help establish, recognize, strengthen and/or cultivate relationships that have the potential to provide, indirectly, longer-term benefits (including strategic, sourcing or similar benefits) to Lexington, the Lexington Funds and/or future funds managed by Lexington; and whether the potential co-investment party has demonstrated a long-term and/or continuing commitment to the potential success of Lexington, the Lexington Funds, and/or future funds managed by Lexington. The factors above are not listed in order of importance or priority, and Lexington is not required to, and does not, consider all of the factors described above with respect to any particular investment. Some factors may be more or less important depending upon the nature of the particular investment and attendant circumstances. The allocation of co-investment opportunities can involve benefits to Lexington including, without limitation, fees or carried interest from the co-investment opportunity and capital commitments to other Lexington Funds. There can be no assurance that Lexington will be successful in offering a co-investment opportunity to a potential co-investor, in whole or in part, that the closing of such coinvestment will be consummated in a timely manner, that a co-investment will take place on terms and conditions that are preferable for the applicable Lexington Fund, or that expenses incurred by a Lexington Fund with respect to the syndication of a co-investment will not be substantial. In addition, to the extent permitted in the applicable Governing Documents, a Lexington Fund will in certain circumstances close on an investment opportunity and later syndicate all or a portion of such opportunity to a co-investor, and Lexington will not necessarily require such co-investor to pay any interest to such Lexington Fund with respect to the Lexington Fund’s earlier capital contributions and/or expense payments in connection with the co-investor’s subsequent acquisition of such opportunity. Similarly, if a Lexington Fund acquires an investment and subsequently sells down a portion of the investment to a third party co-investor, it is possible, subject to the applicable Governing Documents, that such Lexington Fund will not be fully reimbursed for the portion of its expenses that are attributable to such co-investor’s portion of the investment. Further, it is possible that an actual or potential co-investor may experience financial, legal or regulatory difficulties and may have economic, tax, regulatory, contractual, or other business interests or goals that are inconsistent with those of the applicable Lexington Fund, and as a result, may take a different view from Lexington as to appropriate strategy for an investment or may be in a position to take action contrary to a Lexington Fund’s investment objective. In determining whether, and by what margin, the amount of an available investment opportunity exceeds the amount that is appropriate for the participating Lexington Fund(s) (including, for the avoidance of doubt, the Registered Funds), Lexington expects to be subject to potential conflicts of interest because, in most cases, the amount of an investment opportunity available to co-investors increases as the amount allocated to participating Lexington Funds decreases. Because co-investment opportunities generally appeal to Lexington Fund investors and third parties, Lexington could be incentivized to conclude that

the appropriate investment size for the relevant Lexington Fund(s) is smaller than it would have concluded in the absence of potential for allocation to co-investors. In the event that a proposed co-investment opportunity is not consummated but certain costs and expenses have been incurred by one or more Lexington Fund(s), Lexington or its affiliates in pursuit of such investment opportunity (including, without limitation, legal, financial, travel and other business diligence costs and expenses), such costs and expenses generally will be paid solely by such Lexington Fund(s), and it is expected that any potential co-investors (including committed co-investment vehicles) will generally not bear any portion of such “broken deal” costs and expenses. Lexington or its affiliates in certain circumstances establish dedicated co-investment vehicles for specific investors in order to facilitate investments by the relevant investors as coinvestment parties alongside a Lexington Fund. Any such vehicle will be established at Lexington’s or its affiliates’ sole discretion, and Lexington and its affiliates generally have no obligation to offer a similar opportunity to any other investor. Lexington may establish investment vehicles or accounts (including “evergreen” vehicles or accounts) in the future for the purpose of aggregating one or more investors’ existing interests in investment funds managed by other sponsors, and such vehicles or accounts may also make new investments, sourced by Lexington. Such Lexington-managed vehicles are not expected to be “successor funds” under the Governing Documents of any Lexington Fund, and may participate in investment opportunities in accordance with the foregoing away from the Lexington Funds. Such vehicles may invest in actual or proposed investments of a Lexington Fund, and may give rise to conflicts of interest between such vehicles, on the one hand, and such Lexington Fund, on the other. Lexington typically expects such vehicles or accounts to be non-discretionary, or in certain cases, be subject to opt-out rights. There can be no assurance that such conflicts of interest will be resolved in a manner favorable to the relevant Lexington Fund(s). See also “Related Party Transactions” below. Simultaneous Transactions There may be instances where Lexington negotiates transactions with counterparties that involve more than one Lexington Fund in different capacities. For example, a Lexington Fund may sell to or purchase an indirect interest in a portfolio company from a counterparty (such as another sponsor’s fund or limited partners therein), while the same counterparty or, to the extent such counterparty is an Investment Fund, one or more limited partners therein, acquire or sell a direct or indirect interest in the same or another portfolio company to another Lexington Fund. While these transactions may be separate or non-contingent, due to the simultaneous or closely related timing of these transactions, there may be actual or perceived conflicts of interest in connection with such transactions due to Lexington’s duties to the selling Lexington Fund on one hand, and such other Lexington Fund participating in the related transaction on the other, for example with respect to ensuring each transaction is separately in the best interest of each Lexington Fund and that the valuations are fair and reasonable to each Lexington Fund, among other things. To the extent Lexington believes that such transactions rise to the level of a conflict where mitigation would be appropriate, Lexington may, for

example, negotiate each such transaction independently and ensure there is not a crossconditioned closing of the two transactions, to ensure that the terms of each such transaction stand on their own, but is not required to do so or to engage in any other conflict mitigation techniques with respect to such transactions. Spot Pricing Lexington and its affiliates will be required, in certain cases, to allocate purchase prices to specific underlying Investment Funds that are purchased in a single transaction or a series of related transactions, and the methodologies utilized by Lexington and its affiliates to determine such allocations and purchase prices may differ amongst Lexington Funds and specific underlying Investment Funds, and Lexington will face conflicts of interest in regard to such determinations. In certain circumstances, the price allocated to a specific underlying Investment Fund on a Lexington Fund’s books and records may differ significantly from the price allocated to such fund in the applicable purchase agreement. Related Party Transactions On occasion, a Lexington Fund will, as a result of its investment in an Investment Fund, acquire assets owned, in whole or in part (directly or indirectly), by other Lexington Funds or Franklin Templeton (or affiliates thereof), and in such cases, proceeds will flow indirectly from such Lexington Fund to such other Lexington Funds or Franklin Templeton (or affiliates thereof) (such selling funds, “Existing Lexington Investors” and such purchasing funds “Purchasing Lexington Investors”). This could occur, for example, if a Lexington Fund invests in a sponsor’s “continuation vehicle” which acquires assets from an existing vehicle (an “Existing Vehicle”) of such sponsor, and another Lexington Fund or Franklin Templeton (or affiliates thereof) is an investor in that existing fund. A Lexington Fund may also acquire fund interests from a fund-of-funds in which other Lexington Funds or Franklin Templeton (or affiliates thereof) invest. Such transactions generally do not require (and Lexington does not expect to seek) the consent of the advisory boards or comparable governing bodies of the applicable Lexington Funds or any investor under the Governing Documents of the applicable Lexington Funds because such transactions are not directly between a Lexington Fund and an “affiliate” (even in situations where a Lexington Fund or Franklin Templeton (or affiliates thereof) is the lead buyer or represents a majority of the new capital, or where a Lexington Fund or Franklin Templeton (or affiliates thereof) represent a significant portion of the selling investors). There can be no assurance that any Investment Fund interest or asset directly or indirectly acquired or sold by a Lexington Fund or Franklin Templeton (or affiliates thereof) in the types of scenarios described above will not be valued or allocated a sale price that is higher or lower than might have been the case if such asset had been acquired or sold (as applicable) by a third party rather than a Lexington Fund. Lexington will not be required to solicit third-party bids or obtain a third-party valuation prior to causing a Lexington Fund to participate in such transactions. There can be no assurance that the potential conflicts of interest inherent in such transactions will be resolved in a manner favorable to any specific Lexington Fund. In determining whether to proceed with a transaction that involves an Existing Lexington Investor, Lexington will consider whether any factors are present that mitigate the conflict of

interest involved, even if such factors do not eliminate or fully address the conflict of interest. To the extent more than one Lexington Fund participates in such assets, such participation can be expected to be at different times or on different terms (including with respect to the economic terms such as advisory fees and carried interest and the calculations, timing and amount thereof, veto rights with respect to investments and any governance rights, reporting rights or information rights afforded to limited partners of each Lexington Fund and other matters). Non-Controlling Investments; Investments with Third Parties The Lexington Funds will generally hold non-controlling interests in their portfolio investments. The Lexington Funds may make portfolio investments with other third parties through acquisition vehicles, joint ventures, or other entities. The Lexington Funds may coinvest with third parties through consortiums of private equity investors (including limited partners), joint ventures or other entities. Such portfolio investments may involve risks in connection with such third-party involvement, including the possibility that a third-party coventurer may have financial, legal, or regulatory difficulties, resulting in a negative impact on such investment, may have economic or business interests or goals that are inconsistent with those of the Lexington Funds, or may be in a position to take (or block) action in a manner contrary to a Lexington Fund’s investment objectives. In addition, a Lexington Fund may in certain circumstances be liable for the actions of its third-party co-venturers. Furthermore, third-party co-venturers may provide services similar to, and overlapping with, services provided by Lexington to the Lexington Funds or their respective portfolio investments, and, notwithstanding the foregoing, fees attributable to such services will not offset Advisory Fees or otherwise be allocated to, or shared with, limited partners. Additional conflicts would arise if a joint venture partner or counterparty is related to Lexington in any way, such as through a sub-advisory relationship with Lexington and its affiliates. Finally, the allocation of investment opportunities to consortium partners may result in fewer co-investment opportunities (or reduced allocations) being made available to other investors in Lexington Funds. Competition from Investment Funds Investment Funds (or their managers or underlying portfolio companies) in certain circumstances compete with the Lexington Funds or other Investment Funds for investment opportunities. It is also possible that certain Investment Funds (or their managers or underlying portfolio companies) will engage in activities that have adverse consequences on the Lexington Funds and/or other Investment Funds. The foregoing may give rise to conflicts of interest, and there can be no assurance that these matters will be resolved in a manner favorable to the Lexington Funds. Material Non-Public Information; Regulatory Restrictions on Trading Lexington expects, in a variety of circumstances including, without limitation, when Lexington considers a specific direct (or, in some cases, indirect) investment opportunity or a Lexington Fund sits on the advisory committee of an Investment Fund, to come into possession of

material non-public and/or price-sensitive information about certain securities. The Lexington Funds generally are not free to act upon any such information, and Lexington’s possession of such information typically will limit the ability of any Lexington Fund to buy and sell such securities, even if such information was obtained in the context of the investment activities of a different Lexington Fund, and even if the relevant information is not known to the Lexington Personnel (as defined below) responsible for the investment decisions of the Lexington Fund that might otherwise buy or sell the relevant securities. Additionally, Lexington sometimes decides for compliance and similar reasons to restrict the Lexington Funds’ ability to buy and sell certain securities in light of information that Lexington has received or reasonably expects to receive, or for other reasons including, but not limited to, contractual obligations in connection with existing or prospective investments of the Lexington Funds. These restrictions apply to a Lexington Fund regardless of whether any sensitive information has actually been disclosed to the Lexington Personnel responsible for its investment decisions, and could cause a Lexington Fund not to be able to initiate a transaction that it otherwise might have initiated and not to be able to sell an investment that it otherwise might have sold. It is possible that the limitations and restrictions described above will become stricter and/or more frequent over time, in light of Lexington’s relationships and interactions with Franklin Templeton and Franklin Templeton’s various other subsidiaries and business lines (which may come into possession of information that could limit a Lexington Fund’s ability to engage in potential transactions), and Franklin Resources, Inc.’s status as a public company. Strategic Relationships Lexington has entered, and is expected to enter, into agreements with investors and/or one or more of their affiliates or partners involving one or more strategies, as part of an integrated overall arrangement with Lexington, including, solely for purposes of this paragraph, its parent entity and affiliates thereof and/or involving an agreement or understanding to subscribe for a commitment to a Lexington Fund and one or more commitments to other funds managed and/or advised by Lexington (including discretionary co-investment vehicles), which may include a commitment already made to another such fund. Such an agreement would typically involve an investor agreeing to make a capital commitment to multiple Lexington Funds, pursuant to which such investor and/or its affiliates may participate in investment vehicles and/or managed accounts sponsored or advised by Lexington, which would seek to make investments in a range of underlying investment strategies (including investments of a type that would be appropriate for other Lexington Funds), with terms and conditions applicable to such investor and/or its affiliates negotiated between Lexington and such investor on a case by case basis, which will not be available or otherwise apply to investors in other relevant Lexington Funds. As a part of any such arrangement (or as an additional service to an investor in another Lexington Fund) Lexington reserves the right to provide secondment opportunities (or other knowledge transfer opportunities) at Lexington to investors and/or assist an investor in evaluating its portfolio of private fund interests or continuation vehicle “roll” opportunities, and a Lexington Fund may subsequently purchase one or more of an investor’s interests in the ordinary course. In addition, it is possible that the investment objectives pursued by any such funds, vehicles or accounts formed to facilitate a multi-strategy investor’s investments with Lexington will overlap with those of other Lexington Funds and receive allocations of investments, in whole or in part, that would otherwise be appropriate for other Lexington

Funds. Except as required by law, investors in the Lexington Funds will not receive a copy of the agreement memorializing such a multi-strategy investment program (even if in the form of a side letter) or receive any other disclosure or reporting of the terms of or existence of any such relationship or arrangement and will be unable to elect any rights or benefits granted to such multi-strategy investor, even if the amount invested by such investor and/or its affiliates in a Lexington Fund, or its related vehicles, as part of such integrated overall arrangement is less than the commitment of another investor. Specific examples of such additional rights and benefits relating to a multi-strategy investor or a special account can be expected to include, among others, specialized reporting, discounts or reductions on and/or reimbursements or rebates of management fees or carried interest (including through profit sharing or otherwise receiving an interest in carried interest distributions or investment advisory fees received by Lexington), secondment of personnel from the investor to Lexington or an affiliate (or vice versa), specialized trainings for personnel from the investor by Lexington or an affiliate, access by such investor to additional information, negotiated terms regarding the pacing of investments and/or the length of the investment period, allocation of investment and co-investment opportunities, including targeted amounts for co-investments alongside Lexington vehicles (including, without limitation, preferential or favorable allocation of co-investment, and preferential terms and conditions related to co-investment or other participation in Lexington vehicles (including any carried interest and/or management fees to be charged with respect thereto, as well as any additional discounts, reductions, reimbursements or rebates thereof or other penalties that may result if certain target co-investment allocations or other conditions under such arrangements are not achieved)). To the extent any allocations are made pursuant to the Governing Documents of Lexington Funds based on unpaid capital commitments, any such discount or reduction of management or advisory fees will cause the unpaid capital commitments of the applicable investor to fluctuate disproportionately as compared to the unpaid capital commitments of any other limited partner without such management or advisory fee discount or reduction and the same consequences will result from the different management or advisory fees terms amongst investors in Lexington Funds. Lexington, including its personnel, can be expected to receive compensation from such multi-strategy relationships and arrangements, and be incentivized to allocate investment opportunities away from Lexington Funds, or source investment opportunities for such relationships and arrangements. Secondary Transfers To the extent Lexington has approval rights with respect to a secondary transfer of interests in a Lexington Fund pursuant to the applicable Governing Documents, or is asked to identify potential purchasers in connection with any such secondary transfer, Lexington will do so in its sole discretion, generally taking into account certain factors that it deems relevant, which may include: Lexington’s evaluation of the financial resources of the potential purchaser, including its ability to meet capital contribution obligations; whether the potential purchaser meets the suitability standards (e.g., sophistication, no need for liquidity) for investors in the Lexington Fund; Lexington’s perception of its past experiences and relationships with the potential purchaser, including its belief that the potential purchaser would help establish, recognize, strengthen and/or cultivate relationships that may provide, indirectly, longer-term

benefits to current or future Lexington Funds and/or Lexington, and the expected amount and nature of negotiations required in connection with the potential purchaser’s investment; whether the potential purchaser would subject Lexington, the applicable Lexington Fund, or their affiliates to legal, regulatory, reporting, public relations, media or other burdens; the potential purchaser’s investment into another Lexington Fund (including any commitment into a future fund); whether the potential purchaser is a competitor of Lexington, a Lexington Fund, or any of their affiliates; any requirements in such Lexington Fund’s Governing Documents; and any such other facts as it deems appropriate under the circumstances in exercising such discretion. In light of the Lexington Funds’ strategies, Lexington may be incentivized to seek that any proposed sale of an interest in a Lexington Fund be made to another Lexington Fund. Lexington will typically have sole discretion to consent or not consent to the transfer of any interest in a Lexington Fund. Leverage and Affiliate Transactions In certain instances, a Lexington Fund and/or SPV will use leverage (up to certain limits) to finance portfolio investments in a manner consistent with its Governing Documents. The use of leverage may involve a high degree of financial risk. Borrowings by a Lexington Fund and/or SPV have the potential to enhance overall returns that exceed the cost of funds; however, they will further diminish returns (or increase losses on capital) to the extent overall returns are less than the cost of funds. Borrowings repaid out of proceeds received from investments by a Lexington Fund generally will not be deemed distributions to, or capital contributions from, the investors in such Lexington Fund, in which case such proceeds will not be considered investment proceeds under such Lexington Fund’s Governing Documents and will neither increase nor decrease unpaid commitments. In addition, borrowings are in some cases secured by investors’ capital commitments to a Lexington Fund as well as by the assets of the applicable Lexington Fund and subsidiary SPVs, and the documentation relating to such borrowing may provide that during the continuance of a default under such borrowing, the interests of the investors may be subordinated to such borrowing. Moreover, certain counterparties to transactions in which a Lexington Fund participates (including counterparty sellers, lenders, or other credit providers) may require a Lexington Fund to guarantee, or otherwise be liable for, the obligations of (including loans and other extensions of credit to, and hedging and other derivative transactions entered into by) other Lexington Funds, accounts, co-investment vehicles, current or prospective portfolio investments (or any subsidiary thereof), or any SPV formed to effect the acquisition thereof or participating in similar transactions. Many Lexington Funds utilize revolving credit facilities on a long-term basis in advance of calling capital from investors. For administrative convenience, capital calls are sometimes made in “batches” of larger, less frequent capital calls, with a Lexington Fund’s interim capital needs coming from its credit facility. Batching capital calls can increase the risk of potential defaults by investors as a result of there being larger capital calls. To the extent a credit facility obligation is due upon demand by a lender, such a demand may be issued at a time at which liquidity is generally constrained, potentially resulting in greater defaults as a result of liquidity constraints and/or investors facing similar capital calls in multiple funds and being unable to satisfy all such demands simultaneously. Finally, the existence of a credit facility may impair an investor’s ability to transfer its interest in a Lexington Fund as a result of restrictions

imposed on such transfers by the lender. Typically, the interest rate on a revolving credit facility is less than the rate of the preferred return and the preferred return does not accrue on such borrowings (and only accrues on capital contributions when made). As a result, use of a credit facility (or other long-term leverage) generally will result in a higher reported IRR than if the facility had not been utilized in lieu of capital contributions, may reduce or eliminate the preferred return received by investors, and may accelerate or increase distributions of carried interest to the general partner of the applicable Lexington Fund. Therefore, Lexington has an incentive to cause Lexington Funds to borrow under their credit facilities and hold such borrowings outstanding in lieu of calling capital from investors. Lexington may benefit from operating the Lexington Funds in this manner, and the general partner of the applicable Lexington Fund may receive disproportionate benefits from such borrowings. If a Lexington Fund borrows in lieu of calling capital to fund the acquisition of an investment, the borrowing would be used for all partners in such Lexington Fund on a pro rata basis, including the general partner. Borrowings incurred, or guarantees made by, a Lexington Fund are in some cases made on a joint, several, joint and several, or cross-collateralized basis (which may include cross-guarantees and/or be on an investment-by-investment or portfoliowide basis) with other Lexington Funds or related vehicles. Cross-guarantees would typically result in the applicable Lexington Fund being solely liable with respect to its own and any other relevant vehicle’s share of the applicable obligation and would require such Lexington Fund to contribute amounts in excess of its pro rata share, including additional capital to make up for any shortfall if such other relevant vehicle is unable to repay its pro rata share of such indebtedness. In such situations it is not expected that such Lexington Fund would be compensated for being primarily liable for such obligations. In other circumstances, lenders and other market participants could seek “cross default” rights under which a Lexington Fund could be treated as in default under the relevant facility in the event of a default by another Lexington Fund or a Lexington affiliate relating to their respective lending or other facilities; if any such provision were to be triggered, a Lexington Fund’s limited partners could suffer adverse effects resulting from a default by another Lexington Fund or a Lexington affiliate. Borrowing by a Lexington Fund can be secured by capital commitments made by the investors to such Lexington Fund and/or by such Lexington Fund’s assets, and documentation relating to such borrowing may provide that during the continuance of a default under such borrowing, the interests of the investors may be subordinated to such Lexington Fund-level borrowing. Lexington can also cause a Lexington Fund to incur indebtedness that is secured by any assets of such Lexington Fund (e.g., asset-based borrowing, as well as “back leverage” and net asset value (NAV) facilities), and is permitted directly or indirectly through one or more intermediate entities (e.g., special purpose vehicles) to incur indebtedness, including to borrow money from any person, to make guarantees or provide other credit support to any person or to incur any other obligation (including other extensions of credit). Indebtedness is permitted to be incurred for any purpose relating to the activities of a Lexington Fund, including without limitation to: finance any investment-related activities of such Lexington Fund; increase the buying power of such Lexington Fund; provide interim financing to the extent necessary to consummate the purchase of investments prior to the receipt of permanent financing or capital contributions or distributions (as applicable); pay for fund expenses or fund the payment of

Advisory Fees; make, hold or dispose of portfolio investments; provide financing or refinancing; fund the payment of amounts to withdrawing limited partners; fund distributions to the partners; and/or provide collateral to secure outstanding letters of credit or to create reserves, in each case in accordance with the Lexington Fund’s Governing Documents. Additionally, a Lexington Fund is permitted to enter into letters of credit in support of one or more of its portfolio investments, including agreeing to fund additional equity financing or capital expenditures into a portfolio investment (regardless of who the beneficiary to such letter of credit may be) at a certain time or upon the occurrence of a certain event. Borrowings incurred by portfolio investments and intermediate entities of a Lexington Fund generally are not subject to such fund-level limits on borrowing unless specified by the Governing Documents. Lexington may also use leverage differently for different Lexington Funds and other arrangements. As a result of the foregoing, the terms of a particular Lexington Fund’s investment in a portfolio investment and the investment performance thereof may ultimately be materially different than the same with respect to any other Lexington Funds. Investments with Less Established Sponsors A Lexington Fund is likely to invest a portion of its assets in the funds of less established sponsors. Investments related to such sponsors may involve greater risks than are generally associated with investments with more established sponsors. Less established sponsors tend to have fewer resources, and therefore are often more vulnerable to failure. Such sponsors also may have shorter operating histories on which to judge future performance and in many cases, if operating, will have negative cash flow. In addition, less mature sponsors could be deemed to be more susceptible to irregular accounting or other fraudulent practices. In the event of fraud by any sponsor related to a Lexington Fund investment, the Lexington Fund could suffer a partial or total loss of capital invested in such investment. There can be no assurance that any such losses will be offset by gains (if any) realized on such Lexington Fund’s other assets. Illiquidity of Investments by the Lexington Funds; Terms of Underlying Investment Funds A Lexington Fund may not be able to liquidate a particular interest in an Investment Fund or directly held security at the time and upon the terms it desires. Further, the timing of distributions received by the Lexington Funds from the Investment Funds, if any, will likely be at the discretion of such Investment Funds’ management and may not occur at a time that is desirable. Distributions received by the Lexington Funds from the Investment Funds can be in the form of securities. If a Lexington Fund holds securities, in many cases, such Lexington Fund will engage, or cause an SPV to engage, in various hedging transactions, including the purchase and sale of derivative securities which may involve borrowings or guarantees. Unanticipated changes in interest rates, securities prices, currency exchange rates, or other factors could result in losses to such Lexington Fund and its investors. A Lexington Fund may make investments in Investment Funds whose term exceeds the term of such Lexington Fund, or whose term may be extended such that it exceeds the term of such Lexington Fund. Furthermore, notwithstanding that the term of an underlying Investment Fund may have come to an end, an underlying Investment Fund may nevertheless continue to hold unrealized investments or otherwise continue in its winding up and liquidation phase after the end of its

term, and beyond the end of the Lexington Fund’s term. In addition, the governing documents of an underlying Investment Fund can permit the Investment Fund’s general partner, manager, or a percentage in interest of the limited partners to terminate such underlying Investment Fund prior to the end of its stated term. Early termination of an underlying Investment Fund may result in a Lexington Fund receiving distributions of immature and illiquid securities which could have a material adverse effect on the performance of such Lexington Fund. Lack of Liquidity of Interests in the Lexington Funds Investors and prospective investors should be aware of the long-term nature of their investments in the Lexington Funds. There is not now, and will not be, a public market for interests in the Lexington Funds. Interests in the Lexington Funds may not be assigned, transferred, or encumbered without the prior written permission of the general partner of the applicable Lexington Fund. Lexington is under no obligation to facilitate or approve transfers and may reject transfers for any or no reason, and Lexington may be incentivized to seek that any proposed sale of an interest in one Lexington Fund be made to another Lexington Fund. Accordingly, an investor in a Lexington Fund may not be able to liquidate its investment and must be prepared to bear the risks of owning its interest for an extended period of time. An investment in a Lexington Fund is suitable only for sophisticated investors who do not require liquidity for their investment. The inability to transfer interests in the Lexington Funds may limit the availability of estate planning strategies. The Lexington Funds’ interests are not, and will not be, registered under the Securities Act or under the various “Blue Sky” or securities laws of the state or jurisdiction of residence of any Lexington Fund investor. The timing of distributions to investors from the Lexington Funds, if any, will depend in substantial part on the timing of distributions, if any, received by the Lexington Funds from the Investment Funds and/or other investments, and will be unpredictable. Reliance on Management All decisions with respect to the management of a Lexington Fund and the investments of a Lexington Fund will be made by the general partner of such Lexington Fund and/or its affiliates, and thus investors must rely on the ability of such Lexington Fund’s general partner and/or its affiliates to make appropriate investments for such Lexington Fund and to manage and dispose of such investments. It is possible that the general partner of a Lexington Fund and/or its affiliates will be unable to find a sufficient number of attractive opportunities to meet such Lexington Fund’s investment objectives. In addition, the timing and form of distributions from the Lexington Funds will be subject to the discretion of the general partners. Investors will generally have no right or power to participate in the affairs or investment activities of a Lexington Fund or to replace its general partner. Accordingly, no person should purchase an interest in a Lexington Fund unless such person is willing to entrust all aspects of the management of such Lexington Fund and the investments of such Lexington Fund to the Lexington Fund’s general partner and/or its affiliates. Dependence on Key Personnel The success of the Lexington Funds will be highly dependent on the expertise and performance of Lexington’s investment team. There can be no assurance that the members of the investment

team will continue to be associated with Lexington and/or the respective general partners of the Lexington Funds or any of their affiliates throughout the life of the Lexington Funds. The loss of certain of these individuals could have a significant adverse impact on the business of the Lexington Funds. Except to the extent set forth in the applicable Governing Documents, investors in the Lexington Funds will have no recourse in the event that any of these individuals ceases to perform services for the Lexington Funds. Investors are not expected to be permitted to withdraw commitments or investments in the Lexington Funds as a result of the departure of one of the professionals responsible for the activities of the Lexington Funds, and any remedies available to investors in a Lexington Fund are limited to those set forth in such Lexington Fund’s Governing Documents. Franklin Templeton In 2022, Lexington Partners L.P., which directly owns Lexington Advisors LLC, sold 100% of the equity in Lexington Partners L.P. to Franklin Resources, Inc., a global investment management organization that, together with its affiliates, engages in a broad spectrum of activities including financial, advisory, investment, and other activities. The following discussion relates primarily to potential conflicts between Franklin Templeton and Lexington and/or their respective funds, other than the Registered Funds. Potential conflicts of interest relevant to the Registered Funds are discussed in detail in the Registered Funds’ prospectuses and related offering documents. Many of the potential conflicts of interest described herein with respect to a Lexington Fund in relation to Lexington, its related entities and persons and other Lexington Funds, apply in a substantially similar manner with respect to a Lexington Fund in relation to Franklin Templeton and its related investment advisors and investment funds, clients and portfolio companies, which could have interests that conflict with those of a Lexington Fund. For example, Franklin Templeton, its affiliates and its investment funds or accounts will make investments otherwise suitable for certain Lexington Funds (or, in some cases, certain Investment Funds), or form new funds or other vehicles with investment objectives that overlap with those of the Lexington Funds. Franklin Templeton and Lexington are under no obligation to allocate any portion of such investment opportunities to those Lexington Funds (and Franklin Templeton is under no obligation to inform Lexington of any such opportunities), which may result in the Lexington Funds not participating in certain opportunities (in whole or in part) or participating in a different manner than would otherwise have been the case, which could, in turn, have an adverse effect on a Lexington Fund’s performance. In addition, subject to applicable law, a Lexington Fund or Investment Fund could invest with investment funds (or operating companies) affiliated with Franklin Templeton, including in secondary transactions, or invest in portfolio investments in which Franklin Templeton or its controlled affiliates have made prior investments. It is also possible that Franklin Templeton clients or portfolio companies, on the one hand, and Lexington Funds, Investment Funds or their portfolio companies, on the other hand, could compete for investment or business opportunities and could invest in different levels of the same company’s capital structure, which could lead to conflicts of interest. More generally, Franklin Templeton may give advice to its clients or portfolio companies that may cause them to take actions adverse to a Lexington Fund investment.

Franklin Templeton has the potential to earn fees and other compensation (in cash or in the form of securities or other consideration) from or in connection with Lexington Fund investments (or the portfolio companies of Investment Funds) as compensation for services, including in circumstances where clients of Franklin Templeton have interests that conflict with those of a Lexington Fund, and to earn fees and other compensation in connection with unconsummated Lexington Fund transactions. Franklin Templeton also provides a broad range of financial and other services to entities that, in certain circumstances, are expected to include entities in which a Lexington Fund invests (or to the portfolio companies of Investment Funds), directly or indirectly, or potentially the Lexington Funds themselves, and Franklin Templeton generally will be paid fees and other compensation (which may include warrants or other securities) for such services. Other than fees earned in connection with investments (i.e., in connection with a Lexington Fund’s deployment of capital, as opposed to fees for services provided by Franklin Templeton to portfolio investments of Lexington Funds (or the portfolio companies of any Investment Funds)), none of Franklin Templeton’s fees for any of the foregoing will be shared with Lexington Funds or reduce Advisory Fees and any sharing will be solely to the extent expressly set forth in the particular Lexington Fund’s Governing Documents. Franklin Templeton also expects to derive certain ancillary benefits by virtue of its ownership of Lexington, which has the potential to enhance Franklin Templeton’s relationships with various parties, such as sponsors of private equity funds (including sponsors of Investment Funds) or other financial institutions, and may lead to additional business for Franklin Templeton, and the value of any such benefits (to the extent such value could be ascertained) will not reduce Advisory Fees. Franklin Templeton is under no obligation to decline any engagements or investments in order to make an investment opportunity available to any Lexington Fund. Lexington Funds may also co-invest with clients of Franklin Templeton or other persons with whom Franklin Templeton has a relationship in particular investment opportunities, and other aspects of these Franklin Templeton relationships could influence the decisions made by Lexington with respect to Lexington Funds’ portfolio investments and otherwise result in a conflict. Moreover, Lexington and Franklin Templeton could, in the future, enter into additional transactions and arrangements that could give rise to other potential conflicts of interest with respect to the Lexington Funds. Risks Related to Commitment Strategy In many cases, the general partner of a Lexington Fund expects an Investment Fund to draw down less capital than such Lexington Fund has committed to such Investment Fund. If the general partner decides it is in the best interest of the Lexington Fund to fully deploy the total capital commitments of such Lexington Fund’s investors, the general partner will make aggregate commitments to Investment Funds that exceed the aggregate capital commitments of investors to such Lexington Fund. Although each Lexington Fund will monitor cash flow projections closely, there can be no assurance that each such Lexington Fund will be able to meet all of its commitments to the Investment Funds or otherwise successfully implement its commitment strategy. If a Lexington Fund is not able to meet all of its commitments to the Investment Funds, such Lexington Fund may be subject to penalties arising under the terms of its contractual commitments with respect to its investments in Investment Funds, including, without limitation, being required to sell its interest in an Investment Fund or forfeiting a

portion of its investment in an Investment Fund. In such cases, such Lexington Fund’s return from such Investment Fund could be materially lower than it would have been had the Lexington Fund been able to meet all of its commitments. Reliance on Sponsors and Management of Investment Funds The Lexington Funds typically invest in third party-sponsored Investment Funds (although Lexington Funds also invest in other Lexington Funds on occasion). A Lexington Fund will usually not have an active role in the management of such funds or their portfolio investments, and therefore, will not have the opportunity to evaluate the specific investments made by any such fund after the Lexington Fund’s date of investment. Moreover, the Lexington Funds will likely not be able to dispose of their investments in any such funds despite poor performance. The returns of the Lexington Funds will depend significantly on the performance of these unrelated sponsors and could be substantially adversely affected by their poor performance. Additionally, Lexington will generally not be in a position to change an unrelated sponsor’s approach, including with respect to portfolio and risk management, conflicts of interest, environmental, social and corporate governance issues and other relevant matters. The general partners of the Investment Funds will generally have sole and absolute discretion in structuring, negotiating and purchasing, financing, monitoring and eventually divesting investments made by such Investment Funds. Similarly, Lexington will typically not be able to negotiate the level of any fee offsets and will not be responsible for determining whether sponsors are correctly calculating fees or fee offsets. Lexington may not always receive full information from sponsors because certain of this information may be considered proprietary. The lack of access to information may make it more difficult for Lexington to select and evaluate potential investments. There can be no assurance that existing management teams, or any successors, will operate the Investment Funds in accordance with Lexington’s plans or expectations. The returns of the Lexington Funds will depend in large part on the performance of these unrelated investment managers and could be substantially adversely affected by the unfavorable performance of a small number of investment managers. Additionally, Investment Funds need to attract, retain, and develop executives and members of their management teams. The market for executive talent can be, notwithstanding general unemployment levels or developments within a particular industry, extremely competitive. There can be no assurance that Investment Funds will be able to attract, develop, integrate, and retain suitable members of their management teams, and as a result, the Lexington Funds may be adversely affected. In addition, at times, the Lexington Funds’ investment opportunities will require rapid execution, and investment analyses and decisions by the general partners of such Lexington Funds frequently will be undertaken on an expedited basis to take advantage of investment opportunities. In such cases, the information available to the general partners at the time an investment decision is made can be limited, and the general partners at times will not have access to detailed information regarding some or all of the Investment Funds under consideration. Therefore, no assurance can be given that the general partners will have knowledge of all circumstances that could adversely affect an Investment Fund. In addition, a general partner will in certain circumstances seek input from independent consultants in connection with its evaluation and/or diligence of certain proposed Investment Funds. No

assurance can be given as to the accuracy or completeness of the information provided by such independent consultants, and it is possible that the Lexington Funds will incur liability as a result of such consultants’ actions. Holding Vehicles and Special Purpose Vehicles Lexington expects in many cases to pool the Investment Fund interests of a Lexington Fund (and, where applicable, its parallel funds and related special accounts and co-invest vehicles) into holdings vehicles or special purpose vehicles, and it is possible that a Lexington Fund will hold a majority or substantially all of its Investment Fund interests in a single special purpose vehicle. Such special purpose vehicles will be the direct holders of such Investment Fund interests, and the Lexington Fund will not hold separate, direct interests in Investment Funds. The use of such special purpose vehicles gives rise to risks that would not otherwise be present. For example, a Lexington Fund’s interests in such Investment Funds will be exposed to risks as a result of a default by investors in related special accounts or other vehicles or accounts that invest alongside such Lexington Fund, and such risks would not be present if the Lexington Fund owned its interests in such Investment Funds directly, and separately from such other investors. In addition, if such a special purpose vehicle defaults on its obligations with respect to one Investment Fund, the other assets of such special purpose vehicle will be exposed to risks as a result of such default. In some cases, a Lexington Fund will make an investment through a holding vehicle or special purpose vehicle that such Lexington Fund shares with one or more other Lexington Funds or investment vehicles that are not participating in the relevant investment. In such cases, the foregoing risks will similarly apply to such other Lexington Fund(s) and/or investment vehicle(s), notwithstanding that they have no interest in the relevant investment held through such holding vehicle or special purpose vehicle. In certain circumstances, depending on the jurisdiction of organization, applicable tax treaties and other tax, legal, or business considerations, an SPV through which multiple Lexington Funds invest may not provide for complete segregation of assets and liabilities in respect of the applicable Lexington Funds holding investments through such SPV. Accordingly, if any Lexington Fund were unable to meet all of its commitments to the Investment Fund or other investment in which it holds an interest through an SPV, such Lexington Fund’s other investments held through such SPV and other Lexington Funds that hold investments through such SPV could be adversely affected. In addition, to the extent that Lexington establishes an SPV beneath a Lexington Fund to hold directly or indirectly one or more investments (including investments acquired in separate transactions), proceeds received by such SPV from one investment which it holds may be applied to satisfy obligations in respect of one or more other investments held by such SPV. Proceeds may also be used to pay (directly or indirectly via the Lexington Fund) the Lexington Fund’s obligations under its revolving credit facility (including the payment of principal, interest, fees and expenses related thereto), and thereafter such SPV may re-borrow (directly or indirectly via the Lexington Fund) from the facility to satisfy obligations in respect of the investment that generated such proceeds or one or more other investments. The receipt, use and recontribution by such SPV of any such proceeds (whether utilized and re-contributed within one such holding vehicle or transferred to one or more other holding vehicles) shall not be considered distributions received by, or contributions made by, the Lexington Fund or its investors for certain purposes under its Governing Documents (including, for example, that

such proceeds would not reduce or increase, as the case may be, the unfunded commitment of any investor or be subject to any preferred return or be subject to any requirements under the Governing Documents with respect to the timing of distribution of proceeds) and may result in higher or lower reported multiples than if such proceeds had otherwise been distributed (or deemed distributed) to the Lexington Fund or its investors. The use of special purpose vehicles and holding vehicles may permit the general partner of a Lexington Fund to make more investments than would otherwise be the case, and such general partner could be incentivized to do so given the potential to receive more Advisory Fees and carried interest as a result thereof. Lexington does not intend to provide investors with distribution notices or drawdown notices for amounts held and reinvested by holding vehicles or special purpose vehicles in the same manner as it would for amounts held and reinvested by the Lexington Funds. Moreover, significant amounts of cash are held in such holding vehicles for purposes of satisfying ongoing and potential obligations to Investment Funds, and this approach can have adverse impacts on the Lexington Funds. For example, cash may be held in such holding vehicles in lieu of applying such cash to reduce a Lexington Fund’s outstanding borrowings (which would otherwise lower the interest expenses borne by such Lexington Fund). For the avoidance of doubt, any borrowings by such holding vehicles or special purpose vehicles (and/or pledging of their assets) are not subject to the borrowing or other limitations in the Governing Documents of the relevant Lexington Fund, notwithstanding the proportion of such Lexington Fund’s assets held by any such holding vehicle or special purpose vehicle. Multiple Levels of Expense The Lexington Funds and the Investment Funds impose performance-based allocations or fees, management charges, and other expenses. Moreover, Lexington in some cases, in its discretion, causes the Lexington Funds to invest in Investment Funds that charge fees and carried interest, and also (directly or indirectly) invest in underlying investment funds (or other investment vehicles) that themselves charge fees and carried interest. Such fees and expenses will result in greater expense than if investors of a Lexington Fund were able to invest directly in the Investment Funds or the portfolio companies of such Investment Funds. Fees and expenses of the Lexington Funds and the Investment Funds in which the Lexington Funds invest will generally be paid regardless of whether the Lexington Funds or the Investment Funds produce positive investment returns. Lexington Funds are permitted to purchase interests in other Lexington Funds, provided that in each case the sale or purchase is consistent with Lexington’s fiduciary obligations to each relevant Lexington Fund. While Lexington endeavors at all times to act in the best interests of the Lexington Funds, investors should be aware that Lexington’s receipt of compensation from each of the Lexington Funds and the contribution of additional capital by a Lexington Fund to another Lexington Fund creates a potential conflict of interest with respect to such transactions. Financial Market Fluctuations General fluctuations in the market prices of securities and economic conditions generally can reduce the availability of attractive investment opportunities for the Lexington Funds and affect the Lexington Funds’ ability to make investments and the value of the investments held by the Lexington Funds. Instability in the securities markets and economic conditions generally also can increase the risks inherent in the Lexington Funds’ investments. Moreover,

governmental measures undertaken in response to market turmoil (whether regulatory or financial in nature) could have a positive or negative effect on market conditions. There can be no assurance that the market will, in the future, become more liquid than it is at present and it may become more volatile. The ability to realize investments depends not only on portfolio investments and their historical results and prospects, but also on political, market, and economic conditions at the time of such realizations. The duration and ultimate effect of market conditions and whether such conditions may worsen cannot be predicted and there can be no assurances that conditions in the financial markets will not worsen or adversely affect a Lexington Fund or one or more of a Lexington Fund’s portfolio investments. Stakes in Other Sponsors Lexington Funds have the ability to purchase interests in third-party asset managers (i.e., managers not affiliated with Lexington), and such transactions or ownership stakes could present conflicts of interest, for example if a Lexington Fund were to invest in or alongside an Investment Fund managed by such a third-party asset manager. There can be no assurance that such conflicts of interest will not have an adverse impact on the Lexington Funds. Cybersecurity Risk Lexington, the Lexington Funds’ service providers, and other market participants increasingly depend on complex information technology and communications systems to conduct business functions. These systems are subject to a number of different threats or risks that could adversely affect the Lexington Funds and their investors, despite the efforts of Lexington and the Lexington Funds’ service providers to adopt technologies, processes, and practices intended to mitigate these risks and protect the security of their computer systems, software, networks, and other technology assets, as well as the confidentiality, integrity, and availability of information belonging to the Lexington Funds and their investors. For example, unauthorized third parties, including activist, criminal, nation-state or terrorist actors, may attempt to improperly access, modify, disrupt the operations of, or prevent access to these systems of Lexington, the Lexington Funds’ service providers, counterparties, or data within these systems. Third parties may also attempt to fraudulently induce personnel, customers, third-party service providers or other users of Lexington’s systems to disclose sensitive information in order to gain access to Lexington’s data or that of the Lexington Funds or the Lexington Funds’ investors. If technology systems are compromised, become inoperable for extended periods of time or cease to function properly, Lexington, the Lexington Funds, the Investment Funds and/or their portfolio companies may incur significant time or expense to fix or replace them and to seek to remedy the effects of such issues. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in Lexington’s, the Lexington Funds’, the Investment Funds’ and/or their portfolio companies’, and/or service providers’ operations, including the ability to make distributions to limited partners, and result in a failure to maintain the security, confidentiality, or privacy of sensitive data, including personal information relating to investors (and the beneficial owners of investors). A successful penetration or circumvention of the security of Lexington’s systems could result in the loss or theft of an investor’s data or funds, the inability to access electronic systems, loss or theft of proprietary information or corporate data, physical damage to a

computer or network system, or costs associated with system repairs. Such incidents could cause the Lexington Funds, Lexington, or their service providers to incur regulatory penalties, reputational damage, additional compliance costs or financial loss. In addition, Lexington may incur substantial costs related to forensic analysis of the origin and scope of a cybersecurity breach, increased and upgraded cybersecurity, identity theft, unauthorized use of proprietary information, adverse investor reaction, or litigation. Similar types of operational and technology risks are also present for the Investment Funds and the Lexington Funds’ direct portfolio company investments, which could have material adverse consequences for such Investment Funds and such direct portfolio company investments, and may cause the Lexington Funds’ investments to lose value. Data Protection Risk The Lexington Funds depend on Lexington to develop, or procure and utilize, appropriate systems for the Lexington Funds’ activities, and Lexington and the Lexington Funds depend heavily upon computer systems to perform necessary business functions. Lexington’s and the Investment Funds’ information and technology systems (and those of companies on which the Lexington Funds rely, and in which the Lexington Funds invest) are just as with other companies, vulnerable to potential damage or interruption from cyber-attacks (such as computer viruses, malicious software, infiltration or tampering by unauthorized persons, ransomware demands, and denial of service attacks), security breaches (such as physical and electronic break-ins), network failures, computer and telecommunication failures, ransomware demands, denial of service attacks, usage errors by their respective professionals, power outages, and catastrophic events such as fires, tornadoes, floods, hurricanes, and earthquakes. Although Lexington has implemented, and the Investment Funds and (where applicable) portfolio companies likely will have implemented, various measures to manage risks relating to these types of events, if important systems are compromised, become inoperable for extended periods of time, or cease to function properly, it likely would be necessary for Lexington, the Lexington Funds and/or an Investment Fund or portfolio company to make a significant investment to fix or replace them. Investment Funds may be invested in or otherwise involved with companies that have experienced cybersecurity events and/or that, given the rise of cybersecurity incidents, may become involved in future cybersecurity events. Cybersecurity incidents and cyber-attacks have been occurring globally at a more frequent and severe level and will likely continue to increase in frequency in the future (including as a consequence of the COVID-19 pandemic and the increased frequency of virtual working arrangements). The failure or inadequacy of these systems, and/or of disaster recovery plans for any reason, could cause significant interruptions in Lexington’s, the Lexington Funds’ and/or an Investment Fund’s, or portfolio company’s operations and result in a failure to maintain capabilities essential to the Lexington Funds’ operations and/or the security, confidentiality, and privacy of proprietary or sensitive data and information (including personal information of investors) that is processed and stored in, and transmitted through, the computer systems and networks of Lexington, the Lexington Funds, third parties on which the Lexington Funds rely or their respective downstream vendors. Such a failure could harm Lexington’s, the Lexington Funds’ and/or an Investment Fund’s or portfolio company’s reputation, subject any such entity and their respective affiliates to legal claims, and otherwise affect their business and financial performance.

If a significant number of Lexington’s personnel were to be unavailable in the event of a disaster, Lexington’s ability to effectively conduct the Lexington Funds’ business could be severely compromised. In addition, there are increased risks relating to Lexington’s reliance on its computer programs and systems if Lexington’s personnel are required to work remotely for extended periods of time as a result of events such as an outbreak of infectious disease or other adverse public health developments or natural disasters, including an increased risk of cyber-attacks and unauthorized access to Lexington’s computer systems. Lexington’s service providers are subject to the same electronic information security threats as Lexington. If a service provider fails to adopt or adhere to adequate data security policies, or in the event of a breach of its networks, information relating to the Lexington Funds, including information normally made available to investors, may become inaccessible and personally identifiable information of the investors may be lost or improperly accessed, used, or disclosed. Notwithstanding the diligence that Lexington performs on its service providers, there can be no assurance that Lexington will be able to identify all risks or fully and accurately assess the reliability of each service provider’s systems. The loss or improper access, use, or disclosure of Lexington’s or the Lexington Funds’ proprietary information could cause Lexington or the Lexington Funds to suffer, among other things, financial loss, the disruption of their business, liability to third parties, regulatory intervention, or reputational damage. Any of the foregoing events could have a negative effect on the Lexington Funds. There are certain costs (e.g., on-line time) and possible risks (e.g., slow downloading time, system outages, and documents being quarantined in “fire walls”) associated with electronic delivery. Moreover, Lexington cannot provide any assurance that these communication methods are secure and will not be responsible for any security breaches, computer viruses, problems or malfunctions resulting from any computer viruses or other problems that may be associated with the use of an internet-based system. Hedging Arrangements The Lexington Funds and the Investment Funds and/or their portfolio companies in many cases employ hedging techniques designed to reduce the risks of adverse movements in interest rates, securities prices, and currency exchange rates. While such transactions may reduce certain risks, such transactions themselves may entail certain other risks. Thus, while a Lexington Fund may benefit from the use of these hedging mechanisms, unanticipated changes in interest rates, securities prices, or currency exchange rates may result in a poorer overall performance for the Lexington Fund than if it or the Investment Funds and portfolio companies in which the Lexington Fund invests had not entered into such hedging transactions. Impact of Government Regulation, Reimbursement and Reform Certain industry segments in which a Lexington Fund or an Investment Fund may invest are (or may become) (i) highly regulated at both the federal and state levels in the United States and internationally, and (ii) subject to frequent regulatory change. Certain segments may be

highly dependent upon various government (or private) reimbursement programs. While each Lexington Fund intends to invest in companies that seek to comply with applicable laws and regulations, and/or in Investment Funds that similarly intend to invest in such companies, the laws and regulations relating to certain industries are complex, may be ambiguous, or may lack clear judicial or regulatory interpretive guidance. An adverse review or determination by any applicable judicial or regulatory authority of any such law or regulation, or an adverse change in applicable regulatory requirements or reimbursement programs, could have a material adverse effect on the operations and/or financial performance of the companies in which a Lexington Fund or Investment Fund may invest. Any current or future proposed rulemakings or rule amendments by the SEC, to the extent adopted, can be expected to result in material alterations to how Lexington operates its business and/or the Lexington Funds, as well as Lexington’s implementation of the Lexington Funds’ investment strategies, and there can be no assurance that such alterations will not have a material adverse effect on Lexington or the Lexington Funds, their portfolio investments and/or their limited partners. To the extent permitted under the Governing Documents, the incremental costs of compliance with any new SEC rules may be borne by the Lexington Funds, and such costs may be significant. General Tax Considerations An investment in a Lexington Fund may involve complex tax considerations that will differ for each investor, and there may be delays in distributing important tax information to investors (including the distribution of U.S. Schedule K-1s or their equivalent). In addition, Lexington Funds will take positions with respect to certain tax issues that depend on legal and other interpretive conclusions. Should the U.S. Internal Revenue Service (“IRS”) or another tax authority successfully challenge any such positions, a partner or Lexington Fund might be found to have a different tax liability for that year than that reported on its tax return. Secondary Valuations There is no established market for secondary private equity partnership interests, interests in investment vehicles formed for sponsor solutions investments, or for the privately-held portfolio companies of private equity sponsors, and there are not likely to be any comparable companies for which public market valuations exist. Although the acquisition price of the Lexington Funds’ investments is frequently the subject of negotiation, the acquisition price is typically determined by reference to the carrying values most recently reported by the underlying funds (which may be based on interim unaudited financial statements) and other available information. In addition, under limited circumstances, Lexington may not have access to all material information relevant to a valuation analysis. For example, the sponsors of Investment Funds are not generally obligated to update any valuations in connection with a transfer of interests on a secondary basis, and such valuations may not be indicative of current or ultimate realizable values. As a result, the valuation of Investment Funds in which the

Lexington Funds invest may be based on imperfect information and is subject to inherent uncertainties. In addition, investors in the Lexington Funds should be aware that Advisory Fees will be charged and calculated as set forth in the applicable Lexington Fund’s Governing Documents, which can include fees being charged on a basis that is not always tied to the then-current net asset value of the Lexington Fund, including in certain cases with respect to step-downs in Advisory Fees occurring after a Lexington Fund’s investment period. Where Advisory Fees are charged on current value, Lexington generally relies upon the reported value provided by the general partner (or similar managing entity) of an Investment Fund for determination of such Investment Fund’s fair market value, although to the extent Lexington is in possession of necessary information from the applicable Investment Fund, it will make any adjustments to the reported value of such Investment Fund to the extent necessary to comply with U.S. GAAP. As such, Lexington is not incentivized (or required) to write down a higher-thanexpected reported value unless Lexington has received information from such Investment Fund necessary to determine that such reported value is in contravention of U.S. GAAP, and faces conflicts of interest with regard to such determinations. In addition, the determination whether to characterize an investment as having been disposed of or subject to a permanent write-off generally remains in the good faith judgment of Lexington and involves subjective judgments and creates conflicts of interest, due to the impact of such determinations of the total amount of Advisory Fees payable to Lexington. With respect to dividends and/or distributions received by a Lexington Fund, Lexington generally expects to follow the treatment given to such dividend and/or distribution by the transaction sponsor including in determining whether such proceeds constitute a return of capital, a gain on the investment or a combination thereof, which will determine whether a portfolio investment is treated as subject to a disposition in full or in part for purposes of the Lexington Fund’s Governing Documents. As a result, the amount of Advisory Fees generally will not correspond with fluctuations in a Lexington Fund’s net asset value, including following a Lexington Fund’s investment period, and will not be reduced in connection with any investment write-downs, except in a case where the investment is written off as described above and, in all cases, subject to the Lexington Fund’s Governing Documents. Cayman Islands Regulatory Oversight Certain Lexington-sponsored investment vehicles established in the Cayman Islands, including certain alternative investment vehicles and intermediate entities established in the Cayman Islands, have registered or will be required to register and be regulated as private funds under the Private Funds Act (as amended) (the “Private Funds Act”) of the Cayman Islands. Once an investment vehicle is registered as a private fund, the Cayman Islands Monetary Authority (the “Authority”) will have supervisory and enforcement powers to ensure such vehicle’s compliance with the Private Funds Act, which will add costs to the legal, operational, and compliance obligations of the relevant Lexington Funds. The Authority may take certain actions if it determines that a regulated private fund has breached, or is at risk of breaching, any of its obligations under the Private Funds Act. The powers of the Authority include the power to require the substitution of the operator of such vehicle, to appoint a person to advise such vehicle on the proper conduct of its affairs, or to appoint a person to assume control of the affairs of such vehicle, in certain circumstances set out in the Private Funds Act. There are

other remedies available to the Authority including, inter alia, the ability to cancel the registration of the vehicle and to apply to the court for approval of other actions. Russian Invasion of Ukraine In February 2022, the Russian military commenced an invasion of Ukraine, which remains ongoing. Subsequently, the United States, United Kingdom and European Union have announced various sanctions against Russia, and may impose further sanctions designed to target the Russian financial system or take other actions against Russia. In addition, a number of countries have banned Russian planes from their airspace. U.S. and allied countries have recently announced they are committed to taking steps to prevent certain Russian banks from accessing international payment systems. Russia’s invasion of Ukraine, the resulting displacement of persons both within Ukraine and to neighboring countries and the increasing international sanctions could have a negative impact on the economy and business activity globally (including in the United States and other countries in which the Lexington Funds invest), and therefore, could adversely affect the performance of the Lexington Funds’ investments. Given the ongoing nature of the conflict between the two nations and its ongoing escalation (such as Russia’s recent decision to place its nuclear forces on high alert and the possibility of significant cyberwarfare against military and civilian targets globally), it is difficult to predict the conflict’s ultimate impact on global economic and market conditions, and, as a result, the situation presents material uncertainty and risk with respect to the Lexington Funds and the performance of their investments or operations, and the ability of the Lexington Funds to achieve their investment objectives. Furthermore, if after subscribing to a Lexington Fund, an investor is included on a sanctions list, such Lexington Fund may be required to cease any further dealings with the investor’s interest until such sanctions are lifted or a license is sought under applicable law to continue dealings. October 7th Attacks on Israel; Aftermath On October 7th, 2023, Hamas (an organization which has governed Gaza, and which has been designated as a terrorist organization by the United States, the United Kingdom, the European Union, Australia and other nations), committed a terrorist attack within Israel (the “October 7th Attacks”). Israel responded by initiating a full-scale invasion of Gaza. The conflict and measures taken in response have and could be expected to continue having a negative impact on the economy and business activity globally (including in countries in which the Lexington Funds invest), and therefore, could adversely affect the performance of portfolio investments. The severity and duration of the conflict and its future impact on global economic and market conditions (including, for example, oil prices) are impossible to predict, and as a result, present material uncertainty and risk with respect to the Lexington Funds and the performance of their investments and operations, and the ability of the Lexington Funds to achieve their investment objectives. For example, the armed conflict has, at one point or another, involved the United States, Lebanon (and/or Hezbollah), Syria, Iran, Qatar, and/or other countries or terrorist organizations. On October 9, 2025, Israel and Hamas agreed to a U.S.-led peace plan, however any resumption of hostilities and/or any further expansion of the conflict could exacerbate the risks described above. Similar risks exist to the extent that any portfolio investments (or their underlying portfolio companies), service providers, vendor or certain other parties have material operations or assets in the Middle East, or the immediate surrounding areas. In

response to the October 7 Attacks, the United States has announced sanctions and other measures against Hamas-related persons and organizations, and the United States (and/or other countries) can be expected to announce further sanctions related to any resumption of hostilities and/or expansion of the conflict in the future. Non-U.S. Investments A Lexington Fund may invest a substantial portion of its assets in funds or operating companies organized, headquartered and/or focused on investments outside the United States. Non-U.S. securities, including those held by funds in which the Lexington Funds invest, involve certain risks not typically associated with investing in U.S. securities. In addition, portfolio investments (including their respective underlying portfolio companies, as applicable) with operations in non-U.S. jurisdictions may be involved in restructurings, bankruptcy proceedings and/or reorganizations that are not subject to laws and regulations that are similar to the U.S. Bankruptcy Code and the rights of creditors afforded in U.S. jurisdictions. To the extent such non-U.S. laws and regulations do not provide a Lexington Fund with equivalent rights and privileges necessary to promote and protect its interest in any such proceeding, such Lexington Fund’s investments may be adversely affected. OFAC and FCPA Considerations Economic sanction and anti-corruption laws in the United States, including the U.S. Foreign Corrupt Practices Act (“FCPA”) and other jurisdictions may prohibit Lexington, Lexington’s professionals and Lexington Funds from transacting with or in certain countries and with certain individuals and companies. In the United States, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) administers and enforces laws, Executive Orders and regulations establishing U.S. economic and trade sanctions. These types of sanctions may significantly restrict the Lexington Funds’ investment activities in certain emerging market countries. In addition, the Lexington Funds may be adversely affected because of their unwillingness to participate in transactions that violate such laws or regulations. Such laws and regulations may make it difficult in certain circumstances for the Lexington Funds to act successfully on investment opportunities and for the funds and operating companies in which the Lexington Funds invest to obtain or retain business. Any determination that Lexington has violated the FCPA or other applicable anti-corruption laws or anti-bribery laws could subject Lexington to, among other things, civil and criminal penalties, material fines, profit disgorgement, injunctions on future conduct, securities litigation, and a general loss of investor confidence, any one of which could adversely affect Lexington’s business prospects and/or financial position, as well as the Lexington Funds’ ability to achieve their investment objectives and/or conduct their operations. The Lexington Funds may incur costs and expenses associated with engaging external counsel or other third-party consultants or professionals in connection with inquiries or investigations relating to FCPA or other applicable anti-corruption laws or anti-bribery laws. Trade Policy The future of global free trade, and the approach of the U.S. government to tariffs and international trade policy generally (particularly in light of the recent presidential election), is

uncertain. The U.S. and other foreign governments have instituted tariffs on certain goods and have indicated a willingness to impose additional tariffs on U.S. and non-U.S. products. Global trade disruption, significant introductions of trade barriers and bilateral trade frictions, together with any future downturns in the global economy resulting therefrom, could adversely affect the financial performance of the Lexington Funds and their portfolio investments and be an ongoing source of instability, potentially resulting in significant currency fluctuations and/or have other adverse effects on international markets, international trade agreements and/or other existing cross-border cooperation arrangements (whether economic, tax, fiscal, legal, regulatory or otherwise). To the extent that a trade dispute escalates into a “trade war”, there could be significant adverse impacts on the industries in which the Lexington Funds participate and on the Lexington Funds’ overall performance. Foreign Ownership Laws Current laws and regulations in various jurisdictions give heads of state and regulatory bodies the authority to block or impose conditions with respect to acquisitions of, and investments in, local entities by foreign persons if an acquisition or investment threatens to impair national or economic security or is otherwise deemed undesirable. In addition, many jurisdictions restrict foreign investment by taking steps including but not limited to placing limitations on foreign investment, implementing investment screening or approval mechanisms, and restricting the employment of foreigners as key personnel. In addition, a number of U.S. states are passing and implementing state laws prohibiting or otherwise restricting the acquisition of interests in real property located in the state by foreign persons. As a result of such laws, the Lexington Funds may incur significant delays and costs or be altogether prohibited from making particular investments, and the syndication or sale of Lexington Fund assets to certain buyers could be impeded or restricted, all of which could adversely affect the Lexington Funds’ ability to meet their investment objectives. These laws could limit the Lexington Funds’ ability to invest in certain entities or impose burdensome notification requirements, operational restrictions, or delays in pursuing and consummating transactions. Increasing Scrutiny of ESG Matters Lexington and its affiliates are subject to increasing scrutiny from regulators, elected officials, investors and other stakeholders with respect to ESG matters, which may adversely impact the ability of the Lexington Funds to raise capital from certain investors, constrain capital deployment opportunities for the Lexington Funds and impact Lexington’s brand and reputation. With respect to the alternative asset management industry, in recent years, certain investors, including public pension funds, have placed increasing importance on the impacts of investments made by the private funds to which they commit capital, including with respect to climate change and diversity, among other aspects of ESG. On the other hand, anti-ESG sentiment has also gained momentum across the United States, with several states having enacted or proposed “anti-ESG” policies, legislation or issued related legal opinions. Accordingly, Lexington is expected to be subject to competing demands from different investors and other stakeholder groups with divergent views on ESG matters, including the role of ESG in the investment process. This divergence increases the risk that any action or lack thereof with respect to ESG matters will be perceived negatively by at least some potential

stakeholders and could adversely impact Lexington’s reputation. If Lexington and its affiliates do not successfully manage ESG-related expectations across the varied interests of its stakeholders, including existing or potential investors, the Lexington Funds’ ability to access and deploy capital may be adversely impacted. In addition, a failure to successfully manage ESG-related expectations may negatively impact Lexington’s business, erode stakeholder trust and constrain investment opportunities. Environmental Matters Environmental laws, regulations, and regulatory initiatives play a significant role in certain industries and can have a substantial impact on investments in these industries. The Lexington Funds may invest in portfolio investments that are subject to changing and increasingly stringent environmental and health and safety laws, regulations, and permit requirements, and there can be no guarantee that all costs and risks regarding compliance with environmental laws and regulations can be identified. New and more stringent environmental and health and safety laws, regulations, and permit requirements or stricter interpretations of current laws or regulations could impose substantial additional costs on portfolio investments or potential portfolio investments (or their respective underlying portfolio companies). Compliance with such current or future environmental requirements does not ensure that the operations of the Lexington Funds’ portfolio investments will not cause injury to the environment or to people under all circumstances or that the Lexington Funds’ portfolio investments will not be required to incur additional unforeseen environmental expenditures. Any noncompliance with these laws and regulations could subject the Lexington Funds and their investments to material administrative, civil, or criminal penalties or other liabilities. Weather and Climatological Risks As consensus builds that global warming is a significant threat, initiatives seeking to address climate change through regulation of greenhouse gas emissions have been adopted by, are pending, or have been proposed before international, federal, state, and regional regulatory authorities. Climate change may cause more extreme weather conditions and increased volatility in seasonal temperatures, which can interfere with operations and increase operating costs, and damage resulting from extreme weather may not be fully insured. Many industries (e.g., electrical power, mining, manufacturing, transportation, and insurance) face various climate change risks, many of which could conceivably materially impact them. Such risks include (i) regulatory/litigation risk (e.g., changing legal requirements that could result in increased permitting and compliance costs, changes in business operations, the discontinuance of certain operations, and related litigation), (ii) market risk (e.g., declining market for products and services seen as greenhouse gas intensive), and (iii) physical risk (e.g., risks to plants or property owned, operated or insured by a company posed by rising sea levels, increased frequency or severity of storms, drought, and other physical occurrences attributable to climate change). These risks could result in unanticipated delays or expenses, especially for electricity, and under certain circumstances, could prevent completion of investment activities once undertaken, any of which could have an adverse effect on the Lexington Funds. Artificial Intelligence and Machine Learning Developments

In the current period of rapid technological and commercial innovation, new businesses and approaches may be created that could affect Lexington, the Lexington Funds and their portfolio investments or alter the market practices the Lexington Funds’ strategies have been designed to function within and on which the Lexington Funds’ strategies depend for investment return. For example, recent technological developments in artificial intelligence, including machine learning technology and generative artificial intelligence such as ChatGPT (collectively, “AI Technologies”), pose risks to Lexington, the Lexington Funds and their portfolio investments. Any of these technological innovations could damage the Lexington Funds’ portfolio investments (or their underlying portfolio companies), significantly disrupt the market in which they operate and subject them to increased competition, which could materially and adversely affect their business, financial condition and results of investments. AI Technologies are highly reliant on the collection and analysis of large amounts of data and complex algorithms, but it is not possible or practicable to incorporate all relevant data into models that AI Technologies utilize to operate, nor does Lexington expect to be involved in the collection of such data or development of such algorithms in the ordinary course. Moreover, with the use of AI Technologies, there exists a lack of transparency of how inputs are converted to outputs and Lexington in no way will be able to verify this process and its accuracy. Accuracy of such inputs and the resulting impact on the modeling of AI Technologies cannot be verified and could result in risk of diminished quality control or false or misleading information, including coding that may be used by Lexington, the Lexington Funds, their portfolio investments or relevant third parties. Risks related to the effectiveness of AI Technologies could adversely impact Lexington, the Lexington Funds and their portfolio investments (and their underlying portfolio companies) to the extent they rely on the work product of such AI Technologies. This could include Lexington, the Lexington Funds and their portfolio investments experiencing, directly or indirectly, negative impacts or otherwise being subject to or implicated by litigation or investigations involving any possible violation of laws related to use of these technologies, including by operating partners or service providers. Notwithstanding any preventative policies or practices that aim to restrict or govern the use of AI Technologies, it is possible that the Lexington Funds’ portfolio investments (or their underlying portfolio companies) and/or other entities or persons connected to Lexington and/or the Lexington Funds, could utilize AI Technologies in contravention of such policies or otherwise misuse AI Technologies. Adequacy of Reserves As is customary in the industry, the Lexington Funds may establish holdbacks or reserves, including for estimated accrued expenses, Advisory Fees, pending or anticipated liabilities, investments, claims, and contingencies relating to the applicable Lexington Fund. Estimating the appropriate amount of such reserves is difficult and inadequate or excessive reserves could impair the investment returns to investors. If a Lexington Fund’s reserves are inadequate and Lexington is unable to draw down capital commitments or borrowings pursuant to the Governing Documents of such Lexington Fund, the Lexington Fund may be unable to take advantage of attractive investment opportunities, fulfill its obligations to Investment Funds or protect its existing investments. Further, the allocation of investment opportunities among the

Lexington Funds may depend, in part, on their respective reserves at the time of allocating the relevant opportunity, possibly resulting in different investment allocations if any such reserves are inadequate or excessive. Distributions in Kind The Lexington Funds expect to make investments which may not be advantageously disposed of prior to the date the relevant Lexington Fund will be dissolved, either by expiration of the relevant Lexington Fund’s term or otherwise. The Lexington Funds may have to sell, distribute, or otherwise dispose of investments at a disadvantageous time as a result of dissolution. In addition, although upon the dissolution of a Lexington Fund, its general partner (or the relevant liquidator) generally will be required to use its reasonable efforts to reduce to cash and cash equivalents such assets of such Lexington Fund as the general partner or such liquidator shall deem advisable to sell, subject to obtaining fair value for such assets and any tax, legal, contractual, market, or other considerations (including legal restrictions on the ability of a limited partner to hold any assets to be distributed in kind), there can be no assurances with respect to the time frame in which the winding up and the final distribution of proceeds to a Lexington Fund’s limited partners will occur, and this is likely to be the case for investments in Investment Funds, which are generally highly illiquid. In connection with the winding up and dissolution of a Lexington Fund, the Lexington Fund may make distributions in-kind, including, in the form of portfolio investments that are not marketable or are otherwise illiquid (such as limited partnership interests in Investment Funds). At the time of such distribution, such portfolio investments will likely be subject to transfer restrictions limiting marketability. The ability of a Lexington Fund’s limited partners to liquidate positions in such portfolio investments is subject to these risks, and such limited partners must be prepared to hold such portfolio investments for an extended period of time following a determination to dissolve the Lexington Fund in question. The value of the portfolio investments distributed may increase or decrease before such portfolio investments are sold, and a limited partner will incur transaction costs in connection with the sale of any such portfolio investment. Additionally, portfolio investments distributed to a Lexington Fund limited partner may not be readily marketable or saleable and may have to be held by such limited partner for an indefinite period of time. The risk of loss and delay in liquidating these portfolio investments will be borne by the relevant limited partner, with the result that such limited partner may ultimately receive less cash than it would have received if it had been paid in cash. Misconduct of Lexington Personnel and Third-Party Service Providers Lexington’s reputation is critical to maintaining and developing relationships with existing and prospective investors, as well as with the numerous third parties with which Lexington and the Lexington Funds do business. In recent years, there have been a number of highly publicized cases involving fraud or other misconduct by personnel in the financial services industry, and there is a risk that personnel misconduct could occur with respect to the Lexington Funds. Misconduct by personnel or by third-party service providers could cause significant losses to the Lexington Funds. Personnel misconduct could include, among other things, binding the Lexington Funds to transactions that exceed authorized limits or present unacceptable risks

and other unauthorized activities or concealing unsuccessful investments (which, in each case, would result in unknown and unmanaged risks or losses), or otherwise charging (or seeking to charge) inappropriate expenses to the Lexington Funds and/or Lexington. In addition, any improper use or disclosure of confidential information by personnel and third-party service providers could result in litigation or serious financial harm, including limiting the Lexington Funds’ business prospects or future activities. Furthermore, because of Lexington’s diverse business entities and the regulatory regimes under which they operate, misdeeds by a Lexington entity (or its personnel) could result in foreclosing Lexington’s ability to conduct its activities in the manner otherwise intended. It is not always possible to detect, deter, and/or prevent misconduct by personnel and/or service providers, and the precautions Lexington takes to detect and prevent this activity are not guaranteed to be effective in all cases. It is also the case that misconduct at the level of a company in which the Lexington Funds invest also could have a negative effect on such company, and potentially on the Lexington Funds and/or Lexington, and similar challenges in detection, deterrence, and prevention apply, to an even greater degree, at such level. Social Media and Publicity Risk The use of social networks, message boards, internet channels and other platforms has become widespread within the United States and globally. As a result, individuals now have the ability to rapidly and broadly disseminate information or misinformation, without independent or authoritative verification. Any such information or misinformation regarding Lexington, the Lexington Funds or one or more portfolio companies could have a material and adverse effect on the value of the Lexington Funds.

Relationships with Related Persons Lexington is wholly owned by Lexington Partners L.P. (“Lexington Partners”), an investment adviser registered with the SEC. Lexington Partners provides sub-advisory, back-office, administrative and/or other services to Lexington and may receive advisory fee revenue from Lexington in connection with the investment advisory services provided by Lexington to its managed private investment funds. Moreover, Lexington is affiliated with Administradora Lexington Partners, S.C., Lexington Partners UK LLP, Lexington Partners Asia Limited, Lexington Partners Chile SPA, Lexington Partners Luxembourg S.a.r.l., and Lexington Partners ME Limited (collectively, the “Lexington Foreign Affiliates”), each of which provides certain consulting, advisory and/or sub-advisory services to Lexington and its affiliates. Lexington, Lexington Partners, and the Lexington Foreign Affiliates share compliance personnel, and the personnel of the Lexington Foreign Affiliates are subject to the same compliance policies and procedures and Code of Ethics requirements as the personnel of Lexington and Lexington Partners (in addition to any other compliance requirements of applicable regulatory authorities in the Lexington Foreign Affiliates’ respective jurisdictions). Furthermore, various related entities of Lexington serve as general partners of the Lexington Funds. Lexington manages a number of Lexington Funds (including, for purposes of this paragraph, the Registered Funds) that have investment objectives similar to each other. Lexington also expects that it, Lexington Partners, or their personnel, will in the future establish one or more additional investment funds and/or managed accounts with investment objectives substantially similar to, or different from, those of the current Lexington Funds. Allocation of available investment opportunities between and among the Lexington Funds and any “successor” investment funds and/or managed accounts of the type described in the preceding sentence can, and in many cases does, give rise to conflicts of interest. Lexington expects in certain circumstances for it, or its affiliates, to give advice or take actions with respect to the investments of one or more Lexington Funds that Lexington and its affiliates do not, or might not, give or take with respect to other Lexington Funds with similar investment programs, objectives, or strategies. For this and other reasons, Lexington Funds with similar strategies generally do not hold the same securities or achieve the same performance. In addition, it is expected that personnel of Lexington responsible for managing a particular Lexington Fund will have responsibilities with respect to other Lexington Funds, including “successor” funds and other managed accounts. Potential conflicts of interest arise in allocating time, services or functions of these officers and personnel. Lexington will, in certain circumstances, consider, and reject an investment opportunity on behalf of one Lexington Fund and subsequently determine to have another Lexington Fund make an investment in the same opportunity. A potential conflict of interest arises in such circumstances because one or more Lexington Funds generally will benefit from the initial evaluation, investigation, and due diligence undertaken by Lexington on behalf of the original Lexington Fund considering the investment. In such circumstances, the benefitting Lexington Fund(s) will not be required to reimburse the original Lexington Fund for expenses incurred, directly or indirectly, in connection with reviewing such investment.

In addition, in connection with Lexington’s services to the Lexington Funds, Lexington and Lexington Personnel expect to receive certain tangible and intangible benefits. For example, in the course of Lexington’s operations, including research, due diligence, investment monitoring and investment activities, Lexington and Lexington Personnel expect to receive and benefit from various kinds of information, “know-how,” experience, analysis and data relating to financial, industry, market, business operations, trends, budgets, customers, suppliers, competitors, and other metrics (collectively, “Lexington Information”). In many cases, Lexington Information will include tools, procedures, and resources developed by Lexington to organize or systematize data for ongoing or future use. In addition, Lexington Information is expected, in certain instances, to include information received or generated in connection with efforts on behalf of one Lexington Fund’s investment (or prospective investment) in a portfolio investment. As a result of receiving Lexington Information, Lexington believes it is generally better able to anticipate macroeconomic and other trends, and otherwise develop investment strategies. Lexington has in the past, and is likely in the future, to enter into information sharing and confidentiality arrangements with respect to the Lexington Funds’ portfolio investments and other sources of information that may limit the internal distribution and use of such information. Lexington has already used and is likely in the future in certain instances to use Lexington Information in a manner that may provide a material benefit to Lexington, its affiliates, or to certain other Lexington Funds without compensating or otherwise benefitting the Lexington Fund or Lexington Funds from whose investments such information was derived. In addition, Lexington may have an incentive to pursue investments based on the Lexington Information expected to be received or generated. Lexington has in the past, and is likely in the future, to utilize Lexington Information to benefit Lexington, its affiliates or certain Lexington Funds in a manner that otherwise has the potential to create a conflict of interest, but it does not intend to specifically disclose such conflicts to the relevant Lexington Funds. Additionally, as discussed in the section titled “Participation or Interest in Client Transactions; Personal Trading,” Lexington and its related entities are, directly or indirectly, the general partners, limited partners and/or managing members of the general partner of each of the Lexington Funds, including the private investment funds managed by Lexington Partners. Certain principals and related persons of Lexington spend substantially all of their business time on one or more of the Lexington Funds as required pursuant to the terms of each Lexington Fund’s Governing Documents. On the other hand, the time, dedication and scope of work of a professional varies considerably. For example, it is expected that certain personnel will devote substantial time and efforts to multiple Lexington Funds, to leadership roles across multiple investment strategies, and/or to projects related to Franklin Templeton. This has the potential to create conflicts in the allocation of time, resources and investment opportunities to and among the Lexington Funds. Investors are requested to refer to the Governing Documents of each Lexington Fund for complete information on the requisite time commitments of Lexington, Lexington Personnel, and Lexington’s related persons to such Lexington Fund. As discussed above, Lexington Advisors LLC is ultimately owned by Franklin Resources, Inc., which has various subsidiaries that provide financial services, including investment advisory and portfolio management services. See “Franklin Templeton” above.

Selection or Recommendation of Other Advisers As a secondary private equity manager, Lexington selects Investment Funds for its clients. Principals or related persons of the Investment Funds are often permitted to invest in the Lexington Funds. Lexington does not, however, receive compensation from the advisers of such Investment Funds in a manner that would create a material conflict of interest and does not have other business relationships with other advisers that create a material conflict of interest. Certain of Lexington’s principals and/or related persons are invited to serve on the advisory boards of the Investment Funds in which the Lexington Funds invest to provide advice on certain conflicts of interest and other matters pertaining to such Investment Funds. There may be instances where such persons are asked to vote on issues taking the needs of all investors in such Investment Funds into account. In limited circumstances, an investment by a Lexington Fund (or diligence with respect to a potential investment by such Lexington Fund) will cause Lexington and its related persons to become subject to legal or contractual restrictions on their ability to effect transactions for other Lexington Funds, for example due to the receipt of material non-public information. Lexington has engaged consultants (including specialized consultants, external executives and industry roundtable members) and senior advisors located in key areas of interest. Lexington’s advisors work in an advisory capacity with Lexington’s professionals to leverage their strong local connections regarding market intelligence and investment-related resources. The nature of the relationship with each such advisor and the time devotion requirements of each such advisor may vary significantly. The Lexington Funds shall, in Lexington’s discretion, bear their allocable share of the fees, costs and expenses of such advisors. Such advisors are not personnel of Lexington or the Lexington Funds, and therefore, their compensation is in addition to advisory fees paid by the Lexington Funds. To the extent any such fees are paid by a Lexington Fund, they generally will not be offset against or otherwise reduce the Advisory Fee. Subject to applicable law, advisors engaged by Lexington may invest, participate, or engage in (for their own accounts or for the accounts of others), or may possess an interest in, other financial ventures and investment and professional activities of every kind, nature and description, independently or with others, including but not limited to: management of other investment partnerships; investment in, financing, acquisition or disposition of securities; investment and management counseling; providing brokerage and investment banking services; or serving as officers, directors, managers, consultants, advisors or agents of other companies, partners of any partnership, members of any limited liability company or trustees of any trust (and may receive fees, commissions, remuneration or reimbursement of expenses in connection with these activities), whether or not such activities conflict with any interest of Lexington, the Lexington Funds, or their respective investors.

Lexington’s Code of Ethics describes its fiduciary duties and responsibilities to its clients, and sets forth, among other things, Lexington’s policies on (i) receipt of gifts by personnel, (ii) political contributions, and (iii) reporting and monitoring of the personal securities transactions of Lexington Personnel with access to client investment recommendations. The Code of Ethics helps Lexington detect and prevent potential conflicts of interest. Under Lexington’s Code of Ethics, all Lexington Personnel have a duty to act only in the best interests of the Lexington Funds, and all potential conflicts and violations of the Code of Ethics must be promptly reported to Lexington’s Chief Compliance Officer (“CCO”). All Lexington Personnel must acknowledge and adhere to the terms of the Code of Ethics. It is the expressed policy of Lexington that no person employed by Lexington shall prefer his or her own interest to that of an advisory client. To supervise compliance with its Code of Ethics, Lexington requires that certain restricted persons provide annual securities holdings reports and quarterly transaction reports (or equivalent reports or acknowledgments) to the firm’s Legal and Compliance group (“Compliance”), which includes the CCO. Lexington requires such “access persons” to also receive approval from Compliance prior to investing in any initial public offerings or private placements. In an effort to prevent inappropriate securities transactions by Lexington’s personnel, Compliance maintains and makes available a list of restricted securities. Access persons are strictly prohibited from trading on their own behalf in restricted securities without obtaining the prior written approval of Compliance. Lexington requires that all individuals act in accordance with all applicable federal and state regulations governing investment advisory practices. Lexington’s Code of Ethics also includes the firm’s policy prohibiting the misuse of material non-public information. Any individual not in observance of the above may be subject to discipline or termination. Lexington Personnel who violate the Code of Ethics may be subject to remedial actions including, but not limited to, profit disgorgement, fines, censure, demotion, suspension or dismissal. Lexington Personnel are also required to promptly report any violation of the Code of Ethics of which they become aware. Lexington Personnel are required to annually certify compliance with the Code of Ethics.

Lexington reserves the right to refine and modify the Code of Ethics and its other policies and procedures over time. Lexington will provide a complete copy of its Code of Ethics to any client or prospective client upon request. Participation or Interest in Client Transactions; Personal Trading As general partners, limited partners and/or managing members of the general partners of each of the Lexington Funds, Lexington and its related persons have indirect beneficial interests in the securities owned by the Lexington Funds and will share in any profits and losses generated by the Lexington Funds’ investments. Before Lexington makes a recommendation that a Lexington Fund buy or sell a security, all related persons that have direct ownership of such security at the time of such recommendation and would otherwise be expected to participate in the discussions or authorizations concerning such recommendation, are required to disclose such ownership interest to Lexington and may not be permitted to participate in the discussions or authorizations to recommend that a Lexington Fund buy or sell such security. A related person shall not be so restricted if such person’s only interest in a security is (i) held indirectly through one of the Lexington general partner entities, the Lexington Funds or otherwise, or (ii) related to such person’s service as a director or advisor of a portfolio investment entity to facilitate Lexington’s ability to monitor the investment. Lexington and/or certain related persons of Lexington in certain circumstances are permitted, directly or through one or more entities, to sell securities in which they have a direct or indirect ownership interest to certain Lexington Funds in connection with certain “warehousing” or other principal transactions, provided that the sale is consistent with Lexington’s fiduciary obligations to such Lexington Funds. Such transactions will be fully disclosed and the written consent of the applicable Lexington Fund (which, in certain circumstances, may be provided by the applicable Lexington Fund’s advisory board) will be obtained prior to the consummation of any such transactions in accordance with Section 206(3) of the Advisers Act (to the extent such transactions constitute “principal transactions”) and all other applicable state and federal securities laws. In certain situations, related persons of Lexington will be permitted to purchase interests in the same portfolio investments held by one or more Lexington Funds. All such transactions are subject to compliance with Lexington’s Code of Ethics as described above. Lexington reserves the right to cause a Lexington Fund to engage in a “cross transaction” via the purchase or acquisition of a limited partner (or equivalent) interest from or sale or transfer of a limited partner (or equivalent) interest to another Lexington Fund, provided that the transfer is consistent with Lexington’s fiduciary obligations to each Lexington Fund participating in the cross transaction. These transactions can arise when, for example, parallel Lexington Funds and/or committed co-investment vehicles or managed accounts rebalance their portfolios at their final closing, or when a Lexington Fund has warehoused an investment prior to the initial closing of a separate Lexington Fund.

Lexington Funds also are permitted to acquire interests in other Lexington Funds from a Lexington Fund investor to the extent consistent with Lexington’s fiduciary obligations and the applicable Governing Documents. These transactions can arise when, for example, a limited partner interest in a Lexington Fund is included in a larger secondary transaction pursued by a separate Lexington Fund. Lexington reserves the right to also guarantee certain credit facilities entered into by a Lexington Fund or SPV to enable such Lexington Fund or SPV to acquire a portfolio of investments prior to holding an initial closing. In connection with such warehousing arrangements, Lexington will generally be reimbursed for its out-of-pocket costs and receive a backstop guaranty payment from the applicable Lexington Fund or SPV equal to a percentage of the principal amount of the credit facility. Investors are requested to refer to the Governing Documents of the applicable Lexington Fund for additional information on any such loan and warehousing arrangements applicable to such Lexington Fund. While Lexington endeavors at all times to act in the best interests of the Lexington Funds, investors should be aware that Lexington’s receipt of compensation from the Lexington Funds creates inherent potential conflicts of interest. Conflicts of Interest The following discussion relates primarily to the Lexington Funds and Lexington’s associated activities, and not, unless specifically indicated, to the Registered Funds. While certain of the Lexington Funds’ potential conflicts of interest as described below have some relevance to the Registered Funds, the Registered Funds’ prospectuses and related offering documents should be consulted for detailed information on conflicts of interest relevant to the Registered Funds. Lexington and its related entities engage in a broad range of investment-related activities. In the ordinary course of conducting its activities, the interests of a Lexington Fund are expected, in certain instances, to conflict with the interests of Lexington, other Lexington Funds and/or their respective affiliates. For example, the buyers and sellers, directly or indirectly, of any Lexington Fund’s investments will often be investors in Lexington Funds, and a Lexington Fund’s investments in some cases include limited partnership interests in other Lexington Funds. For the avoidance of doubt, Advisory Fees paid by the Lexington Funds with respect to other Lexington Funds are not subject to any offsets. Additionally, underlying funds in which Lexington Funds are investors sometimes sell their assets to other Lexington Funds. While Lexington will seek to negotiate transactions in good faith and on an arm’s length basis, the foregoing presents inherent conflicts of interest and there can be no assurance that there will not be an adverse impact on the Lexington Funds. For example, there can be no assurance that any Investment Fund interest or other asset acquired by a Lexington Fund from such a seller will not be valued or allocated a sale price that is higher than might otherwise have been the case if such asset were acquired from a third party (or lower than might otherwise have been the case if the Lexington Fund is selling to such a buyer). Lexington will not be required to solicit third-party bids or obtain a third-party valuation prior to causing a Lexington Fund to participate in such a transaction. These activities could give rise to potential conflicts of interest

and there can be no assurance that such activities will not have a material adverse effect on the Lexington Funds. Resolution of Conflicts In the case of all conflicts of interest, Lexington’s determination as to which factors are relevant, and the resolution of such conflicts, will be made using Lexington’s best judgment, but in its sole discretion. In resolving conflicts, Lexington will consider various factors, including, without limitation, the interests of the applicable Lexington Funds with respect to the immediate issue and/or with respect to their longer term courses of dealing. Certain procedures for resolving specific conflicts of interest are set forth below. When conflicts arise, the following factors generally mitigate, but will not eliminate, conflicts of interest: •

Many important conflicts of interest will generally be resolved by set procedures, restrictions or other provisions contained in the Governing Documents for the Lexington Funds;

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Lexington has adopted and implemented certain policies and procedures designed to reduce certain conflicts of interest;

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Many of the Lexington Funds have established an advisory board, consisting of representatives of investors not affiliated with Lexington. Lexington is required to obtain advisory board approval with respect to certain conflicts of interest pursuant to the relevant Lexington Funds’ Governing Documents;

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Where Lexington deems appropriate, it can use unaffiliated third parties to help resolve conflicts or to provide input as to the fairness or “arm’s-length” nature of a purchase or sale price (whether or not part of a formal fairness opinion, “request for proposal” process, or proposal or quotation provided exclusively for the benefit of Lexington); and

•

Prior to subscribing for interests in a Lexington Fund, each investor receives information relating to significant potential conflicts of interest arising from the proposed activities of the Lexington Fund.

In certain instances, some conflicts of interest may be resolved in a manner adverse to a Lexington Fund and its ability to achieve its investment objectives. Diverse Membership The investors in the Lexington Funds generally include U.S. taxable and tax-exempt entities, and institutions from jurisdictions outside of the United States. Such investors often have conflicting investment, tax, and other interests with respect to their investments in a Lexington Fund. The conflicting interests among the investors generally relate to, or arise from, among other things, the nature of investments made by a Lexington Fund, the structuring of the acquisition of investments, and the timing of the disposition of investments. As a consequence, conflicts of interest arise in connection with decisions made by Lexington or its affiliates,

including with respect to the nature or structuring of investments, that are more beneficial for one investor than for another investor, especially with respect to investors’ individual tax situations. In selecting and structuring investments appropriate for a Lexington Fund, Lexington and its affiliates will consider the investment and tax objectives of the applicable Lexington Fund as a whole, not the investment, tax, or other objectives of any investor in such Lexington Fund individually. Possibility of Different Information Rights; Outside Statements Certain investors may request information from Lexington relating to the Lexington Funds and the funds and operating companies in which the Lexington Funds invest, and Lexington can generally provide such investors with the information requested. Investors that request and receive such information will consequently possess information regarding the business and affairs of the Lexington Funds that is not generally known to other investors. Additionally, Lexington will meet with members of the Lexington Funds’ advisory boards and observers regularly and, during advisory board meetings, Lexington can be expected to share information in relation to actual or prospective portfolio investments, which information other Lexington Fund investors would not have received. As a result, certain investors may be able to take actions on the basis of such information which, in the absence of such information, other investors do not take. Furthermore, at certain times Lexington may be restricted from disclosing to investors material non-public information regarding any assets in which the Lexington Funds invest. Lexington and its affiliates and employees have made, and may in the future make, oral and written statements or expressions of intent or expectation to investors in the Lexington Funds or their affiliates or acknowledge statements by such persons (“Outside Statements”) regarding one or more Lexington Funds or Lexington’s activities pertaining thereto. These may include, for example, the anticipated or expected allocation and terms of co-investment opportunities, the anticipated or expected allocation of investment opportunities to such Lexington Fund(s) generally, and other topics often addressed in legally binding side letters. Although such Outside Statements are not legally binding, such Outside Statements may influence allocation and other decisions of Lexington and its affiliates and employees with respect to the operations and investment activities of the Lexington Funds and may influence a prospective investor’s decision as to whether to invest in the Lexington Funds. Investors generally will not receive notice of any such Outside Statements, and there can be no assurance that any such arrangements will not have an adverse effect on the Lexington Funds or other investors and, similar to the above, certain investors may be able to take actions on the basis of such information which, in the absence of such information, other investors do not take. Limitations on Confidentiality Obligations Notwithstanding any other statement herein or the provisions of any Lexington Fund’s Governing Documents, Lexington will not as a matter of policy interpret any Lexington Fund’s confidentiality or information rights provisions to: (i) prohibit any limited partner from reporting possible violations of applicable law or regulation to any governmental agency or entity, or making other disclosures that are protected under the whistleblower provisions of

applicable law or regulation; or (ii) require any limited partner to provide notification that it has made such reports or disclosures. Purchase of Interests by Lexington The general partner of a Lexington Fund has the authority to consent to any transfer of all or a portion of an investor’s interest in the applicable Lexington Fund, including a transfer to such general partner or any of its affiliates. Any such transaction would present a conflict in that, by virtue of its role as such, the applicable general partner would be expected to possess more information and more detailed information regarding the Lexington Fund and its investments than the relevant investor. There is no guarantee that any such general partner will consider (or if it does consider, will consummate) a transfer of all or any portion of an interest in a Lexington Fund from an investor in such Lexington Fund to the general partner or its affiliates, or that any such transfer will be available to investors generally. Investors should not expect that any such transfer will be available at any time. Advisory Board Rights Many of the Lexington Funds have established an advisory board, consisting of representatives of investors not affiliated with Lexington. A conflict of interest may exist when some, but not all, investors are permitted to designate a member or a non-voting observer to a Lexington Fund’s advisory board. An advisory board may also have the ability to approve conflicts of interest with respect to Lexington and the applicable Lexington Fund which could be disadvantageous to the other investors, including those investors who are not invited or permitted to designate a member or a non-voting observer to the advisory board. It is anticipated that limited partners that designate representatives to participate on a Lexington Fund’s advisory board will in certain circumstances, by virtue of such participation, have more or earlier information about such Lexington Fund and its investments than other limited partners of such Lexington Fund. Other Conflicts To the extent that Lexington and its affiliates are entitled to receive different advisory fees or performance fees based on the type of investments made by a Lexington Fund, that arrangement creates a potential conflict of interest with respect to the characterization of certain investments and as a result, Lexington in some cases has an incentive to characterize a “primary market” investment linked with a secondary transaction as a “secondary market” investment. Lexington and the Lexington Funds will generally engage common legal counsel and other advisers in a particular transaction, including a transaction in which potential conflicts of interest exist. Members of the law firms engaged to represent the Lexington Funds may be investors in a Lexington Fund and may also represent one or more underlying portfolio investments or investors in a Lexington Fund. In the event of a significant dispute or

divergence of interest between Lexington Funds, Lexington and/or its affiliates, the parties may engage separate counsel in the sole discretion of Lexington and its affiliates, and in litigation and other circumstances separate representation may be required. Additionally, Lexington and the Lexington Funds engage other common service providers. Certain advisors and other service providers or their affiliates (including accountants, administrators, lenders, bankers, brokers, attorneys, consultants, investment or commercial banking firms, and certain other advisors and agents) to Lexington, the Lexington Funds, the Investment Funds, or any of their affiliates also provide goods or services to or have business, personal, political, financial, or other relationships with Lexington and its affiliates. Such advisors and service providers are expected to include some or all of the following: (i) Lexington or a related person or affiliate of Lexington, (ii) an entity with which Lexington or its affiliates or current or former members of their personnel have a relationship or from which Lexington or its affiliates or their personnel otherwise derive financial or other benefit, including for the avoidance of doubt an entity in which Lexington, an affiliate of Lexington or an individual associated with Lexington has an ownership interest; (iii) certain Lexington Fund investors or their affiliates; (iv) actual or potential sources of investment opportunities; or (v) co-investors or transaction counterparties. These relationships have the potential to influence Lexington in deciding whether to select or recommend such a service provider to perform services for the Lexington Funds (the cost of which will generally be borne directly or indirectly by the Lexington Funds and their investors). Notwithstanding the foregoing, any such determination will be made in accordance with Lexington’s fiduciary obligations to the Lexington Funds and investment transactions for the Lexington Funds that require the use of a service provider will generally be allocated to service providers on the basis of Lexington’s judgment as to best execution, the evaluation of which includes, among other considerations, such service provider’s provision of investment-related resources, research and/or other services or resources that Lexington believes to be of benefit to the Lexington Funds. Additionally, Lexington expects that certain service providers, their affiliates and personnel will invest in, or co-invest alongside, one or more Lexington Funds. In certain circumstances, advisors and service providers, or their affiliates, may charge different rates or have different arrangements for services provided to Lexington or its affiliates as compared to services provided to the Lexington Funds, which may result in more favorable rates or arrangements than those payable by the Lexington Funds. Moreover, Lexington is permitted to engage in transactions with prospective and actual investors that entail business benefits to such investors (for example, financial service providers that may also invest in private investment funds such as the Lexington Funds). Such transactions may be entered into prior to or coincident with an investor’s admission to a Lexington Fund or during the term of their investment. The nature of such transactions can be diverse and may include benefits relating to Lexington, the Lexington Funds, and/or their respective portfolio investments. Where Lexington makes determinations of market rates, it can consider a number of factors, which are generally expected to include Lexington’s experience with non-affiliated service providers as well as benchmarking data and other methodologies determined by Lexington to be appropriate under the circumstances. Except where required by a Lexington Fund’s Governing Documents, Lexington undertakes no minimum amount of benchmarking. While Lexington generally expects to obtain benchmarking data regarding the rates charged or quoted

by third parties for similar services, relevant comparisons may not be available for a number of reasons, including, without limitation, as a result of a lack of a substantial market of providers or users of such services or the confidential and/or bespoke nature of such services. Therefore, such market comparisons may not result in precise market terms for comparable services. The expenses, charges and costs of any benchmarking, verification or other analysis related thereto, generally will be borne by a Lexington Fund as a fund expense. Lexington and its personnel have in the past received and expect in the future to receive certain intangible and/or other benefits and/or perquisites arising or resulting from their activities on behalf of a Lexington Fund, including benefits and other discounts provided from service providers. For example, airline or other travel, hotel stays, and credit card charges incurred as Lexington Fund expenses may result in lodging or travel rewards, traveler or customer loyalty or status programs, “miles,” “points,” “cash back,” rebates, discounts and other arrangements, or credit in loyalty/status programs to Lexington and/or its personnel, and such rewards and/or amounts will exclusively benefit Lexington and/or such personnel and will not be shared with such Lexington Fund, its investors and/or its portfolio investments. Lexington has in the past caused and expects, in the future, to cause one or more Lexington Funds to purchase, and/or bear premiums, fees, costs and expenses (including any expenses or fees of insurance brokers) for insurance to insure the applicable Lexington Fund(s), the applicable general partner(s), Lexington and/or their respective directors, officers, employees, agents, representatives, members of the advisory board and other indemnified parties, against liability in connection with the activities of the applicable Lexington Fund(s). This may include a portion of any premiums, fees, costs and expenses for one or more “umbrella” or other insurance policies maintained by Lexington that cover one or more Lexington Funds and/or Lexington (including their respective directors, officers, employees, agents, representatives, members of the advisory committee and other indemnified parties). Lexington will make judgments about the allocation of premiums, fees, costs and expenses for such “umbrella” or other insurance policies among one or more Lexington Funds, and/or Lexington on what it believes to be a fair and reasonable basis, and may make corrective allocations should it determine subsequently that such corrections are necessary or advisable. There can be no assurance that a different allocation would not result in a Lexington Fund bearing less (or more) premiums, fees, costs and expenses for insurance policies. The Lexington Funds have entered into, and are expected in the future to enter into, borrowing arrangements that require certain Lexington Funds to be jointly and severally liable for the repayment of obligations (including the execution of joint guarantees for such borrowings). If one Lexington Fund defaults on such an arrangement, the other applicable Lexington Funds are responsible for the defaulted amount. The Lexington Funds will only enter into such joint and several borrowing arrangements when Lexington determines that such arrangement is necessary or in the best interests of the applicable Lexington Funds and complies with applicable law. The sellers of investments will often be investors in Lexington Funds or sponsors with which one or more Lexington Funds is an existing or former investor, and a Lexington Fund may acquire limited partnership interests in other Lexington Funds, to the extent not prohibited by

applicable law. While Lexington seeks to negotiate transactions in good faith and on an arm’s length basis, the foregoing presents inherent conflicts of interest and there can be no assurance that there will not be an adverse impact on the applicable Lexington Funds. Lexington Funds occasionally acquire interests in other Lexington Funds, either on a secondary basis via purchase from an investor in a Lexington Fund, directly pursuant to the offering of interests in a Lexington Fund, or indirectly via the purchase of a third-party Investment Fund that holds an interest in a Lexington Fund, in each case to the extent consistent with Lexington’s fiduciary duties and to the extent not prohibited by applicable law or the Governing Documents of the applicable Lexington Funds. These transactions can arise when, for example, a Lexington Fund interest is included in a larger secondary transaction pursued by a separate Lexington Fund. Subject to the Governing Documents of the applicable Lexington Funds, the advisory fees and carried interest indirectly paid (or otherwise borne) by a Lexington Fund as a limited partner in another Lexington Fund in which it acquires an interest on a secondary basis will not result in an offset of the acquiring Lexington Fund’s own advisory fee or carried interest payable to Lexington. The potential for Lexington and/or its affiliates to receive advisory fees and carried interest from multiple Lexington Funds creates a conflict of interest with respect to any such acquisition. In addition, as a consequence of Lexington’s status as a subsidiary of a public company, the officers, managers and personnel of Lexington may be asked to take into account certain considerations and other factors in connection with the management of the business and affairs of Lexington that would not necessarily be taken into account if Lexington were not a subsidiary of a public company, including Franklin Resources, Inc.’s need, as a public company, to generate value and returns for its shareholders. The Governing Documents of the Lexington Funds establish complex arrangements among the Lexington Funds, Lexington, investors, and other relevant parties. From time to time, questions may arise regarding certain parties’ rights and obligations in certain situations, some of which may not have been contemplated upon the negotiation and execution of such documents. In some instances, the operative provisions of the Governing Documents, if any, may be broad, unclear, general, conflicting, ambiguous, and vague and may allow for multiple reasonable interpretations. In other instances, there may not be a directly applicable provision. While Lexington will construe the relevant provisions in good faith and in a manner consistent with its fiduciary duty and legal obligations, the interpretations used may not be the most favorable to a Lexington Fund or its investors.

In selecting brokers, Lexington’s primary consideration will be to obtain the most favorable net result for the applicable Lexington Fund under the circumstances, which will not always involve the lowest possible commission cost. In selecting broker-dealers to effect securities transactions, Lexington seeks to obtain best execution by considering factors including, but not limited to: the nature of the transaction, the size of the transaction, execution capability, execution costs, the level of service offered, responsiveness, financial responsibility and reliability, resources, experience in liquidating distributions from private equity funds, research services (such as reports and analyses of markets, industries, companies and economic trends), and such other factors as Lexington considers relevant and beneficial to the Lexington Funds. The applicability of specific criteria will vary depending upon the nature of the transaction, the market in which it is executed, and the extent to which it is possible to select from among multiple brokers or dealers. Research and Soft Dollar Benefits Lexington does not engage in any formal soft dollar arrangements with respect to securities transactions for the Lexington Funds. Any research services and/or other products or services that are provided to Lexington by brokers or dealers may be used for the benefit of all clients of Lexington and do not necessarily benefit solely the Lexington Fund from which the commissions were generated. Lexington has no commitment or arrangement to provide any specific level of commissions or transactions with respect to any proprietary research received. The receipt of research and/or other products or services is not directly connected to the recommendation of brokerage services to the Lexington Funds, but does create a potential conflict of interest of which investors should be aware in assessing Lexington’s choice of broker-dealers. Service Providers and Client Referrals Subject to Lexington’s obligation to seek best execution of all transactions for its clients, Lexington is permitted to consider referrals of investors in determining its selection of thirdparty service providers. Accordingly, in some cases Lexington has an incentive to select or recommend a service provider based on its interest in receiving investor referrals. Any such determinations will be made in accordance with Lexington’s fiduciary obligations to the Lexington Funds and Lexington’s compliance policies and procedures. Directed Brokerage Lexington has discretionary authority to select the brokers or dealers in connection with securities transactions of the Lexington Funds, and investors are not permitted to direct Lexington to use a particular broker or dealer to execute portfolio transactions on behalf of a Lexington Fund. Trade Aggregation Lexington generally will, to the extent possible, place a combined order for two or more Lexington Funds it manages that are engaged in the purchase or sale of the same security if, in its good faith determination, joint execution would be consistent with its duty to seek best

execution, consistent with the terms of the participating Lexington Funds’ Governing Documents, and otherwise in the best interest of the participating Lexington Funds.

Reports to Investors The general partners of each Lexington Fund distribute quarterly and annual written reports to their respective investors. Annual reports generally contain an individual capital account statement as of the end of such fiscal year, a listing of investments held by the Lexington Fund, and the audited financial statements of the Lexington Fund. The quarterly reports generally contain unaudited financial statements of the Lexington Fund for the fiscal quarter. Investors are requested to refer to the Governing Documents of the applicable Lexington Fund for further information on the reports provided by such Lexington Fund to its investors. The U.S. Registered Fund will provide shareholders with an audited annual report and an unaudited semi-annual report within 60 days after the close of the reporting period for which the report is being made, or as otherwise required by the Investment Company Act. The Offshore Registered Fund makes available to shareholders an audited annual report and a semi-annual report containing unaudited financial statements and other information, and the most recent available reports accompany the current prospectus or are provided upon request in accordance with its governing documents and applicable law. Detailed information about Registered Funds’ reporting can be found in the Registered Funds’ prospectuses and related offering documents.

portion of such benefits against advisory fees payable by the applicable Lexington Fund to the extent required under such Lexington Fund’s Governing Documents. Investors are requested to refer to the Governing Documents of the applicable Lexington Fund for complete information on the additional compensation received by Lexington or its affiliates or supervised persons in connection with such Lexington Fund’s investments. Third Party Compensation for Client Referrals and Investor Referrals Lexington and related entities of Lexington enter into compensation arrangements with placement agents or other parties for introducing investors to (and/or otherwise assisting in the fundraising of) a Lexington Fund. These arrangements generally are disclosed in the relevant Lexington Fund’s Form D. Any compensation associated therewith will ultimately be payable by Lexington and/or its related entities, either directly or through an offset of the Advisory Fee payable by the relevant Lexington Fund to Lexington. Moreover, as described above, Lexington is permitted to consider referrals of investors to the Lexington Funds in determining its selection of third-party service providers. Lexington endeavors at all times to put the interests of the Lexington Funds first as part of Lexington’s fiduciary duty to the Lexington Funds. Nevertheless, the receipt of compensation by the placement agents creates a potential conflict of interest and may affect the judgment of placement agents when making referrals to Lexington and the Lexington Funds.

In addition, upon the final liquidation of any such Lexington Fund, Lexington will obtain a final audit and distribute audited financial statements prepared in accordance with GAAP with respect to such Lexington Fund to all investors promptly after completion of the audit. Investors will generally not receive account statements directly from the bank or other qualified custodian holding physical custody of the Lexington Funds’ securities.

Lexington votes all proxies in a prudent manner, considering the prevailing circumstances at such time, and in a manner consistent with the Proxy Voting Policies and Procedures and Lexington’s fiduciary duties to the Lexington Funds. Lexington reviews each proposal submitted for a vote on a case-by-case basis to determine whether it is in the best interest of the applicable Lexington Fund. As a result, depending on the Lexington Fund’s particular circumstances, Lexington may vote one Lexington Fund’s securities differently than it votes those of another Lexington Fund, or may vote differently on various proposals, even though the securities or proposals are similar (or identical). In some instances, Lexington may determine that it is in a Lexington Fund’s best interest for Lexington to “abstain” from voting or not to vote at all, and will do so accordingly. Notwithstanding the foregoing, because proxy proposals and individual company facts and circumstances may vary, Lexington may not always vote proxies in accordance with the Proxy Voting Policies and Procedures. In addition, many possible proxy matters are not covered in the Proxy Voting Policies and Procedures. Generally, Lexington will vote proxies (i) in favor of management’s recommendation for the election of the board of directors and (ii) to approve the financial statements as presented by management. Prior to exercising its voting authority, Lexington, in consultation with Compliance and/or outside counsel, as appropriate, reviews the relevant facts and determines whether a material conflict of interest may exist or arise due to business, personal or family relationships of Lexington, its owners, its personnel or its related persons, with persons having an interest in the outcome of the vote. If it is determined that a material conflict exists, Lexington takes steps to ensure that its voting decision is based on the best interests of the applicable Lexington Fund and is not a product of the conflict. Lexington may, at its discretion, (i) seek the advice of the applicable Lexington Fund’s advisory board in voting such security; (ii) disclose the conflict of interest to the investors in the Lexington Fund (or its advisory board) and either ask for such Lexington Fund’s (or advisory board’s) consent to Lexington’s proposed vote or defer to such Lexington Fund’s (or advisory board’s) voting recommendation; (iii) defer to the voting recommendation of an independent third-party provider of proxy voting services; and/or (iv) take such other action in good faith (in consultation with Lexington’s outside counsel, if appropriate) as would serve the best interest of the Lexington Fund. Depending on the particular circumstances involved, the appropriate resolution of one conflict of interest may differ from the resolution of another conflict of interest, even though the general facts underlying both conflicts may be similar (or identical).

Lexington will deliver to each investor in a Lexington Fund, upon written request, a complete copy of its Proxy Voting Policies and Procedures and/or information on how it voted proxies for the applicable Lexington Fund.