Consilium Investment Management LLC: investment adviser

Investor funds are deposited in either a brokerage firm or a bank custodian account. Consilium may also serve as manager for special purpose vehicles and act as a sub-adviser to assist or manage client portfolios. As of May 29, 2026, Consilium managed approximately $540,599,925 in client assets on a discretionary basis. This amount includes approximately $85,706,157 in assets of two exchange-traded funds for which the Firm serves as investment sub-adviser. CFP I Holdings, LLC, a strategy that invested solely in commercial real estate, separately holds approximately $885,454 in cash reserves maintained pursuant to contractual obligations relating to pending litigation; this amount is not included in the Firm’s regulatory assets under management. All real estate assets held by CFP I Holdings have been liquidated; no investment activity is ongoing, and the remaining cash balance is expected to be distributed to investors upon resolution of the related litigation. No advisory fees are charged or accrued on this account. Class B Business Lines — Sophus Capital Strategies Effective March 2026, the Firm expanded its investment platform to include Global Emerging Markets (“GEM”) and Emerging Markets Small Cap (“EMSC”) equity strategies. These strategies are managed by portfolio management personnel provided to the Firm by Sophus Capital LLC (“Sophus”), a Delaware limited liability company that is a Class B Member of the Firm’s operating company. Sophus’s personnel who exercise discretionary investment authority serve as supervised persons of the Firm under the Investment Advisers Act of 1940 and are subject to the direct supervisory authority of the Firm’s Chief Compliance Officer. The Firm markets the GEM and EMSC strategies under the “Sophus Capital” brand pursuant to a royalty-free trademark license from Sophus. The Firm may offer these strategies through exchangetraded funds (as investment sub-adviser to a primary ETF adviser), separately managed accounts, private funds, or other product structures. Regardless of the product structure, the Firm retains full investment advisory authority and regulatory responsibility for all client accounts and products managed under the Sophus Capital strategies. The Firm makes use of non-discretionary research personnel from two sources. The Firm engages research consultants based in India directly, through AI Investment Managers LLP, who provide investment research and analysis to the Firm across its strategies. In addition, Sophus provides research personnel based in the United Kingdom, Hong Kong, and Singapore who support the GEM and EMSC strategies under a research services agreement. In all cases, these research personnel provide non-discretionary research and analysis only; they do not exercise discretionary investment authority, do not execute or direct trades, and do not have direct client contact. All

discretionary investment decisions are made by the Firm’s portfolio management supervised persons. The GEM and EMSC strategies commenced managing client assets in May 2026. The Firm serves as investment sub-adviser to two exchange-traded funds advised by Empowered Funds, LLC (d/b/a ETF Architect) and issued through the EA Series Trust: the Sophus Capital Emerging Market ETF (ticker: EMEM), which commenced trading on May 20, 2026, and the Sophus Capital Emerging Market Small Cap ETF (ticker: EMSC), which commenced trading on May 21, 2026.

The performance fee is 20% over a specified hurdle rate, and it is paid yearly in arrears. Expenses of the strategy are paid by the investor, including brokerage fees, custody fees and other expenses. The strategy is not open to new investors. Consilium Concentrated GEM SMA Equity Strategy. The Consilium Concentrated GEM SMA Equity Strategy seeks capital appreciation through investments in Global Emerging Market securities. The investment management fee for our Concentrated GEM SMA Strategy is .80% of all assets, annually. The strategy is currently offered only as a separately managed account with a minimum size of USD$ 25 million. Expenses of the strategy are paid by the client, including brokerage fees, custody fees and other operational expenses. CFP I Holdings, LLC. CFP I Holdings, LLC is a Delaware limited liability company that previously pursued a commercial real estate investment strategy. All real estate assets have been liquidated. Approximately $885,454 in cash reserves is maintained pursuant to contractual obligations relating to pending litigation. No advisory fees are charged or accrued on this account. The strategy is closed to new investors.

NOTE: Investors should refer to each Fund’s Offering Memorandum, Subscription Agreements and other offering documents for addition/supplementary information regarding the Funds as well as the fees and expenses paid by the Funds. Consilium reserves the right to negotiate fees and investment minimums.

Equity securities, including exchange-listed securities, securities traded over-the-counter and foreign issues

Corporate debt securities (other than commercial paper)

United States government securities

Option contracts on securities

Limited partnership interests

Private investment funds

Futures contracts

Derivatives contracts

Consilium trades and invests principally, but not solely, in debt and equity securities that are traded in non–U.S. and U.S. public markets. When deemed appropriate, Consilium also invests in options, bonds, convertible debt, preferred stock, swaps (including, but not limited to, interest rate swaps, variance swaps, volatility swaps, commodity swaps, credit default swaps, asset swaps, total return swaps, equity swaps including baskets and emerging markets swaps, variations on any of the foregoing and any other type of over-the-counter instrument), notes, bills, warrants, futures, rights, derivatives, non–U.S. currencies, restricted securities, fixed-income assets and other securities or assets.

Long-term purchases (securities held at least a year) Short-term purchases (securities sold within a year) Exchange-traded and OTC derivatives, including interest rate, currency and equity swaps; interest rate caps, collars and floors; equity and currency options; futures and options on futures; forward foreign currency exchange contracts; capped, inverse, dual index and range floaters; and structured notes

Consilium’s Investment Strategies: Consilium’s current investment universe consists of the global markets, including emerging, frontier and developed markets. Each strategy seeks to control various types of risk through the application of certain guidelines. These limitations represent guidelines measured at the time of investment and, accordingly, each Portfolio may not be within these limits at all times due to changes in the values of its investments and the underlying capital of the Portfolio. In the event that the specific Portfolio exceeds a specified target, the Manager will seek to bring the Fund back with the limitations within a reasonable time subject to market conditions. In addition, in some portfolios, typically the Manager may exceed these guidelines if it believes conditions warrant, and certain guidelines may be subject to change by the Manager immediately upon notice to Shareholders. The following are examples of investment guidelines that seek to control risk within the various portfolios. •

Exposure to any one security will generally be limited to a percentage of the overall portfolio/strategy;

•

Exposure to any one country will generally be limited to a percentage of the overall portfolio/strategy; Exposure to any one industry will generally be limited to a percentage of the overall portfolio/strategy;

•

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•

Gross equity issuer concentration limit will be a specific percentage and debt issuer concentration limit will be a certain percentage of overall capital; and

These general risk guidelines, and/or any portion thereof, may be employed to one or more of the above-listed portfolio products as relevant and necessary. Other additional risk guidelines may be developed and implemented as necessary. These are general limits and may be tailored to a meet a specific mandate. Note: All investments involve the risk of loss, including (among other things) loss of principal, a reduction in earnings (including interest, dividends and other distributions), and the loss of future earnings. These risks include market risk, interest rate risk, issuer risk, and general economic risk. Although we manage the assets in a manner consistent with risk tolerances, there can be no guarantee that our efforts will be successful. The investor should be prepared to bear the risk of loss.

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The litigation relates solely to those real estate transactions and does not arise from CIM’s investment advisory business or its management of client assets. The court granted Easterly’s request for specific performance and ordered the parties to close the real estate transaction in March 2021, which was completed. There have been no findings of liability against CIM or any other defendant on any remaining claim. In January 2023, Easterly filed an amended complaint adding Consilium Investment Capital, Inc., CFP I Holdings, LLC, and Charles T. Cassel III as additional defendants and asserting additional claims. The court subsequently dismissed Easterly’s claims for tortious interference and civil conspiracy against CIM in April 2023, narrowing the claims remaining against CIM to those arising from the original Purchase and Sale Agreement. The defendants filed their answers to the amended complaint in June 2025. Easterly’s claims against two South Korean defendants were dismissed for lack of personal jurisdiction, and Easterly’s appeal of that dismissal was voluntarily dismissed by joint stipulation of all parties in October 2025. No depositions have been taken and no trial date has been set. Easterly is seeking damages for lost income, attorneys’ fees, and other relief. No finding of fraud or other liability has been made against CIM or any other defendant. CIM intends to defend the remaining claims vigorously and believes it has meritorious defenses. The outcome of this litigation cannot be predicted with certainty at this time. CIM does not believe this matter will impair its ability to meet its contractual and fiduciary obligations to its clients. Clients and prospective clients with questions about this matter are encouraged to contact the Compliance Department at compliance@consimllc.com.

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Other Financial Affiliations FUSE Holdings Cross-Reference In October 2025, CSLM Acquisition Corp completed its business combination with Fusemachines, Inc. (NASDAQ: FUSE). The Firm’s principals hold interests in FUSE. Please refer to Item 11 for a full description of the conflict of interest arising from FUSE holdings across client funds and principals’ personal accounts. Affiliation with Sophus Capital LLC Sophus Capital LLC (“Sophus”) is a Delaware limited liability company that serves as the Class B Member of the Firm’s operating company pursuant to an Amended and Restated Operating Agreement effective March 1, 2026. The sole member of Sophus is Michael Reynal, who also serves as Chief Investment Officer for the Global Emerging Markets (“GEM”) strategy and as one of three Managers of the Firm’s operating company. The Firm’s operating agreement establishes a dual-class membership structure. The Class A Member, Consilium Investment Capital, Inc. (controlled by Jonathan Binder), holds all capital interests in the Firm. Sophus holds a Class B profits interest that entitles it to participate in profits attributable to the GEM and EMSC strategies in accordance with the operating agreement. Sophus made no capital contribution and has no interest in the Firm’s capital. Sophus provides portfolio management personnel to the Firm under a Personnel Services Agreement and non-discretionary research personnel under a Research Services Agreement. Portfolio management personnel exercise discretionary investment authority over client accounts and serve as supervised persons of the Firm. Research personnel provide non-discretionary research inputs and do not exercise investment discretion. The Firm’s Chief Compliance Officer has direct supervisory authority over all Sophus personnel providing services to the Firm. The Firm operates the GEM and EMSC strategies under the “Sophus Capital” brand pursuant to a royalty-free trademark license from Sophus. Sophus is not a registered investment adviser and does not independently provide investment advisory services to the public. If the Firm offers the GEM or EMSC strategies through exchange-traded fund (“ETF”) products, the Firm would serve as investment sub-adviser to a primary ETF adviser. The primary ETF adviser relationship currently contemplated is with Empowered Funds, LLC (d/b/a ETF Architect), through the EA Series Trust. In such an arrangement, the Firm’s portfolio management personnel would make all investment decisions and generate trade instructions, while the primary ETF adviser would be

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responsible for trade execution, fund operations, and regulatory compliance at the fund level. The Firm would retain supervisory oversight of the investment decision-making process. SPAC Board and Sponsor Interests Charles T. Cassel, III, the Firm’s Chief Executive Officer and Chief Compliance Officer, serves as a non-officer director of CSLM Digital Acquisition Corp III, Ltd. (“CSLM Digital”), a special purpose acquisition company whose shares trade on the Nasdaq Stock Market under the ticker symbol KOYN. Mr. Cassel previously served as a non-officer director of CSLM Digital’s sponsor, CSLM Acquisition Sponsor II, Ltd. (the “Sponsor”), from July 26, 2024 until his resignation on November 25, 2025. Mr. Cassel holds no officer position with either entity. Consilium Investment Capital, Inc. (“CIC”), which is the sole Class A Member of the Firm’s operating company and is co-owned by Jonathan Binder and Charles Cassel, holds approximately 4% of the Class A shares, 0.174% of the Class B shares, and 49% of the Class C shares of the Sponsor. These interests were acquired in connection with the Sponsor’s formation and are not held through the Firm or any client account.

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While it is impossible to define all situations which might pose a risk of securities laws violations or create conflicts, this Code is designed to address those circumstances where such concerns are most likely to arise. By complying with the guidelines below, the firm's employees can minimize their and the firm's potential exposure to violations of securities laws, prevent fraudulent activity and reinforce fiduciary principles. Failure to comply with the provisions of this Code is a ground for disciplinary action, including discharge, by the firm. Adherence to the Code is considered a basic condition of employment with the firm. If any employee has any doubt as to the propriety of any activity, they are instructed to consult with the firm’s Chief Compliance Officer (“CCO”), Charles T. Cassel III. A copy of this Code and any amendments will be provided to each supervised person (as defined in the Investment Advisers Act of 1940) and employee of Consilium. Each person must acknowledge in writing the receipt of these copies. A “supervised person” means any partner, Officer, director (or other person occupying a similar status or performing similar functions), or employee of an investment adviser, or other person who provides investment advice on behalf of the investment adviser and is subject to the supervision and control of the investment adviser received the materials. Annually, each supervised person/employee must certify that he or she complied with the Code of Ethics during that period. Clients and prospective Clients can obtain a copy of Consilium’ Code of Ethics by contacting Victor Maldonado at Compliance@consimllc.com. Other Conflicts of Interest Directors, officers and employees have a duty to act in the best interests of the Company and its shareholders at all times. As part of this duty, directors, officers and employees are prohibited from engaging in any transaction which involves an improper conflict of interest. A “conflict of interest” exists when a person’s private interests interfere in any way with the interests of the Company. A conflict situation can arise when a director, officer or employee takes actions or has interests that make it difficult to perform his or her Company work objectively and effectively. Conflicts of interest also arise when a director, officer or employee, or members of his or her family, receives improper personal benefits as a result of his or her position in the Company. Loans to, or

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guarantees of obligations of, employees and their family members can create conflicts of interest. It is almost always a conflict of interest for a Company employee to work simultaneously for a competitor, customer or supplier. Employees are not allowed to work for a competitor as a consultant or board member. The firm’s policy is to avoid any direct or indirect business connection with our customers, suppliers or competitors, except on our behalf. Conflicts of interest are prohibited as a matter of Company policy, unless they have been approved by the Company. Wherever a conflict of interest arises, the person involved must promptly disclose the circumstances of the conflict to the Chief Compliance Officer. Except as otherwise disclosed in this Brochure — including the conflicts described below with respect to FUSE/Fusemachines and the Firm’s affiliated special purpose acquisition company interests — Consilium does not recommend that Clients buy or sell securities in which the Firm has a financial interest, and does not buy or sell for its own account securities that it also recommends to Clients. In October 2025, CSLM Acquisition Corp (formerly Consilium Acquisition Corp I), a special purpose acquisition company sponsored by Consilium Investment Capital, Inc. and Consilium Extended Opportunities Fund, LP, completed a business combination with Fusemachines, Inc. (NASDAQ: FUSE). Upon closing of the transaction, the SPAC sponsor entity was dissolved and the shares of FUSE previously held by the sponsor were distributed directly to Jonathan Binder, Charles Cassel, and the Consilium Extended Opportunities Fund, LP. As a result, the Consilium Frontier Equity Fund, LP holds shares of FUSE as a portfolio investment (having participated in a private investment in public equity (“PIPE”) financing at the time of the business combination), and the Consilium Extended Opportunities Fund, LP holds shares of FUSE in a side pocket. A “side pocket” is a separate account within a fund used to segregate illiquid or hardto-value investments from the fund’s main portfolio, typically so that the illiquid investment can be valued and redeemed independently of the fund’s liquid positions. In addition, Mr. Binder and Mr. Cassel each hold shares of FUSE in their personal accounts. Neither principal holds a board seat or any operational or management role at Fusemachines following the completion of the merger; their holdings are purely passive. A conflict of interest exists because investment decisions regarding FUSE — including the timing and sizing of any disposition — affect both client fund accounts and the personal accounts of the Firm’s principals simultaneously. The Frontier Equity Fund’s FUSE shares, acquired through a PIPE financing, are freely tradeable and are not subject to lockup restrictions. The Extended Opportunities Fund’s FUSE shares, received upon dissolution of the SPAC sponsor entity, are held in a side pocket and are subject to a contractual lockup expiring in October 2026; a liquidity discount is applied to these shares for valuation purposes. The Firm addresses this conflict through its personal trading preclearance policy, which requires that any transaction in FUSE in a principal’s personal account be preapproved by the Chief Compliance Officer. Where the transaction involves the CCO personally, approval must be obtained from the Chief Investment Officer. Pre-clearance approvals are valid for five business days. Personal account transactions in FUSE will not be executed in advance of, or on more favorable terms than, corresponding fund transactions. In the future, if the Firm’s principals, the Firm, or any affiliated entity participates in, sponsors, or otherwise has a financial interest in a special purpose acquisition company or similar vehicle, and a Consilium fund or advisory client invests in or alongside such vehicle, the same types of conflicts

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described above could arise. The Firm will apply similar pre-clearance controls and disclosure obligations to any such future transactions. Conflicts of Interest Arising from the Dual-Class Operating Structure (Sophus Capital) Profit Allocation Between Business Lines. The Firm’s operating agreement allocates revenue and expenses between Class A Business Lines (Frontier Emerging Markets, Concentrated GEM SMA) and Class B Business Lines (GEM and EMSC). Certain overhead expenses are shared between the two classes pursuant to a formula-based allocation. The Firm’s principals have economic interests on both sides of this allocation: Jonathan Binder and Charles Cassel control the Class A Member, while Michael Reynal controls the Class B Member. Decisions regarding shared resource utilization, expense classification, and revenue attribution may affect the relative economic interests of both classes. The Firm addresses this conflict through its three-Manager governance structure, which requires unanimous approval for new shared expenses and budget matters, and through the oversight of the Chief Compliance Officer. Portfolio Management Personnel Compensation. The portfolio managers responsible for the GEM and EMSC strategies (Michael Reynal and Maria Lucia Freund) are compensated exclusively through Sophus’s share of Class B profits, not through direct compensation from the Firm. This arrangement means their personal economic interest is aligned with the performance and growth of the Class B strategies. Where a research idea, investment opportunity, or operational resource could benefit both Class A and Class B mandates, the portfolio managers for the Class B strategies may face a conflict between the interests of Class B clients and those of Class A clients. The Firm addresses this conflict through the supervisory authority of the Chief Compliance Officer, pre-trade compliance controls, the Firm’s Code of Ethics, and trade allocation procedures designed to ensure fair treatment of all clients. Overlapping Investment Universes. The Firm’s Class A and Class B strategies may invest in the same or similar emerging market equity securities. Where both classes have a concurrent interest in a particular security, trade allocation and execution sequencing decisions could theoretically favor one class over another. The Firm maintains trade allocation procedures designed to ensure that investment opportunities and trade executions are allocated fairly and equitably among all client accounts, regardless of business line classification. The Chief Compliance Officer monitors trade allocation patterns and reviews for any systematic disparities. Trademark and Brand Dependency. The Firm operates the GEM and EMSC strategies under the “Sophus Capital” brand, which is owned by Sophus Capital LLC and licensed to the Firm on a royaltyfree basis. If the relationship between the Firm and Sophus were to terminate, the Firm would be required to cease using the Sophus Capital name within a 90-day wind-down period. This could require rebranding of products, which could create short-term disruption for clients invested in Sophus Capital-branded strategies. Clients should be aware that the “Sophus Capital” brand is owned by an affiliated entity, not by the Firm. The Firm retains ownership of all client relationships, performance track records, and regulatory responsibilities regardless of the brand under which a strategy is marketed. CSLM Digital Acquisition Corp III (KOYN) — Potential Conflicts As described in Item 10, the Firm’s CEO and CCO serves as a non-officer director of CSLM Digital Acquisition Corp III, Ltd. (“CSLM Digital”), a publicly traded special purpose acquisition company (NASDAQ: KOYN), and previously served as a director of its sponsor. CIC, the Firm’s controlling member, holds a minority equity interest in the sponsor. If a CSLM Digital business combination or related transaction is identified and the Firm determines that participation by a client fund would be

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appropriate, a conflict of interest would arise because Mr. Cassel’s personal directorship interests and CIC’s sponsor equity interest could benefit from client participation in the transaction. The Firm addresses this potential conflict through the following controls. Any transaction in KOYN shares by the Firm’s principals or their affiliates requires pre-clearance by the Firm’s compliance function. Any decision by a client fund to participate in a CSLM Digital business combination, PIPE investment, forward purchase agreement, or similar transaction would require: (i) an independent investment analysis documenting the rationale for participation; (ii) review and approval by the Chief Compliance Officer (with a cross-approval mechanic where the CCO’s personal interest requires review by the Chief Investment Officer); and (iii) disclosure to affected investors as appropriate under the circumstances. The Firm maintains policies and procedures designed to ensure that any client participation in a CSLM Digital transaction is based solely on the investment merits and the best interests of the client. Personal Trading Consilium’s policy prohibits "access persons” (as defined below) from engaging in Personal Securities Transactions (as defined below) involving securities and financial instruments which the firm and any of its affiliates is recommending or trading or contemplates recommending to clients, and certain other securities and financial instruments. No access person can engage in Personal Securities Transactions involving any financial instruments which are:

Owned by a client. This includes all collective investment schemes and managed accounts. This ban also holds true for financial instruments where a credit report is being prepared. Actively contemplated for transactions on behalf of clients, even though no buy or sell orders have been placed. This restriction applies from the moment that an employee has been informed in any fashion that any advisory representative intends to purchase or sell a specific security for clients' accounts. This is a particularly sensitive area and one in which each employee must exercise caution to avoid actions which, to his or her knowledge, are in conflict or in competition with the interests of clients; Debt or equity securities in emerging markets, defined as a country outside the G-10;

The prohibition in this Section of the Code, however, does not extend to sovereign debt securities, shares of open-end investment companies (mutual funds) and Exchange Traded Funds (ETF’s). Unless short sales, options, and margin transactions involve financial instruments which fall within the above prohibitions, employees can engage in such transactions; however, such transactions are strongly discouraged. Any employee engaging in such transactions should recognize the danger of being "frozen" because of the general restrictions which apply to personal transactions as noted above. Any employee, who feels that the above prohibitions create a particular hardship for him or her in a particular case, should discuss the facts with the CCO. In specific cases of extreme hardship, an exception may be granted if the interests of the firm's clients permit.

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An “access person” is a supervised person who has access to nonpublic information regarding clients’ purchase or sale of securities, is involved in making securities recommendation to clients or who has access to such recommendation that are nonpublic. Note that under this last clause, even if an employee has no involvement in making recommendations, they can become an access person simply by learning of recommendations or decisions being made by Consilium in the course of their employment duties. For the purpose of our Code, "Personal Securities Transactions" include securities transactions for an employee’s own account or transactions for other accounts in which they have "beneficial interest," unless they have no direct or indirect influence or control over the account or the transaction. "Beneficial interest" means the opportunity, directly or indirectly, through any contract, arrangement, understanding, relationship or otherwise, to profit, or share in any profit derived from, a transaction in the subject securities. An access person is deemed to have a beneficial interest in securities owned by members of his or her immediate family. Common examples of beneficial interest include joint accounts, spousal accounts, UTMA accounts, partnerships, trusts and controlling interests in corporations. Any uncertainty as to whether an access person has a beneficial interest in a security should be brought to the attention of the CCO. "Immediate family" of an access person means any of the following persons who reside in the same household as the Access Person: child step-child grand-child parent step-parent

grandparent spouse sibling mother-in-law father-in-law

son-in-law daughter-in-law brother-in-law sister-in-law partner

Immediate family includes adoptive relationships and any other relationship (whether or not recognized by law) which the CCO determines could lead to the possible conflicts of interest, diversions of corporate opportunity, or appearances of impropriety which this Code is intended to prevent. If an employee has a substantial measure of influence or control over an account, but neither the employee nor his/her family have any direct or indirect beneficial interest (e.g., a trust for which they serve as trustee but are not a direct or indirect beneficiary), the rules relating to Personal Securities Transactions are not considered to be directly applicable. Therefore, the employee is not prohibited from engaging in Personal Securities Transactions with respect to such accounts, and reporting of such transactions (discussed below) is not required. In all transactions involving such accounts each employee should, however, conform to the spirit of these rules and avoid any activity which might appear to conflict with the firm’s investment advisory clients or with respect to the employee’s position as a supervised person of the firm. Pre-Clearance of Personal Securities Transactions Every Personal Securities Transaction by an access person must be pre-cleared via Comply prior to execution in accordance with the procedures set forth below.

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Any access person wishing to enter into a Personal Securities Transaction shall submit via Comply a pre-trade request to the CCO and/or the Compliance Associate. The request shall (a) state the name of the issuer and type of security, the proposed transaction date, the number of shares or the face amount of the security proposed to be purchased or sold, and (b) represent that to the knowledge and belief of the advisory representative, after due inquiry, the proposed Personal Securities Transaction is not prohibited under the Code. Such request shall be submitted via Comply and approval of the proposed transaction shall be provided by the CCO or the Compliance Associate via Comply, before execution of the proposed transaction. The CCO or the Compliance Associate is required to approve the transactions in Comply of other access persons. Reporting Requirements Rule 204A-1 under the Advisers Act requires access persons of investment advisers to report their personal securities transactions and holdings. Rule 17j-1 of the Investment Company Act was adopted in 1980 and has required that advisers to investment companies have procedures in place that require access persons to submit periodic reports regarding their personal securities holdings and transactions. Consilium has determined to adopt policies under its Code that mirror many of the requirements under 17j-1. Consilium requires that a record of all Personal Securities Transactions made by access persons are reported and monitored. To comply with this policy, Consilium has engaged Comply to capture and monitor all personal accounts declared by access personnel and members of his or her immediate family. Comply will receive downloads of confirmations from brokers, dealers or banks that execute any Personal Securities Transaction. Duplicate copies of statements will be requested from brokers unable to upload information in Comply. The Compliance Staff will monitor the alerts issued by Comply and will review the brokerage statements transactions in all personnel accounts and will discuss any apparent issues first with the access person. In addition access persons are required to present an Initial Statements of Holdings (upon first joining the company) and Annual Statements of holdings, as required by rule 17j-1. Additionally, every access person must file a Quarterly Certificate Form through Comply within 30 calendar days after the end of each calendar quarter. The Quarterly Certificate Form will require every access person to represent that she/he, and each member of his/her immediate family has arranged for the duplicate confirmations and monthly statements for each brokerage account required in the preceding paragraph to be sent to the Compliance staff. Quarterly Certificate Forms are distributed to all access persons. All access persons must file Quarterly Certification Forms even if there were no reportable transactions during the quarter. All Quarterly Certification Forms and periodic brokerage statements are saved and maintained in the Comply system for a period of not less than six years.

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Our portfolio managers ultimately decide on the most effective counterparties to be used based on these qualitative factors, which are carefully considered by the portfolio managers prior to the ultimate decision being made to direct a trade to a particular Directed Broker. Currently due to the volume of Consilium’s equity trades, the firm is limited in the amount of commissions that can be distributed. As a result, on various occasions, the firm’s choice of available Counter-Party/Directed Brokers to whom trades are directed can also be somewhat limited. Nevertheless, Consilium fully evaluates and chooses the best possible Counter-party/Directed Broker for any of its particular trades or groups of trades. Following the selection of a particular broker/counterparty, so as to insure continued best execution and full operational compliance, Consilium’s operations department continually monitors the selection and volumes of the Counter-Parties/Directed Brokers that we are trading with within each fund. Broker Volume reports are prepared and reviewed by the compliance department and the managing directors’ quarterly and qualitative assessments and future trade allocations are made based on those existing broker volumes and concentrations. B. Research and Other Soft Dollar Arrangements Consilium does not maintain any formal soft dollar arrangement and does not direct client brokerage in exchange for research or other services within the meaning of Section 28(e) of the Securities Exchange Act of 1934. Consilium does not operate within the Section 28(e) safe harbor. Consilium may receive research incidentally from brokers and counterparties in connection with the execution of client transactions. Such research may include written reports, analyst discussions, corporate access meetings, and market commentary. Because Consilium receives this research in connection with brokerage relationships, there is a potential conflict of interest in that Consilium may have an incentive to select a broker based in part on the value of research received rather than solely on execution quality or commission rates. Consilium addresses this conflict through its best execution process, which evaluates counterparties on a holistic basis including execution quality, market access, and the overall value of services provided. Research received incidentally from brokers is used to supplement Consilium’s own investment research and directly supports the investment decisionmaking process.

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Adjustments are made as necessary. Accounts managed under the Firm’s Global Emerging Markets and Emerging Markets Small Cap strategies will be reviewed by Michael Reynal, Chief Investment Officer — Global Emerging Markets, and Maria Lucia Freund, Portfolio Manager. Reviews will be conducted on an ongoing basis and will include analysis of portfolio holdings, performance, risk exposures, and compliance with applicable investment guidelines. Mr. Reynal and Ms. Freund are supervised persons of the Firm whose activities are subject to the oversight of the Chief Compliance Officer. The Firm’s Concentrated GEM SMA strategy, including sub-advisory mandates, is managed by Odile Santos Bagao, CFA, and Alex Ryshawy, Co-Portfolio Managers, under the supervision of Jonathan Binder, Chief Investment Officer, Frontier Emerging Markets. Ms. Santos Bagao and Mr. Ryshawy are supervised persons of the Firm whose activities are subject to the oversight of the Chief Investment Officer and the Chief Compliance Officer. Clients may receive the following reports:

Monthly: Letter to investors stating performance for the month Quarterly: Letter to investors stating performance for the quarter Annually: Letter to investors stating annual performance and investment outlook

Fund investors receive monthly and/or quarterly account statements listing the value of their investments. Fund investors also receive an annual K-1, if applicable and a copy of the annual audit for each Fund in which they are invested. Taxable accounts receive an annual tax summary. In addition, due to legal and/or regulatory constraints that must be followed by some of the firm’s investors and/or the specific needs and requests by certain investors, the firm may at its discretion agree to provide certain investors more frequent reports and/or certain other reports than those described above.

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The Adviser is subject to all applicable provisions of the Custody Rule, which includes either subjecting itself to a surprise annual examination by an independent public accountant (the Surprise Examination Approach) or, alternatively, engaging an independent public accountant registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board (PCAOB) to conduct an annual audit of the private fund and deliver audited financial statements to all limited partners or other beneficial owners within 120 days of the end of its fiscal year (the Annual Audit Approach). The Adviser is also deemed to have custody of the assets of CFP I Holdings, LLC, a non-pooled advisory client whose sole remaining asset is a cash reserve held at a qualified custodian (described in Items 4 and 5). The Adviser’s custody arises from the signatory authority of its Chief Compliance Officer, as a manager of CFP I Holdings, over that account. Because CFP I Holdings is not a pooled investment vehicle, the annual-audit option available under the Custody Rule for pooled vehicles is not applicable to this account; the Adviser, in consultation with outside counsel, is addressing the Custody Rule requirements applicable to a non-pooled account of this type. The Adviser maintains all securities and funds of its clients with a “qualified custodian.” Clients will receive no less than, on a quarterly basis, statements directly from the broker-dealer, bank, or other qualified custodian that holds and maintains such client’s assets. Consilium urges its clients to carefully review these statements and compare them to the account statements, if any, that may be provided by the Adviser. The Adviser’s statements can vary from the statements provided by the qualified custodian because of accounting procedures, reporting dates, or valuation methodologies used to value certain securities.

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It is also recognized that while (ii) above is true, no single portfolio is necessarily exactly the same as another. This applies both in the static sense of the overall standing risk-return profile that has been agreed with the client (this is not solely a quantitative function of the prospectus limits but is also influenced by what has been agreed orally and in writing on a qualitative basis) and in the dynamic sense such as cash inflows and outflows that are different for any one portfolio at any one particular time. The firm maintains and adheres to the investment parameters and compliance requirements for each fund. For certain of its fund products, Consilium has authority to determine the following without obtaining specific Client consent:

Securities to be bought or sold Amount of the securities to be bought or sold Broker or dealer to be used Commission rates paid

Investment discretion is typically defined in detail in the specific investment advisory contract with each particular client and the prospectus for each Fund.

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Consilium maintains (i) all proxy statements received regarding the client’s securities, (ii) an electronic “Proxy Voting” log and other records reflecting votes cast on behalf of the client (iii) copies of communications with the client disclosing a conflict of interest and the client’s response (iv) records of the client’s request for proxy voting information, and (v) any documents prepared or used by the adviser that were material to making a decision on how a vote should be cast. For certain clients and accounts, the right to vote Proxy’s is reserved solely for the client. Consilium is typically provided with details of such proxy votes upon request. Consilium will maintain copies of all proxy information received and the Compliance Associate/CCO will review the log on a monthly basis to ensure that any and all proxies are voted in accordance with these policies and procedures. Clients may obtain a copy of Consilium’s voting policies and procedures upon request to Victor Maldanado at Compliance@consimllc.com.