TSP Capital Management Group, LLC: investment adviser

As of December 31, 2025, TSP managed $547,703,886.78 on a discretionary basis and $5,607,397.58 on a non-discretionary basis.

General: TSP also has certain Clients that pay a flat annual investment management fee. Management fees charged for discretionary and non-discretionary management are negotiable. Fees are generally directly debited by TSP in advance at the beginning of each quarter based on the market value of the assets under management in the account as of the last day of the preceding quarter. At the request of a Client, TSP can invoice a Client for fees in lieu of direct debiting. TSP may group family household accounts for application of its management fee. Upon termination of an account, any prepaid unearned fees will be calculated based on the number of days the account was open during the quarter on the date of TSP’s receipt of written notification from the Client. Prepaid unearned fees shall be promptly refunded to the Client. Certain investments, such as mutual funds, may also bear their own fees and expenses, which are in addition to the advisory fees charged by TSP. Clients pay for all of their own operating expenses. This includes all custodial fees, brokerage and transaction costs, including commissions charged by the broker-dealer where the account is held, and all costs of administration of the managed account. Please see the Brokerages Practices section starting on Page 8 for a discussion of our brokerage practices. Clients should review all relevant documentation provided by such parties in connection with entering into a custodial arrangement with such third parties. Neither TSP nor any of its employees receives any compensation for the sale of securities or other

investment products.

Income requirements, tax considerations, and the Client’s overall investment objectives are important variables in determining the appropriate strategy for each account. Our core investments are publicly-traded equities and corporate debt securities which are rated investment grade. Investing in securities involves the risk of loss that Clients should be prepared to bear. Portfolio investments may be affected by force majeure events (i.e., events beyond the control of the party claiming that the event has occurred, including, without limitation, acts of God, fire, flood, earthquakes, outbreaks of an infectious disease, pandemic or any other serious public health concern, war, terrorism, labor strikes, major plant breakdowns, pipeline or electricity line ruptures, failure of technology, defective design and construction, accidents, demographic changes, government macroeconomic policies, social instability, etc.). Some force majeure events may adversely affect the ability of a party (including a portfolio investment or other service provider) to perform its obligations until it is able to remedy the force majeure event. Force majeure events that are incapable of or are too costly to cure may have a permanent adverse effect on portfolio investments. Certain force majeure events (such as war or an outbreak of an infectious disease) could have a broader negative impact on the world economy and international business activity generally, or in any of the countries in which TSP’s Clients may invest specifically. Prolonged

changes in climatic conditions may have a significant impact on the revenues, expenses and conditions of certain TSP Client investments. While the precise future effects of climate change are unknown, it is possible that climate change could affect precipitation levels, droughts, wind levels, annual sunshine, sea levels and the severity and frequency of storms and other severe weather events. These natural occurrences could cause certain portfolio investments and other service providers to incur expenses to prevent damages. Any of the foregoing may therefore adversely affect the performance of TSP Clients and their investments. TSP’s ability to source, manage and divest its investments and its ability to fulfill its investment objectives. As economies and financial markets worldwide become increasingly interconnected, the likelihood increases that geopolitical conflicts in one country or region will adversely impact markets or companies in other countries or regions, including in ways that are difficult to predict or foresee. The impacts of these conflicts or events can be exacerbated by failures of governments and societies to respond adequately to a geopolitical conflict and subsequent emerging events or threats. For example, local or regional armed conflicts have led to significant sanctions by the U.S., EU and other countries against certain countries and persons and companies connected with certain countries. Such armed conflicts and sanctions and other local or regional developments can exacerbate global supply and pricing issues, particularly those related to oil and gas, and result in other adverse developments and circumstances, as well as increased general uncertainty, for markets, economies, Portfolio Companies, businesses, and societies both globally and in specific jurisdictions. Although these types of conflicts have occurred and could also occur in the future, it is difficult to predict when similar conflicts affecting the U.S. or global financial markets and economies will occur, the effects of such events or conditions, potential retaliations in response to sanctions or similar actions, and the duration or ultimate impact of those conflicts. Any such conflicts could have a significant adverse impact on the operations, risk profile, and value of the Funds and their Portfolio Companies (including their underlying portfolio companies), with or without direct exposure to the specific geographies, markets, countries or persons involved in an armed conflict or subject to sanctions. Military actions in Ukraine, Gaza, Venezuela, and Iran have geopolitical uncertainty, including the risk of further conflict, civil unrest, sanctions changes, and disruption to regional energy and capital markets, may increase volatility in global financial markets and adversely affect economic conditions relevant to the Funds’ investments. The risk that an investment horizon is shortened because of an unforeseen event, for example, the loss of a job, which may force you to sell investments that you were expecting to hold for the long term. Investors may lose money if they must sell when the markets are down. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for retired people or those nearing retirement. TSP has adopted a business continuation strategy to maintain critical functions in the event of a partial or total building outage affecting our offices or a technical problem affecting applications, data centers or networks. The recovery strategies are designed to limit the impact on clients from any business interruption or disaster. Nevertheless, our ability to conduct business may be curtailed by a disruption in the infrastructure that supports TSP’s operations. In addition, our asset

management activities may be adversely impacted if certain service providers to TSP or its clients fail to perform. Further, with the increased use of technologies such as the Internet to conduct business, TSP and its Client accounts could be susceptible to operational, information security and related risks. A cybersecurity breach could expose TSP and its Client accounts to substantial costs (including, without limitation, those associated with forensic analysis of the origin and scope of the b reach, increased and upgraded cybersecurity, identity theft, unauthorized use of proprietary information, litigation, adverse investor reaction, the dissemination of confidential and proprietary information and reputational damage), civil liability as well as regulatory inquiry and/or action. In addition, any such breach could cause substantial withdrawals from a Client account. While TSP has established a business continuity plan in the event of, and risk management strategies, systems, policies and procedures to seek to prevent, cybersecurity breaches, there are inherent limitations in such plans, strategies, systems, policies and procedures including the possibility that certain risks have not been identified. Furthermore, TSP and its Client accounts cannot control the cybersecurity plans, strategies, systems, policies and procedures put in place by other service providers to the Client accounts and/or the issuers in which the Client accounts invest. In general, cyber incidents can result from deliberate attacks or unintentional events. Cyber security failures or breaches by a third-party service provider and the issuers of securities in which the portfolio invests, have the ability to cause disruptions and impact business operations, potentially resulting in financial losses, the inability to transact business, and violations of applicable privacy and other laws.

TSP has advised the Cameroon Fund from 2014 to June 2020, and, as is customary with the management of these types of private funds, had custody of the Cameroon Fund’s assets as defined under Rule 206(4)-2 (the “Custody Rule”) of the Investment Advisers Act of 1940, as amended (the “Advisers Act”). Generally, a federally registered investment adviser who has custody of client funds and securities must, among other things: (i) ensure that a qualified custodian maintains the client assets (with certain exceptions); (ii) notify the client in writing of accounts opened by the adviser at a qualified custodian on the client’s behalf; (iii) have a reasonable basis for believing that the qualified custodian sends account statements at least quarterly to clients (or investors in a client that is a pooled investment vehicle); and (iv) ensure that client funds and securities are verified by actual examination each year by an independent public accountant at a time chosen by the accountant without prior notice or announcement to the adviser.

The Custody Rule provides an exception to certain of the foregoing general requirements for a pooled investment vehicle, such as the Cameroon Fund, where such fund is subject to audit at least annually by an independent public accountant registered with the Public Company Accounting Oversight Board (“PCAOB”), and the adviser distributes the fund’s audited financial statements prepared in accordance with generally accepted accounting principles to all fund investors within 120 days of the end of the fund’s fiscal year (the “Audited Financials Alternative”). An investment adviser to a pooled investment vehicle that fails to meet the requirements of the Audited Financials Alternative would need to satisfy all of the requirements of the Custody Rule noted above in order to avoid violating the Custody Rule. With respect to the Cameroon Fund, TSP relied on the Audited Financials Alternative to attempt to comply with the Custody Rule for the years 2014 through 2018. TSP attempted to engage a PCAOB registered firm to audit the Cameroon Fund’s annual financial statements, but due to the nature of the agricultural assets of the Cameroon Fund and other extenuating circumstances, such as the political climate in Cameroon, TSP was unable to do so. The settlement finds that the 2014 and 2015 audits were delivered 686 days and 927 days late, respectively, and that TSP failed to procure audited financials for the Cameroon Fund from 2016 through 2018. Accordingly, the settlement finds that TSP did not satisfy the requirements of the Audited Financials Alternative in Rule 206(4)2(b)(4) for the Cameroon Fund for fiscal years 2014 through 2018 and was therefore obligated to comply with all of the requirements of the Custody Rule with respect to the Cameroon Fund during those years, which it also failed to do. TSP also notes that it has described these audit delays of the Cameroon Fund in its prior amendments to the Form ADV. The settlement with the SEC also finds that TSP failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and rules thereunder. While TSP’s written policies and procedures referenced the Custody Rule, TSP was aware of its obligations under the Custody Rule with respect to the Cameroon Fund, and TSP attempted to comply with the Custody Rule with respect to the Cameroon Fund, the settlement finds that TSP’s policies were not reasonably designed to prevent violations of the Custody Rule because TSP was unable to actually comply with the Custody Rule as described above. As part of the settlement, TSP has agreed to pay a $60,000 penalty, and accept a censure. The Cameroon Fund is no longer a TSP’s client since June 15, 2020.

Comply with applicable provisions of the federal securities laws;

Act with integrity, competence, diligence, respect, and in an ethical manner with the public, Clients, prospective Clients, employers, employees, colleagues in the investment profession, and other participants in the global capital markets;

Adhere to the fundamental standard that TSP and such employees, officers and members should not take inappropriate advantage of their position;

Avoid any actual or potential conflict of interest and implement procedures to mitigate such conflicts, including appropriate disclosures regarding such;

Conduct all personal securities transactions in a manner consistent with the Code of Ethics;

Use reasonable care and exercise independent professional judgment when conducting investment analysis, making investment recommendations, taking investment actions, and engaging in other professional activities;

Practice and encourage others to practice in a professional and ethical manner that will reflect credit on the employee and the profession;

Promote the integrity of, and uphold the rules governing, capital markets; and

Maintain and improve professional competence and strive to maintain and improve the competence of other investment professionals.

The Code of Ethics also requires employees, officers and members to, among other things: 1) preclear certain personal securities transactions; 2) report personal securities transactions on at least a quarterly basis; 3) provide TSP with a detailed summary of certain holdings (both initially upon commencement of employment and annually thereafter) over which such employees and members have a direct or indirect beneficial interest; and 4) report any violations of the Code of Ethics to TSP. TSP also serves as the adviser to an investment club in which the Senior Portfolio Managers of TSP, including TSP’s President, as well as certain advisory Clients, are members. As a result, TSP and its Senior Portfolio Manager and President may have a financial incentive to benefit the interests of the investment club. To mitigate this and any other potential conflicts of interest, TSP has

implemented policies and procedures to ensure investments are made in compliance with its fiduciary duties. To receive more information regarding and/or a copy of TSP's Code of Ethics, please call (908) 273-2105 and ask for either Thomas Paluck or Barbara Klepper.

TSP has negotiated a commission schedule with Fidelity for trades and/or allocations placed electronically using Fidelity Advisor CHANNEL®, as well as manually through a representative on Fidelity’s trading desk. In addition to brokerage services, Fidelity provides TSP’s Clients with custodial and record-keeping services that TSP believes are valuable to the management of Client accounts. TSP may have an incentive to recommend Fidelity based on its interest in receiving research or other products and services, rather than on Clients’ interest in receiving most favorable execution. As a result of Client’s brokerage and custodial arrangement with Fidelity, TSP may, in its discretion, cause Clients to pay transaction costs to Fidelity that are greater than the transaction costs that another qualified broker(s) might charge to effect the same transactions. TSP reviews its brokerage relationship with Fidelity on a periodic and systematic basis to ensure that it is fulfilling its fiduciary duty to seek best execution on Client transactions. TSP does not currently maintain any formal soft dollar arrangements. However, Fidelity provides TSP with research and other products and services (i.e., receipt of duplicate trade confirmations and account statements, trading desk access, the ability to aggregate Clients’ securities transactions, the ability to directly debit advisory fees from Clients’ accounts, and receipt of compliance publications). TSP has determined that it would obtain Fidelity’s research and other products and services regardless of the amount of commissions it generates throughout the year. Therefore, TSP does not believe it is “paying-up” for third-party research, and economic, industry or sector specific research which Fidelity provides to TSP. With respect to a Client that has instructed TSP to utilize a particular broker or dealer other than Fidelity to execute some or all transactions for such Client's account, the Client is responsible for negotiating the terms and arrangements for the account with that broker or dealer. TSP will not seek better execution services or prices from other broker-dealers or be able to aggregate such Client's transactions, for execution through other brokers or dealers, with orders for other accounts advised or managed by TSP. As a result, TSP may not obtain best execution on behalf of the Client, who may pay materially disparate commissions, greater spreads or other transaction costs, or receive less favorable net prices on transactions for the account than would otherwise be the case.

Trade Aggregation and Allocation Policies Transactions for each Client account generally will be effected independently at the direction of each of the Portfolio Managers, unless TSP decides to purchase or sell the same securities for a number of Client accounts simultaneously. If all Portfolio Managers communicate before a trade for their respective Clients and decide to purchase or sell the same securities for the Clients simultaneously, the orders for the same security will be combined or “batched” subject to the aggregation being in the best interests of all participating Clients, to facilitate best execution, and to allocate equitably among TSP’s Clients differences in prices that might have been obtained had such orders been placed independently. TSP effects batched transactions in a manner designed to ensure that no participating Client, including any account in which a related person or affiliate of TSP has a financial interest, is favored over any other Client. Specifically, each Client that participates in a batched transaction will participate at the average share price for all of TSP’s transactions in that security on that business day, with respect to that batched order, and pay commissions and ticket charges (if applicable) based upon the individual Client(s)’ commission schedule. Securities purchased or sold in a batched transaction are allocated pro-rata, when possible, to the participating Client accounts in proportion to the size of the order placed for each account. TSP may, however, increase or decrease the amount of securities allocated to each account if necessary to avoid holding odd-lot or small numbers of shares for particular Clients. Additionally, if TSP is unable to fully execute a batched transaction and TSP determines that it would be impractical to allocate a small number of securities among the accounts participating in the transaction on a pro-rata basis, TSP may allocate such securities in a manner determined in good faith to be a reasonable and fair allocation. Notwithstanding the foregoing, TSP is not obligated to, and may not aggregate securities sale and purchase orders for several reasons, including that it may not believe that such trades are advantageous for Clients, brokers may limit TSP’s ability to place aggregate orders, and directed brokerage arrangements may preclude it from aggregating orders. In any event, not aggregating securities purchase and sale orders may or may not have a negative net price impact on the overall execution of the order. TSP’s allocation procedures seek to allocate investment opportunities among Clients in the fairest possible way taking into account Clients’ best interests. In no case shall allocations involve a practice of favoring or discriminating against any Client or group of Clients. Cross Transactions and Trade Errors Upon occasion, and in accordance with its duty to seek best execution on its Clients’ transactions, TSP may cross trades for eligible Client accounts. A cross trade occurs when TSP purchases and sells a particular security between two or more accounts under its management. These cross transactions are typically done for year-end tax loss selling purposes and only when TSP has determined that such transaction is advantageous and in the best interest of each participating Client. In no instance does TSP receive additional compensation when crossing trades for Client accounts. TSP has internal controls in place to prevent trade errors from occurring. On those occasions when such an error nonetheless occurs, TSP will use reasonable efforts to correct the error as soon as possible. The goal of error correction is to make the client “whole,” and errors are regardless of the

cost to TSP. TSP will maintain a record of each trade error, including information about the trade and how such error was corrected.

Should TSP inadvertently receive proxy information for a security held in the Client’s account, TSP will immediately forward such information on to the Client, but will not take any further action with respect to the voting of such proxy. Upon termination of a Client relationship, TSP shall make a good faith and reasonable attempt to forward proxy information inadvertently received by TSP on behalf of the Client to the forwarding address provided by the Client to TSP. TSP will not be responsible for determining Clients’ participation in class action lawsuits against issuers, as this decision will be reserved solely for the Client. The Client is encouraged to seek adequate legal counsel, as the decision to participate in the class action may preclude other rights. Clients are required to instruct their custodian that TSP should not be designated as the party to receive information on these class action lawsuits. Should TSP inadvertently receive such information for a security held in the Client’s account, TSP will forward such information on to the Client. To the extent TSP considers Clients’ participation in a class action lawsuit to be beneficial and the time required of TSP employees to prepare the claim is reasonable, the Company may participate in class actions when approval is obtained from each Client. Upon termination of the advisory relationship, the Company will make a good faith and reasonable attempt to forward such information inadvertently received by the Company on behalf of the Client to the forwarding address provided to the Company by the Client, if any.