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Entrust Global Partners LLC: investment adviser

Entrust Global Partners LLC is an investment adviser registered with the SEC (file 801-56043, CRD 107940). What it reports on Form ADV: assets and clients, fees, owners, disciplinary history and its client brochure. From the SEC's Investment Adviser Public Disclosure site; read Oct 21, 2026.

Assets managed
$11.8B
Discretionary
100%
Accounts
90
Employees
137
In advisory roles
40
Disclosures
0

Company page · SEC adviser record · Full Form ADV (PDF)

The firm reports that it or a related person has custody of client cash and securities.

Form ADV Part 1A, Item 5, as filed on the SEC Investment Adviser Public Disclosure site; read Oct 21, 2026.

Clients and fees

Whom the firm advises and how it is paid, from Items 5.D, 5.E and 5.G.

Client typeClientsAssetsShare
High net worth individuals1$11.0M0.1%
Private funds and other pooled vehicles86$11.3B95.9%
Pension and profit-sharing plans1$618.3K0.0%
Other advisers1$6.7M0.1%
Sovereign wealth funds1$471.8M4.0%

How it is paid

  • A percentage of assets under your management
  • Performance-based fees

Services

  • Portfolio management for pooled investment vehicles (other than investment companies)
  • Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investment vehicles)
  • Selection of other advisers (including private fund managers)

Who owns it

Schedule A lists direct owners of 5% or more (and officers who own a stake); Schedule B lists the owners of those owners.

Direct owners (Schedule A)

OwnerTypeRoleStakeSinceControlPublic company
Entrust Global LLCCompany (U.S.)OwnerE 75% or moreDec 2024Yes
Gregg Scott HymowitzPersonChairman and chief executive officerC 25% to 50%Apr 1997Yes

Indirect owners (Schedule B)

OwnerOwns a stake inTypeStakeControlPublic company
GH Ep Holdings LLCEntrust Global LLCCompany (U.S.)E 75% or moreYes
Gregg Scott HymowitzGH Ep Holdings LLCPersonE 75% or moreYes

Form ADV reports ownership in bands, not exact stakes: A means 5% to 10%, B 10% to 25%, C 25% to 50%, D 50% to 75%, E 75% or more. F marks a general partner, trustee or managing member, a role that controls the firm without a percentage. Owners of less than 5% are not listed.

Form ADV Schedules A and B, via the SEC Investment Adviser Public Disclosure site.

Disciplinary history

The firm answered No to every disciplinary question on Form ADV (Item 11).

The brochure

Form ADV Part 2A: the plain-language document an adviser must give its clients. Each item is shown as filed; open an item to read all of it.

Entrust Global Partners LLC Form ADV Part 2A, filed Mar 31, 2026. Brochure PDF. Items: 4 · 5 · 6 · 7 · 8 · 9 · 10 · 11 · 12 · 13 · 14 · 15 · 16 · 17 · 18

Item 4. Advisory business

EnTrust Global Partners LLC (“Partners”), a Delaware limited liability company, commenced business operations in February 1999. EnTrust Global Partners Offshore LP (“Offshore”), a Delaware limited partnership, commenced business operations in December 1999. Blue Ocean GP LLC (“BO GP”), a Delaware limited liability company, commenced business operations in June 2018. Offshore and BO GP are investment advisers relying on the SEC registration of Partners. Unless otherwise noted, references herein to “Advisor” generally refers collectively to Partners, Offshore and BO GP. On May 2, 2016, the EnTrust business combined with that of the Permal Group, a Legg Mason subsidiary and global alternative asset manager that was established in 1973 and acquired by Legg Mason in 2005. Gregg S.

Read the rest of Item 4 (4,647 more words)

Hymowitz, the Managing Partner of EnTrust, or entities controlled by him, received a 35% ownership stake in the combined group of companies. Legg Mason retained a 65% ownership stake. On July 31, 2020, EnTrust Global (“EG” or the “Firm”) completed its return to an independent, private company after closing on a previously reported transaction with Franklin Resources pursuant to which Mr. Hymowitz reacquired the 65% interest that Legg Mason, Inc. held in EG. Mr. Hymowitz, founder of the Firm, is the Chairman and Chief Executive Officer of EG, oversees the investment management function of the Advisors and is responsible for managing the EG business on a day-to-day basis. In September 2022, a sovereign wealth fund purchased a minority stake (less than 10%) in EnTrust Global and in January 2024, acquired an additional equity interest in the Firm, bringing its ownership interest to approximately 20%. The investment is passive with no exercise of control or involvement in the daily activities, investments or operations of the Firm, which continue to be managed by Mr. Hymowitz and the Firm’s Management Committee, comprised of EnTrust Global senior executives. In connection with these transactions, a Firm-level Board of Directors was established to periodically discuss business updates and related matters.

Description of Advisory Services EnTrust Global’s business platform offers a variety of investment opportunities across a range of asset classes, strategies, and liquidity profiles, in both the public and private markets. The Firm provides commingled solutions (“Commingled Funds”) as well as individually customized managed accounts or single investor fund structures (collectively, “Strategic Partnerships”). The Firm’s business lines include: Opportunistic Investments, Opportunistic Credit, EnOne Ventures, Blue Ocean Maritime Finance, Blue Ocean 4Impact, Hedge Fund Solutions, and Liquid Alternatives. Investment sub-committees lead each of the Firm’s business lines, with the goal of fostering collaboration, communication, and information flow as necessary. Opportunistic Investments: Opportunistic investments generally stem from dislocations – whether companyspecific or market-based – and focus on catalyst-driven theses that involve a high level of engagement and influence with respect to the target situation. The Firm’s approach to opportunistic investing allows for flexibility across asset classes, sectors, strategies, and geographies, and while agnostic between private and public markets, is designed to earn a premium with longer duration capital. Within the private sphere, the Firm’s Opportunistic-investment strategy has included a number of pre-IPO equity deals, identifying companies that we believe are well-situated for the public markets. Opportunistic Credit: The Advisor’s Opportunistic Credit strategy flexibly targets investments across the credit spectrum, including by aiming to fill a gap in direct lending markets, where middle market financing needs are not being met by traditional lenders given elements of complexity, elevated perceived risk, or time sensitivity. The Opportunistic Credit strategy specifically targets off-the-run situations, where exposures are difficult to replicate and are generally capacity constrained. These investments are primarily in opportunities in more predictable jurisdictions, focusing on situations that require a tailored approach and are actively negotiated. Returns are achieved with no/minimal leverage, with a focus on downside protection via

collateral and creditor protections. The Opportunistic Credit strategy seeks diversification by sourcing and underwriting opportunities across different parts of the capital structure, types of instruments, strategies and sectors, such that returns are not dependent on one particular part of the credit universe. EnOne Ventures: EnTrust Global’s new venture capital/growth equity investment strategy will focus on sports, media, and entertainment (“SME”). EnOne Ventures is a collaboration between EnTrust Global and OneTeam Partners, a leading athlete-built platform that holds proprietary rights to athlete intellectual property through long-term contracts with 8 professional players associations and approximately 30,000 college athletes. EnOne Ventures will target high-growth commercial categories in the SME ecosystem, where EnTrust Global and OneTeam Partners’ collective expertise and resources can attempt to catalyze value and facilitate accretive exits. EnOne Ventures will focus on investments where athletes play a central role in product development, brand credibility, customer acquisition, and value creation across areas such as technology, consumer platforms, health and wellness, youth sports, and similar growth categories. Blue Ocean Maritime Finance: EnTrust Global’s maritime finance strategy (“Blue Ocean”) – which is part of the Firm’s broader maritime-focused Blue Ocean Group – was launched in 2016 to capitalize on the demand for alternative sources of liquidity in the sector given the retrenchment of “traditional” bank lenders. The Blue Ocean strategy focuses on private debt/direct lending opportunities in connection with small- and mediumsized companies in the maritime sector, including the origination of asset-backed financings and opportunistic purchases of such loans. The strategy also opportunistically invests in second lien, mezzanine, lease and equity structures. The Blue Ocean strategy is managed by the Firm’s Blue Ocean Team, which has a dedicated investment committee. The Blue Ocean strategy is comprised of both commingled funds and Strategic Partnerships (collectively, the “Blue Ocean Funds”). Blue Ocean 4Impact: The sole investment of Blue Ocean 4Impact fund (“BO 4Impact”) is Purus Marine Holdings LP (“Purus”), a maritime shipping company launched by the Firm. Purus owns and operates environmentally-advanced ships, with a focus on gas carriers and offshore infrastructure support vessels, and leases them to large corporate operators and end-users, in order to help enable the global maritime energy transition. Hedge Fund Solutions: The Advisor provides discretionary investment advisory services to commingled private funds of hedge funds as part of a multi-strategy platform, which includes the Firm’s Opportunistic investment strategy (“Hedge Fund Solutions”). These funds are offered primarily to institutional and private client investors. The funds are managed according to the objectives and policies described in their respective offering documents (discussed more fully in Item 8). EnTrust Global leverages an extensive network of investment partners as well as an inhouse structuring capabilities to provide a diverse range of exposures that emphasize its expertise across credit, equity, and macro strategies. Liquid Alternatives: EnTrust Global offers access to liquid alternative investment strategies through its minority interest in Alma Capital Investment Management. Founded in 2006, Alma Capital is a European-based asset management company with offices in Luxembourg, Paris, and London. Alma Capital provides liquid alternative investment options in regulated UCITS funds for European institutional investors through both an individual product and multi-manager approach, spanning alternative credit, event driven, managed futures, and global macro strategies. Consulting Arrangements. In connection with the investment activities performed on behalf of the Funds, the Advisor and its affiliates may be presented with opportunities to provide consulting, advisory or other services to companies that involve advice on capital structure, financing arrangements, restructurings and related matters. Such companies may or may not be existing portfolio company investments for a Fund. Subject to applicable law, to the extent that the Advisor or its affiliates wish to perform such consulting services on behalf of a company, any fees for such services may be paid to a Fund who has an investment in that company, used to offset management fees otherwise payable to the Advisor or its affiliates, retained

by the Advisor or its affiliates, or paid to a Fund to the extent the Advisor or its affiliates believe that such opportunity was related to other investment activities being performed on behalf of such Fund or if the Advisor or its affiliates believe that the Fund may make an investment in the company as a result of the consulting services performed. In connection with these consulting arrangements, the Advisor or its affiliates may have access to material non-public information. The Advisor will consider any impact to a Fund prior to accepting any consulting arrangement to evaluate whether such consulting arrangement would not affect trading in securities of a company held by a Fund due to the potential receipt of material non-public information. To seek to address any potential conflict of interest issues that may arise in these consulting arrangements, where a Fund has an existing investment in a company for which the Advisor or its affiliates are being retained to provide consulting services, the Advisor or its affiliates will ensure the company is aware of the pre-existing investment and will seek to ensure that any consulting advice will not be made that is adverse to the Fund’s interest. Unless otherwise noted, references herein to: (i) “Commingled Funds” shall refer to all commingled private investment funds managed by the Advisor across a range of asset classes; and (i) “Funds” shall collectively refer to the Commingled Funds and the Strategic Partnerships. The Advisor may manage other funds in the future with investment strategies that may or may not be similar to those of the Funds, including funds that make direct investments in securities, loan portfolios or other financial products. Certain of the Funds may invest all or substantially all of their assets in a master fund, and references herein to investments made, held or disposed of by such Funds shall include investments made, held or disposed of by their respective master funds. Investor transparency and communication have been a cornerstone of the Advisor’s culture since inception. The Advisor strives to be at the forefront of investor transparency and communication by providing to investors information regarding each Fund’s investments, aggregated and summarized in a clear and concise fashion, and distributed on a timely basis. These investor communications typically include not only monthly and quarterly reports regarding investment performance, but also updates regarding significant events in the financial markets and the opportunity to attend an “Investor Summit” where various fund managers and other global financial industry participants, as well as the Firm’s investment teams, discuss market views and investment strategies. In addition, the Advisor takes a proactive approach to risk management and, through a dedicated operational due diligence process, conducts initial and ongoing due diligence with respect to potential and existing underlying managers of its multi-manager funds (See Item 8). The Advisor has separate strategy-specific investment committees (the “Sub-Committees”) (see Item 8 below) and a Risk Committee that monitors and assesses operational risk across the Firm (the “Risk Committee”).

Availability of Customized Vehicles Strategic Partnerships/Separately Managed Accounts: The Advisor offers institutional clients and high net worth individuals the flexibility of investing through Strategic Partnerships, which invest directly and indirectly in one or more strategies or investments. The Strategic Partnerships, which may invest pari-passu with the Commingled Funds, may follow a strategy sub-set or may follow a differentiated investment strategy specifically tailored to suit the relevant investor’s investment objectives and guidelines. The Advisor may provide advisory services to Strategic Partnerships on a discretionary or non-discretionary basis. The Advisor may establish Strategic Partnerships, individually customized managed accounts or single investor fund structures for certain investors. Customization can assume various forms based on specific investor preferences relating to, among other things: (a) returns; (b) liquidity; (c) volatility; (d) exposure to specific investment strategies, asset classes, and/or geographies; (e) tail risk protection solutions for a strategic partner’s broader portfolio; and/or (f) middle and back office solutions. Aside from portfolio construction and composition issues, such arrangements may afford transparency through periodic calls and

meetings with the Advisor’s key investment professionals and (for applicable strategies that invest with or alongside other managers) underlying managers to provide real-time information regarding the strategic partner’s particular investments, account balances, specific trades, liquidity analyses, risk aggregation analyses and performance on portfolio- and manager-specific levels. Additionally, one of the Advisor’s investment analysts is assigned to each such arrangement to handle questions and issues that may arise on a day-to-day basis. The terms of such arrangements are subject to negotiations between the Advisor and the investor and, as such, will vary across such arrangements and may be different than the terms for the Funds, including, without limitation, the right to receive reports on a more frequent basis or to receive reports that include information not provided to other investors, the right to pay a reduced incentive allocation/fee and/or management fee, the right to consent to investments and to increase investment allocations or participate in opportunistic investments, and such other rights as may be negotiated between the Advisor and such investor. The establishment of such customized vehicles may involve the withdrawal and/or the transfer of investments in underlying investment vehicles or direct investments within a timeframe or in a manner outside of the terms set forth in the Fund’s offering documentation or on terms not offered to other investors. In considering whether to effect such a withdrawal/transfer, the Advisor (in conjunction with the Board of Directors of the relevant Commingled Funds, as applicable) will consider the impact, if any, on remaining investors in the Fund regarding additional expenses to be borne, portfolio concentration or otherwise. The Advisor will not enter into a Strategic Partnership if it determines that such proposed arrangement disadvantages or otherwise negatively impacts the ability of the Advisor to provide the desired level of advisory services to the relevant investor or other investors. Strategic Partnerships may create potential conflicts of interest in the allocation of investment opportunities among the various Strategic Partnerships and between the Strategic Partnerships and the Advisor’s Commingled Funds. The Advisor has adopted an allocation policy intended to mitigate such potential conflicts of interest. (See item 6). Strategic Partnerships may invest directly in Commingled Funds (e.g., the Blue Ocean Funds) or invest alongside such Commingled Funds either directly or through a special purpose vehicle. For such investments, the Advisors will receive a Management Fee and/or Performance Allocation (as defined in Item 5 below) either at the Strategic Partnership level or at the Commingled Fund level, but will not receive duplicative fees.

Opportunistic Investments The Advisor carefully considers investment opportunities to source and gain exposure to more concentrated opportunistic investments. The Advisor constantly evaluates ideas and asset classes for potential opportunistic investment opportunities, which may be investments that have capacity in excess of the amount that an underlying portfolio may be able or willing to invest or may be an independent investment opportunity. Typically, opportunistic investments are sourced in response to market dislocations or involve manager led catalysts. With respect to investing in opportunistic investments, the Advisor will generally seek to make allocation decisions on a fair and equitable basis over time, based on the respective investment guidelines of the relevant Commingled Funds and Strategic Partnerships and after taking into account such factors as the Advisor deems appropriate, including without limitation, the relative amounts of capital available for investment, capital contributions or outflows, the investment programs, strategies, guidelines and restrictions of each Fund, the existing portfolio composition of the Fund, the sizing of the positions, relative weightings of the positions in the respective portfolios, price targets or stop-loss targets of the position as it relates to the particular Fund, legal, tax and regulatory considerations of each Fund, the potential impact an investment

could have on liquidity, exposure guidelines, concentration limits, diversification needs and other portfolio characteristics and other relevant considerations. For example, the Advisor may choose to trim a position in one Fund because it is hitting a concentration limit but hold the same position in the other Funds or for other co- investors. There are certain conflicts of interest that investors should be aware of as a result of these opportunistic investment arrangements from a preferential treatment standpoint, as well as conflicts resulting from side-byside management of opportunistic investment vehicles and the Funds and timing of the monetization of such opportunistic investments. The Advisor could be incentivized to over-allocate well performing investments to opportunistic investment vehicles in order to increase receipt of performance compensation. The Advisor has addressed these conflicts by adopting its Allocation Policy, which outlines the general allocation procedures regarding investments, including opportunistic investments (See Item 6 below). Generally, the Advisor will seek to fully exit or realize an investment at the same time and price for all Funds participating in the opportunistic investment on a pro rata basis, but may take into account liquidity of the position, withdrawal/redemption requests, the pressure that large sales may place on the stock price, regulatory filing obligations, advice of underlying managers, restriction windows, and other relevant factors. Strategic Partnerships, based on, among other things, the structure of the vehicle through which they are investing and the applicable investment mandate, may receive earlier and/or more detailed reporting than Commingled Fund investors. As a result of having potentially greater transparency on opportunistic investment(s), such Strategic Partnerships may have the ability to make decisions with respect to their investment distinct from, and potentially advantageous to, those investing through other structures or with other investment mandates. Expenses associated with a proposed opportunistic investment opportunity that does not come to fruition, such as where the purchase price moves drastically so the investment thesis is no longer compelling, will only be borne by the eligible Funds and investors that would have participated in such investment.

Managed Account Platform Permal Managed Account Platform (the “Platform”): Originally part of the legacy Permal business prior to the business combination with EnTrust Global in 2016, these are Funds managed by unaffiliated third-party investment managers (each, a “PMAP Fund”) for which Offshore serves as portfolio monitor. The Platform may be offered to investors with enhanced transparency and reporting requirements from underlying managers, among other features. A separate investment vehicle is organized for each third-party investment manager and is used to aggregate investments made with that manager among multiple clients of the Advisor. In its capacity as portfolio monitor to the PMAP Funds, Offshore performs various tasks, including, but not limited to, conducting due diligence of the third-party investment managers, internal legal, compliance, accounting and other services and making recommendations to the independent Board of Directors for the PMAP Funds (the “Board”) regarding the hiring and retention of managers for such PMAP Funds. The Board for each PMAP Fund retains the ultimate authority regarding such PMAP Fund’s investment restrictions and its hiring and retention of the third-party investment manager. As compensation for providing portfolio monitoring services, Offshore receives an expense reimbursement or “chargeback” from the PMAP Funds, a fixed fee currently set at 10 bps of average assets under management for each PMAP Fund investor in any year (the “Chargeback”). The Chargeback is intended to be sufficient to cover the costs attributable to the time spent by Offshore’s personnel in providing the portfolio monitoring services. The amount of the Chargeback is subject to the sole discretion and approval of the independent Board for the PMAP Funds, on an annual basis, based on their review and assessment of the reasonableness of the Chargeback, taking into consideration, among other things, the amount and nature of the portfolio monitoring services provided by Offshore. PMAP Fund investors will be notified of any change in the Chargeback prior to its implementation. The Chargeback is in addition to any management and incentive

fees and expenses borne by PMAP Fund investors, both at the PMAP Fund level and at the third-party investment manager level. Portfolio monitoring services provided to any particular PMAP Fund in any given year may not be the same as provided to other PMAP Funds, may vary from year to year and services may not be provided to a particular PMAP Fund in a given year. Offshore has sole discretion in deciding whether to allocate investment assets to a PMAP Fund or to another Fund managed by the Advisor, that may follow a substantially similar investment strategy to that of a PMAP Fund and may have an overall lower cost structure to investors. EnTrust Global investors will not be notified by the Advisor of its decision to invest a portion of such investor’s assets in a PMAP Fund or of the factors that led to this decision. In exercising its discretion in this regard, the Advisor will consider the relative value of the benefits offered by the Platform as it relates to a particular investor and in view of any additional costs to be incurred by the investor. Notwithstanding any decision by the Advisor to invest an investor’s assets in a PMAP Fund, there is no guarantee that enhanced transparency and/or reporting will be provided by any PMAP Fund, at what level or frequency that transparency and/or reporting may occur, or that such transparency/reporting will actually exceed the level/frequency provided by the third-party investment manager in a commingled investment vehicle it manages that follows a substantially similar investment strategy to that of the relevant PMAP Fund. Additionally, there is no guarantee that should enhanced transparency be received, that such transparency will result in additional portfolio gains or mitigation of losses in the relevant PMAP Fund. Offshore has a conflict of interest because it is incentivized to allocate assets to the Platform because of its ability to receive the Chargeback from investors that invest in the PMAP Fund. The Commingled Funds, including, but not limited to, the Opportunistic Credit Commingled Funds and the Blue Ocean Funds, do not currently invest in the Platform and, therefore, are not subject to the Chargeback. Certain PMAP Funds may not be subject to the Chargeback due to regulatory or other restrictions. Any questions regarding the Chargeback, including the investors to which the Chargeback applies, should be directed to the CCO.

Internal Controls The Advisor has established a Compliance and Conflicts Committee (the “Compliance Committee”) to enhance the independence of oversight and controls relating to the Advisor’s compliance policies and procedures and to identify, address and resolve existing and potential conflicts of interest that may arise across the Advisor’s business practices. The Compliance Committee includes members of the Compliance Team/Lara Shalov Mehraban (former Acting Director of the SEC’s New York Regional Office and Supervisor of the New York Office’s Enforcement Division and a current Partner at the law firm of Sidley Austin) and Leonard Ng (Sidley Austin Partner and Head of their UK/EU regulatory practice), who serve as Independent Legal/Compliance Advisors to the Compliance Committee. Issues may be identified for consideration by the Compliance Committee through senior management’s daily interaction with employees. Formal meetings are generally conducted on a quarterly basis, even when no particular issue is identified for consideration, although the Compliance Committee may meet more frequently as issues arise. Documentation of meetings is prepared and maintained. In addition, the Independent Legal/Compliance Advisors and/or the CCO or his designee conduct periodic training sessions for the Advisor’s personnel regarding compliance issues and considerations. Finally, the Compliance Committee discusses on an ongoing basis the Firm’s business practices and relationships as well as how to best mitigate and monitor the inventory of identified and anticipated risks. The Advisors have also established a global Risk Committee (the “Risk Committee”), chaired by the Global General Counsel/CCO and comprised of members from various business units. The Risk Committee monitors

and assesses operational risk across the Firm. Formal meetings are generally held quarterly and ad hoc questions are presented as necessary. Although not required, at the request of the Advisor, PwC, the Funds’ independent auditors, prepares a SOC1 Type 2 Report on Controls Placed in Operations. This report is used by the Advisor to further review and assess its own operational controls on an ongoing basis. The most recent SOC 1 Type 2 Report is as of March 31, 2025. Copies of SOC-1 Type 2 Reports are sent to investors.

Cybersecurity In response to the increasing number of cyber-attacks across different industries and increased regulatory focus on financial firms’ preparedness to protect information and systems and to respond to such attacks, the Advisor conducts an ongoing assessment of its technology systems and controls. The Advisor’s assessment particularly focuses on supervisory controls over, and protection of, systems and confidential information, operational capabilities of systems and where these systems could be improved to provide better protection, preparedness to respond to cyber-attacks, the drafting of written policies and procedures and vendor management. No cybersecurity program can anticipate and prevent all types of cyber-attacks (please refer to “Cybersecurity Risk” under Item 8). The Advisor has invested significant time and resources in strengthening and upgrading its internal controls and systems. This includes an entire infrastructure upgrade of its server environment, having an external vulnerability assessment conducted and strengthening the monitoring of potential threat activity and other controls. The Advisor will continue to monitor its cybersecurity program and spend the necessary time and resources to implement upgrades as necessary.

Artificial intelligence The Advisor utilizes certain technology tools, including applications incorporating artificial intelligence (“AI”), to support aspects of our investment research, and/or operational functions. These tools assist in analyzing large data sets, identifying investment opportunities, or enhancing internal efficiencies. The Advisor’s use of AI is governed by the Advisor’s AI policies and procedures (the “Policy”). The Advisor’s Managing Director, Business Solutions (the “AI Manager”) is responsible for implementing and overseeing the Policy. Under the Policy, proprietary or confidential information of the Advisor and material nonpublic information about the Advisor’s clients and prospective clients may not be transferred or otherwise made accessible to an AI-based platform unless the platform has been approved by the AI Manager and the CCO. Prior to granting such approval, the AI Manager and the CCO will use a risk-based analysis in conducting due diligence, including (as applicable): (I) consulting with employees who propose to use the platform; (II) considering the types of information that may be transferred or otherwise made accessible to the platform, the restrictions on such information and the proposed uses of the platform; (III) reviewing the platform’s terms of use (and any license or other permission) and information security measures (e.g., encryption); (IV) assessing the risks associated with using the platform; and (V) determining whether any other policies or procedures are applicable to the proposed uses of the platform. In addition, the Advisor may utilize third-party service providers that incorporate AI into their products or services and will conduct due diligence on such providers; however, the Advisor does not control their

underlying models or methodologies and are reliant on their representations regarding performance, data handling, and security. The use of AI tools involves inherent limitations and risks. These tools may rely on historical data or third-party data sources that may be incomplete, inaccurate, or biased. AI models may produce outputs that are incorrect, misleading, or not fully explainable. The use of AI tools involves risks stemming from inaccuracies in data input and output, signal processing, predictive analytical and other modeling techniques, information security and related regulatory developments, and flaws in algorithmic logic systems, among others. The Advisor could incur liability or expenses in connection with claims of infringement or similar claims by third parties related to information received through AI Tools from its vendors or other AI tools and uses. There is a risk that reliance on AI tools could result in investment decisions that differ from those that would have been made using traditional methods of analyses. Additionally, AI systems may be subject to operational risks, including system failures, cybersecurity incidents, or model degradation over time. To the extent AI tools are used to support business operations, including client servicing, marketing, or resource allocation, conflicts of interest may arise if such tools are designed or configured in a manner that could favor the interest of the Firm over its clients. We seek to mitigate these risks through internal controls, policies, and human oversight. The AI Manager will periodically review the Advisor’s use of each approved platform, including by updating its due diligence and by testing to confirm that (i) the platform continues to perform as intended, (ii) the approved purposes remain current and (iii) the Advisor’s use of the platform remains limited to approved purposes. In connection with this periodic review, the AI Manager will update its assessment of the risks associated with the use of the platform and confirm that appropriate safeguards are in place to mitigate these risks. If appropriate, additional safeguards will be implemented. On at least an annual basis, the CCO or his designee will provide employees with AI training and will review the Policy to assess its adequacy and effectiveness in connection with applicable laws and regulations and otherwise. As of December 31, 2025, the Advisor managed approximately $11,813,208,176 in regulatory assets under management on a discretionary basis and $6,650,401 in regulatory assets under management on a nondiscretionary basis.

Item 5. Fees and compensation

The fee structure for each Fund is set forth in the offering documents for that Fund, or in the account agreement for the relevant Strategic Partnership, as the case may be. Offshore serves as the management company of the Funds for which EnTrust Global Partners LLC or Blue Ocean GP LLC serve as general partner and, in exchange for providing certain administrative and managerial services, receives a management fee from the Funds (the “Management Fee”).

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The Management Fee is calculated monthly and may vary for different classes of limited partnership interests, limited liability company interests, or shares in the Funds (collectively, the “Interests”), but generally ranges from 0.10% (0.40% per annum) to 0.50% (2.0% per annum) of each limited partner’s capital account, the net asset value of a particular class of Interests, committed (but unfunded capital) or invested capital, as the case may be. In addition, the Advisor may receive an incentive fee/allocation (the “Performance Allocation”) on an annual basis (or, in some cases, quarterly or as agreed to with investors) in certain classes of Fund interests or for certain Funds, generally ranging from 5% to 20% per annum of net profits (typically 15% per annum for the Blue Ocean Funds and certain other Funds, pursuant to a waterfall rather than an annual fee, as described below). As set forth more fully in the offering documentation for a particular Fund, the Performance Allocation for Interests in some Funds is subject to hurdle rates or clawback provisions. The Performance Allocation is generally subject to the recoupment of unrecovered net losses incurred previously. For certain of the Funds (including the Blue Ocean Funds), the Performance Allocation is typically structured as a carried interest, payable after investors have received all of their capital contributions back, plus a preferred return, and subject to a catch-up for the Advisor. Investors in Funds where the Performance Allocation is charged at the overall Fund level or to a particular class as a whole should note that as equalization or series accounting is not used, the Performance Allocation will be based on the overall performance of the Fund or class of Interests, as applicable, as opposed to the specific performance of the shares held by a particular Investor. The Advisor, in its sole discretion, may waive or reduce all or any portion of the Management Fee and/or Performance Allocation for certain investors in the Funds. New Interests may also be created with different fee structures. For Strategic Partnerships, fees generally will track the range of Management Fees/Performance Allocation for the Commingled Funds depending on the amount of assets in the account or as may be negotiated. Any Performance Allocation for a Strategic Partnership will be subject to negotiation between the Advisor and the investor. In addition, the Advisor and/or Funds may, without notice to investors, enter into agreements with certain investors who, in the Advisor’s judgment, make a significant investment in a Fund, granting them, among other things, greater portfolio transparency, fee waivers or reductions, additional rights to reports or other information and other more favorable investment terms than the terms set forth in the offering documentation. The Funds have the power to create different classes of Interests for certain substantial investors and may create additional classes having different rights for the purpose of implementing such agreements. For example, such additional classes of Interests may have different voting rights, management fees or performance compensation arrangements. In offering more favorable investment terms to certain investors, the Advisor and/or Funds shall have no obligation, subject to any applicable “most favored nations” agreements, to offer such additional rights, terms or conditions to any other investors. Each Fund’s expenses are set forth in the respective offering documents for the particular Fund and may include, the Management Fee and the Performance Allocation (if applicable); fees of the Fund’s independent auditors, legal counsel and Administrator; fees for the maintenance of the Fund’s books and accounts, including license fees and costs associated with any software used to maintain the books and records of the Fund, including portfolio management, risk management and investor reporting and technology expenses; fees of any separate accountants retained for the Fund and fees paid pursuant to the

Services Agreement (see discussion below on the Services Agreement); registration, licensing and custodian fees; taxes (including withholding and transfer taxes); bank service fees; insurance premiums; organizational expenses; governmental fees, preparation and distribution of investor reports and other communications with investors and the public, the costs incurred in connection with marketing the Fund Interests (including but not limited to travel, car service, car rental and parking and lodging expenses incurred in attending conferences and related business entertainment at such conferences, and presentations with investors and prospective investors), the cost of updating the Fund’s offering documents, professional fees of consultants (including risk management and compliance consultants and, where appropriate/applicable, valuation experts, agents and ratings agencies) incurred in connection with the operations of the Fund, manager research costs and background checks, subscription fees for market data services, databases, investment data and other news to assist business development efforts and related research expenses and other due diligence tools (including travel and expenses in connection with monitoring and conducting due diligence on investments) and the costs and expenses of securing and maintaining any line of credit or liquidity facility, including interest expense and commitment fees. All travel and lodging expense reimbursements are subject to the Advisor’s Code of Ethics and its Travel & Entertainment Reimbursement Policy, which limit the types of expenses that may be incurred and provide that expenses will only be reimbursed if they are ordinary and reasonable. In addition to the fees and expenses described above, the Funds will bear, directly and indirectly, certain additional expenses, which are described in the relevant offering documentation or separately managed account agreement. Some of these expenses may include, as applicable: 

Dealing fees for subscribing to/redeeming from the Funds – depending upon the class of Interests subscribed to and amount purchased, dealing fees, such as front end or back-end sales charges, may apply to the investor. These amounts are not typically paid to EnTrust Global but are charged and retained by financial intermediaries who offer the Funds for sale to their clients. Distribution fees – for Investors subscribing into a class of Interests of a Fund with a back-end sales charge, an ongoing distribution fee, typically up to 1% will be charged. This fee is also generally paid to the financial intermediary that made the Fund available for sale.

In addition, as discussed further in Item 12 – Brokerage Practices, the Advisor may, on occasion, buy and sell securities traded in secondary markets, including exchange traded funds (“ETFs”), open-end and closed-end funds and other securities. In these cases, investors will bear the costs and expenses (such as commissions or spreads) associated with such trading. For those expenses which relate to or which benefit one or more specifically identifiable Funds, each such expense will be allocated solely to those Funds. For those expenses which cannot reasonably be allocated to a Fund or specific Fund(s) or which benefit all Funds, the expense will be allocated across all Funds on a pro rata or other basis that is fair and equitable to all clients. Each Fund also bears a pro rata portion of the expenses of each underlying fund (where applicable) in which it invests, including the management fees and incentive fees payable to the managers of such funds. In certain cases, the Advisor has been able to negotiate more favorable fee terms than those otherwise payable by an investor in such fund. Organizational costs, including marketing expenses, incurred prior to the launch of a Fund are amortized over five years and shared by all investors in that Fund. A Fund may hold multiple closings. Marketing expenses are borne by investors from the most recent closing through the closing at which they invest, on a pro rata basis according to their respective capital commitments. Certain of the Funds have entered into or are expected to enter into a Services Agreement with the Advisor, pursuant to which certain personnel of the Advisor perform services for both the Advisor and the Funds, including accounting, legal and compliance (including but not limited to oversight of certain risk management and ancillary services). Under the Services Agreement, fees are payable by the relevant Funds

and are currently set at 10 basis points per annum of a Fund’s Net Asset Value (the “Fee”). The amount of the Fee is subject to adjustment (up or down) generally on an annual basis, subject to the sole discretion and approval of the independent board of directors for the offshore Funds, based on its assessment of the reasonableness of the Fee, taking into consideration, among other things, the cost to EnTrust Global to provide the services. The Fee is intended to be sufficient to cover the total compensation and benefit costs and EnTrust Global’s share of taxes for such personnel who typically also provide significant services to the Advisor. Services provided to any particular Fund in any given year may not be the same as provided to other Funds and, from time to time, no services may be provided to a particular Fund in a given year. Certain Funds managed by the Advisor or its investment advisory affiliates may not pay the Fee but may, nonetheless, receive the services set forth above. Investors will be notified of any change in the Fee prior to its implementation. The Services Agreement is available upon request. Certain of the Funds (who do not enter into the Services Agreement) pay a Shareholder Service Fee to the Advisor as set forth in the applicable Fund’s offering documentation. As discussed further in Item 4 – Advisory Business, as compensation for providing portfolio monitoring services to the PMAP Funds, Offshore receives an expense reimbursement or “Chargeback” from the PMAP Funds, a fixed fee currently set at 10 bps of average assets under management for each PMAP Fund investor in any year and reviewed on an annual basis by the independent Board of the PMAP Funds. The offering documents for a particular Fund, or the managed account agreement for a Strategic Partnership, specify the withdrawal terms for such Fund or account, as the case may be. In general, no withdrawal/redemption is permitted other than as set forth in such governing documents, subject to the right of the Advisor or the Fund, as applicable, in its sole discretion and without notice to other investors, to waive such requirements for investors on a case by case basis. EnTrust Global utilizes Best Alternative Advisory Services (“Best”), based in India, for support regarding Fund accounting, operations, compliance/regulatory surveillance and client reporting. Best was acquired by Apex Group Ltd., a global financial services provider. Notwithstanding the acquisition, the team of people at Best dedicated solely to the EnTrust Global business is expected to continue in that capacity and to continue to work collaboratively with EnTrust Global on a daily basis and across different business units to attempt to achieve operational efficiencies in the areas noted above. Where operating a particular Fund is, in EnTrust Global’s discretion, no longer viable, including but not limited to when operating costs have become outsized relative to the Fund’s assets, where the Fund has experienced significant redemptions, or otherwise, or where a Fund liquidates pursuant to its own terms, such Fund will be liquidated in accordance with its constituent documents. Once EnTrust Global decides to liquidate, it will endeavor to treat all investors fairly and equitably in the Fund’s wind-down. In order to do so, EnTrust Global may suspend redemptions (even redemptions already submitted) for Funds that permit redemptions, suspend payment of redemption proceeds, continue to actively manage a portion or all of the Fund’s assets, sell highly illiquid and nonmarketable positions at a loss, and take other steps consistent with its fiduciary duty. In these circumstances, EnTrust Global will attempt to provide investors with an estimated timeline regarding the payment of liquidation proceeds, which will be impacted by the nature of the underlying securities, the global markets, economic and financial conditions and other factors.

Item 6. Performance-based fees and side-by-side management

Performance Based Fees and Side-by-Side Management

The Advisor’s fee structure, including as it relates to performance-based fees, is set forth in response to Item 5 above. In general, the Funds follow the same investment strategy for each separate class of Interests within that particular Fund. Accordingly, the Advisor is not generally incentivized to favor or pursue more speculative investment strategies for those classes of Interests for which it may receive a Performance Allocation. Statement of Allocation Policy and Procedure. It is the Advisor’s policy that no Fund or other account for which the Advisor has investment discretion (collectively, “EnTrust Global Clients”) shall receive preferential treatment over any other EnTrust Global Client.

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In allocating securities among EnTrust Global Clients with a substantially similar investment strategy, it is the Advisor’s policy that all such EnTrust Global Clients should be treated fairly and equitably over time and that, to the extent possible, all EnTrust Global Clients with a substantially similar investment strategy should receive equivalent treatment. Investment opportunities generally will be allocated among those EnTrust Global Clients for which participation in the respective opportunity is considered appropriate by the Advisor taking into account, among other considerations: (a) the nature of the proposed investment and the size of the aggregate position available to EnTrust Global Clients; (b) each EnTrust Global Client’s investment objective and strategies and any investment restrictions applicable to the particular EnTrust Global Client; (c) whether the risk-return profile of the proposed investment is consistent with the EnTrust Global Client’s objectives, whether such objectives are considered (i) solely in light of the specific investment under consideration or (ii) in the context of such EnTrust Global Client’s overall holdings; (d) existing exposure to the proposed investment, if any, and the potential for the proposed investment to create an imbalance in the EnTrust Global Client’s portfolio; (e) liquidity requirements of the EnTrust Global Client and time horizon applicable to the particular client; (f) the EnTrust Global Client’s available cash to invest; (g) tax considerations; (h) legal and/or regulatory restrictions that would or could limit an EnTrust Global Client’s ability to participate in a proposed investment; (i)

the risk parameters for the EnTrust Global Client’s portfolio;

(j)

overall portfolio construction for the EnTrust Global Client;

(k) where a proposed investment is time-sensitive, the ability of the EnTrust Global Client to fund the investment on an expedited basis; (l)

other criteria the Advisor deems relevant (the nature and extent of the differences will vary from client to client); and

(m) the exposure of a new or recently launched Fund to a particular investment strategy. As a result of the application of these factors, allocations and performance across EnTrust Global Clients that are similarly situated will differ for particular investments or over time. Without limiting the generality of the foregoing, the Advisor may enter into investment relationships with strategic investors, for which the Advisor may exercise its discretion to offer such strategic investors certain investment opportunities on a priority basis and/or on preferential terms when such opportunities arise. In exercising such discretion, the Advisor may consider a wide range of factors, including but not limited to, one or more of the following: 

The size and financial resources of the investor, as well as its execution timing and certainty, including the ability of that investor to act as an “anchor” investor for a particular transaction;

Whether allocating investment opportunities to a potential investor will help establish or strengthen relationships that may provide indirectly longer-term benefits (including strategic, sourcing or other similar benefits); and Whether a particular potential investment party has provided value in the sourcing, establishing relationships, participating in diligence and/or negotiations for such potential transaction or is expected to provide value to the business or operations of a portfolio company post-closing

Where an investment opportunity has limited capacity and the investment is suitable for more than one EnTrust Global Client: (i) the Advisor is not obligated to cause an EnTrust Global Client that invested first to withdraw to free up capacity for another EnTrust Global Client; (ii) where two or more EnTrust Global Clients are considering the investment at the same time, the investment generally will be made pro rata based on the capital available among the participating EnTrust Global Clients for the proposed investment and on assets under management. Such pro rata allocations will also be made in consideration of the factors listed above which, as applied in any particular case, may result in one or more EnTrust Global Clients not participating in an investment, or participating in the investment but at a lower allocation percentage than the EnTrust Global Client may request or prefer, or participating at a higher than pro rata allocation percentage.

Item 7. Types of clients

The Advisor’s clients are noted in response to Item 4 above. The minimum initial investment amount for the Funds (or capital commitment amount, as applicable) is set forth in the offering documentation for the particular Fund. Minimum investment requirements are subject to waiver or reduction in the sole discretion of the Advisor (subject to any requirements imposed by applicable law). For certain Funds, the Advisor may refuse to permit a partial withdrawal if the withdrawing investor’s remaining capital account balance or the value of the investor’s Interests, as the case may be, would be less than an amount set forth in the offering documentation, as applicable.

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In addition, each prospective investor must satisfy the accreditation requirements set forth in the offering documents of each Fund in which the Investor intends to invest. Investors in the Funds may include public, corporate and Taft-Hartley pension funds, foundations, endowments, sovereign wealth funds, insurance companies, high net worth individuals and family offices or other investors. In addition, the Advisor may provide investment advisory services to Strategic Partnerships for the benefit of such types of investors. Minimum account sizes for such accounts are subject to negotiation.

Item 8. Methods of analysis, investment strategies and risk of loss

Methods of Analysis Blue Ocean Funds The Blue Ocean Funds’ deal workflow when originating loans/leases is typically a four-step process: Sourcing, Underwriting, Closing and Post-Funding. The Blue Ocean team actively assesses and closely monitors the loans/leases throughout the tenor of the loans/leases. The primary purpose of the review is to reassess and monitor the borrowers’ continuing credit quality and to conduct ongoing stress testing at the portfolio level. Reviews will typically include financial performance, covenants, collateral and liquidation analysis and a market summary. The Blue Ocean team actively monitors the financial and reporting covenants established in the loan agreements or security documents.

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When engaging in other types of transactions (for instance, preferred equity investments), the workflow is generally similar, but is tailored to the type of transaction at hand. The Blue Ocean Executive Committee meets to help oversee the origination, purchase, sale or other disposition (among other actions) regarding the Blue Ocean Funds’ investments. The Blue Ocean Executive Committee consists of Gregg S. Hymowitz, Chairman and Chief Executive Officer of EnTrust Global, Svein Engh, Committee Chair and Portfolio Manager of the Blue Ocean Funds, and Omer Donnerstein, Co-Portfolio Manager. The Blue Ocean Executive Committee approves investment decisions for the Blue Ocean Funds. The Blue Ocean team has grown methodically since inception through organic and inorganic means as key resources were added strategically to enhance the team’s network and industry expertise, and to provide local coverage across key end markets. In October 2021, the Blue Ocean Funds invested in and acquired the portfolio of Netherlands-based Maas Capital, a specialized equity provider in the maritime industry. This portfolio included joint ventures in varied ocean businesses such as commodity shipping and in intermodal and offshore services. The Maas Capital management company (“MC”) and the Blue Ocean Funds (through special purpose investment vehicles) entered into a Master Servicing Agreement whereby MC provides certain services to the Blue Ocean Funds, including but not limited to the sourcing of new investment opportunities and the servicing of the portfolio companies owned by the legacy Maas portfolio. In April 2024, certain of the Blue Ocean Funds invested in and completed their acquisition of Offshore Merchant Partners, an Oslo-based alternative investment fund manager in the maritime and energy industries and OMP’s investment portfolio, consisting of, among other things, investments in varied businesses focused on offshore energy and liquefied natural gas transportation. Subsequent to the acquisition, the legacy Offshore Merchant Partners investment team formed its own independent entity (“OMP”) and entered into agreements whereby OMP provides certain services to the Blue Ocean Funds, including but not limited to the sourcing of new investment opportunities and the servicing of the portfolio companies owned by the legacy Offshore Merchant Partners portfolio. OMP and an affiliate of the Advisor share office space in Oslo. All fees and terms in connection with the above agreements were negotiated on an arm's length basis. The Blue Ocean Funds noted above pay the general operating and overhead expenses incurred by MC and OMP, including in connection with their investment activities for their legacy investment portfolios and these Blue Ocean Funds, such as sourcing, diligencing, servicing and structuring of loan originations and other investment opportunities. All new transactions, whether sourced from the internal Blue Ocean team or from the MC or OMP teams must receive prior approval from the Blue Ocean Investment Committee.

Opportunistic Credit The Opportunistic Credit strategy employs a disciplined, multi-stage investment process designed to identify differentiated opportunities while maintaining rigorous underwriting standards and capital preservation discipline. Given the complex and often bespoke nature of private credit transactions, the process emphasizes thorough screening, independent analysis, structured decision-making, and committee oversight at each stage. The framework is designed to progressively narrow a broad sourcing funnel into a highly selective portfolio of investments that meet risk/return objectives. EnOne Ventures The EnOne Ventures investment process begins with an extensive global sourcing network. This network generates inbound opportunities from a wide variety of investment partners, athletes, and commercial parties. The EnOne team attempts to identify compelling, differentiated opportunities that align with the strategy’s objectives. Once opportunities are identified, rigorous financial, business, and legal due diligence are conducted. The underwriting process emphasizes deep fundamental analysis and scenario testing to assess the risk-reward profile of each investment. The team applies a disciplined relative-value lens to attempt to identify attractive risk-adjusted returns. The investment committee for EnOne Ventures consists of senior personnel of the Advisor and OneTeam Partners, the Advisor’s joint venture partner for this strategy. Hedge Fund Solutions/Opportunistic With respect to the Hedge Funds Solutions’ investment portfolios, although a particular Fund may be strategy specific or specific to a defined universe of investment strategies, the primary objective of the Advisor is to construct a portfolio of investments with consistent risk-adjusted rates of return within different non-correlated investment strategies, thereby seeking to diversify risk and down-side exposure. Position sizing is determined by the relevant Sub-Committee based on quantitative analysis, as well as information gained from feedback from investment analysts during their regular contact with underlying managers, from interaction with portfolio managers and industry investment professionals and from any macro market conditions believed to possibly impede or enhance specific strategy investment opportunities. In selecting managers for a portfolio, the Advisor does not follow a rigid asset allocation policy but instead seeks diversification through a combination of managers trading a range of strategies. The Funds are designed not only to utilize expert managers but also to deploy and redeploy investment capital within a range of investment strategies which the Advisor regards as likely to provide favorable opportunities in changing economic environments. Certain Funds may have more restrictive investment guidelines. The screening process for underlying managers includes a review of a number of different factors, the most important being: A definable investment strategy and process - Each manager must have a clearly defined investment strategy, process and methodology. Just as importantly, the Advisor verifies that the manager has consistently maintained its investment strategy throughout various market conditions. A consistent, risk-adjusted historical performance record – The Funds typically invest with managers who have historical risk-adjusted performance records of significant duration and which are uncorrelated to returns of other managers in the portfolio. Such performance records must demonstrate an ability to achieve returns during both favorable and unfavorable market cycles. Disciplined risk management techniques - Managers are also evaluated on their ability to manage risk to an acceptably low level. Each prospective manager is required to complete the Advisor’s due diligence questionnaire, which is extensive and incorporates questions related to investment strategy, exposures, concentrations, leverage, transparency and performance, as well as risk management, valuation procedures, pricing policies, cash controls and service providers. Once invested with a manager, the Advisor

regularly reviews the overall market risk exposure, hedging and other risk management techniques utilized by the manager to limit market exposure and downside risk. A commonality of financial interests – The Funds typically invest with managers who have meaningful financial commitments jointly with their clients, demonstrated by having significant amounts of their personal capital invested in their own portfolios. The members of the investment team meet regularly to discuss the allocation and sizing of particular investments, the status of investments being considered and matters concerning the investment portfolio generally. Such meetings, both formal and informal, may also include applicable members of the Legal and Compliance Team, the CCO, the Advisor’s financial controllers and other colleagues to discuss among other things, portfolio positioning, construction and risk parameters. The portfolio is reviewed regularly and rebalanced on a monthly basis.

Operational Due Diligence The Advisor takes a proactive approach to risk management and the extensive risk management procedures it has implemented are critical to, although independent of, the investment process. The exact nature of operational due diligence conducted and the amount of time devoted to operational due diligence in any particular circumstance can vary depending on a number of factors, including but not limited to familiarity with the operational infrastructure of an underlying manager and anticipated timeframe of making an investment. The Advisor has engaged an operational due diligence consulting firm (“Consulting Firm”) to assist the Advisor’s internal operational due diligence team in helping to identify and remediate operational risks. The scope of work to be conducted by the Consulting Firm will generally include, but is not limited to, meeting with underlying managers and their key personnel, evaluating their infrastructure and internal controls, helping to perform background checks and preparing operational due diligence responses. As such, references in this section to activities conducted by the Advisor also include activities undertaken by the Consulting Firm. The managers are sourced primarily from referrals from the Advisor’s network of investment professionals and existing managers. Through the interview process, the Advisor garners an in-depth understanding of the manager’s investment thesis and processes. As investment due diligence progresses, the Advisor performs in-depth operational due diligence (as set forth in more detail below). Ongoing due diligence reviews are generally conducted on existing managers approximately every 18-24 months. Operational due diligence is conducted on managers sourced for opportunistic investment opportunities, specifically as it relates to the potential investment. Investment managers generally complete an extensive due diligence questionnaire, which incorporates questions related to firm-level data, investment strategy, as well as risk management, valuation procedures, pricing policies, cash controls, cybersecurity, compliance monitoring and service providers. The Advisor will determine the scope and adequacy of the back-office infrastructure, internal controls, compliance function, valuation and pricing procedures, financial reporting, disaster recovery plans and service providers. Information obtained from the meeting, the questionnaire and other materials available is reviewed and outstanding questions are resolved via follow-up calls, meetings or e-mails. Prior to making an investment with any new manager, members of the Advisor’s team contact individuals within its network for background checks/referrals and contact the administrator and other key service providers of the underlying portfolio to confirm the relationship. The Advisor utilizes certain independent investigative firms to perform background checks on all prospective managers, which may include senior members of their management team, those with trading discretion or cash signatory authority, or who otherwise have been deemed material to certain internal controls. The decision of whether to conduct such background checks is in the discretion of the Advisor, based on the underlying manager’s control processes,

and are conducted in accordance with local jurisdictional restrictions. Decisions regarding initial Fund investments or opportunistic investments with managers and any additional capital allocations are made by the relevant Sub-Committee. Operational due diligence is not conducted on transaction counterparties in direct investing strategies such as Blue Ocean, Opportunistic Credit and EnOne Ventures. Such due diligence is conducted by the appropriate investment team (with support from service providers, as applicable) prior to making an investment.

Investment Strategies For Hedge Fund Solutions, the Advisor seeks to select individual managers that offer a variety of different skills in an effort to further balance the Funds’ investment portfolios and to provide for the preservation of capital while maximizing opportunities for growth. The Advisor considers a number of factors in selecting managers, including, but not limited to: the manager’s basic investment strategy and policies; reputation; prior performance; use of fundamental analysis and other analytical methods; use of leverage and other techniques; and trading acumen. There are no limitations on the investment strategies or techniques that may be employed by the Advisor, the portfolios selected or the structure utilized by the Advisor to access an underlying manager. In most cases, Funds managed by the Advisor invest in commingled private investment funds advised by underlying managers. However, in appropriate cases, other vehicles may be utilized. By way of example only, the Advisor may invest, through a manager or directly, in illiquid securities, special purpose vehicles, single investor vehicles or separately managed accounts. Prospective investors are urged to address any questions regarding strategies (and related risks) that may be employed by managers of the Funds’ assets with the Advisor prior to investment. The primary investment strategies pursued by the Funds are set forth below, although the investment strategy for a particular Fund is set forth in that Fund’s offering documentation. Such strategies may be pursued via direct investments or via investments with third party managers: Global Long/Short Equity – Long/Short Equity managers combine a portfolio of long equity positions with a portfolio of short equity positions. Long equity positions are expected to appreciate in value and short equity positions are expected to decrease in value. A manager can look to add value on both the long and short positions, or can simply use a short position to hedge market exposure by shorting a security or index which has a high degree of correlation to the portfolio’s long positions. Managers may be anywhere from net long to net short depending on market conditions, and generally increase net long exposure when markets are expected to rise and decrease net long exposure when markets are expected to fall. Strategies can be value or growth oriented and may invest in equities across the market capitalization spectrum and across multiple countries and regions. Credit & Special Situations – Credit strategies refer to any strategies that utilize credit related securities such as various fixed income instruments and derivative instruments such as credit default swaps. Common credit strategies include distressed investing and credit arbitrage. Distressed securities strategies invest in companies affected by an adverse financial or operating situation such as bankruptcies, debt restructuring, over-levered balance sheets, corporate reorganizations, poor operating results and/or the distressed sale of assets. A manager may invest in distressed securities believed to be selling at a price below the value of such securities after a reorganization or liquidation of the company. At times, the distressed manager may take an active role in creditor committees during the bankruptcy or reorganization process to work towards a favorable outcome for the securities being held. Depending on the manager’s style, investments may be made in bank debt, corporate debt, trade claims, common stock, preferred stock and/or warrants. Returns from distressed securities strategies are usually dependent on the outcome of the bankruptcy or reorganization process. Credit arbitrage strategies attempt to exploit pricing inefficiencies between similarly structured credit sensitive securities of different issuers. For example, although the bonds of two different

companies may have comparable duration, coupon rates and credit ratings, one bond may trade at a premium to the other. Generally, credit instruments used may include loans, bonds and credit default swaps. A variety of hedging techniques are employed to reduce certain risks, including interest rate and credit risk. A manager may look to exploit the pricing discrepancy by buying the undervalued security and shorting the overvalued security, expecting to make a profit as the prices of the two securities begin to converge. Managers employing a special situations strategy generally utilize distressed-type analysis in order to analyze companies that are not in bankruptcy but are undergoing other event driven transactions such as restructurings, turnarounds and spin-offs. Event Driven, Multi-Strategy & Arbitrage – Event driven investing is also referred to as corporate life cycle investing and focuses on opportunities created by transactional events such as spin-offs, consolidations, mergers and acquisitions, liquidations, recapitalization, bankruptcies and other significant corporate transactions. Event driven strategies analyze these transactions in order to predict the outcome and commit capital in a way that benefits from that outcome. Event driven strategies are broad in scope and employ a diverse set of securities including common and preferred stock, debt securities, warrants, stubs and derivatives. More focused event driven type strategies include merger arbitrage, distressed securities and special situations. The success of the strategy primarily relies on the accurate assessment of the outcome and timing of the transactions and the proper deployment of capital. Multi-strategy managers may engage in a variety of these investment strategies. Activist – Activist managers focus on long-term undervalued strategic investments and work to proactively create a catalyst to unlock value. Activist managers attempt to unlock value in companies by developing relationships with management and seek to implement strategic changes that are expected to lead to higher share prices, such as changes in corporate direction and management, corporate restructuring, recapitalization and share buybacks, improvement of operations or a sale of the company. Profits are made when successful value enhancing activities lead to an increase in the price of the company’s securities. Global Macro – A global macro investment strategy seeks to achieve superior capital appreciation. In pursuing its investment objective, the managers seek to anticipate shifts in global markets, and implement investment strategies with a primary focus in a concentrated, directional and thematic selection of assets, that are designed to achieve positive returns during such market events. Implementation of such investment strategies may involve assuming positions in fixed income, equity, foreign exchange and commodity markets and related derivatives. The Advisor expects that Funds will hold interests in an entity that are of a different class, type or seniority from, or otherwise adverse to, the class, type or seniority of interests held by other Funds. Similarly, from time to time Funds will hold multiple investments across the capital structure of an issuer of varying classes, types or seniorities, but will hold different proportions of each such investment or differing priorities of loans or equity. It is possible that the trading and investment activities of any Fund could conflict with the activities and strategies employed in managing the assets of any other Fund and affect the prices and availability of the securities and instruments in which a Fund invests. For example, from time to time, one Fund may hold unsecured debt or a junior tranche of debt of a borrower, or may become a counterparty to a finance lease with a borrower, while another Fund holds secured debt of the same borrower. This would result in one Fund being senior or junior to another Fund in the capital structure of such entity. In a restructuring, workout or other distressed scenarios the interests of such Funds would likely be adverse to one another, and one such Fund might recover all or part of their investment while the other would not. Decisions about what action should be taken in a troubled situation, including whether to enforce claims, whether to advocate or initiate a restructuring or liquidation inside or outside of bankruptcy, and the terms of any work-out or restructuring, raise conflicts of interest. Furthermore, in circumstances where the Advisors are negotiating the terms of different investments across the capital structure – for instance, where the Advisors are simultaneously negotiating terms of a senior loan and a junior loan (and/or the related intercreditor agreement) on behalf of different Funds – additional conflicts of interest may arise.

In addressing certain of the potential conflicts of interest described herein, the Advisors and/or the applicable underlying manager may, but shall not be obligated to, take one or more actions on behalf of a Fund, including any one or more of the following: (i) causing a Fund to remain passive in a situation in which it is otherwise entitled to vote, (ii) referring the matter to one or more persons that are not affiliated with the Advisors to review or approve of an intended course of action with respect to such matter; (iii) consulting with the Fund on such matter or otherwise requesting that the investors (or an advisory board) approve such matter; (iv) establishing ethical screens or information barriers to separate the Advisors’ investment professionals or assigning different teams of the Advisors’ investment professionals, in each case, to Funds that hold different classes, series or tranches of an issuer’s capital structure; (v) as between two Funds, ensuring (or seeking to ensure) that the underlying investors therein own interests in the same securities or financial instruments are in the same proportions so as to preserve an alignment of interest; or (vi) causing a Fund to divest itself of a security or financial instrument or particular class, series or tranche of an issuer’s capital structure it might otherwise have held, including causing a Fund to sell a security or financial instrument to one or more other Funds (or vice versa),or third party investors or (vii) in circumstances where the Advisors are simultaneously negotiating the terms of potentially conflicting investments (such as negotiating the terms of a senior loan and a junior loan (and/or the related intercreditor agreement)) on behalf of different Funds, taking actions such as (A) retaining separate external counsel for the potentially conflicting investments, (B) seeking consent from an independent third party or the investors themselves, or (C) having separate investment professionals within the Advisors be responsible for the negotiation and approval of the terms of each investment. The Advisor may invest in public or private equities, public or private credit, derivatives of either, commodities or other various financial instruments, based on the various investment strategies employed by underlying managers. In each of these instances, underlying managers may take hedged or unhedged positions, depending on the mandates of their underlying accounts. Such investment strategies may be, but are not limited to macro (both discretionary and systematic), credit (distressed, structured, investment grade and/or high yield), and other strategies. Each of these asset classes have their own bespoke set of risks, some of which may or may not be offset through the diversification employed by the underlying manager and/or by EnTrust Global. Risks associated with such investments may include counterparty risk, market risk, credit risk, interest rate risk and currency risk, among others. Additionally, there may be unforeseen risks that are not hedged and cannot be mitigated by the underlying manager.

Risks Investments in the Funds are speculative and involve a substantial degree of risk, including the risk that an investor could lose some or all of its investment in the Fund. An investment in the Funds should be made only after consulting with independent qualified sources of investment, legal, tax, accounting and other advice. A non-exhaustive list of risks is set forth below including, where applicable, a description of the risk management techniques utilized by the Advisor/underlying managers to attempt to mitigate such risks. For a more comprehensive listing of risk factors relating to an investment in a particular Fund, please refer to the offering documentation for such Fund. Business, legal, tax and other regulatory risks. Legal, tax, and regulatory changes, as well as judicial decisions, could adversely affect the Fund, the Advisor, and/or the investment strategies used to implement a Fund’s trading program. The regulatory environment for private investment funds continues to evolve, and changes in the regulation of private investment funds may adversely affect the value of a Fund’s investments and the ability of a Fund to implement its investment strategy. The financial services industry generally and the activities of private investment funds and their investment advisers, in particular, have been the subject of increasing legislative and regulatory scrutiny. Such scrutiny may increase legal, compliance, administrative and other related burdens and costs as well as regulatory oversight or involvement in a Fund and/or the Advisor or result in ambiguity or conflict among legal or regulatory schemes applicable to a Fund, or the Advisor. In addition, securities and futures markets are subject to extensive statutes, regulations and margin requirements. Various U.S. federal and state regulators, including the SEC, the CFTC, self-regulatory organizations and exchanges, are authorized to take extraordinary actions in the event of market

emergencies. Alternative US or non-US rules or legislation regulating a Fund or the Advisor may be adopted, and the possible scope of any rules or legislation is unknown. There can be no assurances that a Fund or the Advisor will not in the future be subject to regulatory review or discipline. The effects of any regulatory changes or developments on a Fund may affect the manner in which it is managed and may be substantial and adverse. International Conflicts and Geopolitical Events. Wars and other international conflicts have caused disruption to global financial systems, trade and transport, among other things. In response, multiple other countries have put in place sanctions and other severe restrictions or prohibitions on certain of the countries involved, as well as related individuals and businesses. The ultimate impact of these conflicts (and other geopolitical events, including national referenda, elections, interest rates, political movements, humanitarian crises, national and international policy changes, actual or perceived trade wars, import or export controls, tariffs, executive orders, laws, legal systems and regulatory regimes) and their effect on global economic and commercial activity and conditions, and on the operations, financial condition and performance of the Funds or any particular industry, business or investee country and the duration and severity of those effects, is impossible to predict. These matters may have a significant adverse impact and result in significant losses to the Funds. This impact may include reductions in revenue and growth, unexpected operational losses and liabilities, supply chain disruptions and reductions in the availability of capital. It may also limit the ability of the Funds to source, diligence and execute new investments and to manage, finance and exit investments in the future. Developing and further governmental actions (military or otherwise) may cause additional disruption and constrain or alter existing financial, legal and regulatory frameworks and systems in ways that are adverse to the investment strategy which the Funds intend to pursue, all of which could adversely affect the Funds’ ability to fulfill their investment objectives. Market (beta) Risk. Certain of the Funds’ primary mission is to build a portfolio of managers within a range of non-correlated investment strategies that the Advisor regards as likely to provide favorable investment opportunities in most economic environments. Notwithstanding this goal, there is a risk that a manager’s performance will be more closely correlated with the broader markets than was anticipated. Different measuring techniques are employed to monitor market correlations and manager correlations, and stress tests are performed relating to potential changes in market conditions on a regular basis in order to assist in limiting the Funds’ exposure to market (beta) risk. The Funds’ managers perform their own analyses of market exposure and risk and utilize market risk evaluation tools, which vary from manager to manager but incorporate measuring/monitoring risks by asset class, strategy, geographic region and industry sector, as appropriate. Within the Advisor’s due diligence questionnaire are extensive questions related to how the manager measures and monitors risk, and members of the Advisor’s operational due diligence team followup whenever meeting with managers to determine if they have made any changes to their processes or systems. Leveraged Investments. The Funds are permitted to utilize leverage by incurring or having a portfolio company or intermediate entity incur debt to finance all or a portion of certain investments, whether on a temporary or long-term basis. Leverage generally magnifies both the Funds’ opportunities for gain and its risk of loss from a particular investment. The cost and availability of leverage is highly dependent on the state of the broader credit markets (and such credit markets may be impacted by regulatory restrictions and guidelines), which state is difficult to accurately forecast, and at times it may be difficult to obtain or maintain the desired degree of leverage. Leverage often imposes restrictive financial and operating covenants on a company, in addition to the burden of debt service, and potentially will constrain its ability to operate its business as desired and/or finance future operations and capital needs. The leveraged capital structure of portfolio companies will increase the exposure of the Funds’ investments to any deterioration in a company’s condition or industry, competitive pressures, an adverse economic environment or rising interest rates and could accelerate and magnify declines in the value of the Funds’ investments in the leveraged portfolio companies in a down market. These risks generally are expected to increase as interest rates rise, including in circumstances where a portfolio company’s creditworthiness is such that it must borrow at higher interest rates than are available to the Funds. In the event any portfolio company cannot generate adequate cash

flow to meet its debt service, the Funds may suffer a partial or total loss of capital invested in the portfolio company, which could adversely affect the returns of the Funds. Furthermore, should the credit markets be limited or costly at the time the Funds determine that it is desirable to sell all or a part of a portfolio company, the Funds may not achieve exit multiples or enterprise valuations consistent with their forecasts. Furthermore, the companies in which the Funds invest generally will not be rated by a credit rating agency. Except where otherwise required by the offering documentation, the Funds will not be obligated to borrow on behalf of a portfolio company, even in circumstances where the Funds’ creditworthiness would permit borrowing at a lower rate than is available to the portfolio company. The Funds are also permitted to borrow money or guaranty indebtedness (such as a guaranty of a portfolio company’s debt, a letter of credit or other forms of promise to provide funding) or otherwise be liable therefor, and in such situations, it is not expected that the Funds would be compensated for providing such guarantee or exposure to such liability. The use of leverage by the Funds generally also will result in fees, interest expense and other costs to the Funds that may not be covered by distributions made to the Funds or appreciation of their investments. While Fund-level borrowings generally will be subject to limitations set forth in the offering documentation and interim in nature, asset- or intermediate entity-level leverage generally will not be subject to any limitations, including with respect to the amount of time such leverage may remain outstanding. The Funds generally are permitted to incur leverage on a joint, several, joint and several or crosscollateralized basis with one or more other Funds and entities managed by the Advisor or any of its affiliates, including through Fund subsidiaries and other intermediate entities, and may have a right of contribution, subrogation or reimbursement from or against such entities. Certain co-investors (potentially including service providers (including lenders and law firms), third parties, current or former portfolio company management or personnel, sellers or members of management that have rolled their interest or reinvested proceeds in the portfolio company and/or other owners)) are not expected to share in incurring such leverage or the related costs and as a result the Funds will disproportionately bear the risk and/or costs of leverage arrangements. In addition, to the extent the Funds incur leverage (or provides such guaranties), such amounts are permitted to be secured by commitments made by the Funds’ investors and such investors’ contributions may be required to be made directly to the lenders instead of the Funds. Bridge Financing. Subject to the relevant provisions of the offering documentation, the Funds reserve the right to provide interim financing to a portfolio company, including in anticipation of a future issuance of equity or long-term debt securities, in anticipation of another refinancing or sell-down of interests to coinvestors or where such portfolio company has an identified short-term financing need, among other reasons. Such bridge financings may be convertible into a more permanent, long-term security; however, for reasons not always in the Funds’ control, such long-term securities issuance or other refinancing or sell-down may not occur and such bridge investments and interim investments may remain outstanding and be treated as a permanent investment in such portfolio company. The Advisor will determine in its sole discretion the terms, including the interest rate (if any) or other price to be charged, applicable to the portfolio company, coinvestors or other parties acquiring or refinancing bridge financings from the Funds. Such interest rate, or price or other terms may not adequately reflect the Funds’ cost of capital or the risk such investment would not be sold or refinanced. In such event, the interest rate or other terms of such investments may not adequately reflect the risk associated with the position taken by the Funds. Compliance with the concentration limitation under the offering documentation will be measured solely at the time the applicable investment or bridge financing is made. To the extent that a bridge financing becomes a permanent investment, the Funds will not be deemed to have violated their concentration limits, if any, under the offering documentation. Subscription Lines. The Funds generally are permitted to enter into subscription lines with one or more lenders in order to finance their operations, including the acquisition, financing or refinancing of the Funds’ investments, as well as to consolidate or make less frequent capital calls to investors. Fund-level borrowing subjects investors to certain risks and costs. For example, because amounts borrowed under a subscription line typically are secured by pledges of the Advisor’s right to call capital from the investors, investors may be

obligated to contribute capital on an accelerated basis if a Fund fails to repay the amounts borrowed under a subscription line or experiences an event of default thereunder. Moreover, any investor claim against the Funds would likely be subordinate to the Funds’ obligations to a subscription line’s creditors. In addition, Fund-level borrowing will result in additional partnership expenses that will be borne by investors. These expenses typically include interest on the amounts borrowed, unused commitment fees on the committed but unfunded portion of a subscription line, an upfront fee for establishing a subscription line and other one-time and recurring fees and/or expenses, as well as legal fees relating to the establishment, structuring and negotiation of the terms of the borrowing facility, as well as expenses relating to maintaining, renegotiating or terminating the facility. Because a subscription line’s interest rate is based in part on the creditworthiness of the investors and the terms of the offering documentation, it may be higher than the interest rate an investor could obtain individually. To the extent a particular investor’s cost of capital is lower than the relevant Fund’s cost of borrowing, Fund-level borrowing can negatively impact the investor’s overall individual financial returns even if it increases the Fund’s reported net returns in certain methods of calculation. Conflicts of interest have the potential to arise in that the use of Fund-level borrowing typically delays the need for investors to make contributions to a Fund, or results in short-term gains to a Fund, which in certain circumstances enhances the Fund’s return calculations and thereby has the potential to benefit the marketing efforts of the Advisor and its affiliates and increases the likelihood that any hurdle or preferred return component in the Fund’s carried interest arrangements will be met. A portfolio company financing from a subscription line, rather than from a Fund-level equity commitment, has the potential to increase such returns, particularly in instances where the relevant amount has been drawn for an extended period of time. In other circumstances the use of Fund-level borrowing can increase the base of the management fee calculation, such as during periods where management fees are based in whole or in part on an acquisition cost that includes a borrowing component. Because management fees are incurred whether an investment is financed through capital calls or borrowings, and a Fund’s preferred return typically does not accrue on outstanding borrowings, the Advisor has an incentive to cause the Fund to make investments and/or pay such amounts using a subscription line rather than making capital calls. The use of Fund-level borrowing arrangements, and the repayment or non-repayment thereof, can also influence the determination of the end of the Funds’ investment period, and cause or defer a related change in the basis of the Funds’ management fee calculation under the offering documentation. Conflicts of interest also have the potential to arise to the extent that a subscription line is used to make an investment that is later sold in part to co-investors (including one or more co-investing funds managed by the Advisor or its affiliates) as, to the extent co-investors are not required to act as guarantors under the relevant facility or pay related costs or expenses, co-investors nevertheless stand to receive the benefit of the use of the subscription line and neither the Funds nor investors generally will be compensated for providing the relevant guarantee(s) or being subject to the related costs, expenses and/or liabilities. A credit agreement or borrowing facility frequently will contain other terms that restrict the activities of the Funds and the investors or impose additional obligations on them. For example, certain lenders or facilities are expected to impose restrictions on the Advisor’s ability to consent to the transfer of an investor’s interest in the Funds or impose concentration or other limits on the Funds’ investments, and/or financial or other covenants, that could affect the implementation of the Funds’ investment strategy and/or an investor’s ability to transfer its interest in a Fund. In addition, in order to secure a subscription line, the Advisor reserves the right to request certain financial information and other documentation from investors to share with lenders. The Advisor will have significant discretion in negotiating the terms of any subscription line and may agree to terms that are not the most favorable to one or more investors. In certain circumstances, due to separate evaluations of creditworthiness by lenders or facility providers, a portfolio company or other Fund subsidiary is expected to bear higher rates under a borrowing facility than are borne by the Funds, resulting in a potential net benefit to the Funds, or additional potential liquidity constraints or other burdens on the relevant portfolio company or Fund subsidiary.

Fund-level borrowing involves a number of additional risks. For example, drawing down on a subscription line allows the Advisor to fund investments and pay partnership expenses without calling capital, potentially for extended periods of time. Calling a large amount of capital (including amounts that would have represented multiple capital calls or investment closings absent the use of a subscription line) at once to repay the thencurrent amount outstanding under the subscription line could cause short-term liquidity concerns for investors that would not arise had the Advisor called smaller amounts of capital incrementally over time as needed by the Funds. This risk would be heightened for an investor with commitments to other funds that employ similar borrowing strategies or with respect to other leveraged assets in its portfolio; a single market event could trigger simultaneous capital calls, requiring the investor to meet the accumulated, larger capital calls at the same time. Such larger capital amounts may increase the magnitude of potential investor defaults. The Advisor is authorized to use Fund-level borrowing to pay management fees and to reimburse the Advisor for expenses incurred on behalf of the Funds. The Funds are also permitted to utilize Fund-level borrowing when the Advisor expects to repay the amount outstanding through means other than investor capital, including as a bridge for equity or debt capital with respect to an investment. If the Funds ultimately are unable to repay the borrowings through those other means, investors would end up with increased exposure to the underlying investment, which could result in greater losses. If an investment appreciates in value and is disposed of prior to repayment, the Funds generally would apply disposition proceeds to repay the borrowing and related interest and expenses. The absence of invested capital funded by investors potentially will result in a distribution of net proceeds without a preferred return accrual on the amount invested. Accordingly, borrowings have the potential to support the distribution of proceeds to investors and increase the potential carried interest for the Advisor, as reduced by the interest incurred by the Funds. Subject to any limitations in the offering documentation, this scenario potentially incentivizes the Advisor to permanently fund the acquisition and ongoing capital needs of the Funds’ investments and related expenses with the proceeds of such borrowings in lieu of drawing down capital contributions on an as-needed basis, and, accordingly, capital contributions to repay such borrowings may be required only at the time of the disposition of an investment (or never, if principal and interest on such borrowings are always repaid out of disposition proceeds). Investment- and Intermediate Entity-Level Borrowing. Under the offering documentation, the Funds are 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 the Funds, including, without limitation, to: finance any investment-related activities of the Funds; increase the buying power of the Funds; 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 management fees; make, hold or dispose of investments; provide financing or refinancing to portfolio companies; fund the payment of amounts to withdrawing investors; fund distributions; and/or provide collateral to secure outstanding letters of credit or to create reserves, in each case in accordance with the offering documentation. Further, the Funds are expected to provide credit support (including letters of credit) or guarantee the obligations of one or more intermediate entities or portfolio companies that are joined as “qualified borrowers” or “portfolio company borrowers” under a Fund’s subscription line facility for the purpose of providing financing to one or more of such entities in support of one or more investments. Other investors or owners of such intermediate entities (or portfolio companies) generally will not share in the risk and/or cost of such financing, or the guarantees or other credit support the Funds provide in respect thereof under the relevant subscription facility. As a result, in a situation where additional credit support is required, the Funds and not such other investors or owners would be obligated to provide such amounts. However, these other investors or owners have the potential to benefit indirectly therefrom, to the extent the financing improves portfolio company performance. Although in many cases the offering documentation impose limits on borrowings at the Fund level, portfolio investments and intermediate entities generally do

not have such limits on their ability to engage in borrowings or incur leverage with respect to all or a portion of the relevant investments. Liquidity Risk. For certain of the Funds that are not direct investing Funds, the Advisor maintains a schedule of the liquidity provisions for each of the underlying portfolios (including notification dates) and the start dates of the Funds’ investments as well as withdrawal dates. The Funds’ managers also have systems which track the amounts of potential investor withdrawals. Many of these managers have funding capabilities from their prime brokers and/or financial institutions for a certain percentage of the fund’s capital (usually 10-15%). Unlike a single hedge fund investment, the Funds are able to withdraw from several invested hedge funds simultaneously to meet withdrawal requests which minimize the potential adverse impact on any single manager. Nevertheless, there is a risk that due to market conditions, one or more underlying managers may be unable to honor a withdrawal request and will, as a result, impose a gate or suspend withdrawals, or take other actions which limit the ability of a Fund to obtain the cash required to fund withdrawals. In order to obtain access to a reliable source of working capital, some Funds have secured a line of credit, intended to serve as a prudent means of assuring a source of working capital for temporary and emergency purposes, such as funding investments in advance of receiving withdrawal proceeds from underlying managers, to meet unanticipated or large-scale withdrawal requests and to fund managers in anticipation of impending capital contributions. Uncertainty as to the Value of Certain Portfolio Investments. Investments into investment vehicles are valued on the basis of the most recent confirmed price or valuation provided by the relevant manager or administrator, or if unavailable, the estimated price or valuation provided by the relevant manager or administrator. Certain of the investments held by underlying funds will take the form of securities, loans or other assets that are not publicly traded or are illiquid. The fair value of such investments may not be readily determinable and will require the exercise of some measure of discretion in arriving at a valuation. Underlying managers or independent third parties generally will value these investments at fair value, including to reflect significant events affecting the value of investments. Where assets of a Fund are invested either partly or wholly through subsidiary companies or in segregated portfolios, the above policy also applies for the valuation of the investments held by those subsidiary companies or segregated portfolios. Because such valuations, and particularly valuations of private securities and private companies, are inherently uncertain, they may fluctuate over short periods of time and may be based on estimates, models or the value of other securities believed to be comparable, all of which require the exercise of judgment by the party establishing value. In those circumstances in which the valuation is performed by the manager, the manager faces a conflict in establishing value because the valuations have an impact on the fees received by the manager. Even in those circumstances in which a third party establishes the valuation, the conflict may be eliminated, but the valuation may not necessarily be a more accurate reflection of the securities’ fair value. Determinations of fair value may differ materially from the values that would have been used if a ready market for these loans and securities existed. Moreover, the actual price at which a security is sold (or could be sold) may differ from the value used by the underlying investment vehicle for purposes of striking the vehicle’s net asset value. As a result, an investor redeeming from a Fund prior to realization of such an investment may not participate in the ultimate gains or losses therefrom and Net Asset Value could be adversely affected if determinations regarding the fair value of investments were materially higher than the values that are ultimately realized upon the disposal of such loans and securities. Operational Risk. For applicable Funds that are not direct investing Funds, inherent in a fund of funds’ structure is the operational risk that the policies and procedures of underlying managers may not be followed or, even if followed, may not adequately mitigate a particular risk. The Advisor conducts due diligence and regularly monitors the operational infrastructure of managers. However, due diligence is not foolproof and there can be no assurance that the Advisor’s due diligence will be sufficient to ensure that all internal controls are being followed and that a fraudulent scheme devised by an underlying manager will be detected.

Valuation Risk. The Funds that invest in vehicles managed by underlying managers will have limited or no ability to assess the accuracy of valuations received from the underlying managers. Many of the positions held by the underlying vehicles are not traded on an exchange or organized market. In some cases, values are based on pricing models and will be subject to the judgment and discretion of the underlying managers. No assurance can be given that such positions can be sold for the amounts at which they are valued. Moreover, the underlying managers may receive performance-based compensation with respect to such positions based upon unrealized gains. No assurance can be given that such unrealized gains will ultimately be realized. In addition, the Advisor has a Valuation Committee and Valuation Policies and Procedures that govern the process for valuing investment portfolios in accordance with relevant accounting, legal and regulatory guidance. Where investments are made with underlying managers, this review typically involves a review of valuation methodology and approach to ensure reasonableness of the valuation prepared by an independent administrator or other valuation agent. Valuations for Blue Ocean investment vehicles are governed by the Advisors’ Valuation Policy. The Valuation Committee may exercise discretion to depart from the Valuation Procedures if doing so would be in the best interest of, and consistent with, the Advisor’s fiduciary duty or to reasonably attempt to avoid the investment vehicle suffering a materially adverse effect. Although the Advisor has a Valuation Policy, there is no guarantee that the procedures set forth in this policy will be followed or, even if followed, the valuations will be accurate. Access to Information from underlying managers. For applicable Funds, the Advisor requests information from each underlying manager regarding the underlying manager’s historical performance and investment strategy. The Advisor also requests detailed portfolio information on a continuing basis from each underlying manager retained on behalf of a Fund. However, the Advisor may not always be provided with such information because certain of this information may be considered proprietary information by the particular underlying manager. This lack of access to information may make it more difficult for the Advisor to select, allocate among, and evaluate underlying managers. In addition, the Funds do not control any of the underlying managers, their choice of investments, or any other investment decisions. The investments of a Fund are made pursuant to written disclosures from, and/or agreements with, any underlying manager that will provide, among other things, guidelines by which the underlying manager will make its investment decisions. However, while each underlying manager undertakes to follow specified investment programs, it is possible that an underlying manager could deviate from such program, and such deviation could result in a loss of all or a part of a Fund’s investment. Volatility. Volatility both for the Funds and, for Funds investing with underlying managers, their underlying managers, is measured and monitored by members of the Advisor’s investment team on a regular basis utilizing various volatility measurements such as standard deviation and beta. However, at times market conditions may introduce significant volatility to a Fund’s performance.

A.) Blue Ocean Fund Risks In addition to the general risk factors set forth in Item 8, investors should be aware of the following additional risk factors, which are specific to the Blue Ocean Funds. Please refer to the offering documents of the Blue Ocean Funds for more details regarding these risk factors. Risks Related to Investment Activities. The Blue Ocean Funds may be subject to certain investment risks such as risks associated with senior secured loans, mezzanine debt, leasing of commercial cargo vessels, private debt securities that may be below-investment grade, and joint venture investments with shipping companies and other third parties. Among other things, these risks may include the reliance on the Advisor to adequately diligence and monitor borrowers and other counterparties (which are often private companies) in the maritime industry, the potential impact of bankruptcy/insolvency of borrowers, and the typically illiquid nature of the loans and other investments made by the Blue Ocean Funds. In addition, the Blue Ocean Funds may also make other equity investments, which may not appreciate in value prior to disposition.

Maritime Industry Risks. The maritime industry is subject to various risks, each of which could have a material, adverse effect on the Blue Ocean Funds’ investments, including, without limitation: events such as marine disasters, bad weather, mechanical failures, structural failures, human error, war, terrorism, piracy and other circumstances or events; compliance with various laws and regulations, including federal, state and local laws and regulations affecting the marine transportation industry, all of which are subject to amendment or changes in interpretation; requirements to obtain and maintain permits, licenses and certificates and perform routine inspections, monitoring, recordkeeping and reporting with respect to vessels and operation; and global trade agreements, tariffs and subsidies that adversely affect the flow of import and export tonnage and the demand for marine transportation services. If the maritime industry continues to experience dislocation, the Blue Ocean Funds’ ability to achieve their investment objectives may be adversely affected. Additional Shipping Industry Risks. The Blue Ocean Funds will have a limited number of investments, all of which will be in the maritime industry, primarily in shipping companies and offshore oil services companies. As a result, the Blue Ocean Funds will be particularly vulnerable to economic conditions in the shipping industry, including declines in export/import volumes, strikes, increases in fuel costs, uninsured casualties and the difficulties associated with enforcing liens on liquidating collateral in foreign jurisdictions. The Blue Ocean Funds may make loans to special purpose vehicles that own one or more vessels where the borrower’s revenues are limited to income derived from such vessels. If the vessels are not deployed for a period of time, or if revenues fall, the borrower may not have sufficient income to pay operational expenses or to service the debt. Credit Risk. Debt securities are also subject to other creditor risks, including (a) the possible invalidation of an investment transaction as a “fraudulent conveyance” under relevant creditors’ rights laws, (b) so-called “lender liability” claims by the issuer of the obligations and (c) environmental liabilities that may arise with respect to collateral securing the obligations. In addition, in connection with investments in loans there exists the possibility of material misrepresentations or omissions on the part of the borrower. Such inaccuracy or incompleteness may adversely affect the valuation of the collateral underlying the loans or may adversely affect the ability of the Fund to perfect or effectuate a lien on any collateral securing the loan. The Blue Ocean Funds cannot guarantee the accuracy and completeness of representations made by borrowers. Equity Investments. The Blue Ocean Funds make selected equity investments, often via joint ventures or similar structures with shipping companies. The Blue Ocean Funds generally seek to ultimately dispose of these equity investments (including through a sale of the related vessels) and realize gains upon such disposition. However, the equity investments may not appreciate in value and, in fact, may decline in value. Accordingly, the Blue Ocean Funds may not be able to realize gains from their equity investments. In addition, these equity investments often may take the form of joint ventures or similar structures with other shipping companies, in which case the Blue Ocean Funds will be exposed to the risks associated with such structures, with respect to the maritime assets held therein. BO 4Impact. BO 4Impact’s sole investment is Purus Marine Holdings LP, a maritime company launched by EnTrust Global. The risks to which BO 4Impact and Purus Marine are subject generally include the risks relating to the maritime industry discussed above, and the other risks (as applicable) discussed in this Section 8. BO 4Impact and Purus Marine are also subject to other risks, which are more fully set forth in the offering documentation for BO 4Impact, and include among others (i) the risk that Purus Marine will be unable to consummate an initial public offering, company sale, or other exit, and that because Purus Marine is expected to be the only investment held by BO 4Impact, investors in BO 4Impact will therefore be unable to realize liquidity for an extended period of time, (ii) that, as a relatively young business launched within the last several years, Purus Marine will be subject to many of the risks associated with such businesses, and there is no guarantee that it (and therefore BO 4Impact) will be successful, and (iii) that because Purus Marine does, and may continue to, own certain vessels and other maritime assets through joint ventures or similar structures with other shipping companies, it will be exposed to the risks associated with such structures, with respect to maritime assets held therein.

Social, Environmental or Similar Investment Policies. The Advisor may agree with one or more investors to abide by, or may adopt on behalf of the Funds, certain investment policies or restrictions based on social, environmental, governmental or other considerations. Any such policy or restriction could have the effect of limiting the types of investments in which the Funds may participate and narrow the scope of the Funds’ stated investment policy. This could have a material adverse impact on the Funds’ performance. The Funds could also be required to limit the participation of one or more investors in certain types of investments (to the extent any such investment is permitted) and any other investors would then be allocated a greater percentage of the profits and losses attributable to any such investment. The Advisor may agree to such a limited participation arrangement with only one or a small number of investors in which case not all investors would benefit from such terms.

B.) EnOne Ventures Venture and Start-Up Companies. The Funds are permitted to make investments in portfolio companies, including, but not limited to, venture and start-up companies, which involve a number of particular risks that may not exist in the case of investments in large public companies or established private companies, including: These companies may have limited financial resources and limited access to additional financing, which may be accompanied by a deterioration in the value of the Funds’ investments, reduce the likelihood of the Funds realizing an investment return thereon, and increase the risk of such companies defaulting on any obligations, leaving creditors dependent on any guarantees or collateral they may have obtained; 

companies typically have shorter operating histories, narrower product lines and smaller market shares than larger businesses, which tend to render them more vulnerable to competitors’ actions and market conditions, as well as general economic downturns;

Typically we will not have as much information publicly available about these companies as would be available for public companies or more established private companies and such information may not be of the same quality;

These companies often face intense competition, including from established companies with much greater financial, manufacturing and technical resources, more marketing and service capabilities and a greater number of qualified personnel;

These companies are more likely to depend on the management talents and efforts of a small group of persons; as a result, the death, disability, resignation or termination of one or more of these persons could have a material adverse impact on these companies’ ability to meet their obligations;

These companies generally have less predictable operating results, may from time to time be parties to litigation, may be engaged in rapidly changing businesses with products subject to a substantial risk of obsolescence, and may require substantial additional capital to support their operations, finance their expansion, or maintain their competitive position, and the Advisor and its executive officers and directors may, in the ordinary course of business, be named as defendants in litigation arising from the Funds’ investments therein; and

These companies may have difficulty accessing the capital markets to meet future capital needs, which may limit their ability to grow or to repay their outstanding debt upon maturity.

Growth-Stage and Early-Stage Companies. The Funds reserve the right to invest in growth-stage and earlystage companies, many of which may have narrow product lines and small market shares, which tend to render them more vulnerable to competitors’ actions and market conditions, as well as to general economic downturns, compared to more mature companies. The revenues, income (or losses) and projected financial

performance and valuations of early-stage or growth-stage companies can and often do fluctuate suddenly and dramatically. For these reasons, investments in the Funds with growth-stage and early-stage portfolio companies, if rated by one or more ratings agencies, would typically be rated below “investment grade,” which refers to securities rated by ratings agencies below the four highest rating categories. The Funds’ target growth-stage companies may be geographically concentrated and are therefore highly susceptible to materially negative local, political, natural and economic events. In addition, high growth industries are generally characterized by abrupt business cycles and intense competition. Overcapacity in high-growth industries, together with cyclical economic downturns, may result in substantial decreases in the value of many growth-stage companies and/or their ability to meet their current and projected financial performance to service the Funds’ investments. Furthermore, growth-stage companies also typically rely on venture capital and private equity investors, or initial public offerings, or sales for additional capital. Venture capital funds in turn rely on their limited partners to pay in capital over time in order to fund their ongoing and future investment activities. To the extent that a venture capital fund’s limited partners are unable or choose not to fulfill their ongoing funding obligations, the venture capital fund may be unable to continue operationally and/or financially supporting the ongoing operations of the fund’s portfolio companies, which could materially and adversely impact such fund’s financing arrangement with such portfolio companies. These companies, their industries, their products and customer demand and the outlook and competitive landscape for their industries are all subject to change which could adversely impact their ability to execute their business plans and generate cash flow or raise additional capital that would serve as the basis for repayment of the Funds’ investments. Therefore, the Funds’ investments in growth-stage companies may face considerably more risk of loss than companies at other stages of development. Persistent Supply Chain Constraints. Portfolio companies may be reliant on supply chains, and significant supply chain disruptions may lead to elevated costs and slower lead time affecting a vast array of vendors and suppliers in such portfolio company’s industry. Further, given the complexities of a global supply chain, public and private mitigation initiatives within a portfolio company’s industry may be modest and gradual, lacking visibility on normalization concerning such supply chain. Should supply chain disruptions persist, this may lead to upward pressure on prices involving the business of the portfolio company, including raw materials and shipping. A number of factors may also require a portfolio company to seek alternative or additional suppliers, which may not be able to be done in a timely or cost-effective manner. This may cause a significant disruption in the supply of raw materials from current sources, or, in the event of a disruption, there may not be possible alternative materials suppliers of comparable quality at an acceptable price, or at all. Moreover, the suppliers may not be able to fill the orders in a timely manner depending on market conditions or increased demand for product. In addition, if a portfolio company loses or needs to replace an existing manufacturer or supplier as a result of adverse economic conditions or other reasons, additional supplies of raw materials or additional manufacturing capacity may not be available when required on terms that are acceptable to the portfolio company, or at all, or suppliers or manufacturers may not be able to allocate sufficient capacity to the Funds in order to meet the requirements. Even if it is possible to expand existing or find new manufacturing sources, the portfolio company may encounter delays in production and added costs as a result of the time it takes to train the suppliers and manufacturers on the portfolio company’s methods, products and quality control standards. Any delays, interruption or increased costs in the manufacture of the products could have an adverse effect on the portfolio company’s ability to meet retail customer and consumer demand for the products and result in lower net revenues and net income (or higher net loss) both in the short and long term. Increased Existing-Competitor Competition. There is a risk of existing competitors of a portfolio company attempting to establish or grow a vertically integrated model while selling directly to youth sports teams, with a strategy similar to that of one or more portfolio companies. Should any of these competitors be successful, a portfolio company’s business may be negatively impacted. The sports industry as a whole is highly

competitive and subject to rapidly changing consumer preferences, economic conditions and evolving regulations. There can be no assurance that any portfolio company will successfully establish or maintain market demand. Any downturn in the industry, unfavorable market conditions or failure to achieve a viable business model could adversely affect the financial performance of a portfolio company and, in turn, adversely affect the Funds’ performance. Risks related to regulatory changes for NCAA Athletes. The National Collegiate Athletic Association (“NCAA”), which governs most collegiate sports in the United States, has historically prohibited its athletes from receiving any compensation or benefits for their athletic participation, other than scholarships and cost of attendance. However, in recent years, several states have enacted or proposed laws that would allow NCAA athletes to earn income from their name, image, and likeness rights (“NIL”), without jeopardizing their eligibility. The NCAA has adopted new rules that would permit NIL opportunities for its athletes, subject to certain conditions and limitations. However, the NCAA has faced legal challenges and congressional scrutiny over its proposed framework. Moreover, the NCAA’s NIL rules may conflict with or be preempted by state laws, creating a patchwork of inconsistent and potentially incompatible regulations for the Funds and their respective portfolio companies to navigate. Investments in Media and Entertainment. The Funds are permitted to make, and likely will make, investments in the media and entertainment sector. Such investments are expected to include, but are not necessarily limited to, technology-enabled or related growth investments. The success of media and entertainment companies depends substantially on consumer tastes and preferences that change in often unpredictable ways. Such media companies often make large investments in products (e.g., film production, television programming, broadcast rights, etc.) before knowing the extent to which such products will earn consumer acceptance. If a media company’s entertainment offerings and products do not achieve sufficient consumer acceptance, revenue from advertising sales, affiliate fees, subscription fees, theatrical film receipts, licensing rights, merchandise, memorabilia, etc. may decline or fail to grow to the extent anticipated when making investment decisions and thereby adversely affect the profitability of such company. The increasing number of choices available to audiences, including low-cost or free choices, could negatively impact not only consumer demand for media and entertainment companies’ products and services, but also advertisers’ willingness to purchase advertising from such companies. Such companies compete for the sale of advertising revenue with television networks and stations, as well as other advertising platforms. Additionally, the value of a media company’s intellectual property rights is dependent on the scope and duration of such rights as defined by applicable laws in the U.S. and abroad and the manner in which those laws are construed. If those laws are drafted or interpreted in ways that limit the extent or duration of such rights, or if existing laws are changed, a company’s ability to generate revenue from its intellectual property may decrease, or the cost of obtaining and maintaining rights may increase. The unauthorized use of intellectual property may increase the cost of protecting rights to intellectual property or reduce revenues which may also have an impact on the Funds’ investments. Mezzanine Debt. While the Funds intend to invest primarily in equity and equity-like securities of early-stage and growth investments, the Funds also are permitted to invest in credit instruments, including mezzanine debt. Investments in mezzanine debt securities of highly leveraged companies involve a high degree of risk. Highly leveraged companies are inherently more sensitive to adverse business or financial developments or economic factors, including declines in company revenues, increases in company expenses, rising interest rates, downturns in the economy, increasing competition and deteriorating industry conditions. In addition, mezzanine debt securities typically are subordinated to substantial amounts of senior debt, all or a significant portion of which may be secured, which means that distributions to mezzanine holders are available only after satisfaction of claims of senior creditors. While the mezzanine investments may benefit from the same or similar financial and other covenants as those enjoyed by the indebtedness ranking ahead of such investments and may benefit from cross-default provisions and security over the assets of the issuer, some or all of such terms may not be part of particular investments.

C.) Market and Investment Risks Risks of Concentration of Investments. While the Advisor will seek to diversify the assets of the Fund, there is a risk inherent in the fund of hedge funds approach that the Funds will inadvertently have excess concentration and therefore excess exposure to a particular issuer, security, industry sector or geographic region. Additionally, underlying portfolios, particularly opportunistic investments, may be relatively concentrated in one investment or in a relatively small number of investments. Limitations as to strategy, amount of capital or analytical resources can lead to significant concentration practices by a particular manager. Concentration of investments in a limited number of issuers or securities, industries or industry groups, or countries or regions, particularly in the context of event-related investing, can increase investment risk and portfolio volatility. Accordingly, the Funds’ assets may be subject to greater risk of loss than if they were more widely diversified, and the failure or poor performance of any one manager or security could have a material adverse effect on the Fund. Oversight of positions of underlying managers is conducted on an ongoing and real-time basis by research analysts and the operational due diligence team, although even such oversight cannot be a guarantee against investment losses. Hedging Limitations. Although the Advisor may seek one or more managers who employ various hedging techniques, the extent and effectiveness of such hedging strategies may vary substantially. Moreover, not all managers retained by the Advisor will necessarily employ fully hedged or “market-neutral” strategies. Most hedging techniques of managers will be directed primarily toward general market risks or certain issuer risks. Typically, there are numerous investment risks which will not be hedged or necessarily capable of being hedged as a practical matter. To the extent unhedged, investment positions of managers will, in general, be fully exposed to market and investment risks. Hedging techniques have a variety of limitations. Hedging against a decline in the value of a portfolio position by selling short, for example, does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the overall portfolio positions’ value. Hedging through market index options may only protect against an overall market downturn, as compared with price declines in specific securities. Hedge transactions generally also limit the opportunity for gain if the value of the portfolio position should increase, due to the hedging cost or price decline in the hedging position. For a variety of reasons, a manager may not seek or be able to establish a sufficiently accurate correlation between hedging instruments and the portfolio holdings being hedged. Such imperfect correlation may prevent an underlying portfolio from achieving the intended hedge or may expose the Funds to risk of loss. Such losses can include losses on the hedged position, and could be substantial. There can be no assurance, therefore, that investment positions of underlying portfolios will be significantly hedged against investment risks or that such hedging strategies, if any, will in fact prove successful. Event Driven Investing. The Funds utilize managers that employ various investment strategies. The ability of a manager to obtain a profit from these investment strategies may often depend upon factors that are intrinsic to the particular issuer, rather than the market as a whole. Appreciation in the value of such securities may be contingent upon the occurrence of certain events, such as a successful reorganization or merger. If the expected event does not occur, the underlying portfolio may incur a loss on the position. Purchases of Securities and other Obligations of Financially Distressed Companies. Underlying portfolios may purchase securities and other obligations of companies that are experiencing significant financial or business distress, including companies involved in bankruptcy, or other reorganization and liquidation proceedings. Acquired investments may include senior or subordinated debt securities, bank loans, promissory notes and other evidence of indebtedness, as well as payables to trade creditors. Although such purchases may result in significant returns to the Fund, they involve a substantial degree of risk and may not show any return for a considerable period of time. In fact, many of these securities and investments ordinarily remain unpaid while the company is in bankruptcy and may not ultimately be paid unless and until the company reorganizes and/or emerges from bankruptcy proceedings. As a result, such securities may have to be held for an

extended period of time. The level of analytical sophistication, both financial and legal, necessary for successful investment in companies experiencing significant business and financial distress is high. There is no assurance that the nature and magnitude of the various factors that could affect the prospects for a successful reorganization or similar action will be correctly evaluated. Activist Strategy Risks. The underlying portfolios in which the Funds invest may invest a material portion of their capital in publicly traded equity and debt securities of companies that the applicable underlying manager believes are undervalued by the marketplace and are likely to appreciate, including as a result of a change in ownership, corporate direction or management, or as a result of operational improvements. In making such investment, the applicable underlying portfolio may act alone or together with one or more other investors or investment managers acting as a group. In order to implement any actions deemed necessary to maximize value, the underlying manager, or other members of the investing group, may work with the management team of the target company to design an alternate strategic plan and assist them in its execution and may secure the appointment of persons selected by the underlying manager or other members of the group to the company’s management team or board of directors. If necessary, the underlying manager, either alone or as part of a group, may also initiate shareholder actions (including those that may be opposed by company management) seeking to maximize value. Such shareholder actions may include, among other things, re-orienting management’s operational focus, initiating the sale of the company (or one or more of its divisions) to a third party, or an acquisition by the underlying portfolio or other members of the investing group. Such an acquisition may be accomplished either by the underlying portfolio (or the members of the investing group) acting alone, or acting in conjunction with management through a leveraged buyout. In order to accomplish the foregoing, the Fund, either alone or together with other members of a group, may acquire a “control” position in the company’s securities. This activist investment strategy may require, among other things: (i) that the underlying manager properly identify portfolio companies whose securities prices can be improved through corporate and/or strategic action; (ii) that the underlying portfolio acquire sufficient securities of such portfolio companies at a sufficiently attractive price; (iii) that the underlying portfolio avoid triggering anti-takeover and regulatory obstacles while aggregating its position; (iv) that management of portfolio companies and other security holders respond positively to the underlying manager’s proposals; and (v) that the market price of a portfolio company’s securities increases in response to any actions taken by portfolio companies. There can be no assurance that any of the foregoing will occur. Corporate governance strategies may prove ineffective for a variety of reasons, including: (i) opposition by the management or shareholders of the subject company, which may result in litigation and may erode, rather than increase, shareholder value; (ii) intervention of a governmental agency; (iii) efforts by the subject company to pursue a “defensive” strategy, including a merger with, or a friendly tender offer by, a company other than the offeror; (iv) market conditions resulting in material changes in securities prices; (v) the presence of corporate governance mechanisms such as staggered boards, poison pills and classes of stock with increased voting rights; and (vi) the necessity for compliance with applicable securities laws. In addition, opponents of a proposed corporate governance change may seek to involve regulatory agencies in investigating the transaction or the underlying portfolio and such regulatory agencies may independently investigate the participants in a transaction as to compliance with securities or other law. Furthermore, successful execution of a corporate governance strategy may depend on the active cooperation of shareholders and others with an interest in the subject company. Some shareholders may have interests which diverge significantly from those of the applicable underlying portfolio, and some of those parties may be indifferent to the proposed changes. Moreover, securities that the underlying manager believes are fundamentally undervalued or incorrectly valued may not ultimately be valued in the capital markets at prices and/or within the timeframe the underlying manager anticipates, even if a corporate governance strategy is successfully implemented. Even if the prices for a portfolio company’s securities have increased, no guarantee can be made that there will be sufficient liquidity in the markets to allow the applicable underlying portfolio to dispose of all or any of its holdings therein or to realize any increase in the price of such securities.

The Advisor may, on behalf of a Fund, pursue an activist investment strategy as a direct investment and initiate or pursue any of the actions or strategies set forth above. Global Macro Risks. The success of the underlying managers’ global macro investment strategy depends upon the managers’ ability to identify and exploit perceived fundamental, economic, financial and political imbalances that may exist in and among markets throughout the world. Identification and exploitation of such imbalances involves significant uncertainties. There can be no assurance that the managers will be able to locate investment opportunities or to exploit such imbalances. In the event that the theses regarding the underlying fund’s positions fail to be borne out in developments expected by the manager, substantial investment losses may occur. Foreign Securities. Underlying managers may invest in non-U.S. companies where the protections afforded by the laws of the U.S. do not apply. The Funds are subject to various risks inherent in investing in foreign companies, including fluctuations in currency exchange rates, exchange controls, expropriation, burdensome or confiscatory taxation, moratoria, or political or economic events, all of which could have an adverse effect on the Funds’ ability to generate gains. As the Funds determine their gains or losses in U.S. dollars (other than certain Funds), they will be subject to the risk of fluctuations in currency exchange rates between the local currency and dollars and to foreign exchange controls. There can be no assurance that the Funds would not incur losses as a result of adverse changes in currency exchange rates and foreign exchange controls. The Funds are unable to predict the nature of future exchange controls. The imposition of significant increases in the level of exchange controls or other restrictions could have an adverse effect on the Funds. Mortgage-Backed Securities. Price movements of residential and commercial mortgage-backed securities are influenced by, among other things, interest rates, housing price changes, unemployment, wage growth, availability and cost of credit, complexity of the assets and their associated legal documentation, loan level performance data, structuring models, and performance models, counterparty risk including, but not limited to, mortgage originators, mortgage servicers, mortgage insurance providers, and bond insurers, supply and demand in the housing market, changing supply and demand relationships for these assets, level of available leverage for these assets, trade, fiscal, monetary, regulatory and exchange control programs and policies of governments, and national and international political and economic events and policies. In addition, governments from time to time intervene, directly and by regulation, in the mortgage origination and RMBS markets. Such intervention often is intended directly to influence prices and may, together with other factors, materially impact asset prices in unpredictable ways or in a direction harmful to the performance of the Funds. Small and Medium Capitalization Companies. Certain managers may invest in the securities of companies with small- to medium-sized capitalizations. While the securities of such companies often provide significant potential for appreciation, smaller-capitalization securities involve higher risks in some respects than do investments in the securities of larger companies. For example, prices of small-capitalization and even medium-capitalization securities are often more volatile than prices of large-capitalization securities, and the risk of bankruptcy or insolvency of many smaller companies (with the attendant losses to investors) is higher than that for larger, “blue-chip” companies. In addition, due to thin trading in some small-capitalization securities, an investment in such securities may be relatively illiquid. Illiquid Portfolio Securities. To the extent that underlying managers invest in private securities or restricted securities, the valuation of such securities will be determined by the applicable manager, whose determination, despite the conflict to which the manager is subject when establishing such values, will be final and conclusive as to all parties. The value established may not reflect accurately the amount that could be realized if the securities were sold. Due to the lack of an established trading market it could take a significant amount of time to find a buyer or buyers for such securities, and such sale may be at a significant discount to the perceived value of the security.

Collateralized Debt Obligations. Underlying portfolios may invest in collateralized debt obligations (including without limitation collateralized loan obligations (“CLO”) and collateralized bond obligations (“CBO”)(collectively, “CDOs”). CDOs may be fixed pools or may be “market value” or managed pools of collateral which entitle the holders thereof to receive payments that depend primarily on the cash flow from the pool of assets, which may include commercial loans, high yield and investment grade debt, Structured Securities (as defined below) and derivative instruments relating to debt. Holders of CDOs bear various risks, including, among other risks, credit risk, liquidity risk, interest rate risk, market risk, operations risk, structural risk and legal risk. The debt securities issued by CDOs are typically separated into tranches representing different degrees of credit quality, with lower rated tranches of debt securities being subordinate to senior tranches. The senior tranches of debt securities of CDOs, which represent the highest credit quality in the pool, have the greatest collateralization and pay the lowest spreads over LIBOR. Lower rated CDO tranches represent lower degrees of credit quality and pay higher spreads over LIBOR to compensate for the attendant risks. The bottom tranches specifically receive the residual interest payments (i.e., money that is left over after the higher tiers have been paid) rather than a fixed interest rate. The returns on the junior tranches of CDOs are especially sensitive to the rate of defaults in the collateral pool. Structured Securities Generally. Underlying portfolios may invest in interests in securitization vehicles organized and operated solely for the purpose of restructuring the investment characteristics of other debt securities, mortgage-backed securities, CDOs, etc. (collectively, “Structured Securities”). This type of restructuring generally involves the deposit with or purchase by an entity, such as a corporation or trust, of specified instruments and the issuance by that entity of one or more classes of securities backed by, or representing interests in, the underlying instruments. The cash flow on the underlying instruments may be apportioned among the newly issued security to create securities with different investment characteristics such as varying maturities, payment priorities and interest rate provisions, and the extent of the payments made with respect to such securities is dependent on the extent of the cash flow on the underlying instruments. Certain classes of such securities may be subordinated to the right of payment of another class. Subordinated structured investments typically have higher yields and present greater risks than unsubordinated structured investments. Many Structured Securities are highly complex instruments and may be sensitive to changes in interest rates, prepayment rates or both. There is no guarantee that a liquid market will exist for any Structured Securities that an underlying portfolio may wish to sell. Credit Default Swaps. Certain underlying portfolios may enter into credit default swap agreements. The “buyer” in a credit default swap contract is obligated to pay the “seller” a periodic stream of payments over the term of the contract provided that no event of default on an underlying reference obligation has occurred (a “credit event”), in return for a contingent payment upon the occurrence of a credit event with respect to the underlying reference obligation. Generally, a credit event means bankruptcy, failure to pay, obligation acceleration or modification or restructuring. An underlying portfolio may be either the buyer or the seller in the transaction. As a seller, the underlying portfolio receives a fixed rate of income throughout the term of the contract, which typically is between one month and five years, provided that no credit event occurs. If a credit event occurs, the underlying portfolio, as seller, typically must pay the contingent payment to the buyer, which is typically the “par value” (full notional value) of the reference obligation. The contingent payment may be either a cash settlement or physical delivery of the reference obligation in return for payment of the face amount of the obligation. If an underlying portfolio is a buyer and no credit event occurs, the portfolio will lose its investment and recover nothing. However, if a credit event occurs, the underlying portfolio, as buyer, will receive the full notional value of the reference obligation that may have little or no value. Credit default swap agreements may involve greater risks than those associated with a direct investment by the underlying portfolio in the reference obligation. Credit default swap agreements are subject to general market risk, liquidity risk and credit risk. As noted above, if an underlying portfolio is a buyer and no credit

event occurs, it will lose its investment. In addition, the value of the reference obligation received by an underlying portfolio as a seller if a credit event occurs, coupled with the periodic payments previously received, may be less than the full notional value paid to the buyer, resulting in a loss of value to such underlying portfolio and the Fund. Short Selling. Certain of the underlying managers engage in short selling or selling securities they do not own. While short selling may be used for risk management or hedging purposes, as well as to create profit opportunities, there is substantial risk to this strategy because the manager may be required to cover its short positions (the purchase of the securities to replace those borrowed and delivered on sale) involuntarily or otherwise and there is no limitation on the potential upward movement of the purchase price. Short selling can also involve significant borrowing and other costs which can reduce the profit or create losses in particular positions. Options and Other Derivatives. One or more of the underlying managers may invest for speculative and/or risk management purposes in options, financial futures and/or other derivative instruments (collectively, “Derivatives”). The amount of leverage and volatility on Derivatives and, therefore, potential for gain and risk of loss may be substantially greater than that of the underlying asset. Derivatives may also be more volatile and less regulated than traditional debt and equity securities. Options trading entails an entirely distinct set of risks. Options positions may include both long positions, where the underlying portfolio is the holder of put (an option to sell a security at a specified price) or call (an option to buy a security at a specified price) options, as well as short positions, where the underlying portfolio is the seller (“writer”) of an option. Although option techniques can increase investment return, they can also involve a relatively higher level of risk. The expiration of unexercised long option positions effectively results in the loss of the entire cost or premium paid for the option. The writing or selling of an uncovered put or call option can involve, similar to short selling, a theoretically unlimited risk of an increase in the cost of selling or purchasing the underlying securities in the event of exercise of the option. Futures and Options on Futures. One or more of the underlying managers may invest in certain futures contracts, including stock index futures contracts, futures contracts on government securities, interest rates, foreign currencies, metals and energy products, and may trade options on such futures contracts, including purchasing call options, writing (selling) naked or covered call options and purchasing or selling put options on such futures contracts. The underlying managers may also purchase or sell options on securities and securities indices. In addition, they may enter into forward contracts, currency transactions and various swap and swap-like arrangements. Futures contracts markets are highly volatile and are influenced by a variety of factors, including national and international political and economic developments. In addition, because of the low margin deposits normally required in futures trading, a high degree of leverage is typical of a futures trading account. As a result, a relatively small price movement in a futures contract may result in substantial losses to the underlying portfolio. Moreover, futures positions are marked to market each day and variation margin payment must be paid to or by the underlying portfolio. Prior to exercise or expiration, a futures or option position can be terminated only by entering into an offsetting transaction. This requires a liquid secondary market on the exchange on which the original position was established. If a liquid secondary market does not exist for such futures or options, it might not be possible for the underlying portfolio to liquidate a position. No assurance can be given that an active market will exist for the contracts at any particular time. Certain futures exchanges do not permit trading in particular futures contracts at prices that represent a fluctuation in price during a single day's trading beyond certain set limits. If prices fluctuate during a single day's trading beyond those limits, the underlying manager could be prevented from promptly liquidating unfavorable positions and thus be subjected to substantial losses. In addition, the CFTC and various exchanges impose speculative position limits on the number of positions a person or group may hold or control in particular commodities. Unlike trading on domestic futures exchanges, trading on foreign futures exchanges is not regulated by the

CFTC and may be subject to greater risks than trading on domestic exchanges. For example, some foreign exchanges are principal markets so that no common clearing facility exists and a trader may look only to the broker for performance of the contract. In addition, unless the underlying portfolio hedges against fluctuations in the exchange rate between the U.S. dollar and the currencies in which trading is done on foreign exchanges, any profits that the underlying portfolio might realize in trading could be eliminated by adverse changes in the exchange rate, or the underlying portfolio could incur losses as a result of those changes. Use of other derivative instruments presents many of the same risks as those discussed above regarding futures contracts, including those risks relating to volatility, liquidity, hedging and foreign trading.

D.) Structural and Operational Risks Other Clients of Managers; Performance May Vary from Period to Period. Underlying managers generally make trading decisions on behalf of the underlying portfolios in which the Funds invest. These managers may also manage other accounts (including other funds and accounts in which the managers may have an interest) which, together with the Funds could increase the level of competition for the same trades, including the priorities of order entry. This could make it difficult to take or liquidate a position in a particular security. The managers and their principals may employ different trading methods, policies and strategies for different funds or accounts. Therefore, performance results for the Funds may differ from those of the other accounts traded by the same managers. As the funds under management by a particular manager increase, the manager may have increasing difficulty implementing an investment strategy which may have been successful in the past, or difficulty finding sufficient investment opportunities which are attractive. Alternatively, a manager who has been successful may limit the amount of capital it is willing to manage and may decline to accept an additional investment from the Funds. There can be no assurances that a manager’s future results will be similar to his or her past performance. Moreover, even where a manager has achieved excellent results over an extended period, because of cyclical movements and volatility, period to period results may differ materially. Due Diligence in Portfolio Manager Selection Process. The Advisor conducts due diligence which it believes is adequate to select managers with which to invest Fund assets. However, due diligence is not foolproof and may not uncover problems associated with a particular manager or its investment strategies. The Funds and the Advisor may rely upon representations made by hedge fund managers, accountants, attorneys, prime brokers and/or other investment professionals. If any such representations are misleading, incomplete, or false, the Advisor may select a manager that may otherwise have been eliminated from consideration had fully accurate and complete information been made available to the Funds. Similarly, the Advisor conducts ongoing due diligence in an effort to detect material changes in a manager’s personnel or operations which could be material to the Funds. However, such diligence may not be effective in identifying all material problems before they occur or promptly after they have occurred. In addition, although the Advisor intends to employ reasonable diligence in evaluating and monitoring managers, no amount of diligence can eliminate the possibility that one or more managers may engage in improper or fraudulent conduct, including unauthorized changes in investment strategy, misappropriation of assets and unsupportable valuations of portfolio securities. Risk Management. The sophistication of the risk management techniques employed by managers varies from manager to manager. However, even the most sophisticated risk management techniques cannot protect against loss in all circumstances. All risk management models are premised upon assumptions with respect to economic and political conditions, market sentiment, correlations among securities and other assets and other factors. The occurrence of an aberrational event not anticipated by a model can cause a portfolio to sustain a significant loss. Such events may include volatility in energy prices, sharp swings in interest rates or other factors.

Cybersecurity Risk. As part of its business, the Advisor processes, stores and transmits large amounts of electronic information, including information relating to the transactions of the Funds and personally identifiable information of investors. Similarly, service providers for the Advisor may process, store and transmit such information. The Advisor has procedures and systems in place that it believes are reasonably designed to protect such information and prevent data loss and security breaches. However, such measures cannot provide absolute security. The techniques used to obtain unauthorized access to data, disable or degrade service, or sabotage systems change frequently and may be difficult to detect for long periods of time. Hardware or software acquired from third parties may contain defects in design or manufacture or other problems that could unexpectedly compromise information security. Network connected services provided by third parties to the Advisor may be susceptible to compromise, leading to a breach of the Advisor's network. The Advisor's systems or facilities may be susceptible to employee error or malfeasance, government surveillance, or other security threats. On-line services provided by the Advisor to the investors may also be susceptible to compromise. Breach of the Advisor's information systems may cause information relating to the transactions of the Funds and personally identifiable information of the investors to be lost or improperly accessed, used or disclosed. The service providers of the Advisor are subject to the same electronic information security threats as the Advisor. 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 transactions for the Funds or personally identifiable information of investors may be lost or improperly accessed, used or disclosed. The loss or improper access, use or disclosure of the Advisor's or the Funds’ proprietary information may cause the Advisor or the Fund to suffer, among other things, financial loss, the disruption of its business, liability to third parties, regulatory intervention or reputational damage. Any of the foregoing events could have a material adverse effect on the Fund and the investors' investments therein. Risks Related to Electronic Communications. The Advisor, a Fund and/or the Fund’s administrator will provide to investors statements, reports and other communications relating to a Fund and/or the Interests/Shares in electronic form, such as e-mail or through the use of an electronic investor portal (“Electronic Communications”). The foregoing use of an electronic investor portal (despite being password protected) involves the risk that statements, reports and other communications relating to a Fund and/or the Interests/Shares may be stolen or otherwise obtained by unauthorized parties. In addition, Electronic Communications may be modified, corrupted, or contain viruses or malicious code, and may not be compatible with an investor’s electronic system. Furthermore, Electronic Communications may be intercepted, deleted or interfered with without the knowledge of the sender or the intended recipient. In addition, reliance on Electronic Communications involves the risk of inaccessibility, power outages or slowdowns for a variety of reasons. These periods of inaccessibility may delay or prevent receipt of reports or other information by the investors. Substantial Fees, Expenses and Incentive Compensation. By investing in the Funds, which in turn employ managers, an investor will, in effect, incur two forms of investment management services, namely, the services provided by the Advisor in identifying managers, performing due diligence and making investment decisions and the services provided by the managers in selecting investments on behalf of their portfolios. Managers will likely receive incentive based compensation or allocations from or with respect to the Funds’ investment in their portfolios. It is possible that, in any accounting period, one or more managers may receive incentive compensation even though a Fund as a whole suffers a loss. Incentive fees may encourage a manager to make riskier or more speculative investments than would be the case in the absence of such arrangements or to allocate investment opportunities to one underlying portfolio instead of another. Additionally, the fees and expenses of operating the Funds may be substantial. The Funds may incur fees and expenses including, without limitation, the fees and expenses set forth in Item 5 and the fee under the Services Agreement.

Non-Disclosure of Other Arrangements. One or more managers may, without notice to the Funds, enter into agreements with certain investors granting them, among other things, greater portfolio transparency, fee waivers or reductions, interests having different voting rights or restrictions, additional rights to reports and other information and other more favorable investment terms (including withdrawal rights) than the terms offered to the Funds. Such manager shall have no obligation to offer such additional rights, terms or conditions to all of its investors, including the Funds. Classes of Interests are not Separate Legal Entities. Other than as set forth in the offering documentation for a particular Fund, the Funds are single legal entities and creditors of a Fund may generally enforce claims against all assets of such Fund. In the unlikely event that the assets attributable to one Class of Interests were completely depleted by trading losses and a trading deficit remained, a creditor could enforce a claim against the assets of the other Classes. Effects of Substantial Withdrawals. Substantial withdrawals by investors at any one time could require the Funds to liquidate their positions more rapidly than otherwise would be desirable, which could adversely affect the value of both the Interests being withdrawn and the remaining Interests. In addition, this could make it more difficult for the Funds to generate profits or recoup losses, and could even cause the Funds to liquidate its positions prematurely. Potential Conflicts of Interest. There are several potential conflicts of interest between the Advisor and the Funds. Among those that should be considered are: Conflicts with Other Investment Entities or Clients. Mr. Hymowitz, as the Chief Executive Officer of EnTrust Global, will devote a substantial amount of time to the operations and management of other investment vehicles that have objectives similar to, or different from, any particular Fund. Senior management of the Advisor devotes such time to the business of the Funds as it deems necessary. However, additional clients or other business responsibilities at the Firm may have the effect of reducing the time devoted to the investment activities of any particular Fund. In addition to responsibilities with respect to the management and investment activities of any particular Fund or account, the Advisor will have similar responsibilities with respect to various other existing and future pooled investment vehicles. The existence of such multiple vehicles and accounts necessarily creates a number of potential conflicts of interest. Due to various fee schedules among the various Funds, the Advisor may be incentivized to favor one portfolio over another. From time to time, different Funds with different fee schedules may invest in similar products. The Advisor, Mr. Hymowitz and employees (or employees of the Advisor’s affiliates) may invest in one or more classes, tranches or series of the Funds (collectively, “Tranches”). In order to better align his interests with those of investors, Mr. Hymowitz has made substantial investments/commitments to certain of the Funds and may be the largest investor in a Tranche. While such investment may not represent a material portion of the total assets of the Fund, being the largest investor in the Tranche may create certain conflicts in the allocation of investment opportunities and other matters. The Advisor intends to mitigate any such conflict in a manner which is fair to and does not disadvantage other investors. The Advisor, Mr. Hymowitz and such employees also provide similar services to, or fulfill similar roles in respect of, other investment vehicles managed by the Advisor and its investment advisory affiliates (collectively, “EnTrust Global”). Accordingly, although it is anticipated that the Tranches and other investment vehicles will participate in investments that are appropriate for the particular Fund and such other investment vehicles on a pari-passu basis, other investment vehicles may produce investment results that are substantially different from those of a particular Fund. To the extent that other investment vehicles managed by EnTrust Global trade in similar markets and investments at or about the same time, these other investment vehicles may compete with the Tranches with respect to those investments. Investment opportunities will be allocated in accordance with the Fund’s and such investment vehicles’ respective investment objectives and strategies and the Advisor’s investment allocation policy (see Item 6). In accordance with such policy, there may be circumstances in which one or

more accounts or vehicles do not participate in particular investment opportunities on a pro rata basis with the Fund, or at all. In order to further align the interests of the Advisor with its investors, in June 2021 the Advisor formed EnTrust Global KE Fund LLC, a Delaware limited liability company (the “Employee Fund”), that serves as a vehicle through which investments are made by the Advisor’s eligible employees, alongside investment vehicles managed by the Advisor (including without limitation and as applicable, the Funds, the Blue Ocean Funds, Strategic Partnerships and investment vehicles which may be formed in the future (collectively, the “Clients”)). Employees who invest in the Employee Fund may otherwise select those investments in which they participate and are under no obligation to invest in every investment or any investment opportunities in which the Employee Fund participates. For purposes of the Advisor’s Investment Allocation Policy (See Item 6), the Employee Fund will be treated as a client in that target investment allocation percentages will be determined for the Employee Fund and Clients in parallel and Employee Fund participation in investments will not be conditioned on Clients first receiving their entire, targeted investment allocation. The Employee Fund will pay its pro rata share of all third party expenses related to each investment made by the Employee Fund but will not be subject to the Services Fee. As such, the Employee Fund will receive the benefit of services paid for by the Funds. In addition, Mr. Hymowitz and/or eligible employees may invest alongside the Clients in investment vehicles managed by underlying managers or directly in securities in which these investment vehicles invest (collectively, “Employee Investments”). Generally, such Employee Investments will only be made where the investment opportunity is also offered to Clients or where it is determined that Client participation in the investment is not appropriate, taking into account any applicable considerations. These arrangements present potential conflicts of interest in that the Employee Fund and Employee Investments could take a portion of investment opportunities that would otherwise belong to Clients or participate in such investment opportunities on more favorable terms. To mitigate these potential conflicts of interest, i) no such investments will be made where it is determined by the investment team members for that particular investment strategy that the investment is capacity-constrained at the time the investment opportunity is sourced, nor will the Employee Fund or any Employee Investments ii) take any position with respect to an underlying investment that is adverse to a Client’s position in such investment, including investing in a different part of the capital structure or taking a short position where a Client has a long position in the same security or vice versa or iii) make any such investment with knowledge or information, the possession of which would violate the Advisors’ compliance policies, or that is used exclusively to benefit the Employee Fund or Employee Investments. In addition, the Employee Fund will not participate in any investment on more favorable terms than Clients with respect to fees of third party managers or liquidity. Employee Investments will not incur fees incurred by the Employee Fund or Clients attributable to investment vehicles managed by underlying managers but will receive the benefit of services provided to Clients by underlying managers. Because employees have the ability to select the investments in which they will participate, either through the Employee Fund or as Employee Investments, there is a risk that employees will invest in only those investments in which they have the highest conviction. While this does not mean that each investment in which they invest will be successful, there is a risk that the investments made by employees will outperform the returns generated by Clients. The CCO or his designee, with the assistance of other colleagues as appropriate, will periodically review the Employee Fund’s investments and Employee Investments for compliance with the parameters set forth above and take appropriate action, if necessary, to ensure the furtherance of the objective to continue to align the interests of the Advisors and the Clients. Customized Arrangements. The Advisor provides advice to certain investors as part of a customized arrangement reflective of such investor’s particular objectives and overall profile. These investment vehicles established for such arrangements may or may not invest side-by-side (i.e., in parallel) with one or more of the Funds or accounts managed by the Advisor. The agreements entered into with such investors may grant rights not afforded to other investors. Such rights may include, without limitation, increased transparency (e.g., the right to receive reports on a more frequent basis or to receive reports that include information not

provided to other investors), the right to withdraw capital on a more frequent basis than other investors, the right to terminate the arrangement on short notice and such other rights as may be negotiated between the Advisor and such investor. In addition, the fees and expenses paid by such investors may be less than those paid by other investors in the Funds. Conflict with Portfolios Managed by a Client of the Advisor or its Affiliates. The Advisor, in its sole discretion, may invest the assets of the Funds in underlying portfolios in which clients of the Advisor or its affiliates are sponsors, or in which clients, principals or employees of the Advisor or its affiliates have a financial or investment interest. In such instance, the clients, principals or employees of the Advisor or its affiliates may directly or indirectly benefit from such financial or investment interest even though the Funds may never realize any gain from such underlying portfolio. Additionally, when the availability of an investment with a particular manager is limited, the Advisor may allocate such opportunity, among the Funds and other appropriate EnTrust Global investment vehicles or managed accounts, in such manner as the Advisor deems equitable to all parties. Conflicts Regarding Political and Charitable Contributions. Neither the Advisor nor its employees are permitted to make political contributions (subject to any exceptions granted by the CCO). The Advisor and/or its affiliates may make charitable contributions pursuant to requests by potential or existing investors or their representatives. Such contributions, while made for charitable or philanthropic purposes, have the potential to influence such investor’s or potential investor’s decision on whether the Advisor and/or its affiliates manage their assets, continue to manage their assets or the amount of assets managed by the Advisor and/or its affiliates as well as, in certain circumstances, the ability of prospective investors to invest in the Fund. Investors should consider this before investing in the Funds. Conflicts Regarding Timing of Investments. The Funds or other investment vehicles managed by the Advisor and/or its investment advisory affiliates may invest in the same underlying portfolio with respect to the same investment idea at different times, generally because of differences across such Funds/other investment vehicles in the availability of cash or the timeframe in which capital can be called from investors as set forth in the offering documentation. In such circumstances, the net asset value at which the particular Fund/other investment vehicle subscribes for an interest in the underlying portfolio may vary because of different net asset values of the underlying portfolio on different days or may reflect an average of the cost basis of subscribing to the underlying vehicle at different times. Conflicts Regarding Incentive-Based Compensation. Because certain investment personnel of the Advisor or its investment advisory affiliates will receive incentive-based compensation, investors and such personnel have a conflict of interest between their responsibility to manage a Fund for the benefit of investors and their interest in maximizing the compensation that the Advisor will receive. For example, carried interest to the Advisor or its investment advisory affiliates may create an incentive for the Advisor to engage in riskier or more speculative investments than might be the case if the Advisor, its affiliate or such personnel were compensated on a basis not tied to the performance of the Fund. Employee Loans. The Advisor has entered into loan agreements with several employees at each employee’s request and may make additional loans to one or more employees in the future. Such arrangements could present potential conflicts of interest if, for example, such employees, by virtue of their loan agreement, were then incentivized to recommend certain products to investors or to raise a certain amount of capital for the Funds/other investment vehicles managed by the Advisors. For each loan agreement, the term and interest rates were fixed and contractual terms relating to the repayment of principal, interest or otherwise are similar to “market standard” terms typically found in loan agreements of these types. Each loan agreement was funded by the Advisors’ capital and the repayment of the loans, either all or in part, have not been tied to job performance targets, such as whether any of these employees raised a certain amount of capital, achieved any targeted returns, generated a certain level of revenue for the Advisor or the Funds/other investment vehicles managed by the Advisors, or whether the employee remained employed by the Advisor for a specified time period. Any such loans may be made for recruiting

or retention purposes and the terms may vary depending upon the circumstances of the particular employee and the rationale for making the loan, although no loan amount is or will be in an amount material to the Advisors’ operations. E.) Regulatory Risks ERISA Plans and Tax-Exempt Entities. A tax-exempt entity may be subject to Federal and state laws, rules and regulations that regulate its participation, or its ability to engage directly or indirectly through an investment in the Funds, in investment strategies of the types which the Funds’ underlying portfolios may utilize from time to time. Tax exempt entities are encouraged to consult with their own advisers as to the advisability and tax consequences (and, if applicable, ERISA consequences) of an investment in the Funds. Trustees or administrators of ERISA entities, owners of individual retirement accounts and other tax-exempt or taxdeferred entities are urged to carefully review potential investments in the Funds. ERISA Compliance. The Funds may be subject to the fiduciary, prohibited transaction, reporting and disclosure rules of ERISA. Accordingly, to the extent required or otherwise deemed advisable by the Advisor, the Advisor intends to manage the assets of the Funds in accordance with these rules. Although the Advisor believes it to be unlikely, this may require the Advisor to forego, from time to time, investments or other arrangements on behalf of the Funds that might otherwise have been desirable for the Funds. In addition, the pool of available managers or investments may be limited which may in turn limit the Funds’ ability to invest in accordance with their investment objective and strategy. Consequences for Investors as a result of Automatic Exchange of Information (AEOI). “AEOI” means one or more of the following, as the context requires: 1. sections 1471 to 1474 of the US Internal Revenue Code of 1986, as amended, and any associated legislation, regulations or guidance, commonly referred to as the US Foreign Account Tax Compliance Act, the Common Reporting Standard (“CRS”) issued by the Organisation for Economic Cooperation and Development or similar legislation, regulations or guidance enacted in any other jurisdiction which seeks to implement equivalent tax reporting and/or withholding tax regimes; 2. any intergovernmental agreement, treaty or any other arrangement between the Cayman Islands and any of the US, the UK or any other jurisdiction (including between any government bodies in each relevant jurisdiction), entered into to facilitate, implement, comply with or supplement the legislation, regulations or guidance described in paragraph (1.); and 3. any legislation, regulations or guidance implemented in the Cayman Islands to give effect to the matters outlined in the preceding paragraphs. A Fund may take such action as it considers necessary in relation to an investor's holdings or redemption proceeds, as a result of relevant legislation and regulations, including but not limited to, disclosure by a Fund, the Fund’s administrator or such other service provider or delegate of a Fund, of certain information relating to an investor to the Cayman Islands Tax Information Authority or its delegate or equivalent authority and any other foreign government body as may be required by AEOI. Such information may include, without limitation, confidential information such as financial information concerning an investor's investment in the Fund, and any information relating to any investors, principals, partners, beneficial owners (direct or indirect) or controlling persons (direct or indirect) of such investor. A Fund may also compulsorily redeem any Interests/Shares held by an investor in accordance with the terms of the applicable Offering Memorandum and may deduct relevant amounts from a recalcitrant investor so that any withholding tax payable by the Fund or any related costs, debts, expenses, obligations or liabilities (whether internal or external to the Fund) are recovered from such investor(s) whose action or inaction (directly or indirectly) gave rise or contributed to such taxes, costs or liabilities. Failure by an investor to assist

the Fund in meeting its obligations pursuant to AEOI may therefore result in pecuniary loss to such investor. Rules and regulations similar to the above may apply to investors in Funds domiciled in other jurisdictions.

Item 9. Disciplinary information

There are no legal or disciplinary events believed to be material to a client’s evaluation of EnTrust Global.

Item 10. Other financial industry activities and affiliations

EnTrust Global is a global organization with affiliates regulated by the SEC, the U.K. Financial Conduct Authority (“FCA”), the Monetary Authority of Singapore, the Korean Financial Supervisory Commission, the French Authorité des Marchés Financiers, the Australian Securities and Investments Commission, and the Japan Financial Services Agency. In January 2020, EnTrust Global acquired a 25% interest (now 22.5%) in Alma Capital Management (“Alma”), a Luxembourg based and Commission de Surveillance du Secteur Financier regulated fund management company. The Advisor believes that this acquisition expands its ability to offer investors more liquid alternative strategies, including UCITS funds.

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As a large asset management firm, EnTrust Global, from time to time, provides information to various government agencies and regulators or responds to information requests, document requests, subpoenas, or requests for interviews from various government agencies and regulators. EnTrust Global Ltd. (“EGL”) is regulated by the FCA as a full service Alternative Investment Fund Manager (“AIFM”), holds an Australian Wholesale Client Exemption, and is authorized by the Central Bank of Ireland to serve as investment manager to Irish domiciled funds. EGL acts as investment manager to certain offshore products where Offshore is the sub-advisor. EGL may provide discretionary investment advisory services as investment manager to offshore private investment funds and may provide discretionary or non-discretionary advisory services in offering customized strategic alternative solutions through a multi-strategy fund of hedge funds platform or otherwise. EGL delegates day-to-day discretionary management for certain of its clients, including the EnTrust Global Funds, to the Advisor, which receives a percentage of EGL’s gross revenue with respect to these clients as a fee for its services. EGL incorporated a subsidiary, EnTGA Pty Ltd, in November 2021 which serves as a representative office of EGL for the purposes of business development in Australia and to act as EnTrust Global Ltd’s representative to market wholesale clients in the region. EnTrust Global SAS (“SAS”) is regulated by the French Authorité des Marchés Financiers, including full AIFM authorization. SAS may provide discretionary investment advisory services as investment manager to offshore private investment funds and may provide discretionary or non-discretionary advisory services in offering customized strategic alternative solutions through a multi-strategy fund of hedge funds platform or otherwise. SAS is under common control with the Advisor. EnTrust Global SAS Italia, a branch office of SAS, is based in Milan, Italy and focuses on business development in Europe. EnTrust Global SAS NUF, a branch office of SAS, is based in Oslo, Norway and focuses on the Blue Ocean strategy. EnTrust Global (Singapore) Pte. Ltd., regulated by the Monetary Authority of Singapore, provides regional business development support and is under common control with the Advisor. SaintCo Ltd., a Bahamian corporation and a subsidiary of EnTrust Global, provides directorship services for a fee to certain private investment funds in which certain investment vehicles managed by EnTrust Global invest and for which the Advisor serves as portfolio monitor. These portfolio monitoring services, for which the

Advisor is reimbursed for certain expenses, are provided in connection with the Permal Managed Account platform in which the investment vehicles are generally managed by unaffiliated third-party managers. In addition to responsibilities with respect to the management and investment activities of any particular Fund or account, senior management will have similar responsibilities with respect to various other existing and future pooled investment vehicles and separately managed accounts and will devote such time to the business of the Funds as is deemed necessary. However, additional clients or other business responsibilities at the Firm may have the effect of reducing the time devoted to the investment activities of any particular Fund. Refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss and Item 11 – Code of Ethics for a further discussion on potential conflicts of interest.

Item 11. Code of ethics, participation in client transactions and personal trading

The Advisor recognizes that, as a fiduciary, it must serve the interests of its clients. The Advisor further recognizes that it must adhere to the highest standard of care and diligence in conducting its business activities and must be particularly sensitive to situations in which the interests of its advisory clients may be directly or indirectly in conflict with those of the Advisor. Compliance obligations are a priority of the Advisor and, as such, the Advisor has adopted written policies and procedures in accordance with those standards.

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In addition, the Advisor has adopted a Code of Ethics intended to limit or mitigate potential conflicts of interest arising from ownership of securities by the Advisor’s employees that may also be purchased or sold for advisory clients (either directly or through an underlying portfolio). The Code of Ethics may generally be summarized as a “no trading” policy, although exceptions may be made if, in the discretion of the CCO, a proposed employee investment does not present a potential conflict of interest with the Fund’s investment activities or with the Advisor’s business activities, and is not otherwise problematic. The Code of Ethics also contains guidelines and reflects expectations regarding business entertainment, gifts and the standard of conduct required of employees. The Code of Ethics is based on the notion that the Advisor’s employees must act in the best interests of advisory clients and should avoid engaging in business activities, including making personal investments, that create or appear to create a conflict of interest, and is intended to prevent and detect such conflicts or potential conflicts of interest. The Code of Ethics generally prohibits employees of the Advisor from purchasing or selling securities on a discretionary basis for their own accounts, including all securities accounts in their own name and under their control or management. This does not include accounts that hold exclusively open-ended mutual funds, exchange traded funds or notes or government securities, Bitcoin/ Ethereum and other crypto coins or tokens or other accounts over which the employee has no direct or indirect investment discretion (nor does it include the Employee Fund- See Item 8). On a quarterly basis, employees submit to the CCO or his designee attestations to confirm that they are in compliance with the policy. In addition, employees are required to provide links to such accounts that hold any “reportable” securities and complete periodic reports listing their holdings and/or transactions. The CCO or his designee reviews such reports and information on a periodic basis. The CCO may also grant exceptions to the Code of Ethics and take appropriate corrective action with respect to any violations of the Code of Ethics. Notwithstanding the foregoing, the Advisor believes that it is important that employees invest in securities that the Advisor purchases for clients and, therefore, align their interests with and share in the same investment risks and benefits as clients. Accordingly, the Advisor permits eligible employees to invest in any of its Funds. Copies of the Code of Ethics are available upon request by contacting Bruce Kahne, Global General Counsel/CCO (tel. 212.224.5548). The Advisor may determine that it would be in the best interests of one Fund and one or more other Funds to transfer an investment from one account to another (each such transfer, a “Cross Trade”) for a variety of reasons, including, without limitation, tax purposes, liquidity purposes, to rebalance the portfolios of the Funds, or to reduce transaction costs that may arise in an open market transaction. If the Advisor decides to engage in a Cross-Trade, the Advisor will determine that the trade is in the best interests of both Funds involved and take steps to ensure that the transaction is permitted under all applicable laws and regulations and is consistent with the Advisor’s fiduciary duties. In an effort to avoid any potential conflicts of interest, employees of the Advisor are prohibited from using their position at the Advisor to give to or receive from any person or company that does business with the Advisor or that the employee hopes to do business with on behalf of the Advisor, including prospective

investors, their investment consultants or representatives, a gift, favor, special accommodation or similar item of value, so frequently or of such high value as to raise a question of impropriety. Gifts and business entertainment must be consistent with customary business practices and employees are instructed that care should be taken that the entertainment or gift does not appear to be intended to unduly influence the recipient in the exercise of his or her judgment and discretion. The Advisor maintains a hospitality suite at Madison Square Garden (“MSG”) for which it pays a set annual lease payment. While the lease of the suite was initially intended to help establish and maintain business relationships, use of the suite is often made by the Advisor and its employees, employee family members and friends. Unused tickets may be donated to charity or sold. Prospective investors, investors and/or investment consultants are subject to the rules and guidelines of their own organizations, if any, regarding business entertainment. It is the responsibility of each attendee at an MSG event or participant in another form of business entertainment, not the Advisor’s responsibility, to ensure compliance with such rules and guidelines including, for example, paying their own way if required. As a general matter, if an employee of the Advisor provides tickets to an MSG event or other form of business entertainment to persons with whom he or she has professional relationships, he or she should attempt to accompany the recipient of the tickets to the event with at least some reasonable frequency. The Advisor does not generally permit employees to make political contributions, although the CCO grants exceptions in certain circumstances. In addition to the policies described above, the Advisor has adopted and implemented written policies and procedures designed to prevent the misuse of material nonpublic information by the Advisor or persons associated with the Advisor (pursuant to Section 204A of the Advisers Act), as well as the intentional spreading of misinformation or rumors intended to influence the market price of a security. The Advisor’s Insider Trading Policy explains the concepts of an “insider” and “material, nonpublic information,” contains procedures for employees to evaluate the types of information received and requires employees immediately, and prior to affecting any trade or communicating such information, to notify the CCO. The Advisor’s policies and procedures regarding the making of political contributions, social media, and insider trading, among others, are reinforced in training sessions and by the execution of quarterly employee certifications confirming compliance with such policies and procedures. Violations of the Advisor’s Code of Ethics or other policies and procedures may be addressed by various corrective measures. The nature of the corrective action will depend on the severity of the violation committed, in the judgment of the CCO, senior management, the Compliance and Conflicts Committee and, as appropriate, outside counsel. Factors to be considered in determining the appropriate corrective action may include, but not be limited to, whether investors were harmed, whether the violation was intentional, whether the incident was isolated or part of a pattern, and recidivism on the part of the employee.

Item 12. Brokerage practices

For those Funds that invest in funds managed by underlying managers, the Advisor does not select brokerdealers to execute securities transactions. For Funds that may make direct investments in securities, including, but not limited to, the Blue Ocean Funds, the Opportunistic Credit Funds and EnOne Ventures, the Advisor will select broker-dealers. The CCO or his designee will periodically evaluate the nature and amount of such direct trading to determine the additional compliance obligations to be conducted regarding the necessary monitoring and oversight of such direct trading.

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To fulfill any applicable “best execution” obligation, the Advisor generally must execute securities transactions in such a manner that the clients’ total cost or proceeds in each transaction is the most favorable under the circumstances. In deciding what constitutes best execution, the determinative factor is not the lowest possible commission cost but whether the transaction represents the best qualitative execution. The Advisor’s direct investment business has traditionally been very limited, resulting in fewer potential options among brokers. In evaluating available options, the Advisor will take into account such relevant factors as price of the security, commission rate, the ability of the broker to handle the order, reliability and financial responsibility, confidentiality, the ability of the broker to handle execution of aggregated or volume orders and research and other services, if any, provided by such broker to the Advisor. Soft Dollars The Advisor’s current policy is not to use commissions generated by trading for client accounts to pay for third party research services. Brokerage for Client Referrals The Advisor does not use brokerage relationships for client referrals. However, the Advisor does have distribution relationships and placement agreements with broker-dealers as further discussed in Item 14 – Client Referrals and Other Compensation. Trade Errors To the extent the Advisors engage in direct trading, consistent with their fiduciary duties, the Advisors’ policy is to act with the utmost care in executing trades and allocating investments on behalf of investors. When an error is made on behalf of an investor account, the Advisors will attempt to ensure that the best interests of investors are served. The Advisors may from time to time inadvertently purchase, sell or allocate incorrectly an issue, class or number of securities. The Advisors will attempt to legally reverse or unwind trading errors in a fair and equitable manner as soon as practicable and place the account in the same position it would have been in had there been no error. Notwithstanding the foregoing, in order to achieve the goal of placing the account in the same position as it would have been in had there been no error, the Advisors may, in certain circumstances and in their discretion, utilize a different approach than as set forth above.

Item 13. Review of accounts

Review and Monitoring of Underlying Managers Mr. Hymowitz and the Advisor’s investment analysts monitor positions of underlying managers on a regular basis and contact managers frequently to discuss, among other things, strategy developments, market outlook and current thinking. Meetings are held periodically with managers as appropriate. One of the Advisor’s key investment criteria is transparency, and the Advisor’s investment team has established relationships with underlying managers such that there is ongoing communication concerning specific investment ideas, their market views/opinions and business issues in order to gain a better sense of their outlook regarding the general investment environment.

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The Advisor requires managers to comply, at a minimum, with regular, basic exposure requirements that portray an accurate snapshot of the portfolio. The Advisor typically receives performance updates from underlying managers on a monthly or quarterly basis, in addition to updates that are part of ongoing communication. Additionally, the Advisor generally (although not in all cases) receives exposure reports, risk management reports and a listing of the largest positions, both long and short and, where available, full position reports. The investment team reviews and analyzes this data and, in instances where there are divergences from customary trading, unusual position sizes, or types of securities, members of the investment team will speak with the underlying managers to understand the underlying reasons for them. The effects of any divergences are monitored closely and members of the investment team remain in direct contact with the managers. In addition, the Advisor takes a proactive approach to risk management and, has instituted extensive risk management procedures which pervade all aspects of the initial and ongoing due diligence process as it relates to the selection and monitoring of underlying managers, including through the activities of the operational due diligence team. The Advisor uses internally and externally developed systems to monitor risk on both the individual manager level as well as the fund of funds level. Model portfolios of managers and strategies are constructed within varying parameters, and these model portfolios are measured for correlations, risk and performance. The models are employed to analyze how the prospective fund would optimally impact the relevant portfolio vis-à-vis correlation, volatility and performance.

Investor Communications The Advisor strives to provide investors with a high level of transparency by generally providing a variety of communications on a timely basis. A summary of these communications (depending on the particular Fund, the timing and frequency of reports may vary) is set forth below: Performance Update - On a monthly or quarterly basis, depending on the Fund, investors receive a preliminary performance summary. NAV Statement - Additionally, the independent administrator(s) for the Funds sends a monthly NAV statement (quarterly for the Special Opportunities and Blue Ocean Funds) including the value of the Interests and account balance. Investor Summit - An Investor Summit meeting is generally held each year to give investors a chance to hear discussions regarding market views and investment strategies among various fund managers, other global financial industry participants and the Firm’s internal maritime, Opportunistic Credit and EnOne Ventures investment teams. Performance Summary - On a monthly or quarterly basis, depending on the Fund, investors receive a written performance summary, which may include, depending on the Fund, information such as detailed

performance and portfolio exposure information, including underlying manager allocations and strategy exposures. Market Developments Summaries – The Advisor provides investors with a written summary of newsworthy market developments as they occur and invites investors to ask questions concerning such developments. Such summaries were provided, for example, regarding newsworthy events such as the 2008 credit crisis, the 2020 global pandemic, President Trump’s imposition of tariffs in 2025 and the conflicts in Ukraine and Iran. Website - The Advisor also makes available to Fund investors and distributors certain information on a password-protected portion of its website (www.entrustglobal.com). This information generally includes: Funds’ monthly balances and monthly performance of the Funds and underlying investments, fund updates, and the like.

Item 14. Client referrals and other compensation

The Advisor has arrangements with third-party placement agents where the Advisor may compensate such agents for referring prospective investors to the Funds. Any such compensation is paid by the Advisor and not the Funds, the amount of which is negotiated by the Advisor. All such arrangements are memorialized in a written agreement subject to the prior review and approval of the CCO or his designee and in compliance with relevant anti-fraud requirements. The Advisor and/or its affiliates also have agreements in place with certain banks/financial intermediaries for the distribution of Funds domiciled outside the U.S. to investors (predominantly non-US) of such banks/financial intermediaries. This forms part of EnTrust Global’s global fund distribution network worldwide.

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Any compensation paid by EnTrust Global to these financial intermediaries is generally paid by the Advisor or its affiliates out of the investment management fee received from the Funds. The Advisor has also engaged third-party solicitors to market its services and such solicitors may receive a fee based on the average net asset value of a referred Investor’s account. Any such arrangement is disclosed to the relevant investor. The Advisor pays the solicitors’ fees directly and the investor is not subject to any increased or additional fees nor will the use of a solicitor, if any, be a factor in fee negotiations.

Item 15. Custody

The Advisor may be deemed to have custody of client assets as a result of serving as general partner or investment manager of the Funds and the Blue Ocean Funds. The Advisor generally complies with the custody requirements of the Advisers Act by providing GAAP-compliant audited financial statements for the Funds to their respective clients within the required time period following the end of the fiscal year. Additionally, SAS 99 requires auditors to plan and perform their audit to obtain reasonable assurances about whether the financial statements are free of material misstatements, whether caused by error or fraud. Investors in the Funds receive account statements directly from the independent administrator for those Funds.

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Investors should carefully review all account statements they receive. The Advisor may also be deemed to have custody of some or all the assets of clients if one or more of the following apply:    

the Advisor or an affiliate serves as managing member for client portfolios organized as an LLC; employees of the Advisor or an affiliate serve on the Board of Directors for client portfolios organized as corporate entities; clients are invested in special purpose funds; or employees of the Advisor or its affiliates are authorized to move cash to pay expenses or open accounts on behalf of the clients.

Assets of these Funds are custodied with an independent third-party custodian by registering the ownership of each underlying portfolio in which these Funds invest with the custodian for the benefit of these Funds.

Item 16. Investment discretion

The Advisor exercises investment discretion in managing the Funds, which relationship is established through offering documents, Strategic Partnership agreements, investment management agreements or equivalent documentation with respect to the relevant Fund. In exercising discretion, the Advisor will observe the investment policies, limitations and restrictions imposed by the relevant Fund. In the case of a Strategic Partnership, discretionary authority is set forth in the Strategic Partnership agreement, which the client may limit as set forth in that agreement. Under certain circumstances, the Advisor may only provide non-discretionary or advisory services to a client.

Item 17. Voting client securities

Proxy Voting

In providing investment advisory services to the Funds, the Advisor generally does not vote proxies with respect to the securities held by the underlying portfolios. Proxies are typically voted by underlying managers in accordance with their proxy voting policies. From time to time, the Advisor may receive requests for consent from underlying managers with respect to the underlying portfolios managed by such managers in which the Funds invest.

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All such requests are evaluated by the Global General Counsel or his designee, and outside counsel will be consulted as necessary, with respect to whether providing such consent: (i) is in the best interest of the Fund; and (ii) raises any potential conflict of interest with respect to the Advisor’s/Fund’s relationship with such underlying manager or portfolio. At all times, the Advisor will be guided by a determination based on the best interest of the Funds. The Advisor will view proposals as being in the best interests of the Fund and generally will vote in favor of proposals that:     

maintain or strengthen the shared interests of Fund investors and management of the underlying portfolio; increase shareholder value; maintain or increase shareholder influence over the underlying portfolio’s board of directors and management; maintain or increase the rights of shareholders generally; and allow the underlying manager to take advantage of investment opportunities believed to be attractive.

Votes generally will be cast against proposals having the opposite effect, or proposals that increase fees, restrict liquidity or increase risk in an inappropriate or unacceptable manner. With respect to Funds that make direct investments in securities and the Blue Ocean Funds, as applicable, the Advisor will also vote proxies guided by a determination based on the best interest of the Funds. The Advisor may elect to not vote on routine, non-contested matters when the costs (including indirect costs or restrictions) exceed the potential benefit of the vote. The Advisor will abstain from voting proxies when the Advisor believes it is appropriate. These procedures are designed to ensure that proxies are voted in an appropriate manner and should complement the Advisor’s policies and procedures. In exercising its voting discretion, the Advisor shall identify and avoid any direct or indirect conflict of interest raised by such voting decision and will resolve such conflicts before voting. Such conflicts of interest may result from any personal or business relationship between the Advisor, its employees or affiliates, and the underlying manager. In such circumstances, prior to voting, the Advisor will present the matter to the Compliance and Conflicts Committee for a determination. If the conflict is not material, the Committee may determine the manner in which the proxy is voted. In the case of a material conflict, the Committee may direct the Advisor to submit the matter to the Fund’s investors for a determination. If the investors consent or fail to respond within a reasonable time, the Advisor will vote the proxy as described above. If a majority of investors object to the Advisor’s proposed vote response, the proxy will be voted according to the investors’ direction. Alternatively, the Advisor may, in lieu of pass-through voting, elect to vote the interests held by the Fund in the same manner as other investors (i.e., in the same proportion as the “yes” and “no” votes provided by other investors in the underlying portfolios). In all cases, the Advisor will evaluate the facts and circumstances specific to the Funds before deciding whether and how to vote.

The Advisor will evaluate its proxy voting policy on an ongoing basis to determine whether any policy change is warranted.

Item 18. Financial information

The Advisor is not aware of any financial condition reasonably likely to impair its ability to meet contractual commitments to clients and has not been the subject of any bankruptcy petition.

Form ADV Part 2A, via the SEC Investment Adviser Public Disclosure site.